The assessee had undertaken two separate transactions with its AE: export of steel items benchmarked using CPM, and commission income benchmarked using IRR method. The TPO instead applied CUP method for both. The CIT(A) deleted adjustment, noting that in subsequent years the Revenue itself had accepted assessee’s method and no adjustment was made. Tribunal upheld deletion, holding CUP inapplicable where sales considered by TPO were negligible. The High Court affirmed. (AY. 2005-06)