Transfer pricing adjustments for software services, corporate guarantees, expense characterisation and foreign tax credit affirmed under arm's length ...
Scientific Research approval for Sikshya O Anusandhan under section 35(1)(ii) granted subject to reporting, certification, and compliance requirements...
Whether penalty under s.13(1) FEMA for contravention relating to export proceeds/undervaluation should be enhanced up to three times was rejected because the provision prescribes only a maximum ceiling and no minimum or fixed penalty, leaving quantum to the adjudicating authority's judicious discretion based on facts and evidence. The adjudication order contained detailed, reasoned findings evaluating the record, and there is no statutory mandate to impose the maximum penalty merely because it is permissible. Consequently, the request for enhancement failed and the appeal was dismissed. - AT
Whether penalty under s.13(1) FEMA for contravention relating to export proceeds/undervaluation should be enhanced up to three times was rejected because the provision prescribes only a maximum ceiling and no minimum or fixed penalty, leaving quantum to the adjudicating authority's judicious discretion based on facts and evidence. The adjudication order contained detailed, reasoned findings evaluating the record, and there is no statutory mandate to impose the maximum penalty merely because it is permissible. Consequently, the request for enhancement failed and the appeal was dismissed. - AT
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