Allowing the petition the Court held, that a bare perusal of the Transfer Pricing Officer order dated January 31, 2021 would suggest that the Transfer Pricing Officer had never determined the arm’s length price of the international transaction relating to the demerger of business and rather only determined an adjustment. Though the Transfer Pricing Officer’s order, inter alia, reflected some discussion regarding the value of the demerger of the business, it nowhere held  depicted the arm’s length price of such an international transaction.  The Assessing Officer, without affording an opportunity of hearing to the assessee, proceeded to add  to the total income of the assessee, which addition was neither determined nor directed by the Transfer Pricing Officer, as the arm’s length price of the international transaction related to the demerger of the business. The course of action was not available to the Assessing Officer and it was a clear case of excess. The order is not valid. Referred, PCIT v. S.G. Asia Holdings (India) Pvt Ltd  (2019) 14 ITR-OL 256 (SC)  (AY. 2017-18)