Tribunal held that, where there was a Marketing Fund Agreement (MDF) between assessee and AE regarding AMP and shop display activities, scope and value of International Transaction could not have been expanded beyond reimbursement received under MDF agreement to cover entire gamut of AMP expenditure incurred by assessee during year and as such, adjustments made by TPO on account of AMP expenses would not be sustainable in law.  Assessee company was engaged in business of manufacturing and trading of consumer electronics, home appliances, mobile phones and IT products and was also performing critical functions such as quality control and post sale/warranty support as a routine distributor  A company being an aggregator, providing a platform for sale of electronic products of multiple brands and, thus, having a different business model vis-à-vis assessee having routine buy-sell model would not be comparable and hence was to be excluded. A company engaged in sale of surgical and medical equipment would not be comparable to assessee engaged in business of manufacturing and trading of consumer electronics, home appliances, mobile phones and IT products. Matter remanded.  A comparable cannot be rejected merely on ground that its financial year is different particularly when result can be extrapolated using quarterly result. No comparable can be rejected merely on ground that its financial year is different particularly when result can be extrapolated using quarterly results Matter remanded.  (AY. 2014-15)