S.V. Mehrotra, Accountant Member - This appeal filed by the assessee is directed against the order of AO dated 10/10/2011 for AY 2007-08 passed in terms of directions of Dispute Resolution Panel (DRP) u/s 144C(5) dated 02/08/2010.

2. The assessee company was incorporated in the year 1999 as a joint venture between American Express International Inc. and Tata Group. However, in the year 2002, American Express International Inc. became the holding company by acquiring stake from Tata Group. Presently 99.99% of share capital of the company is owned by American Express International Inc. and remaining .01% is owned by Tata Group. The assessee company is providing following services: -

(1) Distribution of AEE charge, credit cards and other cards.

(2) Distribution of AEB personal loans and other retail lending products.

(3) Support for marketing and promotion of products, scheme etc. of AEB.

3. The assessee had filed its return of income declaring loss of Rs. 6,62,96,780/-. The AO noticed that assessee had undertaken International transactions with its associated enterprise to the tune of Rs. 7,03,224/-. Therefore, in accordance with the provisions of section 92CA of the Income Tax Act,