No immunity from sec. 40A(3) disallowance unless case falls under specific clauses of Rule 6DD: ITAT

INCOME TAX : Proviso to section 40A(3A) provides for cushion from disallowance in cases and circumstances as may be prescribed having regard to nature and extent of banking facilities available, considerations of business expediency and other relevant factors and such cases and circumstances have been enlisted in different clauses of rule 6DD having regard to 'business expediency' in an exhaustive manner, which obviously does not cover a case of per se genuine business transaction

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