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    <title>2025 (8) TMI 1275 - ITAT MUMBAI</title>
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    <description>ITAT (MUMBAI) allowed the appeal and deleted additions under section 40A(2). The tribunal found payments of interest at 15% reasonable given similar rates in adjacent years and absence of a benchmark to treat them as excessive. Job charges and purchases from related parties were not disputed on record, so disallowance was unjustified. Salary paid to an employee was comparable to subsequent years and not excessive. The AO&#039;s disallowance-based solely on non-response to s.133(6) notices-was held improper where no adverse material or examination of services was placed on record.</description>
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      <link>https://www.taxtmi.com/caselaws?id=777087</link>
      <description>ITAT (MUMBAI) allowed the appeal and deleted additions under section 40A(2). The tribunal found payments of interest at 15% reasonable given similar rates in adjacent years and absence of a benchmark to treat them as excessive. Job charges and purchases from related parties were not disputed on record, so disallowance was unjustified. Salary paid to an employee was comparable to subsequent years and not excessive. The AO&#039;s disallowance-based solely on non-response to s.133(6) notices-was held improper where no adverse material or examination of services was placed on record.</description>
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