ITAT says Adat Commission Cannot Be Disallowed on Presumptions Alone

ITAT Pune held that the genuineness of business expenditure must be assessed on the evidence and commercial realities of the business, not merely on the high proportion of expenses to commission income. Where the assessee furnished identifiable payee details, banking records and TDS compliance, and the books were not rejected, the entire Adat expenditure could not be disallowed on suspicion alone.