In the matter where the Revenue submitted that the Dispute Resolution Panel erred in applying zero per cent. related party transaction. The order of the Dispute Resolution Panel was in itself contradictory since it had discussed why zero per cent. related party transactions should not be taken. On the other hand, it directed the Transfer Pricing Officer to adopt the same; it was held that the law is well-settled that the threshold limit for applying the related party transactions filter is 15 per cent or 25 per cent depending upon the availability of comparable companies. (AY.  2010-11, 2011-12)