In the result, the appeal of the assessee and the revenue are disposed off with above directions
269T to the Additional/Joint CIT separately. Therefore, the 73 entries have been dropped for purpose of addition as they do not violate the provisions of section 40A(3) of the I.T. Act, 1961. The remaining 178 entries were not satisfactorily explained by the assessee and no evidence was provided to substantiate the claim that earlier the payments have been made