Sec. 92C of Income Tax Act, 1961 — Transfer Pricing —  Selection of comparable — when comparable company is engaged in diversified activities of software development and consultancy, engineering services, web development & hosting and substantially diversified itself into domain of business analysis and business process outsourcing then the same cannot be regarded as functionally comparable with that of the assessee who is rendering software development services to its AE. when comparable company is in the business of software products, the same cannot be compared with a pure software development services provider—Yokogawa IA Technologies India (P.) Ltd. vs. Dy. CIT.2020] 180 ITD 621 (BANG)