Marketing expenditure substantiation may justify limited disallowance, but does not alone establish income misreporting for penalty purposes.

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....Marketing expenditure supported only by self-made vouchers may be disallowed where third-party evidence is absent, but a complete disallowance may be inappropriate when the expenditure is modest relative to turnover, relates to client visits and outstation costs, and audited books contain no adverse comments. The discussion notes that a restricted disallowance was sustained. It further explains that insufficient substantiation of an expenditure claim does not itself establish misreporting under section 270A unless a statutory category, such as misrepresentation, suppression of facts, lack of evidence, or a false book entry, is identified. The related misreporting penalty was deleted.....