Held that since neither foreign AEs were least complex nor could assessee place before TPO relevant and verifiable information of foreign AEs and comparables for enabling him to determine ALP of transaction, A.O. was fully justified in rejecting foreign AE as tested party and adopting assessee itself as a tested party.  Where difference in turnover of assessee and selected company was not as substantial as was considered germane for exclusion, said company could not be excluded on this count particularly when assessee had not disputed otherwise functional and other similarities with said company. Transfer pricing adjustment should be restricted only to international transactions and not entity level transactions. Matter remanded.  (AY. 2014-15)