Section 40A(3) Exceptions of Rule 6DD are not exhaustive and must be interpreted liberally

Significantly paragraph 5 of Circular by the Board on May 31, 1977 ([1977] 108 ITR (St.) 8) reproduced herein below gives a clear indication that Rule 6DD(j) has to be liberally construed and ordinarily where the genuineness of the transaction and the payment and identity of the receiver is established, the requirement of Rule 6DD(j) must be deemed to have been satisfied. Paragraph 5 of the Circular reads as under [1977] 108 ITR (St.) 8, 9: 5. It can be said that it would, generally, satisfy the requirements of Rule 6DD(j), if a letter to the above effect is produced in respect of each transa...