Where the assessee is trying to club the transaction of Production of finished goods with Trading of spare parts, it is held that the Manufacturing segment cannot be aggregated with the Distribution segment and both need to be benchmarked independent of each other. Addition was confirmed. (AY. 2012-13)
Man Diesel & Turbo India Pvt. Ltd. v. ACIT (2020) 191 DTR 380 / 204 TTJ 999 (Pune)(Trib.)
S. 92C : Transfer pricing-Arm’s length price-Manufacturing segment not to be clubbed with distribution segment-Addition was confirmed.