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...
The case involves an offense u/s 5 of FEMA for carrying US$ 50,000 in Travelers Cheques without necessary permissions for a business trip. The appellant was not directly involved in applying for the foreign exchange, which was done by company directors. Despite lack of awareness, appellant was held liable for not verifying RBI permission. Finance Manager was found vicariously liable for being aware of the violation. Penalties were reduced for the appellants due to their minor roles. The appeal partially allowed, reducing penalties to Rs. 50,000 each, already pre-deposited.
The case involves an offense u/s 5 of FEMA for carrying US$ 50,000 in Travelers Cheques without necessary permissions for a business trip. The appellant was not directly involved in applying for the foreign exchange, which was done by company directors. Despite lack of awareness, appellant was held liable for not verifying RBI permission. Finance Manager was found vicariously liable for being aware of the violation. Penalties were reduced for the appellants due to their minor roles. The appeal partially allowed, reducing penalties to Rs. 50,000 each, already pre-deposited.
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