https://www.taxtmi.com/caselaws?id=762529 ITAT Delhi allowed the appeal, reversing CIT(A)'s ad-hoc disallowance of payments to related parties. The tribunal held that since both appellant and payees were in the same tax bracket (30%), there was no revenue loss. Relying on Orange Associates precedent, payments between parties in identical tax brackets cannot constitute tax evasion. The tribunal rejected AO's arbitrary 50% disallowance citing DLF Hilton Hotels judgment, noting absence of findings regarding non-genuine expenses or rejected books. Additionally, disallowance under section 36(1)(iii) was reversed following Reliance Industries precedent regarding interest-free funds sufficiency for investments. en-us Fri, 29 Nov 2024 00:00:00 +0530 Mon, 02 Dec 2024 10:57:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=762529 ITAT Delhi allowed the appeal, reversing CIT(A)'s ad-hoc disallowance of payments to related parties. The tribunal held that since both appellant and payees were in the same tax bracket (30%), there was no revenue loss. Relying on Orange Associates precedent, payments between parties in identical tax brackets cannot constitute tax evasion. The tribunal rejected AO's arbitrary 50% disallowance citing DLF Hilton Hotels judgment, noting absence of findings regarding non-genuine expenses or rejected books. Additionally, disallowance under section 36(1)(iii) was reversed following Reliance Industries precedent regarding interest-free funds sufficiency for investments. Case-Laws Income Tax Fri, 29 Nov 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=762529