Where assessee was engaged in processing, bottling and sale of liquor in India under two segments Bottled in India Scotch (BIIS) and India Made Foreign Liquor (IMFL), in view of fact that manufacturing of ultimate product, market conditions, price and functions of both segments were completely different and distinct, assessee’s segregation approach for benchmarking these segments was justified. (AY.2005-06)
Dy. CIT v. Allied Domecq Spirits and Wine India Pvt. Ltd. (2018) 63 ITR 376/193 TTJ 920 (Delhi) ( Trib.)
S. 92C : Transfer pricing – Arms’ length price – Assessee company processed, bottled and sold liquor in India under two segments Bottled in India Scotch (BIIS) and India Made Foreign Liquor (IMFL) – activities of the assessee are two different segments – assessee’s segregation approach for benchmarking these segments justified.