Held that the Commissioner (Appeals) was justified in applying the turnover filter to exclude companies whose turnover was in excess of Rs. 200 crores from the list of comparables. The assessee’s turnover of about Rs. 29 crores could not be compared with six of the comparable companies whose turnover was more than Rs. 200 crores. As for the remaining three companies, the Tribunal, with reference to assessment year 2010-11 in the case of EI, had treated these three companies as not comparables on the ground that one of the companies was engaged in diversified activities and the second company was engaged in software products, neither of which was comparable with a pure software development service provider such as the assessee. The third company earned revenue from software services as well as sale of software products and did not have segmental details to be comparable with the assessee. Hence, all three companies had to be excluded from the list of comparable companies. Companies functionally different and those with diversified activities without segmental details not comparable. Working capital adjustment to be computed on basis of actuals without an upper limit.  Matter Remanded. Held that prior to March 31, 2013 there had been a letter dated February 18, 2013 issued by the Assessing Officer to the Transfer Pricing Officer making a reference under section 92CA. The fact that the Transfer Pricing Officer received this letter only on April 18, 2013 could not be the basis to conclude that there was no reference under section 92CA and, therefore, the extended period of limitation of three years under the third proviso to section 153(1) was not available to the Revenue. As an order of reference had been made under section 92CA on February 18, 2013, the assessee’s contention that the reference was made two years from the end of the relevant assessment year and, therefore, barred by limitation could not be accepted. On facts extended limitation available to Revenue. (AY.2010-11)