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a) That the Petitioner Company and three of its Distribution Partners https://www.mhc.tn.gov.in/judis/ (“DPs”) namely Apotex Corp, Par Pharmaceuticals, Northstar Healthcare Ltd. are to be treated as “Deemed Associated Enterprises” ['AE'] falling u/s 92A (2) (i).
b) The Profit Split Method (PSM) is Most Appropriate Method (MAM) and the Comparable Uncontrolled Price Method (CUP) adopted by the petitioner is not is not he MAM.