TP- Making distinction between alcoholic beverages like ‘whisky’ and ‘other than whisky’, is undesirable for comparability under TNMM

The arm’s length result under the TNMM is determined to the net profit margin of a comparable transactions under a comparable circumstances and the profitability derived from uncontrolled party engaged in similar business activity under similar circumstances are to be analyzed. The product similarity has to be seen while applying CUP method and not under the TNMM because under the CUP, the focus is on the price of the product sold or transferred.

In assessee’s case, both the transactions with the A.E. and unrelated

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