Assessee entered into international transaction of payment of Management fees with its AE. TPO examined working of allocation of management fees paid by assessee to its AE and noticed that assessee incurred its own separate costs in addition to payment to its AE towards management services fee. He accepted cost allocation on basis of average total assets and third party sales, but refused to accept allocation done on basis of head count and adjustment was proposed in this transaction Held that TPO simply dissected transacted value of international transaction on basis of some working done by him and neither any comparison of payment of management fee in uncontrolled situation was made nor even allocation of third component on basis of head count was done by considering any comparable uncontrolled instance, and ALP was not determined under any of prescribed methods. Such course of action adopted by TPO being contrary to mandatory statutorily stipulated procedure, could not be countenanced and, thus, addition on account of management fee is deleted. (AY. 2016-17)