The assessee before us is engaged in the provision of information technology enabled services and undertakes IT enabled back office medical transcription service exclusively for its AE. The assessee is a 100% export-oriented unit under the software technology park scheme, and enjoys a tax holiday under section 10A of the Act. The short issue requiring our adjudication, on these facts, is whether the transfer pricing provisions cannot be invoked in this case even though admittedly there is no, and there cannot be any, tax avoidance motive in such a situation.