Court Examines Section 40A(3) Compliance on Non-Account Payee Payments; Assessee Used RTGS/NEFT Despite Available Banking Facilities.

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....Addition u/s 40A(3) - Payments made otherwise than by an account payee cheque - It is admitted case of assessee that to one of the parties even payments were made by RTGS/NEFT. So there is no question of lack of banking facilities available with the assessee or that when the payments were made such facility was not accessible. - When the provision of Section 40A(3) is made in the Act with specific intention to discourage colourable payments then the Ld. Tax Authorities below cannot be expected to accept such casual explanations. - AT....