https://www.taxtmi.com/caselaws?id=256114 In transfer pricing for logistics and freight forwarding, a comparable uncontrolled price may be reflected through an agreed pricing formula or residual profit-sharing mechanism, rather than only a fixed monetary price. The Tribunal treated a new ground challenging the 50:50 revenue split model as admissible in a later round because it went to the core legal characterisation of the adjustment. It also noted that transfer pricing rules are anti-abuse provisions and should be applied pragmatically, with newer rules permitting any method based on comparable uncontrolled transactions. The benchmarking issue was sent back for fresh examination on the factual and comparable data. en-us Tue, 18 Nov 2014 00:00:00 +0530 Wed, 04 Feb 2015 06:19:50 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=256114 In transfer pricing for logistics and freight forwarding, a comparable uncontrolled price may be reflected through an agreed pricing formula or residual profit-sharing mechanism, rather than only a fixed monetary price. The Tribunal treated a new ground challenging the 50:50 revenue split model as admissible in a later round because it went to the core legal characterisation of the adjustment. It also noted that transfer pricing rules are anti-abuse provisions and should be applied pragmatically, with newer rules permitting any method based on comparable uncontrolled transactions. The benchmarking issue was sent back for fresh examination on the factual and comparable data. Case-Laws Income Tax Tue, 18 Nov 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=256114