Briefly stated the relevant facts include that the assessee is engaged in the business of gems and jewellery and reported the international transactions as well as Specified Domestic Transactions (SDTs). The details are given in para 4 of the TPO's order. The AO made a referral to the TPO for benchmarking the said transactions in relation to the 'Specified Domestic Transactions' (SDT) and not the 'international transactions'. The assessee sold the goods to the AEs abroad. Assessee paid for purchase of gold involving specified domestic transactions. The assessee also paid director's remuneration, the SDT. The TPO, while accepting other international transactions as well as specified domestic transactions, restricted the benchmarking exercise to the 'specified domestic transaction' relating to the director's remuneration. While benchmarking the said SDT, the TPO benchmarked the international transactions of corporate guarantee which was unreferred by the AO and accepted other international transactions