covered by the
exceptions referred to in Rule 6DD. Rule 6DD provides for an exhaustive
list of cases and circumstances in which a payment ... purchase of land are not covered by the exception provided in Rule 6DD. It
has been held by Kerala High Court in the case
respect of purchases, no disallowance under section
40A(3) , read with rule 6DD(j), could be made. The
Hon'ble Punjab and Haryana High
were covered under any clause
of Rule 6DD of the I.T. Rules, 1962. In light of
the above facts it is held that
view of the provisions of
section 40A(3) read with rule 6DD(j) of the Income-tax
Rules, 1962, as no deduction was allowed
must not be read in
isolation or exclusion of Rule 6DD as an established position, there was no
reason to arrive at a conclusion that ... assessee to bring its case under exceptional
circumstances provided under Rule 6DD which must be read with section
40A(3) for the payment
assessee is not
recorded on Sundays or bank holidays and therefore, Rule 6DDJ would
not be applicable. Similarly, with regard to the payment below ... accounts of the
assessee. Since the transactions are covered by rule
6DD(j) of Income Tax Rules therefore, no adverse
comment is made regarding
