Held that  companies whose turnover in the current year was more than Rs. 200 crores were to be excluded for the purpose of comparable companies.   That the assessee-company was engaged in providing cloud service to its associated enterprises but AS Ltd. was engaged in providing professional services and procurement, implementation and support of ERP products and services. The Dispute Resolution Panel was right in excluding it. That the assessee for the first time before the Dispute Resolution Panel sought to include A Ltd., and S Ltd. as comparables because they passed all the filters and functions, risk and assets analysis. The issue was remitted to the Transfer Pricing Officer for consideration de novo. (AY.2016-17)