TP adjustment deleted as assessee substantiated that ALP of transactions was within tolerable limit

IT/ILT: Where in order to prove that international transactions were carried out at arm's length price, assessee had submitted audited segmental accounts in respect of its associated enterprise and non-associated enterprises, in view of fact that on basis of said accounts difference between ALP determined by TPO in respect of AE transactions and ALP charged by assessee was less than 5 per cent, benefits of proviso to section 92C(2) was available to assessee and, therefore, impugned addition made