Reopening of assessment cannot rest solely on an audit party's opinion; reassessment under Section 147/148 is impermissible and power of revision shou...
Tested party selection: functional analysis identified the least complex unit as the appropriate tested party, altering the transfer pricing adjustmen...
Receipt of foreign currency through a non-banking channel was admitted to have accrued on 16.07.2007 and not repatriated/surrendered within 180 days, constituting contravention of Section 3(a) and Section 4 of the Act of 1999 and Section 8 read with Regulations 3 and 7 of the 2000 Regulations; the penalty was therefore sustained but reduced proportionately considering the amount involved in Singapore Dollars, with adjustment of any pre-deposit. Separately, confiscation of the seized cash was set aside because there was no finding that the cash was used or involved in any hawala transaction or other contravention, and mere possession without nexus to a violation did not justify confiscation. - AT
Receipt of foreign currency through a non-banking channel was admitted to have accrued on 16.07.2007 and not repatriated/surrendered within 180 days, constituting contravention of Section 3(a) and Section 4 of the Act of 1999 and Section 8 read with Regulations 3 and 7 of the 2000 Regulations; the penalty was therefore sustained but reduced proportionately considering the amount involved in Singapore Dollars, with adjustment of any pre-deposit. Separately, confiscation of the seized cash was set aside because there was no finding that the cash was used or involved in any hawala transaction or other contravention, and mere possession without nexus to a violation did not justify confiscation. - AT
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