S. 92C : Transfer pricing-Arm’s length price-Software development service-Comparable-Functionally different-Company, engaged in both development of software products as well as services whose segmental data was also not available could not be accepted as valid comparable-Filter-Related party-Providing multiple services like custom software development in addition to cloud computing, application services and mobile technology-providing software development and IT enabled services like hardware designing-Employee cost-Huge revenue from engineering design charges-broadband services and wireless internet-based communication services-Providing cloud consulting, cloud regulations and cloud application development-Software validation and verification services to banking and financial services industry worldwide-Held to be not comparable-Positive net worth-software development and testing services-Valid comparable.