BEFORE THE HON’BLE SECURITIES APPELLATE TRIBUNAL, MUMBAI MISCELLANEOUS APPLICATION NO. 176 OF 2024 IN APPEAL NO. 191 OF 2024 AMIT SECURITIES LIMITED .APPLICANT/APPELLANT vis BSE LIMITED «+sRESPONDENT Particulars a REPLY ON BEHALF OF THE RESPON : Circular dated January 22, 2020 bearing ref no.| | "| SEBY/HO/CFD/CMD/CIR/P/2020/12 1yn-2r : SE Limited Circular dated 26 September 2019 24 ~ 4, ANNEXURE C (Colly) : Emails dated 18 August 2020 and 04 November 2020 24 It 3., ANNEXURE D: ( Colly) : Emails dated 16 October 2020 and 02 November 2020 JIT Jae 28 - 32 - “6, ANNEXURE E : Email dated 14 December 2020 B3- 35 | 7.ANNEXURE F : Email dated 16 December 2020 z 6-27 | 38-34 Docket — 40BEFORE THE HON’BLE SECURITIES APPELLATE TRIBUNAL, MUMBAI MISCELLANEOUS APPLICATION NO. 176 OF 2024 IN APPEAL NO. 191 OF 2024 AMIT SECURITIES LIMITED .-APPLICANT/APPELLANT viS BSE LIMITED .;RESPONDENT AFFIDAVIT-IN-REPLY ON BEHALF OF THE RESPONDENT TO THE MISCELLANEOUS APPLICATION NO. 176 OF 2024 1, Gopalkrishnan Iyer, working as Vice President of BSE Ltd. (“BSE” / “Respondent” / “Exchange”), being the Respondent abovenamed, having its office at 25" Floor, Phiroze Jeejeebhoy Towers, Dalal Street, Fort, Mumbai - 400 001, do hereby solemnly affirm and state as under: 1, [have perused the present Appeal (“Appeal”) and the captioned Application filed by Amit Securities Limited (“Appellant’/ “Company”/ “Applicant”) vide which the Appellant has challenged the communication dated 02 January 2024 (“Impugned Communication”) (annexed as Exhibit-A to the Appeal) addressed by the Respondent to the Appellant informing the decision passed by the Request Review Committee (“Committee”) of the Respondent. Along with the Appeal, the Appellant has also filed Miscellaneous Application No. 176 of 2024 (“Application”) vide which the Appellant has inter alia sought the following interim reliefs: A, To hear the matter on urgent basis;Ds C. Direct the Respondent to Defreeze the Promoters and Promoters’ Group Holdings and Reinstate the Trading on BSE Ltd.; 2. [have perused the papers, records and files pertaining to the present matter and being duly authorized, I am filing this limited Affidavit-in-Reply (“Reply”) for opposing the grant of the interim reliefs sought by the Appellant vide the Application. I crave leave to file further Affidavit-in Reply on merits to the present Appeal, as and when directed by this Hon’ble Tribunal or if so required. 3. At the outset, I deny each and every statement, allegation, averment and contention raised in the Application and hereby state that nothing contained in the Application should be deemed to be admitted by virtue of it not having been specifically denied herein unless the same has been expressly admitted. I further submit that instead of dealing with the submissions raised in the Application in a paragraph-wise manner, I am dealing with the submissions issue-wise for ease of reference. 4. Before proceeding further and dealing with the contentions raised by the Appellant, I would first provide brief background of the matter and submit the following preliminary objections to the Application Brief background 5. The Respondent is a recognized stock exchange under the provisions of the Securities Contracts (Regulation) Act, 1956 (“SCRA”). The Exchange as well as the companies listed on the Exchange and the constituents/investors dealing in the said listed companies through member brokers are governed by the SCRA, Securities Contracts (Regulation) Rules, 1957 (“SCRR"), Securities and Exchange Board of India (Listing Obligations and Disclosure Requirements) Regulations, 2015 (“LODR Regulations”), the Rules, Bye- laws and Regulations of the Exchange and circulars/ notices issued by the Securities and Pa change Board of India (“SEBI”)/ the Exchange from time to time. The said Rules, 's and Regulations are made pursuant to the provisions of the SCRA. The said Bye-laws are duly approved by the Central Government and/or SEBI under the C3 SCRA and are statutory in nature as held by the Hon’ble Supreme Court in the case of The Stock Exchange versus V § Kandalgaonkar reported in 2015(2) SCC 1 and further the Regulations are made thereunder, In terms of Regulation 97(1) of the LODR Regulations, the recognized stock exchanges are entrusted with a duty to monitor compliance of listed entities with the provisions of the LODR Regulations. SEBI vide Circular bearing reference no. SEBI/HO/CFD/CMD/CIR/P/2018/77 dated 03 May 2018, inter alia, prescribed a Standard Operating Procedure (“SOP”) to be followed by the stock exchanges in cases of non-compliances with certain provisions of the LODR Regulations by listed entities (SOP Circular 2018"). Further, SEBI vide Circular bearing ref. no. SEBI/HO/CFD/CMD/CIR/P/2020/12 dated 22 January , 2020, inter alia, further streamlined the SOP to be followed by the stock exchanges for suspension and revocation of trading of specified securities of the listed entities for non-compliance of certain provisions of the LODR Regulations and initiate action(s) such as imposition of fines, freezing of demat accounts of the promoters, suspension of trading of securities etc., (‘SOP Circular 2020") (Annexed as Exhibit ~ F at pages 95 ~ 106 of the Appeal). A copy of the SOP Circular 2018 is annexed hereto as “Annexure - A“. The Appellant herein, is a public limited company, whose shares are listed with the Exchange and as such, is duty bound to comply with, inter alia, the LODR Regulations, SEBI the Exchange requirements, norms, guidelines, directions ete. Itis pertinent to note that, as part of the compliance with the LODR Regulations, a listed entity in terms of Regulation 33(3) of the LODR Regulations is required to submit quarterly and year to date standalone financial results to the stock exchange within forty- five (45) days of end of each quarter, other than the last quarter. Further, in case the listed entity has any subsidiary, the listed entity is required to submit quarterly/ year to date consolidated financial results. The Exchange vide its circular dated 26 September 2019, disseminated on its website, informed the market that it is mandatory for listed (es to file quarterly/ year to date consolidated financial results. Further, the noticestated that the listed companies are required to consolidate the financial statements of subsidiary and or its associate companies/ joint ventures, as the case may be, along with the standalone results of the listed company from the quarter ending 30 September 2019 onwards. A copy of the Exchange circular dated 26 September 2019 is annexed hereto as “Annexure ~ B” 9. Accordingly, under Regulation 33(3)(b) of the LODR Regulations, the Appellant was required to submit the standalone and consolidated financial results for the quarter ending September 2019 by 14 November 2019. Similarly, under Regulation 33(3)(b) of the LODR Regulations, for the quarter ending December 2019, the standalone and consolidated financial results were required to be submitted by 14 February 2020. However, the consolidated financial results were not submitted by the Appellant for quarters ending September 2019 and December 2019 within the due date. Therefore, the fines were levied on the Appellant in terms of the SOP Circular 2018 and the same was intimated to the Appellant by the Exchange vide email(s) enclosing letter(s) dated 02 December 2019 and 03 March 2020 respectively (Annexed as Exhibit — L at pages 269- 270 and Exhibit ~ M at pages 271-272 of the Appeal). Admittedly, the consolidated financial results for quarter ending September 2019 and December 2019 were filed with the Exchange only on 12 July 2021. 10. Subsequently, the Appellant also failed to comply with Regulation 33 of the LODR Regulations for quarter ending March 2020, Therefore, the Exchange in terms of the SOP Circular 2018, addressed an email dated 18 August 2020 intimating the fines levied on the Applicant. Thereafter, since the Appellant failed to comply with the provision and make payment of the fines, the Exchange addressed a reminder email dated 04 November 2020 to the Appellant as well as the promoters of the Appellant, inter alia, advising the Appellant to make payment of fines within ten (10) days from the date of the email, ling which, action(s) including freezing of the demat accounts of the promoters would 411. Since the Appellant failed to ensure compliance and make payment of fines, the Exchange, in terms of the SOP Circular 2020, issued necessary instructions in December 2020 to the depositories to freeze the demat accounts of the promoters of the Appellant. 12. Thereafter, the Appellant also failed to comply with Regulation 33 of the LODR Regulations for quarter ending June 2020. Accordingly, the Exchange in terms of the SOP Circular 2020, addressed an email dated 16 October 2020 intimating levy of fines on the Appellant. Since the Appellant failed to comply with the provision and make payment of the fines, the Exchange addressed a reminder email dated 02 November 2020 to the Applicant as well as the promoters of the Appellant, inter alia, advising the Appellant to make payment of fines within ten (10) days from the date of the email, failing which, action(s) including freezing of the demat accounts of the promoters would be initiated. A copy of the emails dated 16 October 2020 and 02 November 2020 are annexed hereto as ‘Annexure - D colly”. 13. In the meanwhile, the Appellant also failed to comply with Regulation 33 of the LODR Regulations for quarter ended September 2020 and accordingly, the Exchange in terms of the SOP Circular 2020, addressed an email dated 14 December 2020 intimating levy of fines on the Appellant. A copy of the email dated 14 December 2020 is annexed hereto as “Annexure - E”, 14, Since the non-compliance of Regulation 33 of the LODR Regulations continued for two consecutive quarters (March 2020 and June 2020), the trading of securities of the Appellant was suspended with effect from 18 January 2021 in terms of Annexure Il, Clause 1 and 2 of the SOP Circular 2020 which was also disseminated on the website of the Exchange vide Notice dated 16 December 2020 (“Suspension Notice”). Vide the Suspension Notice, the Exchange also directed continuation of freezing of the entire shareholding of the promoters w.e.f. 16 December 2020. A copy of the Suspension Notice dated 16 December 2020 is annexed herewith as “Annexure - F”. er, the Appellant filed waiver application(s) dated 24 July 2021 seeking waiver of for non-compliance with Regulation 33 for quarters ending September 2019,6 December 2019, March 2020, June 2020 and September 2020 amounting to Rs. 56,40,000/-. The same was placed for consideration of the Committee on 23 December 2021 wherein the Committee had decided to waive the fines levied for non-compliances with Regulation 33 for quarters ending March 2020, June 2020 and September 2020 on account of Covid-19 pandemic thereby granting a waiver of Rs. 21,12,200/-. 16. Pursuant to the intimation of partial waiver, the Appellant once again sought waiver of fines imposed for quarter ending September, 2019 and December, 2019 vide its written representation dated 01 June 2022 which was not waived by the Committee. . 17. The representations of the Appellant were placed before the Committee on 14 October 2022 wherein the Committee decided to grant partial waiver of fines levied for non- compliance with Regulation 33 of the LODR Regulations for quarters ending September 2019 and December 2019 considering that the Appellant had submitted its annual report to the Exchange on 30 November 2020 which consisted of the requisite consolidated financials of the Appellant. The same was intimated to the Appellant vide email dated 21 October, 2022. A copy of the email addressed to the Applicant by the Exchange dated 21 October, 2022 is annexed herewith as “Annexure - G”. 18. Thereafter, the Applicant vide email dated 29 October 2022 and letter dated 16 November 2022 requested BSE to reconsider the remaining penalty which was duly placed before the Committee in its meeting held on 10 March 2023 wherein the Committee decided to deliberate further on the application and advised the Applicant to file its written representation 19. The Applicant filed its written representation vide letter dated 18 March 2023 which was also placed before the Committee in its meeting held on 27 October 2023 wherein the Committee upheld its decision to grant partial waiver of fines levied for non-compliance with Regulation 33 of the LODR Regulations for quarters ending September 2019 and December 2019 considering that the Applicant had submitted its annual report to theFA Communication wherein the Company was directed to pay fine of Rs. 39,64,800/- including GST. Preliminary Objections 20. It is humbly submitted that interim reliefs cannot be granted to the Appellant for the following preliminary reasons: a. The Appellant has prayed for reinstatement of trading of securities of the Applicant by revocation of suspension of its trading and de-freezing of the demat account of its promoters. However, the Applicant has admittedly not even impugned the Suspension Notice vide which the Respondent suspended the trading in the securities of the Applicant and hence, no relief can be granted qua a Suspension Notice that has not even been challenged and has attained finality. b. It is pertinent to note that the entire shareholding of the promoters of the Applicant were frozen with effect from December 2020 and the trading of the securities of the Applicant was suspended with effect from 18 January 2021. It is also pertinent to note that the Applicant, by way of the present Application, is seeking interim relief against an action which was initiated almost three (3) years prior to the Appeal. Hence, the Application and the Appeal be dismissed on grounds of doctrine of laches. c. At this juncture, it is also pertinent to mention that the Applicant herein has not impugned the communications dated 02 December 2019 and 03 March 2020 vide which the fines were intimated to the Applicant. The Respondent has duly considered the waiver request of the Appellant and has granted substantial waiver to the Appellant in terms of the fines. d. It is submitted that the reliefs sought in Prayer C regarding de-freezing of demat accounts and revocation of suspension of trading are de hors of the Impugned munication. Even assuming without admitting the grant of waiver of fines as goght in the Appeal, in terms of the SOP Circular 2020, the Applicant is required to ffolgw the norms for revocation of suspension of trading of securities of theg Appellant in order to seek de-freezing of the demat accounts of the promoters of the Appellant, €. It is humbly submitted that the Appellant is making an attempt to seek the relief of reinstatement of trading (by way of revocation of suspension of its trading) and de- freezing of the demat account of its promoters vide the present Application under the garb of the challenge to Impugned Communication without even impugning the Suspension Notice only to avoid explaining the inordinate delay of approximately 1200 days in challenging of the same and without complying with requisite compliance. f, Further, the relief regarding de-freezing of demat accounts and revocation of suspension of trading is premature considering that the Appellant is contesting imposition of fines levied for non-compliance with disclosure requirements vide the present Appeal. g. The Appellant has repeatedly not complied with disclosure requirements of the LODR Regulations as observed above and hence, is not entitled to any interim relief. In view of the aforesaid, it is humbly submitted that no interim relief can be granted to be Appellant. Submission on Merits 21. Without prejudice to the preliminary objections, it is humbly submitted that even on the ‘merits of the case, the Appellant has failed to provide any cogent reasons that warrant the ‘grant of any interim relief in the facts and circumstances for the following reasons: Lack of Prima Facie Case a. The Applicant has failed to make any prima facie case for grant of stay on the operation and implementation of the Impugned Communication, In terms of the Exchange circular dated 26 September 2019, the Applicant was required to submit tHe\consolidated financial results from quarter ending 30 September 2019 onwards it had nine (9) associate companies. The Appellant in Exhibit-I (at pg. 244 of4 the Appeal) bas admitted that the consolidated financial results for the quarter ending September 2019 and December 2019 were filed by it belatedly on 12 July 2021. Thus, there is an admitted delay on the part of the Appellant in submitting the consolidated financial results in violation of Regulation 33 of the LODR Regulations. However, the Committee, considering the representation of the Appellant waived the fines levied after 30 November 2020 since the Appellant had filed its annual report consisting of the requisite financials, b. The Appellant also incorrectly sought to argue that it had not received any intimation of the non-compliance in terms of the SOP Circular 2018. It is humbly submitted that the intimation(s) with respect to the non-compliances were duly sent to the Appellant vide email(s) dated 02 December 2019 and 03 March 2020 addressed to — amitltd@yahoo.com which is the email ID through which the Applicant has corresponded with the Exchange including the communications pertaining to the waiver of fines levied on the Applicant. 22. Thus, it is humbly submitted that the Appellant has failed to make out a prima facie case ‘on merits, and hence, no interim relief can be granted in such circumstances. Balance of convenience is not in favor of the Appellant, and no irreparable harm is being done to the Appellant 23. The freeze on the demat accounts of the promoters of the Appellant and the suspension in the trading of the securities of the Appellant has been in force since December 2020 and 18 January 2021 respectively. It is humbly submitted that the de-freezing the demat accounts of the promoters of the Appellant and revoking suspension in spite of the failure on the part of the Appellant in making a prima facie case will clearly cause prejudice and harm the interest of the investors at large since the same will not only set as a wrong precedent but such non-compliant listed entities will blatantly flout the applicable lawslo 24. Lastly, it is humbly submitted that the Appellant has failed to demonstrate how the continuation of the suspension and freezing of the demat account of its promoters is causing it irreparable harm, The non-compliance in the present matter dates back to September 2019 / December 2019 and the suspension of the trading of securities of the Applicant has been in force from 18 January 2021. It is pertinent to note that a delay of approximately 1200 days prima facie defeats the contention of the Applicant with respect to irreparable harm and injury being caused to the Appellant. 25. In view of the aforesaid, it is humbly submitted that the Impugned Communication does not suffer from any error and the Appellant has failed to make out any case for grant of interim reliefs and deserves to be rejected. Solemnly declgred at Mumbai ) (Cae Dated this day of April, 2024) BEFORE ME Identified by Me Mis ¥ Low Point io ‘pai 2 400 001- REGISTERED a Apa APR 202 ——VERIFICATION 1, Gopalkrishnan Iyer, working as Vice President of BSE Ltd. (“BSE” / “Respondent” / “Exchange’), being the Respondent abovenamed, having its office at 25% Floor, Phiroze Jeejeebhoy Towers, Dalal Street, Fort, Mumbai — 400 001, do hereby declare and verify that the facts mentioned in paragraphs hereinabove are true to the best of my knowledge, on the basis of the record made available to me, and are as per legal advice, and no ‘material fact has been suppressed in the instant A ffidavit-in-Reply. Solemnly affirmed at Mumbai ) This_gf\ day of April, 2024 lay of April ) Cobo Identified by Me RESPONDENT ME For M/s. The Law Point BEFORE Advocates for the Respondent e M. PABALE LLM. «(CV OF INDIA) 7 Chambers, 34, ambers, Ade siadas Masser RO3d, Pe umal~ 400 091. RE atANNEXURE - A Cig] mae afta ate fae ate Securities and Exchange Board of India CIRCULAR SEBI/HO/CFD/CMDICIRIP/2018/77 May 3, 2018 To, All the Recognized Stock Exchang All Depositories Dear Sir/Madam, Sub: Non-compliance with certain provisions of the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015 and the Standard Operating Procedure for suspension and revocation of trading of specified securities. 1. In exercise of powers under Section 11A(2) of the SEBI Act, 1992 read with Section 9 and 21 of the Securities Contracts (Regulation) Act, 1956 and read with regulation 98 of the the Securities and Exchange Board of India (Listing Obligations and Disclosure Requirements) Regulations, 2015 (‘Listing Regulations"), SEBI had issued a Circular bearing reference number CIR/CFD/CMD/12/2015 dated November 30, 2015, specifying the uniform structure for imposing fines as a first resort for non-compliance with certain provisions of the Listing Regulations and the standard operating procedure for suspension of trading in case the non-compliance is continuing andior repetitive. 2. Thereafter, SEBI had issued another Circular bearing reference number SEBI/HO/CFDICIRIP/2016/116 dated October 26, 2016 advising the manner of freezing of holdings of the promoter and promoter group of a listed entity that failed to pay fines levied by the stock exchange(s).. 3. On the basis of the experience gained and to streamline the process, to maintain consistency and to adopt a uniform approach in the matter of levy of fines for non-compliance with certain provisions of the Listing Regulations, the manner of suspension of trading of securities of a listed entity and the manner of freezing the holdings of the promoter and promoter group of a non-compliant listed entity, it has been decided to issue the present Circular, in supersession of the said Circulars bearing reference numbers CIR/ICFD/CMD/12/2015 dated November 30, 2015 and SEBI/HO/CFDICIRIP/2016/116 dated October 26, 2016. Page | of I 2Cag] Teche sferyfe atk fete aé Securities and Exchange Board of India 4, Henceforth, the stock exchanges shall, having regard to the interests of investors and the securities market: a) take action in case of non-compliances with the Listing Regulations as specified in Annexure | of this Circular, and. b) follow the Standard Operating Procedure ("SOP") for suspension and revocation of suspension of trading of specified securities as specified in Annexure Il of this Circular. Stock Exchanges may deviate from the above, if found necessary, only after recording reasons in writing. 5. In order to ensure effective enforcement of the Listing Regulations, the depositories, on receipt of intimation from the concemed recognized stock exchange, shall freeze or unfreeze, as the case may be, the entire shareholding of the promoter and promoter group in such non-compliant listed entity as well as all other securities held in the demat account of the promoter and promoter group. Further, if a non-compliant entity is listed on more than one recognized stock exchange, the concemed recognized stock exchanges shall take uniform action under this Circular in consultation with each other. 6. The recognized stock exchanges shall take necessary steps to implement this circular. The recognized stock exchanges shall disclose on their website the action(s) taken against the listed entities for non-compliance(s); including the details of the respective requirement, amount of fine levied, the period of suspension, details regarding the freezing of shares, etc. 7. The recognized stock exchanges may keep in abeyance the action or withdraw the action in specific cases where specific exemption from compliance with the requirements under the Listing Regulations/moratorium on enforcement proceedings has been provided for under any Act, Court/Tribunal Orders etc. 8. The above provisions are without prejudice to the power of SEBI to take action under the securities laws. 9. The recognized stock exchanges are advised to bring the provisions of this Circular to the notice of listed entities and the listed entities shall in tum bring the same to the notice oftheir promoter/promoter group. —_ Vs DX > S \* Me \ / \ 2, page 20f NGS) AS) \3anda sfrayfa six fata os Securities and Exchange Board of India 10. This Circular shall come into force with effect from compliance periods ending on or after September 30, 2018. 14. This circular is available on SEBI website at www.sebi.gov.in under the category “Legal”. Yours faithfully, TWPS Chakravarti T Deputy General Manager Compliance and Monitoring Division Corporation Finance Departm Page 3 of I IqBi ANNEXURE aretrr pty ste faBrrr at Securities and Exchange Board of India ACTION TO BE TAKEN IN CASE OF NON-COMPLIANCES 1. The recognized stock exchanges shall take action for non-compliance with the provisions of the Listing Regulations by a listed entity as under: Si. No. Regulation Fine payable and/or oth action to be taken for non- compliance in respect of listed entity Regulation 6(1) Non-compliance with requirement to appoint a qualified company secretary as the compliance officer 1,000 per day Regulation 7(1) Non-compliance with requirement to appoint share transfer agent | 1,000 per day Regulation 13(1)/ 13(3) Failure to ensure that adequate | steps are taken for expeditious redressal of investor complaints Non-submission of the statement on shareholder complaints within the period prescribed under this regulation or under any circular issued in respect of redressal of investor grievances % 4,000 per day Regulation 17(1) Non-compliance with the requirements pertaining to the composition of the Board including failure to appoint woman director 5,000 per day Regulation 18(1) Non-compliance with constitution of audit committee the % 2,000 per day Page 4 of IBi anda sftatr sik ma até Securities and Exchange Board of India 6. | Regulation 19(1)/ 19(2) '% 2,000 per day Non-compliance with the constitution of nomination and remuneration committee 7. | Regulation 20(2) % 2,000 per day | Non-compliance with the. constitution of stakeholder relationship committee 8. | Regulation 21(2) | % 2,000 per day Non-compliance with —_—the constitution of risk management committee 9. | Regulation 27(2) % 2,000 per day _ Non-submission of the Corporate governance compliance report within the period provided under this regulation 10. | Regulation 29(2)/29(3) 1% 10,000 per instance of non- compliance per item Delay in fumishing prior intimation about the meeting of the board of directors 11. | Regulation 31 % 2,000 per day Non-submission of shareholding pattem within the period prescribed 12. | Regulation 32(1) © 1,000 per day | Non-submission of deviations! variations in utilization of issue proceeds 13. | Regulation 33 % 5,000 per day Non-submission of the financial results within the period prescribed under this regulation Page 5 of II IGCap] wate sf ate fer ate Securities and Exchange Board of India 14, | Regulation 34 % 2,000 per day Non-submission of the Annual Report within the period prescribed | under this regulation | 15. | Regulation 39(3) "1,000 per day Non-submission of _ information regarding loss of share certificates and issue of the —dupli certificates within the period prescribed under this regulation 16. | Regulation 42(2)/42(3)/ | € 10,000 per instance of non- 42(4)/42(5) compliance per item Delay in/ non-disclosure of record date/ dividend declaration or non- compliance with ensuring the prescribed time gap between two record dates/ book closure dates | 17. | Regulation 44(3) % 10,000 per instance of non- compliance Non-submission of the voting results within the period provided under this regulation 18. | Regulation 46 ‘Advisoryiwaming letter per instance of non-compliance Non-compliance with _norms | per item pertaining to functional website % 10,000 per instance for every additional advisory/warning letter exceeding the four | advisory/ warning letters in a financial year Concerned recognized stock exchange(s) shall display on their website non-compliance by the listed entity and details of fine levied/ action taken. . The amount of fine realized as per the above structure shall be credited to the "Investor Protection Fund” of the concemed recognized stock exchange. |. The fines specified above shall continue to accrue till the time of rectification of the non-compliance to the satisfaction of the concerned recognized stock Page 6 of I Cexchange or til the scrip of the listed entity is suspended from trading for non-compliance with aforesaid provisions. Such accrual shall be irrespective of any other disciplinary/enforcement action(s) initiated by recognized stock exchange(s)/SEBI. Every recognized stock exchange shall review the compliance status of the listed entities within 15 days from the date of receipt of information and shall issue notices to the non-compliant listed entities to ensure compliance and collect fine as per this circular within 15 days from the date of such notice. While issuing the said notice, the recognized stock exchange shall also send intimation of notice to other recognized stock exchange(s) where the shares of the non-compliant entity are listed. . If the non-compliant listed entity fails to comply with the aforesaid requirement(s) and/or pay fine levied within the stipulated period as per the notice stated above, the concerned recognized stock exchange(s) shall, upon expiry of the period indicated in the notice, forthwith intimate the depositories to freeze the entire shareholding of the promoter and promoter group in such entity as well as all other securities held in the demat account of the promoter and promoter group. . If the non-compliant listed entity subsequently complies with the respective requirement(s) and pays the fine levied, in terms of this Circular, the concemed recognized stock exchange(s) shall display on their website compliance and status of fines paid by the listed entity. Simultaneously, the recognized stock exchange(s) shall intimate the depositories to unfreeze the entire shareholding of the promoter and promoter group in such entity as well as all other securities held in the demat account of the promoter and promoter group, after one month from the date of compliance. . If any non-compliant listed entity fails to pay the fine despite receipt of the notice as stated above, the recognized stock exchange(s) may also initiate appropriate enforcement action. The recognised stock exchange(s) shall also advise the non-compliant listed entity to ensure that the subject matter of non-compliance which has been identified and indicated by the recognised stock exchange(s) and any ‘subsequent action taken by the recognised stock exchange(s) in this regard shall be placed before the Board of Directors of the company in its next meeting. Comments made by the board shall be duly informed to the recognised stock exchange(s) for dissemination. Page 7 of 113. Cg] eta staat ate Pa até Securities and Exchange Board of India ANNEXURE II STANDARD OPERATING PROCEDURE (SOP) . If a listed entity is non-compliant with the provisions of the Listing Regulations as specified under paragraph 2 below, the concerned recognized stock exchange(s) shall: (a) move the scrip of the listed entity to "Z" category wherein trades shall take place on ‘Trade for Trade’ basis by following procedure prescribed at paragraph A below and (b) suspend trading in the shares of such listed entity by following procedure prescribed at paragraph B below. Criteria for suspension of the trading in the shares of the listed entities: (a) Failure to comply with regulation 17(1) with respect to board composition including appointment of woman director for two consecutive quarters; (b) Failure to comply with regulation 18(1) with respect to constitution of audit committee for two consecutive quarters; (©) failure to comply with regulation 27(2) with respect to submission of corporate governance compliance report for two consecutive quarters; (d) failure to comply with regulation 31 with respect to submission of shareholding pattern for two consecutive quarters; (e) failure to comply with regulation 33 with respect to submission of financial results for two consecutive quarters; (f) failure to comply with regulation 34 with respect to submission of Annual Report for two consecutive financial years; (g) failure to submit information on the reconciliation of shares and capital audit report, for two consecutive quarters; {h) receipt of the notice of suspension of trading of that entity by any other recognized stock exchange on any or all of the above grounds. If the non-compliant listed entity complies with the aforesaid requirement(s) after the date of suspension and pays the applicable fine, the recognized stock exchange(s) shall revoke the suspension of trading of its shares by following the procedure prescribed at paragraph C below. If the non-compliant listed entity falls to comply with the aforesaid requirement(s) or fails to pay the applicable fine within 6 months from the date of suspension, the recognized stock exchange(s) shall initiate the Page 8 of 1 1920 Cg] ate tafe ste fer ate Securities and Exchange Board of India accordance with the provisions of the Securities Contracts (Regulation) Act, 1956, the Securities Contracts (Regulation) Rules, 1957 and the Securities and Exchange Board of India (Delisting of Equity Shares) Regulations, 2009 as amended from time to time. A. Standard operating procedure for moving the scrip to "Z" Category i. _ Ifa listed entity commits default in complying with the provisions of the Listing Regulations as specified under paragraph 2 above, the concemed recognised stock exchange(s) shall, in addition to imposing fine under paragraph 1 in Annexure | of this Circular, move the scrip of the listed entity to "2" category wherein trades shall take place on Trade for Trade' basis. li, The recognized stock exchange(s) shall give 7 days prior public notice to investors before moving the scrip to "Z" category or while moving the scrip out of "2" category. While issuing the notice, the recognized stock exchange(s) shall intimate the other recognized stock exchange(s) where the shares of the non-compliant entity are listed. ili, ‘The recognised stock exchange(s) shall move back the scrip of the listed entity from "2" category to the normal trading category (if not suspended as specified in paragraph B below), provided it complies with respective provisions of the Listing Regulations and pays the fine imposed as stated above. While moving the scrip back to normal trading category the recognized stock exchange(s) shall intimate the other recognized stock exchange(s) where the shares of the non-compliant entity are listed. B. Standard operating procedure for suspending the trading i. Before suspending the trading of a scrip, the concerned recognized stock exchange(s) shall send written intimation to the non-compliant listed entity calling upon it to comply with respective requirement(s) and pay the applicable fine within 21 days of the date of the intimation. While issuing the said intimation, the recognized stock exchange(s) shall also inform other recognized stock exchange(s) where the shares of the non- compliant entity are listed to ensure that the date of suspension is uniform across all the recognised stock exchange(s). Simultaneously, the recognized stock exchange(s) shall give website proposing possible suspension of t non-compliant listed entity.vi Capi wet stg ste fate ats Securities and Exchange Board of India If the non-compliant listed entity complies with respective requirement(s) and pays fine two working days before the proposed date of suspension, the trading in its shares shall not be suspended and the concemed recognized stock exchange(s) shall give a public notice on its website informing compliance by the listed entity. While issuing the said notice, the recognized stock exchange(s) shall send intimation of notice to other recognized stock exchange(s) where the shares of the entity are listed. Simultaneously, the recognized stock exchange(s) shall intimate the depositories to unfreeze the entire shareholding of the promoter and promoter group in such entity as well as all other securities held in the demat account of the promoter and promoter group, after one month from the date of compliance. In case of failure to comply with respective requirement(s) and/or pay fine within stipulated period, the recognized stock exchange(s) shall suspend the trading in the shares of a non-compliant listed entity. The entire shareholding of the promoter and promoter group in the non- compliant listed entity as well as all other securities held in the demat account(s) of the promoter and promoter group shall remain frozen during the period of suspension. While suspending trading in the shares of the non-compliant entity, the recognized stock exchange(s) shall send intimation of suspension to other recognized stock exchange(s) where the shares of the non- compliant entity are listed to ensure that the date of suspension is uniform across all the recognised stock exchange(s). After 15 days of suspension, trading in the shares of non-compliant entity may be allowed on ‘Trade for Trade’ basis, on the first trading day of every week for 6 months. In this regard, the recognized stock exchange(s) shall give instruction to its trading members to obtain confirmation from clients before accepting an order for purchase of shares of the non-compliant listed entity on ‘Trade for Trade' basis. The recognized stock exchange(s) shall put in place a system to publish a caution message on its trading terminals, as follows: "Trading in shares of the is presently under ‘suspension and trade to trade basis' and trading shall stop completely and compulsory delisting may be initiated if does not become compliant by *. Page 10 of 11 Q\Cp] acta sg atc fer ate Securities and Exchange Board of India C. Standard operating procedure for revocation of suspension of trading. If the non-compliant listed entity complies with the aforesaid requirement(s) and pays the applicable fine after trading is suspended in the shares of the non-compliant entity, the recognized stock ‘exchange(s) shall, on the date of compliance, give a public notice on its website informing compliance by the listed entity. The recognized stock exchange(s) shall revoke the suspension of trading of its shares after a period of 7 days from the date of such notice. While issuing the said notice, the recognized stock exchange(s) shall send intimation of notice to other recognized stock exchange(s) where the shares of the entity are listed. After revocation of suspension, the trading of shares shall be permitted only in ‘Trade for Trade’ basis for a period of 7 days from the date of revocation and thereafter, trading in the shares of the entity shall be shifted back to the normal trading category. The recognized stock exchange(s) shall intimate the depositories to unfreeze the entire shareholding of the promoter and promoter group in such entity as well as all other securities held in the demat account of the promoter and promoter group, after three months from the date of revocation of the suspension. Page 11 of 1 Ri4116124, 12:55 PM BSEINDIA Annexure - B 3 BSE” The Power of Viti 72,812.66 S&Pe Ee $87.12-0.80% SENSEX 16 Apr 24112:54 | Open Get Quote Enter Security Name / Code / 1D / ISIN "| Home » Corporates > Got Listed > Circulars to Listed Companies Circulars to Companies Go Back List/coMe,/30/2019.20 September 26,2019 Dear Sir/Madam, Subject: Submission of Consolidated Financial Results ‘This has reference to Regulation 33 of SEBI (Listing Obligation and Disclosures Requirements) Regulation, 2015 and the Informal Guidance issued by SEBI on August 02, 2019 in the matter of Shriram Transport Finance Company Limited AAs stated in the aforementioned SEB! Informal Guidance, it is mandatory for listed companies to file quarterly / year to date consolidated financial results. For this purpose, Companies are required to consolidate the financial statements of Subsidiary and or its Associate companies / Joint ventures as the case may be, with the Standalone results of the listed company. The Consolidated Financial Results as mentioned above shall be submitted to the Exchange from the quarter ending September 30, 2019 onwards, Listed Companies are required to take note of the same and comply accordingly. Abhijit Pai ‘Shyam Bhagirath Deputy General Manager Associate Manager Listing Compliance Listing Compliance hitps:uwn.bseinda.comicorporates/Displaydata.aspx7Id=9F539D63-D09%-4CC4-B32A.0CIE2637BEOFAPagescit 12.AnnexuRE-C (coll) Prathyusha Dinavahi Manish Raval 18 August 2020 23:21 amitltd@yahoo.com bsesoplodr Non-Submission of financial results for March 2020. Tracking: Recipient Delivery mitts @yahoo.com bsesopledr ‘akesh parekn@bseinia.com Delivered: 18-08-2020 2321 Suicomp.Piyrta@bseindiacom Delivered: 18.08-2020 23:21 Chandan Thaktar@bsengia.com Delivered: 18-08-2020 2821 samiajsolat@bseingiacom Delivered: 18-08-2020 2821 Ssicomp Kran@bseincacom Delivered: 18-08-2020 23:21 Kushboo Agaral@bseingiacom Delivered: 18-06-2020 23:21 Harshad Naik@bseindacom Delvred: 18-08-2020 2321 Manish Raval@bseindia.com Delivered 18-08-2020 2322 Shweta Neryaran@bsendiacom Delivered: 18-08-2020 23:21 apitajoshi@bseinacom Delivered: 18-06-2020 23:21 Harsha Babade@bsencia.com Delivered: 18-08-2020 23:21 TanwiPatwardhan@bsendiacom Delivered: 18-08-2020 25:21 syam Bhagiath@bsengia com Delivered: 18-06-2020 25:21 Mangalam yer@bseinciacom Delivered: 18-08-2020 2321 neva sahani@bseindiacom Delivered: 18-08-2020 25:21 abhi. pai@bseindia.com Delivered 18-08-2020 2521 Priyanka Chavrasia@bseingia.com Delivered: 18-08-2020 25:21 ‘Ashitsoisar@bseiniacom Delvred: 18-08-2020 2521 To ‘The Company Secretary/Compliance Officer Company Name: Amit Securities Ltd Scrip Code: 531557 Dear Sir/Madam, Sub: Non-Submission of financi: results for the Quarter ended March 2020 Pursuant to Regulation 33 of the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015 where the companies are required to furnish Quarterly Financial Result within 45 days of the end of that quarter to the Exchange & for the last quarter, the company has to submit, within 60 days from the end of the financial year, the Audited Financial Results for entire financial year along with the audited financial results in respect of the last quarter (balancing figure) along with Auditors Report. SEBI vide circular no. SEBI/HO/CFD/CMD1/CIR/P/2020/106 dated June 24, 2020, further extended the timeline for submission of financial results under Regulation 33 of the LODR Regulations to July 31, 2020, for the quarter and the year ending March 31, 2020, Further, as per clause (b) of sub-regulation 3 of Regulation 33 of SEBI (Listing Obligations and Disclosure Requirements) (Amendment) Regulations, 2018 effective from April 1, 2019 the companies are also required to submit quarterly/year-to date consolidated financial results, We have observed from our records that, so far the Company has not submitted the financial results for the quarter/year ended March 2020. (Auditors Report not submitted for consolidated financial results) ‘The company is advised to refer to Circular no. SEBI/HO/CFD/CMD/CIR/P/2018/77 dated May 3, 2018 issued by Securities and Exchange Board of India (SEBI) with respect to non-compliance of certain provisions of the SEBI (Listing Obligations and Disclosure Requirements) Regulations 2015 and Standard Operating Procedure for suspension and revocation of trading of specified securities of listed entities. ‘The company is liable to pay fine amount as mentioned below as on August 18, 2020. As per the provisions of the circular the fines will continue to be computed further till the time of rectification of the non-compliance to the satisfaction of the Exchange or till the scrip of the listed entity is suspended from trading for compliance with aforesaid provisions: CY‘Applicable Regulation of SEBT Fine details as per | Fine payable by the company (LODR) Regulations, 2015 circular (inclusive of GST @ 18 %) as on 9S August 18, 2020 (In Rs.) Regulation 33 Rs, 5000 per day tilthe | Basic Fine | GST @ 18 % | Total Fine Non-submission of the financial date of compliance. payable results within the period prescribed under this regulation 0000 a ‘The Company is therefore advised to note that as per the provisions of this circula ‘+The aforesaid fines including GST along with the financial results (as per Regulation 33) for the said Quarter/year must be submitted within 15 days from the date of this leter, falling which Exchange shall forthwith intimate the depositories to freeze the entire shareholding of the promoter and promoter group in this entity as well as all other securities held in the demat account of the promoter and promoter group. + Further in the event of this being the second consecutive quarter of non-compliance for this Regulation, non- payment of fines including GST and non-submission of financial results, within 15 days of this letter, would result in the company being transferred to Z group and liable for suspension of trading of its equity shares. ‘* The company is also advised to ensure that the subject matter of non-compliance which has been identified and indicated by the Exchange and any subsequent action taken by the Exchange in this regard shall be placed before the Board of Directors of the company in its next meeting. Comments made by the board shall be duly informed to the Exchange for dissemination. ‘A signed scanned copy of the financial results along with the covering letter can be uploaded on the following link of Listing Centre: http://listing.bseindia.com (For assistance in login and uploading on listing centre the company can contact helpdesk on Tel. No. 022-61363155 or email id: listing.centre@bseindla.com). The format of financial results can be downloaded from the website: http://mww.bseindia. com/static/about/downloads.aspx?expandable=2 Please also refer to BSE circular no, DCS/COMP/28/2016-17 dated March 30, 2017 related to filing of financial results in XBRL mode. In case of any further clarification in this matter please email at bse.sop! Yours faithfully ‘Sambhaji Solat Manish Raval Manager Deputy Manager Listing Compliance Listing Compliance Company is requested to remit the fine amount through electronic transfer to the designated bank - detall-given below: ‘Company Name:- Amit Securities Ltd Bank Name Branch Name ‘Recount No. TFSC Code ICICI Bank LUmited (EMS Branch BSERO7E34 TCICD000104| or through cheque favoring BSE Ltd, The company is required to submit the cheque alongwith the covering letter (format given at Annexure I below): ‘Annexut \n letterhead of the company) Listing Compliance, BSE Limited, Ground Floor, P. J. Towers, Fort, Mumbai-400001. Sub: Details of Payment of fines for Non-Compliance with Regulations of SEBI (LODR) Regulations, 2015. Regulation & | Amount ] TOS deducted, | Net Amount paid Code | Quarter paid if any Cheque/DD No. Date UTR No. for RTGS /NEFT_ ‘Compliance Officer / Company Secretary. ‘+ Please mention the Regulation No., Quarter, and amount of TDS deducted on the reverse side of the Cheque/Demand Draft. = In case of payment through RTGS/NEFT, you are requested to send a soft copy of this annexure to bse,soplodr@bseindia.com ‘This mallis classified as by Manish Raval on August 18, 2020 at 23:21:1126 From: Manish Raval Sent: 20 April 2024 15:05 To: Reena Raphel Subject: Fw: Reminder for freezing of promoter demat account for Regulation 33 for March 2020 From: Chandani Thakkar Sent: 04 November 2020 15:57 To: amitit¢@ yahoo.com ; amititd@yahoo.com ; amititd@ yahoo.com Cc: bse.soplodr Subject: Reminder for freezing of promoter demat account for Regulation 33 for March 2020 To; Company Secretary & compliance officer/ Promoter & Promoter group of the company Company Name: Amit Securities Ltd Scrip Code: 531557 Dear Sir/Madam, ‘Sub: Reminder for freezing of promoter demat account for Non-compliance/non-payment of fines for Regulation 33 for March 2020 SEBI vide its circular no, SEBI/HO/CFD/CMD/CIR/P/2018/77 dated May 3, 2018 (SEBI SOP Circular) has inter alia prescribed certain penal actions such as levy of financial fines, freezing of promoter demat accounts, transfer to Zeroup (Trade for Trade) ending with suspension of trading in the securities of the listed entities which do not comply with critical Regulations of SEB! (LODR) Regulations, 2015. It is observed that as per the latest shareholding pattern report submitted by the company, Amit Securiti (scrip code: 531557), your name has been included in the list of promoters /oromoter group of the compan\ s Ltd ‘The company is non-compliant with the provisions of following Regulation for the quarter ended March 2020. As mandated in the SEB! SOP circular the company has been intimated about the pending compliance and has also been informed that all the promoter/promoter group demat accounts would be frozen if the compliance was not completed and fines not paid. The details of fines outstanding, inter alia, for Regulation 33 of SEBI (LODR) Regulations, 2015 for March 2020, pursuant to SEB! SOP Circular dated May 03, 2018 are as under: Regulation Fine Levied Fine Paid Fine Outstanding (incl. GST @ 18 %) (incl. GST @ 18 %) (incl. GST @ 18 %) (Amount in Rs.) (Amount in Rs.) as on November 4, 2020 (Amount in Rs.) Reg. 33 - Financial Results 554600 0 554600 ‘Note: In case of Non-Compliance the fines will continued to be levied till the date of submission. As per Exchange records, it is observed that the company has not yet com) aid the fines. Therefore, as in duty bound in terms of the provisions of SEB! SOP circular the Exchange would be proceeding to give instructions to CQt the depositories to freeze the demat accounts of all the entit ‘company within 10 days from the date of this communication. mentioned in the shareholding pattern by the it may also be noted that presently the SEB! circular stipulates that the freeze on promoter demat accounts should be lifted only after the company complies and pays fines. (Note : For unfreezing of promoters/promoter group's demat accounts, the Company is required to comply with all the pending compliances and pay all the outstanding fines levied under SEBI SOP Circular dated January 22, 2020, ‘May 03, 2018 (Erstwhile SEBI Circulars dated November 30, 2015 and September 30, 2013). In case of any queries in the matter, you are advised to kindly take up the matter with the company, M/s. Amit Securities Ltd ‘Company is requested to transfer the fine amount in the following bank account and confirm the remittance details i.e. UTR No./NEFT Details/Cheque No., etc. on our emai oplodr@bseindia.com Bank Name Account Number of BSE Ltd | IFSC CODE Branch ICICI Bank BSERO7634 'c1c0000104 CMS Branch It may be noted that the Policy for exemption of fines detailing the reasons for waiver / reduction of fines levied as per the provisions of SEB! SOP circular is disseminated on the Exchange website at the following link: https:/Awww.bseindia.com/downloads1/Policy_for_Exemption_of_Fines_SOP.pdf It may further be noted that: + Anapplication for waiver of fines submitted by the company if any, will be considered only after the applicant company has first complied with the compliances for which it is seeking full / partial waiver of fines, as required under the Listing Regulation. + Anillustrative list of scenarios which cannot be considered to fall within the ambit of “events” entailing waiver or reduction of fine has been included in the policy disseminated on the Exchange website at aforesaid link. + The decision of the Exchange shall be final and repeated applications for waivers that are declined earlier, would not be entertained, unless there are any mitigating fresh facts. The Exchange reserves the right to accede to or deny the request for waiver/ reduction in penalty, for reasons to be recorded in writing. ‘Thanks & Regards, Chandani Thakkar I Assistant Manager It Listing Compliance 3S BSE Ltd. P J Towers, Dalal Street, Mumbai - 400001, india Phone (Direct) : 022 - 2272 8514 World's Fastest Exchange With A Speed of 6 Micraseconds ‘This mail is cassified as, by Chandan Thakkar on November 04, 2020 at 16:55:53,Anneyure-D (oly) 28 Manish Raval 16 October 2020 20:55 amititd@yahoo.com bse.soplodr Subject: Non-Submission of financial results for the Quarter ended June 2020 To ‘The Company Secretary/Compliance Officer Company Name: Amit Securities Ltd ‘Scrip Code: 531557 Dear Sir/Madam, Sub: Non-Submission of financial results for the Quarter ended June 2020 Pursuant to Regulation 33 of the SEBI (Listing Obligations and Disclosure Requirements) Regulations, companies are required to furnish Quarterly Financial Result within 45 days of the end of that quarter to the Exchange & for the last quarter, the company has to submit, within 60 days from the end of the financial year, the Audited Financial Results for entire financial year along with the audited financial results in respect of the last quarter (balancing figure) along with Auditors Report. SEBI vide circular no. SEBI/HO/CFD/CMD1/CIR/P/2020/140 dated July 29, 2020, further extended the timeline for submission of financial results under Regulation 33 of the LODR Regulations to September 15, 2020, for the quarter and the year ending June 30, 2020. Further, as per clause (b) of sub-regulation 3 of Regulation 33 of SEBI (isting Obligations and Disclosure Requirements) (Amendment) Regulations, 2018 effective from April 1, 2019 the companies are also required to submit quarterly/year- to date consolidated financial results, ‘We have observed from our records that, so far the Company has not submitted the financial results for the quarter ended June 2020. (Consolidated Financial Results not Submitted) ‘The company is advised to refer to Circular no. SEBI/HO/CFD/CMD/CIR/P/2020/12 dated January 22, 2020 Issued by Securities and Exchange Board of India (SEBI) with respect to non-compliance of certain provisions of the SEBI (Listing Obligations and Disclosure Requirements) Regulations 2015 and Standard Operating Procedure for suspension and revocation of trading of specified securities of listed entities. ‘The company is liable to pay fine amount as mentioned below as on October 16, 2020. As per the provisions of the circular the fines will continue to be computed further till the time of rectification of the non-compliance to the satisfaction of the Exchange or till the scrip of the listed entity is suspended from trading for non- compliance with aforesaid provisions: ‘Applicable Regulation of SEB Fine details as per __| Fine payable by the company (LODR) Regulations, 2015 circular (inclusive of GST @ 18 %) as on October 16, 2020 (In Rs.) Regulation 33 Rs. 5,000 per day till the Basic Fine | GST @ 18 % | Total Fine Non-submission of the financial date of compliance. payable results within the period prescribed under this regulation 155000 27900 | 182900 ‘The Company is therefore advised to note that as per the provisions of this circulai © The aforesaid fines including GST along with the financial results (as per Regulation 33) for the said Quarter must be submitted within 15 days from the date of this letter/email, failing which Exchange shall, pursuant to the provisions of the aforesaid circular, initiate action related to freezing of the entire shareholding of the promoter in this entity as well as all other securities held in the demat account of the promoter. The company is advised to bring the provisions of this Circular to the notice of promoter of the company.A ‘Further in the event of this being the second consecutive quarter of non-compliance for this Regulation, within 15 days of this letter/email, would result in the company being transferred to Z group and liable for suspension of trading of its equity shares, ‘+The company is also advised to ensure that the subject matter of non-compliance which has been identified and indicated by the Exchange and any subsequent action taken by the Exchange in this regard shall be placed before the Board of Directors of the company in its next meeting. Comments made by the board shall be duly informed to the Exchange for dissemination, A signed scanned copy of the financial results along with the covering letter can be uploaded on the following link of Listing Centre: http://listing.bseindia.com (For assistance in login and uploading on listing centre the company can contact helpdesk on Tel, No, 022-61363155 or email id; listing.centre@bseindia.com), The format of financial results can be downloaded from the website: http://www.bseindia.com/stati winloads.aspx?expandable=; Please also refer to BSE circular no. DCS/COMP/28/2016-17 dated March 30, 2017 related to filing of financial results in XBRL mode. In case of any further clarification in this matter please email at bse.soplodr@bseindia.com Yours faithfully Sambhaji Solat Manish Raval Manager Deputy Manager isting Compliance Listing Compliance Company is requested to remit the fine amount through electronic transfer to the designated bank - details given below: ‘Company Name:- Amit Securities Ltd Bank Name Branch Name. ‘Account No. IFSC Code ICICI Bank Limited (CMS Branch BSERO7634 CIC0000104 or through cheque favoring BSE Ltd. The company is required to submit the cheque alongwith the covering letter (format given at Annexure I below): Annexure-I (On letterhead of the company) Listing Compliance, BSE Limited, Ground Floor, P. J. Towers, Fort, Mumbai-400001. ‘Sub: Details of Payment of fines for Non-Compliance with Regulations of SEBI (LODR) Regulations, 2015. Scrip | Regulation & ‘Amount | TDS deducted, | Net Amount paid ] GST No. Code | Quarter paid | ifany (Mandatory to upload on BSE Listing Centre) (*) ‘No of company is not uploaded on the Listing Centre or Declaration for Unregistered Dealer is not received by us, company can not claim any GST input credit for the invoices raised by us.) Remitted by: ‘Cheque/DD No. Date UTR No. for RTGS /NEFT Compliance Officer / Company Secretary. ‘+ Please mention the Regulation No., Quarter, and amount of TDS deducted on the reverse side of the ‘Cheque/Demand Draft. ‘+ In case of payment through RTGS/NEFT, you are requested to send a soft copy of this annexure to bse.soplodr@bseindia,con This mals classified as 5: by Manish Raval on October 16, 2020 at 20:54:35.Sambhaji Solat 19 April 2024 18:15, Reena Raphel bsesoplodr Fw: Reminder for freezing of promoter demat account for Regulation 33 for June 2020 From: Manish Raval Sent: Monday, November 2, 2020 7:37 PM. To: amititd@yahoo.com ; accounts @ mittaludyog.com 'se.soplodr ‘Subject: Reminder for freezing of promoter demat account for Regulation 33 for June 2021 To; ‘Company Secretary & compliance officer/ Promoter of the company Company Name: Amit Securities Ltd Scrip Code: 531557 Dear Sir/Madam, Sub: Reminder for freezing of promoter demat account for Non-compliance/non payment of fines for Regulation 33 for June 2020 SEBI vide its circular no. SEBI/HO/CFD/CMD/CIR/P/2020/12 dated January 22, 2020 (SEBI SOP Circular) has inter alia prescribed certain penal actions such as levy of financial fines, freezing of promoter demat accounts, transfer to Z group (Trade for Trade) ending with suspension of trading in the securities of the listed entities which do not comply with critical Regulations of SEB! (LODR) Regulations, 2015. It is observed that as per the latest shareholding pattern report submitted by the company, Amit Securities Ltd (scrip code: 531557), your name has been included in the list of promoters of the company. The company is non-compliant with the provisions of following Regulation for the quarter ended June 2020. As ‘mandated in the SEB! SOP circular the company has been intimated about the pending compliance and has also been informed that all the promoters’ demat accounts would be frozen if the compliance was not completed and fines not paid. The details of fines outstanding, inter alia, pursuant to SEBI SOP Circular dated January 22, 2020 are as under: Regulation Fine amount outstanding (incl. GST @ 18 %) as on November 2, 2020 (Amount in Rs.) Reg. 33 — Financial Results 283200 ‘Note: In case of Non-Compliance, fines will be computed further till the date of compliance. As per Exchange records, itis observed that the company has not yet complied/ not paid the fines. Therefore, as in duty bound in terms of the provisions of SEBI SOP circular the Exchange would be proceeding to give instructions to the depositories to freeze the demat accounts of all the entities mentioned in the shareholding pattern by the company within 10 days from the date of this communication. . C3\ It may also be noted that presently the SEB! circular stipulates that the freeze on promoter demat accounts should be lifted only after the company complies and pays fines. (Note : For unfreezing of promoters demat accounts, the Company is required to comply with all the pending compliances and pay all the outstanding fines levied under SEB! SOP Circular dated January 22, 2020 (Erstwhile SEBII Circulars dated May 03, 2018; November 30, 2015 and September 30, 2013). In case of any queries in the matter, you are advised to kindly take up the matter with the company, M/s. Amit Securities Ltd ‘Company is requested to transfer the fine amount in the following bank account and confirm the remittance details i.e. UTR No./NEFT Details/Cheque No., etc. on our email id: bse.soplodr@bseindia.com Bank Name Account Number of BSE Ltd _| IFSC CODE Branch ICICI Bank BSERO7634 1cic0000104 CMS Branch It may be noted that the Policy for exemption of fines detailing the reasons for waiver / reduction of fines levied as per the provisions of SEBI SOP circular is disseminated on the Exchange website at the following link: https://www.bseindia.com/downloads1/Poticy_for_Exemption_of_Fines_SOP.pdf It may further be noted that: ‘+ Anapplication for waiver of fines submitted by the company if any, will be considered only after the applicant company has first complied with the compliances for which it is seeking full / partial waiver of fines, as required under the Listing Regulation. + Anillustrative list of scenarios which cannot be considered to fall within the ambit of “events” entailing waiver or reduction of fine has been included in the policy disseminated on the Exchange website at aforesaid link. * The decision of the Exchange shall be final and repeated applications for waivers that are declined earlier, would not be entertained, unless there are any mitigating fresh facts. The Exchange reserves the right to accede to or deny the request for waiver/ reduction in penalty, for reasons to be recorded in writing.Ba Thanks & Regards, ‘Manish Raval Deputy Manager Listing Compliance, BSE Limited, PJ Towers, Dalal Street, Mumbat -400001, India 1:22725025 ‘World's Fastest Exchange With A Speed Of 6 Microseconds, ‘This mail is classified as S -PUL IC by Manish Raval on November 02, 2020 at 18:37:87.Annexure - & From: Manish Raval Bs Sent: Monday, December 14, 2020 9:04 PM To: ‘amititd@yahoo.com' Ce: bse.soplodr ‘Subject: Fines as per SEBI circular no. SEBI/HO/CFD/CMD/CIR/P/2020/12 dated January 22, 2020 Ref.: SOP-CReview-Dec20 To ‘The Company Secretary/Compliance Officer Company Name: Amit Securities Ltd Scrip Code: 531557 Dear Sir/Madam, \ Noe ‘Sub: Fines as per SEBI circular no, SEBI/HO/CFD/CMD/CIR/P/2020/12 dated danninly 2270: ‘The company is advised to refer to Circular no, SEBI/HO/CFD/CMD/CIR/P/2020/12 dated January 22, 2020 Issued by Securities and Exchange Board of India (SEBI) with respect to penal actions prescribed for non- ‘compliance of certain provisions of the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015 and Standard Operating Procedure for suspension and revocation of trading of specified securities of listed entities. ‘The Exchange had also issued a guidance note regarding the provisions of the said SEBI circular which is disseminated on the Exchange website at the following link hi jia.com/downlo: for SEBI SOP df In this regard it Is observed that the company is non-compliant with the following Regulations for the period mentioned below: ‘Applicable Regulation of SEBI | Fine Fines levied for _| Fine payable by the company (LODR) Regulations, 2015 prescribed * (inclusive of GST @ 18 %) Basic | GST@ | Total Fine | 18% | Fine payable Regulation 33 Rs. 5,000/- per | (September 2020 | 135000] 24300/ 159300 Non-submission of the financial | day til the date | quarter) results within the period | of compliance. | Non submission prescribed under this regulation Consolidated financial results not submitted Regulation 28 (4) Rs. 50,000/- per 0 0 0 Non-compliance with obtaining in- | instance principle approval of stock exchange(s) before issuance of securities. Regulation 29(2)/29(3) Rs. 10,000 per 0 0 0 Delay in furnishing prior intimation | instance of non- about the meeting of the board of | compliance per directors item Regulation 31A(3)(a) Rs. 5,000/- per 0 0 0 Non-compliance pertaining to | day til the date delay in submission _of | of compliance. reclassification application to stock exchanges Regulation ___42(2)/42(3)/ | Rs. 10,000 per 0 0 0 42(4)/42(5) instance Delay in/ non-disclosure of record | of non- date/ dividend declaration or non- | compliance ‘compliance with ensuring the | per item prescribed time gap between two record dates/ book closure dates Regulation 44(3) Rs, 10,000 per 0 0 0 Non-submission of the voting | instance results within the period provided | of non- under this regulation compliance Non-obtaining approval_of_stock | instance Regulation 45(3) Rs. 25,000 per 0 0 0 (ee34 ‘exchange(s) before filing request for change of name with Registrar ‘of Companies. Total Fine 135000 | 24300| 159300 As per the provisions of the circular the fines will continue to be computed further till the time of rectification of the non-compliance to the satisfaction of the Exchange or till the scrip of the listed entity is suspended from trading for non-compliance with aforesaid provisions. ‘The Company is therefore advised to note that as per the provisions of this circular: . ‘The company is required to ensure compliance with above regulation and ensure to pay the aforesaid fines including GST within 15 days from the date of this letter/email, failing which Exchange shall, pursuant to the provisions of the aforesaid circular, initiate action related to freezing of the entire shareholding of the promoter in this entity as well as all other securities held in the demat account of the promoter. The company is advised to bring the provisions of this Circular to the notice of promoter of the company. . Further in the event of this being the second consecutive quarter of non-compliance for the Regulation 33, would result in the company being transferred to Z group and liable for suspension of trading of its equity shares. ‘The company Is also advised to ensure that the subject matter of non-compliance which has been identified and indicated by the Exchange and any subsequent action taken by the Exchange inthis regard shall be placed before the Board of Directors of the company in its next meeting. Comments made by the board shall be duly informed to the Exchange for dissemination. {A signed scanned copy of the financial results along with the covering letter can be uploaded on the following link of Listing Centre: http://listina.bseindia.com (For assistance in login on listing center the company can contact helpdesk on Tel. No. 022-61363155 or email id: listina.centre@bseindia.com and for XBRL related queries company may contact on Toll free no. 18002330445 or send emails to bse,xorl@bseindia.com). In case of any further queries / clarifications please email at the following ids: 1) Queries related to Regulation 29, 42, 45(3) ~ listing. crd@bseindia.com 2) Queries related to quantum of fines - bse.soplodr @bseindia.com 3) Queries related to Regulation 28(1) - bse, furtherlisting®bseindia.com Yours faithfully ‘Sambhaji Solat Manish Raval Manager Deputy Manager Listing Compliance Listing Compliance Company is requested to remit the fine amount through electronic transfer to the designate Bank - detalls given below: Company Name | Amit Securities Ltd ‘Bank Name Branch Name ‘Account No. IFSC Code ICICI Bank Limited | CMS Branch ‘BSERO7634 1C1C0000104 ‘or through cheque favoring BSE Ltd. The company is required to submit the cheque alongwith the covering letter (format given at Annexure I below): Annexure-I (On I f the compan Listing Compliance, BSE Limited, Ground Floor, P. J. Towers, Fort, Mumbai-400001, ‘Sub: Details of Payment of fines for Non-Compliance with Regulations of SEBI (LODR) Regulations, 2015. Remittance details: Scrip] Regulation & | Amount | TDS deducted, | Net Amount | GST No. Code | Quarter paid ifany paid (Mandatory to upload on BSE Listing Centre) (*)7515) No of company is not uploaded on the Listing Centre or Declaration for Unregistered Dealer is not received by us, company can not claim any GST input credit for the invoices raised by us.) UTR No. for RTGS /NEFT ‘+ Please mention the Regulation No., Quarter, and amount of TDS deducted on the reverse side of the ‘Cheque/Demand Draft. + In case of payment through RTGS/NEFT, you are requested to send a soft copy of this annexure to bse.soplodr@bseindia.com Thanks & Regards, Manish Raval Deputy Manager Listing Compliance, BSE Limited, PJ Towers, Dalal Street, Mumbai -400001, india 722725025 World's Fastest Exchange With A Speed Of 6 MicrosecondsANNEXuRE -F NOTICES Notice No. 20201216-46 Notice Date 16 Dec 2020 Category ‘Company rotated Segment ae ‘Suspension of trading in securities of companies for non-compliances with provisions of certain oe Regulations of SEB! (Listing Obligations and Disclosure Requirements) Regulations, 2015, Content Pursuant to the provisions of Circular No, SEBI/HO/CFD/CMDICIR/P/2020/12 dated January 22, 2020 (erstwhile Circular no. SEBI/HO/CFD/CMD/CIRIP/2018/77 dated May 3, 2018) issued by Securities and Exchange Board of India (SEB!) with respect to Standard Operating Procedure (SOP) for suspension and revocation of equity shares of listed entities for non-compliance with provisions of SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015, Trading members are requested to note that the following will be effected: 1) Trading in securities of the undermentioned companies will be suspended w.ef January 18, 2024 (being 30 days from issue of this notice); on account of non-compliance with Regulation 33 of SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015 for two consecutive quarters i.e., March 2020 & June 2020. Son Franca Soe aa Forse ce Saar Somtanerway Teratorat a board mousties ae rr e— -—] rE E—] FI [—F E—F E—F om i Paver & RST oJ Eon rovand Sea fe] — i i fo] cE i Soz16__ [recat Engrocrng Firaos [com Sector Secor SpomeUe [Ss2200— oprome nactucure haa re 2), Freazing of the entre shareoking of the promoter inte noncompliant sted entity 28 wel as all oter secures held inthe demat accounts) of the Promoter w.e{ December 16, 2020 til ther noice, Trading Members may further note that: 8) In case, the aforesaid companies comply (tothe satisfaction ofthe Exchange) with all the provisions of SEBI (Listing Oblgatons and Disclosure Requirements) Regulatons, 2016 on or before January 13,2021; racing in securies ofthe sald companies wil ot be suspended. ) However, in case the aforesaid compsnies fall to comply with the provisions of SEBI (isting Obligations and Disclosure Requirements) Reguatons, 2018, oe satisfaction ofthe Exchange on or before January 43,2021; than ‘+ Trading inthe sacurtes of he companies would be suspended w.e(. January 18,2024, and the suspension wll continue til such ime the company comalies and pays the ines, ‘+ 18:aye ater suspension has been effected, acing inthe shares ofthe non-compant companies would be allowed on Trade fr Trade basis In 2 group only on tho frst trading day of every week fr sx months. «Revocation of suspension would be subject ote company further complying with the procedure ang al extant norms prescribed for tevacaton of suspension may be noted tha the following company is also non-compliant with Regulation 33 of SEB (Listing Oblgalions and Disclosure Requirements) Regulations, 2016 for two consecutive quarters ie. March 2020 & June 2020; however, te company has been suspended vide Exchange notice no, 202008030 dated March 3, 2020, CyFor further clarification on the above, please email on bse.soplodr@bseindia,com Sambhaji Solat eel paral MEE Eanptrce 4 Listing Comp| Docomber 16, 2020, 3ANNERURE-G Annexuke - G ZB From: Payal Shah Sent: Friday, October 21, 2022 3:56 PM To: info@amititd.com Cc: bse.soplodr ; Nupur Parasrampuria ‘Subject: Partial waiver of fine levied pursuant to SEBI Circular SEB/HO/CFD/CMD/CIR/P/2020/12 dated January 22, 2020. (Erstwhile SEB! circular SEBI/HO/CFD/CMD/CIR/P/2018/77 dated May 03, 2018.) To, : Mf 7 d The Company Secretary/ Compliance Officer \ Company Name: Amit Securities Ltd *]] Scrip Code: 531557 i} Dear Sir / Madam, Sub: Partial waiver of fine levied pursuant to SEBI Circular SEBI/HO/CFD/CMD/CIR/P/2020/12 dated January 22, 2020. (Erstwhile SEBI circular SEBI/HO/CFD/CMD/CIR/P/2018/77 dated May 03, 2018.) This is with reference to the company’s letter/mail requesting waiver for fine imposed for late/non- compliance with certain provisions of SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015. In this regard, company’s representation for waiver of fine was placed before the “Request Review Committee”. After considering the facts of the case, the written submissions made by the company, the Committee decided the following:- Quarter/Year SET Rea Fine evied | He ron lesa {in| 0/3 Fine Payable (in end bes (in Rs.) a Re) | ReAincludes est) Sep-19 | R€8-33- Financial 2542900} 289100 0 2253800 Results Dec-19 | Re8-33- Financial 2000100] 289100 0 1711000 Results Total 3964800, The approved carve outs have been disseminated on the Exchange website and may be viewed at the following link: https://www.bseindia.com/downloads1/Policy for Exemption of Fines SOP.pdf Therefore, you are requested to pay the outstanding fine amount as mentioned above within 10 days from the date of intimation, failing which action may be initiated pursuant to SEBI circular dated January 22, 2020 relating to freezing of entire shareholding of the Promoters in such entity as well as all other securities held in the Demat account for non-compliance with certain provisions of SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015. The bank details for payment of fines has been given below. After making the payment, you are requested to provide the details of remittance of fine as per Annexure-| given below. Further, you are advised to exercise caution while filling any document with the Exchange and strictly comply with the various circulars of SEBI and the Exchange notices on timely basis. Yours faithfully, Arpita Joshi Payal ShahAA Manager Associate Manager Listing Compliance Listing Compliance Bank details for payment of Company is requested to remit the fine amount through electronic transfer to the designated bank - details given below or through cheque favoring BSE Ltd. jame: Amit Securities Ltd Bank Name kanch Name Jecount No. IFSC Code ICI Bank Limited Ms Branch E icicooo0104 Annexure-| Remitted by: for RTGS /NEFT(in Mandatory to upload Lee Coen po kctronic fund transfer) {Listing Centre) (*) (*)Please ensure that the GSTin Number of the company is uploaded on Listing Centre portal of the Exchange, or Declaration for unregistered dealer is submitted to the Exchange to get the GST input credit to the company Compliance Officer / Company Secretary 1. Cheque should be drawn in the name of “BSE Limited”. Also mention the Regulation No., Quarter, and amount of TDS deducted on the reverse side of the Cheque/Demand Draft. 2. You are requested to send a soft copy of this annexure to bse.soplodr@bseindia.com after making the payment. World’s Fastest Exchange With A Speed Of 6 Microseconds ‘This mall's classified as by payal son October 21, 2022 at 15:56:11,40 BEFORE THE HON’BLE SECURITIES APPELLATE TRIBUNAL M.A. NO. 176 OF 2024 IN APPEAL NO. 191 OF 2024 Amit Securities Limited... Applicant / Appellant Versus BSE Limited «. Respondent AEFIDAVIT-IN-REPLY ON BEHALF OF THE RESPONDENT DATED, APRIL 2024 THE LAW POINT Advocates for Respondent 703-04, Tulsiani Chambers Free Press Journal Marg, Nariman Point, Mumbai-400 021 ‘Tel: 2284 4332 / 2283 4742 Telefax: 2283 4752 E-mail: registrar@thelawpoint.com