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Challenge to Denial of Exemption: Subsidiary Creation Followed SEBI Directions, Contradicting Revenue's Claims on Membership Limits.

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....Denying exemption u/s 11 & 12 - It is quite evident that the floating of subsidiary company was in tune with SEBI directions and contradicts the stand of the revenue that the sub-broker membership of the subsidiary was open to select few and not to public at large and the benefit to select few was extended by the assessee.....