Assessee, a subsidiary of a Mauritius based company, had entered into an international transaction of buying services for sourcing garments, leather etc. in India for its AE and computed ALP of said transaction by adopting TNM method. Assessing Officer accepted application of TNMM by assessee as most appropriate method however  addition made by TPO in assessee’s ALP by applying cost plus 5 per cent mark-up on FOB value of exports among third parties. Tribunal deleted the addition which was affirmed by the High Court.   (AY.  2011-12)