APPELLATE TRIBUNAL UNDER SAFEMA AT NEW DELHI MP-FE-303/CHN/2024 Impleadment FPA-FE-80/CHN/2019 M/s. Rithwik Projects Pvt. Ltd. … Appellant Versus The Special Director, Directorate of Enforcement, Chennai … Respondent Advocates/Authorized Representatives who appeared For the Appellant : Mr. P Murali Mohana Rao, Advocate For the Respondent : Mr. Girish Tripathi, Advocate CORAM SHRI BALESH KUMAR : MEMBER SHRI RAJESH MALHOTRA : MEMBER

FINAL ORDER

25.03.2026 This Order disposes of the Appeal No. FPA-FE-80/CHN/2019 filed by M/s Rithwik Projects Pvt. Ltd. (RPPL), against the Order No. SDE/SRO/HYZO/05/2019 dated 27.09.2019 (Impugned Order), passed by the Special Director, Enforcement Directorate, Government of India, Chennai. The Ld. Adjudicating Authority (AA) imposed the penalty of Rs. 1,20,00,000/- on M/s Rithwik Projects Pvt. Ltd. for the contravention of Section 6 (3) (b) of the Foreign Exchange Management Act, 1999 (FEMA) in terms of Paragraph 9 (1) (B) of Schedule 1 to the said Regulation 5 (1) of the Foreign Exchange Management (Transfer or Issue of Security by a Person Resident Outside India) Regulation 2000, to the extent of Rs.

119,99,85,541/-, vide the Impugned Order.

2. Ld. Coun