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Present stay petition has been filed by assessee seeking stay of outstanding demand of Rs.17,92,38,164/- arising out of final assessment order dated 25.09.2019 passed by Ld.ITO, Circle 2 (1)(1) for A.Y: 2015-16.

2. The Ld.AR submitted that Citrix R&D India Private Limited ('the Petitioner'), a private limited company, having its registered office in Bangalore, subsidiary of Citrix Systems Inc., USA ("Citrix US"). The petitioner is a registered 100% Export Oriented Unit (EOU) with Software Technology Park Scheme ("STPI", Bangalore) (in IT(TP)A No. 2428/Bang/2019) wherein the petitioner performs software development that supports and supplements Citrix US's product offerings in the cloud computing and online services industry. Further, the petitioner is also engaged in rendering order processing services and technical support services to its Associated Enterprises ("AEs"). For the Assessment Year under consideration, the petitioner filed its return of income on November 30, 2015, declaring a total income of Rs.58,17,74,420. In the draft assessment order, addition of Rs. 57,12,70,900/- was made on account of adjustment to the arm's length price of the international transactions between the petitioner and its AEs. This adjustment was made in conformity with the order passed by the Ld.TPO vide order dated 30.10.2018.