https://www.taxtmi.com/caselaws?id=774362 ITAT Mumbai held that additions/disallowances made under Section 153A assessment were unsustainable as they were not based on incriminating material found during search operations, which is essential for unabated assessments. The tribunal deleted disallowances under Section 40A(2)(b) for excess payments to related parties, finding the AO's comparison methodology unscientific and that actual hire charges paid were lower than market rates. Sales promotion expenses disallowance was deleted as assessee's suo-motu 50% disallowance was reasonable. The 25% ad-hoc disallowance of victualling expenses was also deleted, finding adequate supporting documentation was provided without specific defects being identified by the AO. en-us Mon, 30 Jun 2025 00:00:00 +0530 Tue, 08 Jul 2025 08:36:16 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=774362 ITAT Mumbai held that additions/disallowances made under Section 153A assessment were unsustainable as they were not based on incriminating material found during search operations, which is essential for unabated assessments. The tribunal deleted disallowances under Section 40A(2)(b) for excess payments to related parties, finding the AO's comparison methodology unscientific and that actual hire charges paid were lower than market rates. Sales promotion expenses disallowance was deleted as assessee's suo-motu 50% disallowance was reasonable. The 25% ad-hoc disallowance of victualling expenses was also deleted, finding adequate supporting documentation was provided without specific defects being identified by the AO. Case-Laws Income Tax Mon, 30 Jun 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=774362