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 AT upheld SEBI's discretion to levy interest on outstanding registration fees as per Regulation 5 of Schedule-III of Stockbrokers Regulations, 2002, which mandatorily provides for charging 15% interest. The AT ruled that SEBI had no discretion in charging interest, which is compensatory in nature. It directed SEBI to credit interest at 15% p.a. for the brief period from September 6, 2003 to October 1, 2003 when the appellant had a credit balance, but dismissed other claims regarding interest calculation since the appellant had already received credit for interest from 2006 to 2019.
The AT upheld SEBI's discretion to levy interest on outstanding registration fees as per Regulation 5 of Schedule-III of Stockbrokers Regulations, 2002, which mandatorily provides for charging 15% interest. The AT ruled that SEBI had no discretion in charging interest, which is compensatory in nature. It directed SEBI to credit interest at 15% p.a. for the brief period from September 6, 2003 to October 1, 2003 when the appellant had a credit balance, but dismissed other claims regarding interest calculation since the appellant had already received credit for interest from 2006 to 2019.
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