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1990 (2) TMI 95 - ITAT BOMBAY-BExtract: ....... circumstances, the provisions of section 40(a)(iii) of the Act would not be applicable as the payments received by them would neither be subjected to payment of tax nor any deduction of tax therefrom. We, therefore, delete the disallowance and direct the assessing officer to allow the claim of the assessee. 10. In the result, the appeal is allowed
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