Assessee was, thus, a captive routine software development service provider who did not own any significant intangibles. Selected company operated in diversified markets, owned IPRs and brand value and focussed on Research and Development cannot be comparable.

Selected company was an IT consulting firm engaged in consulting, designing, implementing and supporting enterprise applications. It had significant capabilities in transaction, analytics and cloud layers of enterprise application.  It also rendered industry specific solutions spanning business applications consulting, design, implementation and support.  Since services rendered by this company were in nature of knowledge process outsourcing services and were entirely different from routine SWD services rendered by assessee, it would not be comparable.

PLI should be worked by considering provision for doubtful debts as operating expenditure. (AY. 2014-15)