No section 40A(3) addition for Cash Payments to Agriculturists for crop

Bappanalli Brothers Vs ACIT (ITAT Banglore) CIT(A) concluded that the payments were not made directly to the cultivator and therefore the Assessee has not proved existence of circumstances set out in Rule 6DD(e) of the rules. ITAT held that The reasons given by the CIT(A) for treating the payment in question not to the Agriculturists but to R.G.Bhat, who is alleged to be an intermediary, cannot be sustained especially when the two agriculturists have affirmed in an affidavit that they received payment through R. G. Bhat and when the cheques in question, though bearer cheques, were cheques issu...