Tribunal held that where assessee was a captive software development service provider having turnover less than Rs. 200 crores, companies having higher turnover of more than Rs. 200 crores could not be compared with assessee. DRP provided risk adjustment at 1 per cent on ad hoc basis, since assessee was a low risk bearing company for software development services and information technology enabled services segment, while computing risk adjustment, risk assumed by comparables for earning revenue under particular segment was to be analysed.  Assessee was a low risk bearing company for software development services and information technology enabled services segment. DRP provided risk adjustment on ad hoc basis at 1 per cent. Tribunal held that since assessee was low risk bearing company, while computing risk adjustment, risk assumed by comparables for earning revenue under particular segment was to be analysed  and  TPO was to be directed to re-compute risk adjustment in accordance with law. A company rendering software development services and licensing and earning royalty of software products, in absence of segmental details, could not be considered as comparable to assessee. A company engaged in diverse field of activities of software development could not be regarded as functionally comparable with assessee. A company had undergone acquisition which was an extraordinary event that would impact profits for year under consideration, this company could not be considered as comparable. Where TPO selected a company as comparable to assessee, however, assessee contended that said company was not functionally comparable as under this segment same was into high-end KPO services whereas assessee was carrying out back officer services, comparability analysis said company was to be set aside to TPO for fresh consideration. Company was not functionally comparable as under this segment said company was into high-end KPO services whereas assessee was carrying out back officer services.  Matter remanded to TPO.   If information as regards comparable companies available in public domain was insufficient, it was beyond power of assessee to produce correct information about said comparables, however, revenue had sufficient powers under section 133(6) to compel production of required details from comparable companies; therefore, it was no defense to say that assessee had not furnished required details to deny working capital adjustment. TPO was to be directed to recompute working capital adjustment in actual, and to consider same for purposes of computing arm’s length margin. (AY. 2010-11)