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10.7.1 Per contra, the ld DR argued that broader functionally comparability is to be seen under TNMM. The ld DR referred to the observations made by the ld TPO in this regard. The ld TPO had stated that this comparable company is providing specialized services within the field of software development services but these are services and development of product design. The inventory of products reflected in the financial statement just represent 7.8% of the sales and observed Page | 23 Aptiv Components India P. Ltd that it is not a product development company. We find that this Delhi Tribunal in the case of JCIT Vs. Steria India Pvt Ltd for AY 2010-11 in observations made by the ld TPO and the arguments advanced by the ld DR before us in the instant case and held that the said comparable company is engaged into diversified range of software activities and is ISO-9001:2008 certified product engineering and software development company, having special expertise in emerging technology such as cloud computing, business intelligence and mobility and it has been serving client of more than 8 industries across the globe with over 2000 professionals on board. The product engineering services/ outsourced product development services of this company include the product design and development, product feature enhancement, product volume migration, software product testing, product maintenance and support, produce release and license management, SAAS/ SOA services, Web 2.0 services etc; enterprises application development services include customer relationship management, enterprises resource planning, business intelligence, knowledge management, enterprises application integration, consulting etc; ID Services include global offshore software development, custom software development/ bespoke software development, intelligent software testing RIA/ AJAX application development etc and technology expertise of this company include the technology competency centre in relation to Microsoft Competency Centre, Sun Java Competency Centre, Open Source Competency Centre, Cloud Computing practice, mobility practice and BI practice. Accordingly, this Tribunal have concluded that this comparable company is rendering product development services and high end technology services which come under the Knowledge Process Outsourcing (KPO) services and cannot be comparable with Captive Software Development company like assessee. Respectfully following Page | 24 Aptiv Components India P. Ltd the said decision, we hold that this comparable company is functionally different from the assessee company and accordingly, we direct the ld AO/ TPO to exclude the same from the final set of comparables while benchmarking the international transaction by the assessee in respect of software development segment.