Section 92C of the Income Tax Act, 1961 — Transfer Pricing — Computation of arms length price — Comparability of an uncontrolled transaction can be analysed only with the data relating to financial year in which the international transaction has entered into; if the relevant data for the concerned financial year can be deducted from the information available from the annual report of the RSI Ltd, then the relevant segment thereof can be included in the list of comparables with the adjusted data for the relevant financial year. Simply because a company was wrongly considered by the assessee as Comparable cannot act as a deterrent from challenging before the Tribunal the fact that this company is in fact not comparable — Microsoft India P. Ltd. vs. Deputy Commissioner of Income tax [2018] 196 TTJ (Delhi) 137