2016 (5) TMI 97

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....37 crores. 2. Explaining the background facts of the case, it was submitted by the ld. Authorized Representative (AR), the assessee's counsel, that the total income under dispute is at Rs. 981.30 crores, of which the principal sums, aggregating to Rs. 978.40 crores, is comprised of the following sums: Amt (in Rs. crores) a) Disallowance of claim u/s. 80-IA 140.86 b) Disallowance of long term capital loss 329.06 c) Transfer pricing adjustments 508.48   978.40     As regards the issues listed at (a) and (c) above, the same subsist from A.Y. 2007-08 onwards. For the intervening years, i.e., A.Ys. 2007-08 and 2008-09, stay stands already granted by the tribunal, and for which he wou....

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....hibiting the ratio of the demand paid from A.Ys. 2007-08 to 2010-11 (the last year being also subject to a stay application by the assessee, which stands also listed for hearing today instant, though before a different combination). 47% of the total demand for the current year, he would continue, stands paid, as against 46% and 34% for the A.Ys. 2007-08 and 2008-09 respectively. The ld. Departmental Representative (DR) would concede that the assessee has a good prima facie case, though, yet, considering the volume of the outstanding demand, the same amount ought to be paid even as directed to be paid (at Rs. 50 crores) by the tribunal vide its stay order dated 21.12.2011 supra. The ld. counsel for the assessee would, in rejoinder, tak....