Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
The High Court held that the petitioner bank should avail the alternate remedy of appeal u/s 15-T of the SEBI Act against SEBI's order dated January 11, 2023, instead of challenging SEBI's private communications expressing opinion on a legal provision through a writ petition. The Court granted liberty to the petitioner to file an appeal before the Securities Appellate Tribunal (SAT) within four weeks, and directed the SAT to dispose of the appeal on merits without considering the limitation issue. All contentions of parties on merits were left open to be decided by the SAT.
The High Court held that the petitioner bank should avail the alternate remedy of appeal u/s 15-T of the SEBI Act against SEBI's order dated January 11, 2023, instead of challenging SEBI's private communications expressing opinion on a legal provision through a writ petition. The Court granted liberty to the petitioner to file an appeal before the Securities Appellate Tribunal (SAT) within four weeks, and directed the SAT to dispose of the appeal on merits without considering the limitation issue. All contentions of parties on merits were left open to be decided by the SAT.
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