Court Reviews Transfer Pricing Methodology in Freight Forwarding Dispute: TNMM vs. CUP Method for Arm's Length Assessment.

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....Transfer pricing adjustment - AO/TPO/DRP not appreciating the 50:50 revenue split business model between the appellant and its associated enterprises in relation to international transactions, i.e. provision and receipt of freight forwarding services, and, further making an upward adjustment alleging that such transactions were not at arm’s length - TNMM v/s CUP method? - AT....