Aggregate Cash Payments Can’t Trigger Section 40A(3) Disallowance

ITO Vs Satish Singh (ITAT Kolkata) Rule 46A Not Attracted Where Evidence Was Already on Record: ITAT Upholds Deletion of ₹2.75 Cr Disallowance- High-Pitched 40A(3) Disallowance Rejected: Daily Cash Payments Within Limit Held Allowable Kolkata ITAT ‘D’ Bench in ITO vs Satish Singh (ITA No.449/Kol/2025, AY 2018-19, order dated 23-12-2025) dismissed Revenue’s appeal and upheld deletion of ₹2.75 crore disallowance u/s 40A(3), holding that cash payments of salary and commission did not exceed the statutory per-day limit and that Rule 46A was not violated. The assessee, an individual enga...