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TMI Blog2018 (2) TMI 1834X X X X Extracts X X X X X X X X Extracts X X X X ..... one taken by the Coordinate Bench in the matter of Assistant Commissioner of Income Tax- Circle- 1(2) vs M/s R.P. Real Estate Pvt. Ltd. [ 2016 (3) TMI 1303 - CHHATTISGARH HIGH COURT] this Court held that once the Appellate Court and the Tribunal have concurrently found that the explanation offered by the assessee as to why the cash payments made to the sellers is acceptable, the same does not inv ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... #39;s appeal against the order passed by the AO, imposing tax liability to the tune of ₹ 3,41,84,000/- applying Section 40A(3) of the Income Tax Act, 1961 (henceforth, the Act). 3. Section 40A(3) of the Act provides that any expenditure in respect of which a payment or aggregate of payments made to a person in a day, otherwise than by an account payee cheque drawn on a bank or an account ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the deal was made in the presence of competent authority, which has cross checked the payments, therefore, the entire deal having been made in a legally permissible and transparent manner, there was no intention to evade tax. 6. While allowing the appeal the CIT (Appeals) also referred to the order passed by the Coordinate Bench of this Court in Tax Case No. 13 of 2016 decided on 01.03.2016, t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... to hold that once the Appellate Court and the Tribunal have concurrently found that the explanation offered by the assessee as to why the cash payments made to the sellers is acceptable, the same does not involve any substantial question of law as the reasoning assigned and the interpretation applied by the Tribunal and the CIT (Appeals) are duly supported by the judicial precedents. 8. In vie ..... X X X X Extracts X X X X X X X X Extracts X X X X
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