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2019 (3) TMI 211 - AT - Income TaxStay petition - Factor for granting stay - prima facie case - balance of convenience - disallowance of Expenditure for non deduction of TDS u/s 195 - payments were in the nature of “Royalty” and chargeable to tax in the hands of GIL in India - profits attributable to Google Ireland - income accrue in India - international Transactions - HELD THAT:- After considering the existence of prima facie case, balance of convenience, relative hardship, the earlier orders of the Tribunal and the orders of the Hon’ble High Court of Karnataka in the case of the Assessee on identical issue of grant of stay, the offer to pay by the Assessee and the demand of the department, we are of the view that it would be just and appropriate to grant an order of stay of recovery of outstanding demand for a period of 6 months from the date of this order, or till disposal of the appeals of the Assessee, whichever is earlier.
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