Tribunal held that role of TPO must remain confined within those parameters. It was not open to TPO to go beyond such role of determining ALP and intrude in exclusive domain of AO to determine income taxable in hands of assessee. A price decided, even if that be so, between AEs as assessee and buyer of shares were, could never be a valid CUP input for simple reason that it was only transaction value for transactions between independent enterprises that transaction value could be considered as a comparable uncontrolled price.  Accordingly the adoption of NAV or book value was not really warranted. If it was treated as a going concern, valuation based on future earnings was quite justified. However, since TPO failed to examine that aspect of matter at all and simply proceeded on basis of NAV, matter was remitted for fresh determination of ALP. TPO was directed to discard computations based on NAV and adopt an appropriate method of determining ALP of shares sold by assessee to its AE, and if such an ALP was found to be more than transaction value, ALP adjustments would be required. Matter remanded.(AY. 2012-13)