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    <description>The appeal was partly allowed for statistical purposes. The disallowance of waivers under section 41(1) of the Income Tax Act was overturned, as the waivers were not revenue in nature and were not claimed as deductions. The issue of adjusting carry forward losses and depreciation was remanded back to the CIT(A) for further consideration to ensure principles of natural justice are followed.</description>
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      <description>The appeal was partly allowed for statistical purposes. The disallowance of waivers under section 41(1) of the Income Tax Act was overturned, as the waivers were not revenue in nature and were not claimed as deductions. The issue of adjusting carry forward losses and depreciation was remanded back to the CIT(A) for further consideration to ensure principles of natural justice are followed.</description>
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