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    <title>2026 (1) TMI 194 - ITAT DELHI</title>
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    <description>Disallowance under s.40A(2)(b) for purchases from a related concern was held unsustainable because the AO failed to produce comparables or other material to show that the price paid was excessive or unreasonable; since the assessee bought goods at the same discounted price at which the related concern had acquired them, the disallowance was deleted. On addition for cash deposits claimed as accumulated cash gifts, the assessee could not fully substantiate the source; the CIT(A)&#039;s estimation granting 50% relief on grounds of reasonableness was upheld and the balance 50% was sustained as unexplained. On denial of cost of improvement, additional evidence and bank-trail payments supported genuineness and sources, and the CIT(A)&#039;s deletion of the addition was affirmed.</description>
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      <link>https://www.taxtmi.com/caselaws?id=784438</link>
      <description>Disallowance under s.40A(2)(b) for purchases from a related concern was held unsustainable because the AO failed to produce comparables or other material to show that the price paid was excessive or unreasonable; since the assessee bought goods at the same discounted price at which the related concern had acquired them, the disallowance was deleted. On addition for cash deposits claimed as accumulated cash gifts, the assessee could not fully substantiate the source; the CIT(A)&#039;s estimation granting 50% relief on grounds of reasonableness was upheld and the balance 50% was sustained as unexplained. On denial of cost of improvement, additional evidence and bank-trail payments supported genuineness and sources, and the CIT(A)&#039;s deletion of the addition was affirmed.</description>
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