The assessee had sub-contracted work to MIOL in relation to a contract awarded by ONGC to assessee. However, subsequent to a global acquisition by group to which assessee belonged MIOL had become a part of said group and, consequently, an AE of assessee. CUP method had been applied by assessee to determine arm’s length price for inter-company transactions between assessee and its AE in relation to availing of sub-contractor services.  TPO held that assessee had applied CUP method by using a QUOTE from a third party and since a quotation may not be a good base to apply CUP method in normal circumstances, TNMM was MAM. Tribunal held that-CUP method is most direct and reliable way of applying arm’s length principle and price an inter-company transaction but applying of ‘QUOTE’ from third party for economic analysis using CUP method was not a justifiable method, matter was set aside to file of Assessing Officer to determine ALP using CUP method taking into consideration appropriate comparables.  (AY. 2011-12