Penalty couldn’t be imposed on appellant as he took prudently all necessary actions to realize expor

FEMA : Where Adjudicating Officer imposed penalty upon appellant for contravention of provisions of section 18(2) and 18(3) of FERA on ground that appellant had failed to detect discrepancy in Letter of Credit accepted by L.C. Opening Bank which resulted in loss of right to claim export proceeds from said Bank, appellant was required to discharge onus and thereby rebut presumption under section 18(3) to show that appellant had taken all reasonable steps to receive or recover payment for goods ex