Assessee entered into international transactions with its Associated Enterprises (AEs) as regards payment of management fee, research and development (R&D) fees and tender fees. TPO proposed certain ALP adjustment in respect of aforesaid transactions.  DRP held that assessee failed to explain benefit for said charges in earlier years, DRP, further, held that said fees pertained to previous years and same could not be disallowed in instant year. Tribunal held that neither ALP adjustments can be equated with disallowance of expenses, even though effect may be same, nor TPO has authority to disallow expenses and, thus, aforesaid ALP adjustments made by DRP were vitiated in law and was to be deleted.  (AY. 2007-08, 2010-11,2011-12)