Held, that the Assessing Officer had not brought out why the profits of the assessee would not be considered ordinary profits in the course of business. The Assessing Officer had not demonstrated any proof of arrangement for disallowance under the provisions of section 10B(7) read with section 80-IA(10) of the Act. It is mandatory for the Revenue to prove that there was some special arrangement between the assessee and its associated enterprise to earn extra profits and this burden had not been discharged by the Department. Therefore, there was no reason to interfere with the findings of the Commissioner (Appeals) and the relief provided to the assessee was sustained.(AY.2011-12)