ALTISOURCE BUSINESS SOLUTIONS PRIVATE LIMITED,BANGALORE V. DCIT, CIRCLE 1(1)(1), BANGALORE

SA 100/BANG/2025

AI Insights

The case involves M/s. Altisource Business Solutions Pvt. Ltd., the appellant, seeking an extension of stay on the payment of a tax demand pending the disposal of their appeals for the assessment years 2020-21 and 2021-22. The stay was initially granted on 14/03/2025, and the appellant complied with the conditions by paying 20% of the demand from their refunds. The Deputy Commissioner of Income Tax, Bengaluru, was the respondent. The Tribunal considered the compliance of the appellant and the pending decision of the Supreme Court on a related legal issue, which justified the extension of the stay.

• Counselvise Citation: [2025] 140 COUNSELVISE.COM (IT) 773229 (ITAT-BANGALORE)
• Duration Of Justice: 21 day(s)
• Appeal Type: Stay Application
• Pronouncement Date: 25-09-2025
• Appeal Filed By: Assessee
• Order Result: Allowed
• Bench Allotted: C
• Assessment Year: 2021-2022
• Appeal Filed On: 04-09-2025
• Other Referred Cases: CIT vs. Roca Bathroom Products (P.) Ltd. [2021] 127 taxmann.com 332 (Madras)
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Department Lawyers: N. BALUSAMY
• Assessee Lawyers: KETAN VED
• Keywords: Application of stay; Extension of stay

Judgement Text

"IN THE INCOME TAX APPELLATE TRIBUNAL ‘C’ BENCH : BANGALORE BEFORE SHRI PRASHANT MAHARISHI, VICE – PRESIDENT AND SHRI SOUNDARARAJAN K., JUDICIAL MEMBER S.P. Nos. 99 & 100/Bang/2025 (in IT(TP)A Nos. 1843 & 2473/Bang/2024) Assessment Years : 2020-21 & 2021-22 M/s. Altisource Business Solutions Pvt. Ltd., C/o. Altisource Business Solutions Pvt. Ltd., Vaishnavi Tech Park, Ground Floor, Tower C, Outer Ring Road, Bellandur, Bangalore – 560 103. PAN: AAACO9467A Vs. The Deputy Commissioner of Income Tax, Assessment Circle – 1(1)(1), Bengaluru. APPELLANT RESPONDENT Assessee by : Shri Ketan Ved, Advocate Revenue by : Shri N. Balusamy, JCIT – DR Date of Hearing : 19-09-2025 Date of Pronouncement : 25-09-2025 ORDER PER SOUNDARARAJAN K., JUDICIAL MEMBER These are the stay applications filed by the assessee in which they sought to extend the stay granted in S.P. Nos. 18 & 19/Bang/2025 in IT(TP)A Nos. 1843 & 2473/Bang/2024 on 14/03/2025. Printed from counselvise.com Page 2 of 3 S.P. Nos. 99 & 100/Bang/2025 (in IT(TP)A Nos. 1843 & 2473/Bang/2024) 2. At the time of hearing, the Ld.AR submitted that the Tribunal had directed to adjust the 20% of the demand from the refunds and therefore 20% of the demand has been paid. Based on the said submissions, this Tribunal had granted a stay for the period of six months from the date of that order or till the disposal of the appeal whichever is earlier on 14/03/2025. The Ld.AR further submitted that the assessee is ready to dispose of the main appeal but the Ld.DR, by way of a written request, sought for time since one of the issue involved in the appeal for the A.Y. 2021-22 is about the CIT vs. Roca Bathroom Products (P.) Ltd. reported in [2021] 127 taxmann.com 332 (Madras) issue which is pending before the Hon’ble Supreme Court and therefore the non-disposal of the appeal could not be attributable to the assessee and prayed for the extension of stay. In respect of another appeal for the A.Y. 2020-21, the assessee had complied with the conditions and the non-completion of the appeal could not be attributed on the part of the assessee. 3. We have also perused the documents and found that initially this Tribunal had granted a stay on satisfying itself that the assessee had a refund and the same would be adjusted for 20% of the demand. We have also perused the order sheet for A.Y. 2021-22 and found that the appeal could not be heard since the Ld.DR had filed adjournment applications on the ground that one of the issue to be decided is Roca Bathroom Products (P.) Ltd. which is pending before the Hon’ble Supreme Court. Further, the assessee also complied with the conditions and no violation has been pointed out by the Authorities. In such circumstances, we are inclined to extend the stay for a further period of six months from today or till the disposal of the appeal whichever is earlier. Printed from counselvise.com Page 3 of 3 S.P. Nos. 99 & 100/Bang/2025 (in IT(TP)A Nos. 1843 & 2473/Bang/2024) 4. In the result, both the stay petitions filed by the assessee are allowed by extending the stay granted on 14/03/2025. Order pronounced in the open court on 25th September, 2025. Sd/- Sd/- (PRASHANT MAHARISHI) (SOUNDARARAJAN K.) Vice – President Judicial Member Bangalore, Dated, the 25th September, 2025. /MS / Copy to: 1. Appellant 2. Respondent 3. CIT 4. DR, ITAT, Bangalore 5. Guard file 6. CIT(A) By order Assistant Registrar, ITAT, Bangalore Printed from counselvise.com "