basis of the purchase orders placed by the
customers, internal documents like order forwarding memo,
contract review sheet, it appeared to the revenue that ... invoices are same as
those in the purchase orders or other internal documents, the
Appellant collected the duty amount from the customers. The Ld.
Commissioner
Authority obtained on the request dated
11.12.2023, is in nature of internal documents/correspondence and held
by the Public Authority in fiduciary capacity and also ... Commission observes that the information sought by the applicant is an
internal document/correspondence and held by the public authority in
fiduciary capacity. Therefore
into an international transaction.
92D. (1) Every person who has entered into an international transaction shall keep and maintain such information and document in respect ... services; (this document is hereinafter referred as document-II). The contents of this letter were supposed to be part of original statutory documentation.
3.4 Even
furnished requisite documents. Accordingly, you
are required to provide documents, material (including reports, studies,
plan, latest version of other documents), etc. considered ... document
containing the actual purpose reflected in the said documents was
furnished to the Commission. It is noted that no purpose elaborated in
the Internal
furnished requisite documents. Accordingly, you
are required to provide documents, material (including reports, studies,
plan, latest version of other documents), etc. considered ... document
containing the actual purpose reflected in the said documents was
furnished to the Commission. It is noted that no purpose elaborated in
the Internal
investigation reports sent to the Higher Authorities by PCIT,
Hazaribagh were internal office documents and hence, the information sought was denied ... investigation reports sent to the Higher Authorities by PCIT,
Hazaribagh were internal office documents and hence, the information was denied as it did not
serve
dated 20.03.2014
could not be acceded to as it was internal document of the Department. The
Assessing Officer forwarded the gist of findings of said ... basis the Assessing Officer refused on the ground that it was internal
document. However, he gave gist of letter of DDIT(Inv), which is placed
internal documents, i.e., internal
procedures followed by the assessee. Both of them have made reference to
the internal documents prepared by the assessee only ... documents. Hence the flaw, if any, in the availability of internal documents
would not render the external evidences such as, invoices, delivery challans
BSUA and M/s. BPL Ltd., based on various internal documents of the assessee which clearly reveal the nexus between the parties and their relations ... This decision is arrived in spite of availability of various incriminating internal documents, relied upon by the original authority, which unequivocally revealed existence of mutuality
required documents as
required under Rule 10D, penalty could not have been levied.
Assesse had furnished ---required documents and information
inadequacy of anv document ... holding that the assessee have not maintained proper documents.
Even otherwise, international transaction entered upon by the
assessee with its AE had been held
