R.C. Sharma, Accountant Member - These two appeals filed by the assessee are directed against the orders passed by the ld. DRP Panel II, Mumbai dated 17-9-2010 & 12-09-2011for the assessment years 2006-07 and 2007-08, in the matter of order passed by A.O. u/s 143(3) r.w.s. 144C(13) of the Income Tax Act, 1961.

2. Common grounds have been taken by the assessee in both these years, therefore, these were heard together and disposed of by this consolidated order.

3. The following grounds have been by the assessee in A.Y. 2006-07:

"The Additional Commissioner of Income Tax - Range 5(3), Mumbai erred in making as assessment u/s 143(3) r.w.s. 144C(13) and erred in:

1.1 in making an adjustment u/s 92CA towards interest of Rs. 45,01,303 that ought to have been charged to overseas subsidiaries.

1.2 in not appreciating that the loans given to the overseas subsidiaries are in the nature of quasi equity.

1.3 in not considering the external Comparable Uncontrolled Price benchmarks provided by the appellant.

1.4 without prejudice, the rate of interest used by the A 0 is excessive and needs to be substantially reduced.

2.1 in disallowance of interest assumed to be expended on expansion of the busines