Held that there was no concrete evidence to come to the conclusion that there had been diversion of profits from the firm to the assessee. The Department had not challenged the sale price of the products sold by the firm to the assessee. Further, the Commissioner (Appeals) had observed that the products of the assessee involved substantial innovation whereas the products of the firm were generic. The Assessing Officer, who had not pointed out any mistake in the assessee’s books of account, erred in concluding that there had been diversion of profits from the firms claiming exemption under sections 80IE and 80IC(3)(ii)  (AY.2009-10, 2010-11, 2011-12)