IT/ILT : Assessee company involved in manufacturing of soft drink/juice based concentrates and had been supplying concentrates for aerated and non-aerated soft drinks to its deemed AEs in Bangaldesh, Nepal, Bhutan and Srilanka, in addition to its local sales in India. It had obtained a license from its US parent AE for technology to manufacture the concentrate and to use and exploit brands owned by said AE in regions designated to asssessee company. However, no transfer of any unique intangibles
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