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2018 (10) TMI 1266 - AT - Income TaxStay of demand - additions made to the income of the Appellant by the AO stem from the primary finding of the AO that the Appellant has fixed place and agency Permanent Establishment in India - Appellant is a company incorporated in and is a tax resident of United States of America - penalty levied at 100% of the alleged tax sought to be evaded - Held that:- We find that in the case of CIT vs. Liquid Investment Limited [2010 (10) TMI 1021 - DELHI HIGH COURT], has held that when substantial question of law is admitted by the Hon'ble High Court, the issue becomes debatable and, therefore, no penalty u/s. 271(1)(c) is leviable. Here also substantial question of law has been admitted before the Hon’ble Delhi High Court, as stated by the Ld. Counsel for the assessee, therefore, we grant the stay on the outstanding demand in dispute for the period of 180 days or till the disposal of the Main Appeal
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