https://www.taxtmi.com/caselaws?id=253527 The Tribunal allowed the appeal, ruling in favor of the assessee. The rejection of the Comparable Uncontrolled Price (CUP) method by the authorities was overturned, and the Transactional Net Margin Method (TNMM) was not accepted as a replacement. The 50:50 profit-sharing model in the freight forwarding industry was deemed justifiable, aligning with industry standards. The Tribunal emphasized a pragmatic approach to determining the arm's length price, considering industry practices and anti-abuse measures. The arm's length price adjustment of Rs. 2,09,00,179 was deleted, and all other appeal grounds were deemed academic. 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 Tribunal allowed the appeal, ruling in favor of the assessee. The rejection of the Comparable Uncontrolled Price (CUP) method by the authorities was overturned, and the Transactional Net Margin Method (TNMM) was not accepted as a replacement. The 50:50 profit-sharing model in the freight forwarding industry was deemed justifiable, aligning with industry standards. The Tribunal emphasized a pragmatic approach to determining the arm's length price, considering industry practices and anti-abuse measures. The arm's length price adjustment of Rs. 2,09,00,179 was deleted, and all other appeal grounds were deemed academic. Case-Laws Income Tax Tue, 18 Nov 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=253527