TP Comparables Precedent Discipline

The ITAT held that a distributor of TV channels cannot be benchmarked against full-fledged broadcasters or content owners due to fundamental functional differences. 

It reaffirmed that comparability must align with FAR analysis and prior binding rulings in the assessee’s own case. The Tribunal also ruled that imputation of interest on receivables is unwarranted where working capital adjustments already account for such differences. The transfer pricing adjustment was accordingly reworked in favour of the assessee.