Approved resolution plans extinguish unsubmitted pre-approval tax claims, preventing later recovery outside the insolvency process and preserving a cl...
Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
Admissibility of statements recorded under the Customs Act in FEMA proceedings was upheld where those statements were corroborated by independent evidence; retracted confessional statements may be relied upon if supported by corroboration and not shown to be involuntary, and the tribunal accepted prior Supreme Court principles on this point. Digital and physical evidence recovered and examined by GEQD, Hyderabad, including transaction records and slip pads, corroborated payments routed through intermediaries and non-banking channels, supporting findings of contravention of FEMA. Penalties against the principal respondents for contravening FEMA provisions were sustained, while penalties imposed on nominal partners were set aside.
Admissibility of statements recorded under the Customs Act in FEMA proceedings was upheld where those statements were corroborated by independent evidence; retracted confessional statements may be relied upon if supported by corroboration and not shown to be involuntary, and the tribunal accepted prior Supreme Court principles on this point. Digital and physical evidence recovered and examined by GEQD, Hyderabad, including transaction records and slip pads, corroborated payments routed through intermediaries and non-banking channels, supporting findings of contravention of FEMA. Penalties against the principal respondents for contravening FEMA provisions were sustained, while penalties imposed on nominal partners were set aside.
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