https://www.taxtmi.com/caselaws?id=798751 Commission expenditure under section 37(1) was supported by recipient-wise details, PAN particulars, TDS records, Form 26Q and payment evidence, discharging the assessee's initial burden of proving business expenditure. A referral-based business model supported the commercial basis for commission payments. No recipient or payment was specifically identified as non-genuine, excessive or unrelated to business. An estimated commission benchmark without comparable cases, market data or other cogent material could not support an ad hoc disallowance, particularly where the commission ratio broadly aligned with preceding years. The disallowance was therefore deleted. en-us Tue, 08 Sep 2026 00:00:00 +0530 Fri, 11 Sep 2026 08:13:48 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=798751 Commission expenditure under section 37(1) was supported by recipient-wise details, PAN particulars, TDS records, Form 26Q and payment evidence, discharging the assessee's initial burden of proving business expenditure. A referral-based business model supported the commercial basis for commission payments. No recipient or payment was specifically identified as non-genuine, excessive or unrelated to business. An estimated commission benchmark without comparable cases, market data or other cogent material could not support an ad hoc disallowance, particularly where the commission ratio broadly aligned with preceding years. The disallowance was therefore deleted. Case-Laws Income Tax Tue, 08 Sep 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=798751