Allowing the appeal of the assessee the Tribunal held that Companies selected by TPO were functionally dissimilar with assessee then companies could not be included in list of comparables. Company was into development of hardware and software for embedded products, such as, multimedia and some other electronics etc. Apart from that, this company was also engaged in making some programme developing technology intellectual property. As nature of activity carried out by assessee in question was nowhere close to that of Tata Elxsi Ltd., this company could not be included in list of comparables.  ( AY.2007-08)