https://www.taxtmi.com/caselaws?id=243986 The transfer pricing adjustment on freight receipts and freight payments was rejected because the freight arrangement was found to reflect arm's length conditions. The record showed that the overseas entities on both sides performed similar functions, used comparable assets and assumed comparable risks, and the freight revenue and expense were shared equally after transportation costs in both countries. As the Revenue did not dislodge this comparable profile, the 50:50 profit split was accepted as commercially justified and there was no basis for the proposed addition. en-us Thu, 21 Sep 2006 00:00:00 +0530 Sat, 15 Feb 2014 10:58:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=243986 The transfer pricing adjustment on freight receipts and freight payments was rejected because the freight arrangement was found to reflect arm's length conditions. The record showed that the overseas entities on both sides performed similar functions, used comparable assets and assumed comparable risks, and the freight revenue and expense were shared equally after transportation costs in both countries. As the Revenue did not dislodge this comparable profile, the 50:50 profit split was accepted as commercially justified and there was no basis for the proposed addition. Case-Laws Income Tax Thu, 21 Sep 2006 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=243986