The Tribunal held that the Transfer Pricing Officer’s reasoning of constructing a hypothetical comparable uncontrolled price based on the study of third-party scenario was not envisaged as per the benchmarking exercise laid out in rule 10B. The Tribunal held that since centralised information technology services of the total group were distributed among all divisions, subsidiaries and associates who used this facility, the basis of cost allocation was reasonable and could not be faulted. (AY. 2011-12 to 2013-14)