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2006 (4) TMI 218 - AT - Income TaxExtract: .......racter in the hands of the person who has made the payment. Once it is held that this payment is not an expenditure, there is no question of applying the provisions of s. 40A(3) of the Act. Accordingly, we uphold the order of the CIT(A) who has deleted the disallowance under s. 40A(3) of the Act. 5. In the result, the Revenue s appeal is dismissed.
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