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2009 (1) TMI 842 - HC - Income TaxAppeal u/s 260A - Deletion of addition on income from other sources - monies received - ‘agreement’ executed between the assessee and sister concern, Speciality Ranbaxy Limited (SRL) - expenses incurred by the Assessee during the relevant period and were debited in the books of account under the head "pre-operative expenses" - AO held that assessee had received professional charges for which TDS had been deducted by SRL - he concluded that sum received by the assessee from SRL during pre-operative period was to be treated as income from other sources - Accordingly, AO made an addition under the head income from other sources. HELD THAT:- We are of the view that the judgment of the Tribunal deserves to be upheld. Two concurrent authorities i.e., CIT(A) as well as the Tribunal have found that the money received by the assessee from SRL was nothing but reimbursement of expenses incurred by the assessee in respect of common services extended by the assessee to SRL. The said authorities have also found as a fact that the expenses incurred by the assessee are equivalent to the monies received by the assessee from SRL and hence, no income would arise to the assessee if the expenses are set-off there being a direct nexus between the two. In view of these findings of fact we are of the opinion that no question of law, much less a substantial question of law, has arisen for our consideration. In the result, the appeal is dismissed.
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