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    <title>2026 (6) TMI 347 - ITAT DELHI</title>
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    <description>Additional evidence under Rule 46A may be admitted where the assessee shows sufficient cause for non-production before the Assessing Officer and the material is remitted for rebuttal; on those facts, the admission was upheld. An ad hoc, percentage-based disallowance of commission expenditure is not sustainable without concrete material, and relief was confined to the unsupported portion only. A mismatch between Form 26AS and the books can be partly explained through reconciliation, invoices, debit notes, service tax, and incorrect TDS reporting by deductors; the explained addition was deleted and only the unsubstantiated balance was retained. The appellate relief in favour of the assessee was therefore sustained.</description>
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    <pubDate>Mon, 18 May 2026 00:00:00 +0530</pubDate>
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      <link>https://www.taxtmi.com/caselaws?id=792966</link>
      <description>Additional evidence under Rule 46A may be admitted where the assessee shows sufficient cause for non-production before the Assessing Officer and the material is remitted for rebuttal; on those facts, the admission was upheld. An ad hoc, percentage-based disallowance of commission expenditure is not sustainable without concrete material, and relief was confined to the unsupported portion only. A mismatch between Form 26AS and the books can be partly explained through reconciliation, invoices, debit notes, service tax, and incorrect TDS reporting by deductors; the explained addition was deleted and only the unsubstantiated balance was retained. The appellate relief in favour of the assessee was therefore sustained.</description>
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