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...
The AT dismissed the appeal against the penalty imposed under Sections 10(4) and 10(5) of FEMA, 1999, on the appellant, a Deputy General Manager of Andhra Bank, for contravening foreign exchange regulations by failing to obtain requisite permissions for hiring foreign satellite transponders. The appellant's denial of posting at the relevant branch during the period of contravention was found evasive and unsubstantiated, as he failed to produce posting orders for July to December 2012. The Tribunal held that the appellant bore responsibility for the contravention and upheld the penalty of Rs. 10,000/-, already deposited and adjusted accordingly. The appellant was granted liberty to file a review petition with documentary proof of his posting during the relevant period within the prescribed limitation.
The AT dismissed the appeal against the penalty imposed under Sections 10(4) and 10(5) of FEMA, 1999, on the appellant, a Deputy General Manager of Andhra Bank, for contravening foreign exchange regulations by failing to obtain requisite permissions for hiring foreign satellite transponders. The appellant's denial of posting at the relevant branch during the period of contravention was found evasive and unsubstantiated, as he failed to produce posting orders for July to December 2012. The Tribunal held that the appellant bore responsibility for the contravention and upheld the penalty of Rs. 10,000/-, already deposited and adjusted accordingly. The appellant was granted liberty to file a review petition with documentary proof of his posting during the relevant period within the prescribed limitation.
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TaxTMI 
TaxTMI 
of 4918 
