2015 (1) TMI 150

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....dra Kumar ORDER Per: B R Baskaran: The assessee has filed the stay application seeking the stay of collection of outstanding demand of Rs. 31.75 crore relating to A.Y. 2009-10. 2. The learned counsel for the assessee submitted that the assessee filed its return of income for the year under consideration declaring a total income of Rs. 64.90 crores. However, the AO completed the assessm....

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....submitted that the TP adjustment made by the TPO is against the principles laid down by the Special Bench in the case of LG Electronics India Private Limited 22 ITR(T) 1 (Delhi). The learned counsel further submitted that disallowances made u/s 80IC is also not in accordance with the decision rendered by various Benches of the Tribunal and also by the Hon'ble Jurisdictional High Court. Accordingly....

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....ng to Rs. 13.26 crores, which is equivalent to 30% of the total demand raised for the assessment year. The case of the AR is that the various additions made by the AO/TPO are against the principles laid down by the Tribunal in other cases. Under these circumstances, we are of the view that the balance of convenience is in favour of granting partial stay to the assessee. Accordingly, we direct the ....