This was sought to be explained by the assessee by submitting
following documents before the assessing officer:
(i) FIPB approval dt 16 September 7998 authorising ... assessee
while proving the share application money. Ignoring various
documents procured from FIPB confirmations, ROC records,
vehement insistence has been made only on the bank
deliberate attempt to hide the real facts and present bogus
documents procured, on the part of assessee.
a) In view of above detailed and satisfaction
view of the above, I am satisfied that the above
seized documents found at the premises of
assessee covered u/s. 153A belongs to person ... Companies (ROC).
Assessee's Counsel drew our attention to the documents procured from
the ROC which shows that the IFSL limited is an existing
done and delivered outside India
(iii) Drawings and documents including detailed engineering documentation
(iv) Procurement services including inspection and expediting for equipment
(v) Services ... things listed includes licensing of the process, preparation, designing and engineering, documentation, procurement services for equipment, services for obtaining import licences, inspection and expediting services
same was rejected by the learned CIT(A) as a self-
procured document.
8. Before proceeding further, it is relevant to note the provisions
Officer. Therefore,
alleged additional evidence is an afterthought and self serving document
procured by the assessee. He has relied upon the decision
authorised dealer certificates, proofs of
withdrawal and remittance, salary records, residence visa
documentation, and employee list downloaded from the
official UAE Ministry of Labour portal ... appropriate
channels. The DRP's remarks that the assessee could procure
documents "due to close connection" with the employer
remain purely speculative
submitted that, the assessee was not granted
sufficient time to procure documents from M/s. Golden Tobacco
and before the same was could be filed
submitted that, the assessee was not granted
sufficient time to procure documents from M/s. Golden Tobacco
and before the same was could be filed
assessee is a member firm of AWSC and, therefore, procuring such documents in the guise of consultancy for development of computer software to benefit
