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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 ..... lant. Saurabh Kumar, Addl. CIT Sr. DR for the Respondent. ORDER M. Balaganesh, By virtue of this stay application the assessee seeks to keep the demand of Rs. 6,16,12,850/- in abeyance raised for the assessment year 2013-14 pursuant to transfer pricing adjustment made in respect of advertising, marketing and promotion (AMP in short) expenses in the sum of Rs. 15,60,70,679/-. The ld. AR argue ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... towards tax arrears of assessment year 2013-14 till the disposal of the appeal by the Tribunal. He also argued that though the said circular would apply only for matters pending before the Ld. CIT(A), i.e. the first appeal, the impugned appeal before this Tribunal also would have to be construed as first appeal, inasmuch as, on the final assessment order passed by the ld. AO u/s 143(3) read with ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ept 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 Rs. 1.20 crores on or before 27-03-2018 and produce the evidence of payment of the same to the Registry on the very same date. The assessee is also directed not to alienate his immovable properties, if any, without the pr ..... X X X X Extracts X X X X X X X X Extracts X X X X
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