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TMI Blog2018 (4) TMI 1709X X X X Extracts X X X X X X X X Extracts X X X X ..... nce etc. 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. [ 2014 (1) TMI 501 - DELHI HIGH COURT] - HELD THAT:- 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 th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... account of Rent Expenses ignoring the fact that the same is capital expenditure in connection with business activities? - ITA 1033/2017 And CM APPL. 13822/2018 - - - Dated:- 10-4-2018 - MR S. RAVINDRA BHAT AND MR A. K. CHAWLA, JJ. For The Appellant : Mr. Ruchir Bhatia, Sr. Standing Counsel for the Revenue For The Respondent : Mr. S. Ganesh, Sr. Adv. wi ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... is regard, it was urged that the ITAT erred in following the ruling of this Court in the case of Li and Fung India Pvt. Ltd. vs. Commissioner of Income Tax , 361 ITR 85. It is submitted that the assessee company renders support services and the findings of the Transfer Pricing Officer ( TPO ) and Dispute Resolution Panel (DRP) with respect to its controlling critical functions in regard to the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... expenditure. Having regard to these facts, the Court is of the opinion that the application of the rule in Li and Fung India Pvt. Ltd. (supra) was appropriate and therefore this question of law does not arise. The second question of law urged in this appeal is with respect to the payment of ₹ 1,75,16,800/- which the Revenue claimed was capital expenditure. ..... X X X X Extracts X X X X X X X X Extracts X X X X
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