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3. The Assessee is a wholly-owned subsidiary of CPA Mauritius Ltd. which in turn is a subsidiary of CPA Jersey. It offers a comprehensive range of legal support services to its Associated Enterprises („AEs‟) as well as to independent third party customers. During the AY in consideration, the Assessee earned a margin of 36.08% on cost.

4. The Assessee had undertaken the following international transactions during the AY in consideration:

(a) Provision of IT enabled services - TNMM was applied and the value of transaction was Rs.