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102. Assessee's resistance to include this company in the final set of comparables is based on the ground that this company is engaged in development and sale of software products and cannot be regarded as an appropriate comparable for benchmarking the international transaction of provision of software services undertaken by the assessee and is having expertise in emerging technologies such as cloud computing, business intelligence, mobility etc., therefore, it renders the company and in appropriate comparable for benchmarking the routine software services rendered by the assessee. Ld. TPO noted that the assessee canvassed the broader portfolio of services (diversified services) as the basis for the non-comparability of this company.

site/offshore software development, custom software development/bespoke software development, independent software testing, RIA/Ajax application development etc and technology expertise of this company includes the technology competency centers in relation to Microsoft competency Centre, Sun Java competency Centre, open source competency Centre, Cloud computing practice, mobility practice and BI practice.

107. By no stretch of imagination can anyone say that the e-Zest Solutions Ltd which is rendering product development services and high- end technical services which come under the category of KPO services would be comparable with a captive software development company like the assessee and on the ground is not comparable with a company which is into software development services. We consequently find that the Ld. DRP is justified in excluding this company from the final set of comparables to benchmark the international transaction of software development.