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18. The TPO has selected E-Zest Solutions Ltd. in the final set of comparables on the ground that functions carried out by this company are similar to the functions carried out by the assessee. The Ld. AR for the assessee submitted that the Ld. TPO in his order has rejected one of the comparable, vis Vama Industries Ltd. selected by the assessee in the TP study stating that company is engaged in providing engineering services that is more akin to a KPO, but when it comes to selection of comparables, the TPO has accepted E-Zest Solutions Ltd. which is also engaged in engineering services ignoring all the submissions made by the assessee. The Ld. AR further submitted that this company is functionally not comparable as it is engaged in software product development which is evident from the annual report where it carries inventory. This company is into software development services and software product development. It has super normal profits leading to high margins. Further, E-Zest solutions Ltd. is into various business segments and an ISO 9001:2008 certified Product Engineering and Software Development Company, having special expertise in emerging technologies such as Cloud computing business intelligence, etc. Therefore, the same cannot be compared with the assessee company. In this regard, he relied upon number of judicial precedence including the decision of ITAT, Delhi in the case of Clear 2 Pay India Pvt. Ltd. vs ITO (2018) 95 taxmann.com 284 (Del. Trib.).

20. We have heard both parties, perused the material available on record and gone through orders of the authorities below. The main contention of the assessee is that this company is functionally not comparable as it is engaged in Software product development services including product design and development, product feature enhancement, product platform migration, software product testing, maintenance and support and license management etc. This company is into diversified activities and also an ISO 9001:2008 certified Product Engineering and Software Development Company, having special expertise in emerging technologies such as Cloud computing business intelligence, etc. Although, it is involved in diversified activities but no segmental information is available to compare revenue from each segment. This company carries inventories and this clearly shows that it is a product development company. It has super normal profits leading to high margins. Therefore, we are of the considered view that this company cannot be considered as IT(TP)A Nos.945 & 2047/Mum/2016 Mobileum (India) Pvt. Ltd. (Formerly known as Roamware (India) Pvt.Ltd.