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of AT determined no penalties were imposable under FEMA, 1999 for two export transactions involving short-realization of export proceeds. For the first transaction through M.V. Vincentia, the appellant demonstrated bona fide efforts to mitigate losses and obtain RBI approval, with no mandatory requirement for penalty. In the second transaction via MV Riva, excess payment was already received, and respondents failed to substantiate claims of negligence. Consequently, penalties against the corporate entity and individual appellants were set aside, recognizing procedural compliance and absence of intentional contravention.
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