High pitched assessments: 100% demand stay must be Granted

CA Suraj R. Agrawal Brief of the Case:- The Tribunal granted 100 percent stay of demand because (a) the assessed income was more than 10 times the returned income. (Instruction 96 of 1969 was relied upon) & (b) The stand taken by the AO was at variance with the stand taken by TPO. Case Summary:- Facts of the case: The petitioner is engaged in the business of profit management support services to group entities in Asia Pacific Region. During Assessment Year 2011-12 the Petitioner has rendered management support services to its 100 percent Indian subsidiary, DDIL and has received a manageme...