Tax Authorities Can't Alter Arm's Length Agreements Without Collusion Allegations u/s 271(1)(c) of Income Tax Act.

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....Penalty levied u/s.271(1)(c) - Valuation of Goodwill - the I.T. Act does not clothe the taxing authorities with any power or jurisdiction to rewrite the terms of the Agreement arrived at between the parties with each other at arms length and with no allegation of any collusion between them. - HC....