AO Fails to Prove Arrangement with AE; Section 80IA(10) Deduction Disallowance Deemed Unjustified.

Since AO has not conclusively proved the fact that there is an arrangement between assessee and its AE by which the transactions were so arranged as to produce more than the ordinary profits in the hands of assessee, disallowance of part deduction claimed by applying the provisions of section 80IA(10), in our view is not justified - AT .....

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