Held that the funds received by the assessee from JDS could not be treated as its own funds when the money trail unravelled by the Department itself clearly revealed the ultimate beneficiary to be VMS. There can be no other conclusion drawn from the facts before the Department but that of VMS being the ultimate beneficiary of the transactions, and the assessee only being intermediary in the entire process. No benefit could be derived from the appellate order passed in the case of VMS because that entity had applied for dispute resolution. The addition is  not sustainable. Addition is  deleted.(AY.2005-06)