Tribunal held that since no evidence had been placed on record to prove that payments had been made to cultivator, grower or producer as per rule 6DD(e) in order to exclude said payments from provision of section 40A(3),pond and farm maintenance expenses’ could not come under exclusion provided under rule 6DD(e). Disallowance was affirmed. (AY. 2012-13)
Oceanic Bio Harvest Ltd. v. DCIT (2021) 190 ITD 765 (Chennai)(Trib.)
S. 40A(3) : Expenses or payments not deductible-Cash payments exceeding prescribed limits-Pond and farm maintenance expenses-No evidence was produced to prove that the payments had been made to cultivator, grower or produced-Disallowance was confirmed. [R. 6DD(e)]