Held that  as seen from the annual report, GVK Ltd. was a discovery research and development organization providing a broad spectrum of services, across the research and development and manufacturing value chain. It also held a number of patents as provided in its annual report. It was a product company having inventories and undertook very high level research work, which could not be compared to the assessee, which was a captive service provider. This company was to be excluded from the list of comparable companies in the research and development segment. (AY.  2014-15)