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R.P.TOLANI, G.E.VEERABHADRAPPA
Birlasoft (India) Ltd. – Appellant
Versus
Deputy Commissioner of Income-tax, Circle 12(1), New Delhi – Respondent


Advocates Appeared:
Ajay Vohra,Manish Gupta

ORDER

G.E. Veerabhadrappa, Vice President. - By this stay application, the assessee requests the Tribunal to stay the following demand raised for the assessment year 2006-07 :—

Income-tax
Rs. 20,08,89,703
Interest
Rs. 10,24,32,139
Total
Rs. 30,33,21,842
Balance outstanding
Rs. 30,33,21,842

2. For the assessment year 2006-07, the assessee filed a return of income on 31-11-2006, clearing loss of Rs. 22,64,57,900. The assessment was completed vide order dated 27-4-2010 passed under section 143(3) read with section 144C of the Income-tax Act, 1961, assessing the total income of the assessee at Rs. 59,68,20,270, inter alia making the following additions and disallowances :

(i)addition of Rs. 45,15,21,255 on account of international transactions

(ii)Disallowances of set-off of losses of STPI units amounting to Rs. 22,65,96,783

(iii)disallowance of travelling expenses to the tune of Rs. 14,07,18,569.

3. The entire demand that is disputed is the result of above three additions and disallowances. The major dispute is in relation to addition in respect of international transactions. The assessee is engaged in the business of software

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