Transfer pricing comparables and adjustments: Tribunal revisits loss-maker status, segmental comparability, working capital relief, and risk allocatio...
Business expenditure disallowance failed where commission, related-party salary and promotion payments were supported by records and inquiry was inade...
FEMA applied to unrealised export proceeds where the extended repatriation period expired while FEMA was in force; earlier FERA proceedings did not bar action on different export bills, and mere local-currency deposit abroad was not sufficient evidence of taking all reasonable steps to realise the dues. The Tribunal therefore sustained the finding of contravention. For vicarious liability, it held that Section 42 does not depend only on formal designation: a partner or person who signed bank extension letters and participated in export realisation and firm management could be held personally liable where no preventive steps were shown. Penalty on both appellants was upheld.
FEMA applied to unrealised export proceeds where the extended repatriation period expired while FEMA was in force; earlier FERA proceedings did not bar action on different export bills, and mere local-currency deposit abroad was not sufficient evidence of taking all reasonable steps to realise the dues. The Tribunal therefore sustained the finding of contravention. For vicarious liability, it held that Section 42 does not depend only on formal designation: a partner or person who signed bank extension letters and participated in export realisation and firm management could be held personally liable where no preventive steps were shown. Penalty on both appellants was upheld.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4801
Join Channel
TaxTMI 
