Manufacturing & distribution activity being different it is fair to segregate both contracts: ITAT Mumbai

Fulford (India) Limited Vs DCIT (ITAT Mumbai) ITAT Mumbai held that as under distribution segment assessee is purchasing Finished Drug Formulation from its AE for sale in India and under manufacturing segment assessee is transacting with non-AEs, it is fair and reasonable to segregated contract of manufacturing activity and distribution activity. Accordingly, matter remanded. Facts- The assessee/appellant is engaged in the business of manufacturing and distribution of Pharmaceutical Products in India. The assessee is a subsidiary of Schering-Plough Corporation, USA. During the period relevant ...