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2011 (12) TMI 358 - AT - Income TaxApplication for stay of recovery - Revised return - ld. counsel for the assessee brought to our notice that the two major additions which has given rise to the outstanding demand are the disallowance of claim u/s. 80IA of the Income Tax Act, 1961 (the Act) of ₹ 179,70,52,324/- and the addition made by way of transfer pricing adjustment in respect of an international transaction of ₹ 447,76,89,010 - It was further submitted that in various tax disputes the assessee has already paid a sum of ₹ 1700 crores to the Income Tax Department, where matters are pending for adjudication before various appellate authorities - Held that: on the two major issues highlighted by the ld. counsel for the assessee before us there is a prima facie case made out by the assessee - The OECD guidelines also seem to support the plea of the assessee. It was submitted by the ld. counsel for the assessee that a sum of ₹ 35 crores towards outstanding demand has already been paid by the assessee - the appeal of the assessee is directed to be fixed for out of turn hearing on 14/2/2012
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