| COURT: | ITAT Delhi |
| CORAM: | C. M. Garg (JM), Pramod Kumar (AM) |
| SECTION(S): | 10 B(1)(a), 92C(1)(a), Rule 10AB |
| GENRE: | Transfer Pricing |
| CATCH WORDS: | CUP method, Transfer Pricing |
| COUNSEL: | Rohit Tiwari |
| DATE: | November 17, 2014 (Date of pronouncement) |
| DATE: | November 19, 2014 (Date of publication) |
| AY: | 2006-07 |
| FILE: | Click here to view full post with file download link |
| CITATION: | |
| CUP method can be applied by a comparing a pricing formulae, rather than the pricing quantification in amount. Rule 10AB inserted w.e.f. 01.04.2012 is beneficial in nature and so retrospective w.e.f. 01.04.2002 | |
The assessee followed the 50:50 business model of sharing residual profits in equal ratio with the service provider at the other end of the transaction i.e. at the consignee’s end in the case of export transaction and at consigner’s end …
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