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    <title>2025 (12) TMI 1427 - ITAT DELHI</title>
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    <description>Whether estimated disallowance of business expenditure (advertisement, truck freight, crossing charges to branches, and printing/stationery) was justified and, if so, to what extent, was the dominant issue. The ITAT held that in a transport business commercial expediency of such expenses cannot be ruled out, but it is equally settled that claimed expenditure must be supported by demonstrative evidence; the taxpayer&#039;s evidentiary support was deficient, permitting an inference that the expenses were not fully vouched or justified. Hence, an estimated disallowance could not be rejected, though the AO&#039;s estimation was excessive. The ITAT directed the AO to restrict the disallowance to 50% of the amounts disallowed (for each head), partly allowing the Revenue&#039;s appeal.</description>
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      <title>2025 (12) TMI 1427 - ITAT DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=783887</link>
      <description>Whether estimated disallowance of business expenditure (advertisement, truck freight, crossing charges to branches, and printing/stationery) was justified and, if so, to what extent, was the dominant issue. The ITAT held that in a transport business commercial expediency of such expenses cannot be ruled out, but it is equally settled that claimed expenditure must be supported by demonstrative evidence; the taxpayer&#039;s evidentiary support was deficient, permitting an inference that the expenses were not fully vouched or justified. Hence, an estimated disallowance could not be rejected, though the AO&#039;s estimation was excessive. The ITAT directed the AO to restrict the disallowance to 50% of the amounts disallowed (for each head), partly allowing the Revenue&#039;s appeal.</description>
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