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 Appellate Tribunal (AT) upheld the Adjudicating Authority's finding that the Appellant contravened Section 3(a) of FEMA for an amount of US$ 99,770, and Sections 3(a) & 3(d) for amounts US$ 5,95,738.4 and RMB 5,78,079.8. However, it set aside the contravention charge for US$ 16,000 based on the Appellant's statement. The AT ordered the release of the seized foreign currency and Indian currency of Rs. 9.29 Lakh, which was not confiscated. It reduced the consolidated penalty imposed on the Appellant for the contraventions to Rs. 15,00,000/- from the disproportionately higher amount, finding it reasonable. The AT directed the principles of natural justice were not violated as the Appellant's cross-examination request was not sustainable under FEMA provisions.
The Appellate Tribunal (AT) upheld the Adjudicating Authority's finding that the Appellant contravened Section 3(a) of FEMA for an amount of US$ 99,770, and Sections 3(a) & 3(d) for amounts US$ 5,95,738.4 and RMB 5,78,079.8. However, it set aside the contravention charge for US$ 16,000 based on the Appellant's statement. The AT ordered the release of the seized foreign currency and Indian currency of Rs. 9.29 Lakh, which was not confiscated. It reduced the consolidated penalty imposed on the Appellant for the contraventions to Rs. 15,00,000/- from the disproportionately higher amount, finding it reasonable. The AT directed the principles of natural justice were not violated as the Appellant's cross-examination request was not sustainable under FEMA provisions.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
