In the result, the appeals are allowed in favour of the assessee
Bench: Shri N.V. Vasudevan & Ms. Padmavathy S
section 40A(3) and rule 6DD(j). Since we have agreed with the primary finding recorded by the Tribunal, we think it is not necessary for us to go into the alternative finding recorded by the Tribunal. With these observations, questions Nos. 1 and 3 are answered in the affirmative, that is, in favour of the assessee and against