Functional comparability under TNMM supported exclusion of ITeS comparables with R&D, intangibles, diversified operations, or unavailable segmental da...
Functional comparability governs selection of support-service and IT-enabled service comparables, with verification required for unresolved data and m...
Bank account freezing requires statutory authority; anti-money-laundering compliance and KYC monitoring do not permit unilateral indefinite restrictio...
Live broadcasting rights, characterised as a one-time transmission without an enduring benefit, are neither a scientific work nor rights in which copyright subsists. Licence fees for those rights therefore fall outside royalty treatment under the India-UK DTAA, unlike non-live repeat telecasts and highlights. A mutually agreed allocation of broadcasting fees between live and non-live rights remains valid absent material showing that the allocation is unjustified. Release fees received for permitting athletes to participate in a league, being separate from player remuneration and not arising from athletes' personal activities, fall outside the athlete-income provision of the India-UK DTAA.
Live broadcasting rights, characterised as a one-time transmission without an enduring benefit, are neither a scientific work nor rights in which copyright subsists. Licence fees for those rights therefore fall outside royalty treatment under the India-UK DTAA, unlike non-live repeat telecasts and highlights. A mutually agreed allocation of broadcasting fees between live and non-live rights remains valid absent material showing that the allocation is unjustified. Release fees received for permitting athletes to participate in a league, being separate from player remuneration and not arising from athletes' personal activities, fall outside the athlete-income provision of the India-UK DTAA.
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