Pre-amendment reassessment limitation bars late notices under the preserved regime, invalidating consequential reassessment for affected earlier asses...
Cash-sales explanations for bank deposits require documentary reconciliation; reassessment notice survived where effective response time was available...
Functional comparability in transfer pricing prevents ad hoc arm's length adjustments where functions, assets, risks and reliable comparables are unes...
Contingency expenses, exempt-income disallowance, and royalty benchmarking: unsupported adjustments were deleted under consistent accounting and trans...
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The High Court considered an application for compounding contravention under FEMA. The petitioner filed Form FC-TRS belatedly, leading to investigations and complaints. The Court noted that Rule 8(2) of the Compounding Proceeding Rules requires the Compounding Authority to pass an order within 180 days and afford all concerned parties an opportunity to be heard. The Court found that investigations on money laundering charges were ongoing, preventing compounding proceedings. Rule 4(1) empowers the first respondent to compound contraventions, except those related to suspected money laundering. A proviso added to Rule 8(2) prohibits compounding contraventions suspected of terror financing or affecting national sovereignty, remitting such cases to the Adjudicating Authority. The compounding application was returned due to the proviso, which does not allow compounding of contraventions suspected of money laundering.
The High Court considered an application for compounding contravention under FEMA. The petitioner filed Form FC-TRS belatedly, leading to investigations and complaints. The Court noted that Rule 8(2) of the Compounding Proceeding Rules requires the Compounding Authority to pass an order within 180 days and afford all concerned parties an opportunity to be heard. The Court found that investigations on money laundering charges were ongoing, preventing compounding proceedings. Rule 4(1) empowers the first respondent to compound contraventions, except those related to suspected money laundering. A proviso added to Rule 8(2) prohibits compounding contraventions suspected of terror financing or affecting national sovereignty, remitting such cases to the Adjudicating Authority. The compounding application was returned due to the proviso, which does not allow compounding of contraventions suspected of money laundering.
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