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2019 (5) TMI 1525 - HC - Income TaxTP adjustment - Comparable selection - functional similarity between the Assessee and Li and Fung - HELD THAT:- The lack of functional similarity between Li & Fung India and the Assessee on various parameters. The ITAT upheld the ‘net profit/total cost remuneration model’ adopted by the Assessee in determining the ALP of its international transactions. The Court notes that the ITAT has consistently followed its orders for AYs 2006-2007 and 2007-2008 which was affirmed by this Court. Accordingly the impugned order calls for no interference. No substantial question of law arises for determination by this Court.
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