The Tribunal held that HCL had related party transactions of 71.09 per cent. and HP had got 87.44 per cent. related party transactions. Although the Transfer Pricing Officer had mentioned that the objection of the assessee regarding related party transactions was not substantiated with any account details, from the details furnished by the assessee the assessee had categorically mentioned before the Transfer Pricing Officer regarding substantial related party transactions. A potential comparable having more than 25 per cent. related party transactions was to be ignored. Under these circumstances, the Transfer Pricing Officer was directed to exclude the two comparables on account of huge related party transactions. S could not be considered as a comparable on account of unreliable financials. Under these circumstances, the Transfer Pricing Officer was directed to exclude S from the list of comparables. Tribunal also held that  TPO in the instant case, without verification of the working submitted by the assessee at the time of hearing, had simply disallowed the claim, considering the totality of the facts of the case and in the interest of justice, this issue was remanded to the Transfer Pricing Officer with a direction to verify the working capital adjustment, the details of which had been given by the assessee and allow appropriate working capital adjustment to the assessee after due verification of the same. ( AY.2003-04, 2004-05)