Disallowance of Payments to Related Parties Overturned: CBDT Circular & Court Rulings Uphold Equal Tax Treatment.

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....Disallowance u/s 40A(2)(b) for excessive payments to related concerns was deleted based on CBDT Circular 6-P and case laws of Delhi HC in Sigma Research and Bombay HC in Indo Saudi Services, holding that disallowance is unsustainable when payer and payee are taxed at same rate. ITAT ruled in favour of the assessee.....