Held that the company M was a manufacturing and engineering company mainly into space and energy saving ejector vacuum systems. One of the products manufactured was the valve and the company in its annual report had given the financials of the valve products separately. The Transfer Pricing Officer had for the purpose of comparability considered the revenue and cost attributable to valve products only. The level of comparability under transactional net margin method was at a broad level of product comparability and high level functional comparability. Therefore, M could not be excludeThat the company Y was included by the assessee in its transfer pricing study but during the remand proceedings, the assessee sought its exclusion before the Transfer Pricing Officer on the basis that the list of items manufactured by the company included products that were not similar to those of the assessee and the segmental profit with respect to valve products similar to the assessee was not available for comparability. There was no requirement for a segmental comparison, when the overall product range was very similar. Therefore, Y had a broad level of product comparability and high level of functional comparability and rightly included in the list of comparables by the Revenue authorities.  That L was involved in manufacturing of industrial valves, coils, boiler mounting and forge fittings. The range of products include gun metal/bronze valves, cast steel valves, forged steel valves, cast iron valves, boiler mounting valves. The company served industries in oil and gas, power, marine and water, steel and mining, chemical and fertilizers and HVAC. Therefore, applying the principles laid down by the Tribunal in the assessee’s earlier case, L should be included as a comparable, considering the broader product comparability and high level of functional comparability. Since this issue was not originally raised in the first round of proceedings, the entire issue of comparability of the companies was set aside to the Transfer Pricing Officer and it was open for the assessee to seek inclusion of this company based on a fresh transfer pricing study  That the Assessing Officer was to allow the working capital adjustment to the assessee That the assessee’s borrowing was for one year period according to the terms of the loan agreement and therefore the interest charged by the assessee at LIBOR + 150 basis points which was within the range according to the Reserve Bank’s Master Circular, RBI/2005-06/87, A.P. (DIR Series) Circular No. 5, dated August 1, 2005, was within the arm’s length. The adjustment made on this count was to be deleted.(AY.2007-08)