In transfer pricing 2 companies can be compared only if they are functionally comparable

Brief of the case: Assessee was engaged in the field of providing insurance & Human Resources  services to its associated enterprise in UK. The Ld. AO /TPO made an addition to the  income of the assessee by comparing the income of the assessee with the income of the comparable companies because in the eyes of the Ld AO/TPO they were functionally comparable if the companies are in the same functional segment. But on the other hand assessee argued by filing an appeal with ITAT that the addition made by the Ld AO/TPO is not justifiable on the grounds that the above companies are not compara...