The assessee had an international transaction as defined under section 92B with an associated enterprise as defined under section 92 A in the accounting year relevant to AY 2005-06. The price invoiced by the assessee was Rs. 37,39,96,538. The Assessing Officer referred it under section 92CA of the Act and the Transfer Pricing Officer determined the arm’s length price at Rs. 38,05,97,081. The difference was Rs. 66,00,543, which was below five per cent., i. e., the arm’s length price determined exceeded the invoice price only by less than five per cent. This was upheld by the Tribunal. On appeal  by the assessee   dismissing the appeal, that there was only one arm’s length price determined by the Transfer Pricing Officer in accordance with one of the appropriate methods, being the “comparable uncontrolled price method”. It was very clear that the arm’s length price determined was not in excess of the invoice price by more than 5 per cent. The price fixed by the Transfer Pricing Officer was justified.( AY. 2005-06)