TaxTMI 
TaxTMI 
1976 (9) TMI 65
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....sioner, whereby he deleted the addition of Rs. 5,595 made by the Income-tax Officer under. S. 40 A(3) in the assessment year 1974-75. 2. The assessee is a registered firm. The relevant assessment year is 1974-75 corresponding to the accounting year ending on Diwali, 1973. The assessee firm has been carrying on the business of manufacturing of aluminium utensils. The assessee purchased goods wor....
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....is now in appeal before the Income-tax Appellate Tribunal. The learned departmental representative vehemently submitted that under rule 6DD (j) three conditions have to be fulfilled before the amount could be allowed as a deduction. Since the assessee's case does not fall within the exceptions provided therein, the assessee's is not entitled to the deduction. 5. The assessee's representative, o....
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....or utensils. For this purpose, the assessee had to purchase the goods from small and petty hawkers. This business is not carried on, on an organised scale and the purchases cannot, therefore, be made from established dealers. The assessee per force has to purchase the goods form the hawkers, who do not have any account books, cash memos or any other banking facilities. The assessee has, therefore,....
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....ional or unavoidable circumstances. (ii) Because payment in the manner aforesaid was not practicable or would have caused genuine difficulties to the payee having regarding to the nature of the transaction and the necessity for expeditious settlement thereof, and also furnishes evidence to the satisfaction of the Income-tax Officers as to the genuineness of the payment and the identity of the p....