Tax Authority Must Verify Disbursements to Retailers Before Accepting Reimbursement Claims Under Section 263

ITAT upheld the PCIT's order quashing the assessment under section 263 regarding TDS liability on payments to sales promoters claimed as reimbursements. The Tribunal found that the Assessing Officer failed to verify whether the transactions constituted genuine reimbursements as previously mandated. The AO merely accepted documentation without proper verification or reconciliation of whether sales promoters actually redistributed funds to retailers. Critical issues remained unaddressed, including how sales promoters were compensated and whether month-wise reconciliation statements existed to demonstrate actual disbursement to retailers. The ITAT directed the AO to verify disbursements by sales promoters against respective debit notes through proper reconciliation, dismissing the assessee's appeal. .....

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