Held that even while examining the e-mails he did not state that no services have been rendered but had rejected them stating that these were shareholders activity or duplicative in nature. The Commissioner (Appeals) examined the e-mails and gave a categorical finding about the rendition of the services. This finding remained uncontroverted. Further, if the Transfer Pricing Officer was not satisfied with the contents of the e-mails, he could have further probed the transaction with respect to various programmes and their content. In view of these facts, there was no infirmity in the order of the Commissioner (Appeals) in holding that the peculiar intra group services were shown to have been rendered by the associated enterprises to the assessee and directing the transactions to be benchmarked under the transactional net margin method. (AY. 2012-13)