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    <title>2025 (12) TMI 1424 - ITAT DELHI</title>
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    <description>Ad-hoc disallowance of 50% of miscellaneous expenditure was held unsustainable because the AO accepted the nature of expenditure (meetings/AGM) and the assessee produced bills, invoices, vouchers, and payment proof; in absence of specific defects, ad-hoc disallowance was unwarranted, resulting in deletion of the disallowance. Mismatch between sales turnover in the audit report and ITR was plausibly explained as arising from rounding differences and partial reconciliation already accepted by the AO; the residual addition was therefore directed to be deleted. Disallowance under s. 40(a)(i) was upheld because the assessee failed to substantiate the alleged tax-audit reporting error with any rectification/clarification. Transfer pricing/AMP issues were treated as settled under an APA, leaving no surviving dispute.</description>
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    <pubDate>Fri, 28 Nov 2025 00:00:00 +0530</pubDate>
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      <link>https://www.taxtmi.com/caselaws?id=783884</link>
      <description>Ad-hoc disallowance of 50% of miscellaneous expenditure was held unsustainable because the AO accepted the nature of expenditure (meetings/AGM) and the assessee produced bills, invoices, vouchers, and payment proof; in absence of specific defects, ad-hoc disallowance was unwarranted, resulting in deletion of the disallowance. Mismatch between sales turnover in the audit report and ITR was plausibly explained as arising from rounding differences and partial reconciliation already accepted by the AO; the residual addition was therefore directed to be deleted. Disallowance under s. 40(a)(i) was upheld because the assessee failed to substantiate the alleged tax-audit reporting error with any rectification/clarification. Transfer pricing/AMP issues were treated as settled under an APA, leaving no surviving dispute.</description>
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