VIBHU BAKHRU, J.

1. The Assessee has preferred these appeals under Section 260A of the Income Tax Act, 1961 (hereafter ‘the Act’) impugning the orders passed by the Income Tax Appellate Tribunal (hereafter ‘the Tribunal’) in respect of Assessment Years (hereafter ‘AYs’) 2007-08, 2008-09, 2009-10 and 2010-11.

2. The controversy in these appeals relates to the Transfer Pricing Adjustments directed by the Tribunal in respect of the commission earned by the Assessee with respect to certain international transactions with its Associated Enterprises (hereafter 'AEs') which are referred to as "indenting transactions". The Tribunal has directed that the Arms Length Price (hereafter ‘ALP’) in respect of such transactions be determined on the basis of the average rate of commission earned by the Assessee in respect of transactions with unrelated parties ('Non-AEs'). The Assessee claims that the said direction is patently erroneous as the indenting transactions with Non-AEs are not comparable with indenting transactions with its AEs; the volume of the indenting transactions with N