Assessee was engaged in manufacturing and import/export of coloured stones and studded jewellery to/from its Associated Enterprise (AE) and had two manufacturing units.  It adopted Gross Profit Margin/Cost of Production (GPM/COP) as appropriate Profit Level Indicator (PLI) for benchmarking analysis. TPO adopted Operating Profit/Value Added Expenses (OP/VAE) as appropriate PLI. Held that  in a situation in which there is further processing of goods procured before selling same or in a situation which necessitates employment of assets in infrastructure for processing or maintenance of inventories, use of berry ratio does not seem to be quite appropriate.  Therefore, appropriate profit indicator was GPM/COP and since median came to be 12.09 per cent, considering comparables selected by TPO as against assessee’s margin of 13.51 per cent, no TP adjustment was required.  (AY. 2008-09)