https://www.taxtmi.com/caselaws?id=471767 Commercially inseparable channel subscription and advertisement airtime distribution transactions should be aggregated for arm's-length benchmarking where they are mutually reinforcing, use the same assets, and operate under regulatory rights covering both revenue streams. Separate evaluation is unreliable when neither activity can practically be relinquished while retaining the other. Comparable entities must also have a similar functional and asset profile. Businesses involved in programme production, multi-channel broadcasting, radio operations, newspaper circulation, or ownership of significant intangibles are functionally dissimilar to a sports-channel and advertising-inventory distributor and should be excluded from the comparable set. en-us Wed, 08 Feb 2017 00:00:00 +0530 Thu, 17 Sep 2026 13:50:51 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=471767 Commercially inseparable channel subscription and advertisement airtime distribution transactions should be aggregated for arm's-length benchmarking where they are mutually reinforcing, use the same assets, and operate under regulatory rights covering both revenue streams. Separate evaluation is unreliable when neither activity can practically be relinquished while retaining the other. Comparable entities must also have a similar functional and asset profile. Businesses involved in programme production, multi-channel broadcasting, radio operations, newspaper circulation, or ownership of significant intangibles are functionally dissimilar to a sports-channel and advertising-inventory distributor and should be excluded from the comparable set. Case-Laws Income Tax Wed, 08 Feb 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=471767