These imports were made by the respondent from an AE in Switzerland. The respondent sought to arrive at the ALP of the import of Bisoprolol Fumarate on the basis of TNMM and contended that the imports of Bisoprolol Fumarate from its AEs at Rs. 66,702 per kg is the ALP and no adjustment is called for. This the TPO did not accept TNMM as the most appropriate method. The TPO adopted CUP method as the most appropriate method to determine the ALP of the imported API. On application of CUP, the TPO determined the ALP at Rs. 36,831 per kg and ALP for purchase of 345 kgs was adjusted at Rs. 1.27 crores and the TP adjustment of Rs. 1.03 crores was made being the excess amount paid.