S. Muralidhar, J.

1. This appeal by the Assessee, under Section 260A of the Income Tax Act 1961 ('Act') is directed against the impugned order dated 12th December, 2014 passed by the Income Tax Appellate Tribunal (ITAT) in ITA No.6023/Del/2012 for the Assessment Year (AY) 2008-2009.

2. Admit.

Background facts

3. The facts are that the Assessee, Honda Siel Power Products Ltd. (‘HSPP’), is engaged both in the manufacture of licensed products as well as the distribution of goods manufactured by its associated enterprises. The Assessee is engaged in the business of manufacturing of portable generating sets, IC engines, water pumping sets and manufacturing and processing of pressure die casting parts. The HONDA trademark is owned by Overseas Associated Enterprise (AE), i.e. Honda Motor Company, Japan (‘Honda Japan’). During the AY in question, the Assessee entered into the following international transactions with its AE:-

Sl. No.	International transactions	Amount (in Rs.)	Method used by Assessee
i.	Payment for purchase of raw material and c