Kellogg India Pvt. Ltd. is engaged in the manufacture and distribution of breakfast cereals and prepared meals and operates as a licensed manufacturer of the Kellogg brand. During the year under consideration, Kellogg India launched Pringles products in the Indian market. Kellogg India purchases Pringles products from Singapore-based AE Pringles International Operations SARL. Singapore AE does not manufacture Pringles, instead they are manufactured by a third-party contract manufacturer. The goods are then delivered at the cost price plus the 5% surcharge on the third-party manufacturer’s cost. These Pringles are later imported by Kellogg India from its AE and distributed in
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