https://www.taxtmi.com/highlights?id=55930 TP Adjustment - The manufacturing agreement in an unambiguous manner has restricted the assessee to manufacture for Sandoz and its affiliates. Since the import and export transactions are within the group concerns and manufacturing is carried out in accordance with the orders received from AEs, we have no hesitation in holding that there is live link of the import and export transactions. - The assessee has imported APIs from its AEs for manufacturing FDFs and has exported FDFs to its AEs under manufacturing arrangement. - CUP cannot be adopted to benchmark the international transaction of import of APIs. - AT en-us Thu, 17 Dec 2020 09:13:58 +0530 Thu, 17 Dec 2020 09:13:58 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=55930 TP Adjustment - The manufacturing agreement in an unambiguous manner has restricted the assessee to manufacture for Sandoz and its affiliates. Since the import and export transactions are within the group concerns and manufacturing is carried out in accordance with the orders received from AEs, we have no hesitation in holding that there is live link of the import and export transactions. - The assessee has imported APIs from its AEs for manufacturing FDFs and has exported FDFs to its AEs under manufacturing arrangement. - CUP cannot be adopted to benchmark the international transaction of import of APIs. - AT Highlights Income Tax Thu, 17 Dec 2020 09:13:58 +0530 https://www.taxtmi.com/highlights?id=55930