Allowing the appeal of the assessee  the Tribunal held that approach adopted by TPO, as approved by DRP, did not conform to prescription of rule 10B(1)(a) inasmuch as he sought to compare percentage of expenses to sales rather than price paid under a comparable uncontrolled situation. Accordingly even if CUP method was applied to international transactions of Royalty and Technical know-how fee, still no transfer pricing adjustment would be called for.  (AY. 2012-13)