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These are cross-appeals by Assessee and Revenue against the order(s) of the Assessing Officer (AO) u/s. 143(3) r.w.s. 92CA(4) r.w.s. 144C of the Income Tax Act [Act].

2. Briefly stated, assessee Hyundai Motor India Engineering Private Limited was incorporated in November, 2006 as a subsidiary of Hyundai Motor India Ltd., under the Companies Act, 1956. Assessee is a 100% Export Oriented Unit and is registered under the Software Technology Parks of India (STPI) :- 2 -: I.T.A. Nos.128 & 216 /Hyd/2016 Scheme of the Ministry of Information Technology, Government of India. Hyundai Motor India Ltd., itaelf is a subsidiary of Hyundai Motor Company, Korea [Associated Enterprise (AE)] 2.1. Assessee is involved in providing support services in connection with CAE/CAD modeling and iterative simulation. It receives the basic design from its group company with respect to CAD modeling and makes a 3D CAD modeling data of vehicle components using CAD software tools. Assessee is a routing support service provider and it assumes less than normal risk associated with carrying out such business. The International transactions reported by assessee are as under