Circuitous transactions among sister concerns inflicting losses held 'artificial'; concealment penal

IT: Where assessee having purchased distribution right of a film from sister concern at a very high price on minimum guarantee basis, entered into agreement with another sister concern for exhibition of said film on commission basis, there was a valid basis with revenue authorities for regarding transaction in question to be device, and loss, thus, was self inflicted in order to reduce assessee's taxable income earned from production of another film and, therefore, penalty order passed for raisi