Held that the company IBPM was not only the market leader but had huge brand value which made it functionally different and non-compatible as compared to the assessee. Therefore, IBPM was held functionally different and not comparable on functional basis with the assessee. On the other hand, the assessee was providing business process outsourcing services itself and only doing the actual work based on specifications provided by its associated enterprises. It was nothing compared to the brand value of IBPM and neither was the assessee a market leader nor did it have a high turnover. Therefore, the Transfer Pricing Officer was to exclude IBPM from the final set of comparables while benchmarking international transactions of the assessee-company. That MPS was an e-publishing company and was one of the most trusted vendor partners to the global publishing industries. This company provided complete end-to-end publishing solutions and had successfully powered its service business with smart technology. MPS made three U. S. based acquisitions that were completed through a wholly owned subsidiary in the U. S. A. This extraordinary event itself by way of several acquisitions rendered this company not comparable with the assessee. In view of the factual and legal analysis the Transfer Pricing Officer was to exclude MPS from the final set of comparables while benchmarking international transactions of the assessee-company.(AY.2016-17)