Sec. 92C of the Income-tax Act, 1961 - Transfer pricing - Revenue filed Tax Appeal before High Court against the order of Tribunal in applying first and second proviso of Section 92C of the Act and allowing +1-5% range in the case where there is only one reference rate of RBI as a benchmarking rate for determining Arms' Length Price. Revenue also contended that the Tribunal cannot go into issue as to how RBI decides a reference rate of price of a currency which was not an issue before Tribunal. High Court dismissed the Appeal of the revenue holding that “assessee was well justified in claiming the benefit available to it under proviso to section 92C(3) of the Act. DRP was justified in holding that assessee's prices were within +1- 596 range of the RBI rates and therefore there was no necessity for transfer pricing adjustment. SLP of the revenue also dismissed as withdrawn due to low tax effect. - PR. CIT V/s UAE EXCHANGE AND FINANCIAL SERVICE LTD. - [2020] 272 TAXMAN 019 (SC)