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    <title>2025 (3) TMI 1369 - ITAT HYDERABAD</title>
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    <description>Purchase additions based solely on an untested third-party statement could not be sustained where the assessee produced purchase bills, transport documents and bank records, and no independent enquiry was made or cross-examination provided; the alleged bogus purchase addition was therefore deleted. Bonus paid to director-employees was also not disallowable under section 36(1)(ii) because it was authorised by board resolution, linked to services rendered, separately taxed and not shown to be a disguised dividend. The commentary states that contractual remuneration for services is distinct from dividend or profit distribution, and that the Revenue failed to establish any tax-avoidance device.</description>
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      <link>https://www.taxtmi.com/caselaws?id=767983</link>
      <description>Purchase additions based solely on an untested third-party statement could not be sustained where the assessee produced purchase bills, transport documents and bank records, and no independent enquiry was made or cross-examination provided; the alleged bogus purchase addition was therefore deleted. Bonus paid to director-employees was also not disallowable under section 36(1)(ii) because it was authorised by board resolution, linked to services rendered, separately taxed and not shown to be a disguised dividend. The commentary states that contractual remuneration for services is distinct from dividend or profit distribution, and that the Revenue failed to establish any tax-avoidance device.</description>
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