Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings...
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AT partially upheld SEBI's order against a registered stockbroker for misuse of client funds and providing excess exposure beyond T+2+5 days. The broker misutilized funds ranging from Rs. 88,000 to Rs. 2.48 crores across 31 instances, using credit balance clients' funds for debit balance clients' obligations. The charge of non-issuance of contract notes was dismissed as untenable. Applying the doctrine of proportionality and considering precedent of Angel Broking Ltd., while noting the appellant's status as a repeat offender, AT reduced the penalty from original amount to Rs. 15 lakhs.
AT partially upheld SEBI's order against a registered stockbroker for misuse of client funds and providing excess exposure beyond T+2+5 days. The broker misutilized funds ranging from Rs. 88,000 to Rs. 2.48 crores across 31 instances, using credit balance clients' funds for debit balance clients' obligations. The charge of non-issuance of contract notes was dismissed as untenable. Applying the doctrine of proportionality and considering precedent of Angel Broking Ltd., while noting the appellant's status as a repeat offender, AT reduced the penalty from original amount to Rs. 15 lakhs.
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