Addition Under Section 40A(2)(a) Deleted Due to Incorrect Comparison of Services

V Commission Media Private Limited Vs ACIT (ITAT Delhi) The appeal before the Income Tax Appellate Tribunal (ITAT), Delhi, arose from the order of the Commissioner of Income Tax (Appeals) dated 05.07.2024, which upheld various additions and disallowances made by the Assessing Officer (AO) under Section 143(3) of the Income Tax Act, 1961 for Assessment Year 2015–16. The primary issue concerned an addition of ₹2,10,00,000 under Section 40A(2)(a) on the ground that payments made by the assessee to its related party for email marketing services were excessive. The assessee, engaged in internet...