Transfer pricing requires evidence for AMP transactions, functionally reliable comparables, and appropriate aggregation or Berry Ratio benchmarking me...
Revisionary jurisdiction cannot reopen share capital assessments where adequate inquiry supports a permissible view and no independent error is establ...
Reassessment jurisdiction fails where unverified portal information is aggregated without examining the taxpayer's explanation or relevance of entries...
Statutory sanction for delayed reassessment requires approval from the prescribed authority; approval by an inferior authority invalidates jurisdictio...
Transfer pricing margin adjustments require matching treatment of non-operating income and related costs, with comparability issues reconsidered on ev...
Preliminary-expense amortisation and MAT exempt-income adjustments prevailed, while trademark costs and managerial remuneration require fresh verifica...
Export valuation requires contemporaneous evidence; unrelated invoices cannot prove overvaluation, and dual penalties on firm and partner are impermis...
The case involved a violation of the FEMA Act due to accepting and placing bets on cricket matches for clients. The appellant was linked to the raided premises where incriminating evidence was found. The Appellate Tribunal found the appellant guilty based on evidence, including statements and financial transactions. Penalties were imposed u/s 4 of FEMA and u/s 3(d) of the Act of 1999. The Tribunal reduced the penalties to make them proportionate to the contraventions. The total penalty imposed on the appellant was Rs. 50 lakhs, with Rs. 10 lakhs for u/s 4 and Rs. 40 lakhs for u/s 3(d). The appeal was partly allowed based on the revised penalties.
The case involved a violation of the FEMA Act due to accepting and placing bets on cricket matches for clients. The appellant was linked to the raided premises where incriminating evidence was found. The Appellate Tribunal found the appellant guilty based on evidence, including statements and financial transactions. Penalties were imposed u/s 4 of FEMA and u/s 3(d) of the Act of 1999. The Tribunal reduced the penalties to make them proportionate to the contraventions. The total penalty imposed on the appellant was Rs. 50 lakhs, with Rs. 10 lakhs for u/s 4 and Rs. 40 lakhs for u/s 3(d). The appeal was partly allowed based on the revised penalties.
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