"SA No.7/Bang/2026 M/s. Sigma Aldrich Chemicals Pvt. Ltd., Bangalore IN THE INCOME TAX APPELLATE TRIBUNAL “C’’ BENCH: BANGALORE BEFORE SHRI PRASHANT MAHARISHI, VICE PRESIDENT AND SHRI KESHAV DUBEY, JUDICIAL MEMBER SA No.7/Bang/2026 (Arising out of IT(TP)A No.2601/Bang/2024 Assessment Year: 2021-22 M/s. Sigma Aldrich Chemicals Pvt. Ltd. Plot No.12, Bommasandra Jigani Link Road Industrial Area Anekal Taluk Bengaluru 560 100 Karnataka PAN NO : AAHCS1882L Vs. DCIT Circle-6(1)(1) Bengaluru APPELLANT RESPONDENT Appellant by : Sri Tata Krishna, A.R. Respondent by : Sri N. Balusamy, D.R. Date of Hearing : 23.01.2026 Date of Pronouncement : 23.01.2026 O R D E R PER KESHAV DUBEY, JUDICIAL MEMBER: The present Stay Application No. 7/Bang/2026 filed by M/s. Sigma Aldrich Chemicals Pvt. Ltd. (The assessee/Applicant) for the assessment year 2021-22 in IT(TP)A No.2601/Bang/2024 seeking further extension of the stay already granted by the order of the coordinate bench on 18/07/2025, which is placed at pages 18 to 20 of the paper book. It is worthwhile here to mention that this Tribunal vide order dated 06/01/2025 in SP No. 81/Bang/2024 had originally granted Stay with a direction to the AO to verify the payment of Rs. 4.4 crores by the assessee & then to keep the balance demand in abeyance, till disposal of the appeal or 180 days from the date of the receipt of the order, whichever is earlier. Therefore, the claim of the assessee is that there is no change in the facts and circumstances of Printed from counselvise.com SA No.7/Bang/2026 M/s. Sigma Aldrich Chemicals Pvt. Ltd., Bangalore Page 2 of 3 the case and the delay in disposal of appeal is also not on account of the assessee. The assessee has raised a ground of limitation based on the decision of Hon’ble Madras High Court in the case of CIT & Ors v. M/s Roca Bathroom Products Pvt. Ltd. Reported in (2022) 445 ITR 537. It is covered in favour of the assessee but the revenue is seeking adjournment on the earlier occasions when the appeal was posted for hearing. Therefore, the assessee deserves extension of stay. The ld. A.R. reiterated the same facts. 2. The ld. D.R. vehemently stated that the assessee may be directed to deposit the tax beyond what is deposited. 3. We have carefully considered the rival contentions and perused the contentions of the said petition filed before us. The assessee was originally granted stay by an order dated 6.1.2025 in SA No.81/Bang/2024 in IT (TP)A No.2601/Bang/2024 for assessment year 2021-22, wherein the stay was granted on the fact that assessee had deposited a sum of Rs.4.4 crores on 31.12.2024 against the outstanding demand of Rs.20.34 crores. The stay was also granted for the reason that the assessee has challenged the validity of the assessment order by contesting that the issue is covered in favour of the assessee by the decision of Hon’ble Madras High Court in the case of Roca Bathroom Products Pvt. Ltd. cited (supra). After granting of the above stay, either the revenue is seeking adjournment or the bench did not function. Therefore, we are of the considered opinion that the delay in disposal of the appeal is not on account of the assessee. In view of the above facts, we extend the stay originally granted on the same terms and conditions for a further period of 180 days from the date of service of this Order or till the disposal of appeal, whichever is earlier. Printed from counselvise.com SA No.7/Bang/2026 M/s. Sigma Aldrich Chemicals Pvt. Ltd., Bangalore Page 3 of 3 4. In the result, stay application filed by the assessee is allowed. Order pronounced in the open court on 23rd Jan, 2026 Sd/- (Prashant Maharishi) Vice President Sd/- (Keshav Dubey) Judicial Member Bangalore, Dated 23rd Jan, 2026. VG/SPS Copy to: 1. The Applicant 2. The Respondent 3. The CIT 4. The DR, ITAT, Bangalore. 5 Guard file By order Asst. Registrar, ITAT, Bangalore. Printed from counselvise.com "