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    <title>2025 (12) TMI 1751 - ITAT DELHI</title>
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    <description>Additions under s. 68 for alleged commission receipt were unsustainable because the AO identified no incriminating material warranting s. 68 invocation and the receipt was from an Indian payer in India, making foreign remittance formalities irrelevant; deletion by CIT(A) was upheld and the Revenue&#039;s ground was dismissed. Addition under s. 68 for investment in a foreign joint venture failed as evidence showed the investment was made in an earlier FY and was reflected as investment at cost; the addition could not be taxed in the relevant year and was deleted. Ad hoc 10% disallowance of domestic/foreign travel was invalid for want of specific defects and the records showed no cash payments breaching stated limits; deletion was upheld. Rent paid to a director was allowable since genuineness was not disputed and the recipient offered the rent to tax; disallowance was deleted. Salary disallowance was unwarranted as ledger, bank statements, and statutory forms substantiated payment; deletion was upheld.</description>
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    <pubDate>Fri, 24 Oct 2025 00:00:00 +0530</pubDate>
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      <link>https://www.taxtmi.com/caselaws?id=784211</link>
      <description>Additions under s. 68 for alleged commission receipt were unsustainable because the AO identified no incriminating material warranting s. 68 invocation and the receipt was from an Indian payer in India, making foreign remittance formalities irrelevant; deletion by CIT(A) was upheld and the Revenue&#039;s ground was dismissed. Addition under s. 68 for investment in a foreign joint venture failed as evidence showed the investment was made in an earlier FY and was reflected as investment at cost; the addition could not be taxed in the relevant year and was deleted. Ad hoc 10% disallowance of domestic/foreign travel was invalid for want of specific defects and the records showed no cash payments breaching stated limits; deletion was upheld. Rent paid to a director was allowable since genuineness was not disputed and the recipient offered the rent to tax; disallowance was deleted. Salary disallowance was unwarranted as ledger, bank statements, and statutory forms substantiated payment; deletion was upheld.</description>
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      <pubDate>Fri, 24 Oct 2025 00:00:00 +0530</pubDate>
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