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TMI Blog2018 (3) TMI 1784X X X X Extracts X X X X X X X X Extracts X X X X ..... (P.) Ltd. v. CIT [ 2015 (3) TMI 580 - DELHI HIGH COURT] arguing that AMP expenditure is an international transaction - HELD THAT: - We are inclined to accept the arguments of the ld. AR to the extent that the appeal filed before us would have to be construed as first appeal and accordingly, the assessee is directed to pay a sum of ₹ 1.20 crores on or before 27-03-2018 and produce the eviden ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... rlier, subject to fulfillment of aforesaid conditions. - IT Appeal No. 2459 (KOL.) Of 2017 S.A. No. 37 (KOL.) Of 2018 [Assessment Year 2013-14] - - - Dated:- 23-3-2018 - A.T. Varkey, Judicial Member And M. Balaganesh, Accountant Member J.P. Khaitan, Adv. for the Appellant. Saurabh Kumar, Addl. CIT Sr. DR for the Respondent. ORDER M. Balaganesh, ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... among others. He further stated that the assessee had filed a letter dated 07-03-2018 before the ld. AO expressing its willingness to pay 20% of the total demand in consonance with the requirement of the recent CBDT Circular dated 29-02-2016 and also gave his consent for adjustment of refunds of the various years for appropriation towards tax arrears of assessment year 2013-14 till the disposal o ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ed on the decision of Hon'ble Delhi High Court in the case of Sony Ericcson Mobile Communication India (P.) Ltd. v. CIT [2015] 55 taxman.com 240/231 Taxman 113 arguing that AMP expenditure is an international transaction. 2. We have heard the rival submissions. In the facts and circumstances of the case, we are inclined to accept the arguments of the ld. AR to the extent that the appe ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... assessment year 2012-13 on 02-05-2018. In view of the aforesaid findings, we are inclined to keep the demand in abeyance for a period of six months from today or till the disposal off the appeal whichever is earlier, subject to fulfillment of aforesaid conditions. In case, if the assessee fails to make remittance of 1.20 crores on or before 27-03-2018, the conditional stay granted herein would st ..... X X X X Extracts X X X X X X X X Extracts X X X X
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