2018 (4) TMI 1709

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....he Revenue For The Respondent : Mr. S. Ganesh, Sr. Adv. with Mr. Upkar Agrawal and Mr. Prashant Meharchandani, Advocates ORDER Caveat No.999/2017 Since the counsel for the caveator has appeared the caveat stands disposed of. CM APPL. 42250/2017 (for condonation of delay) For the reasons mentioned in the application, the delay in refiling the appeal is hereby condoned. Applicat....

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.... meant that there was significant differences in the international transactions as opposed to those by the assessee in the case of Li and Fung India Pvt. Ltd. (supra). This Court is of the opinion that on this aspect question of law does not arise. The findings of the ITAT with respect to the functional similarity, indeed identity, between the assessee in the case of Li and Fung India Pvt. Ltd. (s....