Assessee is a subsidiary of a US Parent. Using TNM Method, the assessee declared a Profit Level Indicator (PLI) of 16.57%. TPO shortlisted 9 comparable and arrived at a margin of 28.18%. While rejecting these comparable on appeal, the Tribunal held three things. First, comparable was engaged in variety of segments unlike the assessee. In the absence of segmental data, the comparable was rejected. Second, PLI of comparable in dispute. DRP agreed with assessee calculation of comparable’s PLI. AO/TPO cannot overlook (S. 144C). Further, where DRP held entity to be functionally comparable, not for TPO to reject comparable basis other filters as it jeopardises the direction of the DRP. (AY. 2012-13)