Assessee-company purchased its own shares from non-resident shareholders in accordance with a scheme of arrangement sanctioned by High Court. Assessing Officer treated consideration paid by assessee for purchase of its own shares from shareholders as deemed dividend and consequently assessee was liable for payment of DDI under section 115-O. On pendency of appeal the Assessee filed petition seeking for an order of interim stay of all recovery proceedings initiated by revenue. Assessee submitted that they had already paid a sum of Rs. 495 crores, besides a sum of Rs. 898.01 crores towards TDS remittance, available with department. High Court directed revenue to release lien on remaining fixed deposits after assessee made a payment of Rs. 1500 crores in cash or give a letter to bank to remit Rs. 1500 crores to credit of revenue from fixed deposits available, and furnish property security for balance tax liability with interest and penalty.On appeal the Court modified and requirement of security with respect to penalty was to be dispensed with. (AY. 2017-18)