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2014 (7) TMI 1319 - AT - Income TaxAddition on account of Arm’s Length Price of international transaction - MAM selection - HELD THAT:- Finding of the CIT(A) that on the peculiar facts and circumstances of the case TNMM is the most appropriate method deserves to be upheld as the same is in consistency of the finding of the Tribunal in assessee’s own case for the immediately preceding assessment year [2011 (7) TMI 1364 - ITAT DELHI] . However the CO-ordinate Bench had restored the issue to verify the calculation as they had not been vetted either by the AO or by the CIT(A). In the facts of the present case the exercise has been done by the CIT(A) against which the Revenue is in appeal before us on the afore-mentioned ground. We have taken ourselves through the findings arrived at in impugned order which has been extracted in the earlier part of this order. On a consideration thereof and in the absence of any argument pointing to an incorrect fact, circumstance or position of law so as to come to a contrary view we find no good reason to interfere with the finding arrived at in the impugned order. Being satisfied with the reasoning and finding arrived at therein the departmental ground is dismissed.
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