https://www.taxtmi.com/caselaws?id=253527 The CUP method was accepted where the controlled and uncontrolled transactions used the same 50:50 residual profit-sharing formula, because price can include a comparable formula for determining consideration. The Tribunal treated the formula-based pricing in freight forwarding as an industry norm followed in both associated enterprise and independent transactions, and held that the absence of an identical money figure was not decisive. On that basis, substitution of TNMM was found unwarranted, and the arm's length price adjustment was deleted. en-us Tue, 18 Nov 2014 00:00:00 +0530 Fri, 22 May 2015 13:22:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=253527 The CUP method was accepted where the controlled and uncontrolled transactions used the same 50:50 residual profit-sharing formula, because price can include a comparable formula for determining consideration. The Tribunal treated the formula-based pricing in freight forwarding as an industry norm followed in both associated enterprise and independent transactions, and held that the absence of an identical money figure was not decisive. On that basis, substitution of TNMM was found unwarranted, and the arm's length price adjustment was deleted. Case-Laws Income Tax Tue, 18 Nov 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=253527