https://www.taxtmi.com/caselaws?id=127836 Conditional protection against tax recovery may be granted pending appeal where the assessee shows an arguable case and the balance of convenience supports interim relief. Here, the disputed demand concerned attribution of profits from hardware and software supply, research and development income, vendor financing income, and interest under section 234B. The Tribunal noted that the Special Bench view on attribution at 20 per cent for supply revenues had not been stayed, the vendor financing addition had earlier been upheld, the R&D component had been excluded in revision, and the interest issue remained debatable. Recovery was stayed conditionally on part payment, security for the balance, and the stay operating until disposal of the appeals or expiry of 180 days. en-us Tue, 23 Mar 2010 00:00:00 +0530 Sat, 02 Jan 2016 11:16:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=127836 Conditional protection against tax recovery may be granted pending appeal where the assessee shows an arguable case and the balance of convenience supports interim relief. Here, the disputed demand concerned attribution of profits from hardware and software supply, research and development income, vendor financing income, and interest under section 234B. The Tribunal noted that the Special Bench view on attribution at 20 per cent for supply revenues had not been stayed, the vendor financing addition had earlier been upheld, the R&D component had been excluded in revision, and the interest issue remained debatable. Recovery was stayed conditionally on part payment, security for the balance, and the stay operating until disposal of the appeals or expiry of 180 days. Case-Laws Income Tax Tue, 23 Mar 2010 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=127836