https://www.taxtmi.com/caselaws?id=350707 Transactions relating to channel subscription and advertisement airtime sale were treated as inter-related for arm's length price determination because subscriber base and advertisement revenue moved together, both supported the same business objective, and the authorities relied on common use of assets, a changed business model and relevant regulatory guidelines. The HC held that segregation or aggregation in transfer pricing is a fact-specific exercise, and found the lower authorities' reasons reasonable. The aggregation for arm's length analysis was upheld and the Revenue's challenge failed. en-us Tue, 07 Nov 2017 00:00:00 +0530 Wed, 31 Dec 2025 10:28:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=350707 Transactions relating to channel subscription and advertisement airtime sale were treated as inter-related for arm's length price determination because subscriber base and advertisement revenue moved together, both supported the same business objective, and the authorities relied on common use of assets, a changed business model and relevant regulatory guidelines. The HC held that segregation or aggregation in transfer pricing is a fact-specific exercise, and found the lower authorities' reasons reasonable. The aggregation for arm's length analysis was upheld and the Revenue's challenge failed. Case-Laws Income Tax Tue, 07 Nov 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=350707