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    <title>2026 (3) TMI 63 - ITAT SURAT</title>
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    <description>ITAT examined three revenue additions and applied the principles of expense genuineness, withholding liability and proof of receipts. On salary disallowance the tribunal found the assessee produced employee-wise breakdown and supporting records and, absent any AO evidence of non genuineness or diversion, deleted the addition. On alleged failure to deduct tax the tribunal held characterization as reimbursements and lack of AO proof that payments attracted withholding meant Section 40(a)(i)-type disallowance could not be sustained and deleted the addition. On alleged undisclosed receipts the tribunal accepted supplied receipts and TDS particulars, found no contrary evidence, and deleted that addition.</description>
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      <link>https://www.taxtmi.com/caselaws?id=787308</link>
      <description>ITAT examined three revenue additions and applied the principles of expense genuineness, withholding liability and proof of receipts. On salary disallowance the tribunal found the assessee produced employee-wise breakdown and supporting records and, absent any AO evidence of non genuineness or diversion, deleted the addition. On alleged failure to deduct tax the tribunal held characterization as reimbursements and lack of AO proof that payments attracted withholding meant Section 40(a)(i)-type disallowance could not be sustained and deleted the addition. On alleged undisclosed receipts the tribunal accepted supplied receipts and TDS particulars, found no contrary evidence, and deleted that addition.</description>
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