Differentiating between whisky and non-whisky alcoholic beverages is undesirable for comparability u

IT/ILT : Product similarity is must for applying CUP method, not for TNMM. Where assessee sells non-whisky alcoholic beverages(Vodka, Gin, Brandy, Rum etc) to non-AEs and whisky to AEs, Net Profit Margin on sale by assessee of non-whisky alchololic beverages cannot be rejected as internal TNMM for calculating ALP on assessee's sale of whisky to AEs simply based on distinction between whisky & non-whisky as two different products