the learned Authorised Representative has invited our attention towards p. 652 of the paper book as per which it has computed profit (loss) margin from export transactions with AEs and non-AEs, uniformly at (-) 15.46 per cent by allocating the operating costs and revenues in certain percentages, the veracity of which has not been examined by the TPO. Since such a calculation of profit (loss) margin has not been verified by any authority, we set-aside the impugned order and remit the matter to the file of AO/TPO. In such fresh exercise, the TPO will firstly examine if the transactions with the non-AEs can be considered as comparable in terms of nature of products, geographical locations, timing and quantities sold and the afore discussed parameters. In case the transactions of export to the non-AEs are capable for comparison with the international transactions of export to the AEs, then the TPO will proceed to examine the veracity of calculation of the PLI from exports to the non-AEs vis-à-vis exports to the AEs as given on p. 652 of the paper book. In case he gets satisfied, he will proceed to determine the ALP by adopting the internal TNMM as the most appropriate method. In case, the AO/TPO comes to conclusion that the working done by the assessee is not correct and further proper determination of PLI from exports to non-AEs is not possible, then he would be free to benchmark the international transactions as per law after allowing reasonable opportunity of hearing to the assessee.