No infringement of Section 40A(3) four cash payment for seeds to villagers & tribals in naxalite area

Bharat Agro Industries Vs ITO (ITAT Raipur) The first allegation concerns infringement of Section 40A(3) of the Act and consequent applicability of Section 40(a)(ia) of the Act. In this regard, it is the case of the assessee that purchases were made from villagers/Tribals who are procuring the seeds and supplying the same to the assessee. Payments were made to the suppliers only. The Sarpanch of several villages have provided sworn statements to the effect that supplies of seeds were made. The copy of identity proof of Sarpanch, villagers and tribals were also furnished. It is thus contended t...