Held that if the assessee, through a proper working and supporting evidence, established on record that all costs incurred by the assessee, whether direct or business support, had been remunerated with a mark-up of 12 per cent. no adjustment can be made. However, the onus was entirely on the assessee to prove such fact. To provide an opportunity to the assessee to bring material on record in support of its claim that the invoice raised also included the mark-up of 12 per cent. on all types of cost, including business support cost, the issue was to be restored to the Commissioner (Appeals) for de novo adjudication after affording the assessee due opportunity of being heard. (AY.2011-12)