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    <title>2011 (5) TMI 636 - ITAT VISAKHAPATNAM</title>
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    <description>The Commissioner of Income Tax (Appeals) deleted the income estimated towards sub-contract commission, emphasizing that the joint venture did not earn income as the work was executed by its constituent members. The relationship was deemed principal-agent, not contractor-subcontractor. Additionally, the disallowance under Section 40(a)(ia) was overturned based on the nature of the relationship between the joint venture and its members. The Tribunal concluded that the joint venture was formed solely for procuring contracts, with members executing work independently, leading to the dismissal of both revenue appeals.</description>
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