The Tribunal held that the Transfer Pricing Officer might discard the search process or the comparables used by the assessee but could not discard the method which was accepted by the Revenue since the AY 2009-10 onwards. Before adopting the “other method” the Transfer Pricing Officer had to give reason for discarding the five methods mentioned in the rules, but the order of the Transfer Pricing Officer or the Assessing Officer or the Dispute Resolution Panel were devoid of such finding. The Dispute Resolution Panel had put the onus on the assessee whereas the onus lay on the Transfer Pricing Officer to justify the adoption of “other method” as the most appropriate method and not on the assessee. Further, the comparables used by the Transfer Pricing Officer and accepted by the Dispute Resolution Panel related to the payment of royalty relating know-how, patent and process technology and therefore, such comparables could not be accepted on the business profile of the assessee. The lower authorities should have accepted the transactional net margin method as the most appropriate method on the business profile qua the international transaction of the assessee as was accepted in the AYs 2009-10 to 2014-15. (AY. 2016-17)