ALLAHABAD HIGH COURT · SOURCE-REVIEWED INTERIM ORDER
Principal Commissioner of Income Tax-1 v. Mohd Ayaz
INCOME TAX APPEAL No. 13 of 2025 ·
Supplied court order; reported citation not indexed
The appeal was admitted, listing fixed for 29 January 2026, and paper books directed within six weeks.
Division Bench · Shekhar B. Saraf · Rajeev Bharti
1. Facts of the case
Revenue challenged deletion of a Section 40A(3) addition. The admitted questions identify Rs.6,68,97,549 and disputed proof of cash payments and Rule 6DD coverage.
2. Discussion by the Hon’ble Court
Five questions concerned identification of prohibited payments, alleged perversity, documents, estimated disallowance and cited Supreme Court decisions. The order frames issues rather than deciding alleged evidentiary failures.
3. Judicial decision
The appeal was admitted, listing fixed for 29 January 2026, and paper books directed within six weeks.
4. Outcome / in whose favour
The dispute proceeded to hearing; no addition was restored or deleted by this order.
5. Expert Comments
AKHB editorial analysis, distinct from the Court’s findings. Subsequent treatment and current-law applicability have not been verified.
Admission preserves an evidentiary dispute
The five questions place the assessing officer’s identification of prohibited cash payments alongside the assessee’s supporting documents and claimed Rule 6DD coverage. Their wording contains Revenue’s allegations about missing corroboration and perversity. Admission does not establish those allegations or restore the Rs.6,68,97,549 addition.
Source: PDF p.1 · PDF p.2 · PDF pp.1–2, complete order
Prepare the comparison the questions require
The assessment findings, Tribunal reasoning, payment particulars and exception documents must be read together. This is particularly important to distinguish a disallowance based on identified transactions from the estimated approach challenged in the questions. The six-week paper-book direction provides the procedural setting for that comparison.
Source: PDF p.1 · PDF p.2 · PDF pp.1–2, complete order
Authorities within a question are not an answered ratio
Attar Singh Gurmukh Singh and Choudhary Transport appear in the admitted questions. The order does not apply them to decide this dispute. No conclusion that section 40A(3) always permits estimation, or that Rule 6DD was satisfied here, follows from this admission order. The assessment year and any later answer require separate evidence.
Source and verification
Complete supplied 2-page original read and every page visually inspected; original PDF bytes verified by SHA-256 against the review ledger. Only source-identified provisions and assessment years are indexed. No PAN is stated. No current-law clearance is claimed.
Source SHA-256: ece81b5eb1ea1d63c8d8bd3e2adbea68e5914027246cd62d80e330471ba05cc1
Only source-identified provisions are recorded. No current monetary threshold, current statutory equivalence or 2025 Act applicability is inferred.
Source checked 2026-10-21. Subsequent proceedings and current precedential treatment have not been comprehensively verified.
AI disclosure and professional disclaimer
This AKHB research note was prepared with AI assistance from an identified primary report. Independent human review is not represented.
General legal and tax research only; not legal or tax advice. Verify the complete judgment, applicable statutory version and subsequent treatment before reliance. The AKHB Expert Comments is editorial analysis, not the Court’s holding. No current-law clearance is claimed.