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 upheld the contravention finding against the appellant for failing to justify an unaccounted amount of Rs. 7,21,800/- recovered from his premises, which violated Section 10(4) of FEMA. While rejecting the appellant's self-serving defense, the tribunal modified the penalty from Rs. 4,00,000/- to Rs. 1,00,000/-, considering the amount was already confiscated and the appellant was not a habitual offender. The pre-deposit, if any, shall be adjusted against the reduced penalty, with any excess to be refunded within three months from the appeal limitation period.
AT upheld the contravention finding against the appellant for failing to justify an unaccounted amount of Rs. 7,21,800/- recovered from his premises, which violated Section 10(4) of FEMA. While rejecting the appellant's self-serving defense, the tribunal modified the penalty from Rs. 4,00,000/- to Rs. 1,00,000/-, considering the amount was already confiscated and the appellant was not a habitual offender. The pre-deposit, if any, shall be adjusted against the reduced penalty, with any excess to be refunded within three months from the appeal limitation period.
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TaxTMI 
TaxTMI 
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