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2015 (6) TMI 243 - AT - Income TaxTransfer pricing adjustment - CIT(A) deleting the addition made on account of adjustment of arm’s length price - Held that:- The assessee in this case has created a provision for obsolete stocks. Admittedly, such the provision for obsolesce stock has not been made by any of the companies, which are taken as comparables as per the TPO’s order, except for Kirsolkar Oil Engines Ltd. where the provision for stock obsolesce / non moving inventory is only 1.03% of sales as against the provision for stock obsolesce or non moving inventory made by the assessee at 8.98%. There is no dispute that such a provision for stock obsolesce and non moving inventory is an extraordinary time. Ld. CIT(A), has rightly made suitable adjustments by eliminating the said provision from the financial statements of the assessee and thereafter arriving at the operation margin for the purpose of comparability and benchmarking with the other comparables companies. Thus no infirmity in the well reasoned order passed by the Ld. CIT(A) on the issue in dispute - Decided against revenue.
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