Regulatory consolidation for investment advisers: SEBI issues master circular consolidating guidance and prescribing compliance, reporting, fees and s...
Reopening of assessment cannot rest solely on an audit party's opinion; reassessment under Section 147/148 is impermissible and power of revision shou...
Tested party selection: functional analysis identified the least complex unit as the appropriate tested party, altering the transfer pricing adjustmen...
Dominant issue: whether seized demat accounts, attached under Section 37A for alleged contravention of Section 4 of the Act of 1999, may be substituted by a fixed deposit (FD) of equivalent value to secure the claimed amount. Reasoning: seizure aimed to secure an equivalent sum; substitution by an FD equally secures the respondents' interest, is equitable, and permits the appellants to pursue compounding with the RBI; the FD remains subject to final adjudication and any compounding outcome. Outcome: seizure lifted on furnishing an FD of equivalent value, held with lien and subject to adjudication and RBI compounding results. - AT
Dominant issue: whether seized demat accounts, attached under Section 37A for alleged contravention of Section 4 of the Act of 1999, may be substituted by a fixed deposit (FD) of equivalent value to secure the claimed amount. Reasoning: seizure aimed to secure an equivalent sum; substitution by an FD equally secures the respondents' interest, is equitable, and permits the appellants to pursue compounding with the RBI; the FD remains subject to final adjudication and any compounding outcome. Outcome: seizure lifted on furnishing an FD of equivalent value, held with lien and subject to adjudication and RBI compounding results. - AT
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