2018 (6) TMI 34

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X

..... 0% of the disputed tax - Held that:- The order directing the petitioner to deposit 20% of the disputed tax is non-reasoned and non-speaking - thus petitioner has to deposit 15,00,00,000/- in the three AYs. Since the amount of ₹ 5,00,00,000/- is to be deposited within 7 days, there would be stay of recovery of impugned demand by coercive steps till the next date of hearing. - W.P.(C) 1883 .....

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X

..... s specifically examined in the assessments made under Section 143(3) of Mitsui and Co. Ltd., Japan and it has been held that Mitsui Co. Ltd., Japan had nil‟ taxable income for the AYs 2009-2010 and 2014-2015 from P.E. stream. In the AY 2013-2014, Mitsui Co. Ltd., Japan was taxed on the basis of net income and tax on income from P.E. has been paid. Mitsui Co. Ltd., Japan has filed appe .....

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X

..... n terms of the CBDT Circular No.3/15. Petitioner has preferred appeals for the AYs 2009-2010 and 2013-2014 in January, 2017, but appeals have not been decided by the Commissioner of Income Tax (Appeals) [CIT(A)], though several request for early disposal had been made. Learned counsel for the petitioner has submitted that the impugned order directing the petitioner to deposit 20% of the disp .....

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X