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TMI Blog2019 (7) TMI 1978X X X X Extracts X X X X X X X X Extracts X X X X ..... certain legal cases filed against the assessee in USA. If that is so then how it can be said that by rendering these services, the concerned parties had made available technical knowledge to assessee in India. As per the invoices of M/s. Angeli Law Group LLC, the invoice is for professional charges for the month of March to October 2012, April 2013 and May 2013 in addition to that, there is commission payment. Thus additional evidence should be admitted and hence, we are admitting the same and restore the entire matter back in both years to the file of ld. CIT(A) for fresh decision. Appeals filed by the assessee are allowed for statistical purposes. X X X X Extracts X X X X X X X X Extracts X X X X ..... ds is without prejudice to one another and the appellant craves leave of the Hon'ble Income Tax Appellate Tribunal to add, delete, amend or otherwise modify one or more of the above grounds either before or at the time of hearing of this appeal." 3. Similarly, the grounds raised by the assessee for Assessment Year 2014-15 in ITA No. 98/Bang/2018 are as under. "1. That the order passed by the learned Commissioner of Income-Tax in so far it is prejudicial to the interests of the appellant is bad and erroneous in law and against the facts and circumstances of the case. 2. That the learned Commissioner of Income Tax (Appeals) erred in law and on facts in holding that the appellant is required to deduct tax at source u/s 195 of the Ac ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... IT(A). He submitted a request for filing additional evidence being confirmation letter and invoice copies of M/s. Angeli Law Group LLC, confirmation letter and invoice copies of M/s. Akin Gump Strauss Hauer and Feld LLP, confirmation letter from Mr. M David Loic, invoice copy from M/s. BCCC, Avocats and Attorneys- At-Law and invoice copy from M/s. Dan Tan Law, International Litigation and Arbitration. It is also submitted in the said application for granting leave for filing additional evidence that the fees in question was paid to these legal firms for providing legal services to assessee outside India and also for commission outside India. It was submitted that the additional evidence should be admitted and the matter may be restored back ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ssee in India. Now as per the additional evidence filed before us, it is seen that these invoices are in respect of rendering of services to the assessee in respect of certain legal cases filed against the assessee in USA. If that is so then how it can be said that by rendering these services, the concerned parties had made available technical knowledge to assessee in India. As per the invoices of M/s. Angeli Law Group LLC, the invoice is for professional charges for the month of March to October 2012, April 2013 and May 2013 in addition to that, there is commission payment. In our considered opinion, in the facts of present case and in the interest of justice, additional evidence should be admitted and hence, we are admitting the same and ..... X X X X Extracts X X X X X X X X Extracts X X X X
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