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ITAT upheld disallowance under Section 40A(3) against a private limited construction company for cash payments exceeding statutory limits in land purchases. The tribunal rejected the assessee's contention that genuine transactions are exempt from Section 40A(3), emphasizing that the provision applies to otherwise legitimate expenses paid in cash beyond prescribed thresholds. The court distinguished the Achal Alloy precedent, noting it involved business exigency with illiterate payees lacking bank accounts. The tribunal dismissed arguments that no expenditure was incurred merely because purchased land remained in closing stock, holding that debiting purchases to profit and loss account constituted sufficient expenditure recognition. The decision favored revenue authorities, confirming that Section 40A(3) operates independently of transaction genuineness when cash payment limits are exceeded.
ITAT upheld disallowance under Section 40A(3) against a private limited construction company for cash payments exceeding statutory limits in land purchases. The tribunal rejected the assessee's contention that genuine transactions are exempt from Section 40A(3), emphasizing that the provision applies to otherwise legitimate expenses paid in cash beyond prescribed thresholds. The court distinguished the Achal Alloy precedent, noting it involved business exigency with illiterate payees lacking bank accounts. The tribunal dismissed arguments that no expenditure was incurred merely because purchased land remained in closing stock, holding that debiting purchases to profit and loss account constituted sufficient expenditure recognition. The decision favored revenue authorities, confirming that Section 40A(3) operates independently of transaction genuineness when cash payment limits are exceeded.
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