Dismissing the appeal of the Revenue the Court held that mere fact that an entity makes high/extremely high profits/losses does not, ipso facto, lead to its exclusion from list of comparable for purpose of determination of ALP. In such circumstances, an enquiry under rule 10B(3) ought to be carried out, to determine as to whether material differences between assessee and said entity can be eliminated and unless such differences cannot be eliminated, entity should be included as a comparable.  (AY. 2013-14)