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Ramnagar Pachwai and C.S. (S) Shop Versus Income-Tax Officer

[2016] 50 ITR (Trib) 332 - Disallowance made under section 40A(3) - cash payments (in excess of ₹ 20,000 on each occasion) - purchase of its stock-in-trade (country liquor) - Held that:- The payment made by the assessee retail vendor to the Principal, Government of West Bengal through its wholesale agent. The relationship between the assessee (authorised retailer) and Government of West Bengal (the supplier) acting under West Bengal Excise Rules through its authorised wholesaler licensee ( .....

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that the assessee's case falls under the exceptions provided in rule 6DD(b) and rule 6DD(k) of the Rules. We have no hesitation in deleting the disallowance made under section 40A(3) of the Act in all the years under appeal. - Decided in favour of assessee. - I. T. A. Nos. 148/Kol/ 2015, 185 and 186/Kol/2014 - Dated:- 5-8-2016 - N. V. Vasudevan (Judicial Member) and M. Balaganesh (Accountant Member) For the Appellant : S. K. Tulsiyan and R. N. Ram, Authorised Representatives For the Respondent .....

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f the Income-tax Act, 1961 (hereinafter referred to as the "Act") for the assessment years 2007-08, 2008-09 and 2010-11 vide his separate orders dated December 11, 2009, October 21, 2010 and December 14, 2012 respectively. Since issues are identical and facts are common, we dispose of both these appeals by his common order for the sake of convenience. 2. The only issue to be decided in all the appeals is as to whether the learned Commissioner of Income-tax (Appeals) is justified in uph .....

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aging Co. Pvt. Ltd. for purchase of its stock-in-trade in terms of section 40A(3) of the Income-tax Act. The common facts in these cases are as follows : 4. The assessee is a retail vendor of country liquor and Pachai. The country liquor is an excisable commodity. Its purchase and sale are strictly controlled by the State Government. Previously, the retail dealers like the assessee used to deposit the cost price, excise duty, bottling charges, etc., in the treasury against Form TR-7 in cash for .....

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e assessee made payments partly by demand draft and partly by cash deposits in the bank account of its supplier, i.e., M/s. Asansol Bottling and Packaging Co. Pvt. Ltd. maintained in the State Bank of India. While completing the assessments of the assessee, the learned Assessing Officer allowed the payments made by demand drafts but disallowed the cash deposits (in excess of ₹ 20,000 on each occasion) made in the bank account of the supplier maintained in the State Bank of India in terms o .....

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o most important arguments were that since the assessee deposited cash in the State Bank of India, no disallowance under section 40A(3) of the Act is called for in view of the exemption allowed under rule 6DD(a)(ii) of the Income-tax Rules. The learned Commissioner of Income-tax (Appeals) has, however, rejected this submission relying on the hon'ble Kerala High Court decision in the case of K. Abdu and Co. v. ITO reported in [2008] 170 Taxman 297 (Ker) in which it has been held that the exem .....

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c. It was claimed that in such a situation, the cash payments made to the bank account of M/s. Asansol Bottling and Packaging Co. Pvt. Ltd. should be treated as payments made to the Government and hence no disallowance is called for in view of provisions of rule 6DD(b) of the Income-tax Rules which provides that where the payment is made to the Government, no disallowance under section40A(3) is required. The learned Commissioner of Income-tax (Appeals) has rejected this argument on the ground th .....

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ugust 29, 2005 issued by the Excise Department, Government of West Bengal according to which, he argued that the wholesale licensee is an agent of the State Government and is a link between retail vendor (assessee herein) and the State Government. He argued that rule 6(2) of the said notification mandates the retail vendor (i.e., the assessee herein) to deposit the monies directly into the bank account of the wholesale licensee and not by any other mode. He argued that the wholesale licensee is .....

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d 426, the hon'ble Supreme Court had held that it would be reversing the well known canon of interpretation if the plain words of the Statute were to be construed in the light of an alleged intention gathered from outside source. In that case, according to a notification covering co-operative societies, the "profits of any co-operative society" were exempt from tax. However, a dispute was raised as to whether the profits referred to were profits derived by a co-operative society fr .....

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tion to profits derived from business with members alone. Keeping in view the observations of the hon'ble Supreme Court referred to above it appears that the word "State Bank of India" mentioned in rule 6DD(a)(ii) meant only the State Bank of India and the concept of beneficiary as introduced by the hon'ble Kerala High Court in the case of K. Abdu and Co. v. ITO [2008] 170 Taxman 297 (Ker) is not necessary. Again, it is well known even to a layman that, if not the entire, a maj .....

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State Bank of India are eligible for exemption as provided under rule 6DD(a)(ii). 7. He placed reliance on the decision of the co-ordinate Bench of the Bangalore Tribunal in the case of Sri Renukeswara Rice Mills v. ITO reported in [2005] 93 ITD 263 (Bang-Trib.) wherein it was held that the cash payment in the accounts of the payee in a bank is sufficient to get exemption in terms of rule 6DD. It is submitted that the decision of the hon'ble Bangalore Bench in the abovementioned case is mor .....

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ng to the accounts of its customers, should be held as eligible for exemption as provided in rule 6DD(a)(ii) of the Rules. 8. He further argued that the stock-in-trade of the assessee is an excisable commodity. Hence, its cost price, excise duty, bottling charges, etc., are all payable to the Government. Previously, all such payments used to be made to the treasury in cash, along with challan in T.R.-7. But by a notification dated August 29, 2005 the Government of West Bengal, Excise Department .....

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to assessment year 2009-10 and the case of Amrai Pachwai and C. S. Shop, (ITA No. 1251/Kol/2011, dated January 15, 2014 relating to the assessment year 2008-09). In both these cases the hon'ble Tribunal Kolkata Bench held that the payments to the wholesale licensee in cash in excess of ₹ 20,000 should be treated as payments to the Government and are covered by rule 6DD(b) of the Income-tax Rules. The learned Commissioner of Income-tax (Appeals), however, rejected this contention of th .....

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ove are in favour of the assessee. 9. He argued that the genuineness of transactions were not disputed by the Revenue. The payment is made to wholesale licensee and payment has gone into the coffers of the West Bengal Government. He further argued that if the entire purchases made in cash is disallowed, then effectively the learned Assessing Officer would be taxing the entire sale proceeds as income of the assessee which would only result in an anomalous situation. He further argued that the law .....

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ported in [1991] 191 ITR 667 (SC) ; (b) The hon'ble Rajasthan High Court in the case of CIT v. Kalyan Prasad Gupta reported in [2011] 239 CTR (Raj) 447; (c) The hon'ble Karnataka High Court in the case of CIT v. Devendrappa M. Kalal reported in [2013] 219 Taxman 122 (Karn) ; (d) The co-ordinate Bench of this Tribunal in the case of Ashok Mondal v. ITO in ITA No. 873/Kol/2012, dated February 6, 2014 ; (e) The co-ordinate Bench of this Tribunal in the case of Amrai Pachwai and C.S. Shop v. .....

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respect of case of the hon'ble Rajasthan High Court supra relied upon by the learned authorised representative, the same was in respect of payment made by agent to State Government and hence does not fall in the exception provided in rule 6DD of the Rules. In respect of Bangalore Tribunal supra decision relied upon by the learned authorised representative, the payment was made in that case for purchase of agricultural produce and hence was automatically covered by the exception to rule 6DD. .....

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to payment made to State Bank of India, he argued that State Bank of India is only an agent of the customer and hence payment is made to wholesaler who has account with State Bank of India. With regard to the reliance placed on the decision of the hon'ble apex court in the case of Attar Singh Gurmukh Singh v. ITO [1991] 191 ITR 667 (SC), he stated that the question before the hon'ble apex court was with regard to the constitutional validity of the provisions of section 40A(3) of the Act .....

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d by the State. The said notification nowhere compelled the assessee to make cash payments in violation of section 40A(3) of the Act. He argued that the Government wants to distance itself from dealing in the vulnerable commodities like country liquor and accordingly came forward to grant licence to deal with the same to private parties. That does not enable the private party to become Government. He further placed reliance on the decision of the hon'ble Kerala High Court in the case of K. A .....

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nment of West Bengal vide pages 43 to 49 of the paper book and copies of various decisions of High Courts and Tribunals vide pages 50 to 102 of the paper book. We have also gone through the provisions of the West Bengal Excise Rules, 2005 and the Bengal Excise Act, 1909. The facts stated hereinabove remain undisputed and hence the same are not reiterated for the sake of brevity. At the outset, we deem it necessary to incorporate the following clauses from the notification issued by the Excise De .....

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yment of duty in labelled and capsuled bottles from country spirit bottling plants and in bulk from warehouses by the licensed wholesale vendors of the same for the purpose of selling country spirit by wholesale : Rules 1. Short Title and commencement. - (1) These rules may be called the West Bengal Excise (Supply of Country Spirit on Payment of Duty) Rules, 2005. (2) These rules shall come into force from 19th October, 2005. 2. Definitions. - (1) In these rules, unless there is anything repugna .....

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Act' means the Bengal Excise Act, 1909 (Ben. Act V of 1909) ; (vi) 'transport pass' means the transport pass issued in Form III appended to these rules ; (vii) 'warehouse' means the warehouse for supply of country spirit to retail vendors, established at convenient places by the Commissioner at the expense of the State Government, or at the expense of a person to whom the exclusive privilege of supplying or selling country spirit by wholesale has been granted under section 2 .....

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m a country spirit bottling plant. No country spirit in bulk shall be issued without payment of duty from a country spirit warehouse. 4. Personal Ledger Account to be maintained by the wholesale licensee. - The wholesale licensee shall maintain a Personal Ledger Account in accordance with the direction issued by the Commissioner from time to time for the purpose of maintaining an account - current of the duties payable by the wholesale licensee for the issues of country spirit to the retail vend .....

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ssue of country spirit. - (1) The retail vendor or his authorised representative shall submit to the representative of the wholesale licensee, through Excise officer-in-charge of the ware house, a demand for issue of country spirit in Form I appended to these rules in duplicate. The duplicate copy shall be kept in the custody of the Excise officer-in-charge for his official record. (2) No retail vendor of country spirit shall deposit duty direct into the local treasury for issue of country spiri .....

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the retail vendor to whom country spirit is to be issued from the concerned warehouse. The authorised representative as above shall then submit requisition in duplicate in Form II appended to these rules to the Excise Officer-in-Charge of the warehouse separately for each of the retail vendors to whom country spirit is to be issued on the day. (4) On receipt of the requisition in Form II, the Excise officer-in- charge of the warehouse shall allow issue of country spirit from the warehouse. Dupli .....

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ottle irrespective of measure from the bottling charge to the retail country spirit licensees whose licensed premises are located at a distance of 50 kilometres or more by the shortest route from the issuing warehouse on the basis of a certificate to be issued by the Collector in respect of distance. At the end of the month, the wholesaler shall submit a bill in duplicate to the Officer-in-Charge of the warehouse claiming refund of the amount granted as rebate. The Officer-in-Charge shall, on re .....

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rivilege fee." 14. We find that the reliance placed on the decision of the co-ordinate Bench of Bangalore Tribunal in the case of Sri Renukeswara Rice Mills v. ITO reported in [2005] 93 ITD 263 (Bang-Trib) is well founded, wherein, it was held that the cash payment in the bank account of the payee is sufficient to get exemption in terms of rule 6DD inasmuch it is ensured that the payee and payee alone receives the payment and the origin and conclusion of the transaction is traceable thereby .....

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licensee) is not doubted by the Revenue, the provisions of section 40A(3) could not be made applicable to the facts of the instant case. It is observed that the assessee had taken enough precautions from its side to ensure that the payee also do not escape from the ambit of taxation on these receipts by directly depositing the cash in the bank account of the payee. Moreover, the regulations of the West Bengal Government pursuant to notification from its Excise Department dated August 29, 2005 a .....

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iterates this view that "this provision is designed to counter evasion of a tax through claims for expenditure shown to have been incurred in cash with a view to frustrating proper investigation by the Department as to the identity of the payee and reasonableness of the payment." 17. In this regard, it is pertinent to get into the following decisions on the impugned subject : "Attar Singh Gurmukh Singh v. ITO reported in [1991] 191 ITR 667 (SC) (headnote) Section 40A(3) of the Inc .....

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tion on the assessee in his trading activities. Section 40A(3) only empowers the Assessing Officer to disallow the deduction claimed as expenditure in respect of which payment is not made by crossed cheque or crossed bank draft. The payment by crossed cheque or crossed bank draft is insisted upon to enable the assessing authority to ascertain whether the payment was genuine or whether it was out of income from undisclosed sources. The terms of section 40A(3) are not absolute. Consideration of bu .....

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an assessee can be exempted from the requirement of payment by a crossed cheque or crossed bank draft in the circumstances specified under the rule. It will be clear from the provisions of section 40A(3) and rule 6DD that they are intended to regulate business transactions and to prevent the use of unaccounted money or reduce the chances to use black money for business transactions. CIT v. CPL Tannery reported in [2009] 318 ITR 179 (Cal) (page 181) The contention of the assessee that he purchase .....

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s of the assessee that payments are made to producers of hides and skins are also neither doubted nor disputed by the Assessing Officer. On the basis of these facts it is not justified on the part of the Assessing Officer to disallow 20 per cent. of the payments made under section 40A(3) in the process of assessment. We, therefore, delete the addition of ₹ 17,90,571 and ground No. 1 is decided in favour of the assessee. CIT v. Crescent Export Syndicate in ITA No. 202 of 2008, dated July 30 .....

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15,69,116. It is also made clear that without the payment being made by bearer cheque these goods could not have been procured and it would have hampered the supply of goods within the stipulated time. Therefore, the genuineness of the purchase has been accepted by the learned Commissioner of Income-tax (Appeals) which has also not been disputed by the Department as it appears from the order so passed by the learned Tribunal. It further appears from the assessment order that neither the Assessi .....

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e Services Limited for distributing mobile cards and recharge vouchers - Principal company Tata insisted that cheque payment from assessee's co-operative bank would not do, since realisation took longer time and such payments should be made only in cash in their bank account - If assessee would not make cash payment and make cheque payments alone, it would have received recharge vouchers delayed by 4/5 days which would severely affect its business operation - Assessee, therefore, made cash p .....

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payment for purchase of groundnut in cash exceeding prescribed limit - Assessee submitted that he made payment in cash because seller insisted on that and also gave incentives and discounts - Further, seller also issued certificate in support of this - Whether since assessee had placed proof of payment of consideration for its trans action to seller, and later admitted payment and there was no doubt about genuineness of payment, no disallowance could be made under section 40A(3) - Held, yes [Par .....

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llowance of the entire cash purchases results in abnormal trading profit for the assessee which it could never earn. We find a purposive construction should be resorted to while applying the provisions of the Act. Hence it would be more relevant to get into the intention of the Legislature. In our opinion, the primary object of enacting section 40A(3) was twofold, firstly, putting a check on trading transactions with a mind to evade the liability to tax on income earned out of such transaction a .....

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n deposited directly in the bank account of the supplier, i.e., M/s. Asansol Bottling and Packaging Co. Pvt. Ltd. by the assessee. 19. We find that the hon'ble apex court in the case of CTO v. Swastik Roadways reported in [2014] 135 STC 1 (SC) ; (2004) 3 SCC 640 had held that the consequences of non-compliance of Madhya Pradesh Sales tax Act, which were intended to check the evasion and avoidance of sales tax were significantly harsh. The court while upholding the constitutional validity neg .....

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owner of the goods and the failure of C & F agent to furnish information required by the Commissioner is implicit in section 57(2) and the assessing authority concerned has to necessarily record a finding to this effect before levying penalty under section 57(2). Though in the instant case, the issue involved is not with regard to the levy of penalty, but the requirement of law to be followed by the assessee was of as technical nature as was in the case of CTO v. Swastik Roadways reported i .....

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e in adhering to requirement of provisions of section 40A(3) has any such nexus which defeats the object of provision so as to invite such a consequence. We hold that the purpose of section 40A(3) is only preventive and to check evasion of tax and flow of unaccounted money or to check transactions which are not genuine and may be put as camouflage to evade tax by showing fictitious or false transactions. Admittedly, this is not the case in the facts of the assessee herein. The assessee had direc .....

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x Rules are not exhaustive and that the said rule must be interpreted liberally. 20. We also find that the impugned issue is also covered by the decision of the co-ordinate Bench of this Tribunal in the case of Ashok Mondal v. ITO in ITA No. 873/Kol/2012 for the assessment year 2009-10, dated February 6, 2014, wherein it was held that : "7. We have considered the rival submissions. At the outset a perusal of the decision in the case of Smt. Pushpalata Mondal shows that the Tribunal had deci .....

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re agents of the Government and the payments made are to the Government. It also makes it categorically required that the payment is to be made before lifting of the country spirit. Consequently we are of the view that the issue is squarely covered by the decision of the co-ordinate Bench of this Tribunal in the case of Amrai Pachwai and C.S. Shop referred to supra wherein it has been held as follows : '6. We have considered the rival submissions. At the outset a perusal of the assessment or .....

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he payments made by the assessee for the purchase of country spirit from the territorial licensee bottling plant, IFB Agro Industries Ltd., City Centre, Durgapur falls within the exemption provided under rule 6DD(b) of the Income-tax Rules, 1962. Admittedly, the Assessing Officer has recognised that the provision of rule 6DD(b) of the Income-tax Rules, 1962 is applicable in case of payments made to Government directly. This is found in page 2 of the assessment order. A perusal of the Kolkata Gaz .....

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sed wholesale vendor of country spirit. Further, it has been specifically identified that the authorised representative of the wholesale licensee shall realise the necessary amount of duty, cost price and bottling charge, if there be any, at the prescribed rate and such other imposition, as may be prescribed by law, from the retail vendor to whom the country spirit is to be issued from the concerned warehouse. It is also specifically mentioned in section (2) of the said notification that no reta .....

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the warehouse, run by the Government. This shows that any payment made to the warehouse, which is under the direct control of the State Government, is a payment made directly to the Government. Once, this is accepted then the provisions of rule 6DD(b) of the Income-tax Rules, 1962 which clearly spells out that the payment made to the Government in legal tender under the rules framed by the Government, is exempted from the rigours of section 40A(3) of the Act. Here, it is noticed that the paymen .....

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es 1962. In the circumstances, the addition as made by the Assessing Officer and as confirmed by the learned Commissioner of Income-tax (Appeals) by invoking the provisions of section 40A(3) of the Income- tax Act, 1961 stands deleted.' 8. In the result the addition as confirmed by the learned Commissioner of Income-tax (Appeals) stands deleted." We find that this decision was rendered by placing reliance on its earlier decision in the case of Amrai Pachwai and C.S. Shop in ITA No. 1251 .....

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kaging Co. Pvt. Ltd. is a bottling plant cum warehouse under rule 2(vii) of the West Bengal Excise Rules, 2005 with privilege granted under section 22 of the Bengal Excise Act, 1909. At this juncture, it would be relevant to go into the definition of warehouse as provided under the State Excise Rules, 2005 as below : "'Warehouse', under rule 2(vii) of the West Bengal Excise Rules, 2005, means the warehouse for supply of country spirit to retail vendors, established at convenient pla .....

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he Commissioner of State Excise and as such is a State Government establishment. It is also pertinent to note that the expenditure in relation to such warehouse is borne by the State Government or by the licensee to whom the exclusive privilege is granted under section 22 of the Bengal Excise Act, 1909. Hence there could be no doubt that the warehouse is established by the State Excise Commissioner. Hence it could be safely concluded that the ware house so established by the State Excise Commiss .....

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in West Bengal Excise Form No. 26." It would be pertinent to look into section 22 of the Bengal Excise Act, 1909 at this juncture as below : "22. Grant of exclusive privilege of manufacture and sale of country liquor or intoxicating drugs. - (1) The State Government may grant to any person, on such conditions and for such period as it may think fit, the exclusive privilege - (a) of manufacturing, or supplying by wholesale, or (b) of manufacturing, and supplying by wholesale, or (c) of .....

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of any privilege under sub-section (1) shall exercise the same unless or until he has received a license in that behalf from the Collector or the Excise Commissioner." Hence it could be safely concluded that M/s. Asansol Bottling and Packaging Co. Pvt. Ltd. (Bottling Plant) is a warehouse within the meaning of rule 2(vii) of the Excise Rules, 2005 and said warehouse is a State Government establishment, established and controlled by the Excise Commissioner. It would be relevant to reproduce .....

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gly falls under the exception provided in rule 6DD(b) of the Income-tax Rules. 22. It is not in dispute that M/s. Asansol Bottling and Packaging Co. Pvt. Ltd. have been granted licence to act as a wholesaler for supply of country liquor to the retail vendor as per the regulations of the Excise Department, Government of West Bengal. At the cost of repetition, we would like to state that the said regulation mandated the payments to be made directly into the bank account of the said wholesale licen .....

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