https://www.taxtmi.com/caselaws?id=784431 Disallowance of consultancy-fee expenditure was in issue, specifically whether it could rest solely on perceived documentary inconsistencies and general third-party/survey inputs. The Tribunal held that once the taxpayer produced primary evidence (agreement, invoices, bank payments, and TDS), the onus shifted to the AO to rebut it with cogent material. As no incriminating survey material was confronted, no independent corroboration was brought on record, and there was no finding of bogus invoices, non-rendering of services, cash kickbacks, or excessiveness/unreasonableness of the expenditure, mere suspicion could not substitute proof. Extraneous references in the assessment to unrelated penny-stock issues further undermined the addition. The CIT(A)'s deletion of the addition was upheld and the appeal was dismissed. en-us Tue, 30 Dec 2025 00:00:00 +0530 Mon, 05 Jan 2026 08:04:08 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=784431 Disallowance of consultancy-fee expenditure was in issue, specifically whether it could rest solely on perceived documentary inconsistencies and general third-party/survey inputs. The Tribunal held that once the taxpayer produced primary evidence (agreement, invoices, bank payments, and TDS), the onus shifted to the AO to rebut it with cogent material. As no incriminating survey material was confronted, no independent corroboration was brought on record, and there was no finding of bogus invoices, non-rendering of services, cash kickbacks, or excessiveness/unreasonableness of the expenditure, mere suspicion could not substitute proof. Extraneous references in the assessment to unrelated penny-stock issues further undermined the addition. The CIT(A)'s deletion of the addition was upheld and the appeal was dismissed. Case-Laws Income Tax Tue, 30 Dec 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=784431