2018 (10) TMI 1677

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..... S. Ganesh, Sr. Advocate with Mr. Prashant Meharchandani, Adv. ORDER CM APPL. 16423/2018 (rectification of order) We have heard learned counsel for the parties. The application seeks correction of the order dated 10.04.2018 whereby question of law with respect to Transfer Pricing Adjustment, was dealt with. The court declined to frame the question of law. In the course of the order, this cou .....

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..... ndia Pvt. Ltd. - is not appropriate because the assessee renders support services to its members whereas Li Fung is providing services on principal to principal basis to its AEs as well as third party. The second distinction is highlighted with respect to the revenue model - while in Li and Fung the cost plus was on a certain percentage mark up, the rule here is entirely different. This court ha .....

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