Assessee-company, subsidiary of Mauritius based group company was part of Vodafone group.  TPO observed that over a period from 2008-2015, direct and indirect shareholding of Vodafone Group plc in Vodafone India Limited had increased from 51.58 per cent to 100 per cent.Accordingly, TPO made ALP adjustment on account of assignment of call/put options vested by assessee to its Mauritius based group concern, inasmuch as it put said group concern at an undue advantage of buying Vodafone India shares at a price much below market rate without any corresponding benefit to assessee. Consequently, Assessing Officer made high pitched adjustment and raised demand against assessee. Assessee-company filed stay application seeking a blanket unconditional stay on demands contending that Tribunal passed stay order in assessment year 2008-09 wherein assessee deposited substantial amount along with corporate guarantee and same ought to be reckoned for purpose of stay application for subsequent assessment year 2014-15.  Assessee further claimed that deposits made in assessment year 2008-09 had been adjusted by revenue by way of protective adjustment for assessment year 2010-11.  However, Tribunal granted a conditional stay by directing assessee to pay 20 per cent of disputed tax demand and furnish a corporate guarantee-It was noted that assessment year 2008-09, being a substantive assessment, assessment for year 2010-11 would be required to be treated as a protective assessment as put/call options exercised was 2.34 per cent, however, events which triggered taxation in subsequent period were different as it pertained to 6.01 per cent of holding in respect of call and put options being actually exercised. On writ the Court held that  recovery as sought to be made for relevant assessment year could not be in nature of protective recovery and interim order passed by Tribunal on stay application was purely a discretionary order, an upheld. (AY. 2014-15)