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2018 (8) TMI 758 - HC - Income TaxAdditions u/s 40A(3) - payments exceeding ₹ 20,000/- were made in cash to various parties - the amount was shown to be paid to various farmers and even the receipts were also produced. However, the assessee could not furnish / produce those persons / farmers and the assessee explained that it could not produce furnish the names and addresses of the persons to whom cash payment was made - A.O. did not accept the said explanation. However, the A.O., without rejecting the Books of Accounts, made disallowance. - CIT(A) and ITAT deleted the additions. Held that:- it is not in dispute that the assessee is engaged in the business as a Commission Agent for purchase/ sale of food-grain / agricultural produces and is also holding licence issued by the Agricultural Produce Market Committee. In the present case, Rule 6DD(e)(i) shall be applicable and the same is rightly applied by the learned CIT(A) as well as the learned ITAT. It cannot be disputed and it is not disputed that as such, the assessee was engaged in the business of Commission Agent for purchase /sale of food-grain and is also holding licence issued by the Agricultural Produce Market Committee. No substantial question of law arises. - Decided against the revenue.
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