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The AT allowed the appeal in part. The Tribunal found that Respondent Nos. 2 and 3, acting through their director and authorised representative, caused foreign exchange loss of Rs. 23,63,89,843 and procured assets abroad worth Rs. 4,89,69,850 by contravening FEMA provisions; their conduct amounted to masterminding the contraventions. The penalty previously imposed on Respondent No. 1 is maintained subject to the outcome of any cross-appeal. The penalties on Respondent Nos. 2 and 3 are enhanced to Rs. 1,00,00,000 each on parity grounds. The decision affirms liability findings against all respondents and increases monetary sanctions against Respondent Nos. 2 and 3.