The TPO did accept the assessee’s contention of treating foreign AEs as tested parties and proceeded with the ALP determination by taking the assessee as a tested party. Held that a foreign AE can also be taken as tested party. TPO was justified in in rejecting the foreign AE as tested party and adopting the assessee itself as a tested party. The assessee could not provide the TPO with relevant and verifiable information on the foreign AEs and comparables to determine the transaction’s ALP because the foreign/AEs are complex. Matter was set aside and sent to the AO/TPO file for a fresh determination based on directions. Transfer Pricing adjustment to be restricted only to value of International transaction (AY. 2014-15)