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2018 (12) TMI 1663 - AT - Income TaxDetermination of income u/s.153A - disallowance u/s.40A(3) - HELD THAT:- Disallowance out of expenditure could be made if payment or aggregate of payments made to a person in a day exceeds twenty thousand rupees. Ld. first appellate authority has examined this aspect and recorded a categorical finding of fact that payments made by the assessee on a single day did not exceed twenty thousand rupees to a person, if that be so, then how disallowance u/s.40A(3) of the Act could be made. Thus, for the time being, if we do not take cognizance of the first fold of submission that addition ought to be made on the basis of seized material, then also, otherwise on merit this addition could not be made. Ld. first appellate authority has rightly appreciated the facts and circumstances and no interference is called for in the order of the Ld.CIT(A). - Decided in favour of assessee
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