https://www.taxtmi.com/caselaws?id=764030 ITAT Delhi held that disallowance under section 40A(2)(b) for excessive payments to related concerns is not sustainable when both payer and payee are assessed at the same tax rate. The tribunal relied on CBDT Circular 6-P dated 6.7.1968, which clarifies that the provision aims to prevent tax evasion through excessive payments to associates. Following precedents from Delhi HC and Bombay HC, the tribunal deleted the disallowance, ruling in favor of the assessee. en-us Tue, 31 Dec 2024 00:00:00 +0530 Wed, 01 Jan 2025 23:40:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=764030 ITAT Delhi held that disallowance under section 40A(2)(b) for excessive payments to related concerns is not sustainable when both payer and payee are assessed at the same tax rate. The tribunal relied on CBDT Circular 6-P dated 6.7.1968, which clarifies that the provision aims to prevent tax evasion through excessive payments to associates. Following precedents from Delhi HC and Bombay HC, the tribunal deleted the disallowance, ruling in favor of the assessee. Case-Laws Income Tax Tue, 31 Dec 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=764030