https://www.taxtmi.com/caselaws?id=791265 Foreign agency commission was disallowed as business expenditure because the assessee failed to prove the genuineness of the services, the identity and role of the recipient, and the business nexus of the payments; the record also showed adverse third-party material, missing primary evidence, and inconsistencies on payment and foreign remittance compliance. However, where the corresponding liability had already been written back and offered to tax in a later year, the same amount could not be taxed again in the impugned years absent a statutory basis for duplication. The substantive disallowance therefore remained, but relief was limited to preventing double taxation of the written-back amount. en-us Wed, 06 May 2026 00:00:00 +0530 Fri, 08 May 2026 07:30:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=791265 Foreign agency commission was disallowed as business expenditure because the assessee failed to prove the genuineness of the services, the identity and role of the recipient, and the business nexus of the payments; the record also showed adverse third-party material, missing primary evidence, and inconsistencies on payment and foreign remittance compliance. However, where the corresponding liability had already been written back and offered to tax in a later year, the same amount could not be taxed again in the impugned years absent a statutory basis for duplication. The substantive disallowance therefore remained, but relief was limited to preventing double taxation of the written-back amount. Case-Laws Income Tax Wed, 06 May 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=791265