2019 (4) TMI 348

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..... g - HELD THAT:- The assessee could not make out a strong prima facie case on the receipts of addition to the returned income. However, considering the fact that the appellant already paid ₹ 2 crores out of the original demand of ₹ 6,91,49,730/-, the balance demand will be stayed subject to payment of ₹ 1 crore on or before 31st March, 2019. This stay shall stand vacated, in case .....

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..... of ₹ 9,88,26,319/- and denial of benefit of deduction u/s. 80IB of the Act by holding that the activity of the appellant does not amount of manufacturing. It is submitted that the ALP adjustment was made by adopting the cup method as against the TNMM adopted by the assessee as regards to denial of benefit u/s. 80IB of the Act. It is submitted that the process of manufacturing liquid flavour .....

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