https://www.taxtmi.com/highlights?id=103862 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. en-us Thu, 17 Sep 2026 07:52:26 +0530 Thu, 17 Sep 2026 07:52:28 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=103862 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. Highlights Income Tax Thu, 17 Sep 2026 07:52:26 +0530 https://www.taxtmi.com/highlights?id=103862