Reasoned rectification orders require consideration of expenditure disclosed in income-tax returns, preventing revision based on incomplete income com...
Modified returns after business reorganisations cannot trigger fresh scrutiny once the original assessment was complete, invalidating related transfer...
Third-party loose sheets require reliable nexus before supporting unexplained expenditure additions; presumptions do not establish payer identity or o...
TNMM comparability using audited accounts and working-capital adjustments can eliminate unwarranted transfer-pricing additions where verified margins ...
Gross-profit additions on disputed purchases require reasoned appellate determination; disclosed claims alone do not support inaccurate-particulars pe...
Limitation after transfer-pricing remand: fresh TPO reference did not extend the assessment deadline, rendering the consequential assessment time-barr...
Interim judicial restraint on tax deduction prevents default, while supporting reasonable cause and penalty deletion for foreign-leg LFC reimbursement...
Palmolein classification defeated the crude-oil concession; material misdeclaration sustained recovery and confiscation, while separate false-document...
The appellant acquired and sold foreign currencies to Indian residents in violation of Section 3(a) of FEMA, 1999. The validity of the search and seizure conducted by the Directorate was upheld. The appellant's recorded statements, corroborated by seized documents from his residence, established his liability for unauthorized foreign exchange operations without RBI permission. Cross-examination denial did not prejudice the appellant due to independent corroborative evidence. While the appellant claimed efforts to keep his licensed money changer business clean, the penalty was reduced to Rs. 8,50,000/- considering the circumstances.
The appellant acquired and sold foreign currencies to Indian residents in violation of Section 3(a) of FEMA, 1999. The validity of the search and seizure conducted by the Directorate was upheld. The appellant's recorded statements, corroborated by seized documents from his residence, established his liability for unauthorized foreign exchange operations without RBI permission. Cross-examination denial did not prejudice the appellant due to independent corroborative evidence. While the appellant claimed efforts to keep his licensed money changer business clean, the penalty was reduced to Rs. 8,50,000/- considering the circumstances.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4897 
