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...
AT determined appellant violated FEMA, 1999 by illegally possessing unaccounted foreign currency without authorization from RBI. The tribunal found appellant's explanation for foreign currency possession unconvincing and identified mala fide intentions. The seized foreign currency equivalent to INR 3,30,82,775.28 was confiscated under Section 13(2), with a penalty of Rs. One lakh imposed. Additionally, the payment of USD 22,000 to an NRI without RBI permission constituted a breach of Section 3(b), resulting in a supplementary penalty of Rs. 10,000. The appeal was dismissed, and the Adjudicating Authority's original order was fully upheld.
AT determined appellant violated FEMA, 1999 by illegally possessing unaccounted foreign currency without authorization from RBI. The tribunal found appellant's explanation for foreign currency possession unconvincing and identified mala fide intentions. The seized foreign currency equivalent to INR 3,30,82,775.28 was confiscated under Section 13(2), with a penalty of Rs. One lakh imposed. Additionally, the payment of USD 22,000 to an NRI without RBI permission constituted a breach of Section 3(b), resulting in a supplementary penalty of Rs. 10,000. The appeal was dismissed, and the Adjudicating Authority's original order was fully upheld.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
