The Mumbai ITAT rejected the assessee's own recharacterization as value added distributor and upheld the CUP method to benchmark import of Active Pharmaceutical Ingredients. The Bench comprising Vikas Awasthy and Gagan Goyal observed that “segregation of Contract Manufacturing activity and Distribution is fair and reasonable. The TPO rejected assessee's TNMM and adopted CUP method as MAM, collecting data from Customs …
