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    Reassessment jurisdiction beyond three years fails without recorded reasons showing escapement; blanket two-zero cash additions were curtailed
    Contractor settlement expense deductible as business revenue; 14A disallowance and treaty-rate DDT claim remitted for fresh consideration
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      Delay in issuing the show cause notice did not defeat the FEMA...

      FEMA contravention and managing director liability sustained, but penalties reduced for proportionality.

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      FEMAMay 14, 2026Case LawsAT
      Delay in issuing the show cause notice did not defeat the FEMA contravention claim because the company had been alerted early and still failed to produce exchange control copies, bills of entry, or any other proof that goods were imported against the remittances. The Tribunal therefore sustained the finding of contravention of Section 10(6) read with Regulation 6(1), distinguishing authorities relied on by the appellants on their facts. It also upheld separate liability of the Managing Director under Section 42, since he was responsible for the company's business and showed no due diligence to prevent the breach. The penalties on both appellants were, however, reduced as excessive.

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      ActsIncome Tax