There was no advertising agreement obtaining between the assessee and its AE. The last agreement was entered into on 1st April, 2005, which apparently, had come to an end. The TPO had used comparables furnished by the assessee for employing the BLT tool, in ascertaining the ALP qua AMP activities. Concededly, the assessee’s net operating margin was 3.29 per cent, whereas, the arithmetic mean of the net operating margin of comparables chosen by the TPO was 2.09 per cent. The TPO had accepted other international transactions under the TNMM employed by the assessee, except for AMP activities. Tribunal deleted the addition. On appeal the Court held that the  comparables chosen by the TPO had a net margin lower than that registered by the assessee would persuade the Court to hold that no upward adjustment concerning AMP expenses ought to have been made. Lastly, the application of the BLT tool, by the TPO, in determining ALP, injected the order issued by him, which was incidentally approved by the DRP, with a legal error. No substantial question of law arises for consideration. Followed Sony Ericsson Mobile Communications India (P) Ltd. v. CIT (2015) 276 CTR 97/ 117 DTR105/ 55 taxmann.com 240   (Delhi) (HC).  (AY.2007-08)