Power to receive documentary evidence upheld; documents referred in complaint may be placed on record without amendment where omission was inadvertent...
Proof of foreign public documents requires originals or certified diplomatic/notarial copies; inspection must occur in-magna presence and cross-examin...
Prior Sanction Requirement: absence of prescribed approval invalidates reassessment notice; limitation also bars notice if escaped income below thresh...
Eligibility for exemption depends on strict construction of the product description; reapers without binder are ineligible, but confiscation and penal...
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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