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We are of the considered view that aforesaid adhoc disallowance of expenses under various heads of expenses to the tune of 10% of the total expenses incurred by the assessee under these heads of expenses is not warranted and we order deletion of the said adhoc disallowance of expenses.

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Section 194J of the Income Tax Act, 1961— TDS — The ad hoc disallowance of expenses under various heads at 10 percent of total expenses not warranted as there were several reasons for the difference between the income based on the tax deducted at source as reflected in form 26AS and the income as reported in the books of account and the assessee had done all it could do to discharge its onus by submitting reconciliation statements as well explaining the reasons for the difference between the income as reported in form 26AS and the income as reflected in its books of account and there was no defect in the books of accounts— TUV India P. Ltd. vs. Deputy Commissioner of income tax [2019] 75 ITR (trib) 364 (Mumbai)

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