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2. The issue sought to be raised in the present appeals pertains to the adjustment made by the Transfer Pricing Officer and the consequent additions made by the Assessing Officer in the assessment orders pertaining to both the assessment years. The respondent / assessee entered into a service agreement with its associated enterprise in Singapore namely Verizon Communications Singapore Pvt Ltd. Since it was an associated enterprise, the Assessing Officer referred the matter to the Transfer Pricing Officer for determining the arms length price. The Transfer Pricing Officer compared the services provided by the respondent / assessee to its associated enterprise with four companies - Engineers India Ltd, RITES Ltd, TCE Consulting Systems Engineers Ltd and Water & Power Consultancy Services Ltd. Thereafter, the Transfer Pricing Officer made the adjustment, which resulted in the Assessing Officer making the additions in respect of both the years. The assessee went up in appeal in respect of both the assessment years before the Commissioner of Income Tax (Appeals).