Comparability factors – Segmental result : Where assessee was engaged in providing contract software development services to its AEs, a company engaged in providing custom development services to offshore and also engaged in software engineering services in different fields, in absence of segmentals, was to be excluded from list of comparables – Nokia Solutions and Networks India (P.) Ltd. v. Assistant Commissioner of Income-tax, Central Circle-15 – [2024] 160 taxmann.com 729 (Delhi – Trib.)