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Sec. 40A of Income Tax Act, 1961 - Business disallowance - The Department could not sit on the armchair of the assessee and decide as to whether it was appropriate on business expediency for the assessee to incur such expenditure or not. If the transaction is otherwise valid in law and is a part of tax planning, merely because it has resulted in reduction of tax, such expenditure cannot be ignored raising the issue of underlying motive of entering into this type of transaction. Tribunal dismissed the Appeal of the revenue filed against the order of CIT(A) in deleting the addition of Rs.47,07,37,143/- made by the AO on account of Sham Transaction of Revenue Sharing. - ASSTT. CIT V/s VISHNU APARTMENTS (P.) LTD. - [2020] 204 TTJ 033 (UO)(ITAT-DELHI)