Held, that the transactions with an entity were to be considered in a consolidated way, and could not be bifurcated according to the calendar year prevalent in that contracting State. Therefore, the Assessing Officer/Transfer Pricing Officer was to consider the rate applied in the mutual agreement procedure for the transactions between the assessee and the United States associated enterprise for the period April 2012 to December 2012 to the transactions during January 2013 to March 2013. In respect of transactions with other associated enterprises, the assessee in the transfer pricing study report gave bifurcation of the revenue earned from United States associated enterprise and other associated enterprises. Both the transactions are in respect of the software development segment. The arm’s length price was computed only having regard to the United States associated enterprise transactions. In other words, the Transfer Pricing Officer treated the other transactions to be at arm’s length. However, in the event there was any transaction with other associated enterprise was considered in a consolidated way in the amount by the Transfer Pricing Officer, it may be considered in accordance with the ratio laid down in J. P. Morgan Services India P Ltd. [2019 105 taxmann.com 40 (Bom) (HC)  The grounds relating to transfer pricing raised by the assessee were allowed to be withdrawn pursuant to mutual agreement procedure order. (AY. 2013-14)