Held, dismissing the appeal the Court held that the Tribunal after considering in detail the facts of the case had given the finding of fact that the transactional net margin method applied by the assessee was the correct method and the application of comparable uncontrolled price method was not justified, in view of the fact that intra associated enterprise transactions were fundamentally different in character in economic circumstances and contractual terms and these could not be compared with the independent transactions entered into by the assessee. The findings of fact recorded by the Tribunal in the order could not be termed perverse or contrary to the evidence on record. The Tribunal had taken into consideration the voluminous documentary evidence on record for the purpose of coming to the conclusion of adoption of the transactional net margin method by the assessee as the most appropriate method of arriving at the arm’s length price.  No question of law. (AY. 2007-08, 2008-09)