Dismissing the appeal of the Revenue the Tribunal held that Resale price method is most appropriate method. Tribunal also held the Department could not show that those entities were functionally not comparable with the assessee. Some of the companies might have lower margins but those had to be included in the comparability analysis if they were functionally comparable with the assessee. There was no infirmity in the order of the Commissioner (Appeals) deleting the adjustment in arm’s length price of international transactions.(AY.2012-13)