The Tribunal held that where the assessee, a joint venture company, had entered into a principal-to-principal arrangement with ONGC and merely passed on the bareboat charter hire received from ONGC to its associated enterprise without retaining any margin, the transfer pricing adjustment was unwarranted. The benchmarking methodology based on revenue split had already been accepted by the DRP in the assessee’s own case for an earlier year, and there was no change in facts or contractual arrangement. Even after imputing a 2.5% commission, the payment to the AE remained lower than comparable uncontrolled transactions. Accordingly, the transfer pricing adjustment was deleted (AY. 2021-22)