TMI Blog2015 (7) TMI 1070X X X X Extracts X X X X X X X X Extracts X X X X ..... 6-07 and 2007-08 is in favour of the assessee on this issue. Therefore, taking into consideration, the facts and circumstances, we deem it appropriate to stay the outstanding demand subject to the following conditions: (a) The outstanding demand shall remain stayed for a period of 180 days or till the disposal of the appeal, whichever event occurs first; (b) The assessee shall pay sum of ₹ 1,00,00,000/- (Rupees One Crore) on or before 30th August, 2015. (c) The assessee shall submit all necessary paper books before the date of hearing in the appeal. (d) The assessee shall not seek adjournment unless unavoidable circumstance warrants so. - Stay Petition No.76/Ahd/2015 IN ITA No.793/Ahd/2014 - - - Dated:- 20-7-2015 - SHR ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... TPO-I, Ahmedabad (as per para- 3) Rs.467,42,33,199 2. Disallowance u/s.40(a)(ia) (as per para-4) ₹ 78,81,661/- Rs.468,21,14,860/- Total Income Rs.105,23,58,654/- TOTAL INOCME (rounded off) Rs.105,23,58,650/- Assessed u/s.143(3) r.w.s. 144C r.w.s. 92CA(3)of the Income Tax Act. Calculate Tax charge interest u/s.234A, 234B, 234C and 234D as applicable. Give credit of pre-paid taxes after due verification. Issue demand notice challan accordingly. Issue notice u/s.274 r.w.s. 271(1)(c) of the Act. Sd/- Y.P.Verma) Jt. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... d/2011 for the Asstt.Years 2006-07 and 2007-08 reads as under: 11.6.5 Taking all the above facts and circumstances of the issue as discussed in the foregoing paragraphs, in consonance with the case laws quoted (supra) and also the United Nation s Practical Manual on transfer pricing, we direct the AO to adopt GMDAT as the tested party for analyzing the inter-company transactions of the assessee for both the AYs under consideration. To facilitate the TPO to analyze the inter-company transactions in the case of the assessee for selecting GMDAT as tested party as directed above, this issue is restored o the files of the TPO. It is ordered accordingly. 5. The learned counsel for the assessee further contended that the assessee has h ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... following conditions: (a) The outstanding demand shall remain stayed for a period of 180 days or till the disposal of the appeal, whichever event occurs first; (b) The assessee shall pay sum of ₹ 1,00,00,000/- (Rupees One Crore) on or before 30th August, 2015. (c) The assessee shall submit all necessary paper books before the date of hearing in the appeal. (d) The assessee shall not seek adjournment unless unavoidable circumstance warrants so. 8. The registry is directed to list this appeal out of turn hearing on 12th August, 2015 along with other appeals of the assessee, where, identical issue is being involved, as stated by the assessee. 9. In the result, the Stay Petition of the assessee is allowed in the manner ..... X X X X Extracts X X X X X X X X Extracts X X X X
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