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    <title>2013 (8) TMI 1088 - ITAT DELHI</title>
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    <description>The appeal was successful as the Income Tax Appellate Tribunal (ITAT) Delhi held that the addition under section 40A(3) was unjustified. The ITAT ruled that section 40A(3) applies to payments to another person, not within the same entity, to prevent tax evasion and unaccounted money flow. In this case, the transactions were between two concerns of the same assessee for business expediency, as per a distribution agreement with Godrej company. Therefore, the addition was deleted as there was no tax evasion and the transactions were genuine and necessary for business purposes.</description>
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    <pubDate>Wed, 14 Aug 2013 00:00:00 +0530</pubDate>
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      <link>https://www.taxtmi.com/caselaws?id=273407</link>
      <description>The appeal was successful as the Income Tax Appellate Tribunal (ITAT) Delhi held that the addition under section 40A(3) was unjustified. The ITAT ruled that section 40A(3) applies to payments to another person, not within the same entity, to prevent tax evasion and unaccounted money flow. In this case, the transactions were between two concerns of the same assessee for business expediency, as per a distribution agreement with Godrej company. Therefore, the addition was deleted as there was no tax evasion and the transactions were genuine and necessary for business purposes.</description>
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