Tribunal held that when foreign AE, primarily acting as marketing arm of assessee and performing administrative services, was least complex entity, it should be treated as tested party for purpose of TP analysis.

Tribunal also held that CPM is appropriate to be used as MAM in situation wherein international transaction involves provision of services to a related party. Tribunal also held that  TPO was not justified in rejecting segmental accounts of overseas entities used by assessee for transfer pricing analysis as transfer pricing legislation nowhere mandates that segmental accounts of such entities used should be audited. (AY. 2010-11 to 2013-14)