11 grounds have been taken by the assessee but the crux of the issue revolves around the decision of DRP for upholding 10 per cent of thead hocaddition made on account of income distributed for the services rendered for marketing of channel placement rights. After giving all these findings by the DRP, there is no justification for upholding any ad hoc addition of 10 per cent. From the record we further found that the adjustment of 10 per cent so upheld by the DRP was without following any of the prescribed methods under s. 92C(1) of the Act nor has any benchmarking been adopted in determination of the ALP. The Hon'ble jurisdictional High Court in the case of CIT vs. Lever India Exports Ltd. (ITA Nos. 1306, 1307 & 1349 of 2014) have held that the ad hoc determination of ALP de hors s. 92C of the Act cannot be sustained, rendering the entire TP adjustment unsustainable in law.