Conditional stay of transfer-pricing demand requires deposit and cooperation pending early disposal of the appeal process.

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....Recovery of the balance disputed tax demand arising from transfer-pricing adjustments was stayed pending appeal, conditional on deposit of 20% of the outstanding demand after excluding proportionate demand relating to services claimed to have been rendered to an associated enterprise. The stay operates for 180 days or until appeal disposal, whichever occurs first, subject to meeting the deposit condition and cooperating in early appeal disposal. No merits determination was made on the transfer-pricing additions.....