Three comparables excluded as functionally dissimilar; assessee's 15.25% margin arm's-length under Section 92C; Section 10AA deduction reexamined under Section 154

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....The ITAT held that three proposed comparables (Comparable A, Comparable B, Comparable C) are functionally dissimilar to the assessee and must be excluded from the comparable set. Comparable A was engaged in product development, owned significant intangibles and derived substantial non-service revenue; Comparable B was principally a packaged-software trader and geospatial services provider; Comparable C was predominantly a distributor with a materially different cost and employee profile. On exclusion of these entities, the assessee's operating margin of 15.25% falls within the permissible arm's-length range under section 92C, and no transfer-pricing adjustment survives. The AO was directed to re-examine and rectify the denied deduction claim under section 10AA pursuant to the assessee's section 154 application.....