2026 (3) TMI 540

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....i Ajay Uke, Sr DR ORDER PER DR. B.R.R. KUMAR, VICE-PRESIDENT:- Delay condoned. This appeal has been filed by the assessee against the order dated 11.03.2025 passed by the Ld. Commissioner of Income-tax (Appeals), National Faceless Appeal Centre (NFAC), Delhi (hereinafter referred to as the "Ld. CIT(A)" for short), under Section 250 of the Income-tax Act, 1961 (hereinafter referred to a....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....cash payments exceeding the prescribed limit to various persons in a day, aggregating to Rs. 1,90,36,240/-. The Assessing Officer held that such payments violated the provisions of section 40A(3) of the Act and accordingly disallowed the same. The assessee contended before the Assessing Officer that he was acting as a commission agent and the impugned amounts represented payments made to farmers a....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....his own account. The Ld. AR produced before us copies of mandi parchi (receipts), cash book, affidavits of farmers and revenue records were placed on record. The Ld. AR also submitted the copy of CBDT Circular No. 452 dated 17.03.1986, which clarifies distinction between kachha arhatia and pacca arhatia. The Ld. AR, thus, submitted that the payments made to cultivators of agricultural produce are ....