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2015 (12) TMI 519 - DELHI HIGH COURT

2015 (12) TMI 519 - DELHI HIGH COURT - [2016] 381 ITR 258 - Working of Rule 9B - scheme of computation of business income as envisaged under Sections 28 to 44 - Held that:- In the present case, the separate Trading Accounts drawn up by the Assessee in respect of four films for the financial year ended 31st March, 1991 in question indicate a loss which is sought to be carried forward under Rule 9B of the Rules but the Assessee has in fact shown a profit of ₹ 76,751.99/- in its Profit & Loss .....

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40,97,791/- less the profit of ₹ 76,751.99/- disclosed by the Assessee in its Profit & Loss Account). The question whether the expenditure incurred by the Assessee is absorbed in a particular year would depend on the income generated by the Assessee in that year. However, it was incorrect on the part of the Assessee to include the cost of prints along with the MG Royalty amount for the purposes of determining the amount to be carried forward under Rule 9B of the Rules.

The langu .....

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Bombay to negotiate the purchase of distribution rights. The Assessee had also contended that such payments were made as the producers required the payments urgently at various sites where films being produced by them were being shot and it was expected that such payments be made in cash in the normal course of conducting business.In our view, the question whether the Assessee’s business exigencies required payments to be made in cash, is a question of fact. The ITAT has returned a finding in fa .....

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or Standing Counsel with Ms Lakshmi Gurung, Junior Standing Counsel and Mr. Abhishek Sharma JUDGMENT Vibhu Bakhru, J 1. These appeals - four in number - are filed under Section 260A of the Income Tax Act, 1961 (hereafter the Act ) impugning two separate orders of the Income Tax Appellate Tribunal (hereafter ITAT ) in respect of Assessment Years (hereafter AY ) 1992-93 and 1993-94. Whilst ITA Nos. 163/2002 and 377/2004 are Assessee s appeals impugning ITAT s orders dated 19th December, 2001 for A .....

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ether the ITAT was correct in law in admitting the addition made by the assessing officer under Section 40A(3) of the Income-tax Act, 1961? 3. Insofar as the Assessee s appeals are concerned (being ITA Nos. 163/2002 and 377/2004), the following question of law was framed:- Whether the ITAT has erred in concluding that the Assessing Officer s working of Rule 9B was correct in view of the scheme of computation of business income as envisaged under Sections 28 to 44 of the Income-tax Act, 1961? Ass .....

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0 days till the end of the financial year, from the gross realizations pertaining to that feature film and thereafter, amortize the cost of acquisition of the distribution rights of the feature films to the extent of the remaining surplus. It is claimed that the remaining unamortized cost of acquisition is to be carried forward for amortization against business income of the subsequent year. This is disputed by the Revenue. The Revenue contends that the cost of feature films, which have not run .....

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acts in ITA 163/2002. Briefly stated, the said facts are as under:- 5.1 The Assessee is a partnership firm engaged in the business of distribution of Hindi motion-pictures/films in the Territory of Delhi and Uttar Pradesh. The Assessee filed its return of income on 31st October, 1992 for the AY 1992-93 declaring an income of ₹ 1,13,380/-. The return was initially processed under Section 143(1)(a) of the Act and, subsequently, picked up for scrutiny. 5.2 The Assessee filed separate trading .....

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ys as on 31st March, 1991. The Assessee claimed that this expenditure, which was sought to be set off against the income in the current year, was unamortized expenditure that was carried forward in accordance with Rule 9B of the Rules. 5.3 The AO analysed the expenses claimed to have been carried forward by the Assessee from the preceding year and concluded that the same included costs of prints, which according to the AO could not be carried forward under Rule 9B of the Rules. The Table indicat .....

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Assessee, the amount of ₹ 59,19,154/- pertained to Minimum Guaranteed Royalty (MG Royalty) in respect of four films namely Farishtey , Saugandh , Patthar ke Phool and Patthar ke Insaan and did not include the costs of prints. The Assessee claimed that the costs of prints had already been set off against gross realizations relating to the respective films and only the MG Royalty amount was carried forward for amortization during the financial year 1991-92 relevant to the AY 1992-93. 5.5 In .....

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t of the four films are reproduced below:- FARISHTAY PICTURE A/C Release 21.2.91 Particulars Amount Particulars Amount To C/o Royalty 55,00,000.00 By Business 43,99,031.73 To C/o Prints 16,63,006.25 By Loss on picture 27,63,974.52 71,63,006.25 71,63,006.25 SAUGANDH PICTURE A/C Release 24.1.91 Particulars Amount Particulars Amount To C/o Royalty 12,50,000.00 By Business 15.68.809.60 To C/o Prints 7,29,995.30 By Loss on picture 4,11,185.70 19,79,995.30 19,79,995.30 PATTHAR KE PHOOL PICTURE A/C Rel .....

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es incurred by the Assessee including expenses such as publicity expenses specifically incurred in respect of the aforesaid films. Such expenses were directly debited by the Assessee to its Profit and Loss Account for the year ended 31st March, 1991 and were claimed as expenses against income generated from distribution of other films. 5.7 For the AY 1992-93, the Assessee claimed that the expenditure sought to be amortized against business income was only MG Royalty and the same was in accordanc .....

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ibition of that film was available for amortization during the year in question. Thus, according to the AO, the amount carried forward by the Assessee included the cost of prints which was not permissible. 5.8 The AO also allowed a deduction of ₹ 15,66,162/- as expenses for the financial year 1991-92. These expenses were not claimed by the Assessee as according to the Assessee, the same were available for being amortized in the next year (AY 1993-94) as per its interpretation of Rule 9B of .....

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isallowed the claim in respect of the cost of prints, as indicated in the table extracted hereinbefore, and restricted the claim of unamortized MG Royalty carried forward from the preceding year to ₹ 18,21,363/-. 6. The CIT(A) accepted the Assessee s contention as well as its method of accounting and deleted the addition made by the AO. The CIT(A) held that MG Royalty paid by the Assessee could be set off only against realizations from the film in question that were available to the Assess .....

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dditions made under Section 40A(3) of the Act. The question regarding deletion of the addition under Section 40A(3) of the Act is the subject matter of the Revenue s appeal being Appeal No. 260/2002. The ITAT s decision to allow the Revenue s appeal in respect of the issue concerning Rule 9B of the Rules is the subject matter of the Assessee s appeal - ITA 163/2002. Submissions 8. Ms Shashi M. Kapila, learned counsel appearing for the Assessee contended that the short issue involved in the Asses .....

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isition of distribution rights of that film and the unabsorbed cost of acquisition of rights would be carried forward to the next year for amortization against the income of the Assessee. She contended that if this procedure was not followed, the Assessee would not be in a position to set off its normal expenditure against his income in respect of feature films that had not been exhibited for a period of 180 days prior to the end of financial year. She submitted that in the circumstances, such n .....

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submitted that if the cost of feature films is amortized to the extent of the gross realizations then there would be no scope to set off other expenses incurred in connection with the distribution of the feature film and this would distort the true profits of the Assessee. 9. Ms Kapila next referred to the decision of the Commissioner of Income Tax v. Joseph Valakuzhi: (2008) 302 ITR 140 wherein the Supreme Court had held that unamortized expenses, which were permitted to be carried forward in t .....

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amount available for absorption of cost of films was only the net income that remained after deduction of other expenses incurred by the Assessee in connection with the feature film(s), which had not been commercially screened for a period of 180 days before the end of the previous year. 10. Ms Kapila also contended that the Assessee had consistently followed the accounting practice of computing the cost of acquisition of the distribution rights to be carried forward to the next year and the sam .....

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e 9B of the Rules was clear and the cost of acquisition of feature films did not include the amount of expenditure incurred in preparation of positive prints of feature films. She argued that in effect the Assessee was seeking to carry forward the cost of the films for being amortized in the subsequent year, which was not permissible. Reasoning & Conclusion 12. At the outset, it is necessary to refer to Rule 9B of the Rules which reads as under:- Deduction in respect of expenditure on acquis .....

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amount paid by the film distributor to the film producer or to another distributor under an agreement entered into by the film distributor with such film producer or such other distributor, as the case may be for acquiring the rights of exhibition and, where the rights of exhibition have been acquired on a minimum guarantee basis, the minimum amount guaranteed, not being- (i) the amount of expenditure incurred by the film distributor for the preparation of the positive prints of the film; and ( .....

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areas; or (ii) sells the rights of exhibition of the film in respect of some of the areas; or (iii) himself exhibits the film on a commercial basis in certain areas and sells the rights of exhibition of the film in respect of all or some of the remaining areas, and the film is released for exhibition on a commercial basis at least ninety days before the end of such previous year, the entire cost of acquisition of the film shall be allowed as a deduction in computing the profits and gains of suc .....

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released for exhibition on a commercial basis at least ninety days before the end of such previous year, the cost of acquisition of the film in so far as it does not exceed the amount realised by the film distributor by exhibiting the film on a commercial basis or the amount for which the rights of exhibition have been sold or, as the case may be, the aggregate of the amounts realised by the film distributor by exhibiting the film and by the sale of the rights of exhibition, shall be allowed as .....

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the profits and gains of such previous year; and the entire cost of acquisition shall be carried forward to the next following previous year and allowed as a deduction in that year. (5) Notwithstanding anything contained in the foregoing provisions of this rule, the deduction under this rule shall not be allowed unless- (a) in a case where the film distributor,- (i) has himself exhibited the feature film on a commercial basis; or (ii) has sold the rights of exhibition of the feature film; or (ii .....

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ibutor has transferred the rights of exhibition of the feature film on a minimum guarantee basis, the minimum amount guaranteed and the amount, if any, received or due in excess of the guaranteed amount, or where the film distributor follows cash system of accounting, the amount received towards the minimum guarantee and the amount, if any, received in excess of the guaranteed amount, are credited in the books of account maintained by him in respect of the year in which the deduction is admissib .....

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of the Act by the Central Board of Direct Taxes (hereafter CBDT ) and provides for the deduction in respect of expenditure incurred on acquisition of distribution rights of feature films. Rule 9B(1) of the Rules provides that deduction in respect of cost of acquisition of a feature film shall be allowed in accordance with sub-rule (2) to sub-rule (4) of Rule 9B of the Rules. A plain reading of the explanation to Rule 9B(1) of the Rules indicates that where the rights of exhibition have been acqu .....

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s or any expenditure incurred for preparation of the positive prints of films. Indisputably, in view of the plain language of Rule 9B, the expenditure incurred on preparation of positive prints of a film cannot be carried forward for amortization in terms of Rule 9B of the Rules as cost of acquisition of distribution rights of that film. 14. In terms of sub-rule (3) of Rule 9B of the Rules, if a film is not released for exhibition on a commercial basis at least 180 days (now amended to 90 days w .....

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al run of 180 days during the preceding financial year, i.e., financial year 1990-91 relevant to the AY 1991-92. Therefore, the Assessee was entitled to a deduction to the extent that the cost of acquisition of the films did not exceed the amount realized by the Assessee from exhibiting the film on a commercial basis and/or sale of rights of exhibition in respect of some of the areas. 15. The principal issue that needs to be addressed is whether the expression amount realized by the film distrib .....

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e in its business. The Profit & Loss Account of the Assessee for the financial year 1990-91 clearly indicates that the Assessee had debited the expenditure incurred on publicity of the films including the four films in question that had not completed a commercial run of 180 days prior to the end of the financial year, to the Profit and Loss Account. Thus, whilst the Assessee had charged a part of the expenses relating to the four films in question directly to its Profit & Loss Account, i .....

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whilst the Assessee excluded the expenditure incurred on publicity of the films for the purposes of calculating the amount to be set off against realizations of the said film and directly debited the same to its Profit & Loss Account, it sought to treat the cost of preparing positive prints as part of the cost of acquisition of distribution rights of films for the purpose of Rule 9B of the Rules. However, this is precisely what is not permissible in terms of the explanation to Rule 9B(1) of .....

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rints and publicity expenses would never be allowed and would become dead expenses . This, according to the Assessee, results in the scheme of computation of business profits under Section 28, 29 and 37(1) becoming inert, lifeless and redundant . It is contended that Rule 9B of the Rules must be read in a manner so as to avoid such manifest absurdity . In our view, the aforesaid contentions are wholly bereft of any merit. Rule 9B of the Rules only provides for the method of computing the deducti .....

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on a minimum guarantee basis, the minimum guarantee amount excluding the expenditure incurred on preparation of positive prints and expenditure incurred in connection with the advertisement of the films, is considered to be the cost of acquisition of distribution rights of films. In cases where the feature film has not completed a commercial run of hundred and eighty days (ninety days with effect from 1st April, 1999) before the end of the previous year, the deduction on account of cost of acqu .....

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business or profession are computed in accordance with the machinery provisions placed in part D of Chapter IV of the Act, i.e., Sections 28 to 44 DB of the Act. Broadly speaking, under the said computation provisions, income is determined by deducting allowable expenditure from the gross profits and gains of business. In the aforesaid scheme, the cost of acquisition of feature films computed in accordance with Rule 9B of the Rules would also be one such deduction and would be allowed in the sam .....

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ss carried out by the Assessee during the entire year. Thus, in the cases where the minimum guarantee payable for acquiring the distribution rights in respect of films that have not completed a commercial run of 180 days prior to the end of the financial year exceeds the realizations from the commercial exhibition of the film in that year, the Assessee would account for a loss in respect of that film in that year, albeit to the extent of other revenue expenditure incurred for that film; this is .....

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resent case, the separate Trading Accounts drawn up by the Assessee in respect of four films for the financial year ended 31st March, 1991 in question indicate a loss which is sought to be carried forward under Rule 9B of the Rules but the Assessee has in fact shown a profit of ₹ 76,751.99/- in its Profit & Loss Account for the year ended 31st March, 1991. This includes the expenditure incurred by the Assessee for the publicity and advertisement of the four films in question. If the As .....

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is absorbed in a particular year would depend on the income generated by the Assessee in that year. However, it was incorrect on the part of the Assessee to include the cost of prints along with the MG Royalty amount for the purposes of determining the amount to be carried forward under Rule 9B of the Rules. 18. The decision of the Bombay High Court in Prakash Pictures (supra) does not assist the Assessee in any manner. In that case, the Assessee had acquired distribution rights in respect of a .....

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nt entered into by the Assessee (distributor) and the producer (Sagar Enterprises) was modified and the Assessee paid a sum of ₹ 4.25 lacs to Sagar Enterprises for acquiring the rights of Sagar Enterprises in the overflow profits of the unexpired period of the contract. This amount of ₹ 4.25 lacs was claimed by the Assessee as a deduction out of the total collection shown in the Profit & Loss Account for the year ended 30th June, 1978. The Income Tax Officer disallowed the deduct .....

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; 4.25 lacs was paid for acquiring full rights of exhibition of the film and, therefore, the amount paid was admissible as a deduction under Rule 9B of the Rules. On a reference, the Division Bench of the Bombay High Court held that Rule 9B was applicable to the modified contract dated 20th March, 1978. However, the Court also held that the Assessee could not claim the entire deduction of ₹ 4.25 lacs under Rule 9B of the Rules as the deduction was admissible only where the receipts were cr .....

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s case, the amount to be amortized was linked to the receipts credited to the Profit & Loss Account. However, the controversy involved in that case was materially different from the one involved in the present appeals. 19. In Joseph Valakuzhy (supra), the Supreme Court considered the nature of the allowance permitted to be carried forward under Rule 9A of the Rules. The Supreme Court held that the carry forward of the unamortized cost of acquisition was not in the nature of the business loss .....

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ext necessary to consider the Assessee s contention that it had consistently followed the accounting practice of calculating the amount to be carried forward under Rule 9B of the Rules. The same was not objected to by the Assessing Officer in the past and, therefore, applying the rule of consistency, a departure from the past practice was not warranted. In our view, the aforesaid contention also cannot be accepted in cases where the mandate of law is clear. The principle of consistency is a prin .....

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ifferent assessment years has been found as a fact one way or the other and parties have allowed that position to be sustained by not challenging the order, it would not be at all appropriate to allow the position to be changed in a subsequent year . As is apparent from the said decision, the rule of consistency has limited application - where a fundamental aspect permeates through several assessment years; the said aspect has been found as a fact one way or the other; and the parties have not c .....

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is no res judicata, as regards assessment orders, and assessments for one year may not bind the officer for the next year. This is consistent with the view of the Supreme Court that "there is no such thing as res judicata in Income-tax matters" (Raja Bahadur Visheshwara Singh v. CIT [1961] 41 ITR 685 (SC) ; AIR 1961 SC 1062). Similarly, erroneous or mistaken views cannot fetter the authorities into repeating them, by application of a rule such as estoppel, for the reason that being an .....

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IT [2008] 306 ITR 242 (Delhi) had held that the rule of consistency cannot be of inflexible application. 22. As explained earlier, the language of Rule 9B is unambiguous and the Assessee cannot be permitted to claim a carry forward of the cost of distribution rights, which is in variance with the computation as provided in Rule 9B of the Rules. 23. In view of the above, the question of law framed is answered in the negative, that is, in favour of the Revenue and against the Assessee. Revenue s A .....

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lm producers in terms of the agreements entered into with them. It was also contended that the exigencies of business required the Assessee to make such payments to producers in Bombay. The Assessee explained that its office was located at Delhi and it carried on its business in Delhi and the payments made in cash were made to producers in Bombay. Further, in the line of the Assessee s business, the producers expected the payments to be made in cash immediately on concluding the agreements. It w .....

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were recouped by the Assessee from the collections made in respect of the films. According to the Assessee, such payments were not covered under the provisions of Section 40A(3) of the Act. The AO did not accept the Assessee s contentions and made the additions as mentioned above. In appeals preferred by the Assessee, the CIT(A) accepted the Assessee s contention that the payments were not made for purchase of prints but were advanced against the MG Royalty payable for acquiring the limited rig .....

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A) s decision and preferred appeals before the ITAT. The ITAT did not accept the view that the payments in question were outside the scope of Section 40A(3) of the Act; however, the ITAT accepted the contention that such payments had been made on account of exigencies of business. The ITAT further observed that the rigours of Section 40A(3) of the Act had been relaxed by virtue of Rule 6DD of the Rules as well as CBDT Circular No. 220 dated 31st May, 1977 and the instances indicated in the circu .....

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ssee by virtue of Section 40A(3) of the Act. 28. Countering the submissions made on behalf of the Revenue, Ms Kapila submitted that not only the genuineness of the transactions had been established but the ITAT had also accepted, as a fact, that such payments were necessary in the course of conducting business. She also contended that it was necessary to look at the circumstances under which payments had been made and by keeping in view of the commercial constraints and the practicality of the c .....

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advances either for processing the positives of the film or acquiring the rights of exhibition of feature films. Thus, indisputably, such payments were allowable as deduction being revenue expenses incurred wholly and exclusively for business. The only issue to be considered is whether the same have to be disallowed by virtue of Section 40A(3) of the Act because the same were made in cash. 30. Section 40A(3) of the Act as in force during the AYs 1992-93 and 1993-94 reads as under:- (3) Where the .....

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n assessment year commencing prior to the 1st day of April, 1969, in respect of any liability incurred by the assessee for any expenditure and subsequently during any previous year the assessee makes any payment in respect thereof in a sum exceeding ten thousand rupees otherwise than by a crossed cheque drawn on a bank or by a crossed bank draft, the allowance originally made shall be deemed to have been wrongly made and the Assessing Officer may recompute the total income of the assessee for th .....

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han by a crossed cheque drawn on a bank or by a crossed bank draft, in such cases and under such circumstances as may be prescribed, having regard to the nature and extent of banking facilities available, considerations of business expediency and other relevant factors. 31. Rule 6DD of the Rules expressly provides that no disallowance under Sub-section 3 of Section 40A shall be made, inter alia, in circumstances specified thereunder. Clause (j) of Rule 6DD of the Rules (as applicable during the .....

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s in the manner aforesaid was not practicable, or would have cause genuine difficulty to the payee, having regard to the nature of transaction and the necessity for expeditious settlement thereof. 32. Apparently, several representations were received by the CBDT regarding difficulties that were being faced by tax payers due to the lack of uniformity in the interpretation of the aforesaid Rule. In the circumstances, the CBDT issued a circular - being Circular No. 220 dated 31st May, 1977, inter a .....

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y way of crossed cheque/draft and the purchaser's business interest would suffer due to nonavailability of goods otherwise than from this particular seller ; or (v) The seller, acting as a commission agent, is required to pay cash in turn to persons from whom he has purchased the goods; or (vi) Specific discount is given by the seller for payment to be made by way of cash. 33. CBDT further clarified that the above circumstances are not exhaustive but illustrative. There could be cases other .....

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