Revenue fails to prove excessive payments under Section 40(A)(2)(b) without comparable market evidence

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....ITAT allowed appellant's appeal regarding disallowance under section 40(A)(2)(b) for consultancy and development charges. The Revenue failed to discharge its burden of proving payments were excessive or unreasonable by not providing comparable instances or establishing fair market price benchmarks. Following precedent from another case, ITAT held that absent comparable evidence demonstrating excessiveness, the Assessing Officer cannot invoke section 40(A)(2)(b) disallowance provisions. The initial onus lies with Revenue to substantiate claims of unreasonable payments through proper market analysis and comparable transactions. Since no such exercise was undertaken and no attempt made to establish professional fees were excessive, the disallowance was deleted and appeal allowed.....