Donor-directed corpus contributions retain capital character despite exemption claims under section 10(23C)(vi), preventing their treatment as taxable...
Enhanced tax-audit threshold applies where banking records establish compliant non-cash receipts and payments, eliminating penalty exposure for audit ...
Transfer pricing consistency protects identical non-interest-bearing debenture terms from a later notional-interest adjustment without valid statutory...
Rectification of debatable deduction claims cannot reverse scrutiny-approved co-operative society interest income deductions as apparent record errors...
Cash-method accounting bars presumptive interest taxation, while unsupported securities and share-trading additions require reliable material and veri...
The Appellate Tribunal upheld the finding that the appellant contravened Section 3(a) of FEMA in relation to unauthorised foreign exchange dealing, relying on corroborative statements, recovery of US $ 10,000 from the appellant's personal custody, and the absence of a credible explanation for possession of the currency. The plea based on educational background was rejected because the persons involved had prior money-changing experience and were expected to know the legal requirements. Liability for penalty was therefore sustained, but the Tribunal reduced the quantum of penalty in view of the facts and circumstances and directed adjustment of the pre-deposit against the reduced amount.
The Appellate Tribunal upheld the finding that the appellant contravened Section 3(a) of FEMA in relation to unauthorised foreign exchange dealing, relying on corroborative statements, recovery of US $ 10,000 from the appellant's personal custody, and the absence of a credible explanation for possession of the currency. The plea based on educational background was rejected because the persons involved had prior money-changing experience and were expected to know the legal requirements. Liability for penalty was therefore sustained, but the Tribunal reduced the quantum of penalty in view of the facts and circumstances and directed adjustment of the pre-deposit against the reduced amount.
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