Manufacturing Agreement Limits Production to Specific Company; CUP Method Deemed Unsuitable for Benchmarking API Imports.

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....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....