Dismissing the appeal of the Revenue  the Court held that the Commissioner (Appeals) had recorded a finding that since the assessee had earned profit in the technical service segment in contracts other than with SKF the Transfer Pricing Officer should not have loaded the mark-up on the costs and expenses incurred in meeting the obligations under contracts other than with SKF on which the assessee had earned a profit of 36 per cent. on operating cost. The finding of fact had been affirmed in appeal by the Tribunal. The findings had been arrived at by the Commissioner (Appeals) and the Tribunal on the basis of meticulous appreciation of evidence on record. No question of law arose from the order.( AY. 2004-05)