INCOME TAX: Where assessee preferred an appeal before Tribunal against additions made to its income on account of royalty issue, Transfer pricing and attribution along with stay application under section 220 seeking for stay of recovery proceedings, since Tribunal remanded issues related to transfer pricing and attribution to TPO, no arbitrariness or perversity was found in interim order of Tribunal considering only demand related to royalty issue while quantifying sum to be paid by assessee as
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