section. Nonetheless, as an overall matter, GE is correct that in some instances, ITAT‟s characterization of certain conversations appears to overstate the importance of the activities in India (for e.g. e- mail chain on Reliance-GT Exhaust Height; e-mail chain on confirmation of RIL PO No. DG8/3389741). Nevertheless, in many other instances, ITAT‟s decision is sound