Tribunal held that; Foreign AE could be a tested party, provided complete financials of said AE along with complete financials of relevant comparables required to benchmark international transaction were made available before TPO, matter remanded . Tribunal also held that Transaction with AE being higher than ALP, no ALP adjustment could be made, however, failed to establish by sufficient evidence before TPO regarding actual value of international transaction received by AE, matter was to be remanded back for adjudication afresh.  ( AY. 2005 -06 , 2006 -07)