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    <title>2026 (1) TMI 1584 - ITAT DELHI</title>
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    <description>Commission expenditure cannot be disallowed merely because recipients were not personally produced, where payments were made through banking channels and TDS was deducted. The Tribunal noted that the Assessing Officer did not use section 131 summons powers to secure attendance, and held that non-disclosure by the recipients by itself did not render the assessee&#039;s claim bogus. It found the disallowance rested mainly on conjecture and human probability rather than cogent evidence, so the commission expense was allowed. Interest under sections 234A and 234B was treated as consequential and did not call for separate substantive relief.</description>
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    <pubDate>Fri, 16 Jan 2026 00:00:00 +0530</pubDate>
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      <title>2026 (1) TMI 1584 - ITAT DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=467608</link>
      <description>Commission expenditure cannot be disallowed merely because recipients were not personally produced, where payments were made through banking channels and TDS was deducted. The Tribunal noted that the Assessing Officer did not use section 131 summons powers to secure attendance, and held that non-disclosure by the recipients by itself did not render the assessee&#039;s claim bogus. It found the disallowance rested mainly on conjecture and human probability rather than cogent evidence, so the commission expense was allowed. Interest under sections 234A and 234B was treated as consequential and did not call for separate substantive relief.</description>
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      <pubDate>Fri, 16 Jan 2026 00:00:00 +0530</pubDate>
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