https://www.taxtmi.com/highlights?id=105143 Form No. 26AS is relevant evidence of receipts against the deductee's PAN but is not conclusive of income accrual after transfer of the underlying business. Where contemporaneous agreements, reconciliations, non-claim of TDS credit and successor-entity confirmation support the transfer, verification should cover the successor's accounting, assessment of receipts, invoices and TDS credit to prevent duplicate taxation. Advertising expenditure incurred through a holding company may qualify as business expenditure where invoices and published advertisements establish actual services and a direct business nexus. Related-party status, abbreviated invoice particulars, differing advertising rates, or absence of immediate revenue growth do not alone justify full disallowance without identifying an excessive component. en-us Mon, 19 Oct 2026 07:01:13 +0530 Mon, 19 Oct 2026 07:01:14 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=105143 Form No. 26AS is relevant evidence of receipts against the deductee's PAN but is not conclusive of income accrual after transfer of the underlying business. Where contemporaneous agreements, reconciliations, non-claim of TDS credit and successor-entity confirmation support the transfer, verification should cover the successor's accounting, assessment of receipts, invoices and TDS credit to prevent duplicate taxation. Advertising expenditure incurred through a holding company may qualify as business expenditure where invoices and published advertisements establish actual services and a direct business nexus. Related-party status, abbreviated invoice particulars, differing advertising rates, or absence of immediate revenue growth do not alone justify full disallowance without identifying an excessive component. Highlights Income Tax Mon, 19 Oct 2026 07:01:13 +0530 https://www.taxtmi.com/highlights?id=105143