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2012 (11) TMI 312 - ITAT MUMBAIDeletion of Addition in arm's length price made by AO – Held that:- Arm's length price as determined by the TPO by applying the profit margin rate of 3.13% as compared to assessee's profit margin of 1.01%, then also admittedly it falls within the +/- range of 5% as per second proviso to section 92C(2), which provides that if the variation between the arm's length price so determined and price at which the international transaction has actually been undertaken does not exceed five per cent of the latter, the price at which the international transaction has actually been undertaken shall be deemed to be the arm's length price - department's grounds of appeal are rejected - In the result, appeal filed by the department is dismissed.
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