Court held that the Tribunal’s order deleting the disallowance of Rs. 3.54 crores was to be set aside. However, there was no infirmity in the Tribunal’s order as regards the value of scrap sales and the levy of interest and the 5 per cent. of interest income taken as expenditure. Court also held that the practical difficulty was of hitting upon correct comparables to arrive at the arm’s length price for the particular product and therefore the submission of the assessee was accepted even though it was lower than the excess profit over arm’s length price arrived at by the Transfer Pricing Officer under section 92CA(3) by another method was acceptable.(AY.2004-05)