https://www.taxtmi.com/caselaws?id=799145 TNMM benchmarking for a limited-risk distributor of licensed content should assess comparability through functions, assets, risks, contractual terms and reliable financial data; product differences alone do not render software or hardware distributors unsuitable comparables. Rejection of the examined comparables solely because they were outside the film or entertainment industry lacked identified material functional or risk differences. An Other Method revenue split requires comparable uncontrolled transactions, reliable market evidence, or an objective economic basis for allocation. Assigned FAR weightages cannot quantify economic value merely by identifying functions and risks. TNMM was applied for arm's-length-price recomputation, deleting the consequential transfer-pricing adjustment. en-us Tue, 15 Sep 2026 00:00:00 +0530 Thu, 17 Sep 2026 07:52:29 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=799145 TNMM benchmarking for a limited-risk distributor of licensed content should assess comparability through functions, assets, risks, contractual terms and reliable financial data; product differences alone do not render software or hardware distributors unsuitable comparables. Rejection of the examined comparables solely because they were outside the film or entertainment industry lacked identified material functional or risk differences. An Other Method revenue split requires comparable uncontrolled transactions, reliable market evidence, or an objective economic basis for allocation. Assigned FAR weightages cannot quantify economic value merely by identifying functions and risks. TNMM was applied for arm's-length-price recomputation, deleting the consequential transfer-pricing adjustment. Case-Laws Income Tax Tue, 15 Sep 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=799145