Pre-amendment reassessment limitation bars late notices under the preserved regime, invalidating consequential reassessment for affected earlier asses...
Cash-sales explanations for bank deposits require documentary reconciliation; reassessment notice survived where effective response time was available...
Functional comparability in transfer pricing prevents ad hoc arm's length adjustments where functions, assets, risks and reliable comparables are unes...
Contingency expenses, exempt-income disallowance, and royalty benchmarking: unsupported adjustments were deleted under consistent accounting and trans...
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The circular provides the procedure for seeking waiver or reduction of interest levied on persons against whom recovery proceedings are initiated for failure to pay penalty under relevant securities laws. The key points are: SEBI has delegated power to waive/reduce interest to a panel of Executive Directors (for <Rs. 2 crore) or Whole-time Members. Waiver is not allowed for interest on fees payable to SEBI or disgorgement amounts. Application is to be made to the Recovery Officer along with supporting documents showing genuine hardship, circumstances beyond control, and cooperation in inquiries. The Competent Authority shall pass order within 12 months after giving opportunity of being heard.
The circular provides the procedure for seeking waiver or reduction of interest levied on persons against whom recovery proceedings are initiated for failure to pay penalty under relevant securities laws. The key points are: SEBI has delegated power to waive/reduce interest to a panel of Executive Directors (for <Rs. 2 crore) or Whole-time Members. Waiver is not allowed for interest on fees payable to SEBI or disgorgement amounts. Application is to be made to the Recovery Officer along with supporting documents showing genuine hardship, circumstances beyond control, and cooperation in inquiries. The Competent Authority shall pass order within 12 months after giving opportunity of being heard.
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