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3.1 The Transfer Pricing Officer (TPO) has included Accentia Technologies Ltd. ('Accentia') in the final set of comparable on the ground that the company is a BPO and is into healthcare receivable management. The Ld. counsels of the assessee submit that Accentia is engaged in software development and Knowledge Process Outsourcing ('KPO') services in the nature of healthcare revenue cycle management and legal process outsourcing services. However, no separate segmental information is available for the software development and healthcare services provided by the company. Thus it is stated that in M/s Sitel India Pvt. Ltd. 3 the absence of separate segmental information, Accentia has to be rejected as a comparable.

Respectfully following the decision of the co-ordinate bench of Tribunal, we direct the AO/TPO to delete Accentia Technologies Ltd. from the list of comparables."

3.4 Facts being identical, we follow the above order of the Tribunal in assessee's own case for the immediate preceding assessment year and direct the TPO/AO to delete Accentia Technologies Ltd. from the final list of comparables.

Thus the 13th ground of appeal is allowed.

4. The 14th ground of appeal The AO erred in considering Acropetal Technologies Ltd. (Seg). as comparable to the assessee for benchmarking its international transaction of provision of IT enabled services, disregarding the fact that the company is functionally different from the assessee i.e. it is engaged into Knowledge Process Outsourcing Services.

5.1 The TPO included ICRA Online Ltd. (Seg) (in short 'ICRA')on the ground that it is engaged in data processing and data mining and accordingly it is providing similar services (ITeS). The DRP upholds the order of the TPO, which is followed by the AO.

5.2 The Ld. counsels of the assessee submit that as per the annual report, the company has following three business segments:

(i) Information Services,

(ii) Software Services and

(iii) Outsource Services It is further stated that the TPO has considered the operations of the 'Outsourced Services' segment as comparable to the operations of M/s Sitel India Pvt. Ltd. 11 the appellant. The Ld. counsels argue that the annual report of the company does not provide any description as to the nature of the services contained in the segment. However, a reference may be drawn to the annual report of ICRA Ltd., the holding company of ICRA from where it can be seen that the outsourced segment of the company relates to KPO and online software services.

M/s Sitel India Pvt. Ltd. 12 5.4 We have heard the rival submissions and perused the relevant materials on record. The reasons for our decisions are given below.

The TPO has considered the operations of the 'Outsourced Services' segment of ICRA as comparable to the operations of the appellant. However, we find that the annual report of the company does not provide any description as to the nature of the services contained in this segment. As per page 532 of the P/B, a reference may be made to the annual report of ICRA Ltd., the holding company of ICRA from where it can be seen that the outsourced segment of the company relates to KPO and online software services. Also page 8 of the annual report of ICRA Ltd. delineates the business of ICRA stating that the company is engaged in providing KPO and online software services. As per the description at page 532 of the P/B, the knowledge process outsourcing division provides financial and analytical services and support to clients in the area of data extraction, aggregation, electronic conversion of financial statements, validation and analysis, accounting and finance, research and analytics.