Charitable sports promotion: sponsorship receipts alone did not defeat registration where funds supported tournaments and player development activitie...
Overdue associated-enterprise receivables: debt-free status defeated notional-interest adjustment, while employee stock-option costs qualified as busi...
Retrospective assessment-limitation amendments validate final orders while contemporaneous segment data governs transfer-pricing comparability and tol...
Transfer pricing adjustments must track international transactions, while unsupported AMP adjustments and unsuitable manufacturing comparables require...
FERA penalty quantification must be reasoned, reasonable and proportionate to the contravention; the statutory maximum under Section 50 does not by itself justify the amount imposed. Where certain export-realisation contraventions were excluded and an RBI write-off was noted, retaining the original penalty without explaining its basis was disproportionate. A finding that the penalty was not harsh or excessive, without articulated quantification reasons, was insufficient. The penalty was therefore set aside and redetermined at a lower amount, with the appeal partly allowed.
FERA penalty quantification must be reasoned, reasonable and proportionate to the contravention; the statutory maximum under Section 50 does not by itself justify the amount imposed. Where certain export-realisation contraventions were excluded and an RBI write-off was noted, retaining the original penalty without explaining its basis was disproportionate. A finding that the penalty was not harsh or excessive, without articulated quantification reasons, was insufficient. The penalty was therefore set aside and redetermined at a lower amount, with the appeal partly allowed.
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