Collaboration with Arkadin SA Boosts Profits; CIT(A) Finds No Evidence of Payments Lacking Business Purpose or Benefit.

Proof of pudding is in the eating. The travel of assessee from losses to profits pursuant to the collaboration with the Arkadin SA, France is evident. Its acquisition of not only the equipment but also the technical knowhow cannot be presumed to be without any cost. As rightly pointed out by the Ld. CIT(A), the findings of the Assessing Officer that the payments were made without any business purpose and without any commensurate benefit to the assessee are not based on any cogent material and without bringing any adverse material on record. .....

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