Allocation of registration charges: contractual clause overriding statutory presumption allowed as deduction against capital gain after unrebutted doc...
Expenditure tied to investments yielding exempt income restricted to attributable costs; broader disallowance disallowed and adjustments to WDV and mi...
Admissibility of Investigative Statements invalidated reliance on coerced emails and valuation redetermination, resulting in set aside of penalties an...
Classification of printed technical documents: specific Chapter 49.01 entry prevails, enabling claimed customs exemptions for imported manuals and rep...
Round tripping via two wholly owned overseas subsidiaries was held to contravene the prohibition on unauthorised foreign exchange transactions where subsidiaries were used to obtain foreign borrowings and reinvest in Indian group companies rather than to carry on bona fide overseas business; the statutory outward investment regime permits overseas JV/WOS only where bona fide activity exists and Regulation 7 safeguards for financial service entities were circumvented, so the transactions breached the applicable FEMA transfer/issue regulations. The adjudicating authority's reliance on RBI observations was upheld as accompanied by independent analysis, and penalties were sustained.
Round tripping via two wholly owned overseas subsidiaries was held to contravene the prohibition on unauthorised foreign exchange transactions where subsidiaries were used to obtain foreign borrowings and reinvest in Indian group companies rather than to carry on bona fide overseas business; the statutory outward investment regime permits overseas JV/WOS only where bona fide activity exists and Regulation 7 safeguards for financial service entities were circumvented, so the transactions breached the applicable FEMA transfer/issue regulations. The adjudicating authority's reliance on RBI observations was upheld as accompanied by independent analysis, and penalties were sustained.
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