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    <title>2008 (4) TMI 353 - ITAT DELHI-E</title>
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    <description>In stay proceedings, disputed tax recovery may be suspended where the assessee shows a strong prima facie case and the balance of convenience favours protection pending appeal. The Tribunal accepted arguable challenges to business connection in India, income attribution, enhancement of additional income, profit-rate computation, and interest liability, and noted limited precedent on a novel issue. It also considered that partial acceptance of the factual objections could materially reduce the demand and that immediate recovery would cause hardship given the group&#039;s losses. Conditional relief was therefore justified, with the outstanding demand kept in abeyance for a limited period subject to deposit and security, and the appeals directed to be heard out of turn.</description>
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      <link>https://www.taxtmi.com/caselaws?id=65294</link>
      <description>In stay proceedings, disputed tax recovery may be suspended where the assessee shows a strong prima facie case and the balance of convenience favours protection pending appeal. The Tribunal accepted arguable challenges to business connection in India, income attribution, enhancement of additional income, profit-rate computation, and interest liability, and noted limited precedent on a novel issue. It also considered that partial acceptance of the factual objections could materially reduce the demand and that immediate recovery would cause hardship given the group&#039;s losses. Conditional relief was therefore justified, with the outstanding demand kept in abeyance for a limited period subject to deposit and security, and the appeals directed to be heard out of turn.</description>
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