Transfer Pricing Case Analysis on Inclusion / Exclusion of comparables

Beam Global Spirits & Wine (India) Pvt. Ltd. Vs. DCIT (ITAT Delhi) Brief of assessee’s facts: 1. Beam India (the assessee), a wholly owned subsidiary of Beam USA, was engaged in the production and sale of alcoholic beverages in India. 2. During AY 2008-09, the assessee entered following ITs with its AE along with outcome of TPO Order: International Transaction  Amount in INR  Outcome of TP Order  Purchase of compound Alcoholic Preparation 14,35,47,473 Accepted Provision of Marketing support services (‘MSS’) 1,28,11,244 Disputed Reimbursement of expenses 17,69,26,0...