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2019 (6) TMI 1404 - AT - Income TaxDisallowance of commission expenditure - HELD THAT:- The genuineness of the commission expenditure and, the fact that the said expenditure was incurred wholly and exclusively for the purpose of the business of the assessee, admittedly stands established beyond any scope of doubt. Apart there from, we are also of the considered view, that now when on the basis of similar details filed by the assessee the commission expenditure of less than ₹ 1 lac per party, aggregating to ₹ 62,91,155/-, had been accepted by the A.O/DRP, therefore, a different yardstick could not have been adopted by them for verifying the veracity of the balance commission expenditure of ₹ 1,62,05,703/-. On the basis of our aforesaid observations, we are of a strong conviction that now when the assessee had placed on record substantial material to substantiate the genuineness and veracity of the commission expenditure, which has already been accepted by the DRP while disposing off the objections of the assessee, therefore, there was no justifiable reason for disallowing the aforesaid commission expenditure. Accordingly, we vacate the disallowance of commission expenditure made by the A.O. The Ground of appeal No. 2 is allowed.
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