Upgrade From 8.1 ENT On Surface Pro 3 Will Not Complete

Oct 9, 2015

I have a surface pro 3 and I am trying to do an in place upgrade to 10.  Both OSes are Enterprise versions.  The install goes fine and eventually gets to a point where it will revert back to windows 8.1 with the following error: 0xC1900101-0x40017.  

Small background on the machine:  It is running windows 8.1 ENT, SCEP for virus scanner, is on a domain, has been originally imaged using SCCM
 
Here is what I have tried to get this error gone and get 10 installed:
 
Clean boot

Disabled all startup items from task manager and all services not marked as Microsoft

DISM /online /cleanup-image /checkhealth (succeeded)
DISM /online /cleanup-image /scanhealth (succeeded)
DISM /online /cleanup-image /restorehealth (Failed)
Ran via command prompt and all succeeded
net stop wuauserv

[Code] ....

found corrupt files but couldn't fix them.

Running offline scan not but I don't know that it will change the result of the online scan (done this before on other machines)

Tried running from local machine via extracted ISO (Failed)

Tried running from USB3 Thumb drive via extracted ISO (Failed)

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