Reasonable period for FEMA show-cause notices remains fact-specific; merits must be pursued through statutory remedies.

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....In review proceedings concerning FEMA and TISPRO allegations, the HC reiterated that, where no limitation period is prescribed, whether a show-cause notice was issued within a reasonable period is fact-specific and should be urged before the adjudicating authority, with statutory appellate remedies remaining available under FEMA. It refused to treat prior case law on reassessment or statutory delay as a universal bar to penal proceedings, and held that issues about RBI notification timing, the FDI policy, exit from the company, and the definition of "Group Company" were merits-based and partly fact-disputed. Finding no error apparent in the earlier writ order, the review applications were dismissed.....