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...
AT upheld insider trading charges against appellants for violating PIT Regulations through trading in Biocon securities while possessing UPSI. Appellant 1 was deemed a 'connected person' under Regulation 2(1)(g)(i) due to close association with company KMPs during CIMAB licensing negotiations and Biocon-Sandoz deal period. Appellant 2 was classified as connected under Regulation 2(1)(d)(i). The tribunal applied preponderance of probability test, noting suspicious trading patterns during UPSI period and frequent communications with senior management. Despite circumstantial evidence, appellants' close involvement with KMPs handling sensitive cross-border deals established insider status. Penalties and market trading restrictions maintained.
AT upheld insider trading charges against appellants for violating PIT Regulations through trading in Biocon securities while possessing UPSI. Appellant 1 was deemed a 'connected person' under Regulation 2(1)(g)(i) due to close association with company KMPs during CIMAB licensing negotiations and Biocon-Sandoz deal period. Appellant 2 was classified as connected under Regulation 2(1)(d)(i). The tribunal applied preponderance of probability test, noting suspicious trading patterns during UPSI period and frequent communications with senior management. Despite circumstantial evidence, appellants' close involvement with KMPs handling sensitive cross-border deals established insider status. Penalties and market trading restrictions maintained.
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