Section 40A(3) Terms Not Absolute; Rule 6DD Circumstances Not Exhaustive

Smt. Shashikala Ram Kumar Vs ACIT (Hyderabad)

Assesee disputed additions made u/s40(a)(ia) & 40A(3) before the CIT (A) and produced certificates under proviso to section 201(1) whereby CIT(A) deleted the 40(a)(ia) addition but confirmed the addition u/s40A(3). On further appeal before the the Tribunal Revenue contended that unless the assessee proves the circumstances under rule 6DD, he cannot claim any exception to sec 40A(3).

Assessee produced a certificate issued by

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