2022 (9) TMI 1660

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..../Shri Deepak Chopra & Rohan Khare, Advs. For the Respondent : Shri Mrinal Kumar, Sr. DR. ORDER PER SAKTIJIT DEY, JUDICIAL MEMBER: Captioned applications have been filed by the assessee seeking stay on recovery of following outstanding demand: i) Assessment Year 2017-18 : Rs. 72,30,44,038 ii) Assessment Year 2018-19 : Rs. 15,35,41,032 2. The learned counse....

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....ck to the Assessing Officer in the preceding assessment years and in so far as addition on account of royalty payment, the assessee, suo mottu, has made adjustment while computing taxable income, which has not been taken note by the Assessing Officer/Transfer Pricing Officer (TPO). He submitted, assessee's rectification application is still pending before the Assessing Officer/TPO. He submitted, i....

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....e considered rival submissions and perused the material available on record. 5. The merits of the additions giving rise to the present demand can be considered only at the time of hearing of the appeals and not at this stage. However, after considering the facts and material placed before us, prima facie, we are of the view that some of the additions made are repetitive in nature and have been ....

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....l pay an amount of Rs. 4,36,11,069 within four weeks from the date of this order. The balance amount of Rs. 5,63,88,931 shall be paid by assessee after disposal of its rectification application, stated to be pending before the Assessing Officer/TPO, either by way of adjustment of refund, in case, it arises or assessee shall pay it within two weeks from the date of disposal of rectificati....