https://www.taxtmi.com/highlights?id=38882 TPA - there is no difference between the form and substance of the transaction of distribution to recharacterise the transaction as a service agreement - the transaction is a distribution transaction and not service agreement - the TP analysis has to be done afresh and then it has to be seen if the provisions of section 92(3) would apply - AT en-us Fri, 13 Apr 2018 08:17:58 +0530 Fri, 13 Apr 2018 08:17:58 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=38882 TPA - there is no difference between the form and substance of the transaction of distribution to recharacterise the transaction as a service agreement - the transaction is a distribution transaction and not service agreement - the TP analysis has to be done afresh and then it has to be seen if the provisions of section 92(3) would apply - AT Highlights Income Tax Fri, 13 Apr 2018 08:17:58 +0530 https://www.taxtmi.com/highlights?id=38882