The assessee had entered into APA with CBDT on 6.8.2019 covering transactions related to AYs. 2013-14 to 2021-22. For A.Y. 2012-13, eighteen transactions were covered under APA. Out of the eighteen (18) transactions, it was agreed that sixteen (16) transactions will be benchmarked by using the other method while the remaining two (2) transactions will be benchmarked by using Transaction Net Margin Method (TNMM) and Resale Price Method. In the set aside proceedings under the order of the High Court, the Tribunal directed the TPO to consider the FAR of the year under consideration with FAR of the years in APA.  The Revenue sought to challenge this direction on the ground that so far as A.Y. 2012-13 was concerned, APA could not have been used as the basis for benchmarking. The assessee defended the order of the Tribunal on the ground that the Tribunal had, keeping in mind the principles captured in the APA, passed order with the caveat put in place that the TPO needs to verify as to whether the Functions, Assets and Risks (FAR) is the same. The High Court upheld the order passed by the Tribunal as it was passed after taking into consideration several judgments on the issue and held that no error has been committed by the Tribunal concerning either in the application of law or on facts..(AY.2012-13)