TMI Blog2018 (6) TMI 34X X X X Extracts X X X X X X X X Extracts X X X X ..... 2018 - - X X X X Extracts X X X X X X X X Extracts X X X X ..... they had P.E. in India. It is stated that the Income Tax Appellate Tribunal in the case of Mitsui & Co. Ltd., Japan, for the AY 2005-2006, had held that they do not have a P.E. in India. Further, in the present case, high sea sales were made and, therefore, the finding that Mitsui & Co. Ltd., Japan had a P.E. in India is incorrect and contrary to law. In the case of the petitioner, the AO has inv ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... an amount of Rs. 15,00,00,000/- in the three AYs. Subject to the petitioner depositing Rs. 5,00,00,000/- within seven days, there would be stay of recovery of impugned demand by coercive steps till the next date of hearing. Counter-affidavit would be filed within four weeks. Rejoinder, if any, be filed within four weeks, after counter-affidavit is served. The pendency of the present writ petit ..... X X X X Extracts X X X X X X X X Extracts X X X X
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