2019 (10) TMI 646

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....1,21,61,170/- for AY 2013-14. 2. The learned Counsel for the assessee and the learned Sr. DR. on various dates crystallized the demand and stated that the Tribunal vide order dated 13.03.2018 in SA No. 562 & 521/Mum/2017 has stayed the demand subject to conditions. The conditions are in Para 5 which read as under: - "5. We have heard both the counsels and perused the records. On the facts and circumstances of the case, as narrated hereinabove, we are of the opinion that the assessee has a prima facie case and a conditional stay can be granted. Accordingly, we grant the stay of demand on the following conditions: 1. The assessee shall pay of Rs. 15 crores on or before 31.3.2018. 2. The refund of Rs. 28 crores du....

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....d directed AO to adjust the refund of AY 2004-05 and AY 2005-06 against the demand for AY 2013-14 and directed to dispose all the pending rectification application for AY 2007-08, and if there was any refund arising out of the above, then the same should be adjusted against the demand of AY 2013-14. The said refund cannot be adjusted against the demand of the AY 2013-14 as the refunds are on PAN AABC10605H and demand is on the PAN AAACW1663L. Since the two PAN's are different same cannot be adjusted as no modalities are available in the system to facilitate the same. The DGIT System, Delhi has been requested to resolve the issue. However, the issue has not been resolved yet despite all efforts. The Hon'ble ITAT had directed to obta....