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Channel owners cannot be taken as comparables for distributors for transfer pricing purpose
Case Law Details
- Case Name
- Warner Media India Pvt. Ltd. Vs ACIT (ITAT Delhi)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Related Assessment Year
- 2017-18
- Courts
- All ITAT, ITAT Delhi
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Warner Media India Pvt. Ltd. Vs ACIT (ITAT Delhi)
ITAT Delhi held that companies owning and operating channels cannot be compared with distribution company for the purpose of transfer pricing. Accordingly, directs TPO to exclude such comparables for benchmarking distribution segment and determination of ALP.
Facts- The present appeal is preferred by the appellant. It is mainly contested that the seven comparables selected namely Vision Corporation Ltd., News 24 Broadcast India Ltd, TV Vision Ltd, Enter 10 Television Pvt. Ltd, Malayalam Communications Pvt. Ltd, Odisha Television Ltd. and TV To...






