Held, allowing the appeal, that APITCO provided numerous services which were not provided by the assessee ; the assessee was not involved in to skill development, entrepreneurship development and training, research studies, asset reconstruction and management services, energy related service, tourism infrastructure development and environmental management. Further, going through the financial statement of the company for the financial year 2011-12, it is found that the APITCO was held by public shareholders whereas the assessee was held by a private limited company. The services description suggested that APITCO worked predominantly on Government initiative projects. But the assessee was only engaged in providing project management, cost management and management consultancy services. Thus, functionally APITCO was not a comparable company to the assessee and was to be excluded from the list of comparables selected by the Transfer Pricing Officer for benchmarking international transactions for the assessee-company.(AY. 2012-13)