Held that  there is fine line of difference between business process outsourcing and knowledge process outsourcing. It is difficult to determine the involvement of human intelligence or skills in the set of process or activities. It is subjective and needs proper analysis of process of work. The activities carried on by the assessee and the parent company were similar. It was difficult to evaluate how much skills or intelligence were applied in providing support services by the assessee. However, the assessee had submitted the statement of work to substantiate the extent of support services provided by it. Eclerx was to be excluded from the final comparables list on the ground of functional dissimilarity and absence of segmental data. A Ltd. was to be excluded from the list of comparables the turnover of TCS-eServe was Rs. 1,578 crores in this segment, whereas the turnover of the assessee was Rs. 114 crores, and there being significant difference, the Transfer Pricing Officer was to exclude the comparable TCS e-Serve from the final list of comparables. That the Transfer Pricing Officer had adopted an ad hoc two per cent. for finalising the working capital adjustment without assigning any reasons for adopting the percentage. This issue was to be remanded to the Transfer Pricing Officer to adopt a reasonable percentage on actual basis based on the data available on record. That in respect of the Assessing Officer’s not granting credit for tax deducted at source, the Assessing Officer was to verify the records submitted by the assessee on the merits as per law giving the assessee a proper opportunity of being heard. (AY. 2008-09 to 2012-13)