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    <title>2019 (9) TMI 1496 - SECURITIES APPELLATE TRIBUNAL, MUMBAI</title>
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    <description>Regulatory proceedings for delayed adoption of the model code of conduct could not be sustained because, although no limitation period was prescribed, the action was initiated only after more than 15 years and was therefore not taken within a reasonable time; the penalty on the company was set aside. A penalty for failure to close the trading window was also unsustainable because the breach was only technical, no trading took place, and no gain or investor loss was shown; the penalty on the compliance officer was set aside. The common adjudication order was quashed insofar as it concerned the appellants.</description>
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      <description>Regulatory proceedings for delayed adoption of the model code of conduct could not be sustained because, although no limitation period was prescribed, the action was initiated only after more than 15 years and was therefore not taken within a reasonable time; the penalty on the company was set aside. A penalty for failure to close the trading window was also unsustainable because the breach was only technical, no trading took place, and no gain or investor loss was shown; the penalty on the compliance officer was set aside. The common adjudication order was quashed insofar as it concerned the appellants.</description>
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