2001 (1) TMI 51

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....cts and circumstances of the case, the Tribunal is right in holding that the case of the assessee falls in the second proviso to section 40A(3) and rightly deleted the disallowance of Rs. 14,58,691 ?" The Supreme Court, considering the second proviso to section 40A(3) of the Income-tax Act, 1961, observed as under (see Attar Singh Gurmukh Singh v. ITO [1991] 191 ITR 667, 673 (SC) : "The payment ....