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Taxpayer's Expenditure Disallowance u/s 40A(2) Reduced to 10% Due to Lack of Comparable Instances.

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....Disallowance of expenditure u/s 40A(2) - In the absence of any comparable instance of rendering the similar services/supply of goods, it would not be permissible to disallow the expenditure u/s 40A(2). As the needful was not done by the Lower Authorities and on adhoc/estimate basis, the CIT Appeal has restricted the disallowance upto 20% - we restrict the disallowance upto 10% of the expenditure claimed by the Assessee - AT....