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    <title>2016 (11) TMI 1643 - SECURITIES APPELLATE TRIBUNAL, MUMBAI</title>
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    <description>Draft share purchase negotiations and related correspondence were treated as showing that a concrete board decision had been reached by 19 June 2009, so the information became unpublished price sensitive information from that date. The company was therefore required to keep the trading window closed and disclose the board decision within the prescribed time, and its failure to do so was treated as a regulatory breach. Insider trading allegations against directors, relatives and connected entities were upheld on the basis of surrounding circumstances, including linked dealings, trading immediately after UPSI arose, and the absence of a credible explanation for the source of information. Penalties were largely sustained, with limited reduction for disclosure-related delay and for one elderly appellant.</description>
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      <link>https://www.taxtmi.com/caselaws?id=283438</link>
      <description>Draft share purchase negotiations and related correspondence were treated as showing that a concrete board decision had been reached by 19 June 2009, so the information became unpublished price sensitive information from that date. The company was therefore required to keep the trading window closed and disclose the board decision within the prescribed time, and its failure to do so was treated as a regulatory breach. Insider trading allegations against directors, relatives and connected entities were upheld on the basis of surrounding circumstances, including linked dealings, trading immediately after UPSI arose, and the absence of a credible explanation for the source of information. Penalties were largely sustained, with limited reduction for disclosure-related delay and for one elderly appellant.</description>
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