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2020 (12) TMI 1363 - AT - Income TaxTP Adjustment - Upward adjustment in respect of international transaction of freight receipts and expenses - benchmarking under CUP - HELD THAT:- As decided in assessee own case [2012 (4) TMI 260 - ITAT MUMBAI] Tribunal has accepted the benchmarking done by the assessee under CUP method and has also held that the profit sharing ratio of 50:50 is prevalent both in respect of agreement entered into between group companies with unrelated parties as well as the assessee. Respectfully following the same, we uphold the plea of the assessee, and delete the impugned arm’s length price adjustment - The assessee gets the relief accordingly.
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