TPO can only determine ALP using prescribed methods u/s 92C, rule 10B; adhoc adjustments are unauthorized and deleted.

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....TP Adjustment - adhoc adjustment - duty of the TPO is restricted only to the determination of the ALP of an international transaction between two related parties by applying any of the methods prescribed u/s.92C r.w. rule 10B and there is no provision made in the statute empowering TPO for determining the ALP on an estimation basis /adhoc basis - adjustment deleted....