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TMI Blog2014 (3) TMI 1021X X X X Extracts X X X X X X X X Extracts X X X X ..... ibunal have been decided in favour of the assessee,that adjustment of 7.5 Crores has to be carried out by the AO.Considering the facts and circumstances of the case, we are of the opinion that it is a fit case for staying the demand.Accordingly,demand is stayed till the disposal of appeal by the Tribunal or for a period of six months whichever is earlier. AO is directed not to make any adjustment ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Price (ALP) of the International Transactions undertaken by the assessee,that theTPO passed an order on 29.01.2013 and made adjustment of ₹ 190.37 Crores, that assessee filed objections against the Draft Assessment Order to the Dispute Resolu -tion Penal (DRP) on 9th April 2013, that AO passed order u/s. 143(3) r.w. section 144C(13) of the Act determining the total income of the assessee at ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... of the issues in appeal were covered in favour of the assessee by the orders for the earlier years,that AO should be directed to not to make any further adjustment.Departmental Representative (DR) submitted that issue of staying the demand should be decided on merits. 3.We have heard the rival submissions and perused the material before us.We find that the demand is mainly due to the Transfer Pr ..... X X X X Extracts X X X X X X X X Extracts X X X X
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