Document Fragment View
Fragment Information
Showing contexts for: ranbaxy in Ranbaxy Laboratories Ltd. vs Addl. Commissioner Of Income Tax, Range ... on 22 January, 2008Matching Fragments
Sl. No. Name & address of associated enterprise Description of the transaction Quantity Total amount received/receivable As per books Of amount As computed by the assessee Having regard to Arm's length Price
1.
Ranbaxy Unichem Co. Ltd., Bangkok, Thailand Sale of API Refer Note 2 below 442,587 447,567
2. Ranbaxy (Malaysia) Sdn.Bhd., Malaysia Sale of API/raw materials and spare parts Refer Note 2 below 55,853,924 55,853,924
S. No. Overseas Associated Enterprises Net Margin On Sales Ranbaxy Unichem Co.Ltd. - Thailand 3.95% Ranbaxy (Malaysia) Sdn Bhd - Malaysia
-18.00% Ranbaxy Nigeria Ltd. - Nigeria 6.85% Ranbaxy Farmaceutica Ltd. - Brazil 0.49% Ranbaxy- PRP (Peru) S.A.C. - Peru
-41.27% Ranbaxy (Guangzhou China) Ltd. - China 5.67% Ranbaxy Ireland Ltd. - Republic of Ireland 9.59% Basic GmbH Leverkusen - Germany 1.42% Ranbaxy(S.A.)(Proprietary)Ltd.-South Africa 6.52% Ranbaxy Egypt (LLC) - Egypt 10.70% Ranbaxy Vietnam Company Ltd. - Vietnam
-8.77% Ranbaxy Pharmaceuticals BV - Netherlands 0.58% Ranbaxy Pharmaceuticals Inc. - United States of America 10.24% Ohm Laboratories Inc - Untied States of America 11.22% Ranbaxy (U.K.) Ltd. - United Kingdom 2.42% Ranbaxy Europe Ltd. - U.K. 1.94% Ranbaxy Hong Kong Limited 1.51%.
As has been stated in para 4.2, the role played by RLL while dealing with its AEs is that of an "entrepreneur" and RLL bears the ultimate risk of the success or failure of the product sold by its AEs in the overseas markets. In fact, it is in this direction that RLL has to render the support functions and services to its AEs in addition to the sale of the pharmaceutical products. Such support or service is not rendered by RLL to third parties in transactions entered into with them. Moreover, the third parties do not inherit the right to convert the API procured from RLL to a "Ranbaxy" brand dosage form, while the overseas AEs of RLL convert the API into "Ranbaxy" brand dosage form.