https://www.taxtmi.com/caselaws?id=797460 IPL franchise rights that confer exclusive commercial rights to own and operate a franchise, participate in the league and exploit related revenue streams constitute depreciable intangible business or commercial rights. Their actual cost is the full contractual consideration when liability arises on acquisition; deferred instalments are only a payment mode, subject to written-down-value adjustment if consideration is later altered. Transfer-pricing review must test arm's-length consideration and cannot question the commercial expediency, necessity or adequacy of services. Management-fee reimbursement requires fresh determination on supporting evidence rather than a nil value. Where aggregate international transactions exceed the prescribed threshold, a binding CBDT Instruction requires reference to the Transfer Pricing Officer; an internal action plan cannot alter that requirement. en-us Mon, 20 Jul 2026 00:00:00 +0530 Sat, 22 Aug 2026 10:33:34 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=797460 IPL franchise rights that confer exclusive commercial rights to own and operate a franchise, participate in the league and exploit related revenue streams constitute depreciable intangible business or commercial rights. Their actual cost is the full contractual consideration when liability arises on acquisition; deferred instalments are only a payment mode, subject to written-down-value adjustment if consideration is later altered. Transfer-pricing review must test arm's-length consideration and cannot question the commercial expediency, necessity or adequacy of services. Management-fee reimbursement requires fresh determination on supporting evidence rather than a nil value. Where aggregate international transactions exceed the prescribed threshold, a binding CBDT Instruction requires reference to the Transfer Pricing Officer; an internal action plan cannot alter that requirement. Case-Laws Income Tax Mon, 20 Jul 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=797460