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...
The AT held that the appellant, a non-Indian citizen, does not fall under the definition of "person resident in India" under FERA. The tribunal rejected the appellant's arguments and found insufficient evidence to prove the applicant's residential status during the relevant period. Consequently, the application of section 8(1) restricting foreign exchange transactions could not be substantiated. The tribunal summarily dismissed the first argument raised by the appellant and concluded that the provisions of the Act do not automatically apply solely to non-citizen individuals without establishing specific residential criteria as defined in the statutory provisions.
The AT held that the appellant, a non-Indian citizen, does not fall under the definition of "person resident in India" under FERA. The tribunal rejected the appellant's arguments and found insufficient evidence to prove the applicant's residential status during the relevant period. Consequently, the application of section 8(1) restricting foreign exchange transactions could not be substantiated. The tribunal summarily dismissed the first argument raised by the appellant and concluded that the provisions of the Act do not automatically apply solely to non-citizen individuals without establishing specific residential criteria as defined in the statutory provisions.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
