Pre-amendment reassessment limitation bars late notices under the preserved regime, invalidating consequential reassessment for affected earlier asses...
Cash-sales explanations for bank deposits require documentary reconciliation; reassessment notice survived where effective response time was available...
Functional comparability in transfer pricing prevents ad hoc arm's length adjustments where functions, assets, risks and reliable comparables are unes...
Reasoned adjudicatory orders imposing or affirming FEMA penalties must disclose the evidence and reasons supporting liability. Where the Tribunal accepted the company's explanation for seized Indian and foreign currency, it had to address any further evidence justifying penalties against the appellant; reasons could not be inferred merely from factual narration. The High Court set aside the Tribunal's order because it did not reveal the basis for affirming the penalties, and remanded the appeal for fresh, reasoned adjudication uninfluenced by earlier observations.
Reasoned adjudicatory orders imposing or affirming FEMA penalties must disclose the evidence and reasons supporting liability. Where the Tribunal accepted the company's explanation for seized Indian and foreign currency, it had to address any further evidence justifying penalties against the appellant; reasons could not be inferred merely from factual narration. The High Court set aside the Tribunal's order because it did not reveal the basis for affirming the penalties, and remanded the appeal for fresh, reasoned adjudication uninfluenced by earlier observations.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
