https://www.taxtmi.com/caselaws?id=784604 Disallowance under s.40A(3) for cash payment of commission and salary was held unsustainable because the amounts were withdrawn through supervisors acting as agents for onward payment to workers, and individual payments did not exceed the statutory threshold; applying the HC ratio that such agency payments fall outside s.40A(3), the deletion of 20% disallowance was upheld and the Revenue's challenge failed. On admission of additional evidence, the appellate authority found that the material was already before the AO and was misappreciated, rendering r.46A inapplicable; consequently, the Revenue's objection on this ground was rejected and its appeal was dismissed. en-us Tue, 23 Dec 2025 00:00:00 +0530 Thu, 08 Jan 2026 08:36:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=784604 Disallowance under s.40A(3) for cash payment of commission and salary was held unsustainable because the amounts were withdrawn through supervisors acting as agents for onward payment to workers, and individual payments did not exceed the statutory threshold; applying the HC ratio that such agency payments fall outside s.40A(3), the deletion of 20% disallowance was upheld and the Revenue's challenge failed. On admission of additional evidence, the appellate authority found that the material was already before the AO and was misappreciated, rendering r.46A inapplicable; consequently, the Revenue's objection on this ground was rejected and its appeal was dismissed. Case-Laws Income Tax Tue, 23 Dec 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=784604