ITAT Evaluates Stay Petition, Focuses on Royalty Issue After Setting Aside TP Adjustment and Attribution in Other Years.

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....Stay petition - demand raised by AO on three issue, TP adjustment,attribution and royalty - TP adjustment and attribution issue relating to the other assessment years being set aside by the Tribunal - hence the issue contested before the Tribunal by the revenue was only relating to the royalty issue and amount of stay determined based on royalty - ITAT rightly quantified amount for stay....