The assessee selected its overseas AEs as the tested parties for benchmarking its international transactions, contending that they were the least complex entities performing limited functions and assuming minimal risks. The TPO rejected the approach and selected the Indian entity as the tested party without examining the functional analysis and transfer pricing documentation furnished by the assessee. The Hon’ble Tribunal, following the decisions in Atmecs Technologies (P.) Ltd. and Virtusa Consulting Services (P.) Ltd., held that an overseas AE can be selected as the tested party where it is the least complex transacting entity and the requisite documentation is available. Accordingly, the issue was restored to the TPO for fresh consideration after examining the assessee’s transfer pricing documentation and functional profile. The appeal was partly allowed for statistical purposes. [AY 2018-19]