The grounds raised by the assessee are against the addition made on account of transfer pricing adjustment of Rs. 2,60,72,599. the assessee benchmarked the international transaction relating to sale of finished goods with its AE by applying internal TNMM. Whereas, the Transfer Pricing Officer has rejected internal TNMM and determined the arm’s length price by applying external TNMM with fresh set of comparables. It is the contention of the learned Authorised Representative that due to lack of proper representation, the assessee could not justify its claim of applicability of internal TNMM and non–comparability of the comparables selected by the Transfer Pricing Officer. Further, it is seen from record, before learned DRP, the assessee had furnished certain additional evidences which were not admitted on the reasoning that they were not produced before the Transfer Pricing Officer. Learned DRP has also observed that the director’s report to the audited account has not been submitted. In our view, if the assessee furnishes certain evidences even at the appellate stage which may have a crucial bearing on the issue, they should not be rejected on technical ground. Therefore, considering the facts and circumstances of the case, we are inclined to restore the issue to the Assessing Officer/Transfer Pricing Officer for de novo adjudication after providing adequate opportunity of being heard to the assessee.