Sec. 92C of Income-tax Act, 1961 - Transfer pricing - A company engaged in providing on-site services cannot be compared with a company providing similar services from its own premises (in-house) due to several significant differences in operating costs and also the Revenues apart from vital differences in the level of assets employed and risks undertaken. This company cannot be considered as comparable as it is not only engaged in the business of Software products but is also providing on-site services, which make it distinguishable from the assessee-company. Therefore, order issued to exclude this company from the list of comparables. - JOHN DEERE INDIA (P) LTD. V/s ASSTT. CIT - [2020] 206 TTJ 213 (ITAT-PUNE)