Tribunal held that for the assessment year 2011-12, the Department was aggrieved by the Dispute Resolution Panel’s direction to consider cost plus method as the most appropriate method for determining the arm’s length price of the international transaction under the trading segment while the Transfer Pricing Officer had adopted the resale price method as the most appropriate one. In the present case, the Transfer Pricing Officer adopted the transactional net margin method against the assessee’s choice of cost plus method on the same set of comparables for determining the arm’s length price. Admittedly, there being no difference in the facts and circumstances between the two assessment years, in terms of the Tribunal’s direction for the earlier assessment year in the assessee’s own case, the Transfer Pricing Officer was directed to determine the arm’s length price of the transaction under the trading segment using the cost plus method as the most appropriate one.  (AY. 2012-13)