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or relates to" came into effect from 01.06.2015 and is prospective in nature. The Learned Counsel for the Assessee drew the attention of the Bench to the following documents belonging to Cabinet Jean Louis Deniot/Jean Louis Deniot/ Design 39 Inc. in the satisfaction note. 

 Annex.   Page No.                              Description
  A-14      1-19      As per details below payment to beneficiary account of Cabinet
                      Jean Louis
  A-ll    Hard Disc Email conversation regarding payment to Mr. Jean Louis Deniot
                    in foreign currencies
  A-12    Hard Disc
  A-14    Hard Disc Accounts of Impress Estates Pvt. Ltd. Email conversation

regarding designing, furnishing and payment to Mr. Jean Louis Deniot in foreign currency.

A-18 Hard Disc Email conversation regarding payment to Mr. Jean Louis Deniot in foreign currencies Bills of for a hand knitted carpet purchased from M/s Textico A-20 Hard Disc Creations for the Farm House. Email conversation regarding payment to Mr. Jean Louis Deniot foreign currencies. A-2 28-29 Copies Email conversation between Dinesh and Heather Walter and Virgine Deniot regarding invoices from Jean Louis Deniot's office.

B. Print outs of emails retrieved from the hard disc where name of Jean Louis Deniot, Cabinet Jean Louis and Design-39 Inc. is mentioned and also payments to these individuals/entities is mentioned, and C. Invoices sent by Jean Louis Deniot/Cabinet Jean Louis 6.4. He submitted that Hard Disc seized from the premises C-134, Defence Colony, New Delhi and recorded in the Panchnama in the name of AMQ Agro India (P) Ltd., would definitely belong to the AMQ Agro India (P) Ltd., and not the non-resident. The non-resident individual/entity did not have an office in India is an uncontroverted position. Even the assessing authorities have no where alleged that the nonresident had an office in India. Thus, these hard discs cannot be said to belong to the person other than the searched person. So far as the printouts of emails retrieved from the hard discs are concerned, he submitted that the ITA.No.6672 to 6675, 6668 to 6671 & 6667/Del./2018 Moin Akhtar Qureshi, Representative Assessee/Agent of M/s. Jean Louis Deniot etc., New Delhi.

A. Hard Disc and contents thereof.
B. Print outs of emails retrieved from the hard disc where name of Jean Louis Deniot, Cabinet Jean Louis, Design-39 Inc. is mentioned and also payments to these individuals/entities is mentioned, and ITA.No.6672 to 6675, 6668 to 6671 & 6667/Del./2018 Moin Akhtar Qureshi, Representative Assessee/Agent of M/s. Jean Louis Deniot etc., New Delhi.