https://www.taxtmi.com/caselaws?id=795591 Ad hoc disallowance of transportation-related expenditure after rejection of books under section 145(3) requires an evidentiary and rational basis; rejection alone does not justify estimation by guesswork. Banking-channel reimbursements to local agents, supported by ledgers, reimbursement statements, sample records and bank statements, were not shown to be bogus, inflated, fictitious or returned to the assessee. The business model, actual transportation operations and net-profit ratio also did not support an inference of inflated expenditure. The notes state that disallowance rates lacking comparables, past history or other rational support are unsustainable, and the Revenue cannot replace bona fide commercial arrangements with its own judgment without evidence of sham or lack of business purpose. en-us Wed, 27 May 2026 00:00:00 +0530 Fri, 24 Jul 2026 08:36:16 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=795591 Ad hoc disallowance of transportation-related expenditure after rejection of books under section 145(3) requires an evidentiary and rational basis; rejection alone does not justify estimation by guesswork. Banking-channel reimbursements to local agents, supported by ledgers, reimbursement statements, sample records and bank statements, were not shown to be bogus, inflated, fictitious or returned to the assessee. The business model, actual transportation operations and net-profit ratio also did not support an inference of inflated expenditure. The notes state that disallowance rates lacking comparables, past history or other rational support are unsustainable, and the Revenue cannot replace bona fide commercial arrangements with its own judgment without evidence of sham or lack of business purpose. Case-Laws Income Tax Wed, 27 May 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=795591