Held, that the assessee had benchmarked the specified domestic transaction with the arithmetical mean rate  at which the related parties sold the products to independent buyers.. The Transfer Pricing Officer had benchmarked it by taking the lowest or minimum rate ignoring all other comparable uncontrolled transactions. The proviso to section 92C(2) clearly states that where more than one price is determined by the most appropriate method, the arm’s length price shall be taken to be the arithmetical mean of such prices. The benchmarking methodology followed by the Transfer Pricing Officer was prima facie perverse and against the extant provisions contained in proviso to section 92C(2) of the Act. Order of CIT (A) deleting the addition was affirmed. (AY. 2013-14)