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Section 40A(2)(a) of Income Tax Act Unjustly Invoked Without Evidence of Tax Avoidance Intent in Sister Concern Purchases.

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....Purchases from sister concern - applicability of section 40(A)(2)(a) of the Act - The AO has not been able to bring any material on record to show as to how and in what manner the assessee intended to avoid payment of tax before invoking the provisions of Section 40A(2)(a) of the Act. - AT....