https://www.taxtmi.com/caselaws?id=449713 The ITAT Mumbai rejected the assessee's plea to be re-characterized as a Value Added Distributor instead of Licensed Manufacturer for API imports from associated enterprises. The Tribunal upheld CUP as the most appropriate method for benchmarking API transactions, following precedent from Assessment Year 2003-04 involving similar transactions. While rejecting objections to TIPS database usage for comparable selection, the Tribunal allowed reasonable quality adjustments. The case was partially remanded to AO/TPO for fresh examination of the distribution segment after proper segregation from contract manufacturing activities, as the TPO had not examined transactions post-segregation. en-us Tue, 06 Feb 2024 00:00:00 +0530 Sat, 17 Feb 2024 10:08:13 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=449713 The ITAT Mumbai rejected the assessee's plea to be re-characterized as a Value Added Distributor instead of Licensed Manufacturer for API imports from associated enterprises. The Tribunal upheld CUP as the most appropriate method for benchmarking API transactions, following precedent from Assessment Year 2003-04 involving similar transactions. While rejecting objections to TIPS database usage for comparable selection, the Tribunal allowed reasonable quality adjustments. The case was partially remanded to AO/TPO for fresh examination of the distribution segment after proper segregation from contract manufacturing activities, as the TPO had not examined transactions post-segregation. Case-Laws Income Tax Tue, 06 Feb 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=449713