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2014 (3) TMI 15 - AT - Income TaxStay application - Transfer pricing adjustment u/s 92 of the Act – Assignment of call option on shares - Call centre business – Held that:- As made abundantly clear during the course of the hearing, it is not inclined to dwell on the merits of the case at any length, and the objective in the instant hearing was to have a snap shot of the case - This is purview at the stage of the proceedings is only to balance the conflicting interests of the opposite sides - even as explained there expressing a view either way may cause prejudice to either or even both the parties – besides also raise jurisdictional issues inasmuch as here the decision in regarding the stay application – thus, prima facie view, the assessee appears to have a good case - Though no case of financial hardship stands made out, the tax demand raised is itself at 22600% of the returned income of ₹ 10.65 crores, assessee directed to deposit ₹ 200 crores in two installments - stay granted partly.
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