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The ITAT allowed the appellant's appeal concerning the disallowance of sums claimed under an MOU with another entity, rejecting the revenue's contention that the arrangement was a tax evasion device. The Tribunal found no cogent material supporting the addition and upheld the appellant's claim based on the available evidence. However, the appeal against additions under section 40(a)(ii) relating to income tax paid and deferred tax liability was dismissed as infructuous, since the appellant had already adjusted these amounts in the return, and the Assessing Officer was directed to correct the computation accordingly. Consequently, the addition based on the MOU was deleted, while the tax computation was maintained consistent with the appellant's filings.
The ITAT allowed the appellant's appeal concerning the disallowance of sums claimed under an MOU with another entity, rejecting the revenue's contention that the arrangement was a tax evasion device. The Tribunal found no cogent material supporting the addition and upheld the appellant's claim based on the available evidence. However, the appeal against additions under section 40(a)(ii) relating to income tax paid and deferred tax liability was dismissed as infructuous, since the appellant had already adjusted these amounts in the return, and the Assessing Officer was directed to correct the computation accordingly. Consequently, the addition based on the MOU was deleted, while the tax computation was maintained consistent with the appellant's filings.
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