https://www.taxtmi.com/caselaws?id=263884 The Tribunal dismissed the department's appeal, upholding the CIT(A)'s decision to delete the disallowance of part of the deduction under section 10A. The AO's actions were deemed unjustified as he failed to establish an arrangement between the assessee and its AE to derive excess profits. The Tribunal emphasized the necessity of providing conclusive evidence rather than relying on presumptions, ultimately concluding that the disallowance was not justified. en-us Wed, 26 Aug 2015 00:00:00 +0530 Sat, 12 Sep 2015 07:42:22 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=263884 The Tribunal dismissed the department's appeal, upholding the CIT(A)'s decision to delete the disallowance of part of the deduction under section 10A. The AO's actions were deemed unjustified as he failed to establish an arrangement between the assessee and its AE to derive excess profits. The Tribunal emphasized the necessity of providing conclusive evidence rather than relying on presumptions, ultimately concluding that the disallowance was not justified. Case-Laws Income Tax Wed, 26 Aug 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=263884