Managerial remuneration disallowance under s.40A(2)(b) challenged over alleged tax-avoidance; appellate decision restored deletion of addition for directors' salaries

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....Dispute concerned disallowance under section 40A(2)(b) for alleged unreasonable managerial remuneration alleged as a device for tax evasion; the assessing officer relied on comparative salary analysis of directors and senior executives to disallow excess payments, concluding payments were distribution of profits in the form of salarythis finding led to a quantified excess disallowance. The appellate authority deleted the addition, rejecting the assessing officer's conclusion and observing tax payment by company and directors; the matter was decided in favour of the assessee, restoring the deletion of the disallowance.....