Assessing Officer Cannot Apply Section 10A(7) on Assumptions; Requires Concrete Evidence of Unusual Profit Structuring.

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....Applicability of provisions of 10A(7) - without establishing through positive evidence that assessee and its related party have arranged their business transaction in a manner to produce more than ordinary profit to assessee, AO cannot invoke the provisions of section 10A(7) read with section 80IA(10) on mere presumptions and surmises. - AT....