Appellate Tribunal held that as provided in section 92C of the Act, arms’s length price was to be determined by one of the methods prescribed, which was found to be the most appropriate method having regard to the nature of transaction or class of transaction or class of associated persons or functions performed by such persons or such other relevant factors as may be prescribed. The manner in which such most appropriate method was to be applied for determination of arm’s length price was prescribed in rule 10B of Rules. In the present case, neither the assessee nor the Transfer Pricing Officer or the Commissioner (Appeals) had followed this procedure prescribed in section 92C of the Act and rule 10B of the Rules to determine the arm’s length price in relation to the royalty payment made by the assessee to its associated enterprises and hence this matter was remanded to the Assessing Officer for carrying out such exercise. (AY. 2005-06)