2026 (9) TMI 683

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....licant : Smt. Roja - Advocate For the Respondent : Sri. Sandeep Kumar H.S, Addl. CIT ORDER PER BALAKRISHNAN S, ACCOUNTANT MEMBER : This Stay Application (SA) is filed by the assessee seeking stay of outstanding demand of Rs. 4,37,93,270/- arising out of the Order passed by the learned AO, dated 08.10.2024. 2. The learned AR submitted that the Revenue has accepted the Transaction Net....

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....er the second proviso to section 254 of the Act and prayed that the assessee may be directed to pay the statutory deposit. 4. We have heard the rival contentions and perused the material available on record. It was the contention of the learned AR that assessee is consistently following TNMM whereas it was not disputed by the Revenue in the earlier years. The prayer of the assessee is that sinc....