Assessee is\u00a0 engaged in business of distribution of mobile phones and other electronic products. It purchased finished goods from local third party and overseas AEs for purpose of distribution. Assessing Officer passed assessment order making additions with respect to disallowance of royalty expenses paid to AEs and transfer pricing adjustments proposed by TPO. Subsequently, demand notice was issued under section 156 and order under section 281B was passed for provisionally attaching fixed deposits of assessee to protect interest of revenue. The\u00a0 assessee had sought stay of outstanding disputed demand which was inclusive of interest on it under sections 234B and 234C\u00a0 Tribunal held that\u00a0\u00a0 attachment of fixed deposits was done by Enforcement Directorate as well as by Income Tax authorities and there was overlapping of attachments. Since interest of revenue for relevant assessment year was fully covered, till this attachment would continue assessee would not be required to pay any further payment and stay was to be granted. In event attachment of bank accounts as vacated or revoked or disturbed or modified, assessee shall deposit 20 per cent of outstanding liability. (AY. 2018-19)<\/p>\n","protected":false},"excerpt":{"rendered":"
S. 254(2A) : Appellate Tribunal-Stay-Attachment of fixed deposit by ED as well as Income-tax Authorities-Till attachment would continue assessee would not be required to pay any further payment and stay was to be granted-In event attachment of bank accounts as vacated or revoked or disturbed or modified, assessee shall deposit 20 per cent of outstanding liability [S. 254(1), 281B] <\/p>\n","protected":false},"author":3,"featured_media":0,"comment_status":"open","ping_status":"open","sticky":false,"template":"","format":"standard","meta":{"_acf_changed":false,"jetpack_post_was_ever_published":false,"_jetpack_newsletter_access":"","_jetpack_dont_email_post_to_subs":false,"_jetpack_newsletter_tier_id":0,"_jetpack_memberships_contains_paywalled_content":false,"_jetpack_memberships_contains_paid_content":false,"footnotes":""},"categories":[21],"tags":[],"class_list":["post-44400","post","type-post","status-publish","format-standard","hentry","category-income-tax-act"],"acf":[],"jetpack_featured_media_url":"","jetpack_shortlink":"https:\/\/wp.me\/p9S2Rw-by8","jetpack-related-posts":[],"jetpack_sharing_enabled":true,"_links":{"self":[{"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/posts\/44400","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/posts"}],"about":[{"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/types\/post"}],"author":[{"embeddable":true,"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/users\/3"}],"replies":[{"embeddable":true,"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/comments?post=44400"}],"version-history":[{"count":1,"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/posts\/44400\/revisions"}],"predecessor-version":[{"id":44401,"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/posts\/44400\/revisions\/44401"}],"wp:attachment":[{"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/media?parent=44400"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/categories?post=44400"},{"taxonomy":"post_tag","embeddable":true,"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/tags?post=44400"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}