Court Evaluates Income Diversion Claims; Evidence Supports 10% Markup on Management Fees, No Sham Detected.

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....Addition on account of diversion of income / profit - there is no evidence to prove that this was some kind of sham arrangement of profits along with markup and secondly, catena of documents and evidences were filed that the said entity is working there and for which mark-up of 10% of management fees is given, therefore, it cannot be held that all those documents are bogus or sham without any material information on record. - AT....