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ITAT allowed the appeal of the assessee-firm and reversed the AO's disallowance under s.40A(3) read with Rule 6DD of cash consideration paid for purchase of land. The Tribunal found the firm proved identity of vendors, linkage of cash payments to same-day bank withdrawals, and business expediency (vendors' insistence on cash); payments were recorded in sale deeds and made before sub-registrars. Absent any positive finding that the explanation was false, the statutory disallowance could not be imposed. The Tribunal held the transaction fell within recognised exceptions and quashed the addition, allowing the assessee's grounds.
ITAT allowed the appeal of the assessee-firm and reversed the AO's disallowance under s.40A(3) read with Rule 6DD of cash consideration paid for purchase of land. The Tribunal found the firm proved identity of vendors, linkage of cash payments to same-day bank withdrawals, and business expediency (vendors' insistence on cash); payments were recorded in sale deeds and made before sub-registrars. Absent any positive finding that the explanation was false, the statutory disallowance could not be imposed. The Tribunal held the transaction fell within recognised exceptions and quashed the addition, allowing the assessee's grounds.
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