Transfer pricing requires evidence for AMP transactions, functionally reliable comparables, and appropriate aggregation or Berry Ratio benchmarking me...
Revisionary jurisdiction cannot reopen share capital assessments where adequate inquiry supports a permissible view and no independent error is establ...
Reassessment jurisdiction fails where unverified portal information is aggregated without examining the taxpayer's explanation or relevance of entries...
Statutory sanction for delayed reassessment requires approval from the prescribed authority; approval by an inferior authority invalidates jurisdictio...
Transfer pricing margin adjustments require matching treatment of non-operating income and related costs, with comparability issues reconsidered on ev...
Preliminary-expense amortisation and MAT exempt-income adjustments prevailed, while trademark costs and managerial remuneration require fresh verifica...
Export valuation requires contemporaneous evidence; unrelated invoices cannot prove overvaluation, and dual penalties on firm and partner are impermis...
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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