Assessee-company was engaged in business of provision of software development services hence a software product company was incomparable. RPT of comparable company at 18.66 per cent was beyond threshold limit of 15 per cent, this company was to be excluded from list of comparable companies. Company engaged in Knowledge Process Outsourcing (KPO), could not be regarded as comparable to a Software development services provider. A company engaged in engineering and consulting services, in absence of segmental information available to compare margins of SWD services segment of said company, could not be selected as comparable to Software development service provider. Where a company was engaged in manufacturing of software products and was a giant company assuming various risks, it could not be compared with assessee-company, a software developer. Company engaged in manufacturing of software products and assuming various risks, was incomparable. When working capital adjustment is positive, it should be allowed on actual without putting a cap on working capital adjustment, i.e., without restricting working capital adjustment to average working capital component of comparables. (AY. 2010-11)