CPM wasn’t most appropriate method for ALP if FAR analysis of products sold to AE & domestic market weren’t same

IT/ILT: Where assessee sold herbal pharmaceutical products manufactures by it in Indian market as well as to AEs located abroad, in view of fact that functions performed, assets employed and risks undertaken in both segments were not same, CPM could not be considered as most appropriate method for determining ALP in respect of international transactions entered into with AE

from www.taxmann.com Latest Case Laws https://www.taxmann.com/topstories/101010000000182440/cpm-wasn’t-most-appropriate-method-for-alp-if-far-analysis-of-products-sold-to-ae-domestic-market-weren’t-same.aspx