Burmah Devi W/O. Gokul Chand, Rewari vs. ITO Ward -1, Rewari
In the result, the grounds and appeal filed by the assessee are allowed
ITA 9555/DEL/2019[2009-10]Status: DisposedITAT Delhi11 Sept 2024AY 2009-10
Bench: Shri S.Rifaur Rahman & Shri Sudhir Kumarburmah Devi, Vs. Ito, Ward 1, W/O Gokul Chand, Rewari. Flat No.133, Shanti Lok Society, Sector 3, Bawal Road, Rewari (Haryana). (Pan : Apzpd7437E) (Appellant) (Respondent) Assessee By : Shri Pranav Yadav, Advocate Revenue By : Shri Kanv Bali, Sr. Dr Date Of Hearing : 18.07.2024 Date Of Order : 11.09.2024 Order Per S.Rifaur Rahman,Am: This Appeal Has Been Filed By The Assessee Against The Order Of Learned Commissioner Of Income Tax (Appeals), Rohtak [“Ld. Cit(A)”, For Short] Dated 23.10.2019 For Assessment Year 2009-10. 2. Brief Facts Of The Case Are, Original Assessment Was Made Under Section 143 (3) Of The Income-Tax Act, 1961 (For Short “The Act”) Vide Order Dated 28.11.2011. While Framing Assessment, The Ao Observed That The Assessee Made Cash Payments Of Rs.77,47,703/- Against Purchase Of Goods & Also Made
For Appellant: Shri Pranav Yadav, AdvocateFor Respondent: Shri Kanv Bali, Sr. DR
Section 143Section 40A(3)
…the similar issue on record, Hon’ble Punjab & Haryana High Court in the case of Gurdas Garg vs. CIT (A) (supra) has held as under :- “8. The respondent's case is also supported by the judgment of the Supreme Court in Attar Singh Gurmukh Singh vs. ITO, (1991) 4 SCC 385. After referring to Rule 6DD, the Supreme Court held:- "7. In our opinion, there is little merit in this contention. Section 40- A(3) must not be read in isolation or to the exclusion of Rule 6-DD. The section must be read along with the rule. If read together, it will be clear that the provisions are not intended to restrict the business activitie…