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4. The brief facts of the case are that the assessee-company is a wholly owned subsidiary of Roquette Freres S.A., France, engaged in the business of manufacturing starch derivatives, glucose, maltodextrins and related products from its manufacturing units located in India. The Assessing Officer made a reference to the Transfer Pricing Officer (TPO) u/s 92CA of the Act in respect of international transactions with Associated Enterprises. The TPO proposed adjustment by determining the Arm's Length Price (ALP) of intra-group services received by the assessee at NIL, comprising Central Corporate and Area (CCA) services, Global Business Unit (GBU) services, and Information Technology (IT) services. For AY 2017-18, the details of the impugned international transactions are as under:-