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Wissen Infotech Pvt.Ltd.

6. The Assessee submits that relying on various independent researches and studies wishes to conclude that in the software sector, the size of a company's operations has an impact on the margins earned by the companies. The basic conclusion from the analysis shows that operating margins for companies in the software sector increase with increasing size of the company's operations (as proxied by the size of its operating assets) but at a decreasing rate. Hence, it is appropriate to apply upper turnover filter based on the classification of companies in Dun & Bradstreet. Further, as specified above the Ld. TPO rejected specifying R&D expense some percentage of sales, etc. which has not been applied by the assessee company itself in its TP documentation. The assessee company has not selected any company which is having negative net worth.