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    <title>2025 (7) TMI 299 - ITAT HYDERABAD</title>
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    <description>Multiple DIN references arising from migration between assessment systems did not, by themselves, invalidate the assessment order or establish limitation. Amounts collected as privilege fee, special privilege fee, additional privilege fee and contribution to C.M. Relief Fund under the Andhra Pradesh Regulation of Wholesale Trade Act, 1993 as amended were treated as statutory levies belonging to the Government and as diverted by overriding title, so disallowance under section 40(a)(iib) was deleted, including the additional privilege fee addition. Disallowance of leave encashment and contributions to PF, superannuation, gratuity and other funds was sustained because the assessee produced no supporting evidence to dislodge the factual findings.</description>
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      <description>Multiple DIN references arising from migration between assessment systems did not, by themselves, invalidate the assessment order or establish limitation. Amounts collected as privilege fee, special privilege fee, additional privilege fee and contribution to C.M. Relief Fund under the Andhra Pradesh Regulation of Wholesale Trade Act, 1993 as amended were treated as statutory levies belonging to the Government and as diverted by overriding title, so disallowance under section 40(a)(iib) was deleted, including the additional privilege fee addition. Disallowance of leave encashment and contributions to PF, superannuation, gratuity and other funds was sustained because the assessee produced no supporting evidence to dislodge the factual findings.</description>
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