On appeal the Tribunal held  that the assessee had demonstrated the kind of services rendered by it to its AEs as well as non-AEs by placing reliance on agreements and it was argued before the Tribunal that the assessee deals with AEs as well as independent parties being network partners in all regions of the world wherever there were no affiliates of the parent company of the assessee; that agreements of the assessee with its AEs and non-AEs were in equal ratio; that the DRP had rejected internal TNMM because the assessee had not carried out an internal FAR and proper identification of revenue and costs vis-à-vis the audited accounts. With these observations, the Tribunal set aside the order passed by the TPO and AO and directed the assessee to carry out internal FAR and identify proper revenue and costs vis-à-vis the audited accounts to establish internal comparability under TNMM as most appropriate method. Tribunal also  held that if the assessee failed to demonstrate the internal FAR and identification of proper revenue and costs vis-à-vis the audited accounts, it wouid file details in respect of external comparables under TNMM as most appropriate method and the TPO would decide the issue as per law. During the pendency of this appeal, the TPO vide order dt. 31st Oct., 2019 held that it is the external TNMM which should be applied as the most appropriate method. Reasoning of the Tribunal in the impugned order is robust and without any flaw. For, the ultimate aim of the transfer pricing exercise is to determine an accurate value of the ALP for the purpose of taxation and the appellate authorities are not precluded from adopting a method different from that adopted by the assessee in transfer pricing report.  No substantial  question of law.  (AY.  2008-09)