https://www.taxtmi.com/caselaws?id=215506 Where comparable uncontrolled transactions and substantially similar contractual terms established reliable comparability, the CUP method could not be rejected merely because the parties operated in different geographic locations. The Tribunal accepted that the assessee had consistently used CUP for freight receipts and freight expenses, supported by comparable agency arrangements showing a 50:50 gross profit split. It found the year under appeal materially identical to earlier years in business model, risk profile and contracts, and held that geographical differences did not materially affect comparability in the logistics sector. The transfer pricing adjustment based on rejection of CUP was therefore deleted. en-us Fri, 13 Apr 2012 00:00:00 +0530 Sat, 09 Apr 2016 13:44:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=215506 Where comparable uncontrolled transactions and substantially similar contractual terms established reliable comparability, the CUP method could not be rejected merely because the parties operated in different geographic locations. The Tribunal accepted that the assessee had consistently used CUP for freight receipts and freight expenses, supported by comparable agency arrangements showing a 50:50 gross profit split. It found the year under appeal materially identical to earlier years in business model, risk profile and contracts, and held that geographical differences did not materially affect comparability in the logistics sector. The transfer pricing adjustment based on rejection of CUP was therefore deleted. Case-Laws Income Tax Fri, 13 Apr 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=215506