Dismissing the appeal of the revenue the Court held that, the Asseessee had 96% international transactions with US based AEs and rest were with non –US based AEs. There was no distinction between US and non–US  based transactions. US Govt.  entered in to Mutually  Agreed Procedure for determining tax in two countries. CBDT, in later years agreed that such transfer pricing in relation to US based transactions could safely be adopted for purpose of assessee’s non –US based transactions to which the aseessee agreed under Advance Pricing Agreement. Tribunal held that for determining ALP of non–US transactions said  MAP between  India and US could be applied.  High Court up held the order of the Tribunal. (AY. 2007 -08)