TMI Blog2019 (2) TMI 992X X X X Extracts X X X X X X X X Extracts X X X X ..... e on the international transactions alone considered, the effect thereof would be ₹ 15,61,77,887/- only against the sum of ₹ 25,42,23,046/- considered by the AO. Though assessee may have a prima facie case, it has not been able to demonstrate any grave financial difficulties except for pleading that it is running in a loss. Considering the facts and circumstances of the case, we ar ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... of ₹ 2,09,73,525/- and interest of ₹ 1,15,35,425/-. 2. Ld. Counsel for the assessee submitted that tax demand arose mainly on account of downward adjustment of ₹ 25,42,23,046/- on the value of the international transactions of the assessee. As per the ld. AR brought forward business loss from earlier years was not allowed for set off. According to him, if the downward adjust ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e is that if downward adjustment was done on the international transactions alone considered, the effect thereof would be ₹ 15,61,77,887/- only against the sum of ₹ 25,42,23,046/- considered by the ld. AO. Though assessee may have a prima facie case, it has not been able to demonstrate any grave financial difficulties except for pleading that it is running in a loss. Considering the fa ..... X X X X Extracts X X X X X X X X Extracts X X X X
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