VARUN SATYAPAL SINGHAL,VADODARA vs. THE INCOMETAX OFFICER, WARD-1(2)(3( NOW THE DCIT, CIRCLE-1(1)(1), VADODARA

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

Bench: Us, At The Outset, Ld. Counsel For The Assessee Submitted That He Shall Not Be Pressing For Ground Nos. 3, 4 & 5 Of His

6. Thus, from the above it is clear that disallowance under Section 40A(2) for payment being excessive or unreasonable can only be made when the payment is made to the specified persons under clause 40A(2)(b) and when Assessing Officer is of the opinion that such expenditure is excessive or unreasonable having regard to the fair market