Assessee was engaged in providing software development services to its AE. Comparable company was engaged in business of software product, computer programming, consultancy and related services. Segmental result showed that this company had reported unallowable expenses of Rs.193.89 crores and such segmental detail could not be relied upon as margins of said concern could not be finalized in final analysis. Further, under an extraordinary event, it transferred its Product Engineering Services (PES) Business Unit to another group company as part of business restructuring.  Cannot be comparable. Company which is in the business of product design services and graphics animation and gaming, it could not be a comparable. A product company, it could not be comparable. Assessee had not availed any loan from AEs or unrelated third party and was not incurring any interest cost and there was similar delay in receipt of receivables from third parties also and assessee was not charging any interest on third parties, no adjustment could be made on account of interest due on receivable from its AE. (AY. 2015-16)