Inconsistent Characterization by TPO Leads to Remand for Further Examination of Assessee's Distributor and Agent Roles.

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....TPA - TPO confused himself in characterization of the assessee's functions as captive, routine, full-fledged distributor at one place and routine distributor in another place. The Transfer Pricing Officer is also characterizing the assessee as an agent in one place and captive distributor and agent in another place - matter remanded back - AT....