Section 40A(2)(b): No Disallowance for Directors' Pay Raise as No Tax Evasion or Excessive Salary Proven.

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....Addition u/s 40A (2) (b) - exponential increase in the Directors’ remuneration - CBDT Circular clearly states that no disallowance is to be made u/s 40A (2) in respect of payments made to relatives and sister concerns where there is no attempt to evade tax. Clearly no case of evasion of tax can be made out in the present appeal. This circular is binding on the Department and since no motive to evade tax is established and further since the AO has not pointed out any comparables to demonstrate that the salary paid to Directors was excessive, - AT....