Distribution Transaction Needs New Transfer Pricing Analysis; Not a Service Agreement u/s 92(3) Provisions.

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....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....