The assessee is a captive entity (i.e. risk mitigated entity) mainly engaged in providing Information Technology (IT) enabled services in the nature of call center and low end back office support to its associated enterprises (AE) and billing them at cost plus 15%. It was held that a company engaged in the call center business is a comparable company with that of the assessee. Further, comparable companies should be compared for the same financial year. Further, a leading company without segmental information cannot be accepted as a comparable.  (AY. 2013-14)