The assessee was engaged in the business of providing Software Development Services to its wholly owned holding company having a turnover of around Rs. 23 Crores. The TPO had excluded from the list of comparable companies chosen by the assessee in its TP study only those companies whose turnover was less than Rs. 1 Crore, which was upheld by the DRP. The assessee’s contention was that the AO failed to apply the same yardstick to exclude companies with high turnover compared to the assessee. The ITAT relied on the decision of Dell International Services India (P) Ltd. v. DCIT (2018) 89 Taxmann.com 44 (Bang-Trib) which in the similar factual background held that where contrary views on the issue are possible, a view favourable to the assessee should be adopted. The ITAT also relied on the decision of Autodesk India Pvt. Ltd. v. DCIT (2018) 96 Taxmann.com 263 (Bangalore-Tribunal) wherein it is held that high turnover is a ground for excluding companies as not comparable with a company that has low turnover. Therefore, the ITAT excluded the 7 companies from the list of comparable companies, as sought by the assessee, whose turnover in the current year was more than Rs. 200 Crores. (AY. 2017-18)