2025 (2) TMI 1852

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.... Sr. DR ORDER PER SATBEER SINGH GODARA, JM This assessee's appeal for assessment year 2018-19 arises against the Commissioner of Income Tax (Appeals)/National Faceless Appeal Centre [in short, the "CIT(A)/NFAC"], Delhi's DIN and order no. ITBA/NFAC/S/250/2023-24/1057270539(1) dated 20.10.2023 involving proceedings under section 143(3) of the Income-tax Act, 1961 (hereinafter referred to a....

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....4. That Ld. CIT(A) completely failed to appraise the submission of the appellant substantiating the fact that the cash payment in excess of the prescribed limit was made to D.V.N.L. (Dakshinanchal Vidyut Vitran Nigam Ltd) which is wholly owned Government Undertaking and as such is completely covered under the provisions of Rule 6DD of the Income Tax Rules 1961. 5. That the appellant crave....

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.... (1991) 191 ITR 667 (SC) that the impugned disallowance deserves to be upheld. 5. We have given our thoughtful consideration to the assessee's pleadings and the Revenue's vehement contentions. We find no merit to sustain the impugned disallowance. This is for the precise reason that not only the assessee has made payments in cash to the above stated payee but also it is a wholly owned Governmen....