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4. Ld. AR has provided a summary of TP adjustments, post DRP directions as follows:

     S.     International           TPO's      approach       /
                                                                  Amount (INR)
     No.    transaction             allegation

            Alleged     excessive
            AMP       expenditure Substantive addition:
     1      incurred by Appellant Residual Profit Split 34,10,29,024
            and    Payment     of Method ("RPSM")
            Royalty

                                    Protective   addition:
                                    Arbitrarily determined
     3      Payment of royalty
                                    ALP as 2% of sales by
                                    applying CUP

                                No evidence submitted
                                for management support
            Payment          of
                                services received and
     4      management services
                                failure to demonstrate
            fee
                                the need for such
                                services

            Interest             on Imputation of interest
     5      outstanding             beyond specified credit
            receivables             period

5.6. not providing any reason/documentary evidence to demonstrate that the AMP expenses incurred by the Appellant constitute an international transaction, 5.7. not appreciating that in case any incidental benefits arise to the associated enterprise ("AE") on account of incurring AMP expenses, these do not constitute intra-group services so as to constitute an international transaction;

5.8. not appreciating the contribution profit split analysis ("CPSM") and Residual Profit Split Method (RPSM) furnished by the Appellant during assessment proceedings, 5.9. selecting an inappropriate set of comparable companies for the purposes of determining routine return for application of RPSM; and 5.10. determining the weightage of split for application of RPSM on an adhoc basis, thus violating the fundamental principle of transfer pricing.

24. Further we are of the considered view that since Bright Line Test method is used for protective adjustment and Residual Profit Split Method for substantive adjustments, so that shows that the ld. TPO has not found anything from the transactions between the assessee and AE or specific heads of expenditures incurred by the assessee, or specific transactions of AMP expenses of assessee with independent entities, which will establish as evidence of necessity of some compensation from the AE. It is only on the basis of examination of the quantum of AMP expenses the opinion of benefit to AE, has been drawn, which certainly is not sustainable, where the law is that onus is on Revenue to establish existence of an international transaction.