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2012 (8) TMI 330 - ITAT, MUMBAITransfer pricing - adjustment - CIT(A) deleted addition on ground that difference between the ALP so worked out and the sales price shown by the assessee was less than the safe harbor limit of 5% - revenue contesting the same and inclusion of other cases - Held that:- CIT(A) was fully justified in excluding the said three cases suggested by revenue since these were not exactly comparable with the case of the assessee and for the purpose of comparative study and deleting the addition made by the A.O. on account of TP adjustment after having found that the difference between the ALP worked out by excluding the said three cases from comparables and the sales price charged by the assessee to its AE was within the safe harbor limit of 5% - Decided against assessee. Interest on Income Tax refund - Business income vs Income from other sources - Held that:- It is observed that there is a contradiction in the findings recorded by the A.O. conceding it to be interest on income-tax refund whereas and CIT (A) conceded it to be interest on bank deposits, hence matter restored to file of the A.O. to ascertain exact nature of interest income received.
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