https://www.taxtmi.com/caselaws?id=774453 ITAT Chennai allowed the assessee trust's appeal regarding disallowance of software development and business consultancy charges paid to TFMSS. The tribunal found software services were genuine and paid at fair market value, criticizing lower authorities for ignoring crucial evidence including sworn statements and email exchanges while relying on unreliable witnesses. For business consultancy charges, ITAT noted the AO mechanically disallowed claims without proper examination, and CIT(A) confirmed disallowance based on hypothesis rather than evidence. The tribunal emphasized decisions must be supported by appropriate evidence, not personal assumptions. en-us Mon, 07 Jul 2025 00:00:00 +0530 Tue, 08 Jul 2025 17:49:29 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=774453 ITAT Chennai allowed the assessee trust's appeal regarding disallowance of software development and business consultancy charges paid to TFMSS. The tribunal found software services were genuine and paid at fair market value, criticizing lower authorities for ignoring crucial evidence including sworn statements and email exchanges while relying on unreliable witnesses. For business consultancy charges, ITAT noted the AO mechanically disallowed claims without proper examination, and CIT(A) confirmed disallowance based on hypothesis rather than evidence. The tribunal emphasized decisions must be supported by appropriate evidence, not personal assumptions. Case-Laws Income Tax Mon, 07 Jul 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=774453