Assessee provided information technology enabled services to its Irish group company which involved evaluation of Google products and tools for efficiency, bugs, performance, failures and other aspects, software development tasks in relation to development of web-based language translator, etc. In study report, Assessee considered said services as low-end IT services and determined arms’ length price using Transaction Net Margin Method. TPO held that Assessee also rendered R & D services which are in nature of product development, product upgrades, product support, testing of products and product improvement and re-characterized activities/functions as Knowledge Processing Unit and applied Profit Split Method. On appeal before the Tribunal, whether it is settled proposition of law that Profit Split Method can be adopted as most appropriate method in cases involving multiple inter-related international transactions which cannot be evaluated separately – Held, yes – Whether since business of AdWords programme of google required deployment of assets and functions of different entities located in different geographical locations in order to ultimately deliver services and revenues was generated through combined efforts in respect of transactions aggregated with AdWords business transaction, TPO should benchmark transaction by adopting Profit Split Method as most appropriate method – Held, yes (AY. 2009-10)