https://www.taxtmi.com/caselaws?id=178141 ITAT Cochin considered three income-tax issues. It treated an alleged admission before the Assessing Officer as determinative on the section 40(a)(ia) disallowance because no affidavit or contrary material was produced, and sustained that addition. On cash purchases of fish under section 40A(3), it held that the rule 6DD(e)(iii) and CBDT circular exception depends on proving that the payee was a fisherman, headman of fishermen, or authorised person and not a trader or middleman; the matter was remanded for fresh factual verification. It also held that section 40(a)(ia) applies to amounts payable during the year as well as balances outstanding at year-end, so the freight and clearing charges disallowance was upheld. en-us Wed, 24 Sep 2014 00:00:00 +0530 Mon, 15 Feb 2016 16:45:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=178141 ITAT Cochin considered three income-tax issues. It treated an alleged admission before the Assessing Officer as determinative on the section 40(a)(ia) disallowance because no affidavit or contrary material was produced, and sustained that addition. On cash purchases of fish under section 40A(3), it held that the rule 6DD(e)(iii) and CBDT circular exception depends on proving that the payee was a fisherman, headman of fishermen, or authorised person and not a trader or middleman; the matter was remanded for fresh factual verification. It also held that section 40(a)(ia) applies to amounts payable during the year as well as balances outstanding at year-end, so the freight and clearing charges disallowance was upheld. Case-Laws Income Tax Wed, 24 Sep 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=178141