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-12- I.T.A. No. 17/Mds/12 cost can be ascertained in the case of shares of a company. It is also equally not possible to apply Profit Split Method (PSM). The Transactional Net Margin Method (TNMM) is also not applicable as there is no concept of net margin in the sale of shares. The learned senior counsel explained that the only remaining category available in the present case is "such other method as may be prescribed by the Board".

16. The learned senior counsel explained that as far as impugned assessment year is concerned, the Board has not prescribed "any such method" to value the shares transferred in similar circumstances. He, therefore, argued that the computation provisions with reference to ALP have failed and as such, Section 92C cannot be applied to assessee's case. The learned senior counsel has relied on the decision of Hon'ble Supreme Court in the case of CIT v. B.C. Srinivasa Setty (128 ITR 294), wherein the Hon'ble Supreme Court has held as under:-