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    <title>2026 (7) TMI 1477 - ITAT BANGALORE</title>
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    <description>Ad hoc disallowance of transportation-related expenses after rejection of books under section 145(3) requires a rational evidentiary basis and cannot rest on guesswork. Payments reimbursed to local agents through banking channels were supported by ledgers, reimbursement statements, sample records and bank statements, while the agents, fund movement and underlying transportation activity were undisputed. No material indicated bogus, inflated, fictitious or returned payments. Disallowance rates lacked support from comparable cases, past results or other objective criteria, and the business model and net-profit ratio did not indicate inflated expenditure. The disallowance of enroute, sundry, travelling and transportation expenses was directed to be deleted.</description>
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