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2009 (5) TMI 919 - DELHI HIGH COURTExtract: .......mbay who had appeared before him, none of whom have disowned the transaction. We agree with the Tribunal that, apart from failing to appreciate the correct legal position, so far as the facts are concerned, the AO has acted on surmises and conjectures. 5. Appeal is dismissed. It deserves to be dismissed with exemplary costs but we decline to do so.
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