2011 (3) TMI 223

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..... ant Member. - This stay application is filed by the assessee-company seeking stay against the outstanding demand of Rs. 2,88,87,746 for the assessment year 2006-07. 2. The assessee-company is engaged in providing contract software research and development services to its associated enterprise (AE). The brief facts of the case are that the Assessing Officer in his draft assessment order under sec .....

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..... t Rs. 2,88,87,746 consisting of tax and interest thereon. 4. The learned assessee representative for the assessee submitted that the order passed by the Assessing Officer in pursuance of the directions of the DRP is not in conformity with the spirit of law and judicial precedents. It was submitted that the assessment is unreasonably high-pitched and on merits, he submitted that the recomputation .....

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..... The additions made by the Assessing Officer are on account of recomputation of deduction under section 10A and with respect to transfer pricing adjustments, which is debatable in nature. After considering the facts and circumstances of the case, we grant stay in the matter with a direction to the assessee-company to make a payment of Rs. 50,00,000 (Rupees Fifty Lakhs only) in two monthly instalme .....

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