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18. The learned AR has also contended that the AO's assumption that the joint venture was dissolved on 19/8/2005 was wrong, as the agreement for termination of the joint venture was entered into only on 10/12/2005, and that the actual payments and final termination of the joint venture took place only in August, 2007. Accordingly, the learned AR contended that the transaction could not be regarded as a pre determined or paper transaction. As per the sequence of events given by the assessee itself before the AD (which is reproduced by the AO on page Nos.12 to 14 of the assessment order), after signing the joint venture agreement on 16/8/2005, the parties had mutually decided to part ways and the assessee company proposed to go ahead independently with the project, in case the plot is allotted to them jointly. It has been further mentioned by the assessee itself that consequent to this understanding, it had also made on account payment of Rs.3 upfront to Well Wishers on 19/8/2005 itself. Thus, it is admitted by the assessee itself that the decision to terminate the joint venture had been taken by the parties and a payment of Rs.3 crores had also been made to one of the parties as per such understanding, immediately after formation of the joint venture and before allotment of any land by MIDC. Therefore, it is not material that the agreement in this regard was entered into later.