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...
Transfer-pricing adjustments must reflect functional comparability, working-capital effects, and avoid duplicating interest on associated-enterprise r...
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.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4881 
