Profit-sharing agreement mandates income diversion at source, recognized as overriding title, leading to deletion of tax additions.

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....Profit sharing agreement - Diversion of income by overriding title or mere application of income - the assessee has been obligated by virtue of the agreement to divert the income at source and also for the contributions made by the holding company - the revenue sharing agreement entered with the holding company by the assessee is diversion of income by overriding title. - Additions deleted.....