2026 (10) TMI 331

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....Appellant : Mr.P.M.Kathir - Advocate For the Respondent : Mr.Banoth Akhil Ram Naik-JCIT ORDER PER INTURI RAMA RAO, ACCOUNTANT MEMBER : The present Stay Petition is filed by the assessee seeking stay of outstanding demand of Rs. 51,98,220/- for the assessment year 2014-15. 2. The learned Authorised Representative submits that the demand in question has arises on account of addition m....

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....rd rival submissions and perused the material available on record. As noted by us(supra), the demand in question had arisen on account of addition made u/s. 40(a)(i) of the Act for non-deduction of tax at source on payments made to foreign advocates. Admittedly, the appellant made an application seeking reference to Special Bench in view of the conflicting decisions of Coordinate Benches of Tribun....