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Issues:
Application of section 40A(3) of the Income-tax Act, 1961 and rule 6DD(j) of the Income-tax Rules, 1962 to cash payments exceeding Rs. 2,500 in purchase transactions. Analysis: The case involved Bherwa Fertilizers, Pali, making cash payments exceeding Rs. 2,500 in purchase transactions with Kisan Agro Service Centre, Pali, leading to a disallowance of deductions by the Income-tax Officer under section 40A(3) of the Income-tax Act, 1961. The Commissioner of Income-tax upheld the decision, but the Income-tax Appellate Tribunal, Jaipur Bench, Jaipur, allowed the deductions under rule 6DD(j) of the Rules. The Tribunal emphasized the genuineness of payments and the quick nature of fertilizer transactions. However, the Tribunal failed to consider all aspects of rule 6DD(j), prompting a reference to the High Court. The High Court was tasked with determining the applicability of rule 6DD(j) and section 40A(3) to the case. The Court noted that while the Tribunal correctly applied both provisions, it failed to provide findings on exceptional or unavoidable circumstances justifying the cash payments. Consequently, the Court remitted the matter back to the Tribunal for a fresh decision considering the specific requirements of rule 6DD(j) in light of previous judgments and guidelines issued by the Central Board of Direct Taxes. The Court highlighted the need for the Tribunal to assess whether the cash payments met the exceptional circumstances outlined in rule 6DD(j) and stressed that the burden of proof lies with the assessee to demonstrate the genuineness of the transactions. The Court emphasized that even if a transaction is genuine, it must fall within the exceptions specified in rule 6DD(j) to qualify for deductions. The Court directed the Tribunal to reevaluate the case based on these principles and issued guidelines for future assessments of similar cases. In conclusion, the High Court clarified the requirements for applying rule 6DD(j) and section 40A(3) to cash payments exceeding Rs. 2,500 in purchase transactions, emphasizing the need for thorough assessment of exceptional circumstances and genuine transactions. The case was remitted to the Tribunal for a fresh decision in line with the Court's observations and guidelines provided.
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