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    <title>2016 (5) TMI 457 - ITAT DELHI</title>
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    <description>The Tribunal dismissed the Department&#039;s appeal and allowed the assessee&#039;s appeal. It held that the additional payments were not claimed as expenses, so no disallowance could be made. The deemed dividend could not be taxed as the assessee was not a shareholder of the payer companies. Additionally, the disallowance under Section 40A(3) was deemed inapplicable as no deduction was claimed. The order was pronounced on 10/2/2016.</description>
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      <link>https://www.taxtmi.com/caselaws?id=327476</link>
      <description>The Tribunal dismissed the Department&#039;s appeal and allowed the assessee&#039;s appeal. It held that the additional payments were not claimed as expenses, so no disallowance could be made. The deemed dividend could not be taxed as the assessee was not a shareholder of the payer companies. Additionally, the disallowance under Section 40A(3) was deemed inapplicable as no deduction was claimed. The order was pronounced on 10/2/2016.</description>
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