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2005 (8) TMI 334 - AT - Income TaxExtract: .......tances, therefore, we are of the opinion that the impugned payment made in terms of the agreement dated 31-7-1991 was not a case of diversion by an overriding charge. We do not find any infirmity in the orders of the CIT(A) and, accordingly, we uphold his orders. 17. In the result, the appeals filed by the assessee for both the years are dismissed.
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