2017 (5) TMI 489

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..... amount lower than 15% is warranted that is in a case where addition on the same issue has been deleted by appellate authorities in earlier years, the AO should refer the matter to the administrative Pr.CIT/CIT, who shall then decide the quantum/proportion of the demand to be paid. Instead of remanding the matter to the AO for the above exercise, the Court is of the view that the interests of ju .....

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..... xed at less than 15% in light of the Office Memorandum (OM) dated 29th February 2016. 3. The case of the Petitioner is that the AO erred in not accepting the Petitioner s adoption of the revenue recognition method for splitting the tuition fees collected by it from the students coming to its coaching institute as 60% in the first year and 40% in the second. It is submitted that although this ch .....

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..... the quantum/proportion of the demand to be paid. 5. Instead of remanding the matter to the AO for the above exercise, the Court is of the view that the interests of justice will be met by requiring the Petitioner to deposit around 10% of the demand of ₹ 17,57,53,977 as a lump sum amount. It is accordingly directed subject to the Petitioner depositing with the Income Tax Department a sum o .....

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