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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The AT partially upheld penalties against a registered investment advisory firm for multiple regulatory violations under SEBI's IA Regulations. The Tribunal rejected appellant's procedural objections regarding delay in proceedings, double jeopardy claims, and alleged denial of natural justice. Of thirteen alleged violations, the AT affirmed nine, including failures in KYC procedures, risk profiling, suitability assessments, disclosure requirements, fee charging practices, and compliance obligations. The Tribunal found insufficient evidence for four allegations related to execution services, client complaints, solicitation through websites, and qualification requirements. Considering the repeated violations of multiple nature that could have seriously impacted market integrity and investor interests, the AT reduced the penalty from 1 crore to 70 lakhs.
The AT partially upheld penalties against a registered investment advisory firm for multiple regulatory violations under SEBI's IA Regulations. The Tribunal rejected appellant's procedural objections regarding delay in proceedings, double jeopardy claims, and alleged denial of natural justice. Of thirteen alleged violations, the AT affirmed nine, including failures in KYC procedures, risk profiling, suitability assessments, disclosure requirements, fee charging practices, and compliance obligations. The Tribunal found insufficient evidence for four allegations related to execution services, client complaints, solicitation through websites, and qualification requirements. Considering the repeated violations of multiple nature that could have seriously impacted market integrity and investor interests, the AT reduced the penalty from 1 crore to 70 lakhs.
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