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23. In respect of Accentia Technologies Ltd., the ld. Counsel submitted that the said company is providing medical transcription services, medical coding, medical billing, receivables management with respect to the healthcare Receivables Cycle Management Sector. The ld. Counsel submitted that the said company has developed its own software products and owns intangibles in the form of Goodwill. Such software products are primarily the platforms required for rendering medical transcription services. The analysis of activities carried out by Accentia Technologies Ltd. using its own platform would show that the activities of the said company are distinguishable from other medical transcription service providers such as e4e Healthcare Solutions Ltd. The ld. Counsel further pointed that Accentia Technologies Ltd. during the Financial Year 2007-08 has entered into amalgamation/acquisition of other companies, therefore, the said company cannot be selected as comparable. The ld. Counsel in support of his contentions referred to Annual Report of Accentia Technologies Ltd. for Financial Year 2007-08 at page 800 of the paper book.

24. The ld. Counsel for the assessee further submitted that the Co- ordinate Bench of the Tribunal in assessee's own case in ITA No. 336/PN/2014 for assessment year 2009-10 decided on 31-10-2014 excluded Accentia Technologies Ltd. from the list of comparables on account of functional difference.

25. The ld. DR vehemently defended the findings of TPO and DRP in including Accentia Technologies Ltd. in the list of comparables.

26. Both sides heard. We find that the Co-ordinate Bench of the Tribunal in assessee's own case in ITA No. 336/PN/2014 (supra) has excluded Accentia Technologies Ltd. from the list of comparables by observing as under :

"47. The next objection of the learned Authorized Representative for the assessee was with regard to the inclusion of M/s. Accentia Technologies Ltd. which admittedly was engaged in developing its own software products and was rendering medical transcription services. Further, the said company during the year under consideration had made certain acquisitions which in turn affected the margins of the year of the acquisition. We find that Hyderabad Bench of the Tribunal in the case of Capital IQ Information Systems (India) Pvt. Ltd. (supra) had rejected Accentia Technologies Ltd. for having extra-ordinary circumstances i.e. amalgamation. Following the parity of reasoning as adopted by the Hyderabad Bench of the Tribunal, we hold that the said company had different functional profile as compared to the assessee, which in turn explained the abnormally high profit margins earned by the said company as compared to the assessee. Accordingly, we accept the plea of the assessee and hold that the said company is not to be used as comparable in ITES segments of the assessee."

27. Further, on perusal of annual report of Accentia Technologies Ltd. for the Financial Year 2007-08 we find that the said company had acquired Thunga Software Pvt. Ltd. a Medical Transcription and Coding Company, consolidated the operations of Asscent Infoserve Pvt. Ltd. one of its subsidiary, Iridium Technologies and Geosoft Technologies amalgamated into parent company i.e. Accentia Technologies Ltd. The company had also acquired 3 companies in the USA. Thus, on account of extra-ordinary events viz. merger, consolidation and amalgamation there would be aberration in the financial results of the company. It is a well settled principle that where there are extraordinary events in a particular financial year of a company, the said company should not be selected as comparable. Thus, in the light of facts of the case and the decision of Co- ordinate Bench of Tribunal, Accentia Technologies Ltd. cannot be considered as good comparable. Therefore, the same is directed to be excluded from the final list of comparables.