Held that Indian Transfer Pricing guidelines issued by Institute of Chartered Accountants of India vide guidance note on report under section 92E by ICAI and transfer pricing guidelines issued by OECD do not prohibit foreign AE to be a tested party. Therefore, where on consideration of FAR profile of both assessee company and AE, Tribunal held that assessee company was a more complex entity when compared to its foreign AE, said foreign AE could be selected as a tested party. Order of Tribunal is affirmed. Court also held that, where segmental results are available, adjustment can be made only on basis of individual transaction and not on aggregation basis. (AY. 2012-13, 2013-14)