Trademark depreciation and section 14A adjustments: ITAT applies consistency, independent book-profit computation, and no disallowance without exempt ...
Rebuttable search presumptions and corroboration standards shaped deletion of unsubstantiated additions, while rental income and limited profit estima...
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Contravention of the NRNR account regulations attracted penalty against both the authorised dealer and the account holders, because the scheme required the account to be opened only by a non-resident person from funds remitted from outside India, and Section 13(1) of FEMA applied to any person who contravened the Act or regulations. The later omission of Regulation 5(1)(iv) did not extinguish liabilities already incurred, since repeal by omission does not erase prior violations absent contrary intent, so the challenge to the show cause notices failed. Confiscation, however, was set aside because the adjudicating authority and tribunal gave no reasons for ordering it, despite the discretionary nature of Section 13(2) and the repayment of the loan through maturity proceeds.
Contravention of the NRNR account regulations attracted penalty against both the authorised dealer and the account holders, because the scheme required the account to be opened only by a non-resident person from funds remitted from outside India, and Section 13(1) of FEMA applied to any person who contravened the Act or regulations. The later omission of Regulation 5(1)(iv) did not extinguish liabilities already incurred, since repeal by omission does not erase prior violations absent contrary intent, so the challenge to the show cause notices failed. Confiscation, however, was set aside because the adjudicating authority and tribunal gave no reasons for ordering it, despite the discretionary nature of Section 13(2) and the repayment of the loan through maturity proceeds.
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