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2022 (12) TMI 29 - AT - Income TaxDisallowance u/s 40A(3) - purchase of sugarcane in cash - assessee made purchases from farmers of their agricultural produce - As argued AO grossly erred in law and on facts for applying provisions of Section 40A(3) read with Rule 5DD(j) - HELD THAT:- In the light of specific exception provided under Rule 6DD(e) in respect of agricultural produce, since the assessee made purchases of sugarcane, which is essentially an agricultural produce, coupled with the fact that Revenue has earlier accepted this claim of the assessee, we therefore, do not see any infirmity into the impugned order. Same is hereby sustained. This ground of Revenue’s appeal is dismissed. Addition u/s 68 - assessee in this case has failed to provide the genuineness of the transaction and creditworthiness of the lender from whom loans were received - CIT-A deleted the addition - HELD THAT:- CIT(Appeals) has categorically recorded that the amount of unsecured loan during the relevant financial year was received in the earlier financial year and was disclosed in the relevant balance-sheet as such. The ground raised by the Revenue thus lacks merit and is dismissed.
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