https://www.taxtmi.com/caselaws?id=763732 Where the revenue authority establishes a prima facie case from surrounding circumstances, the burden shifts to the appellants to explain the source of foreign funds and rebut the presumption of contravention under foreign exchange law. Here, the offshore entity's investment pattern, its negligible capital base, and the failure of the key person to appear or produce records were sufficient to call for an explanation. Because the appellants did not produce bank records or other best evidence within their control, an adverse inference was justified and the penalty for foreign exchange contravention was upheld. en-us Wed, 27 Nov 2024 00:00:00 +0530 Fri, 27 Dec 2024 09:00:35 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=763732 Where the revenue authority establishes a prima facie case from surrounding circumstances, the burden shifts to the appellants to explain the source of foreign funds and rebut the presumption of contravention under foreign exchange law. Here, the offshore entity's investment pattern, its negligible capital base, and the failure of the key person to appear or produce records were sufficient to call for an explanation. Because the appellants did not produce bank records or other best evidence within their control, an adverse inference was justified and the penalty for foreign exchange contravention was upheld. Case-Laws FEMA Wed, 27 Nov 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=763732