stage, that according to him he had
earlier purchased two mobile sim cards for mobile hand sets when he
was posted at INS Mahish, Port ... mobile sim No. 8108770020. He also claimed to
have advised his wife to replace her old sim No. 9564784782 by the
new mobile sim
when the ass e s s e e so l d SIM card ... cards. Only after the resale of those
prepaid cards, distributors would derive income. At the time of
the assessee selling these pre-paid cards
when the ass e s s e e so l d SIM card ... cards. Only after the resale of those
prepaid cards, distributors would derive income. At the time of
the assessee selling these pre-paid cards
Assessing Officer
further noticed that discounts on pre-paid SIM Cards/recharge coupons had
already been held to be subjected to TDS as 'commission ... retailers and finally
Module (SIM) its services, Idea retailers sell these
appoints distributors products to end
and transfer 'SIM cards' customers charging
engaged in the business of trading in
mobile and accessories including SIM card, pre-paid card etc. During the course of
assessment proceedings ... sale figures
supplied by the assessee out of purchase consideration of SIM card. However, the
ld. CIT (A) did not accept the contention
194H on the
commission payment made by assessee as wholesaler of SIM
cards / mobile phones etc to retailers / sub-dealers thereof
without appreciating the nature ... assessee is
engaged in purchase and sale of mobile & accessories, SIM Cards,
Recharge coupons etc. During the course of assessment proceeding the
AO noted
extended to its pre-paid distributors on distribution of
pre-paid SIM cards/ talktime
2.1 On the facts and circumstances of the case ... discount extended to the distributors of its pre-paid
SIM cards/ talktime during the subject financial year.
2.2 On the facts and circumstances
cupboard), were recovered (i) one ―GILD‖ make mobile phone, with
two SIM cards, having IMEI Nos. 356842041277026 and
356842041277034 (Ex P-2), (ii) one passbook ... mobile phone, with IMEI 351703041833090, but without any SIM
card, and one mobile phone, having Vodafone No. 7838205464, were
recovered and seized, vide Seizure Memos
customer application form so as to dishonestly
procure a SIM card from which to make ransom calls. He was also charged
with having been found ... handwriting on the customer application form (CAF) for
issuance of the SIM card. A-1 denied this evidence as well.
64. The statement
confessed as that of deceased Arshad but when the number of sim card which was inserted in that cellphone was found ... confessed to be that of the deceased Arshad but neither the sim card no. 8126197036 was exhibited during the trial nor the IMEI
