The assessee sought exclusion of certain comparables which had originally been included in its own transfer pricing study after discovering that they were functionally dissimilar. Tribunal held that there is no estoppel against an assessee in transfer pricing proceedings. Merely because a company was initially selected by the assessee as a comparable, the assessee is not precluded from subsequently seeking its exclusion upon demonstrating functional dissimilarity or lack of comparability. Functional comparability must prevail over the initial selection made in the transfer pricing study (AY.2013-14)