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2004 (7) TMI 19 - HC - Income TaxDisallowances of sums on account of lease rent paid to a sister concern - wholly and exclusively for the purpose of the business - lease rent has been paid at the rate of Rs. 1,25,000 per month for land and building and at the rate of Rs. 25,000 per month for plant and machinery - Tribunal has rightly drawn the conclusion that the transactions entered into by the assessee with its sister concern were not genuine and had been entered into merely to divert its profits to the sister concern. In these circumstances, the Tribunal has rightly held that the expenditure cannot be said to have been incurred wholly and exclusively for the purpose of the business as no connection had been established between the expenditure incurred and the activity undertaken by the assessee. Even otherwise, the findings recorded by the Tribunal are pure findings of facts. - assessee’s appeal is dismissed
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