AO Cannot Disallow Deduction Without Proving Excessive Expenditure u/s 40A(2)(b) of Income Tax Act.

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....Disallowance u/s 40A(2)(b) - for the purpose of disallowing a deduction, AO has to form an opinion not only that the expenditure is excessive or unreasonable, but that such expenditure is excessive or unreasonable having regard to the fair market value of the goods, services or facilities for which the payment is made - that is not done - no addition - HC....