Dismissing the appeal of the Revenue the Court held that  that profit margins required to be compared with profit margins of enterprise and not that of any sub-unit or division of enterprise.  Splitting transactions unit wise for determining Arm’s Length Price would not be apposite. Order of Tribunal holding payroll taxes as allowable expenditure is  not erroneous. Res Judicata applicable where fundamental aspects found as fact earlier and accepted. Eligibility of new undertaking for deduction under section 10A most relevant in initial year of operation. Once it is accepted that new undertaking is not formed by splitting  up or reconstruction of extant business or transfer to new business of machinery or plant previously used for any purpose of department cannot relegate on same set of facts in later assessment years.   Expression an international transaction is  to be construed in plural.(AY.2004-05)