Held that Transfer pricing study report must be reliable and correct. Functional asset and risk analysis required to be done. Rejection of  transfer pricing study report is proper. Manufacturing segment and information technology enabled services segment and   manufacturing different products using different materials, those with widely different import-filter for procurement of raw materials or with related-party-transaction filter exceeding 25 Per Cent are  to be excluded. Setting up of export-oriented unit and ownership of intangibles are not explained as impacting business results to merit exclusion. Wide variation between comparables in export-to-turnover ratio to be re-examined. Manufacture of clutch assembly functionally similar to that of brake assembly. Profit margin under the mutual agreement procedure with U. K. entities not to be adopted for transactions with non-U. K. transactions unless factors influencing price similar. Working capital adjustment allowed in subsequent years to be allowed in year in question. Matter remanded for verification. (AY.2007-08)