Stay of demand granted against TP adjustment as demand was raised for first time despite prolonged p

IT/ILT: Where assessee sought stay of demand in respect of transfer pricing adjustment made on account of marketing expenses and service charges, in view of fact that issue relating to marketing expenses was pending adjudication since assessment year 2004-05 whereas adjustment on account of service charges was made for first time in relevant year, a prima facie case for stay of demand was made out subject to assessee making part payment of amount demanded