Final benami adjudication bars contradictory tax-evasion prosecution where settlement findings confirm full disclosure and cooperation without conceal...
Faceless assessment and registration procedures are updated through electronic communication, revised recovery rules, extended deadlines, and replacem...
Risk-based selective vessel boarding requires accurate declarations and preserves master and agent liability where physical inspections are not select...
Functional comparability under TNMM for licence fees paid by a limited-risk distributor of licensed film and television content turns on functions, assets, risks, contractual terms and reliable financial data, rather than product similarity alone. Software and hardware distributors may therefore be valid comparables despite distributing different products. A revenue split under the Other Method requires comparable uncontrolled transactions, reliable market evidence or another objective economic basis to quantify contributions; allocated functional weightages alone cannot establish an arm's length price.
Functional comparability under TNMM for licence fees paid by a limited-risk distributor of licensed film and television content turns on functions, assets, risks, contractual terms and reliable financial data, rather than product similarity alone. Software and hardware distributors may therefore be valid comparables despite distributing different products. A revenue split under the Other Method requires comparable uncontrolled transactions, reliable market evidence or another objective economic basis to quantify contributions; allocated functional weightages alone cannot establish an arm's length price.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
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