Disallowance under sec. 40A(2) without a comparable to prove the excessive payment is not justified: ITAT

INCOME TAX : Where AO disallowed professional expenses incurred by assessee company for taking consultancy and technical services from its sister concern by invoking provision of section 40A(2) on ground that said expenses were excessive of fair market value, since no comparable instance of third party rendering similar services was brought on record so as to show that said expenses incurred by assessee were excessive, such disallowance was to be restricted only to 10 per cent of total expenses

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