Assessee rendered software development services to its AE.  Where selected companies had reported negative margin in impugned assessment year, they could not be considered as incomparable, particularly when in preceding two years, they had reported positive profit margin.  Held that where selected company was engaged in sale of software products and software services and segmental details relating to various segments were not available, said company could not be selected as comparable. Where selected company had reported sale of software license, this company could not be considered as a comparable to a software development service provider. Where selected company reported revenue from software development services as well as business process outsourcing (BPO) services and segmental details relating to revenue earned were not discernible from annual report, it could not be included in list of comparables.(AY. 2013-14)