Held that the aggregation is not a rule of blind application, it is to be applied in certain situations and there has to be a scientific or rational basis for adoption; unless characteristic of ‘closely-linked’ is satisfied, aggregation is not possible.  It is assessee who must prove or at least present facts and data before TPO/Assessing Officer by which it can be proved that there is a situation of ‘closely-linked’ transactions and aggregation is necessary.  In instant case  the assessee had not explained any scientific or convincing reason for aggregation and annual averaging of prices except that arithmetical calculation favoured assessee, assessee must be given an opportunity to prove justification for application of aggregation-theory.  (AY.  2011-12,  2012-13).