Tribunal held that where assessee purchased a product from its AE and resold same to unrelated party without altering or using any intangible assets to add substantial value i.e. resale was made without any value addition, RPM method was to be applied for benchmarking international transaction undertaken by assessee.  Where assessee incurred losses in its initial year of operations and in order to assist assessee for transfer pricing purposes, its AE made subvention payments to reimburse part of operating expenses, said subvention amount received by assessee was operating in nature and was to be included as operating income while computing PLI in hands of assessee. Tribunal also held that since expenditure incurred by assessee was neither incurred at instance or behest of its AE nor there was any understanding or arrangement between parties to allocate or contribute any part of expenditure towards reimbursement of any part of AMP expenditure, no transaction or international transaction could be said to be involved between assessee and its AE. (AY. 2011-12, 2012-13)