Whether TPO was correct in applying CUP instead of TNMM

Last updated: 13 October 2010

Court :
ITAT Mumbai

Brief :
The only issue in assessee's appeal is against the adjustment of Rs.21,95,034/- made by the Transfer Pricing Officer in respect of transaction with associated enterprises which has been partly confirmed by Ld. CIT(A). The company is engaged in the manufacturing and trading of animal health and veterinary products. The product range of Intervet India includes pharmaceutical products, feed additives, poultry vaccines, canine vaccines, Foot and Mouth Disease Vaccine, viral and Bacteria. M/s. Intervet India is the wholly owned subsidiary of Intervet holdings B.V. Netherlands. Company belongs to Intervet Group Head quartered in Netherlands. The entities under the Intervet Group are part of the Akzo Nobal Group a multinational group with headquarters in Netherlands. During the year, it had two production centres, located at Hyderabad and Pune. Hyderabad Unit produces poultry vaccine and pig vaccine and the Pune unit manufacture pharmaceuticals and other veterinary vaccines.

Citation :
2010-TIOL-240-ITAT-MUM