TMI Blog2015 (1) TMI 150X X X X Extracts X X X X X X X X Extracts X X X X ..... nting to ₹ 13.26 crores, which is equivalent to 30% of the total demand raised for the assessment year. The case of the AR is that the various additions made by the AO/TPO are against the principles laid down by the Tribunal in other cases. Under these circumstances, we are of the view that the balance of convenience is in favour of granting partial stay to the assessee. Accordingly, we dire ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... crore relating to A.Y. 2009-10. 2. The learned counsel for the assessee submitted that the assessee filed its return of income for the year under consideration declaring a total income of ₹ 64.90 crores. However, the AO completed the assessment by making additions to the tune of ₹ 89 crores, which consisted of addition made towards TP adjustments to the tune of ₹ 51.54 crores ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... G Electronics India Private Limited 22 ITR(T) 1 (Delhi). The learned counsel further submitted that disallowances made u/s 80IC is also not in accordance with the decision rendered by various Benches of the Tribunal and also by the Hon ble Jurisdictional High Court. Accordingly, the learned AR submitted that there is a prima facie case for granting absolute stay of collection of outstanding demand ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the AR is that the various additions made by the AO/TPO are against the principles laid down by the Tribunal in other cases. Under these circumstances, we are of the view that the balance of convenience is in favour of granting partial stay to the assessee. Accordingly, we direct the assessee to pay a sum of ₹ 10 crores in two equal installments. The first instalment shall be paid on or bef ..... X X X X Extracts X X X X X X X X Extracts X X X X
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