Expense can be disallowed u/s 40A(2)(b) & Not the Receipts

KEC-PLR-KPIPL-JV Vs ITO ( ITAT Delhi) The issue under consideration is whether the disallowance made u/s 40A(2)(b) by AO is justified in law? ITAT states that, in the present case, it is an admitted position that the AO made the addition by invoking the provisions of Section 40A(2)(b) of the Act which are applicable to the expenses considered to be excessive or unreasonable having regard to the fair market value of the goods/services or facilities for which the payment is made. However, in the instant case, the AO estimated the profit of the assessee and determined the income, nowhere he doubt...