Natesan Krishnamurty Vs ITO 103 Taxmann.com 342(Mad), Jhunjhunwala & Co. v. CIT

357 ITR 529Reported decision#6654 most cited

What is Natesan Krishnamurty Vs ITO 103 Taxmann.com 342(Mad), Jhunjhunwala & Co. v. CIT authority for?

The exception under Rule 6DD(j) for payments exceeding Rs. 20,000 cannot be applied if the genuineness of the expenses is doubtful, especially when those expenses are unrecorded.

17

judgments rely on this decision, according to BharatTax’s citation analysis of 366,315 Indian tax judgments — from 2025 to 2025.

Also referred to as

Natesan Krishnamurty Vs ITO · Rule 6DD(j) · Section 40A(3) · disallowance of expenses · genuineness of expenses · unrecorded expenses · exceptions to Section 40A(3)

Sections most often in play

Section 119Section 132(1)Section 143(3)Section 144ASection 153ASection 153CSection 153DSection 158BG

Issues it is cited on

section 153(a)violation of natural justicesection 132(4a)section 40a(3)section 132(1)section 153a(1)section 145(3)section 40asearch assessmentsection 153drule 46asection 145

Judgments citing Natesan Krishnamurty Vs ITO 103 Taxmann.com 342(Mad), Jhunjhunwala & Co. v. CIT

Ramji Vaish, Allahabad vs. DCIT(CC), Allahabad

In the result, all the appeals filed by the assessees are held to be partly allowed as above, while the Departmental appeals in the matter of Vijay Stone

ITA 38/ALLD/2023[2007-08]Status: DisposedITAT Allahabad31 Oct 2025AY 2007-08

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudhary

For Appellant: Sh. Praveen Godbole, C.A. & Sh. SuyashFor Respondent: Sh. Amalendu Nath Mishra, CIT DR & Sh
Section 132(1)Section 153Section 153ASection 153DSection 250

…control of payer for application of rule 6DD(j) could not be said to be established in view of the ratio of decisions in case of Natesan Krishnamurty Vs ITO 103 Taxmann.com 342(Mad), Jhunjhunwala & Co Vs CIT 167 Taxman 58(Delhi), CIT Vs Singamshetty Subba Rao 357 ITR 529(A.P.), Pawar Patkar Constructions 159 ITD 406(Pune Trib). 6. On the facts and circumstances of the case and in law, the CIT(A) erred in holding that the payments in excess of Rs. 20,000 in violation 40A(3) were covered by exception within Rule 6DD(j). without appreciating that when the genuineness of such expenses itself was doubtful as these exp…

Ramji Vaish, Allahabad vs. DCIT, (CC), Allahabad

In the result, all the appeals filed by the assessees are held to be partly allowed as above, while the Departmental appeals in the matter of Vijay Stone

ITA 37/ALLD/2023[2006-07]Status: DisposedITAT Allahabad31 Oct 2025AY 2006-07

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudhary

For Appellant: Sh. Praveen Godbole, C.A. & Sh. SuyashFor Respondent: Sh. Amalendu Nath Mishra, CIT DR & Sh
Section 132(1)Section 153Section 153ASection 153DSection 250

…control of payer for application of rule 6DD(j) could not be said to be established in view of the ratio of decisions in case of Natesan Krishnamurty Vs ITO 103 Taxmann.com 342(Mad), Jhunjhunwala & Co Vs CIT 167 Taxman 58(Delhi), CIT Vs Singamshetty Subba Rao 357 ITR 529(A.P.), Pawar Patkar Constructions 159 ITD 406(Pune Trib). 6. On the facts and circumstances of the case and in law, the CIT(A) erred in holding that the payments in excess of Rs. 20,000 in violation 40A(3) were covered by exception within Rule 6DD(j). without appreciating that when the genuineness of such expenses itself was doubtful as these exp…

Ramji Vaish, Allahabad vs. DCIT, (CC), Allahabad

In the result, all the appeals filed by the assessees are held to be partly allowed as above, while the Departmental appeals in the matter of Vijay Stone

ITA 36/ALLD/2023[2005-06]Status: DisposedITAT Allahabad31 Oct 2025AY 2005-06

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudhary

For Appellant: Sh. Praveen Godbole, C.A. & Sh. SuyashFor Respondent: Sh. Amalendu Nath Mishra, CIT DR & Sh
Section 132(1)Section 153Section 153ASection 153DSection 250

…control of payer for application of rule 6DD(j) could not be said to be established in view of the ratio of decisions in case of Natesan Krishnamurty Vs ITO 103 Taxmann.com 342(Mad), Jhunjhunwala & Co Vs CIT 167 Taxman 58(Delhi), CIT Vs Singamshetty Subba Rao 357 ITR 529(A.P.), Pawar Patkar Constructions 159 ITD 406(Pune Trib). 6. On the facts and circumstances of the case and in law, the CIT(A) erred in holding that the payments in excess of Rs. 20,000 in violation 40A(3) were covered by exception within Rule 6DD(j). without appreciating that when the genuineness of such expenses itself was doubtful as these exp…

Ramji Vaish, Allahabad vs. DCIT(CC), Allahabad

In the result, all the appeals filed by the assessees are held to be partly allowed as above, while the Departmental appeals in the matter of Vijay Stone

ITA 127/ALLD/2023[2011-12]Status: DisposedITAT Allahabad31 Oct 2025AY 2011-12

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudhary

For Appellant: Sh. Praveen Godbole, C.A. & Sh. SuyashFor Respondent: Sh. Amalendu Nath Mishra, CIT DR & Sh
Section 132(1)Section 153Section 153ASection 153DSection 250

…control of payer for application of rule 6DD(j) could not be said to be established in view of the ratio of decisions in case of Natesan Krishnamurty Vs ITO 103 Taxmann.com 342(Mad), Jhunjhunwala & Co Vs CIT 167 Taxman 58(Delhi), CIT Vs Singamshetty Subba Rao 357 ITR 529(A.P.), Pawar Patkar Constructions 159 ITD 406(Pune Trib). 6. On the facts and circumstances of the case and in law, the CIT(A) erred in holding that the payments in excess of Rs. 20,000 in violation 40A(3) were covered by exception within Rule 6DD(j). without appreciating that when the genuineness of such expenses itself was doubtful as these exp…

Ramji Vaish, Allahabad vs. DCIT(CC), Allahabad

In the result, all the appeals filed by the assessees are held to be partly allowed as above, while the Departmental appeals in the matter of Vijay Stone

ITA 126/ALLD/2023[2010-11]Status: DisposedITAT Allahabad31 Oct 2025AY 2010-11

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudhary

For Appellant: Sh. Praveen Godbole, C.A. & Sh. SuyashFor Respondent: Sh. Amalendu Nath Mishra, CIT DR & Sh
Section 132(1)Section 153Section 153ASection 153DSection 250

…control of payer for application of rule 6DD(j) could not be said to be established in view of the ratio of decisions in case of Natesan Krishnamurty Vs ITO 103 Taxmann.com 342(Mad), Jhunjhunwala & Co Vs CIT 167 Taxman 58(Delhi), CIT Vs Singamshetty Subba Rao 357 ITR 529(A.P.), Pawar Patkar Constructions 159 ITD 406(Pune Trib). 6. On the facts and circumstances of the case and in law, the CIT(A) erred in holding that the payments in excess of Rs. 20,000 in violation 40A(3) were covered by exception within Rule 6DD(j). without appreciating that when the genuineness of such expenses itself was doubtful as these exp…

Ramji Vaish, Allahabad vs. DCIT(CC), Allahabad

In the result, all the appeals filed by the assessees are held to be partly allowed as above, while the Departmental appeals in the matter of Vijay Stone

ITA 125/ALLD/2023[2009-10]Status: DisposedITAT Allahabad31 Oct 2025AY 2009-10

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudhary

For Appellant: Sh. Praveen Godbole, C.A. & Sh. SuyashFor Respondent: Sh. Amalendu Nath Mishra, CIT DR & Sh
Section 132(1)Section 153Section 153ASection 153DSection 250

…control of payer for application of rule 6DD(j) could not be said to be established in view of the ratio of decisions in case of Natesan Krishnamurty Vs ITO 103 Taxmann.com 342(Mad), Jhunjhunwala & Co Vs CIT 167 Taxman 58(Delhi), CIT Vs Singamshetty Subba Rao 357 ITR 529(A.P.), Pawar Patkar Constructions 159 ITD 406(Pune Trib). 6. On the facts and circumstances of the case and in law, the CIT(A) erred in holding that the payments in excess of Rs. 20,000 in violation 40A(3) were covered by exception within Rule 6DD(j). without appreciating that when the genuineness of such expenses itself was doubtful as these exp…

Ramji Vaish, Allahabad vs. DCIT(C.C.), Allahabad

In the result, all the appeals filed by the assessees are held to be partly allowed as above, while the Departmental appeals in the matter of Vijay Stone

ITA 101/ALLD/2023[2008-09]Status: DisposedITAT Allahabad31 Oct 2025AY 2008-09

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudhary

For Appellant: Sh. Praveen Godbole, C.A. & Sh. SuyashFor Respondent: Sh. Amalendu Nath Mishra, CIT DR & Sh
Section 132(1)Section 153Section 153ASection 153DSection 250

…control of payer for application of rule 6DD(j) could not be said to be established in view of the ratio of decisions in case of Natesan Krishnamurty Vs ITO 103 Taxmann.com 342(Mad), Jhunjhunwala & Co Vs CIT 167 Taxman 58(Delhi), CIT Vs Singamshetty Subba Rao 357 ITR 529(A.P.), Pawar Patkar Constructions 159 ITD 406(Pune Trib). 6. On the facts and circumstances of the case and in law, the CIT(A) erred in holding that the payments in excess of Rs. 20,000 in violation 40A(3) were covered by exception within Rule 6DD(j). without appreciating that when the genuineness of such expenses itself was doubtful as these exp…

Asstt. Commissioner of Income Tax, Central Circle, Allahabad vs. Vijay Stone Product, Sonebhadra

In the result, all the appeals filed by the assessees are held to be partly allowed as above, while the Departmental appeals in the matter of Vijay Stone

ITA 65/ALLD/2019[2011-12]Status: DisposedITAT Allahabad31 Oct 2025AY 2011-12

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudhary

For Appellant: Sh. Praveen Godbole, C.A. & Sh. SuyashFor Respondent: Sh. Amalendu Nath Mishra, CIT DR & Sh
Section 132(1)Section 153Section 153ASection 153DSection 250

…control of payer for application of rule 6DD(j) could not be said to be established in view of the ratio of decisions in case of Natesan Krishnamurty Vs ITO 103 Taxmann.com 342(Mad), Jhunjhunwala & Co Vs CIT 167 Taxman 58(Delhi), CIT Vs Singamshetty Subba Rao 357 ITR 529(A.P.), Pawar Patkar Constructions 159 ITD 406(Pune Trib). 6. On the facts and circumstances of the case and in law, the CIT(A) erred in holding that the payments in excess of Rs. 20,000 in violation 40A(3) were covered by exception within Rule 6DD(j). without appreciating that when the genuineness of such expenses itself was doubtful as these exp…

Asstt. Commissioner of Income Tax Central Circle, Allahabad vs. Vijay Stone Products, Sonebhadra

In the result, all the appeals filed by the assessees are held to be partly allowed as above, while the Departmental appeals in the matter of Vijay Stone

ITA 64/ALLD/2019[2010-11]Status: DisposedITAT Allahabad31 Oct 2025AY 2010-11

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudhary

For Appellant: Sh. Praveen Godbole, C.A. & Sh. SuyashFor Respondent: Sh. Amalendu Nath Mishra, CIT DR & Sh
Section 132(1)Section 153Section 153ASection 153DSection 250

…control of payer for application of rule 6DD(j) could not be said to be established in view of the ratio of decisions in case of Natesan Krishnamurty Vs ITO 103 Taxmann.com 342(Mad), Jhunjhunwala & Co Vs CIT 167 Taxman 58(Delhi), CIT Vs Singamshetty Subba Rao 357 ITR 529(A.P.), Pawar Patkar Constructions 159 ITD 406(Pune Trib). 6. On the facts and circumstances of the case and in law, the CIT(A) erred in holding that the payments in excess of Rs. 20,000 in violation 40A(3) were covered by exception within Rule 6DD(j). without appreciating that when the genuineness of such expenses itself was doubtful as these exp…

Vijay Stone Product, Sonebhadra vs. Asstt. Commissioner of Income Tax, Central Circle, Allahabad

In the result, all the appeals filed by the assessees are held to be partly allowed as above, while the Departmental appeals in the matter of Vijay Stone

ITA 33/ALLD/2019[2011-12]Status: DisposedITAT Allahabad31 Oct 2025AY 2011-12

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudhary

For Appellant: Sh. Praveen Godbole, C.A. & Sh. SuyashFor Respondent: Sh. Amalendu Nath Mishra, CIT DR & Sh
Section 132(1)Section 153Section 153ASection 153DSection 250

…control of payer for application of rule 6DD(j) could not be said to be established in view of the ratio of decisions in case of Natesan Krishnamurty Vs ITO 103 Taxmann.com 342(Mad), Jhunjhunwala & Co Vs CIT 167 Taxman 58(Delhi), CIT Vs Singamshetty Subba Rao 357 ITR 529(A.P.), Pawar Patkar Constructions 159 ITD 406(Pune Trib). 6. On the facts and circumstances of the case and in law, the CIT(A) erred in holding that the payments in excess of Rs. 20,000 in violation 40A(3) were covered by exception within Rule 6DD(j). without appreciating that when the genuineness of such expenses itself was doubtful as these exp…

Vijay Stone Product, Sonebhadra vs. Asstt. Commissioner of Income Tax, Central Circle, Allahabad

In the result, all the appeals filed by the assessees are held to be partly allowed as above, while the Departmental appeals in the matter of Vijay Stone

ITA 32/ALLD/2019[2010-11]Status: DisposedITAT Allahabad31 Oct 2025AY 2010-11

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudhary

For Appellant: Sh. Praveen Godbole, C.A. & Sh. SuyashFor Respondent: Sh. Amalendu Nath Mishra, CIT DR & Sh
Section 132(1)Section 153Section 153ASection 153DSection 250

…control of payer for application of rule 6DD(j) could not be said to be established in view of the ratio of decisions in case of Natesan Krishnamurty Vs ITO 103 Taxmann.com 342(Mad), Jhunjhunwala & Co Vs CIT 167 Taxman 58(Delhi), CIT Vs Singamshetty Subba Rao 357 ITR 529(A.P.), Pawar Patkar Constructions 159 ITD 406(Pune Trib). 6. On the facts and circumstances of the case and in law, the CIT(A) erred in holding that the payments in excess of Rs. 20,000 in violation 40A(3) were covered by exception within Rule 6DD(j). without appreciating that when the genuineness of such expenses itself was doubtful as these exp…

Vijay Stone Product, Sonebhadra vs. Asstt. Commissioner of Income Tax, Central Circle, Allahabad

In the result, all the appeals filed by the assessees are held to be partly allowed as above, while the Departmental appeals in the matter of Vijay Stone

ITA 31/ALLD/2019[2009-10]Status: DisposedITAT Allahabad31 Oct 2025AY 2009-10

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudhary

For Appellant: Sh. Praveen Godbole, C.A. & Sh. SuyashFor Respondent: Sh. Amalendu Nath Mishra, CIT DR & Sh
Section 132(1)Section 153Section 153ASection 153DSection 250

…control of payer for application of rule 6DD(j) could not be said to be established in view of the ratio of decisions in case of Natesan Krishnamurty Vs ITO 103 Taxmann.com 342(Mad), Jhunjhunwala & Co Vs CIT 167 Taxman 58(Delhi), CIT Vs Singamshetty Subba Rao 357 ITR 529(A.P.), Pawar Patkar Constructions 159 ITD 406(Pune Trib). 6. On the facts and circumstances of the case and in law, the CIT(A) erred in holding that the payments in excess of Rs. 20,000 in violation 40A(3) were covered by exception within Rule 6DD(j). without appreciating that when the genuineness of such expenses itself was doubtful as these exp…

Vijay Stone Product, Sonebhadra vs. Asstt. Commissioner of Income Tax, Central Circle, Allahabad

In the result, all the appeals filed by the assessees are held to be partly allowed as above, while the Departmental appeals in the matter of Vijay Stone

ITA 30/ALLD/2019[2007-08]Status: DisposedITAT Allahabad31 Oct 2025AY 2007-08

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudhary

For Appellant: Sh. Praveen Godbole, C.A. & Sh. SuyashFor Respondent: Sh. Amalendu Nath Mishra, CIT DR & Sh
Section 132(1)Section 153Section 153ASection 153DSection 250

…control of payer for application of rule 6DD(j) could not be said to be established in view of the ratio of decisions in case of Natesan Krishnamurty Vs ITO 103 Taxmann.com 342(Mad), Jhunjhunwala & Co Vs CIT 167 Taxman 58(Delhi), CIT Vs Singamshetty Subba Rao 357 ITR 529(A.P.), Pawar Patkar Constructions 159 ITD 406(Pune Trib). 6. On the facts and circumstances of the case and in law, the CIT(A) erred in holding that the payments in excess of Rs. 20,000 in violation 40A(3) were covered by exception within Rule 6DD(j). without appreciating that when the genuineness of such expenses itself was doubtful as these exp…

M/S Jai Maa Sharda Service Station, Allahabad vs. ACIT, Central Circle, Allahabad

In the result, all the appeals filed by the assessees are held to be partly allowed as above, while the Departmental appeals in the matter of Vijay Stone

ITA 25/ALLD/2019[2011-12]Status: DisposedITAT Allahabad31 Oct 2025AY 2011-12

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudhary

For Appellant: Sh. Praveen Godbole, C.A. & Sh. SuyashFor Respondent: Sh. Amalendu Nath Mishra, CIT DR & Sh
Section 132(1)Section 153Section 153ASection 153DSection 250

…control of payer for application of rule 6DD(j) could not be said to be established in view of the ratio of decisions in case of Natesan Krishnamurty Vs ITO 103 Taxmann.com 342(Mad), Jhunjhunwala & Co Vs CIT 167 Taxman 58(Delhi), CIT Vs Singamshetty Subba Rao 357 ITR 529(A.P.), Pawar Patkar Constructions 159 ITD 406(Pune Trib). 6. On the facts and circumstances of the case and in law, the CIT(A) erred in holding that the payments in excess of Rs. 20,000 in violation 40A(3) were covered by exception within Rule 6DD(j). without appreciating that when the genuineness of such expenses itself was doubtful as these exp…

M/S Jai Maa Sharda Service Station, Allahabad vs. ACIT, Central Circle, Allahabad

In the result, all the appeals filed by the assessees are held to be partly allowed as above, while the Departmental appeals in the matter of Vijay Stone

ITA 24/ALLD/2019[2010-11]Status: DisposedITAT Allahabad31 Oct 2025AY 2010-11

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudhary

For Appellant: Sh. Praveen Godbole, C.A. & Sh. SuyashFor Respondent: Sh. Amalendu Nath Mishra, CIT DR & Sh
Section 132(1)Section 153Section 153ASection 153DSection 250

…control of payer for application of rule 6DD(j) could not be said to be established in view of the ratio of decisions in case of Natesan Krishnamurty Vs ITO 103 Taxmann.com 342(Mad), Jhunjhunwala & Co Vs CIT 167 Taxman 58(Delhi), CIT Vs Singamshetty Subba Rao 357 ITR 529(A.P.), Pawar Patkar Constructions 159 ITD 406(Pune Trib). 6. On the facts and circumstances of the case and in law, the CIT(A) erred in holding that the payments in excess of Rs. 20,000 in violation 40A(3) were covered by exception within Rule 6DD(j). without appreciating that when the genuineness of such expenses itself was doubtful as these exp…

M/S Subhash Stone Product Private Limited, Sonebhadra vs. Asstt. Commissioner of Income Tax Central Circle, Allahabad

In the result, all the appeals filed by the assessees are held to be partly allowed as above, while the Departmental appeals in the matter of Vijay Stone

ITA 108/ALLD/2019[2010-11]Status: DisposedITAT Allahabad31 Oct 2025AY 2010-11

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudhary

For Appellant: Sh. Praveen Godbole, C.A. & Sh. SuyashFor Respondent: Sh. Amalendu Nath Mishra, CIT DR & Sh
Section 132(1)Section 153Section 153ASection 153DSection 250

…control of payer for application of rule 6DD(j) could not be said to be established in view of the ratio of decisions in case of Natesan Krishnamurty Vs ITO 103 Taxmann.com 342(Mad), Jhunjhunwala & Co Vs CIT 167 Taxman 58(Delhi), CIT Vs Singamshetty Subba Rao 357 ITR 529(A.P.), Pawar Patkar Constructions 159 ITD 406(Pune Trib). 6. On the facts and circumstances of the case and in law, the CIT(A) erred in holding that the payments in excess of Rs. 20,000 in violation 40A(3) were covered by exception within Rule 6DD(j). without appreciating that when the genuineness of such expenses itself was doubtful as these exp…

Subhash Stone Product (P) Ltd., Sonebhadra vs. Asstt. Commissioner of Income Tax Central Circle, Allahabad

In the result, all the appeals filed by the assessees are held to be partly allowed as above, while the Departmental appeals in the matter of Vijay Stone

ITA 107/ALLD/2019[2008-09]Status: DisposedITAT Allahabad31 Oct 2025AY 2008-09

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudhary

For Appellant: Sh. Praveen Godbole, C.A. & Sh. SuyashFor Respondent: Sh. Amalendu Nath Mishra, CIT DR & Sh
Section 132(1)Section 153Section 153ASection 153DSection 250

…control of payer for application of rule 6DD(j) could not be said to be established in view of the ratio of decisions in case of Natesan Krishnamurty Vs ITO 103 Taxmann.com 342(Mad), Jhunjhunwala & Co Vs CIT 167 Taxman 58(Delhi), CIT Vs Singamshetty Subba Rao 357 ITR 529(A.P.), Pawar Patkar Constructions 159 ITD 406(Pune Trib). 6. On the facts and circumstances of the case and in law, the CIT(A) erred in holding that the payments in excess of Rs. 20,000 in violation 40A(3) were covered by exception within Rule 6DD(j). without appreciating that when the genuineness of such expenses itself was doubtful as these exp…

Natesan Krishnamurty Vs ITO 103 Taxmann.com 342(Mad), Jhunjhunwala & Co. v. CIT (357 ITR 529) — Cited in 17 Judgments | BharatTax