Referral Commissions Not Insurance Commission: ITAT Deletes 40(a)(ia) Addition

Bhavesh Karamshi Thakkar Vs DCIT (ITAT Mumbai)

Referral Expenses Not Hit by 194D- Referral Payments Not Insurance Commission – Tribunal Deletes 40(a)(ia) Addition

Assessee, a qualified Chartered Accountant & LIC/Reliance Insurance Agent, filed return declaring ₹48,47,710. During scrutiny, AO noted sales promotion expenses of ₹29,96,390, out of which ₹28,50,093 was commission to 14 persons. Notices u/s 133(6) were issued & all parties confirmed receipt, some even appeared under summons u/s 131. Despite confirmations, AO disallowed 30% of commission (₹8,55,02

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