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2022 (10) TMI 153

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..... r assessment years cannot be recovered, we deem it fit to grant stay of recovery of outstanding demand for a period of 180 days or the final disposal of the appeals, whichever is earlier. Since the issues raised in these appeals are covered by the earlier order of the Tribunal for assessment years 2012-2013 to 2014-2015, we post these appeals for hearing to 21st September, 2022. Since the date of hearing is pronounced in the open Court, both the parties have waived the right to separate notice of hearing. Stay applications filed by the assessee are allowed. - SA No.41/Bang/2022 (Arising out of IT(TP)A No.2593/Bang/2019), SA No.42/Bang/2022 (Arising out of IT(TP)A No.372/Bang/2021), SA No.43/Bang/2022 (Arising out of IT(TP)A No.200/Bang/20 .....

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..... 73/Bang/2018 respectively, setting aside the matter to AO with a direction to undertake de novo assessment in accordance with the law. 4. We have heard rival submissions and perused the material on record. All the issues raised in these appeals were considered by the Tribunal in assessee s own case for assessment years 2012-2013 to 2014-2015 (supra). The Tribunal had set aside all the issues to the files of the AO with the direction to undertake de novo assessment in accordance with law. Copy of the report of the A.O. in this regard reads as follows:- 2. The assessee company M/s.TE Connectivity India Pvt. Ltd. has filed application for stay of demand for the AY 2015- 16, 2016-17, 2017-18 and 2018-19. The details of tax demand for th .....

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..... herefore covered by the order of the tribunal for the earlier years discussed supra. 5. Further, the amount of Rs.54.04 crores have also been collected / adjusted against the demand for the AYs 2012-13, 2013-14, and 2014-15. The details of the same is tabulated as under:- AY Amount 2012-2013 30,84,59,920 2013-2014 8,96,19,789 2014-2015 14,23,71,238 Total 54,04,50,947 5. In the above report, the A.O. has mentioned the sum of Rs.54.04 crore has also been collected / adjusted against the demand for assessment yea .....

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