On writ the Court held that  a prima facie case had been made out by the assessee since the associate companies were its tenants from the date when the assessee obtained exemption from payment of Income-tax under section 12A(a) of the Act from the year 1973 onwards. The Department had raised the issue only for the assessment year 2016-17 even though income tax returns were filed by the assessee disclosing the tenancy, right from the date when it was granted exemption from payment of Income-tax under section 12A(a) . The Assessing Officer ought to have considered all these aspects and should have granted stay of the order. The order was not valid.( AY.2016-17)