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2018 (10) TMI 1169 - AT - Income TaxAddition on account of ALP adjustment - Comparable selection - functional comparability - Held that:- The Assessee Company is primarily engaged in the business of distribution of subscription rights of satellite channels of Cartoon Network, WB, CNN POGO and HBO (collectively referred as ‘V’ Channels’) and advertisement inventory to be telecasted on TV Channels. The activities of the assessee are primarily driven towards promoting the channels and associated proprietary intangible assets on the return of income, thus companies functionally dissimilar with that of assessee need to be deselected from final list.
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