https://www.taxtmi.com/caselaws?id=462933 The ITAT RAIPUR held that disallowances made on an adhoc, presumptive basis without rejecting the assessee's books under section 145(3) were arbitrary and unsustainable. Estimated additions on unexplained expenditure (s. 69C), unexplained investments (s. 69), and other expenses lacked any plausible basis and were deleted. The tribunal noted similar expenses were accepted in the preceding year, reinforcing the absence of justification for disallowances. However, the disallowance under section 40(a)(ia) for non-deduction of TDS on interest payments was upheld due to the assessee's failure to produce the required accountant's certificate. The appeal was partly allowed, deleting the estimated disallowances but sustaining the TDS-related disallowance. en-us Fri, 17 May 2024 00:00:00 +0530 Fri, 25 Jul 2025 13:53:58 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=462933 The ITAT RAIPUR held that disallowances made on an adhoc, presumptive basis without rejecting the assessee's books under section 145(3) were arbitrary and unsustainable. Estimated additions on unexplained expenditure (s. 69C), unexplained investments (s. 69), and other expenses lacked any plausible basis and were deleted. The tribunal noted similar expenses were accepted in the preceding year, reinforcing the absence of justification for disallowances. However, the disallowance under section 40(a)(ia) for non-deduction of TDS on interest payments was upheld due to the assessee's failure to produce the required accountant's certificate. The appeal was partly allowed, deleting the estimated disallowances but sustaining the TDS-related disallowance. Case-Laws Income Tax Fri, 17 May 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=462933