Tribunal held, that from the memorandum of understanding entered into by both the joint venture partners it was demonstrated that the parties were individually responsible for their respective share of services to the client and they individually assumed the risks. The respective parties were not entitled to the profit or loss arising from the services performed by the other party. The amount paid to H represented diversion of income by overriding title. The disallowance of the expenses invoking the provisions of section 40(a)(ia) of the Act was not sustainable. (AY. 2011-12)