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    <title>2025 (7) TMI 1486 - ITAT BANGALORE</title>
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    <description>The ITAT Bangalore partially allowed the appeal, restricting disallowance of labour expenses to 10% of total cash withdrawals (Rs.1.67 crore) due to lack of conclusive proof of full misuse. Disallowance of subcontractor payments was deleted for lack of legally acceptable evidence and proper documentation. Purchases disallowance (Rs.17.84 crore) was also deleted, as the assessee provided substantial evidence and the revenue failed to prove transactions were bogus. Regarding payments to alleged bogus subcontractors, the tribunal upheld a 10% ad hoc disallowance due to inconsistencies in the assessee&#039;s defense and lack of clarity in AO&#039;s quantification, while noting possible accommodation entries. Overall, the tribunal balanced interests by sustaining limited disallowances and deleting unsupported additions.</description>
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      <title>2025 (7) TMI 1486 - ITAT BANGALORE</title>
      <link>https://www.taxtmi.com/caselaws?id=775418</link>
      <description>The ITAT Bangalore partially allowed the appeal, restricting disallowance of labour expenses to 10% of total cash withdrawals (Rs.1.67 crore) due to lack of conclusive proof of full misuse. Disallowance of subcontractor payments was deleted for lack of legally acceptable evidence and proper documentation. Purchases disallowance (Rs.17.84 crore) was also deleted, as the assessee provided substantial evidence and the revenue failed to prove transactions were bogus. Regarding payments to alleged bogus subcontractors, the tribunal upheld a 10% ad hoc disallowance due to inconsistencies in the assessee&#039;s defense and lack of clarity in AO&#039;s quantification, while noting possible accommodation entries. Overall, the tribunal balanced interests by sustaining limited disallowances and deleting unsupported additions.</description>
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      <pubDate>Tue, 03 Jun 2025 00:00:00 +0530</pubDate>
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