Penny-stock additions require transaction-specific evidence; general investigation material alone cannot establish undisclosed income or accommodation...
Transfer pricing comparability prioritises reliable external CUPs and foreign-currency LIBOR benchmarks for exports, borrowings and delayed receivable...
Section 153C satisfaction and seized electronic records sustained unexplained-investment addition, subject to proportionate ownership-share verificati...
Regulation 3(2) of the FEMA (Manner of Receipt and Payment) Regulations requires export receipt in the currency appropriate to the final destination as declared by the exporter, and does not envisage payment by a third party; therefore receipts from third parties for exports made before 08.11.2013 contravened Reg.3(2) - consequence: contravention established. RBI circulars of 08.11.2013 and 04.02.2014 subsequently permitted/regulated third-party payments subject to banks' satisfaction of bona fides and FATF norms - consequence: liberalisation applies prospectively. Directors who signed commercial invoices are liable under Section 42(1) - consequence: company penalty reduced to Rs.15,00,000 and two individual penalties of Rs.3,00,000 each upheld; pre-deposits to be adjusted. - AT
Regulation 3(2) of the FEMA (Manner of Receipt and Payment) Regulations requires export receipt in the currency appropriate to the final destination as declared by the exporter, and does not envisage payment by a third party; therefore receipts from third parties for exports made before 08.11.2013 contravened Reg.3(2) - consequence: contravention established. RBI circulars of 08.11.2013 and 04.02.2014 subsequently permitted/regulated third-party payments subject to banks' satisfaction of bona fides and FATF norms - consequence: liberalisation applies prospectively. Directors who signed commercial invoices are liable under Section 42(1) - consequence: company penalty reduced to Rs.15,00,000 and two individual penalties of Rs.3,00,000 each upheld; pre-deposits to be adjusted. - AT
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