https://www.taxtmi.com/caselaws?id=314559 ITAT Mumbai granted conditional stay on collection of disputed tax demand of approximately Rs. 1,130 crores relating to ALP adjustment on assignment of call/put options. Despite assessee's arguments against 20% pre-deposit requirement and existing corporate guarantee for AY 2008-09, tribunal found arguable case but rejected blanket stay. Stay granted on conditions: (i) payment of Rs. 230 crores (20% of disputed demand) within 30 days, (ii) corporate guarantee of Rs. 900 crores from associate company with unencumbered Indian assets, and (iii) full cooperation in expeditious appeal disposal. Stay valid for six months or until further orders. en-us Mon, 19 Jul 2021 00:00:00 +0530 Thu, 20 Jun 2024 06:55:11 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=314559 ITAT Mumbai granted conditional stay on collection of disputed tax demand of approximately Rs. 1,130 crores relating to ALP adjustment on assignment of call/put options. Despite assessee's arguments against 20% pre-deposit requirement and existing corporate guarantee for AY 2008-09, tribunal found arguable case but rejected blanket stay. Stay granted on conditions: (i) payment of Rs. 230 crores (20% of disputed demand) within 30 days, (ii) corporate guarantee of Rs. 900 crores from associate company with unencumbered Indian assets, and (iii) full cooperation in expeditious appeal disposal. Stay valid for six months or until further orders. Case-Laws Income Tax Mon, 19 Jul 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=314559