How many judgments cite Attar Singh Gurmukh Singh v. ITO?

254 judgments on BharatTax cite Attar Singh Gurmukh Singh v. ITO (191 ITR 667), spanning 2015 to 2026.

Which sections of the Income Tax Act does Attar Singh Gurmukh Singh v. ITO come up under?

It is most often cited in judgments turning on Section 40A(3), Section 143(3), Section 133A, Section 143(1), Section 143(2), Section 153A.

Attar Singh Gurmukh Singh v. ITO

191 ITR 667Supreme Court of India1991#331 most cited

What is Attar Singh Gurmukh Singh v. ITO authority for?

Section 40A(3) is not absolute, and its application considers business expediency, practical difficulties, and other relevant factors, while keeping in mind its objective to curb the practice of ploughing unaccounted money into the system.

254

judgments rely on this decision, according to BharatTax’s citation analysis of 367,854 Indian tax judgments — from 2015 to 2026.

Also referred to as

Attar Singh Gurmukh Singh v. ITO · Section 40A(3) · Rule 6DD · cash payments disallowance · business expediency · practical difficulties · genuineness of transaction · objective of Section 40A(3) · unaccounted money · profits and gains of business or profession

Also reported as

59 Taxmann 114 SCC 38559 Taxmann.com 11

Sections most often in play

Section 40A(3)Section 143(3)Section 133A Section 143(1)Section 143(2)Section 153A Section 6DD Section 132(4)

Read the full judgment

Issues it is cited on

section 40a(3)business expediency section 40a section 40 profits and gains of business or profession section 40(a)genuineness of the transaction section 132(4)section 131 undisclosed income incriminating material section 132

Judgments citing Attar Singh Gurmukh Singh v. ITO

Giant Construction Company, Saidapet vs. ACIT, CC -1(4), Chennai

In the result, the appeal filed by the assessee is dismissed

ITA 435/CHNY/2021[2015-16]Status: DisposedITAT Chennai26 Apr 2023AY 2015-16

Bench: Shri V. Durga Rao & Dr. Manish Boradआयकर अपील सं./I.T.A. No.435/Chny/2021 िनधा"रण वष"/Assessment Year: 2015-16 M/S. Giant Construction Company, Vs. The Assistant Commissioner Of 19/10 F1, Rangarajapuram, 4Th Street, Income Tax, Saidapet, Chennai 600 015. Central Circle 1(4), Chennai. [Pan:Aakfg4335N] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri I. Dinesh. Advocate ""थ" की ओर से/Respondent By : Shri P. Sajit Kumar, Jcit सुनवाई की तारीख/ Date Of Hearing : 20.04.2023 घोषणा की तारीख /Date Of Pronouncement : 26.04.2023 आदेश /O R D E R Per V. Durga Rao: This Appeal Filed By The Assessee Is Directed Against The Order Of The Ld. Commissioner Of Income Tax (Appeals) 18, Chennai, Dated 31.08.2021 Relevant To The Assessment Year 2015-16. 2. Brief Facts Of The Case Are That The Assessee Is A Construction Company, A Firm Engaged In The Business Of Executing Civil Contract Work For Pwd Department & Railways. The Partners Of The Assessee Firm Were Shri K. Don Alex Raja, Shri P. Janakar & Shri S. Senthilkumar

For Appellant: Shri I. Dinesh. AdvocateFor Respondent: Shri P. Sajit Kumar, JCIT

Section 115BSection 132Section 153CSection 40A(3)

…आयकर अपीलीय अिधकरण, ‘सी’ "ायपीठ, चे"ई IN THE INCOME-TAX APPELLATE TRIBUNAL ‘C’ BENCH, CHENNAI "ी वी दुगा" राव, "ाियक सद" एवं डॉ. मनीष बोराड, लेखा सद" के सम" BEFORE SHRI V. DURGA RAO, JUDICIAL MEMBER AND DR. MANISH BORAD, ACCOUNTANT MEMBER आयकर अपील सं./I.T.A. No.435/Chny/2021 िनधा"रण वष"/Assessment Year: 2015-16 M/s. Giant Construction Company, Vs. The Assistant Commissioner of 19/10 F1, Rangarajapuram, 4th Street, Income Tax, Saidapet, Chennai 600 015. Central Circle 1(4), Chennai. [PAN:AAKFG4335N] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant by : Shri I. Dinesh. Advocate ""थ" की ओर से/Resp…

Rajesh Kumar, New Delhi vs. ITO, Ward- 35(1), New Delhi

ITA 139/DEL/2018[2013-14]Status: DisposedITAT Delhi26 Apr 2023AY 2013-14

Bench: Sh. Shamim Yahya & Sh. Anubhav Sharmaita No. 139/Del/2018, A.Y. 2013-14

Section 143(3)Section 40A(3)

…compelling factors payment was required in cash. There are judicial pronouncements, as also relied by Ld. AR, that even after amendment of Rule 6DD(j), the legal exposition propounded by the Hon’ble Supreme Court in case of Attar Singh Gurmukh Singh Vs. ITO, 191 ITR 667 (SC), regarding consideration of expediency and other relevant factors cannot be considered to be diluted as the rules framed by way of delegated legislation cannot override the substantive legislation in form of section 40A(3) which has not changed its character. 6.2 The Boards Circular no 220 has been considered in various judicial pronouncemen…

T.Rajendran, Chennai vs. ACIT Non Corporate Circle 20, Chennai

In the result, appeal filed by the assessee is allowed

ITA 2032/CHNY/2019[2012-13]Status: DisposedITAT Chennai13 Apr 2023AY 2012-13

Bench: Shri V. Durga Rao, Hon’Ble & Shri Manjunatha. G, Hon’Bleआयकर अपील सं./Ita No.: 2032/Chny/2019 िनधा"रण वष" / Assessment Year: 2012-13

For Respondent: Shri. AR V Sreenivasan, Addl. CIT

Section 143(3)Section 40A(3)

…ch clear that no disallowance under section 40A(3) can be made, if the transaction for which the payment is made is genuine and due to business expediency and other compelling factors payment was required in cash. In case of Attar Singh Gurmukh Singh Vs. ITO, 191 ITR 667 (SC), the Hon’ble Supreme Court while interpreting the provisions of section 40A(3) read with Rule 6DD has held as under: “6. As to the validity of section 40A(3), it was urged that if the price of the purchased material is not allowed to be adjusted against the sale price of the material sold for want of proof of payment by a crossed cheque or c…

Bandel Thermal Power Employees Co-Operative Stores Ltd., Hooghly vs. A.C.I.T., Circle - 23(1), Hooghly

In the result, the appeal filed by the assessee is partly allowed

ITA 717/KOL/2022[2014-2015]Status: DisposedITAT Kolkata28 Mar 2023AY 2014-2015

Bench: Sri Sanjay Garg & Dr. Manish Borad

Section 143(3)Section 250Section 36Section 40A(3)

…ture for reducing the tax liability. 8. We, therefore, in view of the judicial pronouncements as held by this Tribunal in case of Sri Manoranjan Raha vs. ITO in ITA No. 1448/kol/2011 order dated 18.11.2015, Attar Singh Gurmukh Singh vs. ITO reported in (1991) 191 ITR 667 (SC), CIT vs. CPL Page 3 of 5 I.T.A. No.: 717/KOL/2022 Assessment Year: 2014-2015 Bandel Thermal Power Employees Cooperative Stores Ltd. Tannery reported in (2009) 318 ITR 179 (Cal) and considering the facts that the alleged sum has been paid towards business expediency obligation and the transactions are genuine, set aside the finding of ld. CI…

B Saravanan, Trichy vs. ITO Non Corporate Ward 12(1), Chennai

In the result, appeal filed by the assessee is dismissed

ITA 721/CHNY/2018[2009-10]Status: DisposedITAT Chennai15 Mar 2023AY 2009-10

Bench: Shri Mahavir Singh, Hon’Ble & Shri Manjunatha.G, Hon’Ble

For Appellant: Mr.S.Sridhar, AdvFor Respondent: Mr. AR.V.Sreenivasan

Section 133(6)Section 143(3)Section 194CSection 40Section 40A(3)Section 69D

…High Court respectively have held that the Section is inapplicable, when genuine payment is made to identifiable parties out of disclosed sources, 4. The terms of Section 40A(3) are not absolute according to Allahabad High Court (217 ITR 431), which followed 191 ITR 667 SC; other decisions holding so are: i. 167 ITR 139 Raj ii. 179 ITR 122 Cal iii. 191 ITR 667 SC iv. 200 ITR 490 Del v. 216 ITR 366 Gau vi. 225 ITR 57 Gau vii. 240 ITR 902 Gau viii. 265 ITR 121 Guj ix. 298 ITR 349 Raj x. 366 ITR 122 Gau 5. Even though identical Section 69D requires hundi transactions to be had only by A/c payee cheques, 219 ITR 2…

Jatin Garg & Sons (HUF), New Delhi vs. ITO, Ward-36(5), New Delhi

Appeal of the assessee is dismissed

ITA 5652/DEL/2018[2015-16]Status: DisposedITAT Delhi07 Mar 2023AY 2015-16

Bench: Shri Kul Bharat

Section 143(2)Section 68

…the absence of. any direct evidence, a judicial or quasi judicial Tribunal can base its conclusions on the basis of what are known as notorious facts bearing in mind tlte principles of Section 144 of tlte Evidence Act. " [b] Attar Singh Gurumukh Singh Vs ITO, 191 ITR 667 [SCL wherein, while interpreting the provisions of Section 40A(3), it was held that:- "In interpreting a taxing statute, the court cannot be oblivious of the proliferation of black money which is under circulation in our country." CIT Vs. Durga That though an appellant’s statement must be considered real until Prasad More it was shown that there…

Siddhbali Metals, Delhi vs. ITO, Ward-2(4), Faridabad

Appeal is allowed for statistical purpose

ITA 774/DEL/2020[2016-17]Status: DisposedITAT Delhi19 Jan 2023AY 2016-17

Bench: Shri Kul Bharat

Section 143(1)Section 143(3)Section 147Section 40A(3)

…nsaction is verified and identity of payee is of no doubt then there is no violation of this section. I. Hon'ble ITAT, Delhi in Shri Radhey Shyam Manchanda case (ITA No. 5238/Del/2016) taking cognizance of Attar Singh Gurmukh Singh vs. ITO reported in (1991) 191 ITR 667 (SC):- It will be clear that the provisions are not intended to restrict business activities and genuine and bonafide transactions are kept out of purview of this section, crux at page no. 55 of compilation of case laws. 7 10. That AO himself admitted that the purchase made by applicant firm from M/s Vasu Steel is genuine which was supported b…

Bhandarkar Jewellers, Nagpur vs. Income Tax Office Ward 1(1), Nagpur

Appeal is allowed in above terms

ITA 60/NAG/2019[2013-14]Status: DisposedITAT Nagpur23 Dec 2022AY 2013-14

Bench: Shri S. S. Godaraआयकर अपील सं. / Ita No.60/Nag/2019 िनधा"रण वष" / Assessment Year: 2013-14 Bhandarkar Jewellers, Vs. Ito, Ward- 1(1), Nagpur. Shop No.1, Jyeshta Apartments, Ring Road, Bhamti Parsodi, Nagpur- 440022. Pan : Aaifb4042M Appellant Respondent Assessee By : None Revenue By : Shri G. J. Ninawe Date Of Hearing : 02.11.2022 Date Of Pronouncement : 27.12.2022 आदेश / Order Per S. S. Godara, Jm: This Assessee’S Appeal For Assessment Year 2013-14 Arises Against The Cit(A)-1, Nagpur’S Order Dated 20.12.2018 Passed In Case No. Cit(A)-1/60/2016-17, Involving Proceedings U/S 143(3) Of The Income Tax Act, 1961; In Short “The Act”. Case Called Twice. None Appears At Assessee’S Behest. It Is Accordingly Proceeded Ex-Parte. 2. It Is Noticed With The Able Assistance From The Revenue Side That The Assessee’S Sole Substantive Grievance Challenges Correctness Of Both The Learned Lower Authorities’ Action Disallowing Interest

For Appellant: NoneFor Respondent: Shri G. J. Ninawe

Section 143(3)Section 40A(3)

…IN THE INCOME TAX APPELLATE TRIBUNAL NAGPUR BENCH, NAGPUR – VIRTUAL COURT BEFORE SHRI S. S. GODARA, JUDICIAL MEMBER आयकर अपील सं. / ITA No.60/NAG/2019 िनधा"रण वष" / Assessment Year: 2013-14 Bhandarkar Jewellers, Vs. ITO, Ward- 1(1), Nagpur. Shop No.1, Jyeshta Apartments, Ring Road, Bhamti Parsodi, Nagpur- 440022. PAN : AAIFB4042M Appellant Respondent Assessee by : None Revenue by : Shri G. J. Ninawe Date of hearing : 02.11.2022 Date of pronouncement : 27.12.2022 आदेश / ORDER PER S. S. GODARA, JM: This assessee’s appeal for assessment year 2013-14 arises against the CIT(A)-1, Nagpur’s order dated 20.12.2018 passe…

ITO, Corporate Ward - 6 (3), Chennai vs. Shivaji Hi-Tek Foods Pvt. Ltd., Chennai

The appeal stands dismissed

ITA 111/CHNY/2020[2016-17]Status: DisposedITAT Chennai21 Dec 2022AY 2016-17

Bench: Hon’Ble Shri Mahavir Singh & Hon’Ble Shri Manoj Kumar Aggarwal, Am

For Appellant: Shri Anandd Babunath (CA)-Ld. ARFor Respondent: Shri ARV Sreenivasan (Addl. CIT) –Ld. DR

Section 131Section 143Section 40A(3)

…आयकर अपीलीय अिधकरण ‘ए’ "ायपीठ चे"ई म"। IN THE INCOME TAX APPELLATE TRIBUNAL ‘A’ BENCH, CHENNAI माननीय +ी महावीर िसंह, उपा12 एवं माननीय +ी मनोज कुमार अ6वाल ,लेखा सद9 के सम2। BEFORE HON’BLE SHRI MAHAVIR SINGH, VICE PRESIDENT AND HON’BLE SHRI MANOJ KUMAR AGGARWAL, AM आयकर अपील सं./ ITA No.111/Chny/2020 (िनधाBरण वषB / Assessment Year: 2016-17) Income Tax Officer Shivaji Hi-Tek Foods Pvt. Ltd. बनाम Corporate Ward-6(3), No.100, Medavakkam Main Road, / Vs. Chennai. Kilkattalai, Chennai-600 117. "थायी लेखा सं./जीआइ आर सं./PAN/GIR No. AAVCS-9492-E (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ" की ओरसे/ Assessee by :…

M/S H. K. Infraventure Pvt. Ltd, Varansi vs. Joint. Commissioner of Income Tax, Central Circle, Varansi

ITA 46/ALLD/2019[2012-13]Status: DisposedITAT Allahabad12 Dec 2022AY 2012-13

Bench: Shrivijay Pal Rao & Shri Ramit Kochar

For Appellant: Shri Praveen Godbole, C.AFor Respondent: Shri Ramendra Kumar Viswakarma,CITD.R

Section 143(2)Section 143(3)Section 269SSection 271D

…has shown the same in its books of accounts as loan from Director. Our attention was drawn to page 39-43 of paper book. The ld. CIT-DR relied upon judgment and order of Hon’ble Supreme Court in the case of Attar Singh Gurumukh Singh v. ITO, reported in (1991) 191 ITR 667(SC). The ld. CIT-DR would also rely on judgment and order of Hon’ble Delhi High Court in the case of CIT v. Samora Hotels Private Limited, reported in (2012) 211 Taxman 189(Delhi). It was submitted by ld. CIT- DR that Director of the company is covered under the provisions of Section 269SS read with Section 271D , and if contravention of Section…

Rupesh Vyas, Indore vs. The ACIT3(1), Indore

In the result, this appeal of assessee is dismissed

ITA 909/IND/2018[2014-15]Status: DisposedITAT Indore07 Dec 2022AY 2014-15

Bench: Ms. Suchitra Kamble & Shri B.M. Biyani

Section 10(38)Section 143(3)Section 68Section 69C

…think likely to have happened in the course of normal conduct of public and private business. For this purpose, I rely on the ratio of the following judgments, wherein the doctrine of 'notorious fact' has been taken note of. (i) CWT Vs. Tohtah Industries Ltd. 67 ITR 283, Malini R Rele Vs. ITO 205 ITR 52 (Mumbai) ITAT Third Member. (ii) While analyzing the facts of this case, it is kept in mind that the proceedings under Income Tax Act are not judicial proceedings in the sense in which the phrase 'judicial proceedings' is ordinarily used. The Assessing Officer is not fettered or bound by technical rules about evid…

Rupesh Vyas, Indore vs. The ACIT3(1), Indore

In the result, this appeal of assessee is dismissed

ITA 50/IND/2020[150-16]Status: DisposedITAT Indore06 Dec 2022

Bench: Shri T.R. Senthil Kumar & Shri B.M. Biyani

Section 10(38)Section 143(3)Section 68Section 69C

ACIT, New Delhi vs. M/S. Nagar Dairy Pvt. Ltd., New Delhi

In the result, C.O. Nos. 26, 27 & 28/Del/2016 filed by the assessee are allowed, accordingly the Assessment Orders dated 28

ITA 5473/DEL/2015[2009-10]Status: DisposedITAT Delhi23 Nov 2022AY 2009-10

Bench: Dr. B. R. R. Kumar & Sh. Yogesh Kumar U.S.

Section 153CSection 271(1)(c)Section 40A(3)

…Act is not attracted where the parties are identified and there is no material on record to doubt the genuineness of payments. - in this regard reference is made to the judgment of Hon’ble Supreme Court in the case of Attar Singh Gurmukh Singh vs. ITO (1991) 191 ITR 667, 673 (SC). The ld. CIT(A) on page 230 has observed that “the appellant has submitted the details during the course of assessment proceedings u/s 153C to substantiate its claim that all the payments in excess of Rs. 20,000/- were made on holidays, etc. as per Rule 6DD. The appellant has also furnished the total purchases of milk in cash under the…

ACIT, New Delhi vs. M/S. Nagar Dairy Pvt. Ltd., New Delhi

In the result, C.O. Nos. 26, 27 & 28/Del/2016 filed by the assessee are allowed, accordingly the Assessment Orders dated 28

ITA 5472/DEL/2015[2008-09]Status: DisposedITAT Delhi23 Nov 2022AY 2008-09

Bench: Dr. B. R. R. Kumar & Sh. Yogesh Kumar U.S.

Section 153CSection 271(1)(c)Section 40A(3)

ACIT, New Delhi vs. M/S. Nagar Dairy Pvt. Ltd., New Delhi

In the result, C.O. Nos. 26, 27 & 28/Del/2016 filed by the assessee are allowed, accordingly the Assessment Orders dated 28

ITA 5471/DEL/2015[2007-08]Status: DisposedITAT Delhi23 Nov 2022AY 2007-08

Bench: Dr. B. R. R. Kumar & Sh. Yogesh Kumar U.S.

Section 153CSection 271(1)(c)Section 40A(3)

ACIT, New Delhi vs. M/S. Nagar Dairy Pvt. Ltd., New Delhi

In the result, C.O. Nos. 24 & 25/Del/2016 filed by the assessee are allowed, accordingly the Assessment Orders dated 28

ITA 5470/DEL/2015[2006-07]Status: DisposedITAT Delhi22 Nov 2022AY 2006-07

Bench: Dr. B. R. R. Kumar & Sh. Yogesh Kumar U.S.

For Respondent: “On the facts and in the circumstances of the case

Section 153CSection 271(1)(c)Section 40A(3)

…Act is not attracted where the parties are identified and there is no material on record to doubt the genuineness of payments. - in this regard reference is made to the judgment of Hon’ble Supreme Court in the case of Attar Singh Gurmukh Singh vs. ITO (1991) 191 ITR 667, 673 (SC). The ld. CIT(A) on page 230 has observed that “the appellant has submitted the details during the course of assessment C.O. Nos. 24 & 25/Del/2016 Nagar Dairy Pvt. Ltd. proceedings u/s 153C to substantiate its claim that all the payments in excess of Rs. 20,000/- were made on holidays, etc. as per Rule 6DD. The appellant has also furnis…

ACIT, New Delhi vs. M/S. Nagar Dairy Pvt. Ltd., New Delhi

In the result, C.O. Nos. 24 & 25/Del/2016 filed by the assessee are allowed, accordingly the Assessment Orders dated 28

ITA 5469/DEL/2015[2005-06]Status: DisposedITAT Delhi22 Nov 2022AY 2005-06

Bench: Dr. B. R. R. Kumar & Sh. Yogesh Kumar U.S.

For Respondent: “On the facts and in the circumstances of the case

Section 153CSection 271(1)(c)Section 40A(3)

…Act is not attracted where the parties are identified and there is no material on record to doubt the genuineness of payments. - in this regard reference is made to the judgment of Hon’ble Supreme Court in the case of Attar Singh Gurmukh Singh vs. ITO (1991) 191 ITR 667, 673 (SC). The ld. CIT(A) on page 230 has observed that “the appellant has submitted the details during the course of assessment C.O. Nos. 24 & 25/Del/2016 Nagar Dairy Pvt. Ltd. proceedings u/s 153C to substantiate its claim that all the payments in excess of Rs. 20,000/- were made on holidays, etc. as per Rule 6DD. The appellant has also furnis…

Shri Sanjay Shantilal Jain, Mumbai vs. JCIT, Central Range-8, Mumbai

In the result, the appeal of the In the result, the appeal of the assessee is having ITA No

ITA 6124/MUM/2018[2010-11]Status: DisposedITAT Mumbai31 Oct 2022AY 2010-11

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail () Assessment Year: 2010-11 Shri Sanjay Shantilal Jain, Dcit-Cc 8(3), 72-7, Kalpataru Residency Tower 6Th Floor, Aayakar Bhavan, Vs. B, Sion Koliwada Road, Sion, M.K. Road, Mumbai-400022. Mumbai-400020. Pan No. Aabpj 3761 A Appellant Respondent Assessment Year: 2010-11 Shri Sanjay Shantilal Jain, Jcit, Central Range-8, 72-7, Kalpataru Residency Tower 6Th Floor, Aayakar Bhavan, Vs. B, Sion Koliwada Road, Sion, M.K. Road, Mumbai-400022. Mumbai-400020. Pan No. Aabpj 3761 A Appellant Respondent : Assessee By Mr. Rushabh Mehta, Ar Revenue By : Mr. Manoj Kumar, Cit- Dr : Date Of Hearing 15/09/2022 Date Of Pronouncement : 31/10/2022

For Respondent: Assessee by Mr. Rushabh Mehta, AR

Section 143(3)Section 40A(3)Section 50Section 68Section 69C

…e Apt: Court in the Tax Act, 1961 has also been upheld by the Apt: Court in the Shri Sanjay Shantilal Jain Shri Sanjay Shantilal Jain case of Altar Singh Gurmukh Singh Vs. Income case of Altar Singh Gurmukh Singh Vs. Income- -tax Officer. Ludhiana [1991 1991] 191 ITR 667 (S.C.) Moreover, if the payment 191 ITR 667 (S.C.) Moreover, if the payment is made through is made through cash and not trough account payee cash and not trough account payee chegue/draft, then draft, then it would be quite difficult for the departme it would be quite difficult for the departme 1 to ascertain whether the payment so made by payee…

Shri Sanjay Shantilal Jain, Mumbai vs. DCIT, Central Range-8 (3), Mumbai

In the result, the appeal of the In the result, the appeal of the assessee is having ITA No

ITA 6123/MUM/2018[2010-11]Status: DisposedITAT Mumbai31 Oct 2022AY 2010-11

For Respondent: Assessee by Mr. Rushabh Mehta, AR

Section 143(3)Section 40A(3)Section 50Section 68Section 69C

ITO, W-2, Barnala vs. The Truck Operator Union, Barnala

In the result, the appeal of the Revenue is allowed for statistical purposes

ITA 893/CHANDI/2019[2015-16]Status: DisposedITAT Chandigarh14 Oct 2022AY 2015-16

Bench: Smt.Diva Singh & Shri Vikram Singh Yadavthe Ito बनाम The Truck Operator Union, Ward-2, Barnala Dhanaula Road, Barnala "थायी लेखा सं./Pan No: Aaaat6497M

For Appellant: Shri Deepak Aggarwal, AdvocateFor Respondent: Shri Sarabjeet Singh, CIT, DR

Section 194C(2)Section 250(6)Section 40Section 40A(3)Section 60A(3)

…pplies and loading site is far away and the truckers are from the villages which are mostly not served by the banks or do not maintain any bank accounts and referring to the decision of Hon’ble Supreme Court in case of Attar Singh Gurmukh Singh Vs. ITO (1991) 4 SCC 385 and decision of Hon’ble Gujarat High Court in case of Anupam Tele Services Vs. ITO (2014) 43 taxmann.com 199, it was held that the judicial opinion appears to exclude from the mischief of section 40A(3) those transactions which are duly confirmed and vouched by an audit trail where the sellers identity is thoroughly confirmed and the transaction ve…