An administrative circular issued by SEBI under Section 11(1) of the SEBI Act, 1992, can be subject matter of appeal under Section 15T of the said Act

Supreme Court in the case of National Securities Depository Ltd. v.
Securities and Exchange Board of India [Civil Appeal No.5173 of 2006], while
examining the question as to whether an administrative circular issued by SEBI
under Section 11(1) of the Securities Exchange Board of India Act, 1992, can be the
subject matter of appeal under Section 15T of the said Act, it was held that “it is
orders referable to Sections 11(4), 11(b), 11(d), 12(3) and 15-I of the Act, being
quasi-judicial orders, and quasi judicial orders made under the Rules and
Regulations that are the subject matter of appeal under Section 15T.” It was
observed that administrative orders such as circulars issued referable to Section
11(1) of the Act are outside the appellate jurisdiction of the Securities Appellate
Tribunal [On 7th March, 2017]