The Assessee identified comparables and made adjustments on account of idle capacity on comparables adopted in order to arrive at ALP of its purchase transaction. The TPO held that a comparable having turnover of more than twice turnover of assessee could not be considered as comparable. The High Court observing that it would be impossible to find comparables with all similarities including the similarity of turnover. The High Court further observed that the Tribunal found, on facts, that both te comparable and the assessee were in the segment of manufacture of tractors and power tillers and that all the functions of the comparable and the respondent assessee were the same. Accordingly the High Court found that there was no reason to interfere with the Tribunal’s decision to include the comparable. (AY. 2006-07)