https://www.taxtmi.com/caselaws?id=178637 Reciprocal logistics transactions can satisfy arm's length pricing where the functions performed, assets employed and risks assumed by the Indian and foreign entities are comparable, and the agreed commercial split of freight revenue and freight cost is consistently followed. On those facts, a 50:50 sharing of net freight results supported the view that the international transactions were priced at arm's length. Comparable prior acceptance of similar profit-split arrangements in logistics matters reinforced that conclusion, and the transfer pricing adjustment in respect of freight receipts and freight payments was not sustainable. en-us Wed, 12 Dec 2012 00:00:00 +0530 Mon, 14 May 2018 10:42:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=178637 Reciprocal logistics transactions can satisfy arm's length pricing where the functions performed, assets employed and risks assumed by the Indian and foreign entities are comparable, and the agreed commercial split of freight revenue and freight cost is consistently followed. On those facts, a 50:50 sharing of net freight results supported the view that the international transactions were priced at arm's length. Comparable prior acceptance of similar profit-split arrangements in logistics matters reinforced that conclusion, and the transfer pricing adjustment in respect of freight receipts and freight payments was not sustainable. Case-Laws Income Tax Wed, 12 Dec 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=178637