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    <title>2026 (1) TMI 978 - ITAT MUMBAI</title>
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    <description>Disallowance under analysis concerned treating purchases from five vendors as non-genuine and denying deduction under the principle that expenditure must be wholly and exclusively for business; the factual record did not establish accommodation entries or bogus transactions, and the purchases were shown to be by the operating subsidiary for ongoing projects, with subsequent acceptance of similar transactions in later years, so the part disallowance of 12.5% adopted to plug leakage lacked evidentiary basis and was deleted, resulting in dismissal of Revenues challenge to the CIT(A)s partial deletion and full restoration of the business expenditure.</description>
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      <link>https://www.taxtmi.com/caselaws?id=785222</link>
      <description>Disallowance under analysis concerned treating purchases from five vendors as non-genuine and denying deduction under the principle that expenditure must be wholly and exclusively for business; the factual record did not establish accommodation entries or bogus transactions, and the purchases were shown to be by the operating subsidiary for ongoing projects, with subsequent acceptance of similar transactions in later years, so the part disallowance of 12.5% adopted to plug leakage lacked evidentiary basis and was deleted, resulting in dismissal of Revenues challenge to the CIT(A)s partial deletion and full restoration of the business expenditure.</description>
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