TMI Blog2019 (5) TMI 1523X X X X Extracts X X X X X X X X Extracts X X X X ..... 5 days? - delay in disposal of appeal? - HELD THAT:- It is not disputed by revenue that the matter in issue is no longer res integra and stands concluded by the decision of this Court in M/S CARRIER AIR CONDITIONING AND REFRIGERATION LIMITED [ 2016 (5) TMI 396 - PUNJAB AND HARYANA HIGH COURT] as held wherever the appeal could not be decided by the Tribunal due to pressure of pendency of cases a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... or the assessment year 2009- 2010, claiming the following substantial questions of law:- 1. Whether the Hon'ble ITAT has acted in contravention of the Second Proviso of Section 254(2A) of the Income Tax Act, 1961, as the combined period of stay has been exceeded 365 days? 2. Whether the order of the ITAT be treated as voidab- initio in light of Third P ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ddition of ₹ 8,50,26,705/- on account of Transfer Pricing Adjustments and disallowance of ₹ 5,51,000/- on account of amount spent towards lease hold improvement. Against the said order, the assessee moved before the Dispute Resolution Panel-III, New Delhi who vide order dated 26.11.2013 issued the directions under Section 144C(5) of the Act. In pursuance thereto, the Assessing Officer ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... filed an application for extension of stay and the Tribunal vide order dated 27.11.2014 further extended stay of demand for six months, i.e. upto 5.6.2015 or till the disposal of the appeal, whichever was earlier. Further, the Tribunal vide orders dated 12.6.2015 and 5.2.2016 further extended the stay for another period of six months or till the disposal of the appeal. Another period of 30 days o ..... X X X X Extracts X X X X X X X X Extracts X X X X
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