This is premium content. Please become a Premium member. If you are already a member, login here to access the full content.
Sharing of net revenues consistently in controlled & uncontrolled transactions held as a valid comparable uncontrolled price
Case Law Details
- Case Name
- ACIT Vs. Agility Logistics Pvt. Ltd. (ITAT Mumbai)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Related Assessment Year
- 2004- 05
- Courts
- All ITAT, ITAT Mumbai
Upgrade to Basic or Premium to download.
Already Upgraded? Log in.
ACIT Vs. Agility Logistics Pvt. Ltd. (ITAT Mumbai)- ITAT held that the sharing of net revenues (i.e., amounts billed to customers less third party costs) in a 5o:5o ratio between the origin and destination companies in a consistent manner in controlled as well as uncontrolled transactions, constitutes a comparable uncontrolled price (CUP). In coming to its conclusion, the Tribunal took into account the fact that the 5o:5o model is a common industry practice.
INCOME TAX APPELLATE TRIBUNAL. MUMBAI
ITA No. 2000/Mum/2010 Assessment year 2004- 05
Asst. Commissioner of Income Tax – 8(1) Vs. M/s Ag...
