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Section 40A(2)(b) Challenge: Payments to Joint Venture Subcontract Exempt from Provisions, AO's 99% Payment Noted.

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....Addition made u/s 40A(2)(b) - payment to the persons specified - Payment made towards subcontracting of work to JV - Payment of 99% of receipt instead of 95% as per AO - the provisions of this section 40A(2)(b) are not attracted - AT....