Broad functionality insufficient while selecting transactions/entities for transfer pricing comparables

DCIT Vs New Delhi Television Ltd. (ITAT Delhi) ITAT Delhi held that while selecting the comparables transactions or entities, in case of international transactions, the basis should be one of similarity with the control transactions/entities and mere broad similarity is not sufficient. Facts- The assessee company is engaged in the business of television news broadcasting. The case of the assessee was selected for scrutiny and notice u/s 143(2) of the Act was issued on 14.09.2011. Since the assessee was having international transactions with its Associated Enterprises, therefore, a reference w...