Double Taxation Concerns: Payments Already Taxed at Same Rate Shouldn't Face Disallowance u/s 40A(2)(b.

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....As the amount paid by the assessee to specific persons are taxed in the hands of specific persons at the same rate , disallowance u/s 40A(2)(b) will be meaningless inasmuch as “permitting the Revenue to tax the same income again at the same rate in the hand of principal payer would amount to double taxation".....