Dismissing the  appeal against the single judge order, the  division bench held that the single judge was right in holding that to say that the reason for selection of scrutiny was only for numerical reconciliation was an over simplification of the reason stated for selection. In fact, the single judge had observed that the officer might have been more detailed in the choice of words employed so as to specifically refer to the issue of total employee cost. However, this was not fatal, as the reason for selection by the computer aided selection system had been produced and placed on record by the officer while seeking approval of the Principal Commissioner for reference to the Transfer Pricing Officer. The single judge rightly concluded that the assessee had not only cooperated and participated in the conduct of assessment, but had also filed objections before the Dispute Resolution Panel that were pending disposal. Order of single judge is affirmed. (AY.2016-17)