Assessee, a subsidiary of US based company undertook engineering design services (EDS) for its AEs. Assessee submitted that issue related to transfer pricing adjustment made in respect of EDS had been settled through Mutual Agreement Procedure (MAP) and margin was determined at 15.85 per cent for USA related transactions. Tribunal held that since USA related transactions constituted 96.30 per cent of total turnover of EDS segment for which margin was agreed to be 15.85 per cent under MAP resolution, same rate was to be adopted for non-USA related transactions under EDS segment. (AY. 2011-12)