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It is seen that assessee has entered into a Reseller Agreement with AWS Inc. this year and payment of Rs. 657.3 crores of 'fees' is paid for this agreement. As per this agreement AWS Inc. has appointed assessee as non-exclusive seller of standard & automated cloud computing services etc as discussed above in this order. Assessee is also doing Marketing Support Services for the same contract & business of AWS Inc. for which 165,05,64,374/- is separately paid.

So, when for the same business assessee is already entered into Reseller Agreement & also doing Market Support Service payments too, the additional payment of 17.95 crores for novation of existing customers contract is held as not genuine and sham. In fact, the details filed by assessee on 27.03.2024, where in it is stated that 19.95 crores are for novation of customer contracts, makes it is clear that what to talk of capital revenue or expenditure, the expenditure itself is sham. It is only when details are called for and are examined that their true nature is revealed. Perusal of Reseller Agreement filed by assessee clearly shows that the customer's contract are the core, around which rights and obligations of the parties, have been brought out in the agreement.