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    <title>2026 (7) TMI 601 - ITAT MUMBAI</title>
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    <description>Expenditure recorded in audited books and paid through banking channels, supported by agreements, invoices, Form 15CA/15CB and TDS, cannot be treated as unexplained expenditure under section 69C merely because the Revenue doubts commercial expediency or actual service rendition; the addition was deleted. CSR expenditure already suo motu disallowed in the computation of income under section 37 could not be added again, as that would create impermissible double disallowance; the further addition was also deleted. The ratio is that section 69C applies only where the source of expenditure is unexplained, and a sum already disallowed by the assessee cannot be disallowed twice.</description>
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      <title>2026 (7) TMI 601 - ITAT MUMBAI</title>
      <link>https://www.taxtmi.com/caselaws?id=794715</link>
      <description>Expenditure recorded in audited books and paid through banking channels, supported by agreements, invoices, Form 15CA/15CB and TDS, cannot be treated as unexplained expenditure under section 69C merely because the Revenue doubts commercial expediency or actual service rendition; the addition was deleted. CSR expenditure already suo motu disallowed in the computation of income under section 37 could not be added again, as that would create impermissible double disallowance; the further addition was also deleted. The ratio is that section 69C applies only where the source of expenditure is unexplained, and a sum already disallowed by the assessee cannot be disallowed twice.</description>
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      <pubDate>Fri, 22 May 2026 00:00:00 +0530</pubDate>
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