https://www.taxtmi.com/caselaws?id=775092 The ITAT Delhi allowed the assessee's appeal on multiple grounds. Regarding freight charges disallowance, the Tribunal held that expenses cannot be disallowed based on mere suspicion without proper inquiry into business nature and financials, citing precedent that suspicion cannot substitute proof. For disallowance under section 14A, the Tribunal found the AO failed to record proper satisfaction before making additions, despite the assessee's voluntary disallowance under protest. Concerning Form 26AS mismatch of Rs. 26,910, the addition was deleted as the amount was already declared in the subsequent assessment year, preventing double taxation. The issue of carry forward losses was remitted back to the AO for verification of legal compliance regarding merged company provisions. Finally, interest expenditure disallowance was rejected since the assessee had borrowed against inventories and receivables, demonstrating legitimate business purpose for the loans and associated interest costs. en-us Mon, 30 Jun 2025 00:00:00 +0530 Sat, 19 Jul 2025 08:25:39 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=775092 The ITAT Delhi allowed the assessee's appeal on multiple grounds. Regarding freight charges disallowance, the Tribunal held that expenses cannot be disallowed based on mere suspicion without proper inquiry into business nature and financials, citing precedent that suspicion cannot substitute proof. For disallowance under section 14A, the Tribunal found the AO failed to record proper satisfaction before making additions, despite the assessee's voluntary disallowance under protest. Concerning Form 26AS mismatch of Rs. 26,910, the addition was deleted as the amount was already declared in the subsequent assessment year, preventing double taxation. The issue of carry forward losses was remitted back to the AO for verification of legal compliance regarding merged company provisions. Finally, interest expenditure disallowance was rejected since the assessee had borrowed against inventories and receivables, demonstrating legitimate business purpose for the loans and associated interest costs. Case-Laws Income Tax Mon, 30 Jun 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=775092