The Appellant raised the tax invoices on the purchasers as per the policy of manufacturers of vehicles to maintain uniformity in the price thereof. After the sales were completed, credit notes were issued to the customers granting discounts, in order to meet the competition in the market and for allied reasons.
It was held that impounded loose sheet can at the most be termed as dumb document which did not contain full details about the dates, and its contents were not corroborated by any material and could not relied upon and made the basis of addition.
Protocol amending the Convention and the Protocol between the Republic of India and the State of Israel for the avoidance of double taxation and for the prevention of fiscal evasion with respect to taxes on income and on capital was signed at Jerusalem, Israel on the 14th day of October, 2015 (hereinafter referred to as the said Protocol);
1. Nonresident taxable person, input service distributor, person paying tax under composite levy scheme, deducting TDS/collecting TCS are not required to furnish the details regarding of input supply of goods & services.
As there is no representational right conferred by AAI on the petitioners, the OM DA cannot constitute a franchise in terms of Section 65(47) of the Finance Act. Further as no service is being provided by AAI to the petitioners, there cannot be said to be any taxable service in terms of section 65(105) (zze).
Capital infusion refers to the process whereby funds are injected into startup companies or large companies by an investor with a financial interest in the company. Capital infusion also refers to the process of transferring money from a successful unit, division or subsidiary of a company to another unit that is not doing well with the aim of injecting new life into that unit.
In this case, the expenditure clearly is not towards acquisition of the capital nor is it an integral part of it, it is only the service alone. It is of a similar kind that would otherwise have been permitted under Section 37 of the Income Tax Act.
Assessing Officer, could have only come to a conclusion that the subject transactions were bogus, based on substantive material, and not that because objections were not filed by the petitioner, the assertions made in the pre-assessment notice would have to be deemed to be correct.
In partial modification of Para 2 of the circular IMD/FII&C/30/2008 dated July 21, 2008, it has been decided that the custodians shall submit the monthly reports latest by either the end of the third working day of the succeeding month or the 5th of the succeeding month, whichever is later.
List of Pr. CsIT charges where e-Nivaran is operational is enclosed herewith as per Annexure—A. Some of Pr. CsIT charges have not sent their replies or have been unable to upgrade ASK with e-Nivaran in their respective charges the list of which is separately enclosed herewith as per Annexure —B.
