2019 (2) TMI 1979

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..... of 180 days from the date of this order, whichever is earlier subject to payment of 15% of ₹ 6,38,99,650/- by 15.03.2019. This stay is subject to the condition that the assessee shall file an undertaking before the AO to the effect that it shall not alienate any of its immovable properties till the disposal of the present appeal. With these observations and subject to the above terms and co .....

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..... ekeeping services to ATMs of various banks and financial institutions. The Ld. counsel for the assessee submits that in the assessment proceedings, the Assessing Officer (AO), following the order of the Transfer Pricing Officer (TPO) made an adjustment by rejecting the comparables selected by the applicant and adopting the operating profit margin at 16.89% on the transactions with Associate Enterp .....

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..... was made. This rectification petition is yet to be disposed off by the Ld. CIT(A). The Ld. counsel submits that the petitioner has a prima facie good case and also it is having massive financial difficulty. It is stated by him that the overall balance of convenience is in favour of the petitioner. Thus it is stated that stay of demand be granted till the final disposal of the appeal by the Trib .....

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