Assessee claimed deduction under section 80IB(10) which was allowed by Assessing Officer.  Commissioner found that land was transferred to firm at lower price and firm was used as a device to divert excess profit to sons of land owners.  He accordingly set aside assessment Tribunal held that there was no material available before Commissioner that such guideline value of land was ridiculously low, therefore, in absence of any material to show that assessee had so arranged business and made transaction to produce more than ordinary profits, there was no ground for Commissioner to exercise its power under section 263 of the Act. High Court affirmed the order of the Appellate Tribunal. (AY 2012-13)