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    <title>2025 (3) TMI 1680 - ITAT RAJKOT</title>
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    <description>Documentary support, TDS compliance and banking-channel payments justified deletion of the disallowance of subcontract expenses, while the partner&#039;s salary issue required recomputation of firm profits and consequent redetermination of allowable remuneration under the partnership deed. Ad hoc disallowances of motor car expenses and direct expenses were found excessive on the facts and were restricted to 10% each for want of material proving complete unverifiability. Non-deduction of tax on chartered accountant&#039;s fee attracted section 40(a)(ia), and that disallowance was sustained. The stated ratio is that ad hoc disallowance must rest on material showing non-genuine or unverifiable expenditure, and partner remuneration must follow the finally determined business profit.</description>
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