2010 (11) TMI 797

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..... mount was paid to the contractor which was collected on behalf of the State Government as such no disallowance could have been made in view of r. 6DD(b). The Government has granted contract to collect the royalty to the contractor. The payment was made to the contractor not in individual capacity, but on behalf of the Government of Rajasthan, hence, no disallowance under r. 6DD(b) could have been .....

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..... he AO disallowed 20 per cent of the amount as the payment exceeded Rs. 20,000; payment to the extent of Rs. 61,77,445 was made in cash. Explanation of the assessee in this regard was that during the year the assessee had paid Rs. 64,00,384 as royalty to the State Government and as per policy of the State Government, royalty is collected by the contractor on behalf of the Government and payment to .....

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..... in view of r. 6DD(b). The Government has granted contract to collect the royalty to the contractor. The payment was made to the contractor not in individual capacity, but on behalf of the Government of Rajasthan, hence, no disallowance under r. 6DD(b) could have been made. 7. In our opinion CIT(A) and Tribunal have not committed any illegality in passing the orders. 8. No substantial ques .....

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