Court Rules Revenue-Sharing Agreement Legitimate; Rejects Revenue's Claim of Income Diversion to EMLL as Incorrect.

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....Disallowance on account of Sham Agreement - Revenue sharing agreement entered with the holding company by the assessee is diversion of income by overriding title. The revenue's contention that the entire transaction is sham and aimed at only to divert the income to EMLL cannot be said to be correct based on the facts and the judicial pronouncements.....