AAR held that the expression “a transaction” appearing in section 245N(a) of  Act,  would include more than one transaction. However, the application must be in respect of a related set of transactions. If the facts are not identical and are totally different, such transactions may not be clubbed in one application. Whether the transactions emanate out of the same or related set of activities or contract or are disparate are dependent on the facts and circumstances of each case and the Authority may examine this issue in that context. Payment for offshore supply made outside country in foreign currency . Income did  not accrue or  arise in India .  Employees who had signed contracts not dependent agents. Income from offshore supply of  equipment not taxable in India – DTAA – India -Japan . AAR has  no power to review order.  Department not raising objection at time of  admission of  application .  Authority cannot review order of  admission.