The assessee-company was engaged in the business of manufacture and sale of internal combustion engines, spares, components (including bought-outs) thereof & generating sets, service of engines & gensets/generating sets & allied equipment, etc. The assessee made payment of royalty to its foreign based AE for providing technical know how and technical knowledge for manufacturing of engines to be sold to the customers. The assessee benchmarked this transaction alongwith other international transactions of export sales under overall ‘manufacturing segment’. It used TNMM to benchmark all its international transaction. The Transfer Pricing Officer segregated the international transaction of payment of royalty from other international transactions of the assessee and used CUP method to benchmark said transaction. Tribunal up held the order of the  Transfer Pricing Officer. On appeal High Court held that where  the assessee had used TNMM to benchmark all its international transactions, it was not open to TPO to subject only one element, i.e., payment of royalty for use of technology, to an entirely different CUP method as this would lead to chaos and be detrimental to interests of both assessee and revenue. Appeal of the assessee is allowed. Adjustment was deleted.   (AY. 2015-16 to 2017-18)