https://www.taxtmi.com/caselaws?id=253327 Transfer pricing analysis may benchmark international transactions using a pricing formula or mechanism, not only a fixed monetary price, where that mechanism reflects an industry norm and supports an arm's length result. The Tribunal noted that a 50:50 residual profit-sharing model had been accepted in comparable uncontrolled transactions for CUP analysis, and that insisting on exact amount-wise comparability would undermine the anti-abuse purpose of the transfer pricing rules. It also observed that the additional method introduced by rule 10BA is beneficial procedural legislation and can operate retrospectively. On that basis, the assessee's model was treated as arm's length and the adjustment was deleted. en-us Tue, 18 Nov 2014 00:00:00 +0530 Mon, 05 Jun 2023 14:27:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=253327 Transfer pricing analysis may benchmark international transactions using a pricing formula or mechanism, not only a fixed monetary price, where that mechanism reflects an industry norm and supports an arm's length result. The Tribunal noted that a 50:50 residual profit-sharing model had been accepted in comparable uncontrolled transactions for CUP analysis, and that insisting on exact amount-wise comparability would undermine the anti-abuse purpose of the transfer pricing rules. It also observed that the additional method introduced by rule 10BA is beneficial procedural legislation and can operate retrospectively. On that basis, the assessee's model was treated as arm's length and the adjustment was deleted. Case-Laws Income Tax Tue, 18 Nov 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=253327