See Full Document Text
DRAFT RED HERRING PROSPECTUS
Dated: September 29, 2025
Please read section 32 of the Companies Act, 2013
(Please scan the QR to (This Draft Red Herring Prospectus will be updated upon filing with the RoC)
view the Draft Red Herring 100% Book Built Issue
Prospectus)
SHAH INVESTOR'S HOME LIMITED
CORPORATE IDENTITY NUMBER: U67120GJ1994PLC023257
REGISTERED OFFICE CORPORATE OFFICE CONTACT PERSON EMAIL AND TELEPHONE WEBSITE
810, X-Change Plaza, SIHL House, Opp. Hiral Bhawsar Email: company.secretary@sihl.in www.sihl.in
DSCCSL (53E), Road 5E, Ambawadi Jain Temple, Company Secretary and Tel: +91 9904053335
Block 53, Zone 5, Gift City, Nehru Nagar Cross Road, Compliance Officer
Gandhinagar – 382050, Ahmedabad – 380015
Gujarat, India Gujarat, India
PROMOTERS OF OUR COMPANY: UPENDRA TRIKAMLAL SHAH, PURNIMA UPENDRA SHAH, TANMAY UPENDRA SHAH AND
TRUPTI UTPAL SHAH
DETAILS OF THE ISSUE OF THE EQUITY SHARES OF FACE VALUE OF ₹10 EACH
TYPE ISSUE SIZE* OFFER FOR TOTAL ISSUE SIZE* ELIGIBILITY AND RESERVATION AMONG QIBS, NIIS
SALE SIZE AND RIIS
Fresh Issue Up to 54,00,000 Equity Up to 54,00,000 Equity The Issue is being made in terms of Regulation 6(1) of the
Shares of face value of Shares of face value of Securities and Exchange Board of India (Issue of Capital and
₹10 each aggregating Not Applicable ₹10 each aggregating up Disclosure Requirements) Regulations, 2018, as amended (“SEBI
up to ₹ [●] lakhs to ₹ [●] lakhs ICDR Regulations”). For further details, see “Other Regulatory
and Statutory Disclosure – Eligibility for the Issue” on page 627.
For details in relation to share reservation among Qualified
Institutional Buyers, Non-Institutional Investors and Retail
Individual Investors see “Issue Structure” on page 644.
RISKS IN RELATION TO THE FIRST ISSUE
This being the first public issue of Equity Shares of our Company, there has been no formal market for the Equity Shares of our Company. The face value of
each Equity Share is ₹ 10 each. The Floor Price, the Cap Price and the Issue Price, as determined by our Company in consultation with the Book Running Lead
Manager (“BRLM”), in accordance with the SEBI ICDR Regulations, and on the basis of the assessment of market demand for the Equity Shares by way of the
Book Building Process, as stated in “Basis for Issue Price” on page 365, should not be taken to be indicative of the market price of the Equity Shares after the
Equity Shares are listed. No assurance can be given regarding an active and/or sustained trading in the Equity Shares of our Company, or regarding the price at
which the Equity Shares will be traded after listing.
GENERAL RISK
Investments in equity and equity-related securities involve a degree of risk and investors should not invest any funds in this Issue unless they can afford to take
the risk of losing their entire investment. Investors are advised to read the risk factors carefully before taking an investment decision in this Issue. For taking an
investment decision, investors must rely on their own examination of our Company and the Issue, including the risks involved. The Equity Shares in the Issue
have not been recommended or approved by the Securities and Exchange Board of India (“SEBI”), nor does SEBI guarantee the accuracy or adequacy of the
contents of this Draft Red Herring Prospectus. Specific attention of the investors is invited to “Risk Factors” on page 40.
OUR COMPANY’S ABSOLUTE RESPONSIBILITY
Our Company, having made all reasonable inquiries, accepts responsibility for and confirms that this Draft Red Herring Prospectus contains all information with
regard to our Company and the Issue, which is material in the context of the Issue, that the information contained in this Draft Red Herring Prospectus is true and
correct in all material aspects and is not misleading in any material respect, that the opinions and intentions expressed herein are honestly held and that there are
no other facts, the omission of which makes this Draft Red Herring Prospectus as a whole or any of such information or the expression of any such opinions or
intentions, misleading in any material respect.
LISTING
The Equity Shares issued through the Red Herring Prospectus are proposed to be listed on the Stock Exchanges being BSE Limited and National Stock Exchange
of India Limited. For the purposes of the Issue, the Designated Stock Exchange is [●].
BOOK RUNNING LEAD MANAGER
Name of Book Running Lead Manager Contact Person Email and Telephone
BEELINE CAPITAL ADVISORS Telephone: +91 7949185784
Nikhil Shah
PRIVATE LIMITED Email: mb@beelinemb.com
REGISTRAR TO THE ISSUE
Name of Registrar Contact Person Email and Telephone
MUFG INTIME INDIA PRIVATE Telephone: +91 8108114949
LIMITED (FORMERLY LINK Shanti Gopalkrishnan Email:
INTIME INDIA PRIVATE LIMITED) shahInvestors.ipo@in.mpms.mufg.com
BID/ISSUE PERIOD
ANCHOR INVESTOR BID/ISSUE PERIOD* [●]** BID/ISSUE OPENS ON* [●]** BID/ISSUE CLOSES [●]**^
ON**
*Our Company may, in consultation with the Book Running Lead Manager, consider participation by Anchor Investors in accordance with the SEBI ICDR
Regulations. The Anchor Investor Bidding Date shall be one Working Day prior to the Bid/Issue Opening Date.
** Our Company may, in consultation with the Book Running Lead Manager, consider closing the Bid/Issue Period for QIBs one Working Day prior to the Bid/
Issue Closing Date in accordance with the SEBI ICDR Regulations.
^UPI mandate end time and date shall be at 5:00 p.m. on the Bid/Issue Closing Date.DRAFT RED HERRING PROSPECTUS
Dated: September 29, 2025
Please read section 32 of the Companies Act, 2013
(Please scan the QR to (This Draft Red Herring Prospectus will be updated upon filing with the RoC)
view the Draft Red Herring 100% Book Built Issue
Prospectus)
SHAH INVESTOR'S HOME LIMITED
Our Company was incorporated as “Shah Investors Home Private Limited”, a private limited company under the Companies Act, 1956, pursuant to the certificate
of incorporation dated October 12, 1994, issued by the Assistant Registrar of Companies, Gujarat at Dadra & Nagar Haveli (“RoC”). Subsequently, our Company
was converted into a public company, pursuant to a special resolution passed by shareholders in their extra-ordinary general meeting on February 14, 1995 and
the name of our Company was changed to “Shah Investors Home Limited”. A fresh certificate of incorporation dated March 09, 1995, was issued by the RoC upon
conversion of our Company to a public limited company. Thereafter, the name of our Company was changed to “Shah Investor’s Home Limited”, pursuant to a
shareholder resolution dated October 10, 2000 and a fresh certificate of incorporation consequent on change of name dated October 13, 2000, was issued by the
RoC.
Registered Office: 810, X-Change Plaza, DSCCSL (53E), Road 5E, Block 53, Zone 5, Gift City, Gandhinagar – 382050, Gujarat, India
Corporate Office : SIHL House, Opp. Ambawadi Jain Temple, Nehru Nagar Cross Road, Ahmedabad – 380015 Gujarat, India
Contact Person: Hiral Bhawsar, Company Secretary and Compliance Officer
Tel: +91 9904053335, E-mail: company.secretary@sihl.in, Website: www.sihl.in
Corporate Identity Number: U67120GJ1994PLC023257
OUR PROMOTERS: UPENDRA TRIKAMLAL SHAH, PURNIMA UPENDRA SHAH, TANMAY UPENDRA SHAH AND TRUPTI UTPAL SHAH
INITIAL PUBLIC OFFERING OF UP TO 54,00,000 EQUITY SHARES OF FACE VALUE OF ₹ 10 EACH (“EQUITY SHARES”) OF OUR COMPANY
FOR CASH AT A PRICE OF ₹ [●] PER EQUITY SHARE (INCLUDING A SHARE PREMIUM OF ₹ [●] PER EQUITY SHARE) (“ISSUE PRICE”)
AGGREGATING UP TO ₹ [●] LAKHS (THE “ISSUE”)
THE FACE VALUE OF THE EQUITY SHARE IS ₹ 10 EACH AND THE ISSUE PRICE IS [●] TIMES THE FACE VALUE OF THE EQUITY SHARES.
THE PRICE BAND AND THE MINIMUM BID LOT SIZE WILL BE DECIDED BY OUR COMPANY AND THE PROMOTER IN CONSULTATION
WITH THE BRLM AND WILL BE ADVERTISED IN ALL EDITIONS OF [●] (A WIDELY CIRCULATED ENGLISH NATIONAL DAILY
NEWSPAPER), [●] EDITIONS OF [●] (A WIDELY CIRCULATED HINDI NATIONAL DAILY NEWSPAPER) AND [●] EDITIONS OF [●] (A
WIDELY CIRCULATED GUJARATI DAILY NEWSPAPER, GUJARATI BEING THE REGIONAL LANGUAGE OF GUJARAT WHERE OUR
REGISTERED OFFICE IS LOCATED), AT LEAST TWO WORKING DAYS PRIOR TO THE BID/ ISSUE OPENING DATE AND SHALL BE MADE
AVAILABLE TO THE STOCK EXCHANGES FOR UPLOADING ON THEIR RESPECTIVE WEBSITES IN ACCORDANCE WITH THE SEBI ICDR
REGULATIONS, AS AMENDED.
In case of any revision to the Price Band, the Bid/Issue Period will be extended by at least three additional Working Days after such revision in the Price Band,
subject to the Bid/Issue Period not exceeding 10 Working Days. In cases of force majeure, banking strike or similar circumstances, our Company may, in consultation
with the BRLM, for reasons to be recorded in writing, extend the Bid / Issue Period for a minimum of one Working Day, subject to the Bid/ Issue Period not
exceeding 10 Working Days. Any revision in the Price Band and the revised Bid/Issue Period, if applicable, shall be widely disseminated by notification to the Stock
Exchanges, by issuing a public notice, and also by indicating the change on the website of the BRLM and at the terminals of the Syndicate Member(s) and by
intimation to the Designated Intermediaries and the Sponsor Bank, as applicable.
This is an Issue in terms of Rule 19(2)(b) of the SCRR, read with Regulation 31 of the SEBI ICDR Regulations. The Issue is being made through the Book Building
Process in terms of Regulation 6 (1) of the SEBI ICDR Regulations, wherein not more than 50% of theIssue shall be available for allocation on a proportionate basis
to Qualified Institutional Buyers (“QIBs and such portion, the “QIB Portion”), provided that our Company, in consultation with the BRLM, may allocate up to 60%
of the QIB Portion to Anchor Investors on a discretionary basis (“Anchor Investor Portion”), out of which one-third shall be reserved for domestic Mutual Funds,
subject to valid Bids being received from domestic Mutual Funds at or above the price at which allocation is made to Anchor Investors (“Anchor Investor Allocation
Price”), in accordance with the SEBI ICDR Regulations. In the event of under-subscription, or non-allocation in the Anchor Investor Portion, the balance Equity
Shares shall be added to the Net QIB Portion. Further, 5% of the Net QIB Portion shall be available for allocation on a proportionate basis to Mutual Funds only,
and the remainder of the Net QIB Portion shall be available for allocation on a proportionate basis to all QIB Bidders, including Mutual Funds, subject to valid Bids
being received from them at or above the Issue Price. However, if the aggregate demand from Mutual Funds is less than 5% of the Net QIB Portion, the balance
Equity Shares available for allocation in the Mutual Fund Portion will be added to the remaining Net QIB Portion for proportionate allocation to QIBs. Further, not
less than 15% of the Issue shall be available for allocation to Non-Institutional Bidders (“Non-Institutional Portion”) (of which one third of the Non-Institutional
Portion shall be reserved for Bidders with an application size between ₹ 2.00 lakhs up to ₹ 10.00 lakhs and two-thirds of the Non-Institutional Portion shall be
reserved for Bidders with an application size exceeding ₹ 10.00 lakhs) and under-subscription in either of these two sub-categories of Non-Institutional Portion may
be allocated to Bidders in the other subcategory of Non-Institutional Portion, subject to valid Bids being received at or above the Issue Price and not less than 35%
of the Issue shall be available for allocation to Retail Individual Bidders in accordance with the SEBI ICDR Regulations, subject to valid Bids being received from
them at or above the Issue Price. All potential Bidders (except Anchor Investors) are mandatorily required to participate in the Issue through the Application
Supported by Blocked Amount (“ASBA”) process by providing details of their respective ASBA accounts and UPI ID in case of UPI Bidders using the UPI
Mechanism, as applicable, pursuant to which their corresponding Bid Amount will be blocked by the Self Certified Syndicate Banks (“SCSBs”) or by the Sponsor
Bank under the UPI Mechanism, as the case may be, to the extent of the respective Bid Amounts. Anchor Investors are not permitted to participate in the Issue
through the ASBA Process. For further details, see “Issue Procedure” on page 647
RISKS IN RELATION TO THE FIRST ISSUE
This being the first public issue of Equity Shares of our Company, there has been no formal market for the Equity Shares of our Company. The face value of the
Equity Shares is ₹ 10 each. The Floor Price, the Issue Price or the Price Band as (determined by our Company in consultation with the BRLM, in accordance with
the SEBI ICDR Regulations and on the basis of the assessment of market demand for the Equity Shares by way of the Book Building Process, as stated under “Basis
for Issue Price” on page 365 should not be taken to be indicative of the market price of the Equity Shares after the Equity Shares are listed. No assurance can be
given regarding an active or sustained trading in the Equity Shares of our Company, or regarding the price at which the Equity Shares will be traded after listing.
GENERAL RISKS
Investments in equity and equity-related securities involve a degree of risk and investors should not invest any funds in the Issue unless they can afford to take the
risk of losing their investment. Investors are advised to read the risk factors carefully before taking an investment decision in the Issue. For taking an investment
decision, investors must rely on their own examination of our Company and the Issue, including the risks involved. The Equity Shares in the Issue have not been
recommended or approved by the Securities and Exchange Board of India (“SEBI”), nor does SEBI guarantee the accuracy or adequacy of the contents of this Draft
Red Herring Prospectus. Specific attention of the investors is invited to “Risk Factors” on page 40.
OUR COMPANY’S ABSOLUTE RESPONSIBILITY
Our Company, having made all reasonable inquiries, accepts responsibility for and confirms that this Draft Red Herring Prospectus contains all information with
regard to our Company and the Issue, which is material in the context of the Issue, that the information contained in this Draft Red Herring Prospectus is true and
correct in all material aspects and is not misleading in any material respect, that the opinions and intentions expressed herein are honestly held and that there are no
other facts, the omission of which makes this Draft Red Herring Prospectus as a whole or any of such information or the expression of any such opinions or intentions
misleading in any material respect.
LISTING
The Equity Shares offered through the Red Herring Prospectus are proposed to be listed on the Stock Exchanges. Our Company has received ‘in-principle’ approvals
from BSE and NSE for the listing of the Equity Shares pursuant to letters dated [●] and [●], respectively. For the purposes of the Issue, the Designated StockExchange shall be [●]. A copy of the Red Herring Prospectus and the Prospectus shall be filed with the RoC in accordance with Sections 26(4) and 32 of the
Companies Act, 2013. For further details of the material contracts and documents available for inspection from the date of the Red Herring Prospectus until the Bid/
Issue Closing Date, see “Material Contracts and Documents for Inspection” on page 702.
BOOK RUNNING LEAD MANAGER REGISTRAR TO THE ISSUE
Beeline Capital Advisors Private Limited MUFG Intime India Private Limited (formerly Link Intime India Private
B 1311 - 1314 Thirteenth Floor Shilp Corporate Park Limited)
Rajpath Rangoli Road Thaltej Ahmedabad – 380054, C-101, 1stFloor, 247 Park Lal Bahadur Shastri Marg,
Gujarat, India Vikhroli (West), Mumbai - 400 083, Maharashtra, India
Telephone Number: +91 79 4918 5784 Telephone Number: +91 8108114949
E-mail: mb@beelinemb.com E-mail: shahInvestors.ipo@in.mpms.mufg.com
Investor Grievance E-mail: ig@beelinemb.com Investor Grievance E-mail: shahInvestors.ipo@in.mpms.mufg.com
Website: https://beelinemb.com/ Website: www.in.mpms.mufg.com
Contact Person: Nikhil Shah Contact Person: Shanti Gopalkrishnan
SEBI Registration No.: INM000012917 SEBI Registration Number: INR000004058
BID/ISSUE PERIOD
ANCHOR INVESTOR BID/ISSUE [●]** BID/ISSUE OPENS ON* [●]** BID/ISSUE CLOSES [●]**^
PERIOD* ON**^
*Our Company may, in consultation with the BRLM, consider participation by Anchor Investors in accordance with the SEBI ICDR Regulations. The Anchor Investor
Bidding Date shall be one Working Day prior to the Bid/Issue Opening Date.
** Our Company may, in consultation with the BRLM, consider closing the Bid/Issue Period for QIBs one Working Day prior to the Bid/ Issue Closing Date in
accordance with the SEBI ICDR Regulation.
^UPI mandate end time and date shall be at 5:00 p.m. on the Bid/issue Closing Date.TABLE OF CONTENTS
SECTION I – GENERAL .................................................................................................................................... 1
DEFINITIONS AND ABBREVIATIONS .............................................................................................................. 1
CERTAIN CONVENTIONS, PRESENTATION OF FINANCIAL, INDUSTRY AND MARKET DATA AND
CURRENCY OF PRESENTATION .................................................................................................................... 13
FORWARD LOOKING STATEMENTS ............................................................................................................ 16
SUMMARY OF THE ISSUE DOCUMENT ....................................................................................................... 18
SECTION II – RISK FACTORS ...................................................................................................................... 40
SECTION III – INTRODUCTION ................................................................................................................... 89
THE ISSUE .......................................................................................................................................................... 89
SUMMARY OF FINANCIAL INFORMATION ................................................................................................ 91
GENERAL INFORMATION ............................................................................................................................... 96
CAPITAL STRUCTURE ................................................................................................................................... 104
OBJECTS OF THE ISSUE ................................................................................................................................ 357
BASIS OF ISSUE PRICE .................................................................................................................................. 365
STATEMENT OF SPECIAL TAX BENEFITS ................................................................................................. 375
SECTION IV – ABOUT THE COMPANY ................................................................................................... 382
INDUSTRY OVERVIEW .................................................................................................................................. 382
OUR BUSINESS ................................................................................................................................................ 438
KEY REGULATIONS AND POLICIES ........................................................................................................... 438
HISTORY AND CERTAIN CORPORATE MATTERS ................................................................................... 463
OUR SUBSIDIARIES ........................................................................................................................................ 472
OUR MANAGEMENT ...................................................................................................................................... 475
OUR PROMOTERS AND PROMOTER GROUP ............................................................................................ 496
DIVIDEND POLICY ......................................................................................................................................... 502
SECTION V – FINANCIAL INFORMATION ............................................................................................. 503
OTHER FINANCIAL INFORMATION ............................................................................................................ 575
RELATED PARTY TRANSACTIONS ............................................................................................................. 577
MANAGEMENT’S DISCUSSION AND ANALYSIS OF FINANCIAL CONDITION AND RESULTS OF
OPERATIONS ................................................................................................................................................... 578
CAPITALISATION STATEMENT ................................................................................................................... 611
FINANCIAL INDEBTEDNESS ........................................................................................................................ 612
SECTION VI – LEGAL AND OTHER INFORMATION ........................................................................... 614
OUTSTANDING LITIGATION AND MATERIAL DEVELOPMENTS ........................................................ 614
GOVERNMENT AND OTHER APPROVALS ................................................................................................ 619
GROUP COMPANIES ....................................................................................................................................... 624
OTHER REGULATORY AND STATUTORY DISCLOSURES ..................................................................... 626
SECTION VII – ISSUE RELATED INFORMATION ................................................................................. 638
TERMS OF THE ISSUE .................................................................................................................................... 638
ISSUE STRUCTURE ......................................................................................................................................... 644
ISSUE PROCEDURE ........................................................................................................................................ 647
RESTRICTIONS ON FOREIGN OWNERSHIP OF INDIAN SECURITIES .................................................. 665
SECTION VIII – DESCRIPTION OF EQUITY SHARES AND TERMS OF THE ARTICLES OF
ASSOCIATION ................................................................................................................................................ 666
SECTION IX – OTHER INFORMATION .................................................................................................... 702
MATERIAL CONTRACTS AND DOCUMENTS FOR INSPECTION ........................................................... 702
DECLARATION ................................................................................................................................................ 704
0SECTION I – GENERAL
DEFINITIONS AND ABBREVIATIONS
This Draft Red Herring Prospectus uses certain definitions and abbreviations which, unless the context otherwise
indicates or implies, or unless otherwise specified, shall have the meaning as assigned below. References to
statutes, rules, regulations, guidelines and policies will, unless the context otherwise requires, be deemed to
include all amendments, modifications and replacements notified thereto, as of the date of this Draft Red Herring
Prospectus, and any reference to a statutory provision shall include any subordinate legislation made from time
to time under that provision. In case of any inconsistency between the definitions given below and the definitions
contained in the General Information Document (as defined below), the definitions given below shall prevail.
The words and expressions used in this Draft Red Herring Prospectus but not defined herein, shall have, to the
extent applicable, the meanings ascribed to such terms under the Companies Act, the SEBI ICDR Regulations,
the SCRA, the Depositories Act or the rules and regulations made thereunder.
The terms not defined herein but used in “Objects of the Issue”, “History and Certain Corporate Matters”,
“Financial Indebtedness”, “Basis of Issue Price”, “Statement of Special Tax Benefits”, “Industry Overview”,
“Key Regulations and Policies”, “Financial Information”, “Outstanding Litigation and Other Material
Developments” “Issue Procedure” and “Description of Equity Shares and Terms of Articles of Association”, on
pages , 357, 463,612, 365, 375, 382, 438, 503, 614, 647 and 666 respectively, will have the meaning ascribed to
such terms in those respective sections.
General Terms
Term Description
our Company / the Shah Investor’s Home Limited, a public limited company incorporated under the Companies
Company / the Issuer Act, 1956 and having its Registered Office at 810, X-Change Plaza, DSCCSL (53E), Road 5E,
Block 53, Zone 5, Gift City, Gandhinagar – 382050, Gujarat, India and having its Corporate
Office at SIHL House, Opp. Ambawadi Jain Temple, Nehru Nagar Cross Road, Ahmedabad –
380015 Gujarat, India.
we / us / our Unless the context otherwise indicates or implies, refers to our Company, together with our
Subsidiaries, on a consolidated basis as on the date of this Draft Red Herring Prospectus.
Company Related Terms
Term Description
Articles of Association / Articles of association of our Company, as amended from time to time
Articles / AoA
Audit Committee Audit Committee of our Board. For details see “Our Management – Corporate Governance”
on page 475.
Auditors / Statutory Ashit N Shah & Co, Chartered Accountants (FRN: 100624W)
Auditors
Board / Board of Board of directors of our Company, as constituted from time to time or any duly constituted
Directors committee thereof. For details see “Our Management – Board of Directors” on page 475.
Chairman & Whole Chairman and Whole Time Director of our Company being Upendra Trikamlal Shah
Time Director
Company Secretary and The Company Secretary and Compliance Officer of our Company, namely Hiral Bhawsar.
Compliance Officer For details, see “Our Management – Key Managerial Personnel” on page 475
Corporate Social The corporate social responsibility committee of our Company. For details see “Our
Responsibility Management – Corporate Governance” on page 475.
Committee / CSR
Committee
Corporate Office SIHL House, Opp. Ambawadi Jain Temple, Nehru Nagar Cross Road, Ahmedabad – 380015
Gujarat, India
Director(s) The director(s) on the Board of Directors, as appointed from time to time
Equity Shares The equity shares of our Company of face value of ₹ 10 each
Executive Director(s) Executive director(s) on our Board. For further details of the Executive Director, see “Our
Management” on page 475
Group Companies The group companies of our Company in accordance with the SEBI ICDR Regulations and
the Materiality Policy of our Company. For details see “Group Companies” on page 624
Independent Director(s) The Independent Director(s) on our Board appointed as per the Companies Act, 2013 and the
Listing Regulations. For details, see “Our Management-Board of Directors” on page 475
Independent Chartered Dhrumil A. Shah & Co., Chartered Accountants (FRN: 145163W)
Accountant
IPO Committee The IPO committee of our Board. For details see “Our Management – Corporate
Governance” on page 484.
1Term Description
Key Managerial Key managerial personnel of our Company. For details see “Our Management – Key
Personnel / KMP Managerial Personnel” on page 493.
Key Performance Key financial and operational performance indicators of our Company, as included in ‘Basis
Indicators/ for the Issue Price’ and ‘Our Business -Key Performance Indicators’ on pages 365 and 475,
KPIs respectively
Materiality Policy The Materiality Policy adopted by our Board pursuant to a resolution of our Board dated
September 05, 2025, for identification of the material: (a) outstanding material litigation
proceedings; (b) Group Companies; and (c) material creditors, pursuant to the requirements
of the SEBI ICDR Regulations and for the purposes of disclosure in this Draft Red Herring
Prospectus, the Red Herring Prospectus and the Prospectus.
Material Subsidiary The material subsidiary of our Company being, SIHL Fincap Limited
Memorandum of The memorandum of association of our Company, as amended
Association /
Memorandum/ MoA
Nomination and The nomination and remuneration committee of our Company. For details see
Remuneration “Our Management – Corporate Governance” on page 493.
Committee / NRC
Committee
Non – Executive A Director, not being an Executive Director. For details see “Our Management” on page 475.
Director(s)
Promoters The promoters of our Company namely, Upendra Trikamlal Shah, Purnima Upendra Shah,
Tanmay Upendra Shah and Trupti Utpal Shah. For details see “Our Promoters and Promoter
Group” on page 496
Promoter Group Such persons and entities constituting the promoter group of our Company, pursuant to
Regulation 2(1) (pp) of the SEBI ICDR Regulations. For details, see “Our Promoters and
Promoter Group” on page 496
Registered Office The Registered Office of the Company is located at 810, X-Change Plaza, DSCCSL (53E),
Road 5E, Block 53, Zone 5, Gift City, Gandhinagar – 382050, Gujarat, India.
Registrar of Companies Registrar of Companies, Gujarat at Ahmedabad, India. For details, see “General Information”
/ RoC on page 96
The restated consolidated financial information of our Company and its Subsidiaries
(collectively the “Group”) which comprise of the Restated Consolidated Statement of Assets
and Liabilities for the financial years ended March 31, 2025, March 31, 2024 and March 31,
Restated Consolidated 2023, the Restated Consolidated Statement of Profit and Loss (including Other
Financial Statements/ Comprehensive Income, as applicable) and the Restated Consolidated Statement of Cash
Restated Consolidated Flows for the financial years ended March 31, 2025, March 31, 2024 and March 31, 2023 and
Financial Information” the Restated Consolidated Statement of Changes in Equity for financial years ended March
31, 2025, March 31, 2024 and March 31, 2023 and the summary of material accounting
policies and other explanatory notes to the restated consolidated financial information of the
Group and included in “Financial Information” on page 503
Senior management personnel of our Company in terms of Regulation 2(1) (bbbb) of the SEBI
Senior Management
ICDR Regulations as described in “Our Management – Key Managerial Personnel and Senior
Personnel or SMP
Management Personnel” on page 475
Shareholders The holders of the Equity Shares of our Company from time to time
Stakeholders The stakeholders’ relationship committee of our Company. For details, see “Our Management
Relationship Committee –Corporate Governance” on page 475
Subsidiaries The subsidiaries of our Company being, SIHL Consultancy Limited, SIHL Fincap Limited,
SIHL Global Investments (IFSC) Private Limited and SIHL Strategic Advisors Private
Limited. For details, see “Our Subsidiaries” on page 472
Whole-time Director(s) The whole-time director of our Company. For details see “Our Management” on page 475
Issue Related Terms
Term Description
Abridged Prospectus A memorandum containing such salient features of a prospectus as may be specified by SEBI
in this regard
Acknowledgement Slip The slip or document issued by the relevant Designated Intermediary(ies) to a Bidder as proof
of registration of the Bid cum Application Form
Allot / Allotment Unless the context otherwise requires, allotment of Equity Shares issued pursuant to the Issue
/Allotted
Allotment Advice Note or advice or intimation of Allotment sent to the Bidders who have been or are to be
Allotted the Equity Shares after the Basis of Allotment has been approved by the Designated
Stock Exchange
Allottee A successful Bidder to whom the Equity Shares are Allotted
2Term Description
Anchor Investor(s) A Qualified Institutional Buyer, applying under the Anchor Investor Portion in accordance with
the requirements specified in the SEBI ICDR Regulations and the Red Herring Prospectus, and
who has bid for an amount of at least ₹ 1000.00 lakhs.
Anchor Investor Price at which Equity Shares will be allocated to Anchor Investors in terms of the Red Herring
Allocation Price Prospectus and the Prospectus, which will be decided by our Company and in consultation with
the BRLM during the Anchor Investor Bidding Date
Anchor Investor Application form used by an Anchor Investor to make a Bid in the Anchor Investor Portion and
Application Form which will be considered as an application for Allotment in terms of the Red Herring Prospectus
and the Prospectus
Anchor Investor The day, being one Working Day prior to the Bid/Issue Opening Date, on which Bids by Anchor
Bid/Issue Period or Investors shall be submitted, prior to and after which the BRLM will not accept any Bids from
Anchor Investor Anchor Investors, and allocation to Anchor Investors shall be completed
Bidding Date
Anchor Investor Issue Final price at which the Equity Shares will be issued and Allotted to Anchor Investors in terms
Price of the Red Herring Prospectus and the Prospectus, which price will be equal to or higher than
the Issue Price but not higher than the Cap Price. The Anchor Investor Issue Price will be
decided by our Company and in consultation with the BRLM
Anchor Investor Pay-In With respect to Anchor Investor(s), it shall be the Anchor Investor Bidding Date, and in the
Date event the Anchor Investor Allocation Price is lower than the Issue Price, not later than two
Working Days after the Bid/Issue Closing Date
Anchor Investor Portion Up to 60% of the QIB Portion which may be allocated by our Company and in consultation
with the BRLM, to Anchor Investors on a discretionary basis, in accordance with the SEBI
ICDR Regulations.
One-third of the Anchor Investor Portion shall be reserved for domestic Mutual Funds, subject
to valid Bids being received from domestic Mutual Funds at or above the Anchor Investor
Allocation Price, in accordance with the SEBI ICDR Regulations
Application Supported An application, whether physical or electronic, used by ASBA Bidders to make a Bid and
by Blocked Amount / authorize an SCSB to block the Bid Amount in the ASBA Account and will include applications
ASBA made by RIIs using the UPI Mechanism where the Bid Amount will be blocked upon
acceptance of UPI Mandate Request by RIIs using the UPI Mechanism
ASBA Account A bank account maintained by ASBA Bidders with an SCSB and specified in the ASBA Form
submitted by such ASBA Bidder in which funds will be blocked by such SCSB to the extent of
the specified in the ASBA Form submitted by such ASBA Bidder and includes a bank account
maintained by a Retail Individual Investor linked to a UPI ID, which will be blocked by the
SCSB upon acceptance of the UPI Mandate Request in relation to a Bid by a Retail Individual
Investor Bidding through the UPI Mechanism
ASBA Bidders All Bidders except Anchor Investors
ASBA Form An application form, whether physical or electronic, used by ASBA Bidders to submit Bids
which will be considered as the application for Allotment in terms of the Red Herring
Prospectus and the Prospectus
Banker(s) to the Issue Collectively, the Escrow Collection Bank(s), Refund Bank(s), Sponsor Bank and Public Issue
Account Bank(s), as the case may be
Basis of Allotment Basis on which Equity Shares will be Allotted to successful Bidders under the Issue, as
described in “Issue Procedure” on page 647.
Bid An indication to make an issue during the Bid/Issue Period by an ASBA Bidder pursuant to
submission of the ASBA Form, or during the Anchor Investor Bidding Date by an Anchor
Investor, pursuant to submission of the Anchor Investor Application Form, to subscribe to or
purchase the Equity Shares at a price within the Price Band, including all revisions and
modifications thereto as permitted under the SEBI ICDR Regulations.
The term “Bidding” shall be construed accordingly.
Bid Amount The highest value of optional Bids indicated in the Bid cum Application Form and, in the case
of RIBs Bidding at the Cut off Price, the Cap Price multiplied by the number of Equity Shares
Bid for by such Retail Individual Bidder and mentioned in the Bid cum Application Form and
payable by the Bidder or blocked in the ASBA Account of the Bidder, as the case may be, upon
submission of the Bid.
Bidding Centres Centres at which the Designated Intermediaries shall accept the ASBA Forms, i.e., Designated
Branches for SCSBs, Specified Locations for the Syndicate, Broker Centres for Registered
Brokers, Designated RTA Locations for RTAs and Designated CDP Locations for CDPs
Bid cum Application Anchor Investor Application Form or the ASBA Form, as the context requires
Form
Bid Lot [●] Equity Shares of face value of ₹ 10 each and in multiples of [●] Equity Shares of face value
of ₹ 10 each thereafter
Bid/Issue Closing Date Except in relation to any Bids received from the Anchor Investors, the date after which the
Designated Intermediaries will not accept any Bids, which shall be notified in all editions of
[●] (a widely circulated English national daily newspaper), [●] editions of [●] (a widely
3Term Description
circulated Hindi national daily newspaper) and [●] editions of [●] (a widely circulated Gujarati
daily newspaper, Gujarati being the regional language of Gujarat, where our Registered Office
is located), and in case of any revision, the extended Bid/Issue Closing Date shall also be
widely disseminated by notification to the Stock Exchanges by issuing a press release and also
by indicating the change on the website of the BRLM and at the terminals of the Members of
the Syndicate and by intimation to the Designated Intermediaries and Sponsor Bank(s), as
required under the SEBI ICDR Regulations.
Our Company in consultation with the BRLM, may consider closing the Bid/Issue Period for
QIBs one Working Day prior to the Bid/Issue Closing Date, in accordance with the SEBI ICDR
Regulations.
Bid/ Issue Opening Date Except in relation to any Bids received from the Anchor Investors, the date on which the
Designated Intermediaries shall start accepting Bids, which shall be notified in all editions of
[●] (a widely circulated English national daily newspaper), [●] editions of [●] (a widely
circulated Hindi national daily newspaper) and [●] editions of [●] (a widely circulated Gujarati
daily newspaper, Gujarati being the regional language of Gujarat, where our Registered Office
is located), and in case of any revision, the extended Bid/ Issue Period also be widely
disseminated by notification to the Stock Exchanges by issuing a press release and also by
indicating the change on the website of the BRLM and at the terminals of the Members of the
Syndicate and by intimation to the Designated Intermediaries and Sponsor Bank(s), as required
under the SEBI ICDR Regulations.
Bid/ Issue Period Except in relation to Anchor Investors, the period between the Bid/ Issue Opening Date and the
Bid/ Issue Closing Date, inclusive of both days, during which Bidders (excluding Anchor
Investors) can submit their Bids, including any revisions thereof in accordance with the SEBI
ICDR Regulations and the terms of the Red Herring Prospectus.
Provided that the Bidding shall be kept open for a minimum of three Working Days for all
categories of Bidders, other than Anchor Investors.
Bidder / Applicant Any prospective investor who makes a Bid pursuant to the terms of the Red Herring Prospectus
and the Bid cum Application Form and unless otherwise stated or implied, includes an ASBA
Bidder and an Anchor Investor.
Book Building Process The book building process as described in Part A, Schedule XIII of the SEBI ICDR
Regulations, in terms of which the Issue is being made.
“Book Running Lead The book running lead manager to the Issue, namely Beeline Capital Advisors Private Limited
Manager” or “BRLM”
Broker Centre Broker centres notified by the Stock Exchanges where ASBA Bidders can submit the ASBA
Forms, provided that RIBs may only submit ASBA Forms at such broker centres if they are
Bidding using the UPI Mechanism, to a Registered Broker and details of which are available
on the websites of the respective Stock Exchanges. The details of such Broker Centres, along
with the names and the contact details of the Registered Brokers are available on the respective
websites of the Stock Exchanges (www.bseindia.com and www.nseindia.com) and updated
from time to time.
Bidding Centres Centres at which the Designated Intermediaries shall accept the Bid cum Application Forms,
i.e., Designated SCSB Branches for SCSBs, Specified Locations for Members of the Syndicate,
Broker Centres for Registered Brokers, Designated RTA Locations for RTAs and Designated
CDP Locations for CDPs.
CAN or Confirmation of The notice or advice or intimation of allocation of the Equity Shares sent to Anchor Investors
Allocation Note who have been allocated Equity Shares on / after the Anchor Investor Bidding Date.
Cap Price The higher end of the Price Band, i.e. ₹ [●] per Equity Share, above which the Issue Price and
the Anchor Investor Issue Price will not be finalised and above which no Bids will be accepted.
The Cap Price shall be at least 105% of the Floor Price and less than or equal to 120% of the
Floor Price.
Cash Escrow and Agreement to be entered among our Company, the BRLM, the Syndicate Members, the Bankers
Sponsor Bank to the Issue and Registrar to the Issue for, inter alia, collection of the Bid Amounts from Anchor
Agreement Investors, transfer of funds to the Public Issue Account and where applicable, refunds of the
amounts collected from Bidders, on the terms and conditions thereof
Client ID Client identification number maintained with one of the Depositories in relation to the Bidder’s
beneficiary account.
Collecting Depository A depository participant as defined under the Depositories Act, registered with SEBI and who
Participant or CDP is eligible to procure Bids at the Designated CDP Locations in terms of the SEBI RTA Master
Circular and UPI Circulars issued by the SEBI, as per the list available on the websites of the
Stock Exchanges, as updated from time to time
Cut-off Price The Issue Price, as finalised by our Company, in consultation with the BRLM which shall be
any price within the Price Band. Only Retail Individual Bidders under the Retail Portion are
entitled to Bid at the Cut-off Price. QIBs (including Anchor Investors) and Non-Institutional
Bidders are not entitled to Bid at the Cut-off Price
4Term Description
Cut-Off Time For all pending UPI Mandate Requests, the Sponsor Bank(s) shall initiate requests for blocking
of funds in the ASBA Accounts of relevant Bidders with a confirmation cutoff time of 5:00 pm
on after the Bid/Issue Closing Date.
Demographic Details Details of the Bidders including the Bidder’s address, name of the Bidder’s father/ husband,
investor status, occupation, PAN, DP ID, Client ID and bank account details and UPI ID, where
applicable.
Designated CDP Such locations of the CDPs where Bidders can submit the ASBA Forms, a list of which, along
Locations with names and contact details of the Collecting Depository Participants eligible to accept
ASBA Forms are available on the websites of the respective Stock Exchanges
(www.bseindia.com and www.nseindia.com) as updated from time to time.
Designated Date The date on which funds are transferred from the Escrow Account to the Public Issue Account
or the Refund Account, as appropriate, or the funds blocked by the SCSBs are transferred from
the ASBA Accounts to the Public Issue Account, as the case may be, in terms of the Red
Herring Prospectus and the Prospectus, after the finalisation of the Basis of Allotment in
consultation with the Designated Stock Exchange, following which the Board of Directors or
IPO Committee may Allot Equity Shares to successful Bidders in the Issue.
Designated In relation to ASBA Forms submitted by RIBs with an application size of up to ₹2.00 lakhs and
Intermediaries Non-Institutional Bidders Bidding with an application size of up to ₹5.00 lakhs (not using the
UPI mechanism) by authorising an SCSB to block the Bid Amount in the ASBA Account,
Designated Intermediaries shall mean SCSBs.
In relation to ASBA Forms submitted by UPI Bidders where the Bid Amount will be blocked
upon acceptance of UPI Mandate Request by such UPI Bidders using the UPI Mechanism,
Designated Intermediaries shall mean Syndicate, sub-syndicate/agents, Registered Brokers,
CDPs, SCSBs and RTAs.
In relation to ASBA Forms submitted by QIBs and Non-Institutional Bidders, Designated
Intermediaries shall mean Syndicate, Sub-Syndicate/ agents, SCSBs, Registered Brokers, the
CDPs and RTAs.
Designated RTA Such locations of the RTAs where Bidders can submit the ASBA Forms to RTAs, a list of
Locations which, along with names and contact details of the RTAs eligible to accept ASBA Forms are
available on the respective websites of the Stock Exchanges (www.bseindia.com and
www.nseindia.com) and updated from time to time.
Designated SCSB Such branches of the SCSBs which shall collect ASBA Forms, a list of which is available on
Branches the website of the SEBI at
https://www.sebi.gov.in/sebiweb/other/OtherAction.do?doRecognisedFpi=yes&intmId=35
and
https://www.sebi.gov.in/sebiweb/other/OtherAction.do?doRecognisedFpi=yes&intmId=34,
updated from time to time, and at such other websites as may be prescribed by SEBI from time
to time.
Designated Stock [●]
Exchange
Draft Red Herring This draft red herring prospectus dated September 29, 2025, issued in accordance with the SEBI
Prospectus or DRHP ICDR Regulations, which does not contain complete particulars of the Issue, including the price
at which the Equity Shares will be Allotted and the size of the Issue, and includes any addenda
or corrigenda thereto.
Eligible FPIs FPIs that are eligible to participate in the Issue in terms of applicable law and from such
jurisdictions outside India where it is not unlawful to make an issue/ invitation under the Issue
and in relation to whom the Bid cum Application Form and the Red Herring Prospectus
constitutes an invitation to purchase the Equity Shares issued thereby.
Eligible NRIs NRI(s) eligible to invest under the relevant provisions of the FEMA Rules, on a non-repatriation
basis, from jurisdictions outside India where it is not unlawful to make an issue or invitation
under the Issue and in relation to whom the Bid cum Application Form and the Red Herring
Prospectus will constitute an invitation to purchase the Equity Shares
Escrow Account(s) Accounts opened with the Escrow Collection Bank(s) and in whose favour Anchor Investors
will transfer money through direct credit/ NEFT/ RTGS/NACH in respect of Bid Amounts
when submitting a Bid
Escrow Collection The banks which are clearing members and registered with SEBI as Bankers to an issue under
Bank(s) the BTI Regulations, and with whom the Escrow Account(s) will be opened, in this case being
[●]
First Bidder The Bidder whose name shall be mentioned in the Bid cum Application Form or the Revision
Form and in case of joint Bids, whose name shall also appear as the first holder of the
beneficiary account held in joint names
Fraudulent Borrower Fraudulent borrower as defined under Regulation 2(1) (lll) of the SEBI ICDR Regulations
Fugitive Economic A fugitive economic offender as defined under the Fugitive Economic Offenders Act, 2018
Offender
5Term Description
Floor Price The lower end of the Price Band, i.e. ₹ [●] subject to any revision(s) thereto, at or above which
the Issue Price and the Anchor Investor Issue Price will be finalised and below which no Bids,
will be accepted
Issue Initial public offering of upto 54,00,000 Equity Shares at ₹ [●] per Equity Share (including a
premium of ₹ [●] per Equity Share) aggregating up to ₹ [●] lakhs by our Company.
For further information, see “The Issue” on page 89.
General Information The General Information Document for investing in public issues, prepared and issued in
Document or GID accordance with the SEBI circular no. SEBI/HO/CFD/DIL1/CIR/P/2020/37 dated March 17,
2020, and the UPI Circulars, as amended from time to time. The General Information Document
shall be available on the websites of the Stock Exchanges and the BRLM
Gross Proceeds The Issue proceeds from the Issue
Issue Agreement The agreement dated September 29, 2025 amongst our Company and the BRLM, pursuant to
the SEBI ICDR Regulations, based on which certain arrangements are agreed to in relation to
the Issue
Issue Price The final price at which Equity Shares will be Allotted to successful ASBA Bidders in terms
of the Red Herring Prospectus which will be decided by our Company, in consultation with the
BRLM, on the Pricing Date, in accordance with the Book-Building Process and in terms of the
Red Herring Prospectus. Equity Shares will be Allotted to Anchor Investors at the Anchor
Investor Issue Price, which will be decided by our Company, in consultation with the BRLM,
on the Pricing Date, in accordance with the Book-Building Process and in terms of the Red
Herring Prospectus.
Mutual Fund Mutual funds registered with SEBI under the Securities and Exchange Board of India (Mutual
Funds) Regulations, 1996
Mutual Fund Portion Up to 5% of the Net QIB Portion, or [●] Equity Shares of face value of ₹ 10 each, which shall
be available for allocation to Mutual Funds only, on a proportionate basis, subject to valid Bids
being received at or above the Issue Price.
Net Proceeds The Gross Proceeds less Issue-related expenses applicable to the Issue. For further details about
use of the Net Proceeds and the Issue related expenses, see “Objects of the Issue” on page 357
Net QIB Portion QIB Portion, less the number of Equity Shares Allotted to the Anchor Investors
Non-Institutional All Bidders, that are not QIBs or Retail Individual Bidders and who have Bid for Equity Shares
Investors or NII(s) or for an amount of more than ₹ 2.00 lakhs (but not including NRIs other than Eligible NRIs)
Non-Institutional
Bidders or NIB(s)
Non-Institutional The portion of the Issue being not less than 15% of the Issue comprising of [●] Equity Shares
Portion of face value of ₹ 10 each which shall be available for allocation to NIIs in accordance with the
SEBI ICDR Regulations, to Non-Institutional Bidders, subject to valid Bids being received at
or above the Issue Price.
The allocation to the NIIs shall be as follows:
a) One-third of the Non-Institutional Portion shall be reserved for applicants with an
application size of more than ₹2.00 lakhs and up to ₹10.00 lakhs; and
b) Two-thirds of the Non-Institutional Portion shall be reserved for applicants with an
application size of more than ₹10.00 lakhs.
Provided that the unsubscribed portion in either of the sub-categories specified in clauses (a) or
(b), may be allocated to applicants in the other sub-category of non-institutional investors
Non-Resident or NR A person resident outside India, as defined under FEMA
Price Band Price band of a minimum price of ₹ [●] per Equity Share (Floor Price) and the maximum price
of ₹ [●] per Equity Share (Cap Price) and includes any revisions thereof.
The Price Band and the minimum Bid Lot for the Issue will be decided by our Company in
consultation with the Book Running Lead Manager, which shall be notified in all editions of
[●] (a widely circulated English national daily newspaper), [●] editions of [●] (a widely
circulated Hindi national daily newspaper) and [●] editions of [●] (a widely circulated Gujarati
daily newspaper, Gujarati being the regional language of Gujarat, where our Registered Office
is located), each with a wide circulation, at least two Working Days prior to the Bid/Issue
Opening Date, with the relevant financial ratios calculated at the Floor price and at the Cap
Price, and shall be available to the Stock Exchanges for the purpose of uploading on their
respective websites.
Pricing Date The date on which our Company and in consultation with the BRLM, will finalise the Issue
Price
Prospectus The prospectus to be filed with the RoC, in accordance with the Companies Act, 2013 and the
SEBI ICDR Regulations containing, amongst other things, the Issue Price that is determined at
the end of the Book Building Process, the size of the Issue and certain other information,
including any addenda or corrigenda thereto
6Term Description
Public Issue Account The banks which are clearing members and registered with SEBI under the BTI Regulations,
Bank(s) with whom the Public Issue Account(s) will be opened for collection of Bid Amounts from
Escrow Account(s) and ASBA Accounts on the Designated Date, in this case being [●].
Public Issue Account(s) Bank account to be opened in accordance with the provisions of the Companies Act, 2013, with
the Public Issue Account Bank(s) to receive money from the Escrow Accounts and from the
ASBA Accounts on the Designated Date.
QIB Portion The portion of the Issue (including the Anchor Investor Portion) being not more than 50% of
the Issue, consisting of [●] Equity Shares of face value of ₹ 10 each which shall be allocated to
QIBs, including the Anchor Investors (which allocation shall be on a discretionary basis, as
determined by our Company and in consultation with the BRLM up to a limit of 60% of the
QIB Portion) subject to valid Bids being received at or above the Issue Price or Anchor Investor
Issue Price.
Qualified Institutional A qualified institutional buyer, as defined under Regulation 2(1)(ss) of the SEBI ICDR
Buyers” or “QIBs” Regulations. However, non-residents which are FVCIs and multilateral and bilateral
development financial institutions are not permitted to participate in the Issue.
Red Herring Prospectus The red herring prospectus, including any corrigenda or addenda thereto, to be issued in
or RHP accordance with Section 32 of the Companies Act, 2013 and the provisions of SEBI ICDR
Regulations, which will not have complete particulars of the price at which the Equity Shares
will be issue and the size of the Issue, including any addenda or corrigenda thereto. The red
herring prospectus will be filed with the RoC at least three working days before the Bid/ Issue
Opening Date and will become the Prospectus upon filing with the RoC after the Pricing Date.
Refund Account(s) The ‘no-lien’ and ‘non-interest bearing’ account to be opened with the Refund Bank, from
which refunds, if any, of the whole or part, of the Bid Amount to the Anchor Investors shall be
made
Refund Bank(s) The Banker(s) to the Issue with whom the Refund Account(s) will be opened, in this case being
[●].
Registered Broker Stock brokers registered with the stock exchanges having nationwide terminals other than the
members of the Syndicate, and eligible to procure Bids in terms of the circular No.
CIR/CFD/14/2012 dated October 4, 2012 issued by SEBI
Registrar Agreement The agreement dated September 29, 2025, entered amongst our Company and the Registrar to
the Issue in relation to the responsibilities and obligations of the Registrar to the Issue pertaining
to the Issue
Registrar and Share Registrar and share transfer agents registered with SEBI and eligible to procure Bids at the
Transfer Agents or Designated RTA Locations as per the lists available on the website of BSE and NSE, and the
RTAs UPI Circulars
Registrar, or Registrar to The Registrar to the Issue namely MUFG Intime India Private Limited (formerly Link Intime India
the Issue Private Limited)
Resident Indian A person resident in India, as defined under FEMA
Retail Individual Individual Bidders (including HUFs applying through their Karta and Eligible NRIs and does
Bidders or RIB(s) or not include NRIs other than Eligible NRIs) who have Bid for the Equity Shares for an amount
Retail Individual not more than ₹2.00 lakhs in any of the Bidding options in the Issue
Investors or RII(s)
Retail Portion The portion of the Issue being not less than 35% of the Issue consisting of [●] Equity Shares of
face value of ₹ 10 each which shall be available for allocation to Retail Individual Bidders in
accordance with the SEBI ICDR Regulations, subject to valid Bids being received at or above
the Issue Price
Revision Form Form used by the Bidders to modify the quantity of the Equity Shares or the Bid Amount in
any of their ASBA Form(s) or any previous Revision Form(s), as applicable.
QIB Bidders and Non Institutional Investors are not allowed to withdraw or lower their Bids
(in terms of quantity of Equity Shares or the Bid Amount) at any stage.
SCORES Securities and Exchange Board of India Complaints Redress System, a centralized web based
complaints redressal system launched by SEBI vide circular no. CIR/OIAE/1/2014 dated
December 18, 2014
Self-Certified Syndicate The banks registered with SEBI, issuing services: (a) in relation to ASBA (other than using the
Bank(s) or SCSB(s) UPI Mechanism), a list of which is available on the website of SEBI at
https://www.sebi.gov.in/sebiweb/other/OtherAction.do?doRecognisedFpi=yes&intmId=34
and
https://www.sebi.gov.in/sebiweb/other/OtherAction.do?doRecognisedFpi=yes&intmId=35,
as applicable or such other website as may be prescribed by SEBI from time to time; and (b)
in relation to ASBA (using the UPI Mechanism), a list of which is available on the website of
SEBI at
https://www.sebi.gov.in/sebiweb/other/OtherAction.do?doRecognisedFpi=yes&intmId=40,
or such other website as may be prescribed by SEBI from time to time.
Applications through UPI in the Issue can be made only through the SCSBs mobile applications
(apps) whose name appears on the SEBI website. A list of SCSBs and mobile application,
7Term Description
which, are live for applying in public issues using UPI Mechanism is provided as Annexure
‘A’ to the SEBI circular number SEBI/HO/CFD/DIL2/CIR/P/2019/85 dated July 26, 2019. The
said list is available on the website of SEBI at
https://www.sebi.gov.in/sebiweb/other/OtherAction.do?doRecognisedFpi=yes&intmId=43, as
updated from time to time.
Specified Locations The Bidding centres where the Syndicate shall accept Bid cum Application Forms from relevant
Bidders, a list of which is available on the website of SEBI (www.sebi.gov.in) and updated
from time to time.
Sponsor Bank(s) The Banker(s) to the Issue registered with SEBI which is appointed by the Company to act as
a conduit between the Stock Exchanges and the National Payments Corporation of India in
order to push the UPI Mandate Requests and / or payment instructions of the RIBs using the
UPI Mechanism and carry out any other responsibilities in terms of the UPI Circulars, in this
case being [●].
Stock Exchanges Collectively, BSE Limited and the National Stock Exchange of India Limited
Syndicate Agreement Agreement to be entered into among our Company, the BRLM, and the Syndicate Members in
relation to collection of Bid cum Application Forms by Syndicate
Syndicate Members Intermediaries (other than BRLM) registered with SEBI who are permitted to accept bids,
applications and place orders with respect to the Issue and carry out activities as an underwriter
namely, [●]
Syndicate or members of Together, the BRLM and the Syndicate Members
the Syndicate
Systemically Important Systemically important non-banking financial company as defined under Regulation 2(1)(iii)
Non-Banking Financial of the SEBI ICDR Regulations
Company or NBFC-SI
Underwriters [●]
Underwriting The agreement to be entered into amongst the Underwriters and our Company on or after the
Agreement Pricing Date, but prior to filing of the Prospectus
UPI Unified Payments Interface, which is an instant payment mechanism developed by NPCI
UPI Bidders Collectively, individual investors applying as RIBs in the Retail Portion, and individuals
applying as Non-Institutional Investors with a Bid Amount of up to ₹ 5.00 lakhs in the Non-
Institutional Portion, and Bidding under the UPI Mechanism through ASBA Form(s) submitted
with Syndicate Members, Registered Brokers, Collecting Depository Participants and Registrar
and Share Transfer Agents.
Pursuant to SEBI circular no. SEBI/HO/CFD/DIL2/P/CIR/P/2022/45 dated April 5, 2022, all
individual investors applying in public issues where the application amount is up to ₹ 5.00 lakhs
shall use UPI and shall provide their UPI ID in the bid-cum-application form submitted with:
(i) a syndicate member, (ii) a stock broker registered with a recognized stock exchange (whose
name is mentioned on the website of the stock exchange as eligible for such activity), (iii) a
depository participant (whose name is mentioned on the website of the stock exchange as
eligible for such activity), and (iv) a registrar to an issue and share transfer agent (whose name
is mentioned on the website of the stock exchange as eligible for such activity).
UPI Circulars SEBI circular number SEBI/HO/CFD/DIL2/CIR/P/2019/85 dated July 26, 2019, SEBI RTA
Master Circular (to the extent it pertains to UPI), SEBI circular no. SEBI/HO/CFD/PoD-
1/P/CIR/2024/0154 dated November 11, 2024 along with the circular issued by the National
Stock Exchange of India Limited having reference no. 23/ 2022 dated July 22, 2022and having
reference no. 25/2022 dated August 3, 2022 and the circular issued by BSE Limited having
reference no. 20220702-30 dated July 22, 2022, and having reference no. 20220803-40 dated
August 3, 2022 and any subsequent circulars or notifications issued by SEBI and Stock
Exchanges in this regard.
UPI ID ID created on UPI for single-window mobile payment system developed by the NPCI
UPI Mandate Request A request (intimating the UPI Bidder by way of a notification on the UPI application, by way
of a SMS directing the UPI Bidder to such UPI application) to the UPI Bidder initiated by the
Sponsor Bank to authorise blocking of funds on the UPI application equivalent to Bid Amount
and subsequent debit of funds in case of Allotment
UPI Mechanism The Bidding mechanism that may be used by a UPI Bidder to make a Bid in the Issue in
accordance with the UPI Circulars
UPI PIN Password to authenticate UPI transaction
Wilful Defaulter or Wilful defaulter or a fraudulent borrower as defined under Regulation 2(1)(III) of the SEBI
Fraudulent Borrower ICDR Regulations.
Working Day All days, on which commercial banks in Ahmedabad are open for business; provided however,
with reference to (a) announcement of Price Band; and (b) Bid/Issue Period, Working Day shall
mean all days except all Saturdays, Sundays and public holidays on which commercial banks
in Ahmedabad are open for business and (c) the time period between the Bid/Issue Closing
Date and the listing of the Equity Shares on the Stock Exchanges, “Working Day” shall mean
8Term Description
all trading days of Stock Exchanges, excluding Sundays and bank holidays in India, as per the
circulars issued by SEBI, including the SEBI UPI Circulars
Technical/ Industry Related Terms
Term Description
ACML Arihant Capital Markets Limited
ADTO Average daily turnover
AIF Alternative Investment Funds
Algorithms Computer programs and pre-defined instructions
AMC Annual maintenance fees
AMRUT Atal Mission for Rejuvenation and Urban Transformation
ARPC Average revenue per customer
ARN AMFI Registration Number
AUM Asset Under Management
B30 Beyond Top 30
BSE Bombay Stock Exchange
CAD Current Account Deficit
Capex Capital Expenditure
CareEdge Ratings CARE Ratings Limited
CareEdge Research CARE Analytics and Advisory Private Limited
CTT Commodities Transaction Tax
CY Calendar Year
DBT Direct Benefit Transfer
DFI Development Finance Institution
DIIs Domestic Institutional Investors
DPI Digital Payments Index
DTA Domestic Tariff Area
EDS Equity Derivatives Segments
ELM Extreme Loss Margin
EUIN Employee Unique Identification
F&O Future and Options
FDI Foreign Direct Investment
FDs Fixed Deposits
FIIs Foreign Institutional Investors
FLC Financial Literacy Centre
FLEI Financial Literacy and Education Initiative
FPI Foreign Portfolio Investor
FPIs Foreign Portfolio Investments
FPOs Follow-On Public Offerings
FY Fiscal Year
GIFT City Gujarat International Finance Tec-City
GNDI Gross National Disposable Income
HNI High Net-worth Individual
IFSC International Financial Servies Centre
IFSCA International Financial Services Centres Authority
INVITs Infrastructure Investment Trusts
IPOs Initial Public Offerings
IPPs Institutional Placement Programmes
JAM Jan Dhan-Aadhaar-Mobile
MCX Multi Commodity Exchange
MF Mutual Fund
MFDs Mutual Fund Distributors
MIIs Market Infrastructure Institutions
MTF Margin Trading Funding
NCDEX National Commodity and Derivatives Exchange
NCFE National Centre for Financial Education
NMP National Monetization Pipeline
9Term Description
NSE National Stock Exchange
OFS Offer for Sale
PFCE Private Final Consumption Expenditure
PMJDY Pradhan Mantri Jan Dhan Yojna
PMS Portfolio Management Services
QIPs Qualified Institutional Placements
QSB Qualified Stock Broker
REITs Real Estate Investment Trusts
RMs Relationship Managers
SEBI Securities and Exchange Board of India
SEZ Special Economic Zones
SIHL Shah Investor’s Home Limited
SIPs Systematic Investments Plans
SISL Share India Securities Limited
SLBM Securities Lending and Borrowing Mechanism
SMC Global SMC Global Securities Limited
STT Securities Transaction Tax
T30 Top 30
Conventional and General Terms or Abbreviations
Term Description
“₹” or “Rs.” or Indian Rupees
“Rupees” or “INR”
A/c Account
AGM Annual general meeting
AIF An alternative investment fund as defined in and registered with SEBI under the SEBI AIF
Regulations
BSE BSE Limited
CAGR Compounded Annual Growth Rate
Calendar Year / year Unless the context otherwise requires, shall refer to the twelve-month period ending December
31
CDSL Central Depository Services (India) Limited
CIN Corporate Identity Number
Companies Act, 1956 Companies Act, 1956, and the rules, regulations, notifications, modifications and clarifications
made thereunder, as the context requires
Companies Act, 2013 Companies Act, 2013 and the rules, regulations, notifications, modifications and clarifications
/ Companies Act thereunder
Consolidated FDI The consolidated FDI Policy, effective from October 15, 2020, issued by the DPIIT, and any
Policy amendments or substitutions thereof, issued from time to time
Contract Labour Act The Contract Labour (Regulation and Abolition) Act, 1970.
CSR Corporate social responsibility
Demat Dematerialised
Depositories Act Depositories Act, 1996 read with the rules and regulations thereunder
Depository / NSDL and CDSL
Depositories
DIN Director Identification Number
DP ID Depository Participant’s Identification Number
DP / Depository A depository participant as defined under the Depositories Act
Participant
DPIIT The Department for Promotion of Industry and Internal Trade, Ministry of Commerce and
Industry, Government of India
EBITDA Earnings before interest, tax, depreciation and amortisation
EGM Extraordinary general meeting
EPS Earnings per share
FAQs Frequently asked questions
FCNR Foreign currency non-resident account
FDI Foreign direct investment
FDI Circular or The Consolidated Foreign Direct Investment Policy bearing DPIIT file number 5(2)/2020-FDI
Consolidated FDI Policy dated October 15, 2020, issued by the Department of Promotion of Industry and Internal
Policy Trade, Ministry of Commerce and Industry, Government of India, and any modifications thereto
or substitutions thereof, issued from time to time
FEMA Foreign Exchange Management Act, 1999, including the rules and regulations thereunder
10Term Description
FEMA Rules Foreign Exchange Management (Non-debt Instruments) Rules, 2019
Financial Year / Period of twelve months ending on March 31 on that particular year, unless stated otherwise
Fiscal / FY / F.Y.
FI Financial institutions
FPI(s) A foreign portfolio investor who has been registered pursuant to the SEBI FPI Regulations
FVCI Foreign Venture Capital Investors (as defined under the Securities and Exchange Board of India
(Foreign Venture Capital Investors) Regulations, 2000) registered with SEBI
FVCI Regulations Securities and Exchange Board of India (Foreign Venture Capital Investor) Regulations, 2000
Fugitive Economic An individual who is declared a fugitive economic offender under Section 12 of the Fugitive
Offender Economic Offenders Act, 2018.
GDP Gross domestic product
Central Government / Government of India
GoI
GST Goods and service tax
HUF Hindu undivided family
IT Act The Information Technology Act, 2000
I.T. Act The Income Tax Act, 1961
ICAI The Institute of Chartered Accountants of India
IFRS International Financial Reporting Standards of the International Accounting Standards Board
Ind AS Accounting Standards notified under Section 133 of the Companies Act, 2013 read with the
Companies (Indian Accounting Standards) Rules, 2015, as amended and other relevant
provisions of the Companies Act, 2013
Ind AS Rules Companies (Indian Accounting Standards) Rules, 2015
Indian GAAP Generally Accepted Accounting Principles in India, being, accounting principles generally
accepted in India including the accounting standards specified under Section 133 of the
Companies Act, 2013 read with Rule 7 of the Companies (Accounts) Rules, 2014, as amended
IRDAI Insurance Regulatory and Development Authority of India
IT Information technology
MCA Ministry of Corporate Affairs, Government of India
MCLR Marginal cost of fund-based lending rate
Mn / mn Million
MCA Ministry of Corporate Affairs, Government of India
N.A / NA Not applicable
NACH National Automated Clearing House
National Investment National Investment Fund set up by resolution F. No. 2/3/2005-DD-II dated November 23, 2005
Fund of the GoI, published in the Gazette of India
NAV Net asset value
NBFC Non-Banking Financial Companies
NBFC - SI Systemically important non-banking financial company as defined under Regulation 2(1)(iii) of
the SEBI ICDR Regulations.
NCLT National Company Law Tribunal
NEFT National electronic fund transfer
Negotiable The Negotiable Instruments Act, 1881
Instruments Act
Non-Resident A person resident outside India, as defined under FEMA
NPCI National payments corporation of India
NRE Account Non-resident external account established in accordance with the Foreign Exchange
Management (Deposit) Regulations, 2016
NRI/ Non-Resident A person resident outside India who is a citizen of India as defined under the Foreign Exchange
Indian Management (Deposit) Regulations, 2016 or is an ‘Overseas Citizen of India’ cardholder within
the meaning of section 7(A) of the Citizenship Act, 1955
NRO Account Non-resident ordinary account established in accordance with the Foreign Exchange
Management (Deposit) Regulations, 2016
NSDL National Securities Deposit Limited
NSE National Stock Exchange of India Limited
OCB/ Overseas A company, partnership, society or other corporate body owned directly or indirectly to the
Corporate Body extent of at least 60% by NRIs including overseas trusts in which not less than 60% of the
beneficial interest is irrevocably held by NRIs directly or indirectly and which was in existence
on October 3, 2003, and immediately before such date had taken benefits under the general
permission granted to OCBs under the FEMA. OCBs are not allowed to invest in the issue
p.a. Per annum
P/E Ratio Price/earnings ratio
PAN Permanent account number allotted under the I.T. Act
PAT Profit After Tax
R&D Research and development
11Term Description
RBI Reserve Bank of India
Regulation S Regulation S under the U.S. Securities Act
RONW Return on net worth
Rs. / Rupees/ ₹ / INR Indian Rupees
RTGS Real time gross settlement
SCORES SEBI Complaints Redress System
SCRA Securities Contracts (Regulation) Act, 1956
SCRR Securities Contracts (Regulation) Rules, 1957
SEBI Securities and Exchange Board of India constituted under the SEBI Act
SEBI Act Securities and Exchange Board of India Act, 1992
SEBI AIF Securities and Exchange Board of India (Alternative Investment Funds) Regulations, 2012
Regulations
SEBI RTA Master SEBI master circular bearing number SEBI/HO/MIRSD/POD-1/P/CIR/2024/37 dated May 7,
Circular 2024, to the extent it pertains to UPI
SEBI BTI Securities and Exchange Board of India (Bankers to an Issue) Regulations, 1994
Regulations
SEBI FPI Securities and Exchange Board of India (Foreign Portfolio Investors) Regulations, 2019
Regulations
SEBI ICDR Mater SEBI master circular no. SEBI/HO/MIRSD/MIRSD-PoD-1/P/CIR/2024/53 dated May 22,
Circular for Brokers 2024
SEBI ICDR Master SEBI master circular no. SEBI/HO/CFD/PoD-1/P/CIR/2024/0154 dated November 11, 2024
Circular
SEBI FVCI Securities and Exchange Board of India (Foreign Venture Capital Investors) Regulations, 2000
Regulations
SEBI ICDR Securities and Exchange Board of India (Issue of Capital and Disclosure Requirements)
Regulations Regulations, 2018
SEBI Insider Trading Securities and Exchange Board of India (Prohibition of Insider Trading) Regulations, 2015
Regulations
SEBI Listing Securities and Exchange Board of India (Listing Obligations and Disclosure Requirements)
Regulations Regulations, 2015
SEBI Merchant Securities and Exchange Board of India (Merchant Bankers) Regulations, 1992
Bankers Regulations
SEBI Mutual Funds Securities and Exchange Board of India (Mutual Funds) Regulations, 1996
Regulations
SEBI Takeover Securities and Exchange Board of India (Substantial Acquisition of Shares and Takeovers)
Regulations Regulations, 2011
SEBI SBEB Securities and Exchange Board of India (Share Based Employee Benefits and Sweat Equity)
Regulations Regulations, 2021
SEBI VCF Securities and Exchange Board of India (Venture Capital Fund) Regulations, 1996 as repealed
Regulations pursuant to SEBI AIF Regulations
Specified Securities Equity shares and/or convertible securities
State Government Government of a state of India
Stock Exchanges Collectively, the BSE and NSE
STT Securities transaction tax
TAN Tax deduction account number
TDS Tax deducted at source
U.S. Securities Act United States Securities Act of 1933, as amended
US GAAP Generally Accepted Accounting Principles in the United States of America
USA/ U.S/ US The United States of America
USD/ US$/ $ United States Dollars
VAT Value added tax
VCFs Venture capital funds as defined in, and registered with SEBI under, the SEBI VCF Regulations
12CERTAIN CONVENTIONS, PRESENTATION OF FINANCIAL, INDUSTRY AND MARKET DATA
AND CURRENCY OF PRESENTATION
Certain Conventions
All references to “India” in this Draft Red Herring Prospectus are to the Republic of India and its territories and
possessions and all references herein to the “Government”, “Indian Government”, “GoI”, “Central Government”
or the “State Government” are to the Government of India, central or state, as applicable. All references in this
Draft Red Herring Prospectus to the “U.S.”, “USA” or “United States” are to the United States of America and its
territories and possessions.
Unless otherwise specified, any time mentioned in this Draft Red Herring Prospectus is in Indian Standard Time
(“IST”). Unless indicated otherwise, all references to a year in this Draft Red Herring Prospectus are to a calendar
year.
Unless stated otherwise, all references to page numbers in this Draft Red Herring Prospectus are to the
corresponding page numbers of this Draft Red Herring Prospectus.
Financial Data
Our Company’s Financial Year commences on April 1 and ends on March 31 of the next year. Accordingly, all
references in this Draft Red Herring Prospectus to a particular Financial Year or FY or Fiscal, unless stated
otherwise, are to the 12-month period ended on March 31 of that particular calendar year.
Unless stated otherwise or the context otherwise requires, the financial data and financial ratios in this Draft Red
Herring Prospectus are derived from the Restated Consolidated Financial Information of our Company.
The Restated Consolidated Financial Information of our Company and its Subsidiaries which comprise of the
Restated Statement of Assets and Liabilities as at financial years ended March 31, 2025, March 31, 2024 and
March 31, 2023, the Restated Statement of Profit and Loss (including Other Comprehensive Income, as
applicable) and the Restated Statement of Cash Flows for the financial years ended March 31, 2025, March 31,
2024 and March 31, 2023 and the Restated Statement of Changes in Equity for the financial years ended March
31, 2025, March 31, 2024 and March 31, 2023 and the summary of material accounting policies and other
explanatory notes to the Restated Consolidated Financial Information and included in “Financial Information” on
page 503.
Our Restated Consolidated Financial Information have been prepared in accordance with Ind AS. There are
significant differences between International Financial Reporting Standards (“IFRS”) and Generally Accepted
Accounting Principles in the United States of America (“U.S. GAAP”). The degree to which the financial
information included in this Draft Red Herring Prospectus will provide meaningful information is entirely
dependent on the reader’s level of familiarity with Indian accounting policies and practices, Ind AS, the
Companies Act 2013, the SEBI ICDR Regulations and the Guidance Note on Reports in Company Prospectuses
(Revised 2019) issued by the Institute of Chartered Accountants of India. Accordingly, any reliance by persons
not familiar with Ind AS, the Companies Act 2013, the SEBI ICDR Regulations, the Guidance Note on Reports
in Company Prospectuses (Revised 2019) issued by the ICAI and practices on the financial disclosures presented
in this Draft Red Herring Prospectus should accordingly be limited. We have not attempted to quantify the impact
of IFRS or U.S. GAAP on the financial information included in this Draft Red Herring Prospectus, nor do we
provide a reconciliation of our financial information to those under U.S. GAAP or IFRS and we urge you to
consult your own advisors regarding such differences and their impact on our financial information. For details in
connection with risks involving differences between Ind AS, U.S. GAAP and IFRS see “Risk Factors - Significant
differences exist between Ind AS and other accounting principles, such as U.S. GAAP and IFRS, which may be
material to the Restated Consolidated Financial Information prepared and presented in accordance with SEBI
ICDR Regulations contained in this Draft Red Herring Prospectus” on page 82.
Certain figures contained in this Draft Red Herring Prospectus, including financial information, have been subject
to rounding adjustments. All decimals, including percentages, have been rounded off to two decimal points. In
certain instances, (i) the sum or percentage change of such numbers may not conform exactly to the total figure
given; and (ii) the sum of the numbers in a column or row in certain tables may not conform exactly to the total
figure given for that column or row. However, where any figures that may have been sourced from third-party
industry sources are rounded off to other than two decimal points in their respective sources, such figures appear
in this Draft Red Herring Prospectus as rounded off to such number of decimal points as provided in their
respective sources.
Non-Generally Accepted Accounting Principles Financial Measures
13In evaluating our business, we consider and use non-GAAP financial measures and key performance indicators,
including Revenue from operation, Growth in Revenue from Operations (%), EBITDA, EBITDA Margin (%),
EBIT, EBIT Margin (%) , Profit before Tax, Profit After Tax, Profit After Tax Margin (%), Net Worth, RoE (%),
RoCE (%) , Debt to Equity Ratio, which have been included in this Draft Red Herring Prospectus. The presentation
of these non-GAAP financial measures and key performance indicators is not intended to be considered in
isolation or as a substitute for the financial information prepared and presented in accordance with Ind AS. We
present these non-GAAP financial measures and key performance indicators because they are used by our
management to evaluate our operating performance and formulate business plans.
These non-GAAP financial measures are not defined under Ind AS and are not presented in accordance with Ind
AS. The non-GAAP financial measures and key performance indicators have limitations as analytical tools.
Further, these non-GAAP financial measures and key performance indicators may differ from the similar
information used by other companies, including peer companies, and therefore their comparability may be limited.
Therefore, these metrics should not be considered in isolation or construed as an alternative to profit before tax,
net earned premiums, gross earned premiums or any other measure of performance or as an indicator of our
operating performance, liquidity or profitability or results of operations. In addition, non-GAAP financial
measures used are not a standardised term, hence a direct comparison of non-GAAP financial measures between
companies may not be possible. Other companies may calculate non-GAAP financial measures differently from
us, limiting its usefulness as a comparative measure. For further details, see “Risk Factor - Certain non-GAAP
financial measures and certain other statistical information relating to our operations and financial performance
such as EBITDA, EBITDA margin, interest coverage ratio, net debt to EBITDA ratio, return on capital employed
and return on equity have been included in this Draft Red Herring Prospectus. These non-GAAP financial
measures are not measures of operating performance or liquidity defined by Ind AS and may not be comparable.”
on page 78, respectively.
Currency and Units of Presentation
All references to “Rupee(s)”, “Rs.”, “₹” or “INR” are to Indian Rupees, the official currency of the Republic of
India. All references to “$”, “US$”, “U.S. Dollars” or “USD” are to United States Dollars, the official currency
of the United States of America.
All the figures in this Draft Red Herring Prospectus have been presented in lakhs or in whole numbers where the
numbers have been too small to present in lakhs, unless stated otherwise. One lakhs represents 1,00,000 and one
crore represents 1,00,00,000.
Certain figures contained in this Draft Red Herring Prospectus, including financial information, have been subject
to rounding adjustments. All figures in decimals have been rounded off to the second decimal. In certain instances,
(i) the sum or percentage change of such numbers may not conform exactly to the total figure given, and (ii) the
sum of the figures in a column or row in certain tables may not conform exactly to the total figure given for that
column or row. However, figures sourced from third-party industry sources may be expressed in denominations
other than lakh or may be rounded off to other than two decimal points in the respective sources, and such figures
have been expressed in this Draft Red Herring Prospectus in such denominations or rounded-off to such number
of decimal points as provided in such respective sources.
Exchange Rates
This Draft Red Herring Prospectus contains conversion of certain other currency amounts into Indian Rupees that
have been presented solely to comply with the SEBI ICDR Regulations. These conversions should not be
construed as a representation that these currency amounts could have been, or can be converted into Indian Rupees,
at any particular rate or at all.
The following table sets forth, for the periods indicated, information with respect to the exchange rate between
the Rupee and the other currencies used in the Draft Red Herring Prospectus:
(in ₹)
Exchange rate as on*
Currency
March 31, 2025 March 31, 2024 March 31, 2023
USD 85.58 83.37 82.21
#Source: www.fbil.org.in
Note: Exchange rate is rounded off to two decimal point
*In the event that any of the aforementioned date is a public holiday, the previous calendar day not being a public holiday has been considered.
The exchange rate is rounded off to two decimal places.
Industry and market Data
14Unless stated otherwise, information pertaining to the industry in which our Company operates in, contained in
this Draft Red Herring Prospectus is derived from the “CARE Report” which has been exclusively commissioned
and paid for by our Company, pursuant to an engagement agreement dated April 16, 2025, for the purpose of
understanding the industry in connection with this Issue, since no report is publicly available which provides a
comprehensive industry analysis, particularly for our Company’s services, that may be similar to the CARE
Report. This Draft Red Herring Prospectus contains certain data and statistics from the CARE Report, which is
available on the website of our Company www.sihl.in
CARE Analytics & Advisory Private Limited is an independent agency which has no relationship with our
Company, our Promoters, any of our Directors, Key Managerial Personnel, Senior Management Personnel or the
Book Running Lead Manager.
Industry publications generally state that the information contained in such publications has been obtained from
publicly available documents from various sources believed to be reliable but accuracy, completeness and
underlying assumptions of such third-party sources are not guaranteed. Although the industry and market data
used in this Draft Red Herring Prospectus is reliable, the data used in these sources may have been re-classified
by us for the purposes of presentation however, no material data in connection with the Issue has been omitted.
Data from these sources may also not be comparable. Further, CARE has confirmed that to the best of its
knowledge no consent is required from any Government or other source from which any information is used in
the CARE Report.
For details of risks in relation to CARE Report, see “Risk Factor - Certain sections in this Draft Red Herring
Prospectus contain information from the CARE Report, which was prepared by CARE Analytics and Advisory
Private Limited and exclusively commissioned and paid for by our Company for the purposes of the Issue, and
any reliance on such information for making an investment decision in the Issue is subject to inherent risks” on
page 75 of this Draft Red Herring Prospectus.
15FORWARD LOOKING STATEMENTS
This Draft Red Herring Prospectus contains certain statements which are not statements of historical facts and
may be described as “forward-looking statements”. These forward-looking statements generally can be identified
by words or phrases such as “aim”, “anticipate”, “are likely”, “believe”, “continue”, “expect”, “estimate”,
“intend”, “will likely”, “likely to”, “may”, “seek to”, “shall”, “objective”, “plan”, “project”, “propose”, “will”,
“will continue”, “will pursue”, “will achieve”, “can”, “could”, “goal” or other words or phrases of similar import.
Similarly, statements that describe our Company’s strategies, objectives, plans or goals are also forward-looking
statements. All statements regarding our expected financial conditions, results of operations, business plans and
prospects are forward-looking statements. However, these are not the exclusive means of identifying forward
looking statements. These forward-looking statements include statements as to our business strategy, plans,
revenue and profitability (including, without limitation, any financial or operating projections or forecasts) and
other matters discussed in this Draft Red Herring Prospectus that are not historical facts. However, these are not
the exclusive means of identifying forward looking statements.
These forward-looking statements are based on our current plans, estimates and expectations and actual results
may differ materially from those suggested by such forward-looking statements. All forward-looking statements
are subject to risks, uncertainties, expectations and assumptions about us that could cause actual results to differ
materially from those contemplated by the relevant forward-looking statement.
Actual results may differ materially from those suggested by the forward-looking statements due to risks or
uncertainties associated with our expectations with respect to, but not limited to, regulatory changes pertaining to
the industry in which our Company operates and our ability to respond to them, our ability to successfully
implement our strategy, our growth and expansion, technological changes, our exposure to market risks, general
economic and political conditions in India and globally which have an impact on our business activities,
investments, or the industry in which we operate, the monetary and fiscal policies of India, inflation, deflation,
unanticipated turbulence in interest rates, foreign exchange rates, equity prices or other rates or prices, the
performance of the financial markets in India and globally, changes in domestic laws, regulations, taxes, changes
in competition in the industry in which we operate and incidents of any natural calamities and/or acts of violence.
Certain important factors that could cause actual results to differ materially from our Company’s expectations
include, but are not limited to, the following:
1. Our broking segment contributes 68.90%, 71.60%, and 71.60% of our revenue for the Fiscals 2025, 2024 and
2023, respectively. Any reduction in our revenue from broking segment could have a material adverse effect
on our business, results of operations, cash flows and financial condition.
2. We are subject to extensive statutory and regulatory requirements and supervision. Any failure to comply
with applicable law or changes in the regulatory framework could result in action being initiated against us
by relevant authorities which may have a material adverse impact on our business, results of operations and
financial condition.
3. We rely heavily on our network of Authorised Persons associated with us. Loss of a significant number of
Authorised Persons, or failure to expand our network of Authorised Persons may have an adverse impact on
our business, results of operations and financial conditions. Further, we could be liable for the lapses of our
Authorised Persons.
4. Any failure to obtain, renew and maintain requisite statutory and regulatory permits, licenses and approvals
for our operations from time to time may adversely affect our business.
5. We rely on the Indian exchanges for a significant portion of our business, and we are registered with such
exchanges and are subject to the rules and regulations framed by such exchanges. Any disruption in the
functioning of the exchanges or a disruption to our connection with the exchanges or failure to comply with
exchange rules and regulations could have a material adverse effect on our business and results of operations.
6. Our continued success and growth will be dependent on our ability to retain and grow our client base and
network of Authorised Person and relationship managers. Failure to retain and augment our client base could
have a material adverse effect on our business, financial condition and growth prospectus.
167. We have high working capital requirements. Any failure in arranging adequate working capital for our
operations may adversely affect our business, results of operations, cash flows and financial condition.
8. We have applied for registrations of certain intellectual property rights and any failure to enforce our rights
could have an adverse effect on our business prospects.
9. We are dependent on technology in carrying out our business activities and information technology forms an
integral part of our business. Failure or inadequacies in our information technology systems may hamper our
ability to compete effectively which may result in lower revenue, higher costs and would adversely affect our
business and results of operations.
10. There are certain discrepancies, errors, and non-compliance which have occurred in some of our corporate
records relating to forms filed with the RoC and other provisions of Companies Act, 2013/1956. Any penalty
or action taken by any regulatory authorities in future, for non-compliance with provisions of corporate or
any other law could impact the financial position of the Company to that extent.
For further discussion of factors that could cause the actual results to differ from our estimates and expectations,
see “Risk Factors”, “Our Business” and “Management’s Discussion and Analysis of Financial Position and
Results of Operations” on pages 40, 438 and 578 respectively. By their nature, certain market risk disclosures are
only estimates and could be materially different from what actually occurs in the future. As a result, actual gains
or losses could materially differ from those that have been estimated.
We cannot assure investors that the expectations reflected in these forward-looking statements will prove to be
correct. Given these uncertainties, investors are cautioned not to place undue reliance on such forward-looking
statements and not to regard such statements as a guarantee of our future performance.
Forward-looking statements reflect the current views of our Company as of the date of this Draft Red Herring
Prospectus and are not a guarantee of future performance. These statements are based on our management’s
beliefs, assumptions, current plans, estimates and expectations, which in turn are based on currently available
information. Although we believe the assumptions upon which these forward-looking statements are based are
reasonable, any of these assumptions could prove to be inaccurate, and the forward-looking statements based on
these assumptions could be incorrect. Neither our Company, our Directors, our Promoters, the Book Running
Lead Manager, the Syndicate Members nor any of their respective affiliates or advisors have any obligation to
update or otherwise revise any statements reflecting circumstances arising after the date hereof or to reflect the
occurrence of underlying events, even if the underlying assumptions do not come to fruition.
In accordance with SEBI requirements, our Company will ensure that investors in India are informed of material
developments pertaining to our Company and the Equity Share forming part of the Issue from the date of this
Draft Red Herring Prospectus until the time of the grant of listing and trading permission by the Stock Exchanges.
17SUMMARY OF THE ISSUE DOCUMENT
The following is a general summary of the terms of the Issue included in this Draft Red Herring Prospectus and
is not exhaustive, nor does it purport to contain a summary of all the disclosures in this Draft Red Herring
Prospectus when filed, or all details relevant to prospective investors. This summary should be read in conjunction
with, and is qualified in its entirety by, the more detailed information appearing elsewhere in this Draft Red
Herring Prospectus, including the sections titled “Risk Factors”, “The Issue”, “Capital Structure”, “Objects of
the Issue”, “Industry Overview”, “Our Business”, “Our Promoters and Promoter Group”, “Financial
Information”, “Outstanding Litigation and Other Material Developments” and “Issue Procedure” on pages 40,
89, 104, 357, 382, 438, 496, 503, 614 and 647 respectively of this Draft Red Herring Prospectus.
Unless otherwise indicated, industry and market data used in this section has been derived from industry report
titled ‘Broking Industry in India’ dated September, 2025 (“CARE Report”) prepared and issued by CARE
Analytics & Advisory Private Limited (“CARE”), appointed by us and exclusively commissioned and paid for by
us in connection with the Issue. Unless otherwise indicated, all industry and other related information derived
from the CARE Report and included herein with respect to any particular year refers to such information for the
relevant calendar year. CARE was appointed by our Company and is not connected to our Company, our
Directors, and our Promoters. A copy of the CARE Report is available on the website of our Company at
www.sihl.in
Summary of Primary Business of our Company
We are a retail brokering company that offers a range of services covering equity brokerage services and
derivatives brokerage services, with over three decades of experience. Our services facilitate the buying and
selling of financial products such as equities, IPO investing, mutual funds distribution, and other securities. While
our core operations include equity and derivatives brokerage, we primarily focus on providing secondary market
brokering services to retail customers, comprising both resident and non-resident Indians. In addition to executing
buy and sell orders, our business extends to offering mutual fund distribution, margin trading facility, and stock
lending and borrowing services, which are carried out under the brand name “Shah Investors”. As of March 31,
2025, we have served over 100,000 demat accounts, with more than 37,810 active clients and partnerships with
over 184 authorised persons. We conduct our operations through 11 branches in India, located in Mumbai,
Ahmedabad, Vadodara, Junagadh, Gandhinagar and Rajkot.
For further details, see “Our Business” beginning on page 438.
Summary of the Industry in which our Company operates
The broking industry plays a crucial role in the Indian financial markets by acting as an intermediary between
buyers and sellers of securities such as stocks, bonds, commodities, and other investment assets. Brokers facilitate
the trading of these financial products, ensuring liquidity, efficient price discovery, and proper capital allocation
across the markets. India's brokerage industry is highly competitive and particularly crowded. The market features
numerous large and small players, resulting in intense competition. Additionally, the brokerage landscape is
fragmented, comprising a considerable number of entities registered with SEBI. Over time, the industry has
evolved significantly, largely due to technological advancements, with online trading platforms revolutionizing
the way trades are executed (Source: Care Report).
For further details, see “Industry Overview” beginning on page 382.
Our Promoters
Our Promoters are Upendra Trikamlal Shah, Purnima Upendra Shah, Tanmay Upendra Shah and Trupti Utpal
Shah. For further details, see “Our Promoters and Promoter Group” on page 496.
Issue Size
Up to 54,00,000 Equity Shares of face value ₹ 10 each, aggregating up to ₹ [●]
Issue of Equity Shares (1)
lakhs
Notes:
1. The Issue has been authorized by our Board pursuant to the resolution passed at its meeting held on August 26, 2025, and by our
Shareholders pursuant to a special resolution passed at their meeting held on August 28, 2025.
Objects of the Issue
The Net Proceeds are proposed to be used by our Company in accordance with the details set forth below:
18Sr. Particulars Amount in ₹ % of Net
No. lakhs proceeds
1. Funding working capital requirements of our Company 7,000.00 [●]
2. General corporate purposes(1) [●] [●]
Total Net Proceeds(1) [●] [●]
1. To be finalised upon determination of the Issue Price and update in the Prospectus at the time of filing with the RoC.
For further details, see “Objects of the Issue” on page 357.
Aggregate Pre-Issue and Post-Issue shareholding of our Promoters and members of the Promoter Group
as a percentage of the paid-up Equity Share Capital
The aggregate pre-Issue and post-issue shareholding of our Promoters and members of the Promoter Group, as a
percentage of the pre-Issue paid-up Equity Share capital and post Issue paid-up Equity Share capital of our
Company is set out below:
Equity Shares Percentage of Percentage of
Equity Shares of
Name of the of face value of pre-Issue paid- post-Issue paid-
face value of ₹ 10
Shareholder ₹ 10 each pre- up equity share up equity share
each post-Issue^
Issue capital (%) capital (%)^
Promoters
Upendra Trikamlal Shah* 30,00,000 19.04 [●] [●]
Purnima Upendra Shah* 34,50,000 21.90 [●] [●]
Tanmay Upendra Shah* 25,05,000 15.90 [●] [●]
Trupti Utpal Shah 650,000 4.13
Total (A) 96,05,000 60.97 [●] [●]
Promoter Group
Preeti Upendra Shah 14,15,000 8.98 [●] [●]
Ruchira Shah* 5,80,000 3.68 [●] [●]
Utpal Praful Shah 5,30,000 3.36
Upendra Trikamlal Shah 3,32,500 2.11 [●] [●]
HUF
Kenisha Shah 2,41,200 1.53 [●] [●]
Rehaan Utpal Shah 2,20,000 1.40 [●] [●]
Aashna Utpal Shah 2,20,000 1.40 [●] [●]
Tanmay Upendra Shah 1,00,600 0.64 [●] [●]
HUF
Utpal Praful Shah HUF 36,400 0.23 [●] [●]
Praful Kacharabhai 2400 0.02 [●] [●]
Shah
Nivedita Vijay Vyas 1650 0.01 [●] [●]
Pritish Prafulbhai Shah 1650 0.01 [●] [●]
Total (B) 3,681,400 23.37 [●] [●]
Total (A + B) 13,286,400 84.34 [●] [●]
^To be updated at Prospectus Stage
*The shares our held jointly by the shareholders
Aggregate pre – Issue and post – Issue shareholding of our Promoter, the members of our Promoter Group
and additional top 10 shareholders
Post-Issue shareholding^$
Pre-Issue as at the date of the price band
At the lower end of At the upper end of
advertisement^
the price band (₹[●]) the price band (₹[●])
Number Number
Percentage
of Percentage of
Name of of post –
Equity of post – Equity
shareholder# Number of Equity Percentage of pre- Issue
Shares Issue Shares
Shares of face value Issue Equity Share Equity
of face Equity of face
of ₹10 each capital (%) Share
value of Share value of
capital
₹10 capital (% ₹10
(%)
each(1) each(1)
Promoters
19Post-Issue shareholding^$
Pre-Issue as at the date of the price band
At the lower end of At the upper end of
advertisement^
the price band (₹[●]) the price band (₹[●])
Number Number
Percentage
of Percentage of
Name of of post –
Equity of post – Equity
shareholder# Number of Equity Percentage of pre- Issue
Shares Issue Shares
Shares of face value Issue Equity Share Equity
of face Equity of face
of ₹10 each capital (%) Share
value of Share value of
capital
₹10 capital (% ₹10
(%)
each(1) each(1)
Upendra [●] [●] [●] [●] [●] [●]
Trikamlal Shah*
Purnima Upendra [●] [●] [●] [●] [●] [●]
Shah*
Tanmay Upendra [●] [●] [●] [●] [●] [●]
Shah*
Trupti Utpal Shah [●] [●] [●] [●] [●] [●]
Sub - Total (A) [●] [●] [●] [●] [●] [●]
Members of the Promoter Group
Preeti Upendra [●] [●] [●] [●] [●] [●]
Shah
Ruchira Shah* [●] [●] [●] [●] [●] [●]
Utpal Praful Shah [●] [●] [●] [●] [●] [●]
Upendra [●] [●] [●] [●] [●] [●]
Trikamlal Shah
HUF
Kenisha Shah [●] [●] [●] [●] [●] [●]
Rehaan Utpal [●] [●] [●] [●] [●] [●]
Shah
Aashna Utpal [●] [●] [●] [●] [●] [●]
Shah
Tanmay Upendra [●] [●] [●] [●] [●] [●]
Shah HUF
Utpal Praful Shah [●] [●] [●] [●] [●] [●]
HUF
Nivedita Vijay [●] [●] [●] [●] [●] [●]
Vyas
Praful [●] [●] [●] [●] [●] [●]
Kacharabhai
Shah
Pritish Prafulbhai [●] [●] [●] [●] [●] [●]
Shah
Sub - Total (B) [●] [●] [●] [●] [●] [●]
Additional Shareholders
Rajesh Ramchand [●] [●] [●] [●] [●] [●]
Punjabi
Shruti Rajesh [●] [●] [●] [●] [●] [●]
Punjabi
Sandhya Rajesh [●] [●] [●] [●] [●] [●]
Punjabi
Pearl Tej Shah [●] [●] [●] [●] [●] [●]
Sagar Rajesh [●] [●] [●] [●] [●] [●]
Punjabi
Anila [●] [●] [●] [●] [●] [●]
Rameshchandra
Patel
Rameshchandra [●] [●] [●] [●] [●] [●]
Motabhai Patel
Pratik [●] [●] [●] [●] [●] [●]
Rameshchandra
Patel
Maulik [●] [●] [●] [●] [●] [●]
Rameshchandra
Patel
20Post-Issue shareholding^$
Pre-Issue as at the date of the price band
At the lower end of At the upper end of
advertisement^
the price band (₹[●]) the price band (₹[●])
Number Number
Percentage
of Percentage of
Name of of post –
Equity of post – Equity
shareholder# Number of Equity Percentage of pre- Issue
Shares Issue Shares
Shares of face value Issue Equity Share Equity
of face Equity of face
of ₹10 each capital (%) Share
value of Share value of
capital
₹10 capital (% ₹10
(%)
each(1) each(1)
Akshaya Shah [●] [●] [●] [●] [●] [●]
Sub – Total (C) [●] [●] [●] [●] [●] [●]
Total (A+B+C) [●] [●]
^To be updated in the Prospectus prior to filing with ROC.
#As per the shareholding as on date of filing of this Draft Red Herring Prospectus.
$Subject to finalisation of the Basis of Allotment.
*The shares our held jointly by the shareholders
Summary of Restated Consolidated Financial Information:
(in ₹ lakhs except per share data)
As at and for the Fiscal period ended
Particulars
March 31, 2025 March 31, 2024 March 31, 2023
Equity Share Capital 1,575.40 1,575.40 1,575.40
Net worth 16,808.98 15,054.13 11,745.98
Revenue from operations 9,427.39 7,782.36 5,168.30
Profit after tax 2,338.50 1,793.38 763.17
Earnings per share (basic and diluted) 14.84 11.38 4.84
NAV per equity share 106.70 95.56 74.56
Total borrowings 570.81 353.52 803.42
Notes:
(1) Revenue from Operations means the revenue from operations as appearing in the Restated Consolidated Financial
Information.
(2) Profit after Tax means profit / (loss) for the period/ year from continuing and discontinued operations attributable to the
owners of the parent company as appearing in the Restated Consolidated Financial Information.
(3) Basic EPS and Diluted EPS refer to the Basic EPS and Diluted EPS sourced from the Restated Consolidated Financial
Information.
(4) Net worth’ means aggregate value of the paid-up share capital and other equity created out of the profits, securities premium
account and debit or credit balance of profit and loss account, after deducting the aggregate value of the accumulated losses,
deferred expenditure and miscellaneous expenditure not written off, derived from Restated Consolidated Financial
Information, but does not include reserves created out of revaluation of assets, write-back of depreciation and amalgamation.
(5) Net assets value per equity share (in ₹): Net Asset Value per equity share represents net worth as at the end of the fiscal year,
as restated, divided by the number of Equity Shares outstanding at the end of the period/year adjusted for bonus shares issued
by the Company.
(6) Total borrowings include current and non-current borrowings.
For further details, see “Other Financial Information” on page 575.
Qualifications of the Statutory Auditors which have not been given effect to in the Restated Consolidated
Financial Information
Our Statutory Auditors have not made any qualifications that have not been given effect to in the Restated
Consolidated Financial Information.
Summary of Outstanding Litigation and Material Developments
A summary of outstanding litigation proceedings of our Company, Subsidiaries, Directors, Promoters and Group
Companies, to the extent applicable and as disclosed in the section titled “Outstanding Litigation and Material
Developments” on page 614, in terms of the SEBI ICDR Regulations and the materiality policy approved by our
Board pursuant to resolution dated September 05, 2025, as of the date of this Draft Red Herring Prospectus is set
forth below:
21Disciplinary
actions by the
Aggregate
Statutory or SEBI or Material
Name of the Criminal Tax Amount
Regulatory Stock Civil
Entity Proceedings Proceedings Involved (in
Proceeding Exchanges Litigations
₹ lakhs)
against our
Promoter
Company
By our Company Nil N.A. Nil N.A. Nil Nil
Against our Nil 5 Nil N.A. Nil 415.26
Company
Subsidiaries
By our Subsidiaries Nil N.A. Nil N.A. Nil -
Against our Nil 1 Nil N.A. Nil 4.68
Subsidiaries
Directors (other than Promoter)
By our Directors Nil N.A. Nil N.A. Nil -
Against our Nil Nil Nil N.A. Nil Nil
Directors
Promoters
By our Promoters Nil N.A. Nil Nil Nil -
Against our Nil Nil Nil Nil Nil -
Promoters
KMPs (other than Promoters)
By our KMP Nil N.A. Nil N.A. N.A. -
Against our KMP Nil N.A. Nil N.A. N.A. -
SMPs
By our SMP Nil N.A. Nil N.A. N.A. -
Against our SMP Nil N.A. Nil N.A. N.A. -
N.A. denotes Not Applicable
*To the extent quantifiable
For further details of the outstanding litigation proceedings, see “Outstanding Litigation and Material
Developments” beginning on page 614.
Risk Factors
Investors are advised to read the risk factors carefully before taking an investment decision in the Issue. Details
of our top 10 risk factors are set forth below:
11. Our broking segment contributes 68.90%, 71.60%, and 71.60% of our revenue for the Fiscals 2025, 2024 and
2023, respectively. Any reduction in our revenue from broking segment could have a material adverse effect
on our business, results of operations, cash flows and financial condition.
12. We are subject to extensive statutory and regulatory requirements and supervision. Any failure to comply
with applicable law or changes in the regulatory framework could result in action being initiated against us
by relevant authorities which may have a material adverse impact on our business, results of operations and
financial condition.
13. We rely heavily on our network of Authorised Persons associated with us. Loss of a significant number of
Authorised Persons, or failure to expand our network of Authorised Persons may have an adverse impact on
our business, results of operations and financial conditions. Further, we could be liable for the lapses of our
Authorised Persons.
14. Any failure to obtain, renew and maintain requisite statutory and regulatory permits, licenses and approvals
for our operations from time to time may adversely affect our business.
15. We rely on the Indian exchanges for a significant portion of our business, and we are registered with such
exchanges and are subject to the rules and regulations framed by such exchanges. Any disruption in the
functioning of the exchanges or a disruption to our connection with the exchanges or failure to comply with
exchange rules and regulations could have a material adverse effect on our business and results of operations.
2216. Our continued success and growth will be dependent on our ability to retain and grow our client base and
network of Authorised Person and relationship managers. Failure to retain and augment our client base could
have a material adverse effect on our business, financial condition and growth prospectus.
17. We have high working capital requirements. Any failure in arranging adequate working capital for our
operations may adversely affect our business, results of operations, cash flows and financial condition.
18. We have applied for registrations of certain intellectual property rights and any failure to enforce our rights
could have an adverse effect on our business prospects.
19. We are dependent on technology in carrying out our business activities and information technology forms an
integral part of our business. Failure or inadequacies in our information technology systems may hamper our
ability to compete effectively which may result in lower revenue, higher costs and would adversely affect our
business and results of operations.
20. There are certain discrepancies, errors, and non-compliance which have occurred in some of our corporate
records relating to forms filed with the RoC and other provisions of Companies Act, 2013/1956. Any penalty
or action taken by any regulatory authorities in future, for non-compliance with provisions of corporate or
any other law could impact the financial position of the Company to that extent.
Summary of Contingent Liabilities
As of March 31, 2025, contingent liabilities as per Ind AS 37 as indicated in our Restated Consolidated Financial
Information are as follows:
(in ₹ lakhs)
Particulars As of March 31, 2025
Bank Guarantee 6,000.00
Demand in respect of income tax matters for which appeal is pending 419.94
Total 6,419.94
For further details of contingent liabilities as of March 31, 2025, see “Restated Consolidated Financial
Information – Contingent liabilities and commitments” on page 503.
Summary of Related Party Transactions
Summary of the related party transactions of our Company (without elimination) for the financial years ended
March 31, 2025, March 31, 2024, and March 31, 2023, as per Ind AS 24 – Related Party Disclosures read with
the SEBI ICDR Regulations, derived from Restated Consolidated Financial Information read with SEBI ICDR
Regulations are set forth in the table below:
23(in ₹ lakhs)
For the year % of Total For the year % of Total For the year % of Total
Nature of Name of
Sr. No. % of ended 31st Assets/ Revenue ended 31st Assets/ Revenue ended 31st Assets/ Revenue
Transa ction Related Party
March, 2025 from operation March, 2024 from operation March, 2023 from operation
(i) In the books of Shah Investor's Home Limited
1 Loan Given SIHL Fincap Total Asset - - 1,171.73 3.92 14,817.45 69.94
Limited
2 Loan Repayment SIHL Fincap Total Asset - - 1,171.73 3.92 14,817.45 69.94
Limited
Shamik Chokshi - - 4.50 0.02 3.00 0.01
3 Loan Taken SIHL Fincap Total Asset 17,026.61 56.27 14,228.69 47.63 14,124.97 66.67
Limited
Tanmay 10.00 0.03 - - - 0.00
Upendra Shah
Utpal Praful - - - 300.00 1.42
Shah
4 Loan Repaid SIHL Fincap Total Asset 17,026.61 56.27 14,228.69 47.63 14,124.97 66.67
Limited
Tanmay 10.00 0.03 - - - 0.00
Upendra Shah
Utpal Praful - - - 300.00 1.42
Shah
5 Interest Income SIHL Fincap Revenue from - - 0.14 0.00 1.26 0.02
Limited operations
6 Interest Expense SIHL Fincap Revenue from 170.09 1.80 95.47 1.23 8.67 0.17
Limited operations
7 Consultancy Fees Stock Book LLP Revenue from - - 10.00 0.13 15.00 0.29
operations
8 Brokerage Paid Sur Management Revenue from 12.75 0.14 26.16 0.34 19.41 0.38
Services Private operations
Limited
Arthika 23.67 0.25 - - - -
Quantomics
Private Limites
24For the year % of Total For the year % of Total For the year % of Total
Nature of Name of
Sr. No. % of ended 31st Assets/ Revenue ended 31st Assets/ Revenue ended 31st Assets/ Revenue
Transa ction Related Party
March, 2025 from operation March, 2024 from operation March, 2023 from operation
9 Dividend Paid Directors Revenue from 117.34 1.24 121.30 1.56 61.15 1.18
operations
KMP 6.50 0.07 6.50 0.08 3.25 0.06
Relative of 25.10 0.27 21.09 0.27 10.04 0.19
KMP/Director
10 Rent deposit Trupti Utpal Total Asset (2.00) (0.01) - - (3.00) (0.01)
accepted/(repaid) Shah
Ruchira Shah - (2.31) (0.01) - -
Tanmay - (0.30) (0.00) - -
Upendra Shah
11 Reimbursement Arbor Park LLP Revenue from 0.02 0.00 - - 0.03 0.00
Exps operations
Ruchira Shah 0.04 0.00 1.18 0.02 2.77 0.05
Tanmay 12.08 0.13 5.41 0.07 27.05 0.52
Upendra Shah
Trupti Utpal - - 7.32 0.09 1.13 0.02
Shah
Preeti Shah 0.08 0.00 0.03 0.00 1.40 0.03
Rajesh Punjabi - - - - 0.24 0.00
Shamik Chokshi - - 0.65 0.01 1.06 0.02
Utpal Praful - - - - 1.64 0.03
Shah
12 Managerial Upendra Shah Revenue from 36.00 0.38 41.00 0.53 55.08 1.07
remuneration paid operations
Purnima Shah 36.00 0.38 39.90 0.51 45.36 0.88
Preeti Shah 48.00 0.51 48.00 0.62 48.00 0.93
Tanmay 60.00 0.64 60.00 0.77 60.00 1.16
Upendra Shah
25For the year % of Total For the year % of Total For the year % of Total
Nature of Name of
Sr. No. % of ended 31st Assets/ Revenue ended 31st Assets/ Revenue ended 31st Assets/ Revenue
Transa ction Related Party
March, 2025 from operation March, 2024 from operation March, 2023 from operation
Trupti Utpal 48.00 0.51 48.00 0.62 48.00 0.93
Shah
Utpal Praful 50.00 0.53 60.00 0.77 60.00 1.16
Shah
Rajesh Punjabi 60.00 0.64 60.00 0.77 60.00 1.16
Jinal Shah 13.92 0.15 16.66 0.21 12.48 0.24
Shamik Chokshi - - 5.92 0.08 9.72 0.19
13 Salary to Relative Arpita Jinal Shah Revenue from 10.08 0.11 12.03 0.15 8.88 0.17
of KMP operations
Sandhya Punjabi 27.00 0.29 27.00 0.35 27.00 0.52
14 Rent Income Arbor Park LLP Revenue from - - - - 6.00 0.12
operations
15 Rent Expense Ruchira Shah Revenue from - - 0.57 0.01 2.28 0.04
operations
Tanmay - - 0.43 0.01 2.28 0.04
Upendra Shah
Trupti Utpal 0.25 0.00 3.00 0.04 3.00 0.06
Shah
Upendra Shah 1.44 0.02 1.44 0.02 1.44 0.03
16 Sale of Investment SIHL Total Asset - - - - 145.30 0.69
Commodities
Limited
Sihl Consultancy - - - - 47.89 0.23
Limited
Purnima Shah - - - - 15.26 0.07
Utpal Praful - - - - 101.17 0.48
Shah HUF
Tanmay - - - - 49.67 0.23
Upendra Shah
26For the year % of Total For the year % of Total For the year % of Total
Nature of Name of
Sr. No. % of ended 31st Assets/ Revenue ended 31st Assets/ Revenue ended 31st Assets/ Revenue
Transa ction Related Party
March, 2025 from operation March, 2024 from operation March, 2023 from operation
17 Purchase of Tanmay Total Asset - - 65.81 0.22 - 0.00
P roperty Upendra Shah
Ruchira Shah - - 74.14 0.25 - 0.00
18 Brokerage Income Director Revenue from 1.64 0.02 14.51 0.19 0.02 0.00
operations
Independent 3.21 0.03 0.04 0.00 0.05 0.00
Director
KMP 0.36 0.00 0.84 0.01 0.04 0.00
Subsidiary 0.40 0.00 10.64 0.14 2.17 0.04
Relatives of 28.73 0.30 28.72 0.37 15.48 0.30
Directos/KMPs
Other Related 1.29 0.01 3.23 0.04 5.23 0.10
Parties
19 Donation & CSR Vimal Jyot Revenue from 18.50 0.20 7.50 0.10 13.50 0.26
Charitable Trust operations
20 Director Sitting Amit Doshi Revenue from 0.28 0.00 0.28 0.00 0.28 0.01
Fees operations
Bhishmak Soni 0.28 0.00 0.14 0.00 0.28 0.01
Siddharth Shah - - - - 0.07 0.00
Darshan Patel 0.07 0.00 - - - -
Bhushan Punani 0.07 0.00 - - - -
21 Outstanding
Balance
Deposit Trupti Utpal - 2.00 2.00
Shah
Ruchira Shah - - 1.20
27For the year % of Total For the year % of Total For the year % of Total
Nature of Name of
Sr. No. % of ended 31st Assets/ Revenue ended 31st Assets/ Revenue ended 31st Assets/ Revenue
Transa ction Related Party
March, 2025 from operation March, 2024 from operation March, 2023 from operation
Tanmay 0.45 0.45 0.75
Upendra Shah
Loan Taken Shamik Chokshi - - 4.50
(ii) In the books of SIHL Strategic Advisors Private Limited
1 Loan Given SIHL Fincap Total Asset 256.83 0.85 78.15 0.26 465.67 2.20
Limited
Infinium Mines - - 11.60 0.04 86.00 0.41
and Minerals
Private Limited
Ficus Food Lab - - - - 8.16 0.04
Private Limited
2 Loan Repayment SIHL Fincap Total Asset 256.83 0.85 78.15 0.26 465.67 2.20
Limited
Infinium Mines 74.02 0.24 23.58 0.08 - 0.00
and Minerals
Private Limited
Ficus Food Lab - - - - 8.16 0.04
Private Limited
3 Loan Taken SIHL Fincap Total Asset 301.08 1.00 6.62 0.02 42.79 0.20
Limited
Ficus Food Lab - - - - 0.02 0.00
Private Limited
4 Loan Repayment SIHL Fincap Total Asset 1.08 0.00 6.62 0.02 42.79 0.20
Limited
Ficus Food Lab - - 0.02 0.00 - 0.00
Private Limited
5 Interest Income SIHL Fincap Revenue from 3.13 0.03 0.60 0.01 2.83 0.05
Limited operations
28For the year % of Total For the year % of Total For the year % of Total
Nature of Name of
Sr. No. % of ended 31st Assets/ Revenue ended 31st Assets/ Revenue ended 31st Assets/ Revenue
Transa ction Related Party
March, 2025 from operation March, 2024 from operation March, 2023 from operation
Ficus Food Lab - - - - 0.16 0.00
Private Limited
6 Brokerage paid Shah Investor's Revenue from 0.20 0.00 0.53 0.01 0.34 0.01
Home Limited operations
7 Director Ruchira Shah Revenue from - - - - 11.34 0.22
Remmuneration (Key Managerial operations
Persons)
8 Purchase of Ficus Food Lab Total Asset - - - - 144.00 0.68
Investments Private Limited
9 Outstanding
Balance
Loan Taken SIHL Fincap 300.00 - -
Limited
Ficus Food Lab - - 0.02
Private Limited
Loan Given Infinium Mines - 74.02 86.00
and Minerals
Private Limited
10 Outstanding Ficus Food Lab 144.00 144.00 144.00
Balance in respect Private Limited
of
investments in
related parties
(iii) In the books of SIHL Consultancy Limited
1 Loan Given Infinium Mines Total Asset 0.20 0.00 344.21 1.15 86.31 0.41
and Minerals
Private Limited
SIHL Fincap 1,199.91 3.97 1,033.70 3.46 374.09 1.77
Limited
29For the year % of Total For the year % of Total For the year % of Total
Nature of Name of
Sr. No. % of ended 31st Assets/ Revenue ended 31st Assets/ Revenue ended 31st Assets/ Revenue
Transa ction Related Party
March, 2025 from operation March, 2024 from operation March, 2023 from operation
2 Loan Repayment Infinium Mines Total Asset 0.20 0.00 484.02 1.62 86.00 0.41
and Minerals
Private Limited
SIHL Fincap 1,199.91 3.97 1,033.70 3.46 374.09 1.77
Limited
3 Loan Taken Infinium Mines Total Asset 3.60 0.01 78.89 0.26 - 0.00
and Minerals
Private Limited
SIHL Fincap - - 8.99 0.03 192.00 0.91
Limited
4 Loan Repaid Infinium Mines Total Asset 3.60 0.01 78.89 0.26 - -
and Minerals
Private Limited
SIHL Fincap - - 8.99 0.03 192.00 0.91
Limited
5 Interest Income SIHL Fincap Revenue from 61.54 0.65 8.15 0.10 0.80 0.02
Limited operations
6 Brokerage Paid Shah Investor's Revenue from 0.18 0.00 2.08 0.03 0.88 0.02
Home Limited operations
- - -
7 Consultancy Fees Arbor Park LLP Revenue from 9.91 0.11 9.91 0.13 7.43 0.14
operations
8 Purchase of Shah Investor's Total Asset - - - - 47.89 0.23
Investment Home Limited
9 Outstanding
Balance
Loan Taken
30For the year % of Total For the year % of Total For the year % of Total
Nature of Name of
Sr. No. % of ended 31st Assets/ Revenue ended 31st Assets/ Revenue ended 31st Assets/ Revenue
Transa ction Related Party
March, 2025 from operation March, 2024 from operation March, 2023 from operation
Loan Given Infinium Mines - - - 139.81
and Minerals
Private Limited
(iv) In the books of SIHL Fincap Limited
1 Loan Given Preeti Shah Total Asset 80.30 0.27 245.81 0.82 - 0.00
Shah Investor's 17,026.61 56.27 14,228.69 47.63 14,124.97 66.67
Home Limited
Utpal Praful - - - - 12.02 0.06
Shah
SIHL 4.21 0.01 1.62 0.01 335.17 1.58
Commodities
Limited
Tanmay 54.42 0.18 3,296.38 11.03 10,518.29 49.65
Upendra Shah
Infinium Mines - - 50.00 0.17 0.15 0.00
and Minerals
Private Limited
Ficus Food Lab 606.47 2.00 215.71 0.72 96.26 0.45
Private Limited
SIHL - - 8.99 0.03 192.00 0.91
Consultancy
Limited
SIHL Strategic 301.08 1.00 6.62 0.02 42.79 0.20
Advisors Private
Limited
Stock Book LLP - - 8.91 0.03 4,703.69 22.20
Sur Managment 29.53 0.10 86.46 0.29 72.28 0.34
Service Private
Limited
31For the year % of Total For the year % of Total For the year % of Total
Nature of Name of
Sr. No. % of ended 31st Assets/ Revenue ended 31st Assets/ Revenue ended 31st Assets/ Revenue
Transa ction Related Party
March, 2025 from operation March, 2024 from operation March, 2023 from operation
2 Loan Repayment Preeti Shah Total Asset 205.30 0.68 120.81 0.40 - 0.00
Shah Investor's 17,026.61 56.27 14,228.69 47.63 14,124.97 66.67
Home Limited
Utpal Praful - - - - 12.02 0.06
Shah
SIHL 4.21 0.01 42.16 0.14 294.62 1.39
Commodities
Limited
Tanmay 54.42 0.18 3,296.38 11.03 10,707.29 50.54
Upendra Shah
Infinium Mines - - 50.00 0.17 0.15 0.00
and Minerals
Private Limited
Ficus Food Lab 209.67 0.69 3.97 0.01 96.26 0.45
Private Limited
SIHL - - 8.99 0.03 192.00 0.91
Consultancy
Limited
SIHL Strategic 1.08 0.00 6.62 0.02 42.79 0.20
Advisors Private
Limited
Stock Book LLP - - 8.91 0.03 4,703.69 22.20
Sur Managment 29.53 0.10 138.46 0.46 20.28 0.10
Service Private
Limited
3 Loan Taken Preeti Shah Total Asset 264.56 0.87 - - - 0.00
Shah Investor's - - 1,171.73 3.92 14,817.45 69.94
Home Limited
Upendra T. Shah - - 8.10 0.03 26.59 0.13
32For the year % of Total For the year % of Total For the year % of Total
Nature of Name of
Sr. No. % of ended 31st Assets/ Revenue ended 31st Assets/ Revenue ended 31st Assets/ Revenue
Transa ction Related Party
March, 2025 from operation March, 2024 from operation March, 2023 from operation
SIHL 47.62 0.16 7.80 0.03 410.08 1.94
Commodities
Limited
Tanmay 3,686.91 12.19 3,610.69 12.09 1,537.03 7.25
Upendra Shah
Infinium Mines - - 25.53 0.09 - 0.00
and Minerals
Private Limited
SIHL 1,199.91 3.97 1,033.70 3.46 374.09 1.77
Consultancy
Limited
SIHL Strategic 256.83 0.85 78.15 0.26 465.67 2.20
Advisors Private
Limited
Stock Book LLP - - 0.97 0.00 1,037.01 4.89
Sur Managment 2,475.01 8.18 1,364.88 4.57 446.97 2.11
Service Private
Limited
4 Loan Repaid Preeti Shah Total Asset 264.56 0.87 - - - 0.00
Shah Investor's - - 1,171.73 3.92 14,817.45 69.94
Home Limited
Upendra T. Shah - - 8.10 0.03 26.59 0.13
SIHL 47.62 0.16 7.80 0.03 410.08 1.94
Commodities
Limited
Tanmay 3,686.91 12.19 3,610.69 12.09 1,537.03 7.25
Upendra Shah
Infinium Mines - - 25.53 0.09 - 0.00
and Minerals
Private Limited
33For the year % of Total For the year % of Total For the year % of Total
Nature of Name of
Sr. No. % of ended 31st Assets/ Revenue ended 31st Assets/ Revenue ended 31st Assets/ Revenue
Transa ction Related Party
March, 2025 from operation March, 2024 from operation March, 2023 from operation
SIHL 1,199.91 3.97 1,033.70 3.46 374.09 1.77
Consultancy
Limited
SIHL Strategic 256.83 0.85 78.15 0.26 465.67 2.20
Advisors Private
Limited
Stock Book LLP - - 0.97 0.00 1,037.01 4.89
Sur Managment 2,475.01 8.18 1,364.88 4.57 446.97 2.11
Service Private
Limited
5 Reimbursement Ruchira Shah Revenue from 2.23 0.02 1.98 0.03 1.23 0.02
of expenses operations
SIHL - - 0.04 0.00 0.12 0.00
Commodities
Limited
6 Director Ruchira Shah Revenue from 43.44 0.46 43.44 0.56 32.10 0.62
Remuneration operations
7 Interest Income Ficus Food Lab Revenue from 42.90 0.46 3.97 0.05 0.26 0.00
Private Limited operations
Preeti Shah 1.03 0.01 9.76 0.13 - -
Shah Investor's 170.09 1.80 95.47 1.23 8.67 0.17
Home Limited
SIHL - - 0.07 0.00 0.31 0.01
Commodities
Limited
Stock Book LLP - - 0.01 0.00 12.41 0.24
Tanmay - - 2.43 0.03 33.97 0.66
Upendra Shah
Utpal Praful - - - - 0.02 0.00
Shah
34For the year % of Total For the year % of Total For the year % of Total
Nature of Name of
Sr. No. % of ended 31st Assets/ Revenue ended 31st Assets/ Revenue ended 31st Assets/ Revenue
Transa ction Related Party
March, 2025 from operation March, 2024 from operation March, 2023 from operation
8 Interest Expense Shah Investor's Revenue from - - 0.14 0.00 1.26 0.02
Home Limited operations
SIHL 1.09 0.01 - - 0.52 0.01
Commodities
Limited
Tanmay 4.21 0.04 - - - -
Upendra Shah
SIHL 61.54 0.65 8.15 0.10 0.80 0.02
Consultancy
Limited
SIHL Strategic 3.13 0.03 0.60 0.01 2.83 0.05
Advisors Private
Limited
Sur Managment 12.62 0.13 8.60 0.11 2.25 0.04
Service Private
Limited
Preeti Shah 0.55 0.01 - - - -
9 Rent Expense Upendra T. Shah Revenue from 3.60 0.04 3.60 0.05 3.60 0.07
operations
10 Brokerage Paid Shah Investor's Revenue from 0.02 0.00 8.04 0.10 0.94 0.02
Home Limited operations
11 Outstanding
Balance
Loan Given Preeti Shah - 125.00 -
SIHL - - 40.54
Commodities
Limited
Ficus Food Lab 608.54 211.74 -
Private Limited
35For the year % of Total For the year % of Total For the year % of Total
Nature of Name of
Sr. No. % of ended 31st Assets/ Revenue ended 31st Assets/ Revenue ended 31st Assets/ Revenue
Transa ction Related Party
March, 2025 from operation March, 2024 from operation March, 2023 from operation
SIHL Strategic 300.00 - -
Advisors Private
Limited
Sur Managment - - 52.00
Service Private
Limited
For details of the related party transactions in accordance with Ind AS 24, see “Financial Information –- Note 48– Related Party Disclosures” beginning on page 503.
36Financing arrangements
There have been no financing arrangements whereby our Promoters, members of the Promoter Group, our
Directors and their relatives (as defined in Companies Act, 2013) have financed the purchase of any securities of
our Company by any other person other than in the normal course of the business of the financing entity during a
period of six-months immediately preceding the date of this Draft Red Herring Prospectus.
Weighted average price at which the Equity Shares were acquired by our Promoters in the last one year
preceding the date of this Draft Red Herring Prospectus
The weighted average price at which our Promoters acquired the Equity Shares in the last one year preceding the
date of this Draft Red Herring Prospectus are as follows:
Name Number of Equity Shares Weighted Average Price of Equity
acquired Shares acquired (₹)*
Promoters
Upendra Trikamlal Shah Nil Nil
Purnima Upendra Shah Nil Nil
Tanmay Upendra Shah Nil Nil
Trupti Utpal Shah Nil Nil
*As certified by the Independent Chartered Accountant, Dhrumil A. Shah & Co., Chartered Accountants (FRN: 145163W) by way of their
certificate dated September 29, 2025
Weighted average cost of acquisition of all shares transacted in the three years, 18 months and one year
preceding the date of the Draft Red Herring Prospectus:
Cap Price is ‘x’
Range of acquisition
Weighted average cost of times the
price per Equity
Period acquisition per Equity weighted average
Share: lowest price –
Share (in ₹)^ cost of
highest price (in ₹)
acquisition^
Last three years preceding the date of
Nil [●] Nil
this Draft Red Herring Prospectus
Last 18 months preceding the date of
Nil [●] Nil
this Draft Red Herring Prospectus
Last one year preceding the date of this
NA [●] NA
Draft Red Herring Prospectus
**Inter‑promoter share transfers were effected at nil consideration, resulting in changes to individual promoter holdings. Notwithstanding
these changes, the aggregate weighted‑average cost of the transfers remains nil.
^ To be included once the price band information is available.
As certified by the Independent Chartered Accountant, Dhrumil A. Shah & Co., Chartered Accountants (FRN: 145163W) by way of their
certificate dated September 29, 2025
Average cost of acquisition of Equity Shares of our Promoters
The average cost of acquisition per Equity Share of the Equity Shares held by our Promoters, as at the date of this
Draft Red Herring Prospectus, is set forth below:
Average cost of acquisition per
Name Number of Equity Shares
Equity Share$ (₹)
Promoters:
Upendra Trikamlal Shah 65,51,300 4.11
Purnima Upendra Shah 40,10,200 2.39
Tanmay Upendra Shah 26,51,800 0.65
Trupti Utpal Shah 9,00,100 2.51
Note: In cases of transfers where the cost of acquisition cannot be ascertained or traced with reasonable certainty, the cost has been deemed
to be Nil for the purposes of this determination. For further information, please see the note to “Capital Structure – Details of shareholding
of our Promoters, members of the Promoter Group, Directors, Key Managerial Personnel and Senior Managerial Personnel in our Company
– Shareholding of our Promoters and member of our Promoter Group” on page 266.
$As certified by the Independent Chartered Accountant, Dhrumil A. Shah & Co., Chartered Accountants (FRN: 145163W) by way of their
certificate dated September 29, 2025.
For further details of the acquisition of Equity Shares of our Promoters, see “Capital Structure – Details of
Shareholding of our Promoter” at page 104.
Details of price at which Specified Securities were acquired in the last three years preceding the date of this
Draft Red Herring Prospectus by our Promoters, the Promoter Group or Shareholder(s) with rights to
nominate Director(s) or other special rights:
37Except as stated below, there have been no Specified Securities that were acquired in the last three years preceding
the date of this Draft Red Herring Prospectus, by our Promoters and members of our Promoter Group. There are
no Shareholders with nominee director or other special rights. The details of the price at which these acquisitions
were undertaken are stated below:
Date of acquisition of Number of Equity Acquisition price per
Name of the acquirer
Equity Shares Shares acquired Equity Share (in ₹)
Promoter
Tanmay Upendra Shah 06-03-2023 1,00,000 -
Tanmay Upendra Shah 20-01-2024 2,10,000 -
Tanmay Upendra Shah 20-01-2024 1,40,000 -
Tanmay Upendra Shah 21-02-2024 3,50,000 -
Trupti Utpal Shah 20-01-2024 15,000 -
Trupti Utpal Shah 20-01-2024 10,000 -
Trupti Utpal Shah 21-02-2024 25,000 -
Trupti Utpal Shah 24-07-2024 75,000 -
Trupti Utpal Shah 24-07-2024 75,000 -
Promoter Group
Tanmay Upendra Shah HUF 06-03-2023 1,00,000 -
Utpal Praful Shah 06-03-2023 1,00,000 -
Utpal Praful Shah 20-01-2024 15,000 -
Utpal Praful Shah 20-01-2024 10,000 -
Utpal Praful Shah 21-02-2024 25,000 -
Utpal Praful Shah 24-07-2024 75,000 -
Utpal Praful Shah 24-07-2024 75,000 -
Utpal P. Shah HUF 06-12-2023 1,800 72
Utpal P. Shah HUF 23-12-2023 1,800 72
Utpal P. Shah HUF 20-06-2024 1,000 81
Utpal P. Shah HUF 18-11-2024 3,000 85
Preeti Upendra Shah 06-03-2023 1,00,000 -
Preeti Upendra Shah 20-01-2024 20,000 -
Preeti Upendra Shah 20-01-2024 30,000 -
Preeti Upendra Shah 21-02-2024 50,000 -
Ruchira Tanmay Shah 06-03-2023 1,00,000 -
Ruchira Tanmay Shah 20-01-2024 30,000 -
Ruchira Tanmay Shah 20-01-2024 20,000 -
Ruchira Tanmay Shah 21-02-2024 50,000 -
Shareholders with rights to nominate Directors or other special rights
Nil Nil Nil Nil
Note - No outward transfers are considered above
$As certified by the Independent Chartered Accountant, Dhrumil A. Shah & Co., Chartered Accountants (FRN: 145163W) by way of their
certificate dated September 29, 2025.
Details of Pre – IPO Placement
Our Company is not contemplating a Pre – IPO placement.
Issue of Equity Shares for consideration other than cash in the last one year
Other than as disclosed in “Capital Structure” on page 104, our Company has not issued any Equity Shares for
consideration other than cash in the one year preceding the date of this Draft Red Herring Prospectus.
Split or Consolidation of Equity Shares in the last one year
38Our Company has not undertaken any split or consolidation of Equity Shares in one year preceding the date of
this Draft Red Herring Prospectus.
Exemption from complying with any provisions of securities laws
Our Company has not made any application under Regulation 300(1)(c) of the SEBI ICDR Regulations for
seeking an exemption from complying with any provisions of securities laws by SEBI as on the date of this Draft
Red Herring Prospectus.
39SECTION II – RISK FACTORS
An investment in equity shares involves a high degree of risk. You should carefully consider each of the following
risk factors and all other information in this Draft Red Herring Prospectus, including the risks and uncertainties
described below, before making an investment in the Equity Shares. We have described the risks and uncertainties
that we believe are material, but these risks and uncertainties may not be the only risks relevant to us, the Equity
Shares, or the industry in which we currently operate or propose to operate. Unless specified or quantified in the
relevant risk factors below, we are not in a position to quantify the financial or other implications of any of the
risks mentioned in this section. If any or a combination of the following risks actually occur, our business,
reputation, cash flows, prospects, financial condition and results of operations could suffer, the trading price of
the Equity Shares could decline and you may lose all or part of your investment. The risk factors have been
ordered on the basis of their materiality. For more details on our business and operations, see “Our Business”,
“Industry Overview”, “Key Regulations and Policies”, “Management’s Discussion and Analysis of Financial
Condition and Results of Operations” and “Restated Financial Information” on pages 438, 382, 457, 578, and
503 respectively, as well as other financial and statistical information contained in this Draft Red Herring
Prospectus.
In making an investment decision, you must rely on your own examination of our Company and the terms of the
Offer, including the merits and risks involved and you should consult your tax, financial and legal advisors about
the consequences of investing in the Issue. Prospective investors should pay particular attention to the fact that
our Company is incorporated under the laws of India and is subject to a legal and regulatory environment which
may differ in certain respects from that of other countries. This Draft Red Herring Prospectus also contains
forward-looking statements that involve risks, assumptions, estimates and uncertainties. Our actual results could
differ materially from those anticipated in these forward-looking statements because of certain factors, including
but not limited to the considerations described below. For details, see “Forward-Looking Statements” on page
16.
Our financial year ends on March 31 of each year. Accordingly, references to “Fiscal Year 2023”, “Fiscal Year
2024” and “Fiscal Year 2025”, are to the 12-month period ended March 31 of the relevant year. This Draft Red
Herring Prospectus includes the Restated Financial Information of the Company that has been prepared under
Ind AS notified under Section 133 of the Companies Act, 2013, and in accordance with requirements of Section
26 of Part I of Chapter III of the Companies Act, Paragraph (A) of Clause 11 (I) of Part A of Schedule VI of the
SEBI ICDR Regulations and the Guidance Note on Reports in Company Prospectuses (Revised 2019) issued by
the Institute of Chartered Accountants of India as amended from time to time.
Unless stated otherwise, the industry and market data contained in this section is derived from the industry report
titled “Broking Industry in India” dated September 2025, which is exclusively prepared for the purposes of the
Issue and issued by CARE Analytics and Advisory Private Limited appointed by us pursuant to an engagement
letter dated April 16, 2025, and is exclusively commissioned and paid for by our Company (“CARE Report”).
We commissioned and paid for the CARE Report for the purposes of confirming our understanding of the industry
specifically for the purposes of the Issue, as no report is publicly available which provides a comprehensive
industry analysis, particularly for our Company’s products, that may be similar to the CARE Report. The CARE
Report is available on the website of our Company at https://www.sihl.in/. The data included herein includes
excerpts from the CARE Report and may have been re-ordered by us for the purposes of presentation. CARE
Analytics and Advisory Private Limited is not, and has not in the past, been engaged or interested in the formation,
or promotion, or management, of our Company. Further, it is an independent agency and neither our Company,
nor our Directors, Promoter, KMPs, SMPs, and Subsidiaries, nor the BRLM are a related party to CARE
Analytics and Advisory Private Limited as per the definition of “related party” under the Companies Act, 2013.
Prospective investors are advised not to unduly rely on the CARE Report. There are no parts, data or information
(which may be relevant for the proposed issue), that have been left out or changed in any manner. For more
information and risks in relation to commissioned reports, see “Risk Factors – Certain sections in this Draft Red
Herring Prospectus contain information from the CARE Report, which was prepared by CARE Analytics and
Advisory Private Limited and exclusively commissioned and paid for by our Company for the purposes of the
Issue, and any reliance on such information for making an investment decision in the Issue is subject to inherent
risks.” on page 75. There are no parts, data or information (which may be relevant for the proposed Issue), that
has been left out or changed in any manner. Also see, “Certain Conventions, Use of Financial Information and
Market Data and Currency of Presentation –Industry and Market Data” on page 13. Unless otherwise indicated,
financial, operational, industry and other related information derived from the CARE Report and included herein
with respect to any particular year refers to such information for the relevant calendar year.
40Unless the context otherwise requires, in this section, references to “we”, “us”, or “our” refers to Shah Investor’s
Home Limited on a consolidated basis and references to “the Company” or “our Company” refers to Shah
Investor’s Home Limited on a standalone basis.
Internal Risk Factors
1. Our broking segment contributes 68.90%, 71.60%, and 71.60% of our revenue for the Fiscals 2025, 2024
and 2023, respectively. Any reduction in our revenue from broking segment could have a material adverse
effect on our business, results of operations, cash flows and financial condition.
Our broking segment has consistently been our largest business vertical and contributes a substantial share to our
revenue from operations. Our income from broking and related services in the Fiscals 2025, 2024 and 2023, are
set out below:
Particulars Fiscal 2025 Fiscal 2024 Fiscal 2023
Revenue (in ₹ % of revenue Revenue (in ₹ % of revenue Revenue (in ₹ % of revenue
lakhs) from lakhs) from lakhs) from
operations operations operations
Broking
6,491.13 68.85 5,570.20 71.57 3,702.79 71.64
Segment
Other 2,936.26 31.15 2,212.16 28.43 1,465.51 28.36
Total 9,427.39 100.00 7,782.36 100.00 5,168.30 100.00
Our Brokerage Income is directly proportionate to the traded value and order size. The number of orders and the
trading volume are affected by a variety of external factors that are beyond our control such as the general
macroeconomic conditions, particularly, in India, the monetary and taxation policies of the Government of India,
prevailing market conditions, the prevailing regulatory framework, fluctuation in interest rates, inflation etc. In
addition, our business operations are subject to regulatory limits on brokerage fee rates and net worth requirements
imposed by the exchanges. In addition, our Brokerage Income is also driven by the number of clients, in particular
individual investors, to whom we cater and the size of these transactions.
Set out in the table below are the number of clients in our Broking businesses we catered to, in the Fiscal 2025,
Fiscal 2024 and Fiscal 2023:
Particulars Fiscal 2025 Fiscal 2024 Fiscal 2023
No. of clients catered to in Broking Segment 37,814 35,535 31,372
If there is a significant decline in investor participation in equity markets, or if we are unable to maintain and grow
our client base, particularly, higher yield clients, and, or, if our service levels are not up to client expectations our
Broking business could be adversely affected.
Our brokerage fee levels are primarily driven by the competitive landscape our Company operates in. There is
constant pressure on brokerage yields in the securities industry, especially as we have no exclusivity arrangements
with our clients, our clients may use services from multiple brokerage houses, simultaneously and the products
are standardised and offered online. If we face increased competition on our brokerage fee levels, we may have
to provide additional products and services in addition to lowering our brokerage fee, to attract clients.
Additionally, on account of change in our business model, any reduction in the number of orders may adversely
affect our business since the fee we charge is based on the number of orders executed by us. Further, there is no
assurance that we will be able to attract such clients without having to reduce our fee, which could have a material
adverse effect on our business, financial condition, cash flows and results of operations. Accordingly, if our
competitors are able to provide better services, lower margins, better rates of interest on margin trading facility or
if their products are perceived to be more appealing to clients, they could migrate all or a part of their business to
our competitors and hinder our ability to retain and attract new clients. Further, if we are required to reduce our
margins to retain existing clients or attract new clients it could adversely affect our Broking Segment. Any adverse
impact on our Broking Segment due to any of the aforementioned factors including the external and
macroeconomic factors and the regulatory environment in India, could have a significant adverse impact on our
business, results of operations, profitability, cash flows and financial condition.
2. We are subject to extensive statutory and regulatory requirements and supervision. Any failure to comply
with applicable law or changes in the regulatory framework could result in action being initiated against
41us by relevant authorities which may have a material adverse impact on our business, results of operations
and financial condition.
We have a diversified range of operations and our business activities are subject to extensive supervision and
regulation by the Government and various statutory and regulatory authorities, in particular, SEBI, MCX, AMFI,
APMI, NSDL and the Stock Exchanges. Consequently, we may need to obtain registrations and approvals under,
and comply with, regulations issued by various regulatory authorities to undertake some of our business and
corporate activities, including for the launch of new products, infusion of equity capital, amending our
constitutional documents, change in (i) shareholding / increase in share capital, (ii) designated and non-designated
directors, (iii) control, (iv) status and constitution, and (v) name of the member. Such regulations include the SEBI
(Stock Brokers) Regulations, 1992, the SEBI (Research Analysts) Regulations, 2014, the SEBI (Depositories and
Participants) Regulations, 2018, SEBI (Mutual Funds) Regulations, 1996, Securities and Exchange Board of India
(Portfolio Managers) Regulations, 2020 and the various circulars etc that are issued under the applicable
regulations, AMFI Guidelines, etc. Additionally, we need to ensure compliance with various statutes, such as the
Securities Contracts Regulations Act, 1956, the SEBI Act, 1992, and various rules, regulations, notifications and
circulars issued under such statutes. In addition, our business operations are subject to regulatory limits on
brokerage fee rates and net worth requirements imposed by the exchanges. Additionally, we will continue to
expand our product portfolio as permitted by applicable law, and based on our evaluation of market opportunity,
which could require us to comply with additional regulatory requirements and expose us to risks that we cannot
currently foresee.
Our business activities are also subject to periodic inspection by various applicable authorities, including SEBI.
Any negative findings against us during such inspections may materially and adversely affect our business and
results of operations. While we strive to ensure compliance with applicable laws including various statues, rules,
regulations and circulars issued by SEBI and other relevant regulatory authorities, any failure on our part (or on
the part of our employees) to comply with applicable law could result in action being initiated against us and our
employees by the relevant authorities. Such action could be in the form of monetary fines, strictures on operations,
suspension or cancellation of our various licenses. In addition, the regulatory and statutory framework within
which we operate our business evolves with time. Further, the change could be in response to various aspects
including global regulatory trends, corporate governance and ESG norms. Accordingly, the laws and regulations
applicable to our business are subject to amendments, revisions, replacements etc. including pursuant to action by
government or regulatory authorities or further to intervention or directions of the judicial and quasi-judicial
authorities including the Securities Appellate Tribunal.
In the past three Fiscals regulatory authorities such as SEBI have pursuant to inspections issued
findings/observations letter administrative warnings, deficiency letters, show cause notices. For instance, our
Company received a letter bearing reference no. SEBI/WRO/JS/PD/OW/P/2025/2463/1 dated January 23, 2025
(the “Letter”), from SEBI, highlighting certain observations/findings pursuant to the inspection of our books of
accounts, records, and other documents relating to the upstreaming and down streaming of client funds conducted
by SEBI and the Stock Exchanges on December 05, 2024, December 06, 2024, and January 02, 2025 January 03,
2025. The Letter included the following observations (i) on verification of bank statements, out of 30 sample dates
reviewed, client funds were retained instead of being up streamed to the clearing corporations on 18 dates, (ii)
funds were transferred from the settlement account to the upstreaming client nodal bank account (USCNBA) and
(iii) funds were transferred from the settlement account to the down streaming client nodal bank account
(DSCNBA), wherein the said transfers were not in compliance with SEBI circulars (collectively referred to as the
“Observations”). We submitted our detailed response to the said Observations on February 07, 2025, and have
not received any further communication from SEBI in this regard.
Details of the inspection letter and observation is provided below:
Sr.
Date Observations Penalty
No
1. The data uploaded by the Company for client level Monetary penalty of ₹37,500
NSE Inspection
holding statement, cash and cash equivalent balances and along with advice, warning
Letter of
bank and direction*
Observation dated
January 22, 2025
Account balances by members on a weekly/daily basis is
not correct.
The Company has made pay-out of funds to clients in
excess of their available balances
42Sr.
Date Observations Penalty
No
The Company has not settle the client funds.
Member has engaged as a principal in a business other
than that of securities involving personal financial
liability
The Company has incorrectly reported margin collection
from clients
The Company has incorrectly opened minor accounts in
derivatives segment
The Company has not reported the closure of bank
account to the Exchange within one week of the closure
The Company has not assigned: appropriate
nomenclature to its bank accounts and Trading terminals
situated at the place of inspection were not operated by
approved users/persons
Misuse of clients' funds in the range of ₹48.36 lakhs to The Committee decided to
2. February 16, 2023
₹4.27 crores on 8 days between September 7, 2022, and warn the noticee to ensure
September 22, 2022, thereby violating Principle 1 of the non-recurrence of the
enhanced supervision of stockbrokers. observed violation.
*The company has paid the said penalty.
However there are no arbitration orders in past 3 financial years. Any delay or failure in obtaining such approvals,
or non-compliance with regulatory requirements, observations, or directions, may result in the imposition of fines,
substantial penalties, suspension, or, in extreme cases, termination of our registrations. Such outcomes could have
a material and adverse impact on our business, operations, reputation, and financial performance.
Further, we are subject to various laws relating to the prevention of insider trading, front running and other
conflicts of interest. Conflicts of interest may exist including between, (i) us and our clients; (ii) us and our
Authorised Persons (i.e. agents appointed by us after approval from the relevant stock exchange), (iii) our
employees and us and, or, our clients, (vi) our intermediaries and us; (vii) our intermediaries and our clients or
(viii) the Company and our Subsidiaries. While we are required to frame and implement, and we have put in place
internal controls and measures, we cannot assure you that we or our agents, intermediaries or employees will
always manage such conflicts of interest, including compliance with various applicable laws and regulations. Our
Company has established policies to deal with insider trading, conflict of interest etc. and our activities and
responsibilities are delineated by clear-cut regulations, we cannot assure you that we will always be successful in
ensuring compliance and, or, managing any conflicts of interest. We cannot assure you that changes in applicable
laws will not impose onerous conditions on our business activities, require us to change existing systems, policies
and procedures. Any onerous conditions imposed by relevant authorities, or material changes required to our
systems, policies and procedures may increase our compliance cost or adversely affect our business operations.
There have been no such instances that have occurred in the past.
Further, data collection and storage are increasingly subject to legislation and regulations in various jurisdictions
and governments are increasingly acting to protect the privacy and security of personal information. Our attempts
to comply with applicable legal requirements may not be successful, and may also lead to increased costs for
compliance, which may materially and adversely affect our business, financial condition, cash flows, results of
operations and prospects. We could be adversely affected if legislations or regulations are expanded or amended
to require changes in our business practices, or if such legislations or regulations are interpreted or implemented
in ways that negatively affect our business, financial condition, cash flows, results of operations and prospects.
3. We rely heavily on our network of Authorised Persons associated with us. Loss of a significant number of
Authorised Persons, or failure to expand our network of Authorised Persons may have an adverse impact
on our business, results of operations and financial conditions. Further, we could be liable for the lapses
of our Authorised Persons.
43Our Broking business have consistently been a significant source of our revenues from operations, and we expect
that this will continue for the foreseeable future. While we generate a significant portion of our revenues from
Broking business directly from our clients, we also rely heavily on our Authorised Persons who canvass business
for us. As on March 31, 2025 we had 184 Authorised Persons. Set out in the table below are our aggregate revenues
from our Broking business, the aggregate revenues generated through Authorised Persons and brokerage sharing
expense paid to Authorised Persons in the Fiscal 2025, Fiscal 2024 and Fiscal 2023, in accordance with our
Restated Consolidated Financial Information:
Particulars Fiscal 2025 Fiscal 2024 Fiscal 2023
Revenue % of Revenue % of Revenue % of
(in ₹ lakhs) revenue (in ₹ lakhs) revenue (in ₹ lakhs) revenue
from from from
operations operations operations
Aggregate revenue from
6,491.13 68.85 5,570.20 71.57 3,702.79 71.64
Broking Segment
Revenue generated from
5,104.39 54.14 4,541.55 58.36 2,998.05 58.01
Authorised Persons
Brokerage sharing expense 3,463.18 36.74 3,078.94 39.56 1,964.08 38.00
While we enter into a prescribed contract with each of the Authorised Person associated with us, there can be no
assurance that we will be able to retain the services of such Authorised Persons or that they will not terminate
their association with us. If we are unable to retain the services of a significant number of such Authorised Persons
for any reason including due to expectation of a higher revenue sharing arrangement, our business could be
adversely affected to the extent we are unable to find adequate replacements for such Authorised Persons and the
revenue generated from them. Set out below are details of attrition in our network of Authorised Persons for the
periods indicated therein:
Particulars Fiscal 2025 Fiscal 2024 Fiscal 2023
Total number of Authorised Persons 184 174 193
Number of Authorised Persons who ceased their 17 36 2
association with our Company during the period.
Number of new Authorised Persons appointed 27 17 4
Attrition rate* 9.24% 20.69% 1.04%
The above data has been derived from list of Company’s authorised personnel registered on NSE.
*Attrition rate is calculated by dividing number of Authorized Persons who ceased their association with our Company during the period by
total number of Authorised Persons as at the end of the relevant year.
The growth in our Authorised Persons network has also contributed to the growth of our business. Accordingly,
the inability to consistently grow our network of Authorised Persons could also adversely impact our business,
financial condition and growth prospects. Further, in terms of the prescribed contract with Authorised Persons
and in accordance with applicable law, we are responsible and liable for the acts of omission and commission of
the Authorised Persons and, or, their employees, and accordingly, we may be held responsible for various actions
of the Authorised Persons and their employees. While the contract with the Authorised Persons sets out our inter-
se rights and obligations and requires the Authorised Persons to comply with applicable laws, we cannot assure
you that there will be no failure on the part of Authorised Persons for which we could be made liable.
4. Any failure to obtain, renew and maintain requisite statutory and regulatory permits, licenses and
approvals for our operations from time to time may adversely affect our business.
Our business is subject to compliance with the rules, regulations, bye-laws and circulars prescribed by various
entities including SEBI, APMI, AMFI, depositories, stock exchanges and commodity exchanges, and other
regulatory authorities, and the terms and conditions of the approvals, licenses, registrations and permissions
obtained for operating our business. Some of the approvals, licenses and registrations may elapse in the ordinary
course of business and we make applications for renewal as required in accordance with applicable law, while
certain other registrations are valid until they are suspended or cancelled by the issuing authority but are subject
to payment of registration fee at periodic intervals. Further, in accordance with the regulations formulated by
SEBI and other regulatory authorities, we are required to intimate or obtain approvals amongst others, for changes
in our Board, changes in our shareholding pattern, and undertaking certain corporate actions. We cannot assure
you that in the future that the licenses, approvals and permits applied for or held by us will be issued, approved or
renewed in a prompt manner, or at all, under applicable law. Our failure to renew or obtain such licenses and
approvals in a timely manner, or at all, and comply with the provisions of the applicable laws and regulations
44could lead to suspension or cancellation of our registration or imposition of sanctions by the relevant authorities,
including penalties. While there have not been any such instances of failure to renew or obtain such licenses and
approvals in a timely manner in the past, we may not be able to continue obtaining such licenses for our business
requirements.
5. We rely on the Indian exchanges for a significant portion of our business, and we are registered with such
exchanges and are subject to the rules and regulations framed by such exchanges. Any disruption in the
functioning of the exchanges or a disruption to our connection with the exchanges or failure to comply
with exchange rules and regulations could have a material adverse effect on our business and results of
operations.
Our Broking Segment relies on the Indian exchanges, including NSE, NSEIX, BSE, MCX and MSEI, and the
clearing corporations to execute and settle all our clients’ transactions. Our clients trading systems are connected
to the exchanges and all orders placed by our clients are routed and executed through the exchanges. To use the
services of the exchanges, we are required to be registered as their members. For further details, please refer
“Government approval” on page 619. This registration subjects us to various stock exchange regulations and
periodic inspections by such exchanges. Any disruption in the functioning of the exchanges or a disruption to our
connection with the exchanges could have a material adverse effect on our business and results of operations. We
cannot assure you that we will be able to strictly comply with such regulations or that such inspections would not
find any violations by us. Failure to comply with such regulations could lead to fines, penalties, suspension of our
registrations, and in extreme circumstances, termination of our registration. If our registration with the exchanges
is terminated, we will be unable to provide brokerage services, which will have a material adverse effect on our
business, financial condition and results of operations. In addition, our business operations are subject to
regulatory limits on brokerage fee rates and net worth requirements imposed by exchanges.
6. Our continued success and growth will be dependent on our ability to retain and grow our client base and
network of Authorised Person and relationship managers. Failure to retain and augment our client base
could have a material adverse effect on our business, financial condition and growth prospectus.
Our business operations have in the recent past witnessed significant growth, which is to a large extent correlated
to the growth in our active client base (Active clients are clients who have undertaken transactions in a Fiscal),
our average revenue per client (i.e., broking revenue over Active Clients for the period) (ARPC), and the number
of Authorised Persons who are associated with us. Accordingly, our ability to sustain our growth is materially
linked to our ability to retain and expand our client base and network of Authorised Person and relationship
managers. The table below sets out our number of Active Clients, revenue from Broking Segment and our ARPC:
Particulars Fiscal 2025 Fiscal 2024 Fiscal 2023
Total number of Active Clients 37,814 35,535 31,372
Revenue from Broking Segment (₹ in lakhs) 6,491.13 5,570.20 3,702.79
ARPC (in ₹) 17,166 15,675 11,803
Further, relationship management has been one of the cornerstones of our client acquisition and retention model
and, as on August 31, 2025, we employ 22 relationship managers and will need to provide better and customized
services and products to differentiate ourselves and to retain our existing client base and attract new clients. Our
ability to retain and augment our client base will depend on our ability to continuously provide service levels that
are expected by our clients. As on the date of this Draft Red Herring Prospectus, we had Nil outstanding investor
grievances pertaining to, amongst others, deficiency in service, incorrect or excess charge being levied,
discrepancy in transaction statement etc. which are at various stages of resolution. Failure to retain and augment
our client base could have a material adverse effect on our business, financial condition and growth prospectus.
7. We have high working capital requirements. Any failure in arranging adequate working capital for our
operations may adversely affect our business, results of operations, cash flows and financial condition.
Our business operations are subject to high working capital requirements. Set out in the table below are select
aspects of our assets and liabilities, derived from our Restated Standalone Financial Statements:
(₹ in lakhs)
Particulars As at March 31, 2025 As at March 31, 2024 As at March 31, 2023
Current assets
Trade receivables 1,684.29 752.92 1,074.84
Cash and cash equivalents 8,012.48 12,691.32 2,613.89
Other Balances with Banks 7,332.27 4,534.83 7,404.53
45Particulars As at March 31, 2025 As at March 31, 2024 As at March 31, 2023
Loans (Margin Trading Facility 965.07 1.25 5.09
Book - MTF Book)
Current tax assets (Net) 185.29 185.79 245.28
Other current non-financial assets 81.24 97.74 57.09
Total current assets (A) 18,260.64 18,263.85 11,400.72
Current liabilities
Trade payables 13,587.56 13,990.46 8,339.73
Other financial liabilities 1.60 1.49 2.02
Provisions 162.95 198.31 87.09
Other non-financial liabilities 66.74 111.01 55.31
Total current liabilities (B) 13,818.85 14,301.27 8,484.15
Net working capital (A-B) 4,441.79 3,962.58 2,916.57
Funding pattern
Borrowings & Internal accruals 4,441.79 3,962.58 2,916.57
As certified by the Independent Chartered Accountant, Dhrumil A. Shah & Co., Chartered Accountants (FRN: 145163W) by way of their
certificate dated September 29, 2025.
Currently, we meet our working capital requirements through a mix of internal accruals and working capital
facilities from scheduled commercial banks, other related parties, and loans from others. We also intend to utilise
a portion of Net Proceeds towards funding our working capital requirements. For further details of the proposed
objects of the Issue, see ‘Object of the Issue’ on page 357. As on August 31, 2025, our total fund based outstanding
borrowings including unsecured borrowings (excluding vehicle loans) aggregating ₹ 3,054.04 lakhs on standalone
basis and ₹ 3,380.29 lakhs on consolidated basis.
While we believe that our internal accruals, working capital facilities outlined above and the portion of the Net
Proceeds of the Issue towards working capital, will be sufficient to address our working capital requirements, we
cannot assure you that we will continue to generate sufficient internal accruals and, or, be able to raise adequate
working capital from lenders to address our future needs. Our inability to meet our present working capital
requirements or our enhanced working capital requirements will have an adverse impact on our results of
operation, business and financial condition.
8. We have applied for registrations of certain intellectual property rights and any failure to enforce our
rights could have an adverse effect on our business prospects.
Our trademark is significant to our business and operations. We have applied for trademark of our logo
appearing on the cover page of this Draft Red Herring Prospectus under class 36 and the same has been applied
for registration vide application number 7239764. For further information, see “Government and Other
Approvals” on page 619. Our ability to enforce our trademark and other intellectual property is subject to general
litigation risks and an action for passing off may not sufficiently protect our trademarks or trade names and other
intellectual property rights. If we are unable to register our trademark for various reasons including our inability
to remove objections to our trademark application, or if any of our unregistered trademarks are registered in favour
of or used by a third party, we may not be able to claim registered ownership of such trademarks and consequently,
we may not be able to seek remedies for infringement of those trademarks by third parties other than relief against
passing off by other entities, causing damage to our business prospects, reputation and goodwill. Further, we may
not have adequate mechanisms in place to protect our confidential information. While we do take precautions to
protect confidential information against breach of trust by employees, consultants and investors, it is possible that
unauthorized disclosure of confidential information may occur.
In addition, we may become subject to claims by third parties if we use slogans, names, designs, software or other
such subjects in breach of any intellectual property rights registered by such third party. While there have been
no such instances in the past, any legal proceedings pursuant to such claims, or settlements thereunder, may divert
management attention and require us to pay financial compensation to such third parties, as well as compel us to
change our marketing strategies or brand names of our products and services, which could adversely affect our
business, prospects, results of operation and financial condition.
9. We are dependent on technology in carrying out our business activities and information technology forms
an integral part of our business. Failure or inadequacies in our information technology systems may
46hamper our ability to compete effectively which may result in lower revenue, higher costs and would
adversely affect our business and results of operations.
Our operations rely heavily on the effectiveness of our information technology systems and their ability to
accurately and comprehensively record and process a large number of transactions on a daily basis and in a timely
manner to provide a seamless transactional experience for our clients.
The details of average daily orders we processed in Fiscals 2025, 2024 and 2023 are as set forth below:
Particulars Fiscal 2025 Fiscal 2024 Fiscal 2023
Average daily transactions 19,702 16,416 12,501
Therefore, our IT systems, and our ability to continually adapt such systems to evolving technologies and industry
standards and practices, are critical to our continued success. While we have put in place systems to ensure the
efficacy and effectiveness of our operations including to ensure compliance with the applicable laws such as cyber
security and data privacy, we continually work on strengthening our information technology systems to meet our
clients’ requirements and keep pace with technological developments. Nevertheless, a prolonged disruption, or
failure, of our information processing or communications systems would limit our ability to process transactions
and could hamper our operations and adversely affect our competitiveness. While there have not been prolonged
disruptions or failures of our IT systems, there have been various instances of technical software glitches such as
the portfolio not being visible on our trading application, the last traded prices not being updated and critical
failure of risk management application server for a few hours which resulted in regular automated fund
information to the exchanges being delayed. We rely heavily on technology and rely on our electronic trading
platform and mobile apps to provide a wide range of brokerage and distribution services. Due to the rapid
evolution in technology and AI, trades take place through machine-based algorithms within a few microseconds.
This AI-based buying and selling system has changed the mechanism of supply and demand and it is now to
estimate individualised pricing, based on individualised demand and supply. If we are unable to keep up with
technological changes, especially adapting to the AI based trade system while our competitors invest in improved
or better technologies or entry of new players who may be able to offer clients better products and user experience.
If we are unable to effectively compete on IT-enabled offerings, it could have a material adverse effect on our
business, financial condition, cash flows, results of operations and prospects.
We are required to have business continuity plans and review them periodically, maintain disaster recovery centers
and periodically conduct drills to test these measures, and even though we have taken necessary steps in this
regard, we cannot assure you that there will not be unforeseen circumstances or that our disaster recovery planning
is adequate for all eventualities. Further, failure to continually update such plans or if our data recovery centers
prove inadequate or if these are not properly maintained, our business and results of operations could be adversely
affected, and we could be subject to regulatory action and penalties.
Further, with the rapid evolution of technology systems, the threats to such systems also multiply and we face
varied challenges in dealing with threats including cyber-attacks, such as hacking, phishing and trojans, which
could potentially exploit our network and disrupt services to clients and/or result in the theft of sensitive internal
company data or client information. While we have an established cyber security policy to address and deal with
cyber security and other technology related threats and risks, we cannot assure you that we will be able to prevent
attacks before they occur or mitigate or minimise the risk if such threats materialise. In addition, while our systems
are largely automated it is still subject to, and requires, human intervention and involvement at different levels,
and we cannot rule out the possibility of human error affecting our technology systems. Further, our technology
systems are also vulnerable to disruptions due to catastrophic events, natural disasters, capacity constraints during
peak trading times or times of unusual market volatility, power failure, computer viruses, spam attacks, ransom
ware, distributed denial of services attacks, unauthorized access, data leakage and other similar disruptive events
which we may not be able to prevent or mitigate against. An external information security breach, such as hacker
attacks, frauds, virus or worm infestation of our IT systems, or an internal problem with information protection,
such as failure to control access to sensitive systems, could materially interrupt our business operations or cause
disclosure or modification of sensitive or confidential information. Disruptions to, or instability of, our technology
or external technology, or failure to timely upgrade our online or mobile brokerage platforms could harm our
business, reputation and prospects.
10. There are certain discrepancies, errors, and non-compliance which have occurred in some of our
corporate records relating to forms filed with the RoC and other provisions of Companies Act, 2013/1956.
47Any penalty or action taken by any regulatory authorities in future, for non-compliance with provisions of
corporate or any other law could impact the financial position of the Company to that extent.
There have been certain discrepancies, errors, and non-compliance which have occurred in some of our corporate
records relating to forms filed with the RoC and other provisions of Companies Act, 2013/1956. This may subject
us to regulatory actions and/or penalties which may adversely affect our business, financial condition and
reputation.
For instance, there have been the following non-compliances in relation to regulatory filings:
Default
Events Non-compliance
Period
F.Y. Designations of Utpal Praful Shah, an Utpal Praful Shah, upon being re-designated as a whole time
2021-22 erstwhile director of the Company since director w.e.f. 25.09.2021, was in-eligible for being a member of
till 2023- his appointment was as an Additional the nomination and remuneration committee. However, the
24 Director w.e.f. 01.07.2008. nomination and remuneration committee was not reconstituted ,
thus not being in compliance with the provisions of Section
He was further appointed as an executive 178(1) from 25.09.2021 till 31.03.2024
director w.e.f. 01.10.2008 till 30.09.2013
and was re-appointed as a whole time
director w.e.f. 01.10.2014 till 30.09.2017
Change in designation from whole time
director to non-executive was w.e.f.
01.04.2015.
He was appointed as a member of
nomination and remuneration committee
w.e.f. 26.09.2019 and was re-appointed as
a whole time director w.e.f. 25.09.2021
till 24.09.2024.
Further, there were discrepancies in our Forms MGT-7 for multiple financial years, contain inconsistencies and
errors in the disclosure of our shareholding pattern. For certain years, individuals who are not part of our promoter
group were incorrectly classified as “Promoter Group” resulting in an overstatement of promoter group
shareholding, whereas in other years, certain members of the promoter group were disclosed under “Public/Other
than Promoters,” resulting in an understatement of promoter group shareholding. the bifurcation between
promoter group and public have also not been consistently or accurately disclosed in such filings. Other than these
there were certain clerical/typographical errors in Forms MGT-7 for multiple financial years.
There is no legal proceedings or regulatory action that has been initiated against our Company in relation to such
non-compliance or instances of non-filings or incorrect filings or delays in filing statutory forms with the RoC,
we cannot assure you that such legal proceedings or regulatory actions will not be initiated against our Company
in future and we cannot assure you that we will not be subject to any legal proceedings or regulatory actions,
including monetary penalties by statutory authorities on account of any future inadvertent discrepancies in our
secretarial filings and/or corporate records in the future, which may adversely affect our business, financial
condition and reputation. There can be no assurance that such lapses will not occur in the future, or that we will
be able to rectify or mitigate such lapses in a timely manner, or at all.
11. We are unable to trace some of our historical corporate records. We cannot assure you that no legal
proceedings or regulatory actions will be initiated against our Company in future in relation to the missing
corporate records which may impact our cash flows, financial condition and reputation.
We have been unable to trace certain secretarial records, including the form filings made by our Company.
Accordingly, we had commissioned a physical and electronic search of the RoC records through a practicing
company secretary firm, Mittal V Kothai & Associates, to retrieve missing documents and provide us with a list
of secondary documents relied upon for transfers between shareholders of our Company, and the Practicing
Company Secretary has issued a report dated September 29, 2025, in this regard. For instance, we have been
unable to trace copies of the following corporate records of our Company, which have been sent to ROC vide our
inward letter dated September 23, 2025:
S. No. Brief particulars of untraceable corporate record or form filing
48Allotment Of Shares
1. Form 23 for Registration of Special resolution with MCA for further issue of shares on December 30, 1994
2. Form 23 for Registration of Special resolution with MCA for further issue of shares on October 09, 1995
3. Renunciation letters for shares renounced under Right issue on November 01, 1996
4. Form 23 for Registration of Special resolution with MCA for further issue of shares on October 31, 1999
5. Form 23 for Registration of Special resolution with MCA for further issue of shares on August 01, 2000
6. List of Allottee in form 2 is not complete for August 01, 2000
7. Form 23 for Registration of Special resolution with MCA for further issue of shares on September 15, 2005
8. Form 23 for Registration of Special resolution with MCA for further issue of shares on February 29, 2008
9. MGT-14 for Board Resolution of bonus issue on November 21, 2017
Registration Of Resolution And Agreement
10. Form 23 Appoint of Upendra Shah as Whole-time director resolution date December 01, 2006
11. Form 23 Appoint of Upendra Shah as Whole-time director resolution date February 11, 2012
12. Form 23 Appoint of Tanmay Upendra Shah as Whole-time director resolution date September 30, 2008
13. Form 23 Appoint of Tanmay Upendra Shah as Whole-time director resolution date September 21, 2006
14. Form 23 Appoint of Tanmay Upendra Shah as Whole-time director resolution date February 11, 2012
Return Of Appointment Of Managing Director Or Whole-Time Director Or Manager
15. Form 25 Appoint of Trupti Utpal Shah as resolution date 11/02/2012
Particulars Of Appointment Of Managing Director, Directors, Manager And Secretary And The
Changes Among Them Or Consent Of Candidate To Act As A Managing Director Or Director Or
Manager Or Secretary Of A Company And/ Or Undertaking To Take And Pay For Qualification
Shares
16. Form 32 for Trupti Utpal Shah as Whole-time director resolution date August 21, 2008
17. Form 32 for Upendra Shah as Whole-time director resolution date December 01, 2006
18. Form 32 for Upendra Shah as Managing director resolution date September 01, 2006
19. This is to confirm that the following statutory forms have been not found in respect of Mr. Upendra Trikamlal
Shah and Mrs. Purnima Upendra Shah during their tenure with the Company from October 12, 1994 to
December 1, 2006: Form No. 32; Form No. 25 And Form No. 23
As certified by Mittal V Kothari & Associates, independent practising company secretary, vide their certificate dated September 29, 2025
List of supporting documents not traceable:
No. of
Sr. No. Date Transferor Transferee PCS Remark
shares
Form -7B and Transfer
Upendra Trikamalal
October 31, Jayantibhai K Patel & Kokila Price/consideration is not
1. 1000 Shah & Purnima
1996 J Patel traceable (serial number 14)
Upendra Shah
Form -7B and Transfer
Trupti Utpal Shah &
September 17, Upendra Trikamalal Shah & Price/consideration is not
2. (700) Purnima Upendra
1998 Purnima Upendra Shah traceable (serial number 90)
Shah
Form -7B and Transfer
September Sandhya R Punjabi & Rajesh Price/consideration is not
3. 5300 Trupti Utpal Shah
17,1998 R Punjabi traceable (serial number 88)
Form -7B and Transfer
Trikamlal F Shah & Price/consideration is not
September 17, Upendra Trikamalal Shah &
4. (4000) Upendra Trikamalal traceable (serial number
1998 Purnima Upendra Shah
Shah 112)
Form -7B and Transfer
Upendra Trikamalal Price/consideration is not
Chimanbhai N Patel &
5. May 15, 1999 20000 Shah & Purnima traceable (serial number
Shantaben C Patel
Upendra Shah 117)
Form -7B is not traceable
December 01, Upendra Trikamalal Shah & Bhaveshkumar
6. (400) (serial number 839)
2010 Purnima Upendra Shah Odhavjibhai Savani
Form -7B and Transfer
Upendra Trikamlal
September 17, Suraiya Ranawadia & Price/consideration is not
7. 2000 Shah HUF &
1998 Zubedabibi Ranawadia traceable (serial number 92)
Trikamlal F Shah
49No. of
Sr. No. Date Transferor Transferee PCS Remark
shares
Form -7B and Transfer
Upendra Trikamlal Price/consideration is not
September 17, Arvind M Thakkar &
8. 500 Shah HUF & traceable (serial number
1998 Prafulla A Thakkar
Trikamlal F Shah 105)
Form -7B and Transfer
Purnima Upendra Price/consideration is not
September 17, Rajesh R Punjabi & Sandhya
9. 15000 Shah & Upendra traceable (serial number
1998 R Punjabi
Trikamalal Shah 110)
Form -7B and Transfer
Tanmay Upendra Price/consideration is not
December 30,
10. 46700 Vimlaben T. Shah Shah & Purnima traceable (serial number
2002
Upendra Shah 240)
Form -7B and Transfer
Tanmay Upendra Price/consideration is not
December 30,
11. 49600 Trikamlal F. Shah Shah & Purnima traceable (serial number
2002
Upendra Shah 241)
Form -7B and Transfer
Preeti Upendra Shah Price/consideration is not
12. July 01, 2002 500 Gitaben J. Patel & Purnima Upendra traceable (serial number
Shah 201)
Transfer
Upendra Trikamalal Shah & Mukesh Naranbhai Price/consideration is not
13. March 12, 2013 (600)
Purnima Upendra Shah Kanodia traceable
Transfer
Upendra Trikamalal Shah & Gaurang Madhubhai Price/consideration is not
14. March 12, 2013 (600)
Purnima Upendra Shah Shah traceable
Transfer
Upendra Trikamalal Shah & Price/consideration is not
15. March 20, 2013 (20000) Pearl Shah
Purnima Upendra Shah traceable
Transfer
Upendra Trikamalal Shah & Price/consideration is not
16. March 20, 2013 (20000) Kenisha Shah
Purnima Upendra Shah traceable
Transfer
Upendra Trikamalal Shah & Price/consideration is not
17. March 20, 2013 (10000) Aashna Utpal Shah
Purnima Upendra Shah traceable
Transfer
Upendra Trikamalal Shah & Price/consideration is not
18. March 20, 2013 (10000) Rehaan Utpal Shah
Purnima Upendra Shah traceable
Transfer
Upendra Trikamalal Shah & Ruchira Tanmay Price/consideration is not
19. March 20, 2013 (20100)
Purnima Upendra Shah Shah traceable
Transfer
Upendra Trikamalal Shah & Shah Ritesh Price/consideration is not
20. March 20, 2013 (200)
Purnima Upendra Shah Pankajkumar traceable
Transfer
Upendra Trikamalal Shah & Price/consideration is not
21. March 20, 2013 (200) Ankit P. Shah
Purnima Upendra Shah traceable
Transfer
Upendra Trikamalal Shah & Shah Khushali Price/consideration is not
22. March 20, 2013 (200)
Purnima Upendra Shah Pankajkumar traceable
50No. of
Sr. No. Date Transferor Transferee PCS Remark
shares
Transfer
Upendra Trikamalal Shah & Price/consideration is not
23. March 20, 2013 (200) Panchal Bhavin A.
Purnima Upendra Shah traceable
Transfer
Upendra Trikamalal Shah & Saurin Pravinchandra Price/consideration is not
24. March 20, 2013 (200)
Purnima Upendra Shah Shah traceable
Transfer
Upendra Trikamalal Shah & Price/consideration is not
25. March 20, 2013 (200) Shah Alap Sudhirbhai
Purnima Upendra Shah traceable
Transfer
Sathvara
Upendra Trikamalal Shah & Price/consideration is not
26. March 20, 2013 (200) Pradipkumar
Purnima Upendra Shah traceable
Bakulbhai
Transfer
Upendra Trikamalal
Price/consideration is not
27. April 29, 2013 500 Heta Kalpesh Shah Shah & Purnima
traceable
Upendra Shah
Transfer
Upendra Trikamalal Shah & Kirankumar Ambalal Price/consideration is not
28. May 11, 2013 (300)
Purnima Upendra Shah Patel traceable
Transfer
Upendra Trikamalal Shah & Bina Kalpeshkumar Price/consideration is not
29. May 11, 2013 (300)
Purnima Upendra Shah Shah traceable
Transfer
Upendra Trikamalal Shah & Price/consideration is not
30. July 27, 2017 (1500) Luv Vikram Kothari
Purnima Upendra Shah traceable
Transfer
Neha Jhaveri & Rajiv Upendra Trikamlal Price/consideration is not
31. July 4, 2012 600
Jhaveri Shah HUF traceable
Transfer
Archana Parikh & Ketan Upendra Trikamlal Price/consideration is not
32. July 4, 2012 600
Parikh Shah HUF traceable
Transfer
Price/consideration and
Utpal Praful Shah &
33. May 27, 2013 500 N.A. name of the transferor is not
Trupti Utpal Shah
traceable
Transfer
Utpal Praful Shah & Price/consideration is not
34. July 10, 2013 200 Parul Hiteshbhai Chauhan
Trupti Utpal Shah traceable
Transfer
January 02, Utpal Praful Shah & Trupti Price/consideration of the
35. (400) Kirit Govindlal Shah
2015 Utpal Shah Transferree is not traceable
Transfer
April 27, Utpal Praful Shah & Trupti Hansaben Price/consideration is not
36. (300)
2015 Utpal Shah Ghanshayam Khatri traceable
Transfer
Utpal Praful Shah & Trupti Manish Kishanlal Price/consideration is not
37. April 27, 2015 (300)
Utpal Shah Shajwani (HUF) traceable
Transfer
Utpal Praful Shah & Trupti Kishanlal Ramchand Price/consideration is not
38. April 27, 2015 (300)
Utpal Shah Shajwani (HUF) traceable
51No. of
Sr. No. Date Transferor Transferee PCS Remark
shares
Transfer
November Utpal Praful Shah & Trupti Sonal Sanjaybhai Price/consideration of the
39. (300)
21, 2015 Utpal Shah Shah Transferee is not traceable
Transfer
January 01, Utpal Praful Shah & Price/consideration of the
40. 200 Nishaben Ajaybhai Vakharia
2016 Trupti Utpal Shah Transferor is not traceable
Transfer
February 12, Utpal Praful Shah & Price/consideration of the
41. 300 Sonal Sanjaybhai Shah
2016 Trupti Utpal Shah Transferor is not traceable
Transfer
Price/consideration of the
42. August 11, 2022 1200 Vishal Dipakkumar Parikh Utpal P. Shah HUF
Transferor is not traceable
Transfer
Upendra Trikamalal Shah & Price/consideration is not
43. March 20, 2013 10000 Rehaan Utpal Shah
Purnima Upendra Shah traceable
Transfer
Upendra Trikamalal Shah & Price/consideration is not
44. March 20, 2013 10000 Aashna Utpal Shah
Purnima Upendra Shah traceable
Transfer Price/
September 12, consideration of the
45. 3000 Luv Vikram Kothari Preeti Upendra shah
2018 Transferor is not traceable
Upendra Trikamlal
Shah, Preeti Upendra Transfer
January 31, Shah, Utpal Price/consideration is not
46. 1800 Purnima Ashok Kumar shah
2018 Prafulbhai traceable
Shah/Rajesh R
Punjabi
Upendra Trikamlal
Transfer
Shah, Preeti Upendra
Price/consideration and
February 01, Shah, Utpal
47. 600 N.A. Name of the Transferor is
2018 Prafulbhai
not traceable
Shah/Rajesh R
Punjabi
Upendra Trikamlal
Shah, Preeti Upendra Transfer
February 02, Shah, Utpal Price/consideration is not
48. 1800 Ranjan Narendra Patva
2018 Prafulbhai traceable
Shah/Rajesh R
Punjabi
Upendra Trikamlal
Shah, Preeti Upendra Transfer
February 03, Shah, Utpal Price/consideration is not
49. 1200 Rupa Sunil shah
2018 Prafulbhai traceable
Shah/Rajesh R
Punjabi
Transfer
Upendra Trikamlal Shah,
Price/consideration and
February 06, Preeti Upendra Shah, Utpal
50. (3000) N.A. Name of the transferee is
2018 Prafulbhai Shah/Rajesh R
not traceable
Punjabi
As certified by Mittal V Kothari & Associates, independent practising company secretary, vide their certificate dated September 29, 2025.
In addition, we have been unable to locate share transfer forms, depository instruction slips for various transfers
involving our Promoters. For further details of these transfers, see “Capital Structure - Build-up of the Promoters’
shareholding in our Company” on page 104. Despite reaching out to our Promoters involved in these transfers
regarding any documentation which may be available with them for the aforesaid secretarial and other corporate
documents and records, we have not been able to trace the aforementioned documents. Accordingly, we have
52relied on the report dated September 29, 2025, issued by the practicing company secretary firm, Mittal V Kothai
& Associates.
While no legal proceedings or regulatory action has been initiated against our Company in relation to untraceable
secretarial and other corporate records and documents as of the date of this Draft Red Herring Prospectus, we
cannot assure you that such legal proceedings or regulatory actions will not be initiated against our Company in
future which may impact our cash flows, financial condition and reputation. We cannot assure you that such
untraceable secretarial and other corporate records and documents will be available with us in future.
12. Our Company had issued Equity Shares to more than 49 investors in the past and as a matter of abundant
caution for better corporate governance, our Company has given an exit offer to the eligible shareholders.
The Company, through separate preferential allotments dated 01-11-1996, 31-10-1999 and 29-02-2008 allotted
7,06,000, 40,85,000 and 2,67,000 equity shares of face value of ₹10 each, to 193, 65 and 502 persons (including
Promoters) (the “Original Allottees”) on February 29, 2008 (the “Stated Allotment”). In terms of the first
proviso to Section 67(3), inserted vide Companies Amendment Act, 2000, of the Companies Act, 1956, an offer
or invitation for subscription of shares made to more than 49 persons would be considered as Public Offer. Under
the Companies Act, 2013, post April 01, 2014, any offer or allotment of securities shall be construed as public
issue if the number of offerees / allottees exceeds 200 persons in a financial year.
Post notification of the Companies Act, 2013, as amended, SEBI, by way of its circular number
CIR/CFD/DIL3/18/2015, dated December 31, 2015 (the “2015 Circular”) and circular number
CFD/DIL3/CIR/P/2016/53, dated May 3, 2016 (the “2016 Circular”, and such circulars, together with the SEBI
press release dated November 30, 2015, the “SEBI Circulars”), provided that companies involved in issuance of
securities to more than 49 persons but up to 200 persons in a financial year prior to April 2014 may avoid penal
action subject to fulfilment of certain conditions. Such conditions include, among others, an option to surrender
such securities being provided to the current holders of such securities at an exit price, which is not less than the
subscription amount along with interest at the rate of 15% p.a. (net of amounts already paid to such allottees as
interest, dividend or otherwise) or such higher return as promised to the investors. It was clarified in a press release
issued by SEBI on November 30, 2015, that the exit offer may be provided by the company itself or by the
promoters or by other persons arranged by the company or its promoters.
Our Company (“Applicant”) filed a suo-moto settlement application in terms of the SEBI (Settlement of
Administrative and Civil Proceedings) Regulations, 2014 which is repealed and replaced with SEBI (Settlement
Proceedings) Regulations, 2018 with effect from January 01, 2019 (hereinafter referred to as ‘Settlement
Regulations’) proposing to settle, without admitting the findings of fact and conclusions of law, through a
settlement order, the non-compliance with Section 56, Section 67 and Section 73 of the Companies Act, 1956 and
the provisions of the SEBI(Disclosure and Investor Protection) Guidelines, 2009 (hereinafter referred to as “DIP
Guidelines”). The applicant in the application submitted that it had made preferential allotment of its equity shares
to 502 allottees on February 29, 2008. The said allotment was in violation of Section 56, Section 67 and Section
73 of the Companies Act, 1956 and the DIP Guidelines. The applicant submitted that it had provided an exit offer
to all eligible shareholders and also submitted a certificate of compliance with the requirement of the aforesaid
SEBI Circular from an independent Chartered Accountant. The applicant, vide letter dated March 02, 2019,
proposed the revised settlement terms to settle the defaults mentioned above. The High-Powered Advisory
Committee (‘HPAC’) in its meeting held on March 29, 2019 considered the settlement terms proposed and
recommended the case for settlement upon payment of ₹12,18,750/- (Rupees Twelve Lakh Eighteen Thousand
Seven Hundred and Fifty only) by the applicant towards settlement charges for the defaults. The Panel of Whole
Time Members of SEBI accepted the said recommendation of the HPAC on May 10, 2019, and the same was
communicated to the applicant vide e-mail dated May 15, 2019. Accordingly, the possible proceedings that may
be initiated for the defaults, are settled qua the applicant as per the above terms, by way of the order and SEBI
shall not initiate any enforcement action against the applicant for the said defaults.
Our Company has filed a compounding application along with the applicable fee before National Company Law
Tribunal, Ahmedabad Bench (“NCLT”), in relation to non-compliance under Section 67(3) of the Companies
Act, 1956. The vide NCLT vide its order dated December 6, 2018 had called upon the Company for payment of
a penalty of ₹36,15,750 for the offence.
As the Stated Allotments may be construed to have not been in compliance with the Companies Act, 1956, as a
matter of abundant caution for better corporate governance, our Board, by way of a resolution dated January 18,
2018, nominated the Promoter, Promoter Group and one of the SMPs (Rajesh Punjabi) (“Purchaser”), to provide
53an exit offer pursuant to the SEBI Circulars. The exit offer was provided to all such original allottees who had
held as on January 22, 2018 , (a) Equity Shares allotted by the Company through the Stated Allotments, and (b)
Equity Shares gifted by promoter Mr. Upendra T. Shah, acquired either through direct allotment or secondary
acquisition. (the “Eligible Equity Shareholders”) at an offer price of ₹ 63 per Equity Share (the “Purchase
Consideration”).
The Purchaser has provided an exit offer to Eligible Equity Shareholders at the Purchase Consideration and
pursuant to the exit offer seven shareholders opted to exit for 7,600 shares, out of which 4,000 shares were
purchased by Utpal Praful Shah and 3,600 shares were purchased by Rajesh Punjabi. A Certificate dated February
14, 2018 from Shailesh Shah and Associates, independent peer reviewed Chartered Accountants, in practice
certifying the necessary compliance of the SEBI circulars related to the exit offer process was submitted to SEBI.
13. We could be subject to claims by clients or actions by regulators or both for alleged mis-selling. Any case
of mis-selling, or fraud, could result in claims and fines against us and could have a material adverse
effect on our business, financial condition, cash flows, results of operations and reputation.
We sell our third-party distribution products to our clients who, in choosing the appropriate product, are assisted
by our employees or Authorised Persons who explain the benefits of such product, disclose product features and
advise clients on whether to continue with a particular product or change products. Set out below is our asset
under distribution under mutual fund in Fiscals 2025, 2024 and 2023:
Particulars Fiscal 2025 Fiscal 2024 Fiscal 2023
Mutual Funds (₹) (in lakhs) 4,916.92 3,753.15 2,626.16
We cannot assure you that the process undertaken by our Company’s personnel in assisting clients in purchasing
such third-party products will be comprehensive or that it will not be viewed as being inadequate and we cannot
rule out misconduct or malfeasance on the part of our employees or intermediaries or both. Such misconduct /
malfeasance could include activities such as making mis selling, fraudulent promises of high returns on
investments, recommending inappropriate products and, or, recommending incorrect fund management strategies.
Any case of inadequacy of our processes, mis selling, or fraud, could result in claims and fines against us and
could have a material adverse effect on our business, financial condition, cash flows, results of operations and
reputation.
14. We may fail to detect money laundering and other illegal or improper activities on a timely basis, which
may lead to criminal and, or, regulatory proceedings against us which could have a material adverse effect
on our reputation, business operations, financial condition and results of operation.
We are required to comply with applicable anti-money laundering laws and regulations. These laws and
regulations require financial institutions to establish sound internal control policies and procedures with respect
to anti-money laundering monitoring and reporting activities. Such policies and procedures require us to, among
other things, establish or designate an anti-money laundering framework, conduct client identification in
accordance with relevant rules, duly preserve client identity information and transaction records and report
suspicious transactions to relevant authorities.
We deal with a large number of clients and continuously onboard new clients including through our Authorised
Persons and handle large volumes of monetary transactions. While we comply with applicable laws while
onboarding our clients and with regard to preservation of records, and believe that we have put in place robust
systems and oversight mechanisms, and there have been no instances of misuse of our operations for money
laundering or other illegal activities, we cannot assure you that we will be able to preclude misuse of our operations
by malfeasant entities or that we will be able to identify money laundering and other illegal activities in a timely
manner or at all. If the controls and measures implemented for detecting or eliminating money laundering or other
improper or illegal trading activities are considered inadequate under applicable laws and regulations by any
regulatory, governmental or judicial authority, we may be subject to penal action, freezing or attachment of our
assets, imposition of fines, or both. We cannot assure you that the controls and measures implemented by us are
adequate to detect or eliminate instances of money laundering or illegal trading activities in a timely manner or at
all. Any such lapse may adversely affect our reputation, business operations, financial condition and results of
operations. Failure of the surveillance control and measures implemented by us to detect illegal or improper
activities undertaken through our platforms in a timely manner, or at all, could lead to regulatory actions against
us and adversely affect our reputation.
5415. A significant portion of our brokerage income is derived from a few geographical regions and any adverse
developments affecting such regions could have an adverse effect on our business, cash flows, results of
operation and financial condition.
A significant portion of our brokerage income are derived from our services offered to customer locations in
western India specifically in the state of Gujarat. The contribution of our southern Indian operations as a
percentage of revenue from brokerage income of our Company for Fiscals 2025, 2024 and 2023, expressed in
both absolute terms and as a percentage is as below:
Fiscal 2025 Fiscal 2024 Fiscal 2023
Amount (in ₹ As % of total Amount (in ₹ As % of Amount (in ₹ As % of total
Particulars lakhs) brokerage lakhs) total lakhs) brokerage
Income brokerage Income
Income
Gujarat 6,056.24 93.30 5,210.13 93.53 3,477.31 93.91
Maharashtra 283.44 4.37 234.30 4.21 164.75 4.45
Others 151.45 2.33 125.77 2.26 60.73 1.64
Total 6,491.13 100.00 5,570.20 100.00 3,702.79 100.00
Any decrease in revenues from western India, including due to increased competition or supply, or reduction in
demand, in markets in which we operate, may have an adverse effect on our business, cash flows, results of
operation and financial condition. Further, any significant disruption, including due to social, political or economic
factors or natural calamities or civil disruptions, impacting these geographical regions may adversely affect our
business. Additionally, changes in the policies of the state or local governments of these regions may require us
to incur significant capital expenditure and change our business strategy. We cannot assure you that we will be
able to address our reliance on these few geographical regions, in the future. (Negative statement for past such
instance, if any)
16. We have incurred negative net cash flows from operating activities in Fiscal 2025. Negative net cash flows
could have an adverse impact on our growth prospects
The following table sets forth certain information relating to our cash flows on a consolidated basis for the periods
indicated.
(₹ in lakhs)
Particulars Fiscal 2025 Fiscal 2024 Fiscal 2023
Net cash flow from/(used in) operating activities (3,186.22) 11,019.42 0.45
Net cash used in investing activities (1,123.27) (152.17) (1,988.83)
Net cash generated from / (used in) financing activities (186.35) (697.95) 689.79
Net increase/(decrease) in cash and cash equivalents (4,495.84) 10,169.30 (1,298.59)
Cash and cash equivalents at the beginning of the period/year 13,006.98 2,837.68 4,136.27
Cash and cash equivalents at the end of the period/year 8,511.14 13.006.98 2.837.68
We may in the future experience negative cash flows as well. Negative cash flows over extended periods, or
significant negative cash flows in the short term, could materially impact our ability to operate our business and
implement our growth plans. This situation may have an adverse effect on our cash flows, business, future
financial performance and results of operations. For more information, see “Financial Information” and
“Management's Discussion and Analysis of Financial Condition and Results of Operations” on pages 503 and
578, respectively.
17. Our financial performance is subject to interest rate risk, and an inability to manage our interest rate risk
may have a material adverse effect on our business prospects, financial condition and results of operation.
Interest rates are highly sensitive and fluctuate based on many factors which are beyond our control, including the
monetary policies of the RBI, de-regulation of the financial services sector in India, domestic as well as
international economic and political conditions, inflation and other factors. Our results of operations, including
our interest income from margin trading facility are dependent on our ability to manage our interest rate risk. Our
funding arrangements also include both fixed and floating rate borrowings. For further details kindly refer chapter
“Financial Indebtedness” on page 612. Our finance costs in the Fiscals 2025, 2024 and 2023, are set out below.
55Particulars Fiscal 2025 Fiscal 2024 Fiscal 2023
Finance costs (₹ lakhs) 246.08 90.98 31.24
Finance costs as a % of revenue from operations 2.61 1.17 0.60
Further, we charge interest at a fixed rate in our MTF business, which generated revenues of ₹ 105.79 lakhs in
Fiscal 2025. Any volatility resulting in an increase in interest rates may adversely affect our business due to,
amongst others, reducing profitability margin on our financing products. In the event of a declining interest rate
environment, if our cost of funds does not decline simultaneously or to the same extent as the yield on our interest-
earning assets, it could adversely impact our interest income from financing activities and net interest margin.
Additional risks arising from increasing interest rates, among others, include a reduction in the number of clients
availing of margin trading facility and an increase in defaults on margin funded facilities. Further, interest rates
may also affect our clients’ investment profile and high interest rates may reduce the attractiveness of equity or
equity-linked investments of our clients. There can be no assurance that we will be able to adequately manage our
interest rate risk. If we are unable to effectively manage our interest rate risks, it could have an adverse effect on
our business prospects, financial condition and results of operations.
5618. We have in the past entered into related party transactions and may continue to enter into such transactions under Ind AS 24, in the future, and there can be no
assurance that we could not have achieved more favourable terms had such transactions not been entered into with related parties.
We have, in the past, entered into related party transactions with various parties for Fiscal 2025, Fiscal 2024 and Fiscal 2023, in the ordinary course of our business. A summary
details of our transactions with related parties (including transactions with our Subsidiaries) are set out below:
(in ₹ lakhs)
For the year % of Total For the year % of Total For the year % of Total
Nature of Name of
Sr. No. % of ended 31st Assets/ Revenue ended 31st Assets/ Revenue ended 31st Assets/ Revenue
Transa ction Related Party
March, 2025 from operation March, 2024 from operation March, 2023 from operation
(i) In the books of Shah Investor's Home Limited
1 Loan Given SIHL Fincap Total Asset - - 1,171.73 3.92 14,817.45 69.94
Limited
2 Loan Repayment SIHL Fincap Total Asset - - 1,171.73 3.92 14,817.45 69.94
Limited
Shamik Chokshi - - 4.50 0.02 3.00 0.01
3 Loan Taken SIHL Fincap Total Asset 17,026.61 56.27 14,228.69 47.63 14,124.97 66.67
Limited
Tanmay 10.00 0.03 - - - 0.00
Upendra Shah
Utpal Praful - - - 300.00 1.42
Shah
4 Loan Repaid SIHL Fincap Total Asset 17,026.61 56.27 14,228.69 47.63 14,124.97 66.67
Limited
Tanmay 10.00 0.03 - - - 0.00
Upendra Shah
Utpal Praful - - - 300.00 1.42
Shah
5 Interest Income SIHL Fincap Revenue from - - 0.14 0.00 1.26 0.02
Limited operations
6 Interest Expense SIHL Fincap Revenue from 170.09 1.80 95.47 1.23 8.67 0.17
Limited operations
7 Consultancy Fees Stock Book LLP Revenue from - - 10.00 0.13 15.00 0.29
operations
57For the year % of Total For the year % of Total For the year % of Total
Nature of Name of
Sr. No. % of ended 31st Assets/ Revenue ended 31st Assets/ Revenue ended 31st Assets/ Revenue
Transa ction Related Party
March, 2025 from operation March, 2024 from operation March, 2023 from operation
8 Brokerage Paid Sur Management Revenue from 12.75 0.14 26.16 0.34 19.41 0.38
Services Private operations
Limited
Arthika 23.67 0.25 - - - -
Quantomics
Private Limited
9 Dividend Paid Directors Revenue from 117.34 1.24 121.30 1.56 61.15 1.18
operations
KMP 6.50 0.07 6.50 0.08 3.25 0.06
Relative of 25.10 0.27 21.09 0.27 10.04 0.19
KMP/Director
10 Rent deposit Trupti Utpal Total Asset (2.00) (0.01) - - (3.00) (0.01)
accepted/(repaid) Shah
Ruchira Shah - (2.31) (0.01) - -
Tanmay - (0.30) (0.00) - -
Upendra Shah
11 Reimbursement Arbor Park LLP Revenue from 0.02 0.00 - - 0.03 0.00
Exps operations
Ruchira Shah 0.04 0.00 1.18 0.02 2.77 0.05
Tanmay 12.08 0.13 5.41 0.07 27.05 0.52
Upendra Shah
Trupti Utpal - - 7.32 0.09 1.13 0.02
Shah
Preeti Shah 0.08 0.00 0.03 0.00 1.40 0.03
Rajesh Punjabi - - - - 0.24 0.00
Shamik Chokshi - - 0.65 0.01 1.06 0.02
Utpal Praful - - - - 1.64 0.03
Shah
58For the year % of Total For the year % of Total For the year % of Total
Nature of Name of
Sr. No. % of ended 31st Assets/ Revenue ended 31st Assets/ Revenue ended 31st Assets/ Revenue
Transa ction Related Party
March, 2025 from operation March, 2024 from operation March, 2023 from operation
12 Managerial Upendra Shah Revenue from 36.00 0.38 41.00 0.53 55.08 1.07
remuneration paid operations
Purnima Shah 36.00 0.38 39.90 0.51 45.36 0.88
Preeti Shah 48.00 0.51 48.00 0.62 48.00 0.93
Tanmay 60.00 0.64 60.00 0.77 60.00 1.16
Upendra Shah
Trupti Utpal 48.00 0.51 48.00 0.62 48.00 0.93
Shah
Utpal Praful 50.00 0.53 60.00 0.77 60.00 1.16
Shah
Rajesh Punjabi 60.00 0.64 60.00 0.77 60.00 1.16
Jinal Shah 13.92 0.15 16.66 0.21 12.48 0.24
Shamik Chokshi - - 5.92 0.08 9.72 0.19
13 Salary to Relative Arpita Jinal Shah Revenue from 10.08 0.11 12.03 0.15 8.88 0.17
of KMP operations
Sandhya Punjabi 27.00 0.29 27.00 0.35 27.00 0.52
14 Rent Income Arbor Park LLP Revenue from - - - - 6.00 0.12
operations
15 Rent Expense Ruchira Shah Revenue from - - 0.57 0.01 2.28 0.04
operations
Tanmay - - 0.43 0.01 2.28 0.04
Upendra Shah
Trupti Utpal 0.25 0.00 3.00 0.04 3.00 0.06
Shah
Upendra Shah 1.44 0.02 1.44 0.02 1.44 0.03
16 Sale of Investment SIHL Total Asset - - - - 145.30 0.69
Commodities
Limited
59For the year % of Total For the year % of Total For the year % of Total
Nature of Name of
Sr. No. % of ended 31st Assets/ Revenue ended 31st Assets/ Revenue ended 31st Assets/ Revenue
Transa ction Related Party
March, 2025 from operation March, 2024 from operation March, 2023 from operation
Sihl Consultancy - - - - 47.89 0.23
Limited
Purnima Shah - - - - 15.26 0.07
Utpal Praful - - - - 101.17 0.48
Shah HUF
Tanmay - - - - 49.67 0.23
Upendra Shah
17 Purchase of Tanmay Total Asset - - 65.81 0.22 - 0.00
P roperty Upendra Shah
Ruchira Shah - - 74.14 0.25 - 0.00
18 Brokerage Income Director Revenue from 1.64 0.02 14.51 0.19 0.02 0.00
operations
Independent 3.21 0.03 0.04 0.00 0.05 0.00
Director
KMP 0.36 0.00 0.84 0.01 0.04 0.00
Subsidiary 0.40 0.00 10.64 0.14 2.17 0.04
Relatives of 28.73 0.30 28.72 0.37 15.48 0.30
Directos/KMPs
Other Related 1.29 0.01 3.23 0.04 5.23 0.10
Parties
19 Donation & CSR Vimal Jyot Revenue from 18.50 0.20 7.50 0.10 13.50 0.26
Charitable Trust operations
20 Director Sitting Amit Doshi Revenue from 0.28 0.00 0.28 0.00 0.28 0.01
Fees operations
Bhishmak Soni 0.28 0.00 0.14 0.00 0.28 0.01
Siddharth Shah - - - - 0.07 0.00
Darshan Patel 0.07 0.00 - - - -
60For the year % of Total For the year % of Total For the year % of Total
Nature of Name of
Sr. No. % of ended 31st Assets/ Revenue ended 31st Assets/ Revenue ended 31st Assets/ Revenue
Transa ction Related Party
March, 2025 from operation March, 2024 from operation March, 2023 from operation
Bhushan Punani 0.07 0.00 - - - -
21 Outstanding
Balance
Deposit Trupti Utpal - 2.00 2.00
Shah
Ruchira Shah - - 1.20
Tanmay 0.45 0.45 0.75
Upendra Shah
Loan Taken Shamik Chokshi - - 4.50
(ii) In the books of SIHL Strategic Advisors Private Limited
1 Loan Given SIHL Fincap Total Asset 256.83 0.85 78.15 0.26 465.67 2.20
Limited
Infinium Mines - - 11.60 0.04 86.00 0.41
and Minerals
Private Limited
Ficus Food Lab - - - - 8.16 0.04
Private Limited
2 Loan Repayment SIHL Fincap Total Asset 256.83 0.85 78.15 0.26 465.67 2.20
Limited
Infinium Mines 74.02 0.24 23.58 0.08 - 0.00
and Minerals
Private Limited
Ficus Food Lab - - - - 8.16 0.04
Private Limited
3 Loan Taken SIHL Fincap Total Asset 301.08 1.00 6.62 0.02 42.79 0.20
Limited
Ficus Food Lab - - - - 0.02 0.00
Private Limited
61For the year % of Total For the year % of Total For the year % of Total
Nature of Name of
Sr. No. % of ended 31st Assets/ Revenue ended 31st Assets/ Revenue ended 31st Assets/ Revenue
Transa ction Related Party
March, 2025 from operation March, 2024 from operation March, 2023 from operation
4 Loan Repayment SIHL Fincap Total Asset 1.08 0.00 6.62 0.02 42.79 0.20
Limited
Ficus Food Lab - - 0.02 0.00 - 0.00
Private Limited
5 Interest Income SIHL Fincap Revenue from 3.13 0.03 0.60 0.01 2.83 0.05
Limited operations
Ficus Food Lab - - - - 0.16 0.00
Private Limited
6 Brokerage paid Shah Investor's Revenue from 0.20 0.00 0.53 0.01 0.34 0.01
Home Limited operations
7 Director Ruchira Shah Revenue from - - - - 11.34 0.22
Remmuneration (Key Managerial operations
Persons)
8 Purchase of Ficus Food Lab Total Asset - - - - 144.00 0.68
Investments Private Limited
9 Outstanding
Balance
Loan Taken SIHL Fincap 300.00 - -
Limited
Ficus Food Lab - - 0.02
Private Limited
Loan Given Infinium Mines - 74.02 86.00
and Minerals
Private Limited
10 Outstanding Ficus Food Lab 144.00 144.00 144.00
Balance in respect Private Limited
of
investments in
related parties
62For the year % of Total For the year % of Total For the year % of Total
Nature of Name of
Sr. No. % of ended 31st Assets/ Revenue ended 31st Assets/ Revenue ended 31st Assets/ Revenue
Transa ction Related Party
March, 2025 from operation March, 2024 from operation March, 2023 from operation
(iii) In the books of SIHL Consultancy Limited
1 Loan Given Infinium Mines Total Asset 0.20 0.00 344.21 1.15 86.31 0.41
and Minerals
Private Limited
SIHL Fincap 1,199.91 3.97 1,033.70 3.46 374.09 1.77
Limited
2 Loan Repayment Infinium Mines Total Asset 0.20 0.00 484.02 1.62 86.00 0.41
and Minerals
Private Limited
SIHL Fincap 1,199.91 3.97 1,033.70 3.46 374.09 1.77
Limited
3 Loan Taken Infinium Mines Total Asset 3.60 0.01 78.89 0.26 - 0.00
and Minerals
Private Limited
SIHL Fincap - - 8.99 0.03 192.00 0.91
Limited
4 Loan Repaid Infinium Mines Total Asset 3.60 0.01 78.89 0.26 - -
and Minerals
Private Limited
SIHL Fincap - - 8.99 0.03 192.00 0.91
Limited
5 Interest Income SIHL Fincap Revenue from 61.54 0.65 8.15 0.10 0.80 0.02
Limited operations
6 Brokerage Paid Shah Investor's Revenue from 0.18 0.00 2.08 0.03 0.88 0.02
Home Limited operations
- - -
63For the year % of Total For the year % of Total For the year % of Total
Nature of Name of
Sr. No. % of ended 31st Assets/ Revenue ended 31st Assets/ Revenue ended 31st Assets/ Revenue
Transa ction Related Party
March, 2025 from operation March, 2024 from operation March, 2023 from operation
7 Consultancy Fees Arbor Park LLP Revenue from 9.91 0.11 9.91 0.13 7.43 0.14
operations
8 Purchase of Shah Investor's Total Asset - - - - 47.89 0.23
Investment Home Limited
9 Outstanding
Balance
Loan Taken
Loan Given Infinium Mines - - - 139.81
and Minerals
Private Limited
(iv) In the books of SIHL Fincap Limited
1 Loan Given Preeti Shah Total Asset 80.30 0.27 245.81 0.82 - 0.00
Shah Investor's 17,026.61 56.27 14,228.69 47.63 14,124.97 66.67
Home Limited
Utpal Praful - - - - 12.02 0.06
Shah
SIHL 4.21 0.01 1.62 0.01 335.17 1.58
Commodities
Limited
Tanmay 54.42 0.18 3,296.38 11.03 10,518.29 49.65
Upendra Shah
Infinium Mines - - 50.00 0.17 0.15 0.00
and Minerals
Private Limited
Ficus Food Lab 606.47 2.00 215.71 0.72 96.26 0.45
Private Limited
64For the year % of Total For the year % of Total For the year % of Total
Nature of Name of
Sr. No. % of ended 31st Assets/ Revenue ended 31st Assets/ Revenue ended 31st Assets/ Revenue
Transa ction Related Party
March, 2025 from operation March, 2024 from operation March, 2023 from operation
SIHL - - 8.99 0.03 192.00 0.91
Consultancy
Limited
SIHL Strategic 301.08 1.00 6.62 0.02 42.79 0.20
Advisors Private
Limited
Stock Book LLP - - 8.91 0.03 4,703.69 22.20
Sur Managment 29.53 0.10 86.46 0.29 72.28 0.34
Service Private
Limited
2 Loan Repayment Preeti Shah Total Asset 205.30 0.68 120.81 0.40 - 0.00
Shah Investor's 17,026.61 56.27 14,228.69 47.63 14,124.97 66.67
Home Limited
Utpal Praful - - - - 12.02 0.06
Shah
SIHL 4.21 0.01 42.16 0.14 294.62 1.39
Commodities
Limited
Tanmay 54.42 0.18 3,296.38 11.03 10,707.29 50.54
Upendra Shah
Infinium Mines - - 50.00 0.17 0.15 0.00
and Minerals
Private Limited
Ficus Food Lab 209.67 0.69 3.97 0.01 96.26 0.45
Private Limited
SIHL - - 8.99 0.03 192.00 0.91
Consultancy
Limited
SIHL Strategic 1.08 0.00 6.62 0.02 42.79 0.20
Advisors Private
Limited
65For the year % of Total For the year % of Total For the year % of Total
Nature of Name of
Sr. No. % of ended 31st Assets/ Revenue ended 31st Assets/ Revenue ended 31st Assets/ Revenue
Transa ction Related Party
March, 2025 from operation March, 2024 from operation March, 2023 from operation
Stock Book LLP - - 8.91 0.03 4,703.69 22.20
Sur Managment 29.53 0.10 138.46 0.46 20.28 0.10
Service Private
Limited
3 Loan Taken Preeti Shah Total Asset 264.56 0.87 - - - 0.00
Shah Investor's - - 1,171.73 3.92 14,817.45 69.94
Home Limited
Upendra T. Shah - - 8.10 0.03 26.59 0.13
SIHL 47.62 0.16 7.80 0.03 410.08 1.94
Commodities
Limited
Tanmay 3,686.91 12.19 3,610.69 12.09 1,537.03 7.25
Upendra Shah
Infinium Mines - - 25.53 0.09 - 0.00
and Minerals
Private Limited
SIHL 1,199.91 3.97 1,033.70 3.46 374.09 1.77
Consultancy
Limited
SIHL Strategic 256.83 0.85 78.15 0.26 465.67 2.20
Advisors Private
Limited
Stock Book LLP - - 0.97 0.00 1,037.01 4.89
Sur Managment 2,475.01 8.18 1,364.88 4.57 446.97 2.11
Service Private
Limited
4 Loan Repaid Preeti Shah Total Asset 264.56 0.87 - - - 0.00
66For the year % of Total For the year % of Total For the year % of Total
Nature of Name of
Sr. No. % of ended 31st Assets/ Revenue ended 31st Assets/ Revenue ended 31st Assets/ Revenue
Transa ction Related Party
March, 2025 from operation March, 2024 from operation March, 2023 from operation
Shah Investor's - - 1,171.73 3.92 14,817.45 69.94
Home Limited
Upendra T. Shah - - 8.10 0.03 26.59 0.13
SIHL 47.62 0.16 7.80 0.03 410.08 1.94
Commodities
Limited
Tanmay 3,686.91 12.19 3,610.69 12.09 1,537.03 7.25
Upendra Shah
Infinium Mines - - 25.53 0.09 - 0.00
and Minerals
Private Limited
SIHL 1,199.91 3.97 1,033.70 3.46 374.09 1.77
Consultancy
Limited
SIHL Strategic 256.83 0.85 78.15 0.26 465.67 2.20
Advisors Private
Limited
Stock Book LLP - - 0.97 0.00 1,037.01 4.89
Sur Managment 2,475.01 8.18 1,364.88 4.57 446.97 2.11
Service Private
Limited
5 Reimbursement Ruchira Shah Revenue from 2.23 0.02 1.98 0.03 1.23 0.02
of expenses operations
SIHL - - 0.04 0.00 0.12 0.00
Commodities
Limited
6 Director Ruchira Shah Revenue from 43.44 0.46 43.44 0.56 32.10 0.62
Remuneration operations
67For the year % of Total For the year % of Total For the year % of Total
Nature of Name of
Sr. No. % of ended 31st Assets/ Revenue ended 31st Assets/ Revenue ended 31st Assets/ Revenue
Transa ction Related Party
March, 2025 from operation March, 2024 from operation March, 2023 from operation
7 Interest Income Ficus Food Lab Revenue from 42.90 0.46 3.97 0.05 0.26 0.00
Private Limited operations
Preeti Shah 1.03 0.01 9.76 0.13 - -
Shah Investor's 170.09 1.80 95.47 1.23 8.67 0.17
Home Limited
SIHL - - 0.07 0.00 0.31 0.01
Commodities
Limited
Stock Book LLP - - 0.01 0.00 12.41 0.24
Tanmay - - 2.43 0.03 33.97 0.66
Upendra Shah
Utpal Praful - - - - 0.02 0.00
Shah
8 Interest Expense Shah Investor's Revenue from - - 0.14 0.00 1.26 0.02
Home Limited operations
SIHL 1.09 0.01 - - 0.52 0.01
Commodities
Limited
Tanmay 4.21 0.04 - - - -
Upendra Shah
SIHL 61.54 0.65 8.15 0.10 0.80 0.02
Consultancy
Limited
SIHL Strategic 3.13 0.03 0.60 0.01 2.83 0.05
Advisors Private
Limited
Sur Managment 12.62 0.13 8.60 0.11 2.25 0.04
Service Private
Limited
Preeti Shah 0.55 0.01 - - - -
68For the year % of Total For the year % of Total For the year % of Total
Nature of Name of
Sr. No. % of ended 31st Assets/ Revenue ended 31st Assets/ Revenue ended 31st Assets/ Revenue
Transa ction Related Party
March, 2025 from operation March, 2024 from operation March, 2023 from operation
9 Rent Expense Upendra T. Shah Revenue from 3.60 0.04 3.60 0.05 3.60 0.07
operations
10 Brokerage Paid Shah Investor's Revenue from 0.02 0.00 8.04 0.10 0.94 0.02
Home Limited operations
11 Outstanding
Balance
Loan Given Preeti Shah - 125.00 -
SIHL - - 40.54
Commodities
Limited
Ficus Food Lab 608.54 211.74 -
Private Limited
SIHL Strategic 300.00 - -
Advisors Private
Limited
Sur Managment - - 52.00
Service Private
Limited
For further information on our related party transactions, see ‘Summary of the Issue Document – Summary of Related Party Transactions’ and ‘Restated Consolidated Financial
Information - Related Party Disclosure’ on page 503.
While we believe that our past related party transactions have been conducted on an arm’s length basis, there can be no assurance that we could not have achieved more
favourable terms if such transactions had not been entered into with related parties. Furthermore, it is likely that we will continue to enter into related party transactions in the
future. There can be no assurance to you that such transactions in the future or any other future related party transactions that we may enter into, individually or in the aggregate,
will not have an adverse effect on our business, cash flows, financial condition and results of operations. Further, such transactions in the future or any future transactions with
our related parties, either individually or in the aggregate, may potentially involve conflicts of interest. Additionally, there can be no assurance that any dispute that may arise
between us and related parties will be resolved in our favour.
6919. Objects of the Issue for which the funds are being raised have not been appraised by any bank or financial
institutions. Any variation in the utilization of our Net Proceeds as disclosed in this Draft Red Herring
Prospectus would be subject to certain compliance requirements, including prior Shareholders’ approval.
We propose to use the Net Proceeds towards working capital requirements and general corporate purposes. For
details, see “Objects of the Issue” on page 357. The proposed deployment of Net Proceeds has not been appraised
by any bank or financial institution or other independent agency and is based on internal management estimates
based on current market conditions and historic level of expenditure. Any variation in the utilization of the Net
Proceeds may be on account of a variety of factors such as our financial condition, business and strategy and
external factors such as market conditions and the competitive environment in which we operate, which may not
be within the control of our management, and would be subject to various other approvals, which include obtaining
prior approval of the Shareholders of the Company and applicable law. Various risks and uncertainties, including
those set forth in this “Risk Factors” section, may limit or delay our efforts to use the Net Proceeds to achieve
profitable growth in our business. Accordingly, the use of the Net Proceeds to fund our growth and for other
purposes identified by our management may not result in actual growth of our business, increased profitability or
an increase in the value of our business and your investment.
20. There is outstanding litigation against our Company, Subsidiary, our Directors, KMPs and Senior
Management (“SM”) which if determined adversely, could affect our business and results of operations.
Our Company and certain of our Directors are involved in certain legal proceedings. These proceedings are
pending at different levels of adjudication before various courts and tribunals. Our Company and Directors may
be required to devote management and financial resources towards enforcing our and their rights under such
actions. However, we cannot assure you that these matters will be settled in our favor or in favor of our Directors,
or that no further liability will arise out of these claims. Any such action may include claims for substantial or
unspecified compensatory and punitive damages, as well as civil, regulatory proceedings against our Directors,
officers or employees, and the probability and amount of liability, if any, may be significant or remain unknown
for significant periods of time.
A summary of such legal proceedings, including material legal proceedings, is set out below:
Disciplinary
actions by the
Aggregate
Statutory or SEBI or Material
Criminal Tax Amount
Name of the Entity Regulatory Stock Civil
Proceedings Proceedings Involved (in
Proceeding Exchanges Litigations
₹ lakhs)
against our
Promoter
Company
By our Company Nil N.A. Nil N.A. Nil Nil
Against our Nil 5 Nil N.A. Nil 415.26
Company
Subsidiaries
By our Subsidiaries Nil N.A. Nil N.A. Nil -
Against our Nil 1 Nil N.A. Nil 4.68
Subsidiaries
Directors (other than Promoter)
By our Directors Nil N.A. Nil N.A. Nil -
Against our Nil Nil Nil N.A. Nil Nil
Directors
Promoters
By our Promoters Nil N.A. Nil Nil Nil -
Against our Nil Nil Nil Nil Nil -
Promoters
KMPs (other than Promoters)
By our KMP Nil N.A. Nil N.A. N.A. -
Against our KMP Nil N.A. Nil N.A. N.A. -
SMPs
By our SMP Nil N.A. Nil N.A. N.A. -
Against our SMP Nil N.A. Nil N.A. N.A. -
N.A. denotes Note Applicable
*To the extent quantifiable.
70Given the uncertainties and complexity of many of these regulatory or legal proceedings, their outcome generally
cannot be predicted with any reasonable degree of certainty. We cannot assure you that any of the outstanding
legal proceedings will be settled in our favor, or that no additional liability will arise out of these proceedings. We
may incur significant expenses and management time in such legal proceedings and may have to make provisions
in our financial statements, which could increase our expenses and liabilities. An adverse outcome in any of these
proceedings could have an adverse effect on our business, financial condition, results of operations, and prospects.
Moreover, even if we ultimately prevail in the litigation, regulatory action or investigation, we could suffer
significant harm to our reputation, which could materially affect our prospects and future growth. For further
details, see “Outstanding Litigation and Material Developments” beginning on page 614 of this Draft Red Herring
Prospectus.
21. We are exposed to credit risk arising out of receivables in our day-to-day operations. If these credit risks
materialise it would increase the level of our non-performing assets, and expose us to significant losses.
We may suffer significant losses from credit exposures from our clients and counterparties. Our Broking Segment,
in particular, is subject to the risk that a client or counterparty may fail to perform its obligations or that the value
of any collateral held by us to secure the obligations might become inadequate. We are exposed to credit risk
arising out of receivables from clearing houses of exchanges which comprise initial margins placed with clearing
houses and receivables relating to sales of securities which the clients have traded but are not yet settled. We
square off and settle positions in client accounts through a trading system in accordance with our risk management
policies.
We are dependent on a number of parties like brokers, exchanges, banks, registrars and share transfer agents,
clearing houses and other intermediaries for transaction execution and, or, our day-to-day operations. Difficulties
in assessing credit risks associated with our day-to-day lending operations may lead to an increase in the level of
our non-performing assets, which could adversely affect our business prospects, financial condition and results of
operations. Set out in the table below are our trade receivables for the periods indicated.
Fiscal 2025 Fiscal 2024 Fiscal 2023
Amount (in % of Amount (in % of Amount (in % of
Particulars ₹ lakhs) revenue ₹ lakhs) revenue ₹ lakhs) revenue
from from from
operations operations operations
Total trade receivables 1,685.59 17.88 778.48 10.00 1,095.75 21.20
While we have put in place risk management systems to monitor risk arising out of the open positions of the
clients in our MTF Business if any of these counterparties do not perform their obligations due to bankruptcy,
lack of liquidity or for any reason whatsoever, and any collateral or security they provide proves inadequate to
cover their obligations at the time of the default, we could suffer significant losses and it would have an adverse
effect on our financial condition, cash flows, results of operations and cash flows. Any claim that we have would
also be subject to enforceability of such claims. We are responsible for contracts entered into by us on behalf of
our clients. Although we attempt to minimize our exposure to specific clients, these measures may not be
sufficient. For example, we provide a margin lending product to our clients, allowing them to trade on the basis
of margins that they deposit with us. Additionally, we also extend permissible short- term credit to our clients and
face credit risks relating to such receivables if there is an adverse market movement.
22. We have incurred indebtedness including in the form of loans from banks may incur substantial additional
indebtedness. Conditions and restrictions imposed on us pursuant to such indebtedness could adversely
affect our ability to obtain financing in the future.
As of August 31, 2025, our total sanctioned and outstanding indebtedness (including fund-based and non-fund
based borrowings but excluding unsecured) was ₹ 24,099.45 lakhs and ₹ 9,359.80 lakhs, respectively. The
indebtedness we have incurred includes financing from banks and from other entities. The level of our
indebtedness could have several important consequences, including but not limited to the following:
• a significant portion of our cash flow may be used for repayment of our existing debt, which will reduce the
available cash flow to fund our business operations;
• defaults of payment and other obligations under our financing arrangements may result in an event of default,
acceleration of our repayment obligations and enforcement of related security interests over our assets;
71• Fluctuations in market interest rates may require us to pay higher rates of interest for future financing and
will also affect the cost of our borrowings; and
• our ability to obtain additional financing in the future or renegotiate or refinance our existing indebtedness
on terms favourable to us may be limited.
Additionally, our financing agreements contain certain conditions and restrictive covenants that require us to
obtain consents from respective lenders prior to carrying out specified activities and entering into certain
transactions. Our lenders require us to obtain their prior approval for certain actions, which, amongst other things,
restrict our ability to undertake various actions including incur additional debt, alter our share capital etc, which
may hamper our efforts to improve our operating margins and carry out our growth strategies. While our Company
has received necessary approval from its lenders and the debenture trustees (for the non-convertible debentures
issued by our Company) to undertake this Issue, we cannot assure you that we will be able to obtain approvals to
undertake any other aforementioned activities as and when required or comply with such covenants or other
covenants in the future. For further details regarding our indebtedness, see ‘Restated Consolidated Financial
Information’ and ‘Financial Indebtedness’ on pages 503 and 612, respectively. Any failure to observe the
covenants under our financing agreements or obtain the necessary waivers may inter alia lead to the termination
of our credit facilities, trigger-cross default provisions, result in non-availability of further debt funding under the
facilities either in whole or in part, or the acceleration payment obligations under such facilities, and, or, could
lead to us having to restructure of our borrowings. Any of the above could strain our cash flow and affect the
availability of funds for our business activities, which could adversely affect our results of operations.
23. Our Company has acquired certain premises including branch offices from our Promoters and members
of Promoter Group, who may be deemed to be interested in the said acquisition.
Our Company has entered into various sale deeds for acquisitions of branch offices with our Promoters. The table
below set forth the details of such sale deeds:
Interest of the
Promoter /
Sr. No. Location Primary Purpose Sale Consideration
members of the
Promoter Group
1. Office No. F-19 & F- Branch Office The branch office ₹62.00 lakhs
20, 1st Floor, was acquired from
Samrudhi Complex, Tanmay Upendra
Opp. Sarjan Shah, our Promoter
Bunglow-2, New and Managing
C.G Road, Director & Chief
Chandkheda, Financial Officer,
Ahmedabad - vide two sale deeds
382424, Gujarat, both dated June 07,
India 2023
2. Office No. F-123, Branch Office The branch office ₹145.00 lakhs
First Floor, Shubh was acquired from
Business Park, Trupti Utpal Shah,
Pethapur - 382610, our Promoter and
Gandhinagar, Whole Time
Gujarat, India Director, vide a sale
deed dated April 12,
2025
3. 104, Platinum II, Branch Office The branch office ₹70.00 lakhs
Opp. S.T. colony, was acquired from
College Road, Moti Ruchira Shah,
Baug, Junagadh - spouse of Tanmay
362001, Gujarat, Upendra Shah who is
India our Promoter and
Managing Director,
& Chief Financial
Officer vide a sale
deed dated
September 11, 2023.
72We have entered into these sale deeds with our Promoters and members of Promoter Group, in our ordinary course
of business. These transactions followed all applicable laws, were conducted on an arm’s length basis, and did not
have any material impact on the financial performance of our Company. As of the date of this Draft Red Herring
Prospectus, there are no significant conflicts of interest. If any such conflicts arise in the future, it could materially
impact our business, financial performance, and overall condition.
24. We are heavily reliant on our Promoters, Key Managerial Personnel, and Senior Management. Failure to
retain or replace them will adversely affect our business.
The success of our business operations is attributable to our Promoters, Key Managerial Personnel and Senior
Management. We believe that the experience of our Promoters, our Key Managerial Personnel and Senior
Management team has enabled us to experience consistent growth and profitability as well as a robust liquidity
and capital position. We benefit from the strategic vision, expertise and experience of our Promoters and our
Executive Directors who continue to be integral to our operations, growth and profitability.
Our ability to sustain our growth depends upon our ability to attract and retain key personnel, developing
managerial experience to address emerging business and operating challenges and ensuring a high standard of
client service. The trust and confidence our clients place in us are largely a reflection of the skills, reputation, and
leadership provided by our Key Managerial Personnel, senior management and, given that relationship
management has been one of the cornerstones of our client acquisition and retention model, our relationship
managers also are an important aspect of our success.
If we are unable to retain our existing pool of KMP and senior management, unable to hire additional qualified
personnel, our ability to expand our business will be impaired and our results of operations could be adversely
affected.
25. Some of the properties from which we operate our business have been taken on leave and license basis /
rent. We cannot assure you that the leave and license, and, or rent agreements will be renewed upon
termination or that we will be able to obtain other premises on similar commercial terms.
We do not own the premises on which a number of our offices are situated. Some of the properties from which
we operate our business have been taken on leave and license basis / rent from third parties. For details of our
properties, see ‘Our Business – Property’ on page 382. During the Fiscal 2025, Fiscal 2024 and Fiscal 2023, our
rent expenses were as follows.
Particulars Fiscal 2025 Fiscal 2024 Fiscal 2023
Rent expenses (₹ lakhs) 41.03 29.99 27.01
Rent expenses as a percentage of revenue from operations 0.44 0.39 0.52
We cannot assure you that we will have the right to occupy these premises in the future, or that we will be able to
continue with the uninterrupted use of these premises, including due to any non-compliance by, or disputes as to
title of, the counter-party which may impair our operations and adversely affect our financial condition. We cannot
assure you that we will be able to renew the lease and license / rent agreements in a timely manner or at all.
Further, identification of a new location to house our operations and relocating our offices to the new premises
may place significant demands on our senior management and other resources and also involve us incurring
significant expenditure. Any inability on our part to timely identify a suitable location for a relocated office could
have an adverse impact on our business.
26. There are operational risks associated with our business activities which, if realised, may have a material
adverse effect on our business, financial condition, cash flows, results of operations and growth prospects.
We face various operational risks related to our business operations including:
• human and systems errors, including in the confirmation, entry or settlement of transactions, due to the
complexity and high volume of transactions;
• deviations from defined processes and inadvertent errors;
73• delay or failure to timely execute instructions or complete transactions including transactions pertaining to
the transfer, pledge or un-pledge securities to and from depository participants;
• failure to establish and maintain an effective controls and compliance oversight over our employees;
• failure of technology in our processes, including risk management and settlement processes, causing errors
or disrupting our operations;
• delay or disruption in timely completion of obligations by market and other intermediaries including banks,
exchanges, depositories and other participants;
• failure of our complex automated risk management systems due to incorrect or inadequate algorithms;
• failure to comply with other applicable laws, regulations, accounting norms or regulatory policies; and
• inadequate due diligence, including with respect to client verification and KYC processes.
If any or a combination of the foregoing were to occur, it could have a material adverse effect on our business,
financial condition, cash flows, results of operations and prospects.
Additionally, we also face the risk of regulatory penalties from the exchanges or regulators for failures of routine
operational processes. In the past, we have been penalised by the regulators and exchanges for non-compliance
with regulations, rules and byelaws relating to operational failure, including in connection with cases of
operational failures beyond our control, and we cannot assure you that such failures, consequent penalties will not
be imposed in future. For certain instances of action against us by SEBI, please see ‘Risk factor - We are subject
to extensive statutory and regulatory requirements and supervision. Any failure to comply with applicable law or
changes in the regulatory framework could result in action being initiated against us by relevant authorities which
may have a material adverse impact on our business, results of operations and financial condition’ on page 41.
27. We depend on the accuracy and completeness of information about clients and counterparties for our
business. Any misrepresentation, errors in or incompleteness of such information could adversely affect
our business and financial performance.
We rely significantly on the information furnished to us by, or on behalf of, clients (including in relation to their
financial transactions and past credit history) for various aspects of our business operations, such as new client
enrolment, appointing new Authorised Persons and servicing our clients. We may also rely on certain
representations from our clients as to the accuracy and completeness of the information provided by them. We
may receive inaccurate or incomplete information as a result of inadvertence, negligence or deliberate
misrepresentation. Our risk management measures may not be adequate to prevent such activities or detect
inaccuracies in such information in a timely manner, or at all, which may expose us risks including pertaining to
allegations of fraud, money laundering etc, and expose us to regulatory and criminal proceedings, which may
adversely affect our reputation, business prospects, financial condition and results of operations.
28. Our contingent liabilities as at March 31, 2025 as per Ind AS 37, as disclosed in our Restated Consolidated
Financial Information could adversely affect our financial condition.
As of March 31, 2025, our contingent liabilities and guarantees identified under the Ind AS 37, on a consolidated
basis, were as follows:
Particulars As at March 31, 2025 (₹ in lakhs)
Bank Guarantees 6,000.00
Demand in respect of income tax matters for which appeal is pending 419.94
In the event, that any of these contingent liabilities or a material proportion of these contingent liabilities
materialize, our future financial condition, result of operations and cash flows may be adversely affected. For
details of our contingent liabilities and guarantees as at March 31, 2025 as per Ind AS 37, see “Restated
Consolidated Financial Information – Note 34 - Notes to Restated Ind AS Consolidated Summary Statements -
Contingent Liability and Commitment” on page 503.
74We cannot assure you that in matters where orders have been passed in our favour, there will be no appeal from
the other parties involved or whether we can ascertain the liabilities involved in such matters at this stage unless
we are impleaded in such proceedings. If any new developments arise, such as a change in Indian law or rulings
against us by appellate courts or tribunals, we may need to make provisions in our financial statements that could
increase our expenses and current or long-term liabilities or reduce our cash and bank balance. For further details,
see section “Outstanding Litigation and Other Material Developments” on page 614.
29. If research reports disseminated by us contain errors, then it could have a material adverse effect on our
business, financial condition or results of operations.
As of August 31, 2025, our research team comprises 10 employees. Our research team provides our clients with
research covering recommendations on various quantitative and qualitative research requirements relating to the
securities markets such as equity fundamentals, derivatives, commodities, and mutual funds, in addition to
macroeconomic or industry- related research for investor education. Research analysts and the report generated
are subject to the applicable SEBI framework. Although, we exercise due care and caution prior to issuing research
recommendations and we comply with applicable law, the accuracy, adequacy or completeness of such
information cannot be guaranteed inter alia because our research report and the recommendation contained therein
are based on information obtained from third party sources and information that is generally available in the public
domain. Errors or omissions in the information or for the results obtained from the use of such information may
cause our research findings to be incorrect. Further, certain industry and market data may be subject to
assumptions, and methodologies for assumptions vary widely among different data sources. Additionally, such
assumptions may change due to various factors which are beyond our control. Accordingly, there can be no
assurance that our assumptions, or those relied upon by us, will be accurate or that such assumptions will not
change – any such change could affect the accuracy of our research findings. While there have been no instances
in the immediately preceding 3 Fiscals, inaccurate research report or recommendations may expose us to client
complaints, have a materially adverse effect on our brokerage and distribution businesses, and may subject us to
regulatory action which may harm our reputation, which could subsequently have a material adverse effect on our
business, financial condition or results of operations.
30. Our Company has paid dividends in the last 3 Fiscals. There can be no assurance that our Company will
continue to pay dividends in the future.
Our Company has paid dividends during the last 3 Fiscals. For further details, see the ‘Dividend Policy’ at page
502. Our Company’s ability to pay dividends in the future will depend upon a variety of internal and external
parameters, including (i) profits earned during the financial year; (ii) retained earnings; (iii) earnings outlook; (iv)
present and future working capital requirements of the our Company; (v) past dividend trends; (v) any other
relevant factors and material events as may be deemed fit by our Board; (vi) dividend pay-out ratios of companies
in the same industry; (ii) macro-economic environment – significant changes in macro-economic environment
materially affecting the businesses in which our Company is engaged in the geographies in which our Company
operates; (vii) capital markets – dividend pay-out may depend upon the capital market environment and cost of
capital to raise fresh funds through alternate resources. In addition, our ability to pay dividends may be impacted
by a number of other factors, including any tax and regulatory changes in the jurisdiction in which our Company
operates which significantly affects the business, taxation and other regulatory changes and restrictive covenants
under our future loan or financing documents or arrangements, our Company may enter into financing
arrangements to fund requirements for our business activities from time to time, applicable Indian legal
restrictions, our Articles of Association, and other factors considered relevant by the Board of Directors of our
Company.
31. Certain sections in this Draft Red Herring Prospectus contain information from the CARE Report, which
was prepared by CARE Analytics and Advisory Private Limited and exclusively commissioned and paid
for by our Company for the purposes of the Issue, and any reliance on such information for making an
investment decision in the Issue is subject to inherent risks.
We have availed the services of an independent third-party research agency, CARE Analytics and Advisory
Private Limited, to prepare an industry report titled “Broking Industry in India” dated September 2025 (“CARE
Report”) commissioned and paid by us for purposes of inclusion of such information in this Draft Red Herring
Prospectus. We engaged CARE pursuant to an engagement letter dated April 16, 2025. We commissioned and
paid for the CARE Report for the purpose of confirming our understanding of the Broking Industry in India
exclusively in connection with the Issue. The CARE Report uses certain methodologies for market sizing and
forecasting and may include numbers relating to our Company that differ from those we record internally. All
75such information in this Draft Red Herring Prospectus indicates the CARE Report as its source, as applicable.
Accordingly, any information in this Draft Red Herring Prospectus derived from, or based on, the CARE Report
should be read taking into consideration the foregoing. Given the scope and extent of the CARE Report,
disclosures herein are limited to certain excerpts and the CARE Report has not been reproduced in its entirety in
this Draft Red Herring Prospectus. Neither our Company, our Directors, our Subsidiaries, Promoters, Promoter
Group, Key Managerial Personnel, Senior Management Personnel are related to CARE.
Accordingly, investors should read the industry related disclosure in this Draft Red Herring Prospectus in this
context. Industry sources and publications are also prepared based on information as of specific dates. CARE has
advised that while it has taken due care and caution in preparing the commissioned report, which is based on
information obtained from sources that it considers reliable (“Information”), it does not guarantee the accuracy,
adequacy or completeness of the Information. Industry sources and publications may also base their information
on estimates, projections, forecasts, other third-party sources and assumptions that may prove to be incorrect. The
commissioned report also highlights certain industry and market data, which may be subject to assumptions. There
are no standard data gathering methodologies in the industry in which we conduct our business, and methodologies
and assumptions vary widely among different industry sources. Further, such assumptions may change based on
various factors. Due to possibly flawed or ineffective collection methods or discrepancies between published
information and market practice and other problems, the statistics herein may be inaccurate or may not be
comparable to statistics produced for other economies and should not be unduly relied upon. Furthermore, we
cannot assure you that they are stated or compiled on the same basis or with the same degree of accuracy as may
be the case elsewhere. Statements from third parties that involve estimates are subject to change, and actual
amounts may differ materially from those included in this Draft Red Herring Prospectus. Our position in the
market may differ, favourably or unfavourably, from that presented in this Draft Red Herring Prospectus. Further,
the commissioned report is not a recommendation to invest or disinvest in our Company. Prospective Investors
are advised not to unduly rely on the commissioned report or extracts thereof as included in this Draft Red Herring
Prospectus, when making their investment decisions. For further details, see “Certain Conventions, Presentation
of Financial, Industry and Market Data – Industry and Market Data” on page 13.
32. A significant decrease in our liquidity could negatively affect our business, in particular the Broking
Segment, reduce client confidence in us and may also adversely impact our brand.
Our liquidity is dependent upon our timely access to, and costs associated with raising, capital. Our funding
requirements historically have been met from a combination of loans and working capital facilities as well as
equity contributions. As of August 31, 2025, our total sanctioned and outstanding indebtedness (including fund-
based, non-fund based borrowings and unsecured borrowings) was ₹ 24,198.27 lakhs and ₹ 9,458.62 lakhs,
respectively. For details of our outstanding borrowing please see ‘Financial Indebtedness’ on page 612.
Maintaining adequate liquidity is crucial to our operations, particularly, our brokerage operations, including key
functions such as transaction settlement and margin trading facility and other business activities with substantial
cash requirements. We place margins with clearing houses of respective exchanges, which may fluctuate
significantly from time to time based on the nature and volume of our clients’ trading activity. Although we meet
our liquidity needs primarily through cash generated from operating activities, internal accruals and debt, we are
not permitted to raise debt beyond a specific limit, specifically to fund our margin funding requirements. A
reduction in our liquidity could affect our ability to trade on the exchanges, and reduce the confidence of our
clients in us, which may result in the loss of client accounts, all of which would affect our revenues, business
prospects and growth. We provide broking services across the equity, commodity, derivatives and currency
segments, for which we offer margin-based products on our brokerage platform, wherein clients are required to
deposit the prescribed initial margin for the transaction executed by us on their behalf and thereafter pay the
balance amount. Accordingly, if a client fails to pay the balance amount on or before the due date, then it may
affect our liquidity. In the event of high market volatility or adverse movements in share prices, it is possible that
clients may not, or may be unable to, honour their commitment, and, consequently, any inability on our part to
pay the margins or honour the pay-in obligation to the exchanges, or both, may be detrimental to our business,
reputation and profitability.
Factors that may adversely affect our liquidity position include a significant abrupt increase in our broking
services, volatile markets, and settlement of large transactions on behalf of our brokerage clients. We use cash
generated from our operating activities and external financing to meet our liquidity or regulatory capital
requirements. During periods of disruption in the credit and capital markets or changes in the regulatory
environment, potential sources of external financing could be limited and our borrowing costs may increase.
External financing may not be available to us on commercially acceptable terms, or at all, due to disruptions in
76the credit and capital markets, changes in regulations relating to capital raising activities, general market
conditions for capital raising activities, and other economic and political conditions outside our control. Any of
the risks highlighted above in relation to a decrease in our liquidity, could have a material adverse effect on our
brand, business, results of operation and prospects.
33. We have a large pool of employees and employee benefits expense is a significant portion of our total
expenses. Also, our operations could be adversely affected by strikes or increased wage demands by our
employees which could adversely affect our operations and our profitability.
We operate in a human resource intensive industry and if our relationship with our employees deteriorates, we
may experience labour unrest, strikes or work stoppages. As on August 31, 2025, our Company’s work force
comprised 174 permanent employees including our KMP and senior management. While we consider our current
employee relations to be good, and we have no trade unions in our Company, we cannot assure you that we will
not experience disruptions at work due to disputes or other problems with our work force, which may adversely
affect our ability to perform our obligations under our contractual arrangements. Set out below are the details of
our employee benefits expense during the Fiscal 2025, Fiscal 2024 and Fiscal 2023:
Particulars March 31, 2025 March 31, 2024 March 31, 2023
Employee benefits expense (in ₹ lakhs) 1,151.50 1,092.19 957.05
Employee benefits expense (as a % of total revenue
12.21 14.03 18.52
from operations)
Any disputes may also result in disruptions in our operations, which may adversely affect our business and results
of operation. In addition, disputes with our employees could also impact our reputation. While we have not faced
any significant disputes with our employees, as a collective, we cannot assure you that there will be no such issue
in future. We will need to recruit new employees, who will have to be trained and integrated into our operations.
We will also have to train existing employees to adhere properly to the ever-evolving regulatory environment,
internal controls and risk management procedures. Failure to train and motivate our employees properly may
result in an increase in employee attrition rates, require additional hiring, reduce the quality of client service,
divert management resources, increase our exposure to high-risk credit and impose significant costs on us.
34. An inability to maintain adequate insurance cover in connection with our business may adversely affect
our operations and profitability.
Our operations are subject to various risks and hazards which may adversely affect revenue generation and
profitability. While we believe that we have adequate safeguards in line with industry standards to protect our
assets from various risks inherent in our business, including through relevant insurance cover, it is possible that
our insurance cover may not provide adequate coverage in certain circumstances. For details of our insurance, see
‘Our Business - Insurance’ on page 438. The table below provides details of the aggregate coverage of the
insurance policies obtained by as a percentage of our total assets in the periods indicated:
Particulars March 31, 2025 March 31, 2024 March 31, 2023
Amount of insurable assets (₹ lakhs)* 1465.99 1454.67 1350.38
Aggregate coverage under the insurance policies (₹
907.05 873.04 855.05
lakhs)
Insurance coverage (%) 61.87 60.02 63.32
*Assets include investment property, property, plant and equipment, other intangible assets and Right of Use Assets.
Additionally, while we maintain shares and stock broker insurance we cannot assure you that the terms of our
insurance policies will be adequate to cover any damage or loss suffered by us or that such coverage will continue
to be available on reasonable terms or will be available in sufficient amounts to cover one or more large claims,
or that the insurer will not disclaim coverage as to any future claim. Our insurance policies may not provide
adequate coverage in certain circumstances and are subject to certain deductibles, exclusions and limits on
coverage. In addition, we renew our insurance coverage in the normal course of our business, but we cannot assure
you that such renewals will be granted in a timely manner, at an acceptable cost or at all. To the extent that we
suffer loss or damage for which we did not obtain or maintain insurance and, or, which is not covered by insurance
or exceeds our insurance coverage or where our insurance claims are rejected, the loss would have to be borne by
us and our results of operations, cash flows and financial condition may be adversely affected.
35. Competition from existing and new market participants in our line of business may affect our market
share, or results of operations.
77The broking industry in India is rapidly evolving and intensely competitive. We expect competition to continue
to intensify in the future. It is possible that there may in the future be consolidation in the market, amongst the
smaller market participants, between such smaller participants and the larger participants, or between the larger
participants. Any such consolidation may create stronger competitors in the market overall, and/or leave us at a
competitive disadvantage. The broking industry plays a crucial role in the Indian financial markets by acting as
an intermediary between buyers and sellers of securities such as stocks, bonds, commodities, and other investment
assets. Brokers facilitate the trading of these financial products, ensuring liquidity, efficient price discovery, and
proper capital allocation across the markets. India's brokerage industry is highly competitive and particularly
crowded. The market features numerous large and small players, resulting in intense competition. Additionally,
the brokerage landscape is fragmented, comprising a considerable number of entities registered with SEBI. Over
time, the industry has evolved significantly, largely due to technological advancements, with online trading
platforms revolutionizing the way trades are executed.
We face competition from various companies in the broking industry. We also face competition from the wealth
management arms of several market participants, including established Indian and foreign banks, private banks
and dedicated broking houses. As a consequence, they may not be able to retain end customers or generate new
business or may choose to migrate their new business to more established players, who are able to offer greater
benefits.
We use technology in almost every aspect of our business, including sales, risk management, fraud detection,
client service and settlement. Further, our competitors could utilise more advanced technology, substantially
greater financial resources, well-established branch network, big data and innovation to simplify and improve the
client experience, increase efficiencies, redesign products, improve client targeting, alter business models or to
effect disruptive changes in the Indian broking and financial services industry. If we do not anticipate, innovate,
keep pace with, and adapt to, technological and other changes impacting the Indian broking financial services
industry, it could harm our ability to compete in the market, decrease the attractiveness of our products to clients
and materially and adversely affect our business, financial condition and results of operations. Further, increased
competition may result either in a decrease in our market share, or force us to reduce our fees or increase marketing
expenses so as to preserve our market share either of which would decrease our revenue from operations,
profitability and results of operations.
36. Certain non-GAAP financial measures and certain other statistical information relating to our operations
and financial performance such as EBITDA, EBITDA margin, interest coverage ratio, net debt to
EBITDA ratio, return on capital employed and return on equity have been included in this Draft Red
Herring Prospectus. These non-GAAP financial measures are not measures of operating performance or
liquidity defined by Ind AS and may not be comparable.
We have, in this Draft Red Herring Prospectus, included various operational and financial performance indicators
and certain non-GAAP measures. Some of these measures may not be derived from our Restated Consolidated
Financial Information and may not have been subjected to an audit or review by our Statutory Auditor, and each
of which is a supplemental measure of our performance and liquidity and not required by, or presented in
accordance with Ind AS, IFRS or U.S. GAAP. Further, such measures and indicators are not defined under Ind
AS, IFRS, U.S. GAAP or other accounting standards, and, therefore, should not be viewed as substitutes for
performance, liquidity or profitability measures under such accounting standards. The manner in which such
operational and financial performance indicators including industry-related statistical information are calculated
and presented, and the assumptions and estimates underlying or used in such calculation, may vary from that used
by other similarly placed companies in India and other jurisdictions.
In addition, such measures are not standardised terms, hence a direct comparison between companies may not be
possible. Other companies may calculate such measures differently from us, limiting the usefulness of such Non-
GAAP measures as a comparative metric. Further, these measures should not be considered in isolation or
construed as an alternative to cash flows, profit/ (loss) for the periods or any other measure of financial
performance or as an indicator of our operating performance, liquidity, profitability or cash flows generated by
operating, investing or financing activities derived in accordance with Ind AS. Investors are accordingly cautioned
against placing undue reliance on such information in making an investment decision and are cautioned that they
should consult their own advisors and evaluate such information in the context of the Restated Consolidated
Financial Information and other information relating to our business and operations included in this Draft Red
Herring Prospectus.
7837. Our directors including our independent directors do not have any experience of being a director in a listed
company. This may require them to divert their attention from our business concerns to understand the
detailed operations of a listed company.
Currently, our Board comprises of 8 directors out of which 4 are independent directors. A majority of our
Directors, except Amit Lalitkumar Doshi, Bhushan Chelaram Punani , have never been appointed as a director on
the board of a listed company. While our Directors possess the required qualifications and appropriate skills,
experience and knowledge required to act as independent director of our Company and are experienced in their
respective fields, they may not have adequate experience in being a director of a listed company. Accordingly,
such directors will need to familiarise themselves with the regulatory framework within which listed companies
in India operate and to the extent that they are unfamiliar with such framework their ability to discharge their
functions as independent directors could be adversely affected. As a listed company, we will be subject to
increased scrutiny of our affairs by shareholders, regulators and the public at large that is associated with being a
listed company and will also be subject to increased corporate governance requirements. Accordingly, the lack of
experience of our directors of being directors of a listed company, may require them to divert their attention from
our business concerns to understand the detailed operations of a listed company.
38. If we are subject to any frauds, theft, or embezzlement by our employees, Authorised Persons or others we
are associated with, it could adversely affect our reputation, results of operations, financial condition and
cash flows.
Our operations may be subject to incidents of fraud, theft or embezzlement by our employees, Authorised Persons
or other persons we are associated with. While there has not been any instance of material fraud, theft, or
embezzlement in the immediately preceding 3 Fiscals, we cannot assure you that we will not experience any fraud,
theft, embezzlement or similar incidents in the future, which could adversely affect our financial condition and
business. Further, if these acts are directed at our clients or the funds of our clients or other third parties, we may
be subject to criminal and other proceedings, which could adversely affect our reputation, results of operations,
financial condition, and cash flows.
39. Some of our Group Companies are associated with companies which operate in a similar line of business
as our Company, which may lead to competition with these entities and could potentially result in a loss of
business opportunity for our Company.
Sur Management Services Private Limited and Arthika Quantomics Private Limited, our Group Companies, also
operate in a similar line of business to our Company and our Subsidiary.. For further details, please see ‘Our
Promoters and Promoter Group’ and ‘Our Group Companies’ on pages 496 and 624, respectively. The interest
of our Promoters may conflict with our interests or the interests of our Shareholders, and may favour these
companies in certain situations, or not direct opportunities to our Company. Any of the above may adversely
impact our business, financial condition and results of operations.
External Risk Factor
40. Any downturn or disruption in the securities markets, which are affected by general economic and market
conditions in India and globally, may have a material adverse effect on our business, financial condition,
cash flows, results of operations and prospects.
We operate in the financial services industry in India where we conduct our business and generate substantially
all of our revenues. We primarily offer secondary market brokering services to retail customers that comprise of
both, residents and non-resident Indians. Our Company is also actively engaged in the business of providing
services such as mutual funds distributorship, margin trading facility, stock lending and borrowing. The Indian
financial market has experienced notable fluctuations in turnover across various exchanges in recent years. From
FY20 to FY25, the combined turnover for all exchanges has shown impressive growth, with a CAGR of
approximately 44.5% and Q-o-Q growth of 75.9% from Rs 116 trillion in Q1FY25 to Rs 203 trillion in Q1FY26.
This growth trend highlights the performance of key exchanges, including the BSE, NSE, Multi Commodity
Exchange (MCX), and National Commodity and Derivatives Exchange. In Jun’25, the MTF book grew
significantly, reaching Rs. 879 billion, a 23.7% increase over Mar’25, the MTF book grew at a CAGR of 87%
from last trading day of Mar’20 to last trading day of Jun’25. This growth is driven by rising investor awareness
of MTF's benefits in boosting buying power and potential returns, along with a bullish stock market. Interest
income from MTF ranges between 15% to 35% of total revenue for leading players. (Source: Care Report).
79Our business including our Broking and Margin Trading Facility businesses are, highly dependent on the
securities market, which is significantly affected by global macroeconomic factors, and in particular,
macroeconomic factors affecting India. The Indian equity markets are affected by a variety of factors
including growth in India’s GDP, taxation, monetary and other policies of the Government of India, laws and
regulations that affect trading, political measures and regulatory developments, and general political stability,
inflation, interest rate levels, change in consumer spending and saving patterns such as a shift from one
category of investment to another, currency exchange rates and foreign investment including perceived
unattractiveness of the Indian markets. Accordingly, a downturn in the Indian securities markets, persistent
or short term, could adversely impact trading and investment patterns, result in decline in trading volumes
and size, and, consequently, adversely impact our business, prospectus, results of operation and financial
condition. In addition, global factors such as global economic instability or recession, geopolitical tensions,
war or hostilities, cybersecurity threats or attacks and other forms of disruption to or curtailment of global
communication could result in a macroeconomic downturn and have an adverse effect on the financial
services industry in India and, consequently, on our business, results of operation and financial condition.
41. Political, economic or other factors that are beyond our control may have an adverse effect on our business
and results of operations.
The Indian economy and capital markets are influenced by economic, political and market conditions in India and
globally. Our results of operations and cash flows are significantly affected by factors influencing the Indian
economy. Factors that may adversely affect the Indian economy and, consequently, our results of operations, may
include:
• high rates of inflation in India could increase our costs without proportionately increasing our revenue, and
as such decrease our operating margins;
• high rates of interest could result in an increase in the cost of funds for us as well as our clients;
• any slowdown in economic growth or financial instability in India;
• any exchange rate fluctuations;
• any scarcity of credit or other financing, resulting in an adverse impact on economic conditions;
• prevailing income conditions among clients;
• volatility in, and actual or perceived trends in trading activity on, the relevant market’s principal stock
exchanges;
• changes in existing laws and regulations in India;
• political instability, terrorism or military conflict in the region or globally, including in various neighbouring
countries;
• occurrence of natural or man-made disasters;
• any downgrading of debt rating of India by a domestic or international rating agency; and
• instability in financial markets.
42. A slowdown in economic growth in India could adversely affect our business.
The structure of the Indian economy has undergone considerable changes in the last decade. These include the
increasing importance of external trade and of external capital flows. Any slowdown in the growth of the Indian
or global economy or the financial services industry or any future volatility in securities or commodities market
could adversely affect our business, financial condition and results of operations. India’s economy could be
adversely affected by a general rise in interest rates, fluctuations in currency exchange rates, adverse conditions
affecting commodity prices or various other factors.
Further, conditions outside India, such as slowdowns in the economic growth of other countries, could have an
impact on the growth of the Indian economy and government policy may change in response to such conditions.
The Indian economy and financial markets are also significantly influenced by worldwide economic, financial
and market conditions. Any global financial turmoil, particularly in the United States, the EU, China or Asian
emerging market countries, may have an impact on the Indian economy. Although economic conditions differ in
each country, investors’ reactions to any significant developments in one country can have adverse effects on the
financial and market conditions in other countries. A loss of investor confidence in the financial systems,
particularly in other emerging markets, may cause increased volatility in Indian financial markets, and could have
an adverse effect on our business, financial condition and results of operations and the price of the Equity Shares.
8043. A downgrade in India’s sovereign debt ratings, may affect have an adverse impact on our business,
financial condition and the trading price of the Equity Shares.
Our borrowing costs and our access to the debt capital markets depend significantly on the credit ratings of India.
Any adverse revisions to India’s credit ratings for domestic and international debt by international rating agencies
may adversely impact our ability to raise additional financing and the interest rates and other commercial terms
at which such financing is available, including raising any overseas additional financing. A downgrading of
India’s credit ratings may occur, for example, upon a change of government tax or fiscal policy, which are outside
our control. This could have an adverse effect on our ability to fund our growth on favourable terms or at all, and
consequently adversely affect our business and financial performance and the price of our Equity Shares.
44. We may be affected by competition law in India and any adverse application or interpretation of the
Competition Act could adversely affect our business.
The Competition Act, 2002, of India, as amended (Competition Act) regulates practices having an appreciable
adverse effect on competition (AAEC) in the relevant market in India. Under the Competition Act, any formal or
informal arrangement, understanding or action in concert, which causes or is likely to cause an AAEC is
considered void and results in the imposition of substantial penalties. Further, any agreement among competitors
which directly or indirectly involves the determination of purchase or sale prices, limits or controls production,
shares the market by way of geographical area or number of guests in the relevant market or directly or indirectly
results in bid-rigging or collusive bidding is presumed to have an AAEC in the relevant market in India and is
considered void. The Competition Act also prohibits abuse of a dominant position by any enterprise.
On April 11, 2023, the Competition (Amendment) Bill 2023 received the assent of the President of India to
become the Competition (Amendment) Act, 2023 (“Competition Amendment Act”), amending the Competition
Act and giving the CCI additional powers to prevent practices that harm competition and the interests of
consumers. It has been enacted to increase the ease of doing business in India and enhance transparency. The
Competition Amendment Act, inter alia, modifies the scope of certain factors used to determine AAEC, reduces
the overall time limit for the assessment of combinations by the CCI and empowers the CCI to impose penalties
based on the global turnover of entities, for anti- competitive agreements and abuse of dominant position. The
Competition Commission of India has on September 9, 2024, issued The Competition Commission of India
(Combinations) Regulations, 2024, which came into effect on September 10, 2024, and which repeals The CCI
issued Competition Commission of India (Procedure for Transaction of Business Relating to Combinations)
Regulations, 2011. The impact of these regulations is yet to be ascertained.
The Competition Act aims to, among others, prohibit all agreements and transactions which may have an AAEC
in India. Consequently, all agreements entered into by us could be within the purview of the Competition Act.
Further, the CCI has extra-territorial powers and can investigate any agreements, abusive conduct or combination
occurring outside India if such agreement, conduct or combination has an AAEC in India. However, the impact
of the provisions of the Competition Act on the agreements entered into by us cannot be predicted with certainty
at this stage. We are currently not a party to an outstanding proceeding, nor have we received any notice in relation
to non-compliance with the Competition Act and the agreements entered into by us. However, if we are affected,
directly or indirectly, by the application or interpretation of any provision of the Competition Act, or any
enforcement proceedings initiated by the CCI, or any adverse publicity that may be generated due to scrutiny or
prosecution by the CCI or if any prohibition or substantial penalties are levied under the Competition Act, it would
adversely affect our business, results of operations and prospects.
45. Adverse geopolitical conditions such as an increased tension between India and its neighbouring
countries, the conflict between Israel and other countries in West Asia, could adversely affect our business,
results of operations and financial condition.
Adverse geopolitical conditions such as increased tensions between India and its neighbouring countries, resulting
in any military conflict in the region could adversely affect our business and operations. Such events may lead to
countries including the Government of India imposing restrictions which could have an adverse effect on the
Indian economy. Further, any restriction on commodities, or other factors cause global supply chain disruptions
could have an impact on global prices and could have an adverse effect on the commodities markets in India could
be affected. For instance, the government of India has imposed additional tariffs in the nature of countervailing
duty and anti-dumping duty on a number of items imported from China. Any such measure or reciprocal duties
imposed on Indian products by China or other countries may adversely affect our results of operations and
financial condition could have a chilling effect on trade and commerce between the nations which could lead to
81uncertainty in the securities and commodities markets, inflate costs etc. Further, prolonged Russia-Ukraine
conflict and the armed hostilities between Israel and other countries in West Asia, impacting, inter alia, global
trade, prices of oil and gas could have an inflationary impact on the Indian economy, result in higher interest rates
and adversely affect our business, results of operations and financial condition.
46. Governmental actions and changes in policy, laws and regulations and their interpretation could adversely
affect our business, result of operations and financial condition.
The Government of India and the State Governments in India have broad powers to affect the Indian economy
and our business in numerous ways. Any change in the existing policies of Government of India and, or, State
Government, or foreign government policies, or new policies affecting the economy of India or any foreign
country, affecting foreign investment into India, could adversely affect our business operations. Moreover, we
also cannot assure you that the Central Government or State Governments in India, will not implement new
regulations and policies which will require us to obtain additional approvals and licenses from the Government
and other regulatory bodies or impose onerous requirements and conditions on our operations. We cannot predict
the terms of any new policy, and we cannot assure you that such a policy will not be onerous. Such new policy
may also adversely affect our business, cash flows, financial condition and prospects. In addition to changing laws
and regulations, the interpretation of extant laws and regulations also could undergo change over time resulting
inter alia in uncertainty, and such changes may adversely affect our business, result of operations and financial
condition.
47. The occurrence of natural or man-made disasters could adversely affect our results of operations, cash
flows and financial condition. Hostilities, terrorist attacks, civil unrest and other acts of violence could
adversely affect the financial markets and our business.
The occurrence of natural disasters, including cyclones, storms, floods, earthquakes, tsunamis, fires, explosions,
pandemic disease and man-made disasters, including acts of terrorism and military actions, could adversely affect
our results of operations, cash flows or financial condition. Terrorist attacks and other acts of violence or war may
adversely affect the Indian securities markets. In addition, any deterioration in international relations, especially
between India and its neighbouring countries, may result in investor concern regarding regional stability which
could adversely affect the price of the Equity Shares. In addition, India has witnessed local civil disturbances in
recent years, and it is possible that future civil unrest as well as other adverse social, economic or political events
in India could have an adverse effect on our business. Such incidents could also create a greater perception that
investment in Indian companies involves a higher degree of risk and could have an adverse effect on our business
and the market price of the Equity Shares.
48. Significant differences exist between Ind AS and other accounting principles, such as U.S. GAAP and
IFRS, which may be material to the Restated Consolidated Financial Information prepared and presented
in accordance with SEBI ICDR Regulations contained in this Draft Red Herring Prospectus.
We have not attempted to quantify the impact of U.S. GAAP or any other system of accounting principles on the
financial data, prepared and presented in accordance with Ind AS for the 6 months ended September 30, 2024,
and in Fiscal 2024, Fiscal 2023 and Fiscal 2022 included in this Draft Red Herring Prospectus, nor do we provide
a reconciliation of our financial statements to those of U.S. GAAP or any other accounting principles. U.S. GAAP
differs in significant respects from Ind AS. Accordingly, the degree to which the Restated Consolidated Financial
Information included in this Draft Red Herring Prospectus will provide meaningful information is entirely
dependent on the reader's level of familiarity with Ind AS and SEBI ICDR Regulations. Any reliance by persons
not familiar with Indian accounting practices on the financial disclosures presented in this Draft Red Prospectus
should accordingly be limited. Additionally, Ind AS differs in certain respects from IFRS and therefore financial
statements prepared under Ind AS may be substantially different from financial statements prepared under IFRS.
49. Investors may have difficulty enforcing foreign judgments against us or our management.
We are incorporated under the laws of India and all our Directors and Key Managerial Personnel reside in India.
A majority of our assets, and the assets of our Directors and officers, are also located in India. Where investors
wish to enforce foreign judgments in India, they may face difficulties in enforcing such judgments. India is not a
party to any international treaty in relation to the recognition or enforcement of foreign judgments. India exercises
reciprocal recognition and enforcement of judgments in civil and commercial matters with a limited number of
jurisdictions. In order to be enforceable, a judgment obtained in a jurisdiction which India recognises as a
reciprocating territory must meet certain requirements of the Code of Civil Procedure, 1908, of India (Civil Code).
Further, the Civil Code only permits enforcement of monetary decrees not being in the nature of any amounts
82payable in respect of taxes or, other charges of a like nature or in respect of a fine or other penalty and does not
provide for the enforcement of arbitration awards. Judgments or decrees from jurisdictions not recognised as a
reciprocating territory by India cannot be enforced or executed in India. Even if a party were to obtain a judgment
in such a jurisdiction, it would be required to institute a fresh suit upon the judgment and would not be able to
enforce such judgment by proceedings in execution. Further, the party which has obtained such judgment must
institute the new proceedings within three years of obtaining the judgement.
As a result, you may be unable to: (i) effect service of process outside of India upon us and such other persons or
entities; or (ii) enforce in courts outside of India judgments obtained in such courts against us and such other
persons or entities. It is unlikely that a court in India would award damages on the same basis as a foreign court
if an action were brought in India. Furthermore, it is unlikely that an Indian court would enforce foreign judgments
if it viewed the amount of damages awarded as excessive or inconsistent with Indian practice. A party seeking to
enforce a foreign judgment in India is required to obtain prior approval from the RBI to repatriate any amount
recovered pursuant to the execution of such foreign judgment, and any such amount may be subject to income tax
in accordance with applicable laws.
Risks relating to the Equity Shares
50. Investors may be subject to Indian taxes arising out of capital gains on the sale of the Equity Shares.
Under current Indian tax laws, unless specifically exempted, capital gains arising from the sale of equity shares
held as investments in an Indian company are generally taxable in India. Any capital gain realized on the sale of
listed equity shares on a Stock Exchange held for more than 12 months immediately preceding the date of transfer
will be subject to long-term capital gains in India at the specified rates depending on certain factors, such as
whether the sale is undertaken on or off the Stock Exchanges, the quantum of gains and any available treaty relief.
Accordingly, you may be subject to payment of long- term capital gains tax in India, in addition to payment of
Securities Transaction Tax (“STT”), on the sale of any Equity Shares held for more than 12 months immediately
preceding the date of transfer. STT will be levied on and collected by a domestic stock exchange on which the
Equity Shares are sold. Further, any capital gains realized on the sale of listed equity shares held for a period of
12 months or less immediately preceding the date of transfer will be subject to short- term capital gains tax in
India.
In terms of the Finance Bill (No.2), 2024, with effect from July 24, 2024, taxes payable by an assessee on the
capital gains arising from transfer of long-term capital assets (introduced as Section 112A of the Income-Tax Act,
1961) shall be calculated on such long-term capital gains at the rate of 12.5%, where the long-term capital gains
exceed ₹125,000. The stamp duty for transfer of certain securities, other than debentures, on a delivery basis is
currently specified at 0.015% and on a non-delivery basis is specified at 0.003% of the consideration amount.
Further, any gain realized on the sale of listed equity shares held for a period of 12 months or less will be subject
to short term capital gains tax in India. Short-term capital gains, arising from the sale of such equity shares on a
stock exchange would be subject to tax at the rate of 15% (plus applicable surcharge and cess) for transfers taking
place before July 23, 2024. However, per the amendment sought by the Finance Bill, short-term capital gains will
be taxed at 20% for transfers taking place after July 23, 2024.
Under the Finance Act 2020, any dividends paid by an Indian company will be subject to tax in the hands of the
shareholders at applicable rates. Such taxes will be withheld by the Indian company paying dividends. The
Company may or may not grant the benefit of a tax treaty (where applicable) to a non- resident shareholder for
the purposes of deducting tax at source pursuant to any corporate action including dividends. Investors are advised
to consult their own tax advisors and to carefully consider the potential tax consequences of owning Equity Shares.
Unfavourable changes in or interpretations of existing, or the promulgation of new, laws, rules and regulations
including foreign investment and stamp duty laws governing our business and operations could result in us being
deemed to be in contravention of such laws and may require us to apply for additional approvals.
51. Fluctuation in the exchange rate between the Indian Rupee and foreign currencies may have an adverse
effect on the value of our Equity Shares, independent of our operating results.
On listing, our Equity Shares will be quoted in Indian Rupees on the Stock Exchanges. Any dividends in respect
of our Equity Shares will also be paid in Indian Rupees and subsequently converted into the relevant foreign
currency for repatriation, if required. Any adverse movement in currency exchange rates during the time taken for
such conversion may reduce the net dividend to foreign investors. In addition, any adverse movement in currency
exchange rates during a delay in repatriating the proceeds from a sale of Equity Shares outside India, for example,
because of a delay in regulatory approvals that may be required for the sale of Equity Shares, may reduce the
83proceeds received by Shareholders. For example, the exchange rate between the Indian Rupee and the U.S. dollar
has fluctuated substantially in recent years and may continue to fluctuate substantially in the future, which may
have an adverse effect on the returns on our Equity Shares, independent of our operating results.
52. The Equity Shares have never been publicly traded and the Issue may not result in an active or liquid
market for the Equity Shares. Further, the price of the Equity Shares may be volatile, and you may be
unable to resell the Equity Shares at or above the Issue Price.
Prior to the Issue, there has been no public market for the Equity Shares, and an active trading market on the
Indian Stock Exchanges may not develop or be sustained after the Issue. Listing and quotation do not guarantee
that a market for the Equity Shares will develop, or if developed, there will be liquidity of such market for the
Equity Shares. The Issue Price of the Equity Shares may bear no relationship to the market price of the Equity
Shares after the Issue. The market price of the Equity Shares after the Issue can be volatile as a result of several
factors beyond our control, including volatility in the Indian and global securities markets, our results of
operations, the performance of our competitors, developments in the Indian and global financial services industry,
changing perceptions in the market about investments in this sector in India, investor perceptions of our future
performance, adverse media reports about us or our sector, changes in the estimates of our performance or
recommendations by financial analysts, significant developments in India’s economic liberalisation and
deregulation policies, and significant developments in India’s fiscal regulations. In addition, the Stock Exchanges
may experience significant price and volume fluctuations, which may have a material adverse effect on the market
price of the Equity Shares.
General or industry specific market conditions or stock performance or domestic or international macroeconomic
and geopolitical factors unrelated to our performance may also affect the price of the Equity Shares. In particular,
the stock market as a whole in the past has experienced extreme price and volume fluctuations that have affected
the market price of many companies in ways that may have been unrelated to the companies’ operating
performances. For these reasons, investors should not rely on recent trends to predict future share prices, results
of operations or cash flow and financial condition.
53. The requirements of being a publicly listed company may strain our resources.
We are not a publicly listed company and none of our securities are listed on any stock exchange. We have not,
consequently, been subjected to the increased scrutiny of our affairs by shareholders, regulators and the public at
large that is associated with being a listed company. As a listed company, we will incur significant legal,
accounting, corporate governance and other expenses that we did not incur as an unlisted company. We will be
subject to the SEBI Listing Regulations, which will require us to file audited annual and unaudited quarterly
reports with respect to our business and financial condition. If we experience any delays, we may fail to satisfy
our reporting obligations and, or, we may not be able to readily determine and accordingly report any changes in
our results of operations as promptly as other listed companies. Further, as a publicly listed company, we will
need to maintain and improve the effectiveness of our disclosure controls and procedures and internal control over
financial reporting, including keeping adequate records of daily transactions. In order to maintain and improve
the effectiveness of our disclosure controls and procedures and internal control over financial reporting, significant
resources and management attention will be required. As a result, our management’s attention may be diverted
from our business concerns, which may adversely affect our business, prospects, results of operations and financial
condition.
54. Any further issuance of Equity Shares, or convertible securities or other equity linked instruments by us
may dilute your shareholding.
We may be required to finance our growth through future equity offerings. Any future equity issuances by us,
including a primary offering of Equity Shares, convertible securities or securities linked to Equity Shares including
through exercise of ESOPs, may lead to the dilution of investors’ shareholdings in our Company. Any future
equity issuances by our Company may adversely affect the trading price of the Equity Shares, which may lead to
other adverse consequences including difficulty in raising capital through offering of our Equity Shares or
incurring additional debt. In addition, any perception by investors that such issuances or sales might occur may
also affect the market price of our Equity Shares. We cannot assure you that we will not issue Equity Shares,
convertible securities or securities linked to Equity Shares or that our Shareholders will not dispose of, pledge or
encumber their Equity Shares in the future.
8455. Subsequent to the listing of the Equity Shares, we may be subject to pre-emptive surveillance measures
like Additional Surveillance Measures and Graded Surveillance Measures by the Stock Exchanges in order
to enhance market integrity and safeguard the interest of investors.
SEBI and the Stock Exchanges, in the past, have introduced various pre-emptive surveillance measures with
respect to the shares of listed companies in India (the “Listed Securities”) in order to enhance market integrity,
safeguard the interests of investors and potential market abuses. In addition to various surveillance measures
already implemented, and in order to further safeguard the interest of investors, the SEBI and the Stock Exchanges
have introduced additional surveillance measures (“ASM”) and graded surveillance measures (“GSM”). ASM is
conducted by the Stock Exchanges on Listed Securities with surveillance concerns based on certain objective
parameters such as price-to-earnings ratio, percentage of delivery, client concentration, variation in volume of
shares and volatility of shares, among other things. GSM is conducted by the Stock Exchanges on Listed Securities
where their price quoted on the Stock Exchanges is not commensurate with, among other things, the financial
performance and financial condition measures such as earnings, book value, fixed assets, net worth, other
measures such as price- to-earnings multiple and market capitalization.
Upon listing, the trading of our Equity Shares would be subject to differing market conditions as well as other
factors which may result in high volatility in price, and low trading volumes as a percentage of the combined
trading volume of our Equity Shares. The occurrence of any of the abovementioned factors or other circumstances
may trigger any of the parameters prescribed by SEBI and the Stock Exchanges for placing our securities under
the GSM and/or ASM framework or any other surveillance measures, which could result in significant restrictions
on trading of our Equity Shares being imposed by SEBI and the Stock Exchanges. These restrictions may include
requiring higher margin requirements, limiting trading frequency or freezing of price on the upper side of trading,
as well as mentioning of our Equity Shares on the surveillance dashboards of the Stock Exchanges. The imposition
of these restrictions and curbs on trading may have an adverse effect on the market price, trading and liquidity of
our Equity Shares and on the reputation and conditions of our Company. Any such instance may result in a loss
of our reputation and diversion of our management’s attention and may also decrease the market price of our
Equity Shares which could cause you to lose some or all of your investment.
56. There are restrictions on daily movements in the trading price of the Equity Shares, which may adversely
affect a shareholder’s ability to sell Equity Shares or the price at which Equity Shares can be sold at a
particular point in time.
Following the Issue, our listed Equity Shares will be subject to a daily “circuit breaker” imposed on listed
companies by the Stock Exchanges, which does not allow transactions beyond certain volatility in the trading
price of the Equity Shares. This circuit breaker operates independently of the index-based market- wide circuit
breakers generally imposed by SEBI on Indian Stock Exchanges. The percentage limit on the Equity Shares’
circuit breaker will be set by the Stock Exchanges based on historical volatility in the price and trading volume of
the Equity Shares. The Stock Exchanges are not required to inform our Company of the percentage limit of the
circuit breaker, and they may change the limit without our knowledge. This circuit breaker would effectively limit
the upward and downward movements in the trading price of the Equity Shares beyond the circuit breaker limit
set by the Stock Exchanges. As a result of this circuit breaker, we cannot give you any assurance regarding the
ability of shareholders to sell Equity Shares or the price at which shareholders may be able to sell their Equity
Shares.
57. The determination of the Price Band and the Issue Price is based on various factors and assumptions and
the Issue Price of the Equity Shares may not be indicative of the market price of the Equity Shares after
the Issue.
The determination of the Price Band is based on various factors and assumptions and will be determined by our
Company in consultation with the BRLMs. Furthermore, the Issue Price of the Equity Shares will be determined
by our Company in consultation with the BRLMs, through the Book Building Process. These will be based on
numerous factors, including factors as described under “Basis of Issue Price” on page 365 and may not be
indicative of the market price for the Equity Shares after the Issue. The factors that could affect the market price
of the Equity Shares include, among others, broad market trends, our financial performance and results post-
listing, and other factors beyond our control. We cannot assure you that an active market will develop, or sustained
trading will take place in the Equity Shares or provide any assurance regarding the price at which the Equity
Shares will be traded after listing. Further, the current market price of some securities listed pursuant to certain
previous issues managed by the BRLMs is below the respective issue price.
8558. There is no guarantee that our Equity Shares will be listed on the BSE and the NSE in a timely manner
or at all.
There is no guarantee that our Equity Shares will be listed on the BSE and the NSE in a timely manner or at all.
In accordance with Indian law, permission for listing and trading of our Equity Shares will not be granted until
after certain actions have been completed in relation to this Issue and until Allotment of Equity Shares pursuant
to this Issue. In accordance with current regulations and circulars issued by SEBI, our Equity Shares are required
to be listed on the BSE and the NSE within such time as mandated under UPI Circulars, subject to any change in
the prescribed timeline in this regard. However, we cannot assure you that the trading in our Equity Shares will
commence in a timely manner or at all. Any failure or delay in obtaining final listing and trading approvals may
restrict your ability to dispose of your Equity Shares.
59. You may not be able to immediately sell any of the Equity Shares you subscribe to in this Issue on an Stock
Exchanges.
The Equity Shares are proposed to be listed on the Stock Exchanges. Pursuant to Indian regulations, certain actions
must be completed before the Equity Shares can be listed and commence trading, including the crediting of the
investor’s demat accounts within the timeline specified under applicable law. Further, in accordance with Indian
law, permission for listing and trading of our Equity Shares will not be granted until after certain actions have
been completed in relation to this Issue and until Allotment of Equity Shares pursuant to this Issue. The Allotment
of Equity Shares in the Issue and the credit of Equity Shares to the investor’s demat account with the relevant
depository participant and listing is expected to be completed within the period as may be prescribed under
applicable law. Any failure or delay in obtaining the approvals or otherwise commencement of trading in the
Equity Shares would restrict investors’ ability to dispose of their Equity Shares. We cannot assure you that the
Equity Shares will be credited to investors’ demat accounts, or that trading in the Equity Shares will commence
within the prescribed time periods or at all which could restrict your ability to dispose of the Equity Shares.
60. Rights of shareholders under Indian laws may be more limited than under the laws of other jurisdictions.
Indian legal principles related to corporate procedures, directors’ fiduciary duties and liabilities, and shareholders’
rights may differ from those that would apply to a company in another jurisdiction. Shareholders’ rights including
in relation to class actions, under Indian law may not be as extensive as shareholders’ rights under the laws of
other countries or jurisdictions. Investors may have more difficulty in asserting their rights as shareholder in an
Indian company than as shareholder of a corporation in another jurisdiction.
61. Financial difficulty and other problems in certain financial institutions in India could have a material
adverse effect on our business, results of operations, future cash flows and financial condition.
Indian financial system may be affected by financial difficulties faced by all or some of the Indian financial
institutions whose commercial soundness may be closely related as a result of credit, trading, clearing or other
relationships. This risk, which is sometimes referred to as ‘systemic risk’, may adversely affect financial
intermediaries, such as clearing agencies, banks, securities firms and exchanges. Any such difficulties or
instability of the Indian financial system in general could create an adverse market perception about Indian
financial institutions and banks and adversely affect our business.
62. Financial instability, economic developments and volatility in securities markets in other countries may
also cause the price of the Equity Shares to decline.
The Indian economy and its securities markets are influenced by economic developments and volatility in
securities markets in other countries. Investors’ reactions to developments in one country may have adverse effects
on the market price of securities of companies located in other countries, including India. For instance, the
economic downturn in the U.S. and several European countries during a part of Fiscals 2008 and 2009 adversely
affected market prices in the global securities markets, including India. Further, events like the collapse of the
Silicon Valley Bank could also cause an economic downturn. Negative economic developments, such as rising
fiscal or trade deficits, or a default on national debt, in other emerging market countries may also affect investor
confidence and cause increased volatility in Indian securities markets and indirectly affect the Indian economy in
general.
A loss of investor confidence in the financial systems of other emerging markets may cause increased volatility
in Indian financial markets and the Indian economy in general. Any worldwide financial instability could also
86have a negative impact on the Indian economy, including the movement of exchange rates and interest rates in
India. Any financial disruption could have an adverse effect on our business, future financial performance,
shareholders’ equity and the price of the Equity Shares.
63. Under Indian law, foreign investors are subject to investment restrictions that limit our ability to attract
foreign investors, which may adversely impact the trading price of the Equity Shares.
Under foreign exchange regulations currently in force in India, transfer of shares between non-residents and
residents are freely permitted, subject to certain exceptions, if they comply with the valuation and reporting
requirements specified by the RBI. If a transfer of shares is not in compliance with such requirements and does
not fall under any of the exceptions specified by the RBI, then the RBI’s prior approval is required. In addition,
shareholders who seek to convert Rupee proceeds from a sale of shares in India into foreign currency and repatriate
that foreign currency from India require a no-objection or a tax clearance certificate from the Indian income tax
authorities. We cannot assure you that any required approval from the RBI or any other Government agency can
be obtained on any particular terms or at all. For further details, see “Restrictions on Foreign Ownership of Indian
Securities” on page 665.
Further, in accordance with Press Note No. 3 (2020 Series), dated April 17, 2020, issued by the DPIIT and the
FEMA Rules, any investment, subscription, purchase or sale of equity instruments by entities, investments under
the foreign direct investment route by entities of a country which shares land border with India or where the
beneficial owner of an investment into India is situated in or is a citizen of any such country will require prior
approval of the Government of India. Further, in the event of transfer of ownership of any existing or future
foreign direct investment in an entity in India, directly or indirectly, resulting in the beneficial ownership falling
within the aforesaid restriction/ purview, such subsequent change in the beneficial ownership will also require
approval of the Government of India. We cannot assure you that any required approval from the RBI or any other
governmental agency can be obtained on any particular terms, in a timely manner or at all.
64. If security or industry analysts do not publish research, or publish unfavourable or inaccurate research
about the business of our Company, the price and trading volume of the Equity Shares may decline.
The trading market for the Equity Shares may depend, in part, on the research and reports that securities or industry
analysts publish about us or our business. We may be unable to sustain coverage by established and, or, prominent
securities and industry analysts. If either none or only a limited number of securities or industry analysts maintain
coverage of our Company, or if these securities or industry analysts are not widely respected within the general
investment community, the trading price for our Equity Shares could be negatively impacted. In the event we
obtain securities or industry analyst coverage, if one or more of the analysts downgrade our Equity Shares or
publish inaccurate or unfavourable research about our business, our Equity Shares price may decline. If one or
more of these analysts cease coverage of our Company or fail to publish reports on us regularly, demand for our
Equity Shares could decrease, which might cause the price and trading volume of our Equity Shares to decline.
65. QIBs and Non-Institutional Investors are not permitted to withdraw or lower their Bids (in terms of
quantity of Equity Shares or the Bid Amount) at any stage after submitting a Bid and Retail Individual
Bidders and are not permitted to withdraw their bids after bid/offer closing date.
Pursuant to the SEBI ICDR Regulations, QIBs and Non-Institutional Investors are not permitted to withdraw or
lower their Bids (in terms of quantity of Equity Shares or the Bid Amount) at any stage after submitting a Bid.
Retail Individual Investors can revise their Bids during the Bid/Issue Period and withdraw their Bids until
Bid/Issue Closing Date. While our Company is required to complete Allotment pursuant to the Issue within 3
Working Days from the Bid/Issue Closing Date, events affecting the Bidders’ decision to invest in the Equity
Shares, including material adverse changes in international or national monetary policy, financial, political or
economic conditions, our business, results of operation or financial condition may arise between the date of
submission of the Bid and Allotment. Our Company may complete the Allotment of the Equity Shares even if
such events occur, and such events limit the Bidders’ ability to sell the Equity Shares Allotted pursuant to the
Issue or cause the trading price of the Equity Shares to decline on listing.
66. A third party could be prevented from acquiring control of our Company because of anti-takeover
provisions under Indian law.
There are provisions in Indian law that may delay, deter or prevent a future takeover or change in control of our
Company, even if a change in control would result in the purchase of your Equity Shares at a premium to the
87market price or would otherwise be beneficial to you. Such provisions may discourage or prevent certain types of
transactions involving an actual or threatened change in control of our Company. Under the SEBI Takeover
Regulations, an acquirer has been defined as any person who, directly or indirectly, acquires or agrees to acquire
shares or voting rights or control over a company, whether individually or acting in concert with others. Although
these provisions have been formulated to ensure that interests of investors or shareholders are protected, these
provisions may also discourage a third party from attempting to take control of our Company. Consequently, even
if a potential takeover of our Company would result in the purchase of the Equity Shares at a premium to their
market price or would otherwise be beneficial to its stakeholders, it is possible that such a takeover would not be
attempted.
88SECTION III – INTRODUCTION
THE ISSUE
The following table summarizes details of the Issue:
Up to 54,00,000 Equity Shares of face value of ₹10
Issue of Equity Shares (1)(5)
each, aggregating up to ₹ [●] lakhs
which includes:
The Issue comprises of:
Not more than [●] Equity Shares of face value of ₹10
A. QIB Portion(2)(3)(4)
each aggregating to ₹ [●] lakhs
of which:
(i) Anchor Investor Portion Up to [●] Equity Shares of face value of ₹10 each
(ii) Net QIB Portion (assuming Anchor Investor Portion is Up to [●] Equity Shares of face value of ₹10 each
fully subscribed)
of which:
a. Available for allocation to Mutual Funds only (5% of the Up to [●] Equity Shares of face value of ₹10 each
Net QIB Portion)
b. Balance for all QIBs including Mutual Funds Up to [●] Equity Shares of face value of ₹10 each
Not less than [●] Equity Shares of face value of ₹10
B. Non-Institutional Portion
each aggregating to ₹ [●] lakhs
of which:
One-third of the Non-Institutional Portion available for allocation Up to [●] Equity Shares of face value of ₹10 each
to Bidders with an application size of more than ₹ 2.00 lakhs to
₹ 10.00 lakhs
Two-third of the Non-Institutional Portion available for Up to [●] Equity Shares of face value of ₹10 each
allocation to Bidders with an application size of more than ₹
10.00 lakhs
C. Retail Portion Not less than [●] Equity Shares of face value of ₹10
each aggregating to ₹ [●]lakhs
Pre and post-Issue Equity Shares
Equity Shares outstanding prior to the Issue (as at the date of this [●] Equity Shares of face value of ₹10 each
Draft Red Herring Prospectus)
Equity Shares outstanding post the Issue [●] Equity Shares of face value of ₹10 each
See “Objects of the Issue” on page 357 for information
Use of Net Proceeds of the Issue
on the use of proceeds arising from the Issue.
Notes:
1. The Issue has been authorized by our Board pursuant to the resolution passed as its meeting of our Board held on August 26, 2025, and
by our Shareholders pursuant to a special resolution passed at their meeting held on August 28, 2025.
For details, see “Other Regulatory and Statutory Disclosures – Authority for the Issue” on page 626.
2. Subject to valid bids being received at or above the Issue Price, under subscription, if any, in any category, except in the QIB Portion,
would be allowed to be met with spill-over from any other category or combination of categories of Bidders, as applicable, at the
discretion of our Company, in consultation with the Book Running Lead Manager, and the Designated Stock Exchange, subject to
applicable laws. Undersubscription, if any, in the QIB Portion (excluding the Anchor Investor Portion) will not be allowed to be met with
spill-over from other categories or a combination of categories.
3. Our Company, in consultation with the Book Running Lead Manager, allocate up to 60% of the QIB Portion to Anchor Investors on
a discretionary basis in accordance with the SEBI ICDR Regulations. The QIB Portion will accordingly be reduced for the Equity
Shares allocated to Anchor Investors. One-third of the Anchor Investor Portion shall be reserved for domestic Mutual Funds only,
subject to valid Bids being received from domestic Mutual Funds at or above the Anchor Investor Allocation Price. Further, 5% of
the Net QIB Portion shall be available for allocation on a proportionate basis to Mutual Funds only, and the remainder of the Net
QIB Portion shall be available for allocation on a proportionate basis to all QIB Bidders other than Anchor Investors, including
Mutual Funds, subject to valid Bids being received at or above the Issue Price. In the event of under-subscription in the Anchor
Investor Portion, the remaining Equity Shares shall be added to the Net QIB Portion. The Net QIB Portion shall be available for
allocation on a proportionate basis to all QIB Bidders other than Anchor Investors, including Mutual Funds, subject to valid Bids
being received at or above the Issue Price. For details, see “Issue Procedure” on page 647.
4. SEBI through its circular (SEBI/HO/CFD/DIL2/CIR/P/2022/45) dated April 5, 2022, has prescribed that all individual investors
applying in initial public offerings opening on or after May 1, 2022, where the application amount is up to ₹500,000, shall use the
UPI Mechanism. Individual investors bidding under the Non-Institutional Portion bidding for more than ₹200,000 and up to
₹500,000, using the UPI Mechanism, shall provide their UPI ID in the Bid cum Application Form for Bidding through Syndicate,
sub-syndicate members, Registered Brokers, RTAs or CDPs, or online using the facility of linked online trading, demat and bank
account (3 in 1 type accounts), provided by certain brokers.
5. Allocation to Bidders in all categories, except Anchor Investors, if any, Non-Institutional Bidders and Retail Individual Bidders, shall
be made on a proportionate basis subject to valid Bids received at or above the Issue Price. The allocation to each Retail Individual
Bidder shall not be less than the minimum Bid Lot, subject to availability of Equity Shares in the Retail Portion and the remaining
available Equity Shares, if any, shall be allocated on a proportionate basis. For further details, see “Issue Procedure” on page 647.
89Not less than 15% of the Issue shall be available for allocation to Non-Institutional Bidders of which one-third of the Non-Institutional
Portion will be available for allocation to Bidders with an application size of more than ₹ 200,000 and up to ₹ 1,000,000 and two-
thirds of the Non-Institutional Portion will be available for allocation to Bidders with an application size of more than ₹ 1,000,000
and under-subscription in either of these two sub-categories of Non-Institutional Portion may be allocated to Bidders in the other
sub-category of Non-Institutional Portion. The allocation to each Non-Institutional Bidder shall not be less than the minimum
application size, subject to availability of Equity Shares in the Non-Institutional Portion and the remaining available Equity Shares,
if any, shall be allocated on a proportionate basis in accordance with the conditions specified in this regard in Schedule XIII of the
SEBI ICDR Regulations.
Allocation to Bidders in all categories except the Anchor Investor Portion, Non-Institutional Portion and the Retail
Portion, if any, shall be made on a proportionate basis subject to valid Bids received at or above the Issue Price,
as applicable.
The allocation to each of the RIBs shall not be less than the minimum Bid Lot, subject to availability of Equity
Shares in the Retail Portion and the remaining available Equity Shares, if any, shall be allocated on a proportionate
basis. The allocation to each of the NIIs shall not be less than the minimum application size, subject to the
availability of Equity Shares in Non-Institutional Portion, and the remaining Equity Shares, if any, shall be
allocated on a proportionate basis in accordance with the SEBI ICDR Regulations. For further details, see “Terms
of the Issue”, “Issue Structure” and “Issue Procedure” on pages 638, 644 and 647 respectively.
90SUMMARY OF FINANCIAL INFORMATION
The following tables set forth summary financial information derived from our Restated Consolidated Financial
Information for the Financial Years ended March 31, 2025, March 21, 2024 and March 31, 2023. The summary
financial information presented below should be read in conjunction with “Financial Information” and
“Management’s Discussion and Analysis of Financial Condition and Results of Operations” on page 503 and 578,
respectively.
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91SUMMARY OF RESTATED CONSOLIDATED STATEMENT OF ASSETS AND LIABILITIES
(in ₹ lakhs)
Sr.
Consolidated
No.
Particulars
Year ended Year ended Year ended
March 31, 2025 March 31, 2024 March 31, 2023
1 Financial assets
a Cash and Cash Equivalents 8,511.14 13,006.98 2,837.68
b Bank Balance other than (a) above 7,342.30 4,544.86 7,444.71
c Receivables 1,685.59 778.48 1,095.75
d Loans 1,897.30 1,319.24 1,817.24
e Investments 7,730.27 7,223.65 4,972.85
f Other Financial assets 267.47 282.80 308.38
Sub Total - Financial Assets 27,434.07 27,156.01 18,476.61
2 Current assets
b Current tax assets (Net) 220.30 217.72 256.47
c Investment Property 86.35 90.77 -
d Property, Plant and Equipment 2,103.74 2,085.66 2,067.15
e Capital work-in-progress 107.54 39.84 7.23
f Intangible assets under development 13.94 13.94 1.50
g Other Intangible asset 4.06 6.41 11.40
h Goodwill on Consolidation 54.07 54.07 54.07
i Other non -financial assets 232.44 211.69 312.46
Sub Total - Non-Financial Assets 2,822.44 2,720.10 2,710.28
Total assets 30,256.51 29,876.11 21,186.89
II LIABILITIES AND EQUITY
Liabilities
1 Financial Liabilities
a Payables
(I) Trade Payables
Total outstanding dues of micro enterprises and
(i) 3.11 - -
small enterprises
Total outstanding dues of creditors other than micro
(ii) 12,411.80 13,655.46 8,339.73
enterprises and small enterprises
(II) Other Payables
Total outstanding dues of micro enterprises and
(i) - - -
small enterprises
Total outstanding dues of creditors other than micro
(ii) 5.54 2.89 3.01
enterprises and small enterprises
b Borrowings (Other than Debt Securities) 570.81 353.52 803.42
c Other financial liabilities 13.77 11.15 2.02
Sub Total - Financial Liabilities 13,005.03 14,023.02 9,148.18
2 Non-Financial Liabilities
a Current tax liabilities (Net) 35.05 15.77 7.16
b Deferred tax liabilities (Net) 78.70 367.47 71.02
c Provisions 166.76 200.03 91.07
d Other non-financial liabilities 64.74 121.09 58.03
Sub Total - Non-Financial Liabilities 345.25 704.36 227.28
3 EQUITY
a Equity Share capital 1,575.40 1,575.40 1,575.40
b Other Equity 15,233.58 13,478.73 10,170.58
c Non-Controlling Interest 97.25 94.60 65.45
Sub Total - Equity 16,906.23 15,148.73 11,811.43
Total Liabilities and Equity 30,256.51 29,876.11 21,186.89
92SUMMARY OF RESTATED CONSOLIDATED STATEMENT OF PROFIT AND LOSS
(in ₹ lakhs)
Sr. No. Consolidated
Particulars Year ended Year ended Year ended
March 31, 2025 March 31, 2024 March 31, 2023
Revenue From Operations
i. Interest Income 2,503.63 1,578.60 1,141.73
ii. Dividend Income 61.27 74.92 47.98
iii. Rental Income 10.08 8.94 6.00
iv. Fees and commission Income 6,759.19 5,843.20 3,932.46
v. Net gain on fair value changes 72.02 198.59 (191.44)
vi. Sale of products - 35.42 199.34
vii. Sale of services 21.20 40.48 17.13
viii. Other operating income - 2.21 15.10
(I) Total Revenue from operations 9,427.39 7,782.36 5,168.30
(II) Other Income 19.12 122.93 64.66
(III) Total Income (I+II) 9,446.51 7,905.29 5,232.96
Expenses
i. Finance Costs 246.08 90.98 31.24
ii. Fees and commission expense 3,801.13 3,378.43 2,256.57
iii. Impairment on financial instruments (0.87) (1.82) 22.23
iv. Purchases of Stock -in -trade - 35.74 -
Changes in Inventories of finished goods, stock -in -
v. - - 207.05
trade and work -in - progress
vi. Impairment on financial instruments - - -
vii. Employee Benefits Expenses 1,151.50 1,092.19 957.05
viii. Depreciation, amortization and impairment 164.14 144.24 132.02
ix. Others expenses 944.31 764.85 638.10
(IV) Total Expenses (IV) 6,306.29 5,504.61 4,244.26
(V) Profit / (loss) before exceptional items and tax (III -
3,140.22 2,400.68 988.70
IV)
(VI) Exceptional items - - -
(VII) Profit/(loss) before tax (V -VI ) 3,140.22 2,400.68 988.70
(VIII) Tax Expense
(i) Current Tax 831.30 591.20 257.87
(ii) Deferred Tax (28.36) 5.30 (0.92)
(iii) (Excess)/Short provision for tax relating to prior
(4.28) (1.02) (8.72)
years
(IX) Profit / (loss) for the period from continuing
2,341.56 1,805.20 740.47
operations (VII -VIII)
(X) Profit/(loss) for the period 2,341.56 1,805.20 740.47
(XI) Share of profit from associate (net of taxes) - - 27.30
(XII) Profit after tax and share in profit of associate 2,341.56 1,805.20 767.77
(XIII) Other Comprehensive Income
(A) (i) Items that will not be reclassified to profit or loss (534.16) 1,984.74 (517.56)
(ii) Income tax relating to items that will not be
107.64 (295.10) 62.51
reclassified to profit or loss
Subtotal (A) (426.52) 1,689.64 (455.05)
(B) (i) Items that will be reclassified to profit or loss - - 3.11
(ii) Income tax relating to items that will be
- - (0.36)
reclassified to profit or loss
Subtotal (B) - - 2.75
Other Comprehensive Income (A + B) (426.52) 1,689.64 (452.30)
Total Comprehensive Income for the period
(XIV) (XII+XIII) (Comprising Profit (Loss) and other 1,915.04 3,494.84 315.47
Comprehensive Income for the period)
93Sr. No. Consolidated
Particulars Year ended Year ended Year ended
March 31, 2025 March 31, 2024 March 31, 2023
(XV) Net Profit attribute to :
Owners of parent 2,338.50 1,793.38 763.17
Non-Controlling Interest 3.06 11.82 4.60
(XVI) Other Comprehensive income/(loss) attribute to:
Owners of parent (426.11) 1,672.31 (448.95)
Non-Controlling Interest (0.41) 17.33 (3.35)
Total Comprehensive Income attribute to:
(XVII)
(XVII)=(XV)+(XVI)
Owners of parent 1,912.39 3,465.69 314.22
Non-Controlling Interest 2.65 29.15 1.25
(XVIII) Earnings per equity share
Basic & Diluted 14.84 11.38 4.84
94SUMMARY OF RESTATED CONSOLIDATED CASH FLOW STATEMENT
(in ₹ lakhs)
Consolidated
Sr.
Particulars Year ended Year ended Year ended
No.
March 31, 2025 March 31, 2024 March 31, 2023
A CASH FLOW FROM OPERATING
ACTIVITES
Profit Before Tax 3,140.22 2,400.68 988.70
Add/(less) : Adjustments
Depreciation /amortization 164.14 144.24 132.02
Finance cost 246.08 90.98 31.24
Dividend Income (61.27) (74.92) (47.98)
Impairment on financial instruments (0.87) (1.82) 22.23
Unrealized/realized (gain)/ loss on fair value
(72.02) (198.59) (75.30)
changes
Profit & Loss on sale of Fixed asset (1.46) 22.63 (17.33)
Operating profit before working capital
3,414.82 2,383.20 1,033.58
changes
Adjustments for changes in working capital:
Decrease/increase in Other bank Balance (2,747.44) 2,899.84 (1,519.31)
Decrease/increase in trade and other receivables (907.12) 317.27 120.28
Decrease/increase in Loans given (578.06) 498.00 (617.11)
Decrease/increase in Other Financial Assets 15.33 25.58 1.60
Decrease/increase in Inventories - - 207.05
Decrease/increase in Other Non-Financial Assets (21.04) (51.05) 70.33
Decrease/increase in Trade payables (1,237.90) 5,315.61 1,065.82
Decrease/increase in Other financial liabilities 2.64 8.67 (60.38)
Decrease/increase in Other Non-financial
(56.35) 63.06 (18.12)
liabilities
Decrease/increase in Provisions (58.03) 106.03 (7.29)
Cash Generated from Operations
Direct Tax Paid (Net of Refunds) (963.07) (546.79) (276.00)
Net Cash used in / generated from Operating
(3,186.22) 11,019.42 0.45
Activities
B CASH FLOW FROM INVESTING
ACTIVITES
Purchase/ Proceeds from sale of Investment (943.14) (62.70) (1,348.07)
Purchase of Fixed Asset (241.40) (164.39) (689.10)
Dividend Income Received 61.27 74.92 48.34
Net Cash from Investing Activities (1,123.27) (152.17) (1,988.83)
C CASH FLOW FROM FINANCING
ACTIVITES
Proceeds/ Payment from Borrowings 217.29 (449.89) 799.80
Finance Cost (246.08) (90.98) (31.24)
Dividend Paid (157.56) (157.08) (78.77)
Net Cash from Financing Activities (186.35) (697.95) 689.79
Net Increase / (Decrease) in Cash and Cash
(4,495.84) 10,169.30 (1,298.59)
Equivalents (A+B+C)
Cash And Cash Equivalents - Opening Balance 13,006.98 2,837.68 4,136.27
Cash And Cash Equivalents - Closing Balance 8,511.14 13,006.98 2,837.68
Notes:
1. Cash and cash equivalents represents cash and bank balances as per Balance Sheet, intercorporate deposits placed for three months
or lower tenure.
2. Previous year’s figures have been regrouped, wherever necessary. As per our report attached.
95GENERAL INFORMATION
Our Company was originally incorporated as “Shah Investors Home Private Limited”, a private limited company
under the Companies Act, 1956, pursuant to the certificate of incorporation dated October 12, 1994, issued by the
Assistant Registrar of Companies, Gujarat at Dadra & Nagar Haveli (“RoC”). Subsequently, our Company was
converted into a public company, pursuant to a special resolution passed by shareholders in their extra-ordinary
general meeting on February 14, 1995 and the name of our Company was changed to “Shah Investors Home
Limited”. A fresh certificate of incorporation dated March 09, 1995, was issued by the RoC upon conversion of
our Company to a public limited company. Thereafter, the name of our Company was changed to “Shah Investor’s
Home Limited”, pursuant to a shareholder resolution dated October 10, 2000, and a fresh certificate of
incorporation consequent on change of name dated October 13, 2000, was issued by the RoC.
Corporate Identity Number: U67120GJ1994PLC023257
Company Registration Number: 023257
Registered Office:
810, X-Change Plaza,
DSCCSL (53E), Road 5E, Block 53, Zone 5,
Gift City, Gandhinagar – 382050,
Gujarat, India
Corporate Office:
SIHL House,
Opp. Ambawadi Jain Temple,
Nehru Nagar Cross Road,
Ahmedabad – 380015
Gujarat, India
For details in relation to the changes in the registered office of our Company, see “History and Certain corporate
Matters - Changes in our registered office” on page 463.
Address of the Registrar of Companies
Our Company is registered with the Registrar of Companies, Gujarat at Ahmedabad (“RoC”) situated at the
following address:
Registrar of Companies
ROC Bhavan, Opp Rupal Park Society,
Behind Ankur Bus Stop, Naranpura
Ahmedabad – 380013
Gujarat, India.
Board of Directors of our Company
Our Board comprises the following Directors as on the date of filing of this Draft Red Herring Prospectus:
Name Designation DIN Address
Upendra Trikamlal Chairman and 00023057 17/345 Satyagrah Chhavni Socitey, Jodhpur
Shah Whole - Time Tekra Satellite, Ahmedabadh – 380015, Gujarat,
Director India
Purnima Upendra Whole-time 00023091 17/345 Satyagrah Chhavni Socitey, Jodhpur
Shah Director Tekra Satellite, Ahmedabadh – 380015, Gujarat,
India
Tanmay Upendra Managing Director 00023067 17/345 Satyagrah Chhavni Socitey, Jodhpur
Shah and Chief Financial Tekra Satellite, Ahmedabadh – 380015, Gujarat,
Officer India
Trupti Utpal Shah Whole-time 02342717 22/525, Satyagrah Chhavni, Premchand Nagar
Director Road, Satellite, Ahmedabad – 380015, Gujarat,
India
Amit Lalitkumar Independent 01603380 112, Nobles Antrix, MR. Commerce Six Road,
Doshi Director Navrangpura, Ahmedabad – 380009, Gujarat,
India
96Name Designation DIN Address
Darshan Bharatbhai Independent 08708073 31 Vrindavan, NR Akshar Flat, Inquilab Society
Patel Director , Gulabi Tekra Polytechnic, Ahmedabad –
380015, Gujarat, India.
Bhushan Chelaram Independent 00119874 34 Spring Field Judges Bungalows Road,
Punani Director Vastrapur, Ahmedabad – 380015, Gujarat, India
Abhinav Mahesh Independent 07889492 102, Shyamal Flat, Near Red Cross 12 Gujarat
Kapadia Director Society, Paldi, Ahmadabad- 380007 Gujarat,
India
For brief profiles and further details of our directors, see “Our Management” on page 9797.
Company Secretary and Compliance Officer
Hiral Bhawsar is the Company Secretary and Compliance Officer of our Company. Her contact details are as
follows:
Hiral Bhawsar
810, X-Change Plaza,
DSCCSL (53E), Road 5E, Block 53, Zone 5,
Gift City, Gandhinagar – 382050,
Gujarat, India.
Telephone: +91 9904053335
E-mail: company.secretary@sihl.in
Investor Grievances
Investors can contact the Company Secretary and Compliance Officer, the Book Running Lead Manager or the
Registrar to the Issue in case of any pre-Issue or post-Issue related matters, such as non-receipt of letters of
Allotment, non-credit of Allotted Equity Shares in the respective beneficiary account, non-receipt of refund orders
or non-receipt of funds by electronic mode.
All Issue related grievances, other than that of Anchor Investors, may be addressed to the Registrar to the Issue
with a copy to the relevant Designated Intermediary(ies) to whom the Bid cum Application Form was submitted.
The Bidder should give full details such as name of the sole or first Bidder, Bid cum Application Form number,
Bidder’s DP ID, Client ID, UPI ID, PAN, date of submission of the Bid cum Application Form, address of the
Bidder, number of Equity Shares applied for, the name and address of the Designated Intermediary(ies) where the
Bid cum Application Form was submitted by the Bidder and ASBA Account number (for Bidders other than RIBs
using the UPI Mechanism) in which the amount equivalent to the Bid Amount was blocked or the UPI ID in case
of RIBs using the UPI Mechanism.
Further, the Bidder shall also enclose a copy of the Acknowledgment Slip or provide the acknowledgement
number received from the Designated Intermediaries in addition to the information mentioned hereinabove. All
grievances relating to Bids submitted through Registered Brokers may be addressed to the Stock Exchanges with
a copy to the Registrar to the Issue. The Registrar to the Issue shall obtain the required information from the
SCSBs for addressing any clarifications or grievances of ASBA Bidders.
All Issue-related grievances of the Anchor Investors may be addressed to the Book Running Lead Manager giving
full details such as the name of the sole or First Bidder, Anchor Investor Application Form number, Bidders’ DP
ID, Client ID, PAN, date of the Anchor Investor Application Form, address of the Bidder, number of the Equity
Shares applied for, Bid Amount paid on submission of the Anchor Investor Application Form and the name and
address of the Book Running Lead Manager where the Anchor Investor Application Form was submitted by the
Anchor Investor.
Book Running Lead Manager
Beeline Capital Advisors Private Limited
B/1311-1314, Thirteenth Floor,
Shilp Corporate Park, Rajpath Rangoli Road,
Thaltej, Ahmedabad - 380054
Gujarat, India
Tel: +91 79 4918 5784
E-mail: mb@beelinemb.com
Website: https://beelinemb.com/
Investor Grievance e-mail: ig@beelinemb.com
Contact Person: Nikhil Shah
97SEBI Registration No: INM000012917
Beeline Capital Advisors Private Limited is the sole Book Running Lead Manager to the Issue.
The following table sets forth the inter-se allocation of responsibilities for various activities in relation to the Issue
among the Book Running Lead Manager:
Sr. No. Activity
1. Capital structuring, positioning strategy and due diligence of the Company including the
operations/management/business plans/legal etc. Drafting and design of the DRHP, RHP and Prospectus and
of statutory advertisements including corporate advertising, brochure, etc. and filing of media compliance
report, application form and abridged prospectus.
2. Ensuring compliance with stipulated requirements and completion of prescribed formalities with the Stock
Exchanges, RoC and SEBI including finalisation of Prospectus and RoC filing.
3. Appointment of intermediaries – Bankers to the Issue, Registrar to the Issue, advertising agency, printers to
the Issue including co-ordination for agreements.
4. Domestic institutional marketing including banks/ mutual funds and allocation of investors for meetings and
finalizing road show schedules
5. Preparation of road show presentation and FAQs
6. International institutional marketing of the Issue, which will cover, inter alia:
• Finalising media, marketing, public relations strategy and publicity budget including list of
frequently asked questions at retail road shows
• Finalising collection centres
• Finalising application form
• Finalising centres for holding conferences for brokers etc.
• Follow - up on distribution of publicity; and
• Issue material including form, RHP / Prospectus and deciding on the quantum of the Issue material
7. Non-Institutional and Retail marketing of the Issue, which will cover, inter alia:
• Formulating marketing strategies, preparation of publicity budget;
• Finalise media and public relation strategy;
• Finalising centres for holding conferences for stock brokers, investors, etc;
• Finalising collection centres as per Schedule III of the SEBI ICDR Regulations; and
• Follow-up on distribution of publicity and Issue material including application form, red herring
prospectus, prospectus and brochure and deciding on the quantum of the Issue material.
8. Managing anchor book related activities including anchor co-ordination, Anchor CAN, intimation of anchor
allocation and submission of letters to regulators post completion of anchor allocation, and coordination with
Stock Exchanges for anchor intimation, book building software, bidding terminals and mock trading.
9. Managing the book and finalization of pricing in consultation with Company.
10. Post bidding activities including management of escrow accounts, coordinate non-institutional allocation,
coordination with Registrar, SCSBs and Bankers to the Issue, intimation of allocation and dispatch of refund
to Bidders, etc.
Post - Issue activities, which shall involve essential follow-up steps including allocation to Institutional
Investors including Anchor Investors, follow-up with Bankers to the Issue and SCSBs to get quick estimates
of collection and advising the Issuer about the closure of the Issue, based on correct figures, finalisation of
the basis of allotment or weeding out of multiple applications, listing of instruments, dispatch of certificates
or demat credit and refunds and coordination with various agencies connected with the post- Issue activity
such as registrar to the Issue, Bankers to the Issue, SCSBs including responsibility for underwriting
arrangements, as applicable.
Co-ordination with SEBI and Stock Exchanges for all post Issue reports including the initial and final post
Issue report to SEBI.
Legal Counsel to our Company as to Indian law
M/s. Crawford Bayley & Co.
State Bank Building, 4th Floor
NGN Vaidya Marg
Fort, Mumbai – 400 023
Maharashtra, India.
Telephone: +91 22 2266 3353
Statutory Auditor to our Company
Ashit N Shah & Co.
1 Shantinath Apartment, B/h Doctor House, Ellisbridge, Ahmedabad - 380006
Telephone: + 91 9327058201
98E-mail: ashitnshah@hotmail.com
Peer Review No.: 01964
Firm Registration Number: 100624W
Changes in Statutory Auditors
Except as disclosed below, there has been no change in our statutory auditors in the three years preceding the date
of this Draft Red Herring Prospectus;
Name of the Auditor Date of Change Reason for change
Ashit N Shah & Co. September 29, 2025 Appointment as the statutory
1 Shantinath Apartment, Shantisadan Society, auditors of the Company.
B/h Doctor House, Ellisbridge, Ahmedabad -
380006
Telephone: + 91 9327058201
E-mail: ashitnshah@hotmail.com
Peer Review No.: 01964
Firm Registration Number: 100624W
Dhrumil A Shah & Co., Chartered September 29, 2025 Completion of tenure as the
Accountants* statutory auditors of the
1, Shantinath Apartment, Shantisadan Society Company.
B/H. Doctor House Ellisbridge, Ahmedabad –
380006, Gujarat, India
Telephone: +91 9913798282
E-mail: dhrumilashahco@gmail.com
Peer Review No.: 015459
Firm Registration Number: 145163W
As on the date of signing of the Restated Financial Statements, i.e., September 05, 2025, M/s. Dhrumil A Shah & Co, Chartered Accountants,
was the Statutory Auditor of our Company. However, in accordance with the provisions of Section 139 of the Companies Act, 2013, M/s.
Dhrumil A Shah & Co, Chartered Accountants completed his maximum permissible term as Statutory Auditor and therefore not eligible for
reappointment in such capacity in the AGM held on September 29, 2025.
Registrar to the Issue
MUFG Intime India Private Limited (formerly Link Intime India Private Limited)
C-101, 1stFloor,
247 Park Lal Bahadur Shastri Marg,
Vikhroli (West),
Mumbai - 400 083, Maharashtra, India
Tel: +91 8108114949
E-mail: shahinvestors.ipo@in.mpms.mufg.com
Investor Grievance E-mail:
Website: www.in.mpms.mufg.com.
Contact Person: Shanti Gopalakrishnan
SEBI Registration Number: INR000004058
Banker(s) to the Issue
Escrow Collection Bank(s)
[●]
Refund Bank(s)
[●]
Public Issue Account Bank(s)
[●]
Sponsor Bank(s)
[●]
Bankers to our Company
HDFC Bank Limited
HDFC Bank Limited, 3rd Floor, C – Wing,
Sheetal Westpark, Imperia, Nr One Mall & Vastrapur Lake
99Vastrapur, Dist. Ahmedabdh, Gujarat – 380054
Telephone Number: +91 6353620703
Contact Person: Gautam Jadav
Website: www.hdfcbank.com
Email: gautam.jadav1@hdfcbank.com
SEBI registeration: INB100000063
CIN: L65920MH1994PLC080618
Syndicate Members
[●]
Designated Intermediaries
Self-Certified Syndicate Banks
The list of SCSBs notified by SEBI for the ASBA process is available at
https://www.sebi.gov.in/sebiweb/other/OtherAction.do?doRecognisedFpi=yes&intmId=35, or at such other
website as may be prescribed by SEBI from time to time. A list of the Designated SCSB Branches with which an
ASBA Bidder (other than a UPI Bidders using the UPI Mechanism), not Bidding through Syndicate/Sub Syndicate
or through a Registered Broker, RTA or CDP may submit the Bid cum Application Forms, is available at
https://www.sebi.gov.in/sebiweb/other/OtherAction.do?doRecognisedFpi=yes&intmId=34, or at such other
websites as may be prescribed by SEBI from time to time.
Further, the branches of the SCSBs where the Designated Intermediaries could submit the ASBA Form(s) of
Bidders (other than RIBs) is provided on the website of SEBI at https
://www.sebi.gov.in/sebiweb/other/OtherAction.do?doRecognisedFpi=yes&intmId=35 which may be updated
from time to time or at such other website as may be prescribed by SEBI from time to time.
Details of nodal officers of SCSBs, identified for Bids made through the UPI Mechanism, are available at
www.sebi.gov.in
SCSBs and mobile applications enabled for UPI Mechanism
In accordance with SEBI Circular No. SEBI/HO/CFD/DIL2/CIR/P/2019/76 dated June 28, 2019 and SEBI
Circular No. SEBI/HO/CFD/DIL2/CIR/P/2019/85 dated July 26, 2019, and SEBI Circular No.
SEBI/HO/CFD/DIL2/CIR/P/2022/51 dated April 20, 2022, UPI Bidders Bidding using the UPI Mechanism may
apply through the SCSBs and mobile applications whose names appears on the website of the SEBI
(https://www.sebi.gov.in/sebiweb/other/OtherAction.do?doRecognisedFpi=yes&intmId=40) and
(https://www.sebi.gov.in/sebiweb/other/OtherAction.do?doRecognisedFpi=yes&intmId=43) respectively, as
updated from time to time.
Applications through UPI in the Issue can be made only through the SCSBs mobile applications (apps) whose
name appears on the SEBI website. A list of SCSBs and mobile application, which are live for applying in public
issues using UPI mechanism is provided as Annexure ‘A’ to the SEBI circular no.
SEBI/HO/CFD/DIL2/CIR/P/2019/85 dated July 26, 2019. This list is also available at
www.sebi.gov.in/sebiweb/other/OtherAction.do?doRecognisedFpi=yes&intmId=43 appearing in the “list of
mobile applications for using UPI in public issues” displayed on the SEBI website as updated from time to time
or any such other website as may be prescribed by SEBI from time to time. Details of nodal officers of SCSBs,
identified for Bids made through the UPI Mechanism, are available at www.sebi.gov.in.
Syndicate SCSB Branches
In relation to Bids (other than Bids by Anchor Investor and RIBs) submitted under the ASBA process to a member
of the Syndicate, the list of branches of the SCSBs at the Specified Locations named by the respective SCSBs to
receive deposits of Bid cum Application Forms from the members of the Syndicate is available on the website of
the SEBI (https://www.sebi.gov.in/sebiweb/other/OtherAction.do?doRecognisedFpi=yes&intmId=35) and
updated from time to time or any other website prescribed by SEBI from time to time. For more information on
such branches collecting Bid cum Application Forms from the Syndicate at Specified Locations, see the website
of the SEBI https://www.sebi.gov.in/sebiweb/other/OtherAction.do?doRecognisedFpi=yes&intmId=35 as
updated from time to time or any other website prescribed by SEBI from time to time.
Registered Brokers
Bidders can submit ASBA Forms in the Issue using the stock broker network of the stock exchange, i.e. through
the Registered Brokers at the Broker Centres. The list of the Registered Brokers, including details such as postal
100address, telephone number and e-mail address, is provided on the websites of the Stock Exchanges at
https://www.bseindia.com/ and https://www.nseindia.com, as updated from time to time.
RTAs
The list of the RTAs eligible to accept ASBA Forms at the Designated RTA Locations, including details such as
address, telephone number and e-mail address, is provided on the websites of the SEBI at
https://www.sebi.gov.in/sebiweb/other/OtherAction.do?doRecognisedFpi=yes&intmId=10 and Stock Exchanges
at https://www.bseindia.com/Static/PublicIssues/RtaDp.aspx and
https://www.nseindia.com/products/consent/equities/ipos/asba-procedures.htm or any such other websites as
updated from time to time.
Collecting Depository Participants
The list of the CDPs eligible to accept ASBA Forms at the Designated CDP Locations, including details such as
name and contact details, is provided on the website of the Stock Exchanges at
http://www.bseindia.com/Static/Markets/PublicIssues/RtaDp.aspx
http://www.nseindia.com/products/content/equities/ipos/asba_procedures.htm or any such other websites as
updated from time to time.
Experts
Except as stated below, our Company has not obtained any expert opinions:
Our Company has received written consent dated September 29, 2025 from the Statutory Auditor, namely Ashit
N Shah & Co, Chartered Accountants, to include their name as required under Section 26(1) of the Companies
Act, 2013 read with SEBI ICDR Regulations, in this Draft Red Herring Prospectus, and as an “expert” as defined
under Section 2(38) of the Companies Act, 2013 and such consent has not been withdrawn as on the date of this
Draft Red Herring Prospectus. However, the term “expert” shall not be construed to mean an “expert” as defined
under the U.S. Securities Act.
Our Company has received written consent dated September 29, 2025 from Independent Chartered Accountants,
namely, Dhrumil A. Shah & Co., Chartered Accountants to include their names as required under section 26 (1)
of the Companies Act, 2013 read with SEBI ICDR Regulations, in in respect of their (a) examination report dated
September 05, 2025 on the Restated Consolidated Financial Information (b) The statement of possible special tax
benefits on direct taxes and indirect taxes each dated September 05, 2025, (c) certificates issued by them, , in this
DRHP, and as an “expert” as defined under section 2(38) of the Companies Act, 2013, and such consents has not
been withdrawn as on the date of this DRHP.
Our Company has received written consent dated September 29, 2025 from Mittal V Kothari & Associates,
Practising Company Secretaries, to include their name in this Draft Red Herring Prospectus and as an “expert” as
defined under Section 2(38) of the Companies Act, 2013, to the extent that and in their capacity as practising
company secretary, in relation to their certificate dated September 29, 2025. However, the term “expert” shall not
be construed to mean an “expert” as defined under the U.S. Securities Act.
Monitoring Agency
If the Fresh Issue size is more than ₹10,000 lakhs, a monitoring agency shall be appointed prior to filing the Red
Herring Prospectus with the RoC. Our Company will appoint the monitoring agency to monitor utilization of the
Net Proceeds, in accordance with Regulation 41 of the SEBI ICDR Regulations, prior to the filing of the Red
Herring Prospectus with RoC. For further details in relation to the proposed utilisation of the Net Proceeds, see
“Objects of the Issue - Proposed schedule of implementation and deployment of Net Proceeds” on page 357.
Appraising Entity
None of the objects of the Issue for which the Net Proceeds will be utilised have been appraised by any agency.
Credit Rating
As this is an Issue of Equity Shares, there is no credit rating for the Issue.
IPO Grading
No credit rating agency registered with the SEBI has been appointed in respect of obtaining grading for the Issue.
Debenture Trustees
As this is an Issue of Equity Shares, no debenture trustee has been appointed for the Issue.
Green Shoe Option
101No green shoe option is contemplated under the Issue.
Filing of this Draft Red Herring Prospectus
A copy of this Draft Red Herring Prospectus is being filed electronically on the SEBI’s intermediary online portal
at https://siportal.sebi.gov.in, in accordance with the SEBI ICDR Master Circular. It will also be filed with SEBI
at:-
Securities and Exchange Board of India
Corporation Finance Department
Division of Issues and Listing
SEBI Bhavan, Plot No. C4 A, ‘G’ Block
Bandra Kurla Complex, Bandra (E)
Mumbai, 400 051
Maharashtra, India
A copy of the Red Herring Prospectus, along with the material contracts and documents required to be filed under
Section 32 of the Companies Act, 2013 will be filed with the RoC and a copy of the Prospectus to be filed under
Section 26 of the Companies Act, 2013 would be filed with the RoC at its office, and through the electronic portal.
Book Building Process
Book building, in the context of the Issue, refers to the process of collection of Bids from investors on the basis
of the Red Herring Prospectus and the Bid cum Application Forms within the Price Band, which will be decided
by our Company, in consultation with the BRLM, and if not disclosed in the Red Herring Prospectus, will be
advertised all editions of [●], an English national daily newspaper and all editions of [●], a Hindi national daily
newspaper and editions of [●], a Gujarati daily newspaper (Gujarati being the regional language of Gujarat, where
our Registered Office is located), each with wide circulation, at least two Working Days prior to the Bid/Issue
Opening Date and shall be made available to the Stock Exchanges for the purpose of uploading on their respective
websites. The Issue Price shall be determined by our Company, in consultation with the BRLM, after the Bid/Issue
Closing Date. For further details, see “Issue Procedure” on page 647
All Bidders, except Anchor Investors, are mandatorily required to use the ASBA process for participating
in the Issue by providing details of their respective ASBA Account in which the corresponding Bid Amount
will be blocked by SCSBs. In addition to this, the RIBs may participate through the ASBA process by either
(a) providing the details of their respective ASBA Account in which the corresponding Bid Amount will be
blocked by the SCSBs; or (b) through the UPI Mechanism. Except for Allocation to RIBs, Non-Institutional
Bidders and the QIBs in the Net QIB Portion, Allocation in the Issue will be on a proportionate basis.
Anchor Investors are not permitted to participate in the Issue through the ASBA process.
In accordance with the SEBI ICDR Regulations, QIBs and Non-Institutional Investors are not permitted
to withdraw or lower the size of their Bids (in terms of the quantity of the Equity Shares or the Bid
Amount) at any stage. Retail Individual Investors can revise their Bids during the Bid/ Issue Period
and withdraw their Bids until the Bid/ Issue Closing Date. Further, Anchor Investors cannot withdraw
their Bids after the Anchor Investor Bidding Date. Allocation to QIBs (other than Anchor Investors)
and Non-Institutional Investors will be on a proportionate basis while allocation to Anchor Investors
will be on a discretionary basis. For further details, see “Terms of the Issue” and “Issue Procedure” on
pages 638 and 647 respectively.
Our Company will comply with the SEBI ICDR Regulations and any other directions issued by SEBI in relation
to this Issue. In this regard, our Company has appointed the BRLM to manage this Issue and procure Bids for this
Issue.
The Book Building Process is in accordance with guidelines, rules and regulations prescribed by SEBI and
are subject to change from time to time. Bidders are advised to make their own judgement about an
investment through this process prior to submitting a Bid.
Bidders should note the Issue is also subject to: (i) obtaining final listing and trading approvals of the Stock
Exchanges, which our Company shall apply for after Allotment within three Working Days of the Bid/Issue
Closing Date or such other time period as prescribed under applicable law, and (ii) acknowledgment of the RoC
for filing of the Prospectus with the RoC.
For further details on the method and procedure for Bidding, see “Issue Structure”, “Issue Procedure” and “Terms
of the Issue” on pages 644, 647 and 638, respectively.
Illustration of Book Building and Price Discovery Process
102For an illustration of the Book Building Process and the price discovery process, see “Issue Procedure” on page
647.
Underwriting Agreement
Our Company will comply with the SEBI ICDR Regulations and any other directions issued by SEBI in relation
to this Issue. In this regard, our Company has appointed the BRLM to manage this Issue and procure Bids for this
Issue. Pursuant to the terms of the Underwriting Agreement, the obligations of the Underwriters will be several
and will be subject to certain conditions to closing, as specified therein.
The Underwriting Agreement is dated [●]. The Underwriters have indicated their intention to underwrite the
following number of Equity Shares:
(This portion has been intentionally left blank and will be filled in before filing of the Prospectus with the RoC)
Name, Address, Telephone
Indicative Number of Equity
Number and Email Address of Amount Underwritten (in ₹ lakhs)
Shares to be Underwritten
the Underwriters
[●] [●] [●]
The above-mentioned is indicative underwriting amount and will be finalised after determination of Issue Price
and actual allocation in accordance with provisions of the SEBI ICDR Regulations.
In the opinion of our Board (based on representations made to our Company by the Underwriters), the resources
of the Underwriters are sufficient to enable them to discharge their respective underwriting obligations in full.
The Underwriters are registered with SEBI under Section 12(1) of the SEBI Act or registered as brokers with the
Stock Exchange(s). Our Board / IPO Committee will at its meeting accept and enter into the Underwriting
Agreement mentioned above on behalf of our Company.
Allocation among the Underwriters may not necessarily be in proportion to their underwriting commitment set
forth in the table above.
Notwithstanding the above table, the Underwriters shall be severally responsible for ensuring payment with
respect to the Equity Shares allocated to investors respectively procured by them in accordance with the
Underwriting Agreement. The Underwriting Agreement has not been executed as on the date of this Draft Red
Herring Prospectus and will be executed after determination of the Issue Price and allocation of Equity Shares,
but prior to the filing of the Prospectus with the RoC. The extent of underwriting obligations and the Bids to be
underwritten in the Issue shall be as per the Underwriting Agreement.
103CAPITAL STRUCTURE
The share capital of our Company, as on the date of this Draft Red Herring Prospectus, is set forth below.
(in ₹, except share data)
S. No. Particulars Aggregate nominal Aggregate value at
value Issue Price*
A) A U THORISED SHARE CAPITAL(1)
3,00,00,000 equity shares of face value of ₹10 each 30,00,00,000 -
B) IS SUED, SUBSCRIBED AND PAID-UP SHARE CAPITAL BEFORE THE ISSUE
1,57,54,000 Equity Shares of face value of ₹10 each 15,75,40,000 -
C) PR ESENT ISSUE(2)
Fresh Issue of up to 54,00,000 Equity Shares of face value of ₹10 [●] [●]
each aggregating up to ₹[●] Lakhs(2)
D) IS SUED, SUBSCRIBED AND PAID-UP SHARE CAPITAL AFTER THE ISSUE
[●] Equity Shares of face value of ₹10 each* [●] -
E) SE CURITIES PREMIUM ACCOUNT
Before the Issue (as on date of this Draft Red Herring Prospectus) Nil
After the Issue* [●]
* To be included upon finalisation of the Issue Price and Basis of Allotment.
(1) For details in relation to the changes in the authorised share capital of our Company in the last 10 years, see “History and Certain
Corporate Matters – Amendments to our Memorandum of Association” on page 463.
(2) Our Board has authorised the Issue, pursuant to their resolution dated August 26, 2025, and our Shareholders have authorised the Issue
pursuant to a special resolution dated August 28, 2025.
104Notes to capital structure
1. Share capital history of our Company
(a) Equity share capital
The following table sets forth the history of the Equity Share capital of our Company:
Issue
Face
Number of Price Cumulative
value Reason for / Cumulative
Date of equity per Nature of Name of allottees along with the number of Paid-up equity
per Nature of Number if
allotment shares equity Consideration equity shares allotted to each allottee share capital
equity allotment equity shares
allotted share (₹)
share (₹)
(₹)
October 12, 200 10 10 Cash Initial Subscription Allotment of 100 equity shares to Upendra 200 2,000
1994 to MoA# Trikamlal Shah and 100 equity shares to Purnima
Upendra Shah
December 30, 12,62,700 10 10 Cash Further issue Number 12,62,900 1,26,29,000
Sr. Name of allottee /
1994 of equity
No. shareholder
shares
1. Upendra Trikamlal Shah 4,12,500
2. Purnima Upendra Shah 1,70,000
3. Rajesh R. Punjabi 1,20,000
4. Vimlaben Trikamlal
80,000
Shah
5. Trikamlal F. Shah 70,000
6. Chimanbhai N. Patel 47,500
7. Vipul C. Desai 41,000
8. Sandhya R. Punjabi 30,000
9. Rameshchandra M. Patel 20,000
10. Anila R. Patel 20,000
11. Sonal N. Shah 10,000
12. Kantilal M. Gajjar 10,000
13. Maltiben R. Patwa 10,000
14. Kantilal A. Patel 10,000
15. Rajiben M. Patel 10,000
16. Madhavlal S. Patel 10,000
105Issue
Face
Number of Price Cumulative
value Reason for / Cumulative
Date of equity per Nature of Name of allottees along with the number of Paid-up equity
per Nature of Number if
allotment shares equity Consideration equity shares allotted to each allottee share capital
equity allotment equity shares
allotted share (₹)
share (₹)
(₹)
17. Biharilal C. Patel 10,000
18. Narendra R. Sindhi 7,100
19. Hitendra M. Patel 6,000
20. Prabhakar S. Khammar 5,500
21. Trupti Girish Shah 5,000
22. Mahendra B. Patel 5,000
23. Jitendra D. Saraiya 5,000
24. Bharat M. Shah 5,000
25. Jitendra M. Panchal 5,000
26. Nirupa Deepak Mehta 5,000
27. Dipak S. Shah 5,000
28. Harshad B. Bhimani 5,000
29. Siddhartha M. Mehta 5,000
30. Sanjay B. Bhimani 5,000
31. Vijaybhai B. Shah 5,100
32. Rajiv N. Bhavsar 5,000
33. Kamlaben M. Shah 5,000
34. Lalit A. Parikh 5,000
35. Madhukanta K. Jani 5,000
36. Chhayaben M. Shah 5,000
37. Jayantibhai K. Patel 5,000
38. Ajitkumar M. Sheth 5,000
39. Jaswantbhai S.
5,000
Khammar
40. Ashwinbhai G. Patel 5,000
41. Akshaya S. Shah 5,000
42. Daxaben P. Yadav 5,000
106Issue
Face
Number of Price Cumulative
value Reason for / Cumulative
Date of equity per Nature of Name of allottees along with the number of Paid-up equity
per Nature of Number if
allotment shares equity Consideration equity shares allotted to each allottee share capital
equity allotment equity shares
allotted share (₹)
share (₹)
(₹)
43. Hasmukh M. Shah 5,000
44. Nirupama K. Shah 3,500
45. Manubhai L. Shah 3,000
46. Alka Sunil Mehta 1,500
47. Trupti U. Shah 40,000
October 09, 37,100 10 10 Cash Further issue Number 13,00,000 1,30,00,000
Sr. Name of allottee /
1995 of equity
No. shareholder
shares
1. Shantaben Chimanlal
1,000
Patel
2. Vipul Chandrakant Desai 1,500
3. Hitendrakumar Patel 4,000
4. Tanmay Reat Est. & Fin.
15,600
Ltd.
5. Suman K. Patel 1,000
6. Dr. Kiritbhai K. Shah 3,500
7. Nalin Sumtilal Shah 3,000
8. Savitaben S. Shah 1,000
9. Sanjay Sumtilal Shah 2,000
10. Kamlesh J. Shah 1,000
11. Ambalal J. Patel 1,000
12. Nasimbibi Mutvalli 500
13. Suraiya Ranawadia 1,000
14. Bhavanji Patel 1,000
November 01, 1,74,100 10 10 Cash Preferential issue Number 14,74,100 1,47,41,000
Sr. Name of allottee /
1996 of equity
No. shareholder
shares
1. Arun M. Nayak 500
107Issue
Face
Number of Price Cumulative
value Reason for / Cumulative
Date of equity per Nature of Name of allottees along with the number of Paid-up equity
per Nature of Number if
allotment shares equity Consideration equity shares allotted to each allottee share capital
equity allotment equity shares
allotted share (₹)
share (₹)
(₹)
2. Arvind M. Thakkar 500
3. Arvind P. Patel 500
Ashokkumar Somabhai
4. 500
Mistry
5. Ashvin R. Mehta 500
Atul Mahendrabhai
6. 500
Mehta
7. Avni Shah 500
8. Bharti D. Patel 500
Bhartiben Mukeshbhai
9. 500
Patel
Bhartiben Mukeshbhai
10. 500
Patel
11. Bhavesh J. Joshi 500
Bhavesh Prakashchandra
12. 500
Shah
13. Bhupendra M. Shah 500
14. Bhupendra Vastupal Shah 500
15. Bipin T. Modi 500
16. Biren J. Desai 500
17. C. N. Patel HUF 1,000
18. Chandrakant M. Patel 500
19. Chandrakant Thakkar 500
108Issue
Face
Number of Price Cumulative
value Reason for / Cumulative
Date of equity per Nature of Name of allottees along with the number of Paid-up equity
per Nature of Number if
allotment shares equity Consideration equity shares allotted to each allottee share capital
equity allotment equity shares
allotted share (₹)
share (₹)
(₹)
Charulata Mangeshkumar
20. 500
Shah
21. Chhaganlal M. Patel 500
22. Chirag V. Shah 2,000
23. Darshana Kirit Shah 500
24. Deepika Godiawala 500
25. Dhaivat R. Shukla 500
26. Dhanendra Shah 500
Dhanjibhai Magjibhai
27. 500
Patel
28. Dharmendra V. Shah 500
29. Dharmesh Kantibhai Patel 500
30. Dhiraj Patel 500
31. Dipti V. Shah 1,000
Dr. Jitendra Shantilal
32. 1,000
Shah
33. Dr. Shobha Sankhe 500
34. Dr. Suryakant Sankhe 500
35. Gangaben Ratilal Patel 500
36. Gargi Rameshbhai Patel 1000
37. Gilbert Daniel D'souza 500
109Issue
Face
Number of Price Cumulative
value Reason for / Cumulative
Date of equity per Nature of Name of allottees along with the number of Paid-up equity
per Nature of Number if
allotment shares equity Consideration equity shares allotted to each allottee share capital
equity allotment equity shares
allotted share (₹)
share (₹)
(₹)
38. Girish Ramanlal Shah 700
39. Girish Shah 500
Hansa Narendrakumar
40. 1,000
Joshi
41. Hansaben K. Joshi 500
42. Harish R. Punjabi 1,000
43. Hetal Jayesh Shah 500
44. Hetal Jayesh Shah 2,000
45. Hetalben Patel 500
46. Jagruti P. Patel 500
Jaikishan Vasudev
47. 500
Jadwani
48. Jajvalaya R. Shukla 500
Janak Narendrakumar
49. 1,000
Joshi
50. Janardan G. Vyas 1,500
Javnikaben Ashokkumar
51. 1,000
Gajjar
52. Jayaben Vithalbhai Patel 500
53. Jayantilal Patel 500
54. Jayesh Girishbhai Shah 1,000
55. Jayesh Girishbhai Shah 1,500
110Issue
Face
Number of Price Cumulative
value Reason for / Cumulative
Date of equity per Nature of Name of allottees along with the number of Paid-up equity
per Nature of Number if
allotment shares equity Consideration equity shares allotted to each allottee share capital
equity allotment equity shares
allotted share (₹)
share (₹)
(₹)
56. Jayshree Sudhir Shah 500
57. Jigar Rameshbhai Patel 1,000
Jiltendrakumar Amichand
58. 500
Patel
59. Kaivan Shah 500
60. Kantaben Patani 500
61. Kantibhai Somabhai Patel 500
62. Kantilal Patel 500
Kapilaben Rameshbhai
63. 1,000
Patel
Kashinath Rambhau
64. 500
Borhade
Kashyap Chandravadan
65. 500
Sitwala
66. Kaushalya S. Madhyani 500
67. Keshavlal Patel 500
68. Kirtykumar Joshi 500
69. Kishori Nagori 500
70. Kokilaben R. Shah 500
Krishnajivan Bhikhalal
71. 1,000
Mehta
72. Kusum Arvind Modi 500
73. Kusum S. Patel 500
111Issue
Face
Number of Price Cumulative
value Reason for / Cumulative
Date of equity per Nature of Name of allottees along with the number of Paid-up equity
per Nature of Number if
allotment shares equity Consideration equity shares allotted to each allottee share capital
equity allotment equity shares
allotted share (₹)
share (₹)
(₹)
74. Kusumben Patel 500
75. Leela Atul Mehta 500
76. Leenaben Janakbhai Shah 500
77. Lelaben S. Patel 500
78. Madhusudan Patel 500
79. Maniben Dhanjibhai Patel 500
80. Manisha Arjun Murjani 500
81. Manjibhai Patel 600
82. Manju Ashoklal Murjani 500
Manjulaben Jayantilal
83. 500
Patel
84. Niten Shah 2,000
Mittal Narendrakumar
85. 1,000
Joshi
86. Mogiben Kantilal Patel 500
87. Naimish Kantibhai Patel 500
88. Narendra Vastupal Shah 500
89. Navinchandra C. Shukla 500
90. Navinchandra Patel 500
91. Nayana K. Jani 500
112Issue
Face
Number of Price Cumulative
value Reason for / Cumulative
Date of equity per Nature of Name of allottees along with the number of Paid-up equity
per Nature of Number if
allotment shares equity Consideration equity shares allotted to each allottee share capital
equity allotment equity shares
allotted share (₹)
share (₹)
(₹)
92. Nikunj Desai 500
93. Nilesh Girishbhai Modi 500
94. Padmaben B. Shah 1,000
95. Pankaj Jiltendra Patel 500
96. Paresh Shantilal Patel 500
97. Poonam H. Punjabi 1,000
98. Prabhaben Patel 600
Prafulkumar Somabhai
99. 500
Mistry
100. Prafulla A. Thakkar 500
101. Prakash L. Punjabi 500
102. Prakash R. Shah 500
103. Pramodbhai N. Patel 500
104. Pravinbhai J. Patel 500
105. Priti U. Shah 10,000
Purnima Rohitkumar
106. 500
Shah
107. Purvi Patel 1,000
108. Pushpa Dilip Shah 500
109. Radhika Shah 2,000
113Issue
Face
Number of Price Cumulative
value Reason for / Cumulative
Date of equity per Nature of Name of allottees along with the number of Paid-up equity
per Nature of Number if
allotment shares equity Consideration equity shares allotted to each allottee share capital
equity allotment equity shares
allotted share (₹)
share (₹)
(₹)
110. Rajenda A. Shukla 500
111. Rajendra Kantilal Shah 500
112. Rajnikant Kantilal Shah 500
113. Raksha J. Shah 500
Rameshbhai Dahyabhai
114. 2,000
Patel
115. Ramjibhai Patel 600
116. Ranchod N. Shah 500
117. Ratilal Vishram Patel 500
118. Rekhaben Patel 500
Rohitkumar Chinubhai
119. 500
Shah
120. Samir Maneklal Turakhia 500
121. Sanjay Mehta 500
122. Savitri D. Patel 500
123. Sevantilal P. Shah 500
Shah Devendra
124. 500
Prakashchandra
125. Shah Heeta Naraeshbhai 500
126. Shah Kunal Satishbhai 500
127. Shailesh K. Patel 500
114Issue
Face
Number of Price Cumulative
value Reason for / Cumulative
Date of equity per Nature of Name of allottees along with the number of Paid-up equity
per Nature of Number if
allotment shares equity Consideration equity shares allotted to each allottee share capital
equity allotment equity shares
allotted share (₹)
share (₹)
(₹)
Shantilal Khimjibhai
128. 500
Patel
129. Shantilal R. Patel 500
130. Shefali Siddhartha Mehta 500
Shobha Kashinath
131. 2,500
Borhade
132. Shrichand T. Madhyani 500
133. Smita Gilbert D'Souza 500
Somabhai Ishwarlal
134. 500
Mistry
135. Sudhirkumar C. Shah 500
136. Sulochana Rajnikant Shah 500
137. Sunder Chandumal 500
138. Tej J. Shah 500
139. Tej Krishen Kachru 500
140. Tejas M. Barot 500
141. Trikamlal F. Shah 36,600
142. Vasantlal Chandulal Shah 500
Vastupalbhai Keshavlal
143. 500
Shah
144. Vikram C. Shah 500
145. Vimlaben T. Shah 35,000
115Issue
Face
Number of Price Cumulative
value Reason for / Cumulative
Date of equity per Nature of Name of allottees along with the number of Paid-up equity
per Nature of Number if
allotment shares equity Consideration equity shares allotted to each allottee share capital
equity allotment equity shares
allotted share (₹)
share (₹)
(₹)
Vinodiniben Sureshbhai
146. 500
Shah
Vithalbhai Mavjibhai
147. 500
Patel
148. Yogesh C. Patel 500
November 01, 5,31,900 10 10 Cash Right issue Number 20,06,000 2,00,60,000
Sr. Name of allottee /
1996 of equity
No. shareholder
shares
1. Alka Sunil Mehta 1,500
2. Anuradha R. Bhavsar 5,000
3. Ashwin Govindlal Patel 1,000
4. Ashwinbhai G. Patel 1,000
Ashwinkumar Govindlal
5. 1,000
Patel
Ashwinkumar Govindlal
6. 1,000
Patel
7. Bharat M. Shah 2,500
8. Bharat M. Shah 2,500
9. Bharatbhai Gopani 1,000
10. Bharatkumar Saraiya 1,000
11. Chirag Manubhai Shah 2,000
12. Daxaben P.Yadav 2,000
13. Geetaben M. Patel 500
116Issue
Face
Number of Price Cumulative
value Reason for / Cumulative
Date of equity per Nature of Name of allottees along with the number of Paid-up equity
per Nature of Number if
allotment shares equity Consideration equity shares allotted to each allottee share capital
equity allotment equity shares
allotted share (₹)
share (₹)
(₹)
14. Geetaben M. Patel 500
15. Geetaben M. Patel 500
16. Geetaben M. Patel 500
17. Geetaben M. Patel 1000
18. Induben Gopani 1,000
19. Jyostanaben M. Patel 1,000
20. Kalpana S. Jani 1,000
21. Kirit Kantilal Shah 3,500
22. Krupa Ashwin Patel 1,000
23. Laxmiben Ramanlal Patel 500
24. Manubhai L. Shah 2,000
25. Narmadaben M. Patel 500
26. Narmadaben M. Patel 1,000
27. Nasimbibi Mutvalli 500
28. Nirupama K. Shah 3,000
29. Pohapsingh H. Yadav 1,000
30. Prabhubhai M. Patel 1,000
31. Pranavbhai Khambhati 1,000
117Issue
Face
Number of Price Cumulative
value Reason for / Cumulative
Date of equity per Nature of Name of allottees along with the number of Paid-up equity
per Nature of Number if
allotment shares equity Consideration equity shares allotted to each allottee share capital
equity allotment equity shares
allotted share (₹)
share (₹)
(₹)
32. Pravin D. Patel 500
33. Pravin D. Patel 500
34. Priti U. Shah 31,400
35. Purnima U. Shah 22,000
36. Purnima U. Shah 20,800
37. Pushpaben M. Patel 1,000
38. Rajesh R. Punjabi 21,800
39. Rajiben M. Patel 1,000
40. Sachin Manubhai Shah 1,000
41. Sachin Manubhai Shah 1,000
42. Samir P. Yadav 2,000
43. Sandhya R. Punjabi 20,000
44. Savitaben N. Patel 500
45. Savitaben N. Patel 500
46. Savitaben N. Patel 1,000
47. Savitaben N. Patel 1,000
48. Savitaben S. Shah 1,000
Shantaben Chimanlal
49. 1,500
Patel
118Issue
Face
Number of Price Cumulative
value Reason for / Cumulative
Date of equity per Nature of Name of allottees along with the number of Paid-up equity
per Nature of Number if
allotment shares equity Consideration equity shares allotted to each allottee share capital
equity allotment equity shares
allotted share (₹)
share (₹)
(₹)
50. Shobhanaben A. Vaghela 1,000
51. Snehlata Manubhai Shah 2,000
52. Sonal N. Shah 10,000
53. Sudhanshu K. Jani 1,000
54. Suman K. Patel 1,500
55. Suraiya Ranawadia 1,000
56. Trikamlal F. Shah 20,000
57. Trupti U. Shah 30,800
58. Trupti U. Shah 20,100
59. Upendra T. Shah 85,800
60. Upendra T. Shah 1,00,000
61. Upendra T. Shah 75,000
62. Ushaben Saraiya 2,000
63. Vimlaben T. Shah 10,700
October 31, 4,08,500 10 10 Cash Further issue Sr. Name of allottee / Number 24,14,500 2,41,45,000
1999 No. shareholder of equity
shares
1. Pratik Rameshchandra
9,500
Patel
2. Anita Rameshchandra
10,000
Patel
119Issue
Face
Number of Price Cumulative
value Reason for / Cumulative
Date of equity per Nature of Name of allottees along with the number of Paid-up equity
per Nature of Number if
allotment shares equity Consideration equity shares allotted to each allottee share capital
equity allotment equity shares
allotted share (₹)
share (₹)
(₹)
3. Ranjanben Saraiya 1,000
4. Manjula N. Shah 1,000
5. Jayshree Vikram Shah 500
6. Rajendra Kantilal Shah 500
7. Hetal Brijal Parikh 1,000
8. Sonal Deepakbhai Shah 1,000
9. Ajay Devendra Patel 500
10. Mrudula Balvantbhai
1,000
Patel
11. Chandravadan Sitwala 500
12. Drigesh C. Sitwala 500
13. Lata Shah 500
14. Mohanlal M. Patel 500
15. Samir P. yadav 1,000
16. Pohapsingh H. Yadav 1,000
17. Daksha P. Yadav 1,000
18. Briijal Hasmukhbhai
1,000
Parikh
19. Depak S. Shah 1,000
20. Gitaben M. Patel 1,500
21. Savitaben N. Patel 1,500
22. Rajiben M. Patel 1,500
23. Madhavlal S. Patel 1,500
24. Gilaben Jayantilal Patel 500
25. Nirmlaben Modi 500
26. Jitendra Govindbhai Patel 500
27. Harish Punjabi 1,000
28. Poonam Punjabi 1,000
120Issue
Face
Number of Price Cumulative
value Reason for / Cumulative
Date of equity per Nature of Name of allottees along with the number of Paid-up equity
per Nature of Number if
allotment shares equity Consideration equity shares allotted to each allottee share capital
equity allotment equity shares
allotted share (₹)
share (₹)
(₹)
29. Bharti Shah 1,000
30. Chandraben Madhubhai
1,000
Parmar
31. Pushpaben M. Patel 1,000
32. Vithalbhai H. Patel 500
33. Vimlaben V. Patel 500
34. Dhaval Babubhai Patel 500
35. Manisha Paresh Patel 500
36. Devendra Sombhai Patel 500
37. Nayana DevendraPatel 500
38. Minaxi M. Shah 500
39. Arvind M. Thakkar 1,000
40. Prafula M. Thakkar 1,000
41. Neeta Dipak Patel 1,000
42. Purvi H. Patel 1,000
43. Kaushik Ramanlal Patel 1,000
44. Dipak Ramanlal Shah 1,000
45. Dinubhai Javerilal Shah 500
46. Sheelaben Dilipkumar
500
Patel
47. Lilavati Patel 500
48. Sheelaben D. Patel 2,000
49. Kanayalal C. Murjani 1,000
50. Meena K. Murjani 1,000
51. Bachubhai Parikh 1,000
52. Bhadraben Parikh 1,000
53. Vidhyut Shah 1,000
54. Hiren J. Patel 1,000
121Issue
Face
Number of Price Cumulative
value Reason for / Cumulative
Date of equity per Nature of Name of allottees along with the number of Paid-up equity
per Nature of Number if
allotment shares equity Consideration equity shares allotted to each allottee share capital
equity allotment equity shares
allotted share (₹)
share (₹)
(₹)
55. Sanket J. Patel 1,000
56. Upendra Trikamlal Shah
9,000
(HUF)
57. Sonal N. Shah 3,000
58. Tanmay Upendra Shah 19,000
59. Rajesh R. Punjabi 46,000
60. Sandhya R. Punjabi 36,000
61. Purnima Upendra Shah 37,000
62. Upendra Trikamlal Shah 1,31,000
63. Trupti U. Shah 29,500
64. Priti U. Shah 30,000
65. Dipti Paragbhai Shah 2,500
August 01, 5,85,500 10 10 Cash Further issue Sr. Name of allottee / Number 30,00,000 3,00,00,000
2000 No. shareholder of equity
shares
1. Upendrabhai Trikamlal 3,10,000
Shah &
Purnimaben Upendrabai
Shah*
2. Purnimaben Upendrabhai 93,400
Shah &
Upendrabhai Trikamlal
Shah*
3. Priti Upendrabhai Shah & 36,000
Purnimaben Upendrabhai
Shah*
4. Tanmay Upendrabhai 28,000
Shah &
Purnimaben Upendrabhai
Shah*
5. Rajesh Ramchandra 25,000
Punjabi &
122Issue
Face
Number of Price Cumulative
value Reason for / Cumulative
Date of equity per Nature of Name of allottees along with the number of Paid-up equity
per Nature of Number if
allotment shares equity Consideration equity shares allotted to each allottee share capital
equity allotment equity shares
allotted share (₹)
share (₹)
(₹)
Sandhaya Rajesh
Punjabi*
6. Trishla Sanjay Bhimani & 18,000
Sandhya Rajesh Punjabi*
7. Trupti Upendrabhai Shah 13,000
& Purnimaben
Upendrabhai Shah*
8. Upendra Tikamlal Shah 9,000
(HUF) &
Tanmay Upendrabhai
Shah*
9. Sandhya Rajesh Punjabi 10,000
& Rajesh Ramchandra
Punjabi*
10. Gauriben Prafulbhai Shah 6,000
& Utpal Prafulbhai Shah*
11. Tej Jitendrabhai Shah 5,000
12. AjitKumar Manshukal 5,000
Shethi &
Bhavana Ajitkumar
Sethi*
13. Rupal Pritesh Shah & 4,000
Pritish Prafulbhai Shah*
14. Indu Narendra Jain 3,500
15. Prachi Narendra Jain 3,500
16. Siddarth Bharat Shah 3,000
17. Sharvil Hemantbhai Shah 1,500
& Satyendra Jivrajbhai
Shah*
18. Harsha Amrish Trivedi & 1,000
Amrish Curlabhbhai
Trivedi
19. Keshavlal Chaganlal 1,000
Patel & Champaben
Keshavlal Patel
123Issue
Face
Number of Price Cumulative
value Reason for / Cumulative
Date of equity per Nature of Name of allottees along with the number of Paid-up equity
per Nature of Number if
allotment shares equity Consideration equity shares allotted to each allottee share capital
equity allotment equity shares
allotted share (₹)
share (₹)
(₹)
20. Priti Chirag Shah & 1,000
Nirmalaben
Vinodchandra Shah*
21. Tarunaben Shantilal 600
Lodha
22. Champaben Keshavlal 500
Patel &
Keshavlal Chhaganlal
Patel*
23. Hemant Udaykumar Roy 500
24. Ketan Arvindbhai 500
Nanvati & Falguni Ketan
Nanvati*
25. Sanjay Arvindbhai Metha 500
& Komal Sanjay Mehta*
26. Paresh Manubhai Jansari 500
27. Darshini Jinal Shah & 500
Jinal Deepakbhai Shah*
28. Brijesh Sureshbhai Patel 500
29. Rasikbhai Lakshimich & 500
Panchal
Varsha Rasik Panchal*
30. Rekhaben Dipakbhai 500
Vora & Dipakbhai
Babubhai Vora*
31. Raju Shankarlal Thakor 500
32. Divya Rakshesh Dave & 500
Rakshesh Umeshchandra
Dave*
33. Hetal Jayesh Sheth & 500
Jayesh Girish Sheth*
34. Jignesh Navinchandra 500
Shukla & Tushar
Navinchandra Shukla*
124Issue
Face
Number of Price Cumulative
value Reason for / Cumulative
Date of equity per Nature of Name of allottees along with the number of Paid-up equity
per Nature of Number if
allotment shares equity Consideration equity shares allotted to each allottee share capital
equity allotment equity shares
allotted share (₹)
share (₹)
(₹)
35. Ketan Arvindbhai 500
Nanavati
36. Nilesh Girishchandra 500
Modi & Palak
Nileshkumar Modi*
37. Pritesh Dineshchandra 500
Modi & Pushpaben
Dineshchandra Modi*
September 15, 15,00,000 10 10 Cash Further issue Number 45,00,000 4,50,00,000
Sr. Name of allottee /
2005 of equity
No. shareholder
shares
1. Mrs. Preeti Tej Shah & 2,50,000
Mr. Tej J Shah *
2. Mrs. Purnima U. Shah & 5,00,000
Mr. Upendra T. Shah*
3. Mr. Rajesh R. Punjabi & 50,000
Mrs. Sandhya R.
Punjabi*
4. Mr. Tanmay U. Shah & 60,000
Mrs. Purnima U. Shah*
5. Mrs. Trupti U. Shah & 80,000
Mr. Utpal P. Shah*
6. Mr. Upendra T. Shah & 5,00,000
Mrs. Purnima U. Shah*
7. Mr. Utpal P. Shah & 10,000
Mrs. Trupti U. Shah*
8. Mr. Tej J. Shah & 50,000
Mrs. Preeti T. Shah*
November 01, 45,00,000 10 N.A. N.A. Bonus issue in the Number 90,00,000 9,00,00,000
Sr. Name of allottee /
2007 ratio of 1:1 (one for of equity
No. shareholder
every one equity shares
share held) 1. Anila R. Patel & R.M. 20,000
Patel*
2. Akshaya S. Shah 5,000
3. Avni Shah & Ashit Shah* 500
125Issue
Face
Number of Price Cumulative
value Reason for / Cumulative
Date of equity per Nature of Name of allottees along with the number of Paid-up equity
per Nature of Number if
allotment shares equity Consideration equity shares allotted to each allottee share capital
equity allotment equity shares
allotted share (₹)
share (₹)
(₹)
4. Bharat M. Shah 10,000
5. Bachubhai Parikh & 1,000
Sanjiv Parikh*
6. Bhadraben Parikh & Mita 1,000
Parikh*
7. Bharti Shah & Parag 1,000
Shah*
8. Chandraben Madhubhai 1,000
Parmar & M.S. Parmar*
9. Dipak S. Shah & S.D. 5,000
Shah*
10. Dhawal Babubhai Patel 500
& Dipti Shah*
11. Girish Shah & Lata 500
Shah*
12. Harshad B. Bhimani & 5,000
R.H. Bhimani*
13. Harish R. Punjabi & P.H. 2,000
Punjabi*
14. Hetal Jayesh Shah & J.G. 2,500
Shah*
15. Hetalben Patel 500
16. Shah Heeta Naraeshbhai 500
& B.N. Shah*
17. Hetal J. Shah & Jayesh 500
G. Shah*
18. Jayesh Girishbhai Shah & 2,500
H.J. Shah*
19. Jitendrakumar Amichand 500
Patel & P.J. Patel*
20. Jitendra Govindbhai Patel 500
& H.J. Patel*
21. Jignesh Shukla & Tushar 500
Shukla*
126Issue
Face
Number of Price Cumulative
value Reason for / Cumulative
Date of equity per Nature of Name of allottees along with the number of Paid-up equity
per Nature of Number if
allotment shares equity Consideration equity shares allotted to each allottee share capital
equity allotment equity shares
allotted share (₹)
share (₹)
(₹)
22. Jitendra Sariya & 2,000
Ushaben Sariya &
Mamataben Sariya*
23. Kirit Kantilal Shah & 3,500
N.K. Shah*
24. Kaushalya S. Madhyani 500
& S.T. Madhyani*
25. Kishori Nagori & K.N. 500
Nagori*
26. Kusumben Patel 500
27. Shah Kunal Satishbhai & 500
S.B. Shah*
28. Kirit Kantilal Shah & 500
N.K. Shah & Darshna K.
Shah*
29. Krishnajivan Bhikhalal 1,000
Mehta
30. Lata Shah & Girish Shah 500
31. Lilavatiben Patel & 500
Pravin Patel*
32. Maulik R. Patel & 10,000
Rameshchandra M.
Patel*
33. Manisha Paresh Patel 500
34. Madhusudan Patel 500
35. Nirupama K. Shah & 3,500
K.K. Shah*
36. Nalin Sumtilal Shah & 3,000
R.N. Shah*
37. Jignesh N. Shukla 500
38. Navinchandra Patel & 500
K.J. Patel*
39. Nilesh Girishbhai Modi 1,000
& P.N. Modi*
127Issue
Face
Number of Price Cumulative
value Reason for / Cumulative
Date of equity per Nature of Name of allottees along with the number of Paid-up equity
per Nature of Number if
allotment shares equity Consideration equity shares allotted to each allottee share capital
equity allotment equity shares
allotted share (₹)
share (₹)
(₹)
40. Purnima Upendra Shah & 10,02,400
Upendra T. Shah*
41. Priti U. Shah & P. 1,61,000
Upendra Shah*
42. Preeti T. Shah & Tej J. 2,80,200
Shah*
43. Pankaj Jitendra Patel & 500
J.A. Patel*
44. Poonam H. Punjabi & 2,000
H.R. Punjabi*
45. Prakash L. Punjabi & 500
A.P. Punjabi*
46. Purvi Patel & Hitesh 2,000
Patel*
47. Pratik Rameshchandra 10,000
Patel & R.M. Patel*
48. Rajesh R. Punjabi & S.R. 2,73,600
Punjabi*
49. Rameshchandra M. Patel 20,000
& A.R. Patel*
50. Raksha J. Shah & R.N. 500
Shah*
51. Ramjibhai M. Patel 600
(Poonam H. Punjabi) *
52. Ranchhod N. Shah & R.J. 500
Shah*
53. Rekhaben Patel & 500
Madhusudan Patel*
54. Ruchira T. Shah & 9,000
Tanmay U. Shah*
55. Sandhya R. Punjabi & 1,32,500
R.R. Punjabi*
56. Sanjay Sumitlal Shah & 2,000
R.S. Shah*
57. Sonal Deepakbhai Shah 6,000
& D.S Shah*
128Issue
Face
Number of Price Cumulative
value Reason for / Cumulative
Date of equity per Nature of Name of allottees along with the number of Paid-up equity
per Nature of Number if
allotment shares equity Consideration equity shares allotted to each allottee share capital
equity allotment equity shares
allotted share (₹)
share (₹)
(₹)
58. Tej Jitendra Shah & 69,200
Preeti T. Shah*
59. Trupti U. Shah & P. 2,30,900
Upendra Shah*
60. Tej J. Shah 500
61. Tanmay Upendra Shah & 2,87,200
P. Upendra Shah*
62. Tej Shah 5,000
63. Upendra Trikamlal Shah 17,89,700
& P. Upendra Shah*
64. Utpal P. Shah & Trupti U. 12,000
Shah*
65. Upendra Trikamlal Shah 52,000
& Trikamlal F. Shah*
66. Upendra Trikamlal Shah 56,200
(HUF) & Tanmay
Upendra Shah*
67. Vipul C. Desai & C.A. 1,000
Desai*
68. Vinodiniben Sureshbhai 500
Shah & S.G. Shah*
69. Vidhyut Shah 1,000
70. Vimlaben V. Patel 500
71. Vithalbhai H. Patel 500
February 29, 2,67,000 10 150 Cash Preferential issue Sr. Name of allottee / Number 92,67,000 9,26,70,000
2008 No. shareholder of equity
shares
1. Srujal Shah 300
2. Chintan S Parikh 300
3. Sushila Babubhai Patel 300
4. Manjulaben Patel 1,000
5. Kruti Jatin Patel 1,200
129Issue
Face
Number of Price Cumulative
value Reason for / Cumulative
Date of equity per Nature of Name of allottees along with the number of Paid-up equity
per Nature of Number if
allotment shares equity Consideration equity shares allotted to each allottee share capital
equity allotment equity shares
allotted share (₹)
share (₹)
(₹)
6. Babubhai Ambalal Patel 300
7. Jyotsna Laxesh Chudgar 300
8. Ambalal Maganlal Patel 300
9. Chaturbhai Patel HUF 500
10. Ramilaben D Patel 600
11. Divyakant C Patel HUF 500
12. Bharatkumar C Patel 600
13. Sitaben C Patel 400
14. Chaturbhai Harjivan
900
Das
15. Shilpaben B Patel 500
16. Jatin Vinodchandra Patel
1,200
HUF
17. Neeta Jatin Patel 1,200
18. Jatin Vinodchandra Patel 1,400
19. Lilaben Satishbhai Patel 300
20. Babubhai Dolatsinh
300
Darbar
21. Bhanumati Indravadan
300
Bhatt
22. Bhagwandas Bababhai
300
Desai
23. Kinjal Harshad Patel 300
24. Janardan Induprasad
300
Patel
25. Jwellin Shah 400
26. Dinesh Shah 700
27. Leena Shah 300
28. Nikunj Mahendrabhai
300
Patel
130Issue
Face
Number of Price Cumulative
value Reason for / Cumulative
Date of equity per Nature of Name of allottees along with the number of Paid-up equity
per Nature of Number if
allotment shares equity Consideration equity shares allotted to each allottee share capital
equity allotment equity shares
allotted share (₹)
share (₹)
(₹)
29. Kundan Vallabhai Patel 300
30. Deepakbhai Sumatilal
1,000
Shah
31. Sanjay Sumatilal Shah 1,000
32. Nalin Sumantilal Shah 1,000
33. Jayantibhai Bhikhabhai
1,000
Patel
34. Manish Babulal
1,000
Vaghasia
35. Alpa Bhaveshbhai Patel 1,000
36. Hemal Vipinchandra
600
Karbhari
37. Dushyant Sureshbhai
600
Shah
38. Alpesh Jayantilal Shah 600
39. Dipakbhai
600
Navinchandra Shah
40. Akash Nalimkumar
500
Shah
41. Hetal Kamleshbhai Shah 500
42. Milanben Pareshbhai
400
Mehta
43. Paresh Champaklal
400
Mehta
44. Avani Vinodchandra
300
Karbhari
45. Pratibhaben
300
Satishkumar Mehta
46. Kamlesh Jayantibhai
300
Shah
47. Bharatbhai Umedchand
300
Gopani
48. Kalpeshbhai Rasiklal
300
Shah
131Issue
Face
Number of Price Cumulative
value Reason for / Cumulative
Date of equity per Nature of Name of allottees along with the number of Paid-up equity
per Nature of Number if
allotment shares equity Consideration equity shares allotted to each allottee share capital
equity allotment equity shares
allotted share (₹)
share (₹)
(₹)
49. Mukeshbhai Govindbhai
300
Patel
50. Kanchan Nareshbhai
1,000
Patel
51. Amit Ashokbhai Parikh 1,000
52. Malti Ashokbhai Parikh 700
53. Krina Amit Parikh 700
54. Monali Divyeshbhai
1,000
Shah
55. Rajesh Kapoor 1,000
56. Chander Choithram
300
Vanvari
57. Indumati Chander
300
Vanvari
58. Vimal Dairy Limited 600
59. Nilay Bharatkumar
300
Contractor
60. Bina Kalpeshkumar
300
Shah
61. Trupti Mehta 1,000
62. Surya Bhupendra Mehta 300
63. Bhumita Hiteshbhai
1,000
Sanghvi
64. Inaxi Nareshbhai Shah 300
65. Ketan Tejpal Parikh 400
66. Rajiv Tejpal Parikh 300
67. Sonal Rajiv Parikh 300
68. Atul Chandrakant Shah 300
69. Pathik Atulbhai Shah 300
70. Harshadkumar Ravalji 300
71. Indumati Vora 300
132Issue
Face
Number of Price Cumulative
value Reason for / Cumulative
Date of equity per Nature of Name of allottees along with the number of Paid-up equity
per Nature of Number if
allotment shares equity Consideration equity shares allotted to each allottee share capital
equity allotment equity shares
allotted share (₹)
share (₹)
(₹)
72. Palak Desai 2,000
73. Jayprakash Desai 2,000
74. Jigna Tejas Dave 600
75. Shachish Piyush Doctor 300
76. Devang Navinchandra
400
Gandhi
77. Bhanuben Natverlal
300
Shah
78. Natverlal Shankerlal
300
Shah
79. Dinesh H Pande 300
80. Bharatbhai Chimanlal
300
Dani
81. Dipesh Sunilbhai Mehta 300
82. Dinesh Natverlal Shah 3,000
83. Sarojben Bharat Shah 2,000
84. Sejal Gopal Shah 3,000
85. Tapan Dinesh Shah 300
86. Bharat Natverlal Shah 300
87. Hinaben Dinesh Shah 300
88. Hansaben Ghanshyam
300
Khatri
89. Manish Gopalkrishna
500
Patwari
90. Gopal Natverlal Shah 300
91. Premilaben Anilkumar
300
Chauhan
92. Mahendra Hargovandas
1,000
Patel
93. Taraben Mahendrabhai
300
Patel
133Issue
Face
Number of Price Cumulative
value Reason for / Cumulative
Date of equity per Nature of Name of allottees along with the number of Paid-up equity
per Nature of Number if
allotment shares equity Consideration equity shares allotted to each allottee share capital
equity allotment equity shares
allotted share (₹)
share (₹)
(₹)
94. Roopa Manojkumar
500
Shah
95. Manojkumar Lalbhai
500
Shah
96. Avanish Niranjan Patel 300
97. Harshadbhai Keshavlal
500
Patel
98. Premilaben Harshadbhai
500
Patel
99. Bhumika Bharatkumar
300
Patel
100. Smitaben Keshavlal
300
Patel
101. Hiren Harshadbhai Patel 400
102. Rajendra Kantilal Patel 1,000
103. Kantilal Ambalal Patel 1,000
104. Vidya Kantilal Patel 1,000
105. Bipin Shankerlal Vyas 300
106. Mandakini Nimesh
300
Desai
107. Harshadbhai Keshavlal
300
Patel HUF
108. Sangita S Desai 300
109. Jaimini Jatin Patel 300
110. Shantiben Narsinhbhai
1,500
Patel
111. Bindu Rajiv Patel 500
112. Rajiv Narsinhbhai Patel 1,000
113. Vishnubhai Chhaganlal
300
Patel
114. Jaydeep Dhananjay
300
Patel
134Issue
Face
Number of Price Cumulative
value Reason for / Cumulative
Date of equity per Nature of Name of allottees along with the number of Paid-up equity
per Nature of Number if
allotment shares equity Consideration equity shares allotted to each allottee share capital
equity allotment equity shares
allotted share (₹)
share (₹)
(₹)
115. Darshan A Desai 300
116. Varsha Jagdishchandra
300
Purani
117. Kaushik Purani 300
118. Yogesh Dilipbhai Patel 300
119. Paresh Mahendrakumar
300
Patel
120. Dinesh Ambalal Modi 300
121. Priyata Haresh Jethva 300
122. Ramilaben Shamjibhai
300
Jethva
123. Mayur Manubhai Parikh 300
124. Sushma Mayoor Parikh 300
125. Nisith Shah 300
126. Vinod Mehta 1,000
127. Kundan Rameshbhai
500
Gandhi
128. Hardik Dharmendrabhai
300
Patel
129. Ashok Nanakram
300
Ramtri
130. Sonia Rajesh Kapoor 1,000
131. Kirtikumar Modi 300
132. Aanal M Shah 1,000
133. Smitaben Maheshkumar
300
Patel
134. Maheshkumar Somabhai
300
Patel
135. Neha Parful Shah 300
136. Amit Chinubhai Patel 600
137. Tushar Rawal 300
135Issue
Face
Number of Price Cumulative
value Reason for / Cumulative
Date of equity per Nature of Name of allottees along with the number of Paid-up equity
per Nature of Number if
allotment shares equity Consideration equity shares allotted to each allottee share capital
equity allotment equity shares
allotted share (₹)
share (₹)
(₹)
138. Amitbhai Popatlal Shah 300
139. Janakkumar Bhanubhai
300
Babaria
140. Anuradha Bhavsar 300
141. Rajiv Bhavsar 300
142. Ranjan Patwa 300
143. Naziralam
300
Dinmohmmed Sheikh
144. Prahash Fin-stock
1,000
Private Limited
145. Suresh Maneklal Shah 300
146. Jitendra Amarchand
400
Desai
147. Pratimaben Shanabhai
300
Patel
148. Viral D Shah 400
149. Neha Jhaveri 300
150. Hasmukhray Shah 1,500
151. Narendrakumar Joshi 1,000
152. Kalpana Nitin Shah 500
153. Mandakini Shailesh
500
Shah
154. Rashmika Shah 500
155. Lopa Shah 400
156. Monali Birenkumar
400
Shah
157. Kiritkumar Govindlal
400
Shah
158. Shardaben A Shah 300
159. Anjali Hiteshbhai Shah 300
136Issue
Face
Number of Price Cumulative
value Reason for / Cumulative
Date of equity per Nature of Name of allottees along with the number of Paid-up equity
per Nature of Number if
allotment shares equity Consideration equity shares allotted to each allottee share capital
equity allotment equity shares
allotted share (₹)
share (₹)
(₹)
160. Vinodchandra Keshavlal
300
Shah
161. Bharatkumar Amaratlal
300
Shah
162. Induben Dineshbhai
300
Bhavsar
163. Dipika Jayesh Shah 300
164. Jayesh Indravadan Shah 300
165. Indravadan Shah 300
166. Chintan Pankajkumar
300
Shah
167. Minal Kiritbhai Parikh 1,000
168. Pranav Kiritbhai Parikh 1,000
169. Sharad Kaniyalal
300
Acharya
170. Surendra Popatlal Shah 300
171. Jignesh Maniar 300
172. Shivani Maniar 300
173. Shreyans Rasiklal Doshi 2,000
174. Janak Narendrakumar
1,000
Joshi
175. Piyusha J Vakil 300
176. Deviben M Pujara 300
177. Yogeshchandra Manohar
300
Neve
178. Nilima Yogeshchandra
300
Neve
179. Piyushkumar
600
Krishnachandra Dani
180. Bhavana Piyushkumar
400
Dani
181. Anand Ashvin Dalal 500
137Issue
Face
Number of Price Cumulative
value Reason for / Cumulative
Date of equity per Nature of Name of allottees along with the number of Paid-up equity
per Nature of Number if
allotment shares equity Consideration equity shares allotted to each allottee share capital
equity allotment equity shares
allotted share (₹)
share (₹)
(₹)
182. Ashvin Chinubhai Dalal 300
183. Asit Jitendrabhai Zaveri 300
184. Kunj Sanjay Shah 300
185. Hitesh Vithalbhai Patel 300
186. Jitesh Suresh Shah 500
187. Harish Patel 300
188. Hina Vithalani 800
189. Varshaben G Gadani 500
190. Upendra Vithalani 500
191. Rashmiben Gajjar 300
192. Harivadan Shivlal
300
Bhavsar
193. Dhirajlal Prabhudas
400
Kansara
194. Dilip R Soni 300
195. Rajendrakumar S Shah 300
196. Chandresh R Soni 300
197. Gitaben Girishkumar
300
Kotak
198. Rajesh Maneklal Kotak 300
199. Prakash Hasmukhlal
300
Kotak
200. Sunil Prahladbhai
1,000
Sevani
201. Kiranben Sunilbhai
1,000
Sevani
202. Govind Rukmanbhai
300
Nama
203. Girish Hasmukhlal
300
Kotak
204. Ajaykumar N Chaudhari 1,000
138Issue
Face
Number of Price Cumulative
value Reason for / Cumulative
Date of equity per Nature of Name of allottees along with the number of Paid-up equity
per Nature of Number if
allotment shares equity Consideration equity shares allotted to each allottee share capital
equity allotment equity shares
allotted share (₹)
share (₹)
(₹)
205. Arvindbhai Prabhudas
300
Patel
206. Neha Patel 300
207. Jayshree Patel 300
208. Dwipal D. Patel 300
209. Suleman Khoja 300
210. Ramesh Sorathia 300
211. Bharati Dinesh Desai 600
212. Shachi Dinesh Desai 600
213. Dakshaben Shah 300
214. Neeta Dipak Patel 300
215. Bhavini Rupeshbhai
300
Patel
216. Anita Alpeshkumar
300
Shah
217. Mrunalini Patel 300
218. Sudha Kamlesh Modi 300
219. Rekhaben Rajeshkumar
600
Kotak
220. Bharat J. Patel 500
221. Darshan Bharatbhai
1,000
Patel
222. Poornima Shah 300
223. Ashokkumar Shah 300
224. Dhruva Hardikkumar
800
Dave
225. Janak Natvarlal Patel 300
226. Rashmikaben
300
Dineshkumar Modi
227. Rashmika Janakumar
300
Patel
139Issue
Face
Number of Price Cumulative
value Reason for / Cumulative
Date of equity per Nature of Name of allottees along with the number of Paid-up equity
per Nature of Number if
allotment shares equity Consideration equity shares allotted to each allottee share capital
equity allotment equity shares
allotted share (₹)
share (₹)
(₹)
228. Renuka Arvind Patel 2,000
229. Ashish Dhanjibhai
300
Davda
230. Mehal Ashish Davda 300
231. Ankur Harshadray
400
Pandya
232. Krunal D. Shah 500
233. Indira Piyush Dalal 300
234. Sandip Bharatkumar
300
Patel
235. Vimalagauri Naranlal
300
Patel
236. Vishvajit Patel 400
237. Rupeshkumar
300
Rameshchandra Patel
238. Naranlal Maneklal Patel 300
239. Rajesh Patel 300
240. Navinchandra V Shah 500
241. Jayantibhai Asari 1,000
242. Chirag Shah 300
243. Nareshchandra Shah 300
244. Rajendra Kantilal Shah 300
245. Jyotsana Rajendra Shah 300
246. Jankiben
300
Dharmendrakumar Patel
247. Anil Baldevbhai Patel 300
248. Nitin Kanubhai Patel 300
249. Shital Bihagbhai Angreji 300
250. J.D. Saraiya H.U.F. 1,000
140Issue
Face
Number of Price Cumulative
value Reason for / Cumulative
Date of equity per Nature of Name of allottees along with the number of Paid-up equity
per Nature of Number if
allotment shares equity Consideration equity shares allotted to each allottee share capital
equity allotment equity shares
allotted share (₹)
share (₹)
(₹)
251. Kaushikkumar Ramanlal
300
Patel
252. Amita Kaushik Patel 300
253. Manisha Manish Doshi 300
254. Manish Girish Doshi 300
255. Taruna Girish Doshi 300
256. Girish Lalbhai Doshi 300
257. Shobhan S. Parikh 300
258. Khodidas Prabhudas
300
Barot
259. Praful K. Shah 400
260. Kamleshbhai Patel 1,000
261. Ghanshyambhai Patel 600
262. Mahesh Ramanlal
300
Gandhi
263. Jagruti Pravin Master 300
264. Gauri P Rohra 2,000
265. Malaben B. Rohra 1,000
266. Shyamal T. Rohra 1,000
267. Rajkumar Devnani 1,000
268. Vipul C. Desai 300
269. Chetna Vipul Desai 300
270. Sarojben C. Desai 300
271. Satish Ratilal Budhbatti 300
272. Premila Jagdish
300
Bhimani
273. Prashant J. Bhimani 300
274. Dipikaben Upendrabhai
300
Prajapati
141Issue
Face
Number of Price Cumulative
value Reason for / Cumulative
Date of equity per Nature of Name of allottees along with the number of Paid-up equity
per Nature of Number if
allotment shares equity Consideration equity shares allotted to each allottee share capital
equity allotment equity shares
allotted share (₹)
share (₹)
(₹)
275. Divyaben Y. Prajapati 300
276. Shachi Devang Patel 1,000
277. Hardik J. Bhimani 300
278. Rajnikant Hiralal Patel 400
279. Amitbhai Bhagvandas
600
Choksi
280. Chandrakant A. Desai 300
281. Dipal Rameshbhai Shah 600
282. Surekha Suketu Javeri 300
283. Shaileshbhai Shah 300
284. Bharatkumar Daftary 300
285. Dharmesh Rasiklal Shah 300
286. Dilipbhai R Patel 300
287. Sheelaben D. Patel 300
288. Piyush Doshi 1,400
289. Rekha Doshi 1,400
290. Trivedi Sneha 300
291. Ila Thakker 300
292. Naveen Kejriwal 500
293. Laxmiben Chauham 1,000
294. Harshad Vyas 1,000
295. Sheetal Vyas 1,400
296. Babubhai Shah 300
297. Niraj Dilipkumar Shah
600
HUF
298. Dilipkumar Rasiklal
600
Shah HUF
299. Sushma Mahesh Gandhi 300
142Issue
Face
Number of Price Cumulative
value Reason for / Cumulative
Date of equity per Nature of Name of allottees along with the number of Paid-up equity
per Nature of Number if
allotment shares equity Consideration equity shares allotted to each allottee share capital
equity allotment equity shares
allotted share (₹)
share (₹)
(₹)
300. Pushpaben P. Shah 300
301. Nishant M. Shah 300
302. Suraj Ghelabhai Shah 300
303. Sangita Patel 300
304. Vaishali Shah 300
305. Bhavana Patel 300
306. Dhiren Narottamdas
300
Shah
307. Anal Naresh Shah 300
308. Naresh Kalyanbhai Shah 300
309. Dixitkumar
1,000
Dashrathbhai Patel
310. Sanjaykumar
1,000
Rameshbhai Patel
311. Mohamed Yusuf Memon 300
312. Rameshbhai N. Sojitra 300
313. Usmangani A. Memon 300
314. Abdurrehman A.
400
Memon
315. Gulammohamed A.
300
Memon
316. Sarabai Usmangani
300
Memon
317. Kanubhai M. Patel 300
318. Pushpa Shah 300
319. Bhupendra Shah 300
320. Arvind C. Choksi 300
321. Bhavesh Bhogilal Patel 300
322. Nilam Mahesh Patel 300
143Issue
Face
Number of Price Cumulative
value Reason for / Cumulative
Date of equity per Nature of Name of allottees along with the number of Paid-up equity
per Nature of Number if
allotment shares equity Consideration equity shares allotted to each allottee share capital
equity allotment equity shares
allotted share (₹)
share (₹)
(₹)
323. Upendra T. Prajapati
300
HUF
324. Meghnaben Kumarbhai
1,000
Mehta
325. Kumarbhai Pratapbhai
1,000
Mehta
326. Hansaben Mahendrabhai
1,000
Mehta
327. Mahendrabhai
1,000
Chandulal Mehta
328. Chintan Mahendrabhai
1,000
Mehta
329. Bunty Hundraj Devnani 1,000
330. Deepak Hundraj
1,000
Devnani
331. Hundraj Govindram
1,000
Devnani
332. Prashant Shankerprasad
300
Vyas
333. Chirag Amrutlal Patel 500
334. Hemang Amrutlal Patel 500
335. Amratbhai Harjivandas
500
Patel
336. Hasumatiben Amratlal
500
Patel
337. Amratbhai Harjivandas
500
Patel HUF
338. Lalit Shah 300
339. Raju Shah 300
340. Archana Parikh 600
341. Hitendra Patel 300
342. Rakesh Thaker 300
343. Devang C Mehta 300
144Issue
Face
Number of Price Cumulative
value Reason for / Cumulative
Date of equity per Nature of Name of allottees along with the number of Paid-up equity
per Nature of Number if
allotment shares equity Consideration equity shares allotted to each allottee share capital
equity allotment equity shares
allotted share (₹)
share (₹)
(₹)
344. Renukaben
300
Arvindkumar Patel
345. Kamlesh Kothari 300
346. Dipan Kothari 700
347. Nikunj Desai 300
348. Induben R. Patel 1,000
349. Narendra D. Patel 500
350. Mina N. Patel 600
351. Nilesh Kothari 300
352. Sanjay Kanhaiyalal
300
Kaushik
353. Tarun V. Sharma 500
354. Kalpesh Thaker 300
355. Bhikhalal H. Soni 300
356. Rajesh Rohra 500
357. Sushilaben
300
Narendrabhai Dani
358. Mukundbhai
6,000
Shambhubhai Patel
359. Prashant Ukabhai Patel 300
360. Bipin Vallabhbhai Patel 300
361. Nirav Dhansukhlal Shah 600
362. Nachiket Avinash Bhatt 300
363. Samir Dashrathbhai
300
Patel
364. Daxa Vallabhbhai Patel 300
365. Bipinchandra Popatlal
300
Patel
366. Bharti Dinesh Patel 300
367. Pravin Maneklal Patel 300
145Issue
Face
Number of Price Cumulative
value Reason for / Cumulative
Date of equity per Nature of Name of allottees along with the number of Paid-up equity
per Nature of Number if
allotment shares equity Consideration equity shares allotted to each allottee share capital
equity allotment equity shares
allotted share (₹)
share (₹)
(₹)
368. Sharadkumar Khodidas
300
Antala
369. Bhadreshkumar
300
Purushottambhai Patel
370. Nanubhai Popatbhai
300
Patel
371. Shamjibhai
500
Gangarambhai Vasoya
372. Babubhai Premjibhai
300
Sukhadiya
373. Jagdishkumar Gopalbhai
300
Rakholiya
374. Viral Rameshchandra
500
Bhatt
375. Kirankumar Patel 300
376. Sudhir Venkatesh
1,000
Kulkarni
377. Champaben G. Patel 500
378. Bhikhabhai Trikambhai
300
Patel
379. Nilay Ghanshyambhai
300
Pandya
380. Shamalbhai
300
Mulchandbhai Gajjar
381. Aatishkumar Dhirajlal
300
Chokshi
382. Sureshchandra
300
Chandulal Shah
383. Madhukarbhai
500
Kanjibhai Patel
384. Pramodbhai
300
Shambhubhai Patel
385. Kajal Sandip Vasani 300
386. Rajendra Chandulal
400
Shah
146Issue
Face
Number of Price Cumulative
value Reason for / Cumulative
Date of equity per Nature of Name of allottees along with the number of Paid-up equity
per Nature of Number if
allotment shares equity Consideration equity shares allotted to each allottee share capital
equity allotment equity shares
allotted share (₹)
share (₹)
(₹)
387. Daxa Mody 300
388. Bhumika Kapadia 300
389. Babiben N. Solanki 500
390. Prakash K. Shah 300
391. Urmil Anubhai Shah 300
392. Gitaben Hitendrabhai
300
Patel
393. Dayma Ashok Babulal 300
394. Pavankumar Kanodia 300
395. Chandubhai Haribhai
300
Patel
396. Sharad Bipinchandra
1,200
Patel
397. Mangtilal Chothemal
300
Gupta
398. Virenkumar Kanubhai
300
Patel
399. Dipika Nikul Patel 300
400. Darshan Aroon Shah 500
401. Jigar Modi 500
402. Vidyaben Modi 500
403. Vinodbhai Somabhai
300
Patel
404. Nilam Sanjaybhai Patel 300
405. Sanjay Vindobhai Patel 300
406. Mittal N. Patel 500
407. Visnuprasad Shivlal
300
Patel
408. Savitaben Natverbhai
500
Patel
409. Krishna Natubhai Patel 300
147Issue
Face
Number of Price Cumulative
value Reason for / Cumulative
Date of equity per Nature of Name of allottees along with the number of Paid-up equity
per Nature of Number if
allotment shares equity Consideration equity shares allotted to each allottee share capital
equity allotment equity shares
allotted share (₹)
share (₹)
(₹)
410. Natverlal Haribhai Patel 300
411. Chandrakant Dave 300
412. Jyotiben Dave 300
413. Divya Prakash Gera 300
414. Nirmala Upendra Savani 1,200
415. Dharmesh Odhavjibhai
1,100
Savani
416. Ramesh C. Shah 300
417. Kishanlal Ramchand
300
H.U.F
418. Manishkumar Kishanlal
300
H.U.F
419. Rita Kishanlal Shajwani 300
420. Bhumika Mahesh
300
Shajwani
421. Mahesh Kishanlal
300
Shajwani
422. Shrenik Mohanlal Shah
600
H.U.F
423. Sukesh Mohanlal Shah
600
H.U.F
424. Lalita Ashok Shah 600
425. Hemant Jayantilal Shah 1,000
426. Bhavana Dasharath
300
Shah
427. Ragini Modi 300
428. Narendra Chimanlal
300
Shah
429. Sanjay Mohanlal Shah
600
H.U.F
430. Tejaskumar
300
Nareshkumar Shah
148Issue
Face
Number of Price Cumulative
value Reason for / Cumulative
Date of equity per Nature of Name of allottees along with the number of Paid-up equity
per Nature of Number if
allotment shares equity Consideration equity shares allotted to each allottee share capital
equity allotment equity shares
allotted share (₹)
share (₹)
(₹)
431. Manisha B. Patel 300
432. Jyotsanaben S. Patel 300
433. Bharvi Patel 300
434. Manubhai Ambalal Patel 300
435. Govindbhai S. Patel 800
436. Kiritkumar Ramanlal
300
Patel
437. Sunitaben G. Patel 1,000
438. Kaushik Bhikhbhai
300
Patel
439. Ganpatbhai Ambalal
300
Patel
440. Alaknanda N. Patel 300
441. Komalben G. Patel 300
442. Prahaldbhai Patel 300
443. Priti Saurabh Shah 900
444. Naynaben Shah 300
445. Mukund Modi 300
446. Saurabh Modi 300
447. Tilottama Yewley 500
448. Naresh Hargovindbhai
300
Patel
449. Sonal Sanjay Shah 300
450. Truptiben Hiteshbhai
300
Shah
451. Siddharth Shantilal
300
Dikshit
452. Rupa Sunil Shah 300
453. Kaushal Kailaschandra
500
Dalal
149Issue
Face
Number of Price Cumulative
value Reason for / Cumulative
Date of equity per Nature of Name of allottees along with the number of Paid-up equity
per Nature of Number if
allotment shares equity Consideration equity shares allotted to each allottee share capital
equity allotment equity shares
allotted share (₹)
share (₹)
(₹)
454. Kajal Kaushal Dalal 500
455. Ashokbhai Prajapati 300
456. Seemaben Prajapati 300
457. Atulbhai Patel 300
458. Nayana Devendra Patel 300
459. Davendra Somabhai
300
Patel
460. Jimil Chokshi 300
461. Amrutbhai R. Chaudhari 500
462. Mauli Anal Dave 300
463. Rajesh Pahlajrai
300
Chellani HUF
464. Suman Rajesh Chellani 300
465. Bhavana Manoj Dalal 300
466. Manoj Ramchand Dalal
300
HUF
467. Ghanshyam I. Amin 300
468. Ramiben Amrutbhai
500
Chaudhari
469. Kaushikbhai Dahyabhai
300
Patel
470. Kamlesh Dahyabhai
300
Patel
471. Arvindbhai Dahyabhai
300
Patel
472. Pohapsingh Yadav 400
473. Khurshidbanu Parwala 400
474. Vinod Kirti Mehta 300
475. Jitendra Shantilal Shah 300
476. Budhalal Chimanlal
300
Kuvadia
150Issue
Face
Number of Price Cumulative
value Reason for / Cumulative
Date of equity per Nature of Name of allottees along with the number of Paid-up equity
per Nature of Number if
allotment shares equity Consideration equity shares allotted to each allottee share capital
equity allotment equity shares
allotted share (₹)
share (₹)
(₹)
477. Indiraben Jayantilal
300
Shah
478. Rupal Shah 300
479. Manjulaben Mehta 300
480. Vishal Jayantilal Shah 300
481. Hansaben Girjashankar
300
Raval
482. Anilkumar Popatlal
300
Raval
483. Gemarbhai M. Patel 300
484. Rajeshkumar Shankarlal
600
Shah
485. Kalpana Manish Mehta 300
486. Sanjay Sarabhai 500
487. Ajay Sarabhai 500
488. Avinash Gupte 300
489. Atash Shah 4,100
490. Sejal Ronakbhai Dalal 300
491. Anip Nikunjbhai Parikh 300
492. Shruti Agrawal 2,000
493. Hema J. Kamdar 10,000
494. Swati Binod Agarwal 1,000
495. Minesh Indravadan
300
Shah
496. Ajay Shah 300
497. Parikh Lisa Anip 500
498. Anip Nikunjbhai Parikh 500
499. Jawahar Gopichand
300
Kapoor
500. Anuj Jain HUF 500
151Issue
Face
Number of Price Cumulative
value Reason for / Cumulative
Date of equity per Nature of Name of allottees along with the number of Paid-up equity
per Nature of Number if
allotment shares equity Consideration equity shares allotted to each allottee share capital
equity allotment equity shares
allotted share (₹)
share (₹)
(₹)
501. Sanjay Bhimani 3,100
502. Rajesh R Punjabi 3,000
May 10, 2013 (7,31,600) 10 50 - Buy-back of shares Number 85,35,400 8,53,54,000
Sr. Name of allottee /
of equity
No. shareholder
shares
1. Surendra Popatlal Shah 600
2. Rashmika Shah 1,000
3. Kothari Kamlesh
600
Navinchandra
4. Dipal Rameshbhai Shah 1,200
5. Nalin Sumanitlal Shah 1,700
6. Rutvi Deepakkumar
700
Shah
7. Avanish Niranjan Patel 600
8. Darshan Bharatbhai
1,700
Patel
9. Bharat J. Patel 1,000
10. Priti Darshan Patel 300
11. Sanjay Sumatilal Shah 1,700
12. Tej J. Shah 5,000
13. Tej J. Shah 6,000
14. Pearl Broking Services
2,100
Limited
15. Vaishali Shah 600
16. Raksha J. Shah 1,000
17. Ranchhod N. Shah 1,000
18. Shamalbhai
600
Mulchandbhai Gajjar
19. Dipakbhai
1,200
Navinchandra Shah
20. Tej Jitendra Shah 1,19,200
152Issue
Face
Number of Price Cumulative
value Reason for / Cumulative
Date of equity per Nature of Name of allottees along with the number of Paid-up equity
per Nature of Number if
allotment shares equity Consideration equity shares allotted to each allottee share capital
equity allotment equity shares
allotted share (₹)
share (₹)
(₹)
21. Tej Jitendra Shah 19,200
22. Champaben G. Patel 1,000
23. Jwellin Shah 800
24. Prashant Shankerprasad
600
Vyas
25. Amratbhai Harjivandas
1,000
Patel HUF
26. Amratbhai Harjivandas
1,000
Patel
27. Chirag Amrutlal Patel 1,000
28. Hasumatiben Amratlal
1,000
Patel
29. Dayma Ashok Babulal 600
30. Nilam Sanjay Patel 600
31. Sanjay Vinodbhai Patel 600
32. Vinodbhai Somabhai
600
Patel
33. Kiritkumar Ramanlal
600
Patel
34. Krishna Natubhai Patel 600
35. Savitaben Natverbhai
1,000
Patel
36. Natverlal Haribhai Patel 600
37. Bhupendra Shah 600
38. Pushpa Shah 600
39. Mittal N. Patel 500
40. Hemang Amrutlal Patel 1,000
41. Ramiben Amrutlal Patel 1,000
42. Amrutbhai R. Chaudhari 1,000
43. Chintan Pankajkumar
600
Shah
153Issue
Face
Number of Price Cumulative
value Reason for / Cumulative
Date of equity per Nature of Name of allottees along with the number of Paid-up equity
per Nature of Number if
allotment shares equity Consideration equity shares allotted to each allottee share capital
equity allotment equity shares
allotted share (₹)
share (₹)
(₹)
44. Avni Shah 500
45. Nilay Bharatbhai
300
Contractor
46. Ramesh C. Shah 600
47. Pratapbhai C. Mehta 300
48. Chintan M. Mehta 1,000
49. Meghnaben Kumarbhai
1,700
Mehta
50. Kumarbhai Pratapbhai
1,700
Mehta
51. Hansaben Mahendra
1,700
Mehta
52. Mahendrabhai
1,700
Chandulal Mehta
53. Prakash L. Punjabi 1,000
54. Kaushalya S. Madhyani 1,000
55. Surendra Popatlal Shah 300
56. Mukesh Naranbhai
600
Kanodia
57. Shah Saurin
200
Pravinchandra
58. Mehulkumar D. Patel 200
59. Heta Kalpeshbhai Shah 200
60. Devendrakumar S.
200
Gandhi
61. Gaurang M. Shah 600
62. Kalpesh Shirish Jhaveri 200
63. Rashmika Umesh Shah 500
64. Leena Ravindra Shah 900
65. Kirit Ravindra Shah 100
66. Doshi Rekha Piyush 3,150
154Issue
Face
Number of Price Cumulative
value Reason for / Cumulative
Date of equity per Nature of Name of allottees along with the number of Paid-up equity
per Nature of Number if
allotment shares equity Consideration equity shares allotted to each allottee share capital
equity allotment equity shares
allotted share (₹)
share (₹)
(₹)
67. Doshi Piyush 3,150
68. Doshi Minal Piyush 1,050
69. Ujas Piyush Doshi 1,050
70. Kothari Kamlesh
300
Navinchandra
71. Rupang Bharatbhai
100
Shah
72. Jitendrakumar Dhirajlal
2,550
Saraiya HUF
73. Sanjay H. Mistry 300
74. Dharmesh Rasiklal Shah 900
75. Ushaben Saraiya 450
76. Dipal Rameshbhai Shah 600
77. Surekha Suketu Javeri 900
78. Kaushal
1,500
Kaislashchandra Dalal
79. Kajal Kaushal Dalal 1,500
80. Nalin Sumantilal Shah 850
81. Rutvi Deepakbhai Shah 350
82. Deepak Shah 1,950
83. Darshan Aroon Shah 1,500
84. Rupalben Sanjaykumar
450
Shah
85. Sanjay Sumtilal Shah 850
86. Shah Akash Nalinkumar 1,500
87. Shah Aman Nalinkumar 450
88. Shah Sonalben
900
Dipakbhai
89. Dr. Kirit Kantilal Shah 3,000
90. Shah Vaishali Viralbhai 300
155Issue
Face
Number of Price Cumulative
value Reason for / Cumulative
Date of equity per Nature of Name of allottees along with the number of Paid-up equity
per Nature of Number if
allotment shares equity Consideration equity shares allotted to each allottee share capital
equity allotment equity shares
allotted share (₹)
share (₹)
(₹)
91. Dr. Nirupama Kirit Shah 1,000
92. Arunaben Shamalbhai
300
Patel
93. Pohapsingh Yadav 1,200
94. Sanjay Mehta 600
95. Dipakbhai
600
Navinchandra Shah
96. Suman Rajesh Chellani 900
97. Rajesh P. Chellani HUF 900
98. Bhavini R. Shah 2,400
99. Raju Shankerbhai
600
Thakor
100. Jignesh Navinchandra
1,000
Shukla
101. Pritesh Gautam Shah 150
102. Bhumika Vatsal Shah 100
103. Jwellin Shah 400
104. Manju Prashant Vyas 250
105. Patel Amrutlal
1,000
Harjivandas
106. Chirag Amrutlal Patel 500
107. Hasumatiben Amratlal
500
Patel
108. Dayma Ashok Babulal 300
109. Patel Nilamben S. 300
110. Patel Sanjaybhai V. 300
111. Vinodbhai Somabhai
300
Patel
112. Hemant Udaykumar
400
Roy
156Issue
Face
Number of Price Cumulative
value Reason for / Cumulative
Date of equity per Nature of Name of allottees along with the number of Paid-up equity
per Nature of Number if
allotment shares equity Consideration equity shares allotted to each allottee share capital
equity allotment equity shares
allotted share (₹)
share (₹)
(₹)
113. Nilay Ghanshyambhai
900
Pandya
114. Patel Kiritkumar R. 300
115. Jaldevsingh S.
400
Chundawat
116. Samir Rajendra Shah 500
117. Bhupendra Hemchand
600
Shah
118. Hemag Patel 500
119. Shah Ritesh
200
Pankajkumar
120. Ankit P. Shah 200
121. Viral Babubhai Shah 200
122. Rima Dhirajlal Patel 400
123. Jayesh Jitendrabhai
400
Pittaliya
124. Rekha Dipak Vora 400
125. Nirav Ramanlal Patel 150
126. Pravinkumar M. Patel 900
127. Maulikaben Nileshbhai
600
Gandhi
128. Bharat Mohanlal Shah 10,000
129. Hasmukhlal Amrutlal
200
Belani
130. Pittaliya Hardik
200
Kiritbhai
131. Bhavi Shalin Shah 300
132. Bhavini R. Shah 400
133. Suleman Sadruddin
900
Khoja
134. Desai Sarojben
1,800
Chandrakant
157Issue
Face
Number of Price Cumulative
value Reason for / Cumulative
Date of equity per Nature of Name of allottees along with the number of Paid-up equity
per Nature of Number if
allotment shares equity Consideration equity shares allotted to each allottee share capital
equity allotment equity shares
allotted share (₹)
share (₹)
(₹)
135. Desai Chetna V. 1,500
136. Shah Chintan
300
Pankajkumar
137. Trupti Utpal Shah 1,50,000
138. Shah Shaivi Rohitbhai 200
139. Nilay Bharatbhai
300
Contractor
140. Neha Tarun Patel 800
141. Jayshree Utkal Patel 800
142. Pravinchandra A. Shah 900
143. Jawahar Kapoor 900
144. Shah Deval Minalkumar 150
145. Sonal Bharadwaj Bhatt 200
146. Manisha Pinalkumar
100
Modi
147. Dipika Jayeshkumar
900
Shah
148. Jayesh Indravadan Shah 900
149. Indravadan Shankarlal
900
Shah
150. Ramesh Sorathia 900
151. Nilesh Girishbhai Modi 600
152. Preeti Tej Shah 2,00,000
153. Bhadresh H. Punjabi 600
154. Janki Krutin Shah 150
155. Sagar Rajesh Punjabi 1,00,000
156. Ansuyaben P. Mehta 900
157. Pratap C. Mehta 150
158. Chintan M. Mehta 1,550
158Issue
Face
Number of Price Cumulative
value Reason for / Cumulative
Date of equity per Nature of Name of allottees along with the number of Paid-up equity
per Nature of Number if
allotment shares equity Consideration equity shares allotted to each allottee share capital
equity allotment equity shares
allotted share (₹)
share (₹)
(₹)
159. Meghnaben Mehta 850
160. Chandra Choithram
900
Vanvari
161. Indumati Vanvari 900
162. Vishal Jayantilal Shah 900
163. Prahladbhai R. Patel 900
November 21, 85,35,400 10 N.A. N.A. Bonus issue in the Number 1,70,70,800 17,07,08,000
Sr. Name of allottee /
2017 ratio 1:1 (one for of equity
No. shareholder
every one Equity shares
Share held) 1. Aashit Jitendrabhai
900
Jhaveri
2. Aashna Utpal Shah 1,10,000
3. Abdur Rehman A.
Menon &
1,200
Gulammohamed A.
Menon*
4. Ajaykumar N Chaudhari 2,000
5. Akshaya Shah 10,000
6. Amit Ashokbhai Parikh 3,000
7. Amita Kaushik Patel &
Kaushikkumar Ramanlal 300
Patel*
8. Amrut Ramanlal
1,000
Chaudhari
9. Anand A. Dalal 1,500
10. Anil Baldevbhai Patel 1,050
11. Anila Rameshchandra
Patel & Rameshchandra 40,000
Motibhai Patel*
12. Anitaben Sanjaykumar
450
Patel
13. Anuradha & Rajiv* 900
159Issue
Face
Number of Price Cumulative
value Reason for / Cumulative
Date of equity per Nature of Name of allottees along with the number of Paid-up equity
per Nature of Number if
allotment shares equity Consideration equity shares allotted to each allottee share capital
equity allotment equity shares
allotted share (₹)
share (₹)
(₹)
14. Arunaben Jitendrakumar
400
Desai
15. Arunakumar Babulal
350
Vyas
16. Arvind Maneklal Patel
750
& Renuka Arvind Patel*
17. Ashokkumar Bapulal
Shah & Purnima 900
Ashokkumar Shah*
18. Ashvin Chinubhai Dalal 600
19. Atul Chandrakant Shah 600
20. Atulbhai Chandrakant
300
Shah
21. Atulkumar
600
Vinodchandra Shah
22. Bachubhai Jesingbhai
2,000
Parikh
23. Baiju Manubhai Patel &
400
Kinal Baijubhai Patel*
24. Bhadraben Bachubhai
2,000
Parikh
25. Bhanuben Natverlal
900
Shah
26. Bharat Mohanlal Shah 10,000
27. Bharat Natverlal Shah 900
28. Bharat Jayantilal Patel 300
29. Bharat Pravinchandra
Daftary & Nayana 300
Bharat Daftary*
30. Bharatbhai Gopani 900
31. Bharati Suresh Shah 300
32. Bharatkumar I. Patel 400
160Issue
Face
Number of Price Cumulative
value Reason for / Cumulative
Date of equity per Nature of Name of allottees along with the number of Paid-up equity
per Nature of Number if
allotment shares equity Consideration equity shares allotted to each allottee share capital
equity allotment equity shares
allotted share (₹)
share (₹)
(₹)
33. Bharatkumar Vallabhdas
600
Daftary
34. Bharti Shah & Parag
2,000
Shah*
35. Bhavesh Jitendrakumar
800
Desai
36. Bhavi Shalin Shah &
Shah Hansaben 100
Anilkumar*
37. Bhavin Shaileshbhai
200
Shah
38. Bhavini R. Shah 200
39. Bhavna Piyushkumar
400
Dani
40. Bhavna Sanjay Patel &
900
Sanjay H. Patel*
41. Bhikhabhai T. Patel 600
42. Bhikhalal Hajarimal
900
Soni
43. Bhumika Vatsal Shah 100
44. Bhumika Mahesh
900
Shajwani
45. Bhumika Viral Kapadia 300
46. Bijal Rakeshbhai Doshi 900
47. Bina Kalpeshkumar
900
Shah
48. Bindu R. Patel & Rajiv
1,800
N. Patel*
49. Bipinchandra Popatlal
900
Patel
50. Bunty Hundraj 9,000
51. Chandraben Madhubhai
2,000
Parmar
161Issue
Face
Number of Price Cumulative
value Reason for / Cumulative
Date of equity per Nature of Name of allottees along with the number of Paid-up equity
per Nature of Number if
allotment shares equity Consideration equity shares allotted to each allottee share capital
equity allotment equity shares
allotted share (₹)
share (₹)
(₹)
52. Chandrakant Purshottam
Dave & Jyotiben 900
Chandrakant Dave*
53. Chandrikaben B. Patel 450
54. Chandubhai Haribhai
900
Patel
55. Chetnaben Arvindbhai
900
Patel
56. Chintan S. Parikh 900
57. Chirag Vinodchandra
600
Shah
58. Choksi Jyotika
200
Harivadan
59. Darshan B. Patel 850
60. Dave Dhruva Hardik &
Dave Hardikkumar 1,000
Harvadan*
61. Davendra Somabhai
900
Patel
62. Daxa Vallabhbhai Patel 900
63. Deepak Shah & Sonal
10,000
Shah*
64. Desai Vipul C. 2,300
65. Devang Navinchandra
1,200
Gandhi
66. Dhaval B. Patel &
1,000
Babubhai A. Patel*
67. Dilipbhai R. Patel 300
68. Dinesh Buddhibhai
Shah & Jayshree Dinesh 2,100
Shah*
69. Dipak Babubhai Vora &
200
Rekha Dipak Vora*
162Issue
Face
Number of Price Cumulative
value Reason for / Cumulative
Date of equity per Nature of Name of allottees along with the number of Paid-up equity
per Nature of Number if
allotment shares equity Consideration equity shares allotted to each allottee share capital
equity allotment equity shares
allotted share (₹)
share (₹)
(₹)
70. Dipika Nikul Patel &
600
Nikul Jitendra Patel*
71. Dipika Nikul Patel 300
72. Divya Prakash Gera 600
73. Divyesh Babulal Shah 450
74. Doctor Shachish Piyush 300
75. Dr. Kirit Kantilal Shah
& Dr. Nirupama Kirit 5,000
Shah*
76. Dr. Nirupama Kirit Shah
& Dr. Kirit Kantilal 6,000
Shah*
77. Gandhi Sushmaben
900
Mahesh
78. Gangarambhai
500
Tribhovandas Patel
79. Gemarbhai Muljibhai
900
Patel
80. Ghanshyambhai P. Patel 1,500
81. Girish Hasmukhlal
900
Kotak
82. Gita Girish Kotak 900
83. Gita Hitendrabhai Patel 900
84. Gita B. Patel 500
85. Gopal Natverlal Shah 900
86. Govind Rukmanbhai
900
Nama
87. Gulam Mohmed A.
Memon & Usmangani 900
A. Memon*
88. Hansa Niranjanbhai
300
Patel
163Issue
Face
Number of Price Cumulative
value Reason for / Cumulative
Date of equity per Nature of Name of allottees along with the number of Paid-up equity
per Nature of Number if
allotment shares equity Consideration equity shares allotted to each allottee share capital
equity allotment equity shares
allotted share (₹)
share (₹)
(₹)
89. Hansaben
450
Narendrakumar Joshi
90. Hansaben Ghanshayam
900
Khatri
91. Hansaben M. Mehta &
850
Mahendra C. Mehta*
92. Harish Patel 600
93. Harsha Lalbhai Shah 200
94. Harshad Babulal Vyas 2,400
95. Harshadbhai Bhogilal
10,000
Bhimani
96. Hemant Udaykumar
200
Roy
97. Hetal Jayesh Shah 6,000
98. Hinaben Dineshkumar
900
Shah
99. Hiral Janak Joshi 3,000
100. Hitendra Natvarlal Patel 900
101. Hitesh Chandrakant
600
Patel
102. Hitesh Vitthalbhai Patel
900
& Parul Hitesh Patel*
103. Inaxi Nareshbhai Shah 900
104. Induben Dineshbhai
600
Bhavsar
105. Jagruti Pravin Master &
900
Pravin Devidas Master*
106. Janki Krutin Shah 50
107. Jasica Mehta 900
108. Jayantibhai Bhikhabhai
2,550
Patel
109. Jayesh Jitendrabhai
200
Pittaliya
164Issue
Face
Number of Price Cumulative
value Reason for / Cumulative
Date of equity per Nature of Name of allottees along with the number of Paid-up equity
per Nature of Number if
allotment shares equity Consideration equity shares allotted to each allottee share capital
equity allotment equity shares
allotted share (₹)
share (₹)
(₹)
110. Jayesh Girish Shah 5,000
111. Jayshree P. Kotak 900
112. Jayshree Utkal Patel 100
113. Jigna Tejash Dave 1,800
114. Jignesh A. Maniar &
1,200
Ashwin T. Maniar*
115. Jignesh Navinchandra
1,600
Shukla
116. Jinal Shah & Arpita
600
Shah*
117. Jitendra Chandulal Modi 900
118. Jitendrakumar Dhirajlal
4,000
Saraiya
119. Jyotiben Chandrakant
Dave & Chandrakant 900
Purshottam Dave*
120. Jyotsana Rajendra Shah 1,800
121. Kaivan R. Shah 600
122. Kajal Ramesh Shah 200
123. Kalpanaben Manishbhai
900
Mehta
124. Kamleshbhai Dahyabhai
Patel & Ragini 900
Kamleshbhai Patel*
125. Kanan Sanjaybhai Dalal
& Sanjay Sarabhai 1,000
Dalal*
126. Kanchan Nareshbhai
2,550
Patel
127. Kanta Shyamlal Rohra 150
128. Kanubhai Natvarlal
600
Prajapati
165Issue
Face
Number of Price Cumulative
value Reason for / Cumulative
Date of equity per Nature of Name of allottees along with the number of Paid-up equity
per Nature of Number if
allotment shares equity Consideration equity shares allotted to each allottee share capital
equity allotment equity shares
allotted share (₹)
share (₹)
(₹)
129. Kaushik Bhikhabhai
600
Patel
130. Kaushikbhai Dahyabhai
Patel & Parulben 900
Kaushikbhai Patel*
131. Kaushikkumar Ramanlal
Patel & Amita 300
Kaushikkumar Patel*
132. Kenisha Shah 1,20,600
133. Ketan Tejpal Parikh 1,200
134. Khurshid Banu Parwala
1,200
& Parvez Parwala*
135. Kinjal Paresh Jansari 600
136. Kirankumar Ambalal
300
Patel
137. Kirit Kanjibhai Macwan 100
138. Kirit M. Patel & Vina K.
150
Patel*
139. Kishanlal Ramchand
900
Shajwani
140. Kotak Rajesh Maneklal 900
141. Kotak Rekhaben
1,800
Rajeshkumar
142. Kothari Dipan
700
Chandreshkumar
143. Krina Amit Parikh 2,100
144. Krishnajivan Bhikhalal
2,000
Mehta
145. Kundan Rameshbhai
1,500
Gandhi
146. Kundan Vallabhbhai
900
Patel
147. Lalita Ashok Shah 1,800
166Issue
Face
Number of Price Cumulative
value Reason for / Cumulative
Date of equity per Nature of Name of allottees along with the number of Paid-up equity
per Nature of Number if
allotment shares equity Consideration equity shares allotted to each allottee share capital
equity allotment equity shares
allotted share (₹)
share (₹)
(₹)
148. Luv Vikram Kothari 1,500
149. Mahendrabhai
Chandulal Mehta & 850
Hansaben M. Mehta*
150. Mahesh Ramanlal
900
Gandhi
151. Mahesh Kishanlal
900
Shajwani
152. Malti Ashokbhai Parikh 2,100
153. Manish Kishanlal
900
Shajwani
154. Manish Babulal
850
Vaghasia
155. Manish D. Kansara 600
156. Manju Prashant Vyas &
Prashant Shankerprasad 50
Vyas*
157. Manjula K. Vyas 600
158. Maulik Rameshchandra
Patel & Rameshchandra 20,000
Motibhai Patel*
159. Modi Manisha
100
Pinalkumar
160. Modi Jigar Hiralal &
Modi Vidhyaben 1,500
Mulchanddas*
161. Modi Vidhyaben
Mulchanddas & Modi 1,500
Jigar Hiralal*
162. Mohamedyusuf Memon
& Mohamedjuned 900
Memon*
163. Monali Biren Shah 1,200
164. Nachiket Avinash Bhatt 900
167Issue
Face
Number of Price Cumulative
value Reason for / Cumulative
Date of equity per Nature of Name of allottees along with the number of Paid-up equity
per Nature of Number if
allotment shares equity Consideration equity shares allotted to each allottee share capital
equity allotment equity shares
allotted share (₹)
share (₹)
(₹)
165. Nagori Kishori
1,000
Krishnachandra
166. Nalin Sumatilal Shah 6,000
167. Nanubhai Popatbhai
600
Patel
168. Naranlal Maneklal Patel
& Vimlagauri Naranlal 750
Patel*
169. Narendrakumar
2,550
Ramanlal Joshi
170. Naresh Hargovindbhai
900
Patel
171. Natverlal Shankerlal
900
Shah
172. Naveen Kejriwal 250
173. Navinchandra V. Shah &
1000
Manjula N. Shah*
174. Nayna Devendra Patel 900
175. Neeta Dipak Patel &
900
Dipak Ramanlal Patel*
176. Neha Tarun Patel 100
177. Nikita Bharatbhai
200
Choksi
178. Nilesh Girishbhai Modi
& Palak Nileshbhai 2,000
Modi*
179. Nilima Yogeshchandra
Manohar Neve &
1,500
Yogeshchandra Manohar
Neve*
180. Nirav Ramanlal Patel &
Urmilaben Kalidas 250
Patel*
181. Nirmala U. Savani 2,850
168Issue
Face
Number of Price Cumulative
value Reason for / Cumulative
Date of equity per Nature of Name of allottees along with the number of Paid-up equity
per Nature of Number if
allotment shares equity Consideration equity shares allotted to each allottee share capital
equity allotment equity shares
allotted share (₹)
share (₹)
(₹)
182. Nishant M. Shah 600
183. Nishant M. Shah 300
184. Nishith Shah 900
185. Pankajkumar
1,000
Jitendrakumar Patel
186. Parikh Heeta Brijal 1,000
187. Parth Jitendra Patel 1,000
188. Patel Alpa Bhaveshbhai 1,000
189. Patel Bhadresh P. 300
190. Patel Dashrathbhai H. 450
191. Patel Dixitkumar
2,550
Dashrathbhai
192. Patel Hansaben P. 600
193. Patel Jankiben
450
Dharmendrakumar
194. Patel Kanubhai
450
Hargovindas
195. Patel Nikita Nareshbhai 450
196. Patel Rajeshkumar
1,000
Kevaldas
197. Patel Sanjaykumar
2,550
Rameshbhai
198. Pathik Atul Shah 300
199. Pathik Atulbhai Shah 600
200. Pearl Shah 1,20,000
201. Piyushkumar
600
Krishnachandra Dani
202. Poornima Ashokkumar
Shah & Ashokkumar 900
Bapulal Shah*
203. Pradip Ashwinkumar
200
Roy
169Issue
Face
Number of Price Cumulative
value Reason for / Cumulative
Date of equity per Nature of Name of allottees along with the number of Paid-up equity
per Nature of Number if
allotment shares equity Consideration equity shares allotted to each allottee share capital
equity allotment equity shares
allotted share (₹)
share (₹)
(₹)
204. Praful K. Shah & Gauri
1,200
P. Shah*
205. Prahash Fin-Stock PVT
3,000
LTD
206. Prakash Hasmukhlal
900
Kotak
207. Prashant Ukabhai Patel 900
208. Pratik Rameshchandra
Patel & Rameshchandra 20,000
Motibhai Patel*
209. Preeti Upendra Shah 2,80,900
210. Premilaben Anilkumar
900
Chauhan
211. Pritesh Gautam Shah &
50
Jagruti Pritesh Shah*
212. Priti Darshan Patel &
Darshan Bharatbhai 150
Patel*
213. Priti Upendra Shah &
3,22,000
Purnima Upendra Shah*
214. Pritiben Dixitkumar
450
Patel
215. Purnima Upendra Shah
& Upendra Trikamlal 20,04,800
Shah*
216. Purvi Hitesh Patel &
Hitesh Chandrakant 4,000
Patel*
217. Rajendra Chandulal
1,200
Shah
218. Rajesh Kishanchand
500
Rohra
219. Rajesh Ramchandra
Punjabi & Sandhya 5,700
Rajesh Punjabi*
170Issue
Face
Number of Price Cumulative
value Reason for / Cumulative
Date of equity per Nature of Name of allottees along with the number of Paid-up equity
per Nature of Number if
allotment shares equity Consideration equity shares allotted to each allottee share capital
equity allotment equity shares
allotted share (₹)
share (₹)
(₹)
220. Rajesh Kanitlal Patel 900
221. Rajesh Ramchand
4,47,200
Punjabi
222. Rajiv Bhavsar &
900
Anuradha Bhavsar*
223. Rajiv N. Patel 1,650
224. Rajiv N. Patel & Bindu
2,550
R. Patel*
225. Rajiv Tejpal Parikh 900
226. Ramesh C. Shah &
300
Shobhna R. Shah*
227. Rameshchandra
Motibhai Patel & Anila 40,000
Rameshchandra Patel*
228. Ranjan Narendra Patwa 900
229. Rashmiben P. Gujjar &
900
Pravinbhai M. Gujjar*
230. Rasiklal Manchandbhai
675
Doshi
231. Rehaan Utpal Shah 1,10,000
232. Renish Rajendrakumar
900
Shah
233. Renukaben
900
Arvindkumar Patel
234. Riddhiben Shreyansbhai
1,050
Doshi
235. Ritadevi Kishanlal
900
Shajwani
236. Roopa Monojkumar
Shah & Manojkumar L. 1,500
Shah*
237. Ruchira T. Shah 1,71,000
238. Ruchira Tanmay Shah &
30,600
Tanmay Upendra Shah*
171Issue
Face
Number of Price Cumulative
value Reason for / Cumulative
Date of equity per Nature of Name of allottees along with the number of Paid-up equity
per Nature of Number if
allotment shares equity Consideration equity shares allotted to each allottee share capital
equity allotment equity shares
allotted share (₹)
share (₹)
(₹)
239. Rupa Sunil Shah 600
240. Rupang Bharatbhai
300
Shah
241. Sagar Rajesh Punjabi 24,850
242. Sameer M Chiplunkar 200
243. Samir Rajendra Shah &
Jyotsana Rajendra 100
Shah*
244. Sandhya Rajesh Punjabi
& Rajesh Ramchandra 1,65,800
Punjabi*
245. Sangeeta Manishbhai
150
Vaghasia
246. Sanjay Hargovindbhai
300
Mistry
247. Sanjaybhai Sumtilal
4,000
Shah
248. Sarabai Usmangani
Memon & Usmangani 1,800
A. Memon*
249. Shah Alap Sudhirbhai 200
250. Shah Deval Milankumar 50
251. Shah Kamlesh
900
Jayantibhai
252. Shah Kaushali
200
Pankajkumar
253. Shah Minesh I. & Shah
900
Nila M. *
254. Shah Monali 2,550
255. Shah Sanjay Mohanlal 1,800
256. Shah Shrenik Mohanlal 1,800
257. Shah Sonalben
12,000
Dipakbhai
172Issue
Face
Number of Price Cumulative
value Reason for / Cumulative
Date of equity per Nature of Name of allottees along with the number of Paid-up equity
per Nature of Number if
allotment shares equity Consideration equity shares allotted to each allottee share capital
equity allotment equity shares
allotted share (₹)
share (₹)
(₹)
258. Shah Sukeshkumar
1,800
Mohanlal
259. Shah Vatsal Sudhirbhai 400
260. Shah Prakash
Kacharabhai & Shah 900
Sujay Prakash*
261. Shah Srujal
Nipamkumar & Pratibha 900
Shah*
262. Shailesh P. Shah 300
263. Shantiben N. Patel &
3,000
Rajiv N. Patel*
264. Sharad Bipinbhai Patel 3,600
265. Shardaben A. Shah &
Jaydip Arvindbhai 600
Shah*
266. Sheela Ajaybhai Dalal &
1,000
Ajay Sarabhai Dalal*
267. Sheelaben D. Patel 300
268. Sheetal Vyas 3,150
269. Shehjad Alam
600
Naziralam Shaikh
270. Shital Bihagbhai Angreji 900
271. Shobhan S. Parikh 300
272. Shobhna Janakkumar
900
Babaria
273. Shreyans Rasiklal Doshi 3,375
274. Shruti Rajesh Punjabi 1,04,800
275. Shweta Bhavin Kathiara 900
276. Shyamlal Thakurdas
850
Rohra
277. Sonal Rajiv Parikh 900
173Issue
Face
Number of Price Cumulative
value Reason for / Cumulative
Date of equity per Nature of Name of allottees along with the number of Paid-up equity
per Nature of Number if
allotment shares equity Consideration equity shares allotted to each allottee share capital
equity allotment equity shares
allotted share (₹)
share (₹)
(₹)
278. Soni Chandraeshkumar
900
Rasiklal
279. Soni Dilipkumar
900
Rasiklal
280. Sudha Kamlesh Modi 900
281. Sudhir Venkatesh
Kulkarni & Pushpa 1,000
Sudhir Kulkarni*
282. Sunny Amit Shah 300
283. Suresh Maneklal Shah
900
& Ramila Suresh Shah*
284. Swati Agrawal 1,000
285. Tanmay Upendra Shah
& Purnima Upendra 5,75,900
Shah*
286. Tanmay U. Shah 5,300
287. Tapan Dineshbhai Shah 900
288. Tejas Nareshkumar Shah 300
289. Trupti Utpal Shah 2,32,300
290. Upendra Odhavjibhai
750
Savani
291. Upendra T. Shah &
28,75,900
Purnima U. Shah*
292. Upendra Trikamlal Shah 1,16,400
293. Upendra Trikamlal Shah 1,00,000
294. Urmil Anubhai Shah 600
295. Utpal P. Shah 1,400
296. Utpal Praful Shah &
65,950
Trupti Utpal Shah*
297. Varshaben G. Gadani 1,000
298. Vasani Kajal Sandip 900
174Issue
Face
Number of Price Cumulative
value Reason for / Cumulative
Date of equity per Nature of Name of allottees along with the number of Paid-up equity
per Nature of Number if
allotment shares equity Consideration equity shares allotted to each allottee share capital
equity allotment equity shares
allotted share (₹)
share (₹)
(₹)
299. Vidhyaben Jayantibhai
450
Patel
300. Vidhyut Shah 2,000
301. Vimlaben Vitthalbhai
1,000
Patel
302. Vishal Dipakkumar
600
Parikh
303. Vishnuprasad Shivlal
900
Patel
304. Vitthalbhai Haribhai
1,000
Patel
305. Yogeshchandra Manohar
Neve & Nilima 300
Yogeshchandra Neve*
306. Avni Shah & Ashit
500
Shah*
307. Girish Shah & Lata
1,000
Shah*
308. Jitendrakumar
1,000
Amichand Patel
309. Ramjibhai M. Patel 1,200
310. Shah Kunal Satishbhai
Shah & Satishbhai 1,000
Bharatbhai Shah*
311. Vinodiniben Sureshbhai
Shah & Sureshbhai 1,000
Gokaldas Shah*
312. Lata Shah & Girish
1,000
Shah*
313. Lilavatiben Patel &
500
Pravin Patel*
314. Manisha Paresh Patel 1,000
315. Manish Babulal
1,700
Vaghasia
316. Alpa Bhaveshbhai Patel 2,000
175Issue
Face
Number of Price Cumulative
value Reason for / Cumulative
Date of equity per Nature of Name of allottees along with the number of Paid-up equity
per Nature of Number if
allotment shares equity Consideration equity shares allotted to each allottee share capital
equity allotment equity shares
allotted share (₹)
share (₹)
(₹)
317. Muskeshbhai
600
Govindbhai Patel
318. Vimal Dairy Limited 1,200
319. Nilay Bharatkumar
300
Contractor
320. Dinesh H. Pande &
600
Santosh Dinesh Pande*
321. Dipesh Sunilbhai Mehta 600
322. Yogesh Dilipbhai Patel 600
323. Paresh Mahendrakumar
600
Patel
324. Kiritkumar Modi 600
325. Amitbhai Popatlal Shah 600
326. Anjali Hiteshbhai Shah 600
327. Jignesh Maniar &
600
Shivani Maniar*
328. Piyush J. Vakil 600
329. Piyushkumar
Krishnachandra Dani &
1,200
Bhavana Piyushkumar
Dani*
330. Bhavana Piyushkumar
Dani & Piyushkumar 800
Krishnachandra Dani*
331. Sunil Prahladbhai
2,000
Sevani
332. Kiranben Sunilbhai
2,000
Sevani
333. Mrunalini Patel 600
334. Rajesh Patel 300
335. Navinchandra V. Shah &
500
Manjulaben N. Shah*
176Issue
Face
Number of Price Cumulative
value Reason for / Cumulative
Date of equity per Nature of Name of allottees along with the number of Paid-up equity
per Nature of Number if
allotment shares equity Consideration equity shares allotted to each allottee share capital
equity allotment equity shares
allotted share (₹)
share (₹)
(₹)
336. Kaushikkumar Ramanlal
Patel & Amita 600
Kaushikkumar Patel*
337. Amita Kaushik &
Kaushikkumar Ramanlal 600
Patel*
338. Shobhan S. Parikh 600
339. Khodidas Prabhudas
600
Barot
340. Chander Murjani 2,000
341. Shyamlal T. Rohra 1,700
342. Dilipbhai R. Patel 600
343. Sheelaben D. Patel 600
344. Kanubhai M. Patel 600
345. Bhavesh Bhogilal Patel
600
& Hina Bhavesh Patel*
346. Nilam Mahesh Patel &
600
Mahesh Bhogilal Patel*
347. Renuben Manojbhai
2,000
Chhabadiya
348. Dipan Kothari 1,400
349. Rajesh Rohra 1,000
350. Sushilaben
600
Narendrabhai Dani
351. Bipin Vallabhbhai Patel 600
352. Nirav Dhansukhlal Shah 1,200
353. Samir Dashrathbhai
600
Patel
354. Bharti Dinesh Patel &
600
Dinesh Tulsidas Patel*
355. Sharadkumar Khodidas
600
Antala
177Issue
Face
Number of Price Cumulative
value Reason for / Cumulative
Date of equity per Nature of Name of allottees along with the number of Paid-up equity
per Nature of Number if
allotment shares equity Consideration equity shares allotted to each allottee share capital
equity allotment equity shares
allotted share (₹)
share (₹)
(₹)
356. Shamjibhai
1,000
Gangarambhai Vasova
357. Babubhai Premjibhai
600
Sukhadiya
358. Jagdishkumar Gopalbhai
600
Rakholiya
359. Kirankumar Patel &
600
Jyotsana Patel*
360. Sudhir Venkatesh
Kulkarni & Pushpa 2,000
Sudhir Kulkarni*
361. Bhumika Kapadia 600
362. Mittal N. Patel 500
363. Dharmesh Odhavjibhai
1,800
Savani
364. Jyotsanaben S. Patel 600
365. Truptiben Hiteshbhai
600
Shah
366. Arvindbhai Dahyabhai
Patel & Renukaben 600
Arvindbhai Patel*
367. Vinod Kirti Mehta 600
368. Sheela Ajay Dalal &
500
Ajay Sarabhai Dalal*
369. Kanan Sanjay Dalal &
500
Sanjay Sarabhai*
370. Shruti Agrawal 3,300
371. Hema J Kamdar 10,000
372. Swati Binod Agarwal 1,700
373. Ajay Shah 600
374. Anuj Jain 1,000
375. Ashvin Chinubhai Dalal 300
178Issue
Face
Number of Price Cumulative
value Reason for / Cumulative
Date of equity per Nature of Name of allottees along with the number of Paid-up equity
per Nature of Number if
allotment shares equity Consideration equity shares allotted to each allottee share capital
equity allotment equity shares
allotted share (₹)
share (₹)
(₹)
376. Harish Patel 300
377. Dharmesh K. Patel HUF 400
378. Varshaben G. Gadani 500
379. Naveen Kejriwal 500
380. Dhruva Hardikkumar
100
Dave
381. Sangeeta Manishbhai
300
Vaghasia
382. Kanta Shyamlal Rohra 300
383. Madhu Agrawal 300
384. Bhaveshkumar
400
Odhavjibhai Savani
385. Arunkumar Babulal
700
Vyas HUF
February 17, (13,16,800) 10 55 - Buy-back of shares Number 1,57,54,000 15,75,40,000
Sr. Name of allottee /
2021 of equity
No. shareholder
shares
1. Purnima Upendra Shah 2,09,600
2. Upendra Trikamlal Shah 2,01,800
3. Tanmay Upendra Shah
11,200
HUF
4. Ruchira Tanmay Shah 61,200
5. Tapan Dineshbhai Shah 1,800
6. Hinaben Dineshkumar
1,800
Shah
7. Bhanuben Natverlal
3,600
Shah
8. Bharat Natverlal Shah 1,800
9. Gopal Natverlal Shah 1,800
10. Tanmay Upendra Shah 1,46,800
11. Ruchira T. Shah 1,62,000
179Issue
Face
Number of Price Cumulative
value Reason for / Cumulative
Date of equity per Nature of Name of allottees along with the number of Paid-up equity
per Nature of Number if
allotment shares equity Consideration equity shares allotted to each allottee share capital
equity allotment equity shares
allotted share (₹)
share (₹)
(₹)
12. Preeti Upendra Shah 93,800
13. Nachiket Avinash Bhatt 900
14. Shah Sonalben
7,000
Dipakbhai
15. Utpal Prafulbhai Shah 15,700
16. Bharat Mohanlal Shah 10,000
17. Rajesh Ramchand
48,000
Punjabi
18. Shruti Rajesh Punjabi 9,600
19. Hansaben M. Mehta 1,700
20. Anuradha Rajiv Bhavsar 1,800
21. Rajesh R. Punjabi 11,400
22. Jasica Mehta 1,800
23. Mahendrabhai
1,700
Chandulal Mehta
24. Trupti Utpal Shah 14,600
25. Nachiket Avinash Bhatt 900
26. Sandhya Rajesh Punjabi 81,600
27. Upendra Trikamlal Shah
1,00,300
HUF
28. Asha Nitin Parikh 6,600
29. Nilesh Girishbhai Modi 1,200
30. Suresh Maneklal Shah 1,800
31. Naresh Hargovindbhai
1,800
Patel
32. Kaushik Bhikhabhai
1,800
Patel
33. Darshan B. Patel 1,700
34. Priti Darshan Patel 300
180Issue
Face
Number of Price Cumulative
value Reason for / Cumulative
Date of equity per Nature of Name of allottees along with the number of Paid-up equity
per Nature of Number if
allotment shares equity Consideration equity shares allotted to each allottee share capital
equity allotment equity shares
allotted share (₹)
share (₹)
(₹)
35. Amrut Ramanlal
2,000
Chaudhari
36. Hitendra Natverlal Patel 1,800
37. Anil Baldevbhai Patel 2,100
38. Kanan Sanjaybhai Dalal 2,500
39. Sheela Ajaybhai Dalal 2,500
40. Bipinchandra Popatlal
1,800
Patel
41. Nannubhai Popatbhai
1,200
Patel
42. Sharad Bipinbhai Patel 400
43. Jyotsana Rajendra Shah 3,600
44. Ashokkumar Bapulal
1,800
Shah
45. Devang Navinchandra
2,400
Gandhi
46. Jigna Tejash Dave 3,600
47. Patel Dasharathbhai H. 900
48. Patel Kanubhai
900
Hargovindas
49. Hansaben Ghanshyam
1,800
Khatri
50. Chandrikaben B. Patel 900
51. Inaxi Nareshbhai Shah 1,800
52. Shital Bihagbhai Angreji 1,800
53. Dipesh S. Mehta 1,200
54. Pritesh Gautam Shah 100
55. Sarabai Usmangani
2,700
Memon
56. Hitesh Vitthalbhai Patel 1,800
181Issue
Face
Number of Price Cumulative
value Reason for / Cumulative
Date of equity per Nature of Name of allottees along with the number of Paid-up equity
per Nature of Number if
allotment shares equity Consideration equity shares allotted to each allottee share capital
equity allotment equity shares
allotted share (₹)
share (₹)
(₹)
57. Patel Jankiben
600
Dharmendra kumar
58. Kundan Rameshbhai
2,000
Gandhi
59. Jignesh A. Maniar 3,600
60. Nishant M. Shah 1,800
61. Kanchan Nareshbhai
5,100
Patel
62. Krina Amit Parikh 4,200
63. Amit Ashokbhai Parikh 6,000
64. Naresh S. Patel 900
65. Malti Ashokbhai Parikh 4,200
66. Divyesh Babulal Shah 900
67. Shah Monali 5,100
68. Manjula K. Vyas 1,200
69. Sheetal Vyas 6,300
70. Arunkumar Babulal
2,100
Vyas
71. Swati Agrawal 5,400
72. Madhu Binod Agrawal 600
73. Vimal Dairy Limited 2,400
74. Bhikhalal Hajarimal
1,800
Soni
75. Renukaben
1,800
Arvindkumar Patel
76. Shobhana Janakkumar
1,800
Babaria
Note: N.A. refers to Not Applicable
*The shares our held jointly by the shareholders.
#Our Company was incorporated on October 12, 1994. The date of subscription to the Memorandum of Association is October 07, 1997.
182The following table provides the list of allotments and number of allottees in each financial year:
Fiscal Year Number of Allotments Total Number of Allottees
1994-95 1 47
1995-96 1 14
1996-97 2 211#$
1997-98 - -
1998-99 - -
1999-00 1 65#
2000 - 01 1 37
2002 - 03 - -
2003 - 04 - -
2005 - 06 1 8
2006 - 07 - -
2007 - 08 1 502#
2008 - 09 - -
2009 - 10 - -
2011 - 12 - -
2012 - 13 - -
2014 - 15 - -
2022 - 23 - -
2023 - 24 - -
2024 - 25 - -
Note:
# The allotment of equity shares to allottees were in violation of Section 67(3) of the Companies Act, 1956. A suo moto compounding application against this violation was filed by our Company. The National Company
Law Tribunal, pursuant to an order dated December 06, 2018 has disposed of the compounding application with a compounding fee of ₹36,15,750. Our Company also filed a suo-moto settlement application in terms of
the SEBI (Settlement of Administrative and Civil Proceedings) Regulations, 2014 which is repealed and replaced with SEBI (Settlement Proceedings) Regulations, 2018 with effect from January 01, 2019. The High-
Powered Advisory Committee (‘HPAC’) in its meeting held on March 29, 2019 considered the settlement terms proposed and recommended the case for settlement upon payment of ₹12,18,750/- (Rupees Twelve Lakh
Eighteen Thousand Seven Hundred and Fifty only) by the applicant towards settlement charges for the defaults, which was duly paid and Our Company has been unable to trace certain share transfer forms. Further
details see, “Risk Factor – Our Company had issued Equity Shares to more than 49 investors in the past and as a matter of abundant caution for better corporate governance, our Company has given an exit offer to the
eligible shareholders” on page 53
$The name of certain allottees are being repeated in the list of allottees, the total number of allottees are 193 for the Fiscal Year 1996-1997.
Except as disclosed in the “Risk Factor – We are unable to trace some of our historical corporate records. We cannot assure you that no legal proceedings or regulatory actions
will be initiated against our Company in future in relation to the missing corporate records which may impact our cash flows, financial condition and reputation” on page 47,
our Company is in compliance with the Companies Act, 1956 and Companies Act, 2013, to the extent applicable, with respect to issuance of Equity Shares from the date of
incorporation of our Company till the date of filing of this Draft Red Herring Prospectus.
183Secondary Transactions involving the Promoters, Promoter Group since incorporation of our Company
The following table sets forth the details of secondary transactions of equity shares of our Company:
Date of Name of Name of Nature of Number of Face Transfe Nature of
transfer transferor transferee transaction equity value r price consideratio
shares per per n
transferre equit equity
d y share
share (₹)
(₹)
Upendra T Shah
June 27, Trikamlal F Shah Upendra T Shah & Transfer 69,000 10 10 Cash
1996 & Vimalaben T Purnima Upendra
Shah* Shah*
June 27, Vimlaben T Shah Upendra T Shah & Transfer 79,000 10 10 Cash
1996 & Trikamlal F Purnima Upendra
Shah* Shah*
October Jayantibhai K Upendra T Shah & Transfer 1,000 10 Nil N.A.
31, 1996# Patel & Kokila J Purnima Upendra
Patel* Shah*
Septembe Upendra T Shah Trupti Utpal Shah Transfer (700) 10 Nil N.A.
r 17, & Purnima & Purnima
1998# Upendra Shah* Upendra Shah*
Septembe Upendra T Shah Trikamlal F Shah Transfer (4,000) 10 Nil N.A.
r 17, & Purnima & Upendra T
1998# Upendra Shah* Shah*
May 15, Chimanbhai N Upendra T Shah & Transfer 20,000 10 Nil N.A.
1999# Patel & Purnima Upendra
Shantaben C Shah*
Patel*
May 15, Ajitbhai M Sheth Upendra T Shah & Transfer 5,000 10 10 Cash
1999 & Bhavna A Purnima Upendra
Sheth* Shah*
May 12, Chhayaben Upendra T Shah & Transfer 2,500 10 10 Cash
2000 Jawahar Jethawa Purnima Upendra
& Jawahar Shah*
Tulsidas
Jethawa*
May 12, Chhayaben Upendra T Shah & Transfer 2,500 10 5 Cash
2000 Mahendrabhai Purnima Upendra
Shah & Shah*
Mahendrabhai
Chinubhai Shah*
May 21, Padmaben B Upendra T Shah & Transfer 1,000 10 10 Cash
2001 Shah Purnima Upendra
Shah*
August Upendra T Shah Pearl Tej Shah Transfer (1,00,000) 10 10 Cash
20, 2008 & Purnima
Upendra Shah*
August Upendra T Shah Aashana Utpal Transfer (1,00,000) 10 10 Cash
20, 2008 & Purnima Shah
Upendra Shah*
August Upendra T Shah Rehaan Utpal Transfer (1,00,000) 10 10 Cash
20, 2008 & Purnima Shah
Upendra Shah*
February Nikunj Upendra T Shah & Transfer 300 10 80 Cash
28, 2009 Mahendrabhai Purnima Upendra
Shah & Mita Shah*
Nikunj Shah*
February Dushyant Upendra T Shah & Transfer 600 10 80 Cash
28, 2009 Sureshbhai Shah Purnima Upendra
Shah*
February Alpesh Jayantilal Upendra T Shah & Transfer 600 10 80 Cash
28, 2009 Shah Purnima Upendra
Shah*
184Date of Name of Name of Nature of Number of Face Transfe Nature of
transfer transferor transferee transaction equity value r price consideratio
shares per per n
transferre equit equity
d y share
share (₹)
(₹)
February Milanben Upendra T Shah & Transfer 400 10 80 Cash
28, 2009 Pareshbhai Purnima Upendra
Mehta Shah*
February Paresh Upendra T Shah & Transfer 400 10 80 Cash
28, 2009 Champaklal Purnima Upendra
Mehta Shah*
February Rajesh Kapoor Upendra T Shah & Transfer 1,000 10 150 Cash
28, 2009 Purnima Upendra
Shah*
February Harshadkumar Upendra T Shah & Transfer 300 10 80 Cash
28, 2009 Ravalji Purnima Upendra
Shah*
February Indumati Vora Upendra T Shah & Transfer 300 10 80 Cash
28, 2009 Purnima Upendra
Shah*
February Priyata Haresh Upendra T Shah & Transfer 300 10 150 Cash
28, 2009 Jethva Purnima Upendra
Shah*
February Ramilaben Upendra T Shah & Transfer 300 10 150 Cash
28, 2009 Shamjibhai Purnima Upendra
Jethva Shah*
February Sonia Rajesh Upendra T Shah & Transfer 1,000 10 150 Cash
28, 2009 Kapoor Purnima Upendra
Shah*
February Aanal M Shah & Upendra T Shah & Transfer 1000 10 80 Cash
28, 2009 Manish Shah* Purnima Upendra
Shah*
February Smitaben Upendra T Shah & Transfer 300 10 80 Cash
28, 2009 Maheshkumar Purnima Upendra
Patel Shah*
February Maheshkumar Upendra T Shah & Transfer 300 10 80 Cash
28, 2009 Somabhai Patel Purnima Upendra
Shah*
February Neha Parful Shah Upendra T Shah & Transfer 300 10 80 Cash
28, 2009 & Praful A Shah* Purnima Upendra
Shah*
February Viral D Shah Upendra T Shah & Transfer 400 10 150 Cash
28, 2009 Purnima Upendra
Shah*
February Hasmukhray Upendra T Shah & Transfer 1,500 10 150 Cash
28, 2009 Shah Purnima Upendra
Shah
February Anita Upendra T Shah & Transfer 300 10 80 Cash
28, 2009 Alpeshkumar Purnima Upendra
Shah & Alpesh Shah*
Balchandbhai
Shah*
February Satish Ratilal Upendra T Shah & Transfer 300 10 150 Cash
28, 2009 Budhbhatti Purnima Upendra
Shah*
February Premila Jagdish Upendra T Shah & Transfer 300 10 150 Cash
28, 2009 Bhimani & Purnima Upendra
Jagdish Shah*
Keshavlal
Bhimani*
February Prashant J Upendra T Shah & Transfer 300 10 150 Cash
28, 2009 Bhimani Purnima Upendra
Shah*
185Date of Name of Name of Nature of Number of Face Transfe Nature of
transfer transferor transferee transaction equity value r price consideratio
shares per per n
transferre equit equity
d y share
share (₹)
(₹)
February Dipikaben Upendra T Shah & Transfer 300 10 150 Cash
28, 2009 Upendrabhai Purnima Upendra
Prajapati Shah*
February Divyaben Y Upendra T Shah & Transfer 300 10 150 Cash
28, 2009 Prajapati Purnima Upendra
Shah*
February Shachi Devang Upendra T Shah & Transfer 1,000 10 150 Cash
28, 2009 Patel Purnima Upendra
Shah*
February Hardik J Upendra T Shah & Transfer 300 10 150 Cash
28, 2009 Bhimani Purnima Upendra
Shah*
February Rajnikant Harilal Upendra T Shah & Transfer 400 10 150 Cash
28, 2009 Patel & Purnima Upendra
Shantaben R Shah*
Patel*
February Amitbhai Upendra T Shah & Transfer 600 10 150 Cash
28, 2009 Bhagvandas Purnima Upendra
Chokshi & Shah*
Nitaben
Amitbhai
Choksi*
February Sangita Patel Upendra T Shah & Transfer 300 10 150 Cash
28, 2009 Purnima Upendra
Shah*
February Rameshbhai N. Upendra T Shah & Transfer 300 10 150 Cash
28, 2009 Sojitra Purnima Upendra
Shah*
February Upendra T Upendra T Shah & Transfer 300 10 150 Cash
28, 2009 Prajapati Purnima Upendra
Shah*
February Devang C Mehta Upendra T Shah & Transfer 300 10 80 Cash
28, 2009 Purnima Upendra
Shah*
February Induben R Patel Upendra T Shah & Transfer 1,000 10 80 Cash
28, 2009 Purnima Upendra
Shah*
February Mina N Patel Upendra T Shah & Transfer 600 10 80 Cash
28, 2009 Purnima Upendra
Shah*
February Mukundbhai Upendra T Shah & Transfer 6000 10 150 Cash
28, 2009 Shambhubhai Purnima Upendra
Patel Shah*
February Babiben N Upendra T Shah & Transfer 500 10 150 Cash
28, 2009 Solanki & Purnima Upendra
Nanjibhai A. Shah*
Solanki*
February Bhavana Upendra T Shah & Transfer 300 10 150 Cash
28, 2009 Dasharath Shah Purnima Upendra
& Dasharath Shah*
Chimanlal Shah*
February Ragini Modi & Upendra T Shah & Transfer 300 10 80 Cash
28, 2009 Mukund Modi* Purnima Upendra
Shah*
February Narendra Upendra T Shah & Transfer 300 10 150 Cash
28, 2009 Chimanlal Shah Purnima Upendra
Shah*
186Date of Name of Name of Nature of Number of Face Transfe Nature of
transfer transferor transferee transaction equity value r price consideratio
shares per per n
transferre equit equity
d y share
share (₹)
(₹)
February Manisha B Patel Upendra T Shah & Transfer 300 10 80 Cash
28, 2009 & Bhavesh G Purnima Upendra
Patel* Shah*
February Bharvi Patel Upendra T Shah & Transfer 300 10 80 Cash
28, 2009 Purnima Upendra
Shah*
February Manubhai Upendra T Shah & Transfer 300 10 80 Cash
28, 2009 Ambalal Patel Purnima Upendra
Shah*
February Govind Bhai S Upendra T Shah & Transfer 800 10 80 Cash
28, 2009 Patel Purnima Upendra
Shah*
February Sunitaben G Upendra T Shah & Transfer 1,000 10 80 Cash
28, 2009 Patel & Purnima Upendra
Govindbhai S Shah*
Patel*
February Alaknanda N Upendra T Shah & Transfer 300 10 80 Cash
28, 2009 Patel Purnima Upendra
Shah*
February Naynaben Shah Upendra T Shah & Transfer 300 10 150 Cash
28, 2009 Purnima Upendra
Shah*
February Mukund Modi Upendra T Shah & Transfer 300 10 80 Cash
28, 2009 Purnima Upendra
Shah*
February Saurabh Modi & Upendra T Shah & Transfer 300 10 80 Cash
28, 2009 Mukund Modi* Purnima Upendra
Shah*
February Tilottama Upendra T Shah & Transfer 500 10 80 Cash
28, 2009 Yewley & Purnima Upendra
Yogesh Yewley* Shah*
February Hansaben Upendra T Shah & Transfer 300 10 80 Cash
28, 2009 Girjashankar Purnima Upendra
Raval Shah*
February Anilkumar Upendra T Shah & Transfer 300 10 80 Cash
28, 2009 Popatlal Raval Purnima Upendra
Shah*
February Avinash Gupte Upendra T Shah & Transfer 300 10 80 Cash
28, 2009 Purnima Upendra
Shah*
February Atash Shah Upendra T Shah & Transfer 4,100 10 150 Cash
28, 2009 Purnima Upendra
Shah*
February Minal Kiritbhai Upendra T Shah & Transfer 1,000 10 80 Cash
28, 2009 Parikh & Purnima Upendra
Kiritbhai Parikh* Shah*
February Pranavvbhai Upendra T Shah & Transfer 1,000 10 80 Cash
28, 2009 Khambhati & Purnima Upendra
Kirtibhai Shah*
Ramanlal
Parikh*
February Sanjay Bhimani Upendra T Shah & Transfer 3,100 10 150 Cash
28, 2009 Purnima Upendra
Shah*
February Narendra D. Upendra T Shah & Transfer 500 10 80 Cash
28, 2009 Patel Purnima Upendra
Shah*
187Date of Name of Name of Nature of Number of Face Transfe Nature of
transfer transferor transferee transaction equity value r price consideratio
shares per per n
transferre equit equity
d y share
share (₹)
(₹)
March 7, Sushila Babubhai Upendra T Shah & Transfer 300 10 80 Cash
2009 Patel & Purnima Upendra
Babubhai Shah*
Ambalal Patel &
Ambalal
Maganlal Patel*
March 7, Manjulaben Patel Upendra T Shah & Transfer 1,000 10 150 Cash
2009 Purnima Upendra
Shah*
March 7, Kruti Jatin Patel Upendra T Shah & Transfer 1,200 10 150 Cash
2009 Purnima Upendra
Shah*
March 7, Babubhai Upendra T Shah & Transfer 300 10 80 Cash
2009 Ambalal Patel & Purnima Upendra
Sushila Babubhai Shah*
Patel*
March 7, Jyotsana Laxesh Upendra T Shah & Transfer 300 10 80 Cash
2009 Chudgar & Purnima Upendra
Laxesh Shah*
Harshadrai
Chudgar*
March 7, Ambalalmaganla Upendra T Shah & Transfer 300 10 80 Cash
2009 l Patel & Purnima Upendra
Babubhai Shah*
Ambalal Patel &
Sushila Babubhai
Patel*
March 7, Chaturbhai H Upendra T Shah & Transfer 500 10 80 Cash
2009 Patel Purnima Upendra
Shah*
March 7, Ramilaben D Upendra T Shah & Transfer 600 10 80 Cash
2009 Patel & Purnima Upendra
Divyakant C Shah*
Patel*
March 7, Divyakant C Upendra T Shah & Transfer 500 10 80 Cash
2009 Patel Purnima Upendra
Shah*
March 7, Bharatkumar C Upendra T Shah & Transfer 600 10 80 Cash
2009 Patel & Purnima Upendra
Shilpaben B Shah*
Patel*
March 7, Sitaben C Patel& Upendra T Shah & Transfer 400 10 80 Cash
2009 Chaturbhai H Purnima Upendra
Patel* Shah*
March 7, Chaturbhai Upendra T Shah & Transfer 900 10 80 Cash
2009 Harjivandas Purnima Upendra
Patel & Sitaben Shah*
C Patel*
March 7, Shilpaben B Upendra T Shah & Transfer 500 10 80 Cash
2009 Patel & Purnima Upendra
Bharatkumar C Shah*
Patel*
March 7, Jatin Upendra T Shah & Transfer 1,200 10 150 Cash
2009 Vinodchandra Purnima Upendra
Patel Shah*
March 7, Neeta Jatin Patel Upendra T Shah & Transfer 1,200 10 150 Cash
2009 & Jatin Purnima Upendra
Vindochandra Shah*
Patel*
188Date of Name of Name of Nature of Number of Face Transfe Nature of
transfer transferor transferee transaction equity value r price consideratio
shares per per n
transferre equit equity
d y share
share (₹)
(₹)
March 7, Jatin Upendra T Shah & Transfer 1,400 10 150 Cash
2009 Vinodchandra Purnima Upendra
Patel & Neeta Shah*
Jatin Patel*
March 7, Lilaben Upendra T Shah & Transfer 300 10 80 Cash
2009 Satishbhai Patel Purnima Upendra
Shah*
March 7, Babubhai Upendra T Shah & Transfer 300 10 80 Cash
2009 Dolatsinh Darbar Purnima Upendra
Shah*
March 7, Bahnumati Upendra T Shah & Transfer 300 10 80 Cash
2009 Indravadan Bhatt Purnima Upendra
Shah*
March 7, Kinjal Harshad Upendra T Shah & Transfer 300 10 80 Cash
2009 Patel & Harshad Purnima Upendra
Harikrishna Shah*
Patel*
March 7, Janardan Upendra T Shah & Transfer 300 10 80 Cash
2009 Induprasad Patel Purnima Upendra
Shah*
March 7, Mahendra Upendra T Shah & Transfer 1,000 10 150 Cash
2009 Hargovandas Purnima Upendra
Patel & Taraben Shah*
Mahendrabhai
Patel*
March 7, Taraben Upendra T Shah & Transfer 300 10 150 Cash
2009 Mahendrabhai Purnima Upendra
Patel & Shah*
Mahendra
Hargovandas
Patel*
March 7, Manokkumar Upendra T Shah & Transfer 500 10 80 Cash
2009 Lalbhai Shah Purnima Upendra
Shah*
March 7, Harshadbhai Upendra T Shah & Transfer 500 10 80 Cash
2009 Keshavlal Patel Purnima Upendra
Shah*
March 7, Premilaben Upendra T Shah & Transfer 500 10 80 Cash
2009 Harshadbhai Purnima Upendra
Patel Shah*
March 7, Bhumika Upendra T Shah & Transfer 300 10 80 Cash
2009 Bharatkuamar Purnima Upendra
Patel Shah*
March 7, Smitaben Upendra T Shah & Transfer 300 10 80 Cash
2009 Keshavlal Patel Purnima Upendra
Shah*
March 7, Hiren Upendra T Shah & Transfer 400 10 80 Cash
2009 Harshadbhai Purnima Upendra
Patel & Shah*
Premilaben
Harshadbahi
Patel &
Harshadbhai
Keshavlal Patel*
March 7, Rajendra Upendra T Shah & Transfer 1,000 10 80 Cash
2009 Kantilal Patel & Purnima Upendra
Kantilal Ambalal Shah*
Patel*
189Date of Name of Name of Nature of Number of Face Transfe Nature of
transfer transferor transferee transaction equity value r price consideratio
shares per per n
transferre equit equity
d y share
share (₹)
(₹)
March 7, Kantilal Ambalal Upendra T Shah & Transfer 1,000 10 80 Cash
2009 Patel & Rajendra Purnima Upendra
Kantilal Patel* Shah*
March 7, Vidya Kantilal Upendra T Shah & Transfer 1,000 10 80 Cash
2009 Patel & Kantilal Purnima Upendra
Ambalal Patel* Shah*
March 7, Bipin Shankerlal Upendra T Shah & Transfer 300 10 80 Cash
2009 Vyas Purnima Upendra
Shah*
March 7, Mandakini Upendra T Shah & Transfer 300 10 80 Cash
2009 Nimesh Desai & Purnima Upendra
Nimesh Shah*
Jagdishbhai
Desai*
March 7, Harshadbhai Upendra T Shah & Transfer 300 10 80 Cash
2009 Keshavlal Patel Purnima Upendra
Shah*
March 7, Sangita S Desai Upendra T Shah & Transfer 300 10 80 Cash
2009 & Suryakant R Purnima Upendra
Desai* Shah*
March 7, Jaimini Jatin Upendra T Shah & Transfer 300 10 80 Cash
2009 Patel & Jatin Purnima Upendra
Bhanuprasad Shah*
Patel*
March 7, Vishnubhai Upendra T Shah & Transfer 300 10 80 Cash
2009 Chhaganlal Patel Purnima Upendra
& Kokila Shah*
Vishnubhai
Patel*
March 7, Jaydeep Upendra T Shah & Transfer 300 10 80 Cash
2009 Dhananjay Patel Purnima Upendra
& Dhananjay H Shah*
Patel*
March 7, Darshan A Desai Upendra T Shah & Transfer 300 10 80 Cash
2009 & Arvindkumar Purnima Upendra
P Desai* Shah*
March 7, Varsha Upendra T Shah & Transfer 300 10 80 Cash
2009 Jagdishchandra Purnima Upendra
Purani Shah*
March 7, Kaushilk Purani Upendra T Shah & Transfer 300 10 80 Cash
2009 Purnima Upendra
Shah*
March 7, Dinesh Ambalal Upendra T Shah & Transfer 300 10 80 Cash
2009 Modi & Purnima Upendra
Rashmika Shah*
Dineshkumar
Modi*
March 7, Dwipal D Patel Upendra T Shah & Transfer 300 10 80 Cash
2009 & Devang G Purnima Upendra
Patel* Shah*
March 7, Janak Natverlal Upendra T Shah & Transfer 300 10 80 Cash
2009 Patel & Natverlal Purnima Upendra
Keshavlal Patel* Shah*
March 7, Rashmikaben Upendra T Shah & Transfer 300 10 80 Cash
2009 Dineshkumar Purnima Upendra
Modi Shah*
March 7, Rashmika Upendra T Shah & Transfer 300 10 80 Cash
2009 Janakkumar Purnima Upendra
Shah*
190Date of Name of Name of Nature of Number of Face Transfe Nature of
transfer transferor transferee transaction equity value r price consideratio
shares per per n
transferre equit equity
d y share
share (₹)
(₹)
Patel & Janak
Natverlal Patel*
March 7, Renuka Arvind Upendra T Shah & Transfer 2,000 10 150 Cash
2009 Patel & Arvind Purnima Upendra
M Patel & Shah*
Krunal A Patel*
March 7, Ashish Upendra T Shah & Transfer 300 10 80 Cash
2009 Dhanjibhai Purnima Upendra
Davda Shah*
March 7, Mehal Ashish Upendra T Shah & Transfer 300 10 80 Cash
2009 Davda Purnima Upendra
Shah*
March 7, Ankur Upendra T Shah & Transfer 400 10 80 Cash
2009 Harshadray Purnima Upendra
Pandya Shah*
March 7, Krunal D Shah & Upendra T Shah & Transfer 500 10 80 Cash
2009 Rakhi Krunal Purnima Upendra
Shah* Shah*
March 7, Indira Piyush Upendra T Shah & Transfer 300 10 80 Cash
2009 Dalal & Piyush Purnima Upendra
Dalal* Shah*
March 7, Sandip Upendra T Shah & Transfer 300 10 80 Cash
2009 Bharatkumar Purnima Upendra
Patel & Shah*
Bhartiben
Bharatkumar
Patel*
March 7, Vimlagauri Upendra T Shah & Transfer 300 10 80 Cash
2009 Naranlal Patel & Purnima Upendra
Naranlal Shah*
Maneklal Patel &
Hiren Naranlal
Patel*
March 7, Vishvajit M Patel Upendra T Shah & Transfer 400 10 150 Cash
2009 & Mahendra H Purnima Upendra
Patel* Shah*
March 7, Naranlal Upendra T Shah & Transfer 300 10 80 Cash
2009 Maneklal Patel & Purnima Upendra
Vimlagauri Shah*
Naranlal Patel &
Hiren Naranlal
Patel*
October Rupeshkumar Upendra T Shah & Transfer 300 10 80 Cash
01, 2009 Rameshchandra Purnima Upendra
Patel & Nitu Shah*
Rupeshkumar
Patel*
October Sharad Upendra T Shah & Transfer 300 10 80 Cash
01, 2009 Kanaiyalal Purnima Upendra
Acharya Shah*
October Bhagwandas Upendra T Shah & Transfer 300 10 80 Cash
01, 2009 Bababahi Desai Purnima Upendra
Shah*
Novembe Babubhai Shah Upendra T Shah & Transfer 300 10 80 Cash
r 02, 2009 Purnima Upendra
Shah*
Novembe Tarun V Sharma Upendra T Shah & Transfer 500 10 80 Cash
r 02, 2009 Purnima Upendra
Shah*
191Date of Name of Name of Nature of Number of Face Transfe Nature of
transfer transferor transferee transaction equity value r price consideratio
shares per per n
transferre equit equity
d y share
share (₹)
(₹)
Novembe Atulbhai Patel Upendra T Shah & Transfer 300 10 80 Cash
r 02, 2009 Purnima Upendra
Shah*
December Gauri P Rohra Upendra T Shah & Transfer 2,000 10 80 Cash
1, 2009 Purnima Upendra
Shah*
February Sureshchandra Upendra T Shah & Transfer 300 10 80 Cash
01, 2010 Chandulal Shah Purnima Upendra
& Krunal Shah*
Sureshkumar
Shah*
March 02, Raju Shah Upendra T Shah & Transfer 300 10 80 Cash
2010 Purnima Upendra
Shah*
March 02, Lalit Shah Upendra T Shah & Transfer 300 10 80 Cash
2010 Purnima Upendra
Shah*
Septembe Hemal Upendra T Shah & Transfer 600 10 80 Cash
r 01, 2010 Vipinchandra Purnima Upendra
Karbhari Shah*
Septembe Avanti Upendra T Shah & Transfer 300 10 80 Cash
r 01, 2010 Vinodchandra Purnima Upendra
Karbhari Shah*
Septembe Kunj Sanjay Upendra T Shah & Transfer 300 10 80 Cash
r 01, 2010 Shah & Sanjay Purnima Upendra
Shantilal Shah* Shah*
Septembe Ashok Nanakram Upendra T Shah & Transfer 300 10 80 Cash
r 01, 2010 Ramtri Purnima Upendra
Shah*
Septembe Jitendra Shantilal Upendra T Shah & Transfer 300 10 80 Cash
r 01, 2010 Shah Purnima Upendra
Shah*
Septembe Upendra Upendra T Shah & Transfer 500 10 80 Cash
r 01, 2010 Vithalani & Hina Purnima Upendra
Vithalani* Shah*
Septembe Hina Vithalani & Upendra T Shah & Transfer 800 10 80 Cash
r 01, 2010 Upendra Purnima Upendra
Vithalani* Shah*
Septembe Chirag Shah & Upendra T Shah & Transfer 300 10 80 Cash
r 01, 2010 Nareshchandra Purnima Upendra
Shah* Shah*
Septembe Mauli Anal Dave Upendra T Shah & Transfer 300 10 80 Cash
r 01, 2010 Purnima Upendra
Shah*
October Manish Upendra T Shah & Transfer 500 10 80 Cash
01, 2010 Gopalkrishna Purnima Upendra
Patwari & Shah*
Gopalkrishna
Ranchhodlal
Patwari*
Novembe Aatishkumar Upendra T Shah & Transfer 300 10 80 Cash
r 01, 2010 Dhirajlal Purnima Upendra
Chokshi Shah*
& Meetaben A.
Chokshi*
December Upendra T Shah Kenisha Tanmay Transfer (1,00,000) 10 10 Cash
01, 2010 & Purnima Shah
Upendra Shah*
192Date of Name of Name of Nature of Number of Face Transfe Nature of
transfer transferor transferee transaction equity value r price consideratio
shares per per n
transferre equit equity
d y share
share (₹)
(₹)
December Upendra T Shah Srujal Shah & Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Prathibha Shah* equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Chintan S Parikh Transfer of (300) 10 Nil Gift
01, 2010 & Purnima equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Jwellin Shah Transfer of (400) 10 Nil Gift
01, 2010 & Purnima equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Dinesh Shah & Transfer of (700) 10 Nil Gift
01, 2010 & Purnima Jayshree Shah* equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Leena Shah & Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Ravindra Shah* equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Kundan Vallabhai Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Patel equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Dipakbhai Transfer of (600) 10 Nil Gift
01, 2010 & Purnima Navinchandra equity shares
Upendra Shah* Shah by way of
gift
December Upendra T Shah Akash Transfer of (500) 10 Nil Gift
01, 2010 & Purnima Nalinkumar Shah equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Hetal Transfer of (500) 10 Nil Gift
01, 2010 & Purnima Kamleshbhai equity shares
Upendra Shah* Shah by way of
gift
December Upendra T Shah Kamlesh Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Jayantibhai Shah equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Bharatbhai Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Umedchand equity shares
Upendra Shah* Gopani by way of
gift
December Upendra T Shah Kalpeshbhai Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Rasiklal Shah equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Mukeshbhai Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Govindbhai Patel equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Malti Ashokbhai Transfer of (700) 10 Nil Gift
01, 2010 & Purnima Parikh equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Krina Amit Parikh Transfer of (700) 10 Nil Gift
01, 2010 & Purnima equity shares
Upendra Shah*
193Date of Name of Name of Nature of Number of Face Transfe Nature of
transfer transferor transferee transaction equity value r price consideratio
shares per per n
transferre equit equity
d y share
share (₹)
(₹)
by way of
gift
December Upendra T Shah Chander Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Choithram equity shares
Upendra Shah* Vanvari by way of
gift
December Upendra T Shah Indumati Chander Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Vanvari equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Nilay Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Bharatkumar equity shares
Upendra Shah* Contractor by way of
gift
December Upendra T Shah Bina Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Kalpeshkumar equity shares
Upendra Shah* Shah by way of
gift
December Upendra T Shah Surya Bhupendra Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Mehta & equity shares
Upendra Shah* Bhupendra by way of
Jethalal Mehta* gift
December Upendra T Shah Inaxi Nareshbhai Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Shah equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Ketan Tejpal Transfer of (400) 10 Nil Gift
01, 2010 & Purnima Parikh equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Rajiv Tejpal Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Parikh equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Sonal Rajiv Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Parikh equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Atul Chandrakant Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Shah equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Pathik Atulbhai Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Shah equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Jigna Tejas Dave Transfer of (600) 10 Nil Gift
01, 2010 & Purnima equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Shachish Piyush Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Doctor equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Devang Transfer of (400) 10 Nil Gift
01, 2010 & Purnima Navinchandra equity shares
Upendra Shah* Gandhi by way of
gift
194Date of Name of Name of Nature of Number of Face Transfe Nature of
transfer transferor transferee transaction equity value r price consideratio
shares per per n
transferre equit equity
d y share
share (₹)
(₹)
December Upendra T Shah Bhanuben Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Natverlal Shah equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Natverlal Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Shankerlal Shah equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Dinesh H Pande & Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Santosh Dinesh equity shares
Upendra Shah* Pande by way of
gift
December Upendra T Shah Dipesh Sunilbhai Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Mehta equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Tapan Dinesh Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Shah equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Bharat Natverlal Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Shah equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Hinaben Dinesh Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Shah equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Hansaben Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Ghanshyam equity shares
Upendra Shah* Khatri by way of
gift
December Upendra T Shah Gopal Natverlal Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Shah equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Premilaben Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Anilkumar equity shares
Upendra Shah* Chauhan by way of
gift
December Upendra T Shah Roopa Transfer of (500) 10 Nil Gift
01, 2010 & Purnima Manojkumar Shah equity shares
Upendra Shah* & Manojkumar L, by way of
Shah* gift
December Upendra T Shah Avanish Niranjan Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Patel equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Bindu Rajiv Patel Transfer of (500) 10 Nil Gift
01, 2010 & Purnima & Rajiv equity shares
Upendra Shah* Narsinhbhai by way of
Patel* gift
December Upendra T Shah Yogesh Dilipbhai Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Patel equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Paresh Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Mahendrakumar equity shares
Upendra Shah* Patel
195Date of Name of Name of Nature of Number of Face Transfe Nature of
transfer transferor transferee transaction equity value r price consideratio
shares per per n
transferre equit equity
d y share
share (₹)
(₹)
by way of
gift
December Upendra T Shah Mayur Manubhai Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Parikh equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Sushma Mayoor Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Parikh equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Nisith Shah Transfer of (300) 10 Nil Gift
01, 2010 & Purnima equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Kundan Transfer of (500) 10 Nil Gift
01, 2010 & Purnima Rameshbhai equity shares
Upendra Shah* Gandhi by way of
gift
December Upendra T Shah Hardik Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Dharmendrabhai equity shares
Upendra Shah* Patel by way of
gift
December Upendra T Shah Kirtikumar Modi Transfer of (300) 10 Nil Gift
01, 2010 & Purnima equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Amitbhai Popatlal Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Shah equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Janakkumar Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Bhanubhai equity shares
Upendra Shah* Babaria & by way of
Shobhana gift
Janakkumar
Babaria*
December Upendra T Shah Anuradha Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Bhavsar & Rajiv equity shares
Upendra Shah* Bhavsar* by way of
gift
December Upendra T Shah Rajiv Bhavsar & Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Anuradha equity shares
Upendra Shah* Bhavsar* by way of
gift
December Upendra T Shah Ranjan Patwa Transfer of (300) 10 Nil Gift
01, 2010 & Purnima equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Naziralam Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Dinmohmmed equity shares
Upendra Shah* Sheikh & by way of
Shehiadalam gift
Sheikh*
December Upendra T Shah Suresh Maneklal Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Shah & Ramila equity shares
Upendra Shah* Suresh Shah* by way of
gift
196Date of Name of Name of Nature of Number of Face Transfe Nature of
transfer transferor transferee transaction equity value r price consideratio
shares per per n
transferre equit equity
d y share
share (₹)
(₹)
December Upendra T Shah Jitendra Transfer of (400) 10 Nil Gift
01, 2010 & Purnima Amarchand Desai equity shares
Upendra Shah* & Bhavesh by way of
Jitendrakumar gift
Desai*
December Upendra T Shah Pratimaben Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Shanabhai Patel & equity shares
Upendra Shah* Ghanshyambhai by way of
Haribhai Patel* gift
December Upendra T Shah Neha Jhaveri & Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Rajiv Jhaveri* equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Rashmika Shah & Transfer of (500) 10 Nil Gift
01, 2010 & Purnima Umesh Shah* equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Monali Transfer of (400) 10 Nil Gift
01, 2010 & Purnima Birenkumar equity shares
Upendra Shah* Shah* by way of
gift
December Upendra T Shah Kiritkumar Transfer of (400) 10 Nil Gift
01, 2010 & Purnima Govindlal Shah* equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Shardaben A Shah Transfer of (300) 10 Nil Gift
01, 2010 & Purnima & Jaydip A Shah* equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Anjali Hiteshbhai Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Shah equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Vinodchandra Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Keshavlal Shah equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Bharatkumar Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Amaratlal Shah & equity shares
Upendra Shah* Pannaben by way of
Bharatkumar gift
Shah*
December Upendra T Shah Induben Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Dineshbhai equity shares
Upendra Shah* Bhavsar by way of
gift
December Upendra T Shah Dipika Jayesh Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Shah equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Jayesh Indravadan Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Shah & Dipika equity shares
Upendra Shah* Jayesh Shah* by way of
gift
December Upendra T Shah Indravadan Shah Transfer of (300) 10 Nil Gift
01, 2010 & Purnima equity shares
Upendra Shah* by way of
gift
197Date of Name of Name of Nature of Number of Face Transfe Nature of
transfer transferor transferee transaction equity value r price consideratio
shares per per n
transferre equit equity
d y share
share (₹)
(₹)
December Upendra T Shah Chintan Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Pankajkumar equity shares
Upendra Shah* Shah by way of
gift
December Upendra T Shah Surendra Popatlal Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Shah & Leena equity shares
Upendra Shah* Surendra Shah* by way of
gift
December Upendra T Shah Jignesh Maniar & Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Shivani Maniar* equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Shivani Maniar & Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Jignesh Maniar* equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Piyusha J Vakil Transfer of (300) 10 Nil Gift
01, 2010 & Purnima equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Deviben M Pujara Transfer of (300) 10 Nil Gift
01, 2010 & Purnima equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Yogeshchandra Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Manohar Neve & equity shares
Upendra Shah* Nilima by way of
Yogeshchandra gift
Neve*
December Upendra T Shah Nilima Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Yogeshchandra equity shares
Upendra Shah* Neve & by way of
Yogeshchandra gift
Manohar Neve*
December Upendra T Shah Piyushkumar Transfer of (600) 10 Nil Gift
01, 2010 & Purnima Krishnachandra equity shares
Upendra Shah* Dani & Bhavana by way of
Piyushkumar gift
Dani*
December Upendra T Shah Bhavana Transfer of (400) 10 Nil Gift
01, 2010 & Purnima Piyushkumar equity shares
Upendra Shah* Dani & by way of
Piyushkumar gift
Krishnachandra
Dani*
December Upendra T Shah Anand Ashvin Transfer of (500) 10 Nil Gift
01, 2010 & Purnima Dalal equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Ashvin Chinubhai Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Dalal equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Asit Jitendrabhai Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Zaveri equity shares
Upendra Shah* by way of
gift
198Date of Name of Name of Nature of Number of Face Transfe Nature of
transfer transferor transferee transaction equity value r price consideratio
shares per per n
transferre equit equity
d y share
share (₹)
(₹)
December Upendra T Shah Hitesh Vithalbhai Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Patel & Parul equity shares
Upendra Shah* Hitesh Patel* by way of
gift
December Upendra T Shah Harish Patel Transfer of (300) 10 Nil Gift
01, 2010 & Purnima equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Varshaben G Transfer of (500) 10 Nil Gift
01, 2010 & Purnima Gadani equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Rashmiben Gajjar Transfer of (300) 10 Nil Gift
01, 2010 & Purnima & Pravinbhai equity shares
Upendra Shah* Gajjar* by way of
gift
December Upendra T Shah Harivadan Shivlal Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Bhavsar equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Dhirajlal Transfer of (400) 10 Nil Gift
01, 2010 & Purnima Prabhudas equity shares
Upendra Shah* Kansara by way of
gift
December Upendra T Shah Dilip R Soni Transfer of (300) 10 Nil Gift
01, 2010 & Purnima equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Rajendrakumar S Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Shah equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Chandresh R Soni Transfer of (300) 10 Nil Gift
01, 2010 & Purnima equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Gitaben Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Girishkumar equity shares
Upendra Shah* Kotak by way of
gift
December Upendra T Shah Rajesh Maneklal Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Kotak equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Prakash Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Hasmukhlal equity shares
Upendra Shah* Kotak by way of
gift
December Upendra T Shah Govind Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Rukmanbhai equity shares
Upendra Shah* Nama by way of
gift
December Upendra T Shah Girish Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Hasmukhlal equity shares
Upendra Shah* Kotak by way of
gift
December Upendra T Shah Arvindbhai Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Prabhudas Patel equity shares
Upendra Shah*
199Date of Name of Name of Nature of Number of Face Transfe Nature of
transfer transferor transferee transaction equity value r price consideratio
shares per per n
transferre equit equity
d y share
share (₹)
(₹)
by way of
gift
December Upendra T Shah Neha Patel Transfer of (300) 10 Nil Gift
01, 2010 & Purnima equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Jayshree Patel Transfer of (300) 10 Nil Gift
01, 2010 & Purnima equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Suleman Khoja Transfer of (300) 10 Nil Gift
01, 2010 & Purnima equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Ramesh Sorathia Transfer of (300) 10 Nil Gift
01, 2010 & Purnima equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Bharati Dinesh Transfer of (600) 10 Nil Gift
01, 2010 & Purnima Desai & Dinesh equity shares
Upendra Shah* Jawaharlal Desai* by way of
gift
December Upendra T Shah Shachi Dinesh Transfer of (600) 10 Nil Gift
01, 2010 & Purnima Desai & Bharti equity shares
Upendra Shah* Dinesh Desai* by way of
gift
December Upendra T Shah Dakshaben Shah Transfer of (300) 10 Nil Gift
01, 2010 & Purnima equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Neeta Dipak Patel Transfer of (300) 10 Nil Gift
01, 2010 & Purnima & Dipak equity shares
Upendra Shah* Ramanlal Patel* by way of
gift
December Upendra T Shah Bhavini Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Rupeshbhai Shah equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Mrunalini Patel Transfer of (300) 10 Nil Gift
01, 2010 & Purnima equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Sudha Kamlesh Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Modi equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Rekhaben Transfer of (600) 10 Nil Gift
01, 2010 & Purnima Rajeshkumar equity shares
Upendra Shah* Kotak by way of
gift
December Upendra T Shah Bharat J Patel & Transfer of (500) 10 Nil Gift
01, 2010 & Purnima Gita B Patel* equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Poornima Shah & Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Ashokkumar equity shares
Upendra Shah* Shah* by way of
gift
200Date of Name of Name of Nature of Number of Face Transfe Nature of
transfer transferor transferee transaction equity value r price consideratio
shares per per n
transferre equit equity
d y share
share (₹)
(₹)
December Upendra T Shah Ashokkumar Shah Transfer of (300) 10 Nil Gift
01, 2010 & Purnima & Poornima equity shares
Upendra Shah* Shah* by way of
gift
December Upendra T Shah Rajesh Patel Transfer of (300) 10 Nil Gift
01, 2010 & Purnima equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Navinchandra V Transfer of (500) 10 Nil Gift
01, 2010 & Purnima Shah & equity shares
Upendra Shah* Manjulaben N by way of
Shah* gift
December Upendra T Shah Nareshchandra Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Shah & Sweta equity shares
Upendra Shah* Shah* by way of
gift
December Upendra T Shah Rajendra Kantilal Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Shah & Jyotsana equity shares
Upendra Shah* Rajendra Shah* by way of
gift
December Upendra T Shah Jyotsana Rajendra Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Shah & Rajendra equity shares
Upendra Shah* Kantilal Shah* by way of
gift
December Upendra T Shah Jankiben Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Dharmendrakuma equity shares
Upendra Shah* r Patel* by way of
gift
December Upendra T Shah Anil Baldevbhai Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Patel equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Shital Bihagbhai Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Angreji equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Kaushik kumar Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Ramanlal Patel & equity shares
Upendra Shah* Amita Kaushik by way of
Patel* gift
December Upendra T Shah Amita Kaushik Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Patel & Kaushik equity shares
Upendra Shah* kumar Ramanlal by way of
Patel* gift
December Upendra T Shah Shobhan S Parikh Transfer of (300) 10 Nil Gift
01, 2010 & Purnima equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Khodidas Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Prabhudas Barot equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Praful K. Shah & Transfer of (400) 10 Nil Gift
01, 2010 & Purnima Gauri P. Shah & equity shares
Upendra Shah* Pritish P. Shah* by way of
gift
December Upendra T Shah Ghanshyambhai Transfer of (600) 10 Nil Gift
01, 2010 & Purnima Patel equity shares
Upendra Shah*
201Date of Name of Name of Nature of Number of Face Transfe Nature of
transfer transferor transferee transaction equity value r price consideratio
shares per per n
transferre equit equity
d y share
share (₹)
(₹)
by way of
gift
December Upendra T Shah Mahesh Ramanlal Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Gandhi equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Jagruti Pravin Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Master & Pravin equity shares
Upendra Shah* Devidas Master* by way of
gift
December Upendra T Shah Vipul C Desai & Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Chetna Vipul equity shares
Upendra Shah* Desai* by way of
gift
December Upendra T Shah Chetna Vipul Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Desai & Vipul C equity shares
Upendra Shah* Desai* by way of
gift
December Upendra T Shah Sarojben C Desai Transfer of (300) 10 Nil Gift
01, 2010 & Purnima & Chandrakant A equity shares
Upendra Shah* Desai* by way of
gift
December Upendra T Shah Chandrakant A Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Desai & Sarojben equity shares
Upendra Shah* C Desai* by way of
gift
December Upendra T Shah Dipal Rameshbhai Transfer of (600) 10 Nil Gift
01, 2010 & Purnima Shah equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Surekha Suketu Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Javeri equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Shaileshbhai Shah Transfer of (300) 10 Nil Gift
01, 2010 & Purnima & Bharatbhai equity shares
Upendra Shah* Patel & Bhartiben by way of
Patel* gift
December Upendra T Shah Bharatkumar Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Daftary equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Dharmesh Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Rasiklal Shah equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Dilipbhai R Patel Transfer of (300) 10 Nil Gift
01, 2010 & Purnima equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Sheelaben D Patel Transfer of (300) 10 Nil Gift
01, 2010 & Purnima equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Ila Thaker & Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Kalpesh Thaker* equity shares
Upendra Shah* by way of
gift
202Date of Name of Name of Nature of Number of Face Transfe Nature of
transfer transferor transferee transaction equity value r price consideratio
shares per per n
transferre equit equity
d y share
share (₹)
(₹)
December Upendra T Shah Niraj Dilipkumar Transfer of (600) 10 Nil Gift
01, 2010 & Purnima Shah equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Dilipkumar Transfer of (600) 10 Nil Gift
01, 2010 & Purnima Rasiklal Shah equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Sushma Mahesh Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Gandhi equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Pushpaben P Shah Transfer of (300) 10 Nil Gift
01, 2010 & Purnima & Pravinchandra equity shares
Upendra Shah* A. Shah* by way of
gift
December Upendra T Shah Nishant M Shah & Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Sonal M Shah* equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Vaishali Shah & Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Viral Naccindas equity shares
Upendra Shah* Shah* by way of
gift
December Upendra T Shah Bhavana Patel & Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Sanjay Patel* equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Mohamed Yusuf Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Memon & equity shares
Upendra Shah* Mohamed Juned by way of
Menon* gift
December Upendra T Shah Usmangani A Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Memon & Gulam equity shares
Upendra Shah* Mohamed A by way of
Memom* gift
December Upendra T Shah Abdurrehman A Transfer of (400) 10 Nil Gift
01, 2010 & Purnima Memon & equity shares
Upendra Shah* Gulammohamed by way of
A Memom* gift
December Upendra T Shah Gulammohamed Transfer of (300) 10 Nil Gift
01, 2010 & Purnima A Memon & equity shares
Upendra Shah* Usmangani A by way of
Memom* gift
December Upendra T Shah Sarabai Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Usmangani equity shares
Upendra Shah* Memon & by way of
Usmangani A gift
Memom*
December Upendra T Shah Kanubhai M Patel Transfer of (300) 10 Nil Gift
01, 2010 & Purnima equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Pushpa Shah Transfer of (300) 10 Nil Gift
01, 2010 & Purnima equity shares
Upendra Shah* by way of
gift
203Date of Name of Name of Nature of Number of Face Transfe Nature of
transfer transferor transferee transaction equity value r price consideratio
shares per per n
transferre equit equity
d y share
share (₹)
(₹)
December Upendra T Shah Bhupendra Shah Transfer of (300) 10 Nil Gift
01, 2010 & Purnima equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Arvind C Chokshi Transfer of (300) 10 Nil Gift
01, 2010 & Purnima & Ashish A equity shares
Upendra Shah* Choksi* by way of
gift
December Upendra T Shah Bhavesh Bhogilal Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Patel & Hina equity shares
Upendra Shah* Bhavesh Patel* by way of
gift
December Upendra T Shah Nilam Mahesh Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Patel & Mahesh equity shares
Upendra Shah* Bhogilal Patel* by way of
gift
December Upendra T Shah Prashant Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Shankerprasad equity shares
Upendra Shah* Vyas & Manju by way of
Prashant Vyas* gift
December Upendra T Shah Chirag Amrutlal Transfer of (500) 10 Nil Gift
01, 2010 & Purnima Patel equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Hemang Amrutlal Transfer of (500) 10 Nil Gift
01, 2010 & Purnima Patel equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Amratbhai Transfer of (500) 10 Nil Gift
01, 2010 & Purnima Harjivandas Patel equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Hasumatiben Transfer of (500) 10 Nil Gift
01, 2010 & Purnima Amratlal Patel equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Amratbhai Transfer of (500) 10 Nil Gift
01, 2010 & Purnima Harjivandas Patel equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Archana Parikh & Transfer of (600) 10 Nil Gift
01, 2010 & Purnima Ketan Parikh* equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Hitendra Patel Transfer of (300) 10 Nil Gift
01, 2010 & Purnima equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Rakesh Thaker Transfer of (300) 10 Nil Gift
01, 2010 & Purnima equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Renukaben Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Arvindkumar equity shares
Upendra Shah* Patel by way of
gift
December Upendra T Shah Kamlesh Kothari Transfer of (300) 10 Nil Gift
01, 2010 & Purnima equity shares
Upendra Shah*
204Date of Name of Name of Nature of Number of Face Transfe Nature of
transfer transferor transferee transaction equity value r price consideratio
shares per per n
transferre equit equity
d y share
share (₹)
(₹)
by way of
gift
December Upendra T Shah Dipan Kothari Transfer of (700) 10 Nil Gift
01, 2010 & Purnima equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Nikunj Desai & Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Dipti Desai* equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Nilesh Kothari & Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Lopa Kothari* equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Kalpesh Thaker & Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Ila Thaker* equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Bhikhalal H Soni Transfer of (300) 10 Nil Gift
01, 2010 & Purnima equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Rajesh Rohra Transfer of (500) 10 Nil Gift
01, 2010 & Purnima equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Sushilaben Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Narendrabhai equity shares
Upendra Shah* Dani by way of
gift
December Upendra T Shah Prashant Ukabhai Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Patel equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Bipin Vallabhbhai Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Patel equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Nirav Transfer of (600) 10 Nil Gift
01, 2010 & Purnima Dhansukhlal Shah equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Nachiket Avinash Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Bhatt equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Samir Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Dashrathbhai equity shares
Upendra Shah* Patel by way of
gift
December Upendra T Shah Daxa Vallabhbhai Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Patel equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Bipinchandra Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Popatlal Patel equity shares
Upendra Shah* by way of
gift
205Date of Name of Name of Nature of Number of Face Transfe Nature of
transfer transferor transferee transaction equity value r price consideratio
shares per per n
transferre equit equity
d y share
share (₹)
(₹)
December Upendra T Shah Bharti Dinesh Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Patel & Dinesh equity shares
Upendra Shah* Tulsidas Patel* by way of
gift
December Upendra T Shah Pravin Maneklal Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Patel & Shanta equity shares
Upendra Shah* Pravin Patel* by way of
gift
December Upendra T Shah Sharadkumar Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Khodidas Antala equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Bhadreshkumar Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Purshottambhai equity shares
Upendra Shah* Patel by way of
gift
December Upendra T Shah Nanubhai Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Popatbhai Patel equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Shamjibhai Transfer of (500) 10 Nil Gift
01, 2010 & Purnima Gangarambhai equity shares
Upendra Shah* Vasoya by way of
gift
December Upendra T Shah Babubhai Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Premjibhai equity shares
Upendra Shah* Sukhadiya by way of
gift
December Upendra T Shah Jagdishkumar Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Gopalbhai equity shares
Upendra Shah* Rakholiya by way of
gift
December Upendra T Shah Viral Transfer of (500) 10 Nil Gift
01, 2010 & Purnima Rameshchandra equity shares
Upendra Shah* Bhatt & Rajni by way of
Ambalal Patel* gift
December Upendra T Shah Kirankumar Patel Transfer of (300) 10 Nil Gift
01, 2010 & Purnima & Jyotsna Patel* equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Champaben G Transfer of (500) 10 Nil Gift
01, 2010 & Purnima Patel equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Bhikhabhai Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Trikambhai Patel equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Nilay Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Ghanshyambhai equity shares
Upendra Shah* Pandya by way of
gift
December Upendra T Shah Shamalbhai Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Mulchandbhai equity shares
Upendra Shah* Gajjar & by way of
Arunaben gift
Shamalbhai
Gajjar*
206Date of Name of Name of Nature of Number of Face Transfe Nature of
transfer transferor transferee transaction equity value r price consideratio
shares per per n
transferre equit equity
d y share
share (₹)
(₹)
December Upendra T Shah Kajal Sandip Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Vasani equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Rajendra Transfer of (400) 10 Nil Gift
01, 2010 & Purnima Chandulal Shah equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Prakash K Shah & Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Sujay P Shah & equity shares
Upendra Shah* Parool P Shah* by way of
gift
December Upendra T Shah Urmil Anubhai Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Shah equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Gitaben Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Hitendrabhai equity shares
Upendra Shah* Patel by way of
gift
December Upendra T Shah Dayma Ashok Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Babulal equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Chandubhai Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Haribhai Patel equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Dipika Nikul Patel Transfer of (300) 10 Nil Gift
01, 2010 & Purnima & Nikul Jitendra equity shares
Upendra Shah* Patel* by way of
gift
December Upendra T Shah Darshan Aroon Transfer of (500) 10 Nil Gift
01, 2010 & Purnima Shah equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Jigar Modi & Transfer of (500) 10 Nil Gift
01, 2010 & Purnima Vidhyaben Modi* equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Vidyaben Modi & Transfer of (500) 10 Nil Gift
01, 2010 & Purnima Jigar Modi* equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Vinodbhai Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Somabhai Patel equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Nilam Sanjaybhai Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Patel equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Sanjay Vinodbhai Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Patel equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Mittal N Patel Transfer of (500) 10 Nil Gift
01, 2010 & Purnima equity shares
Upendra Shah*
207Date of Name of Name of Nature of Number of Face Transfe Nature of
transfer transferor transferee transaction equity value r price consideratio
shares per per n
transferre equit equity
d y share
share (₹)
(₹)
by way of
gift
December Upendra T Shah Visnuprasad Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Shivlal Patel equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Savitaben Transfer of (500) 10 Nil Gift
01, 2010 & Purnima Natverbhai Patel equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Krishna Natubhai Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Patel equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Natverlal Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Haribhai Patel equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Chandrakant Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Dave & Jyotiben equity shares
Upendra Shah* Dave* by way of
gift
December Upendra T Shah Jyotiben Dave & Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Chandrakant equity shares
Upendra Shah* Dave* by way of
gift
December Upendra T Shah Divya Prakash Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Gera & Neeti equity shares
Upendra Shah* Prakash Gera* by way of
gift
December Upendra T Shah Ramesh C Shah & Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Shobana R Shah* equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Kishanlal Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Ramchand equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Manishkumar Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Kishanlal equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Rita Kishanlal Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Shajwani equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Bhumika Mahesh Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Shajwani equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Mahesh Kishanlal Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Shajwani equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Shrenik Mohanlal Transfer of (600) 10 Nil Gift
01, 2010 & Purnima Shah equity shares
Upendra Shah* by way of
gift
208Date of Name of Name of Nature of Number of Face Transfe Nature of
transfer transferor transferee transaction equity value r price consideratio
shares per per n
transferre equit equity
d y share
share (₹)
(₹)
December Upendra T Shah Sukesh Mohanlal Transfer of (600) 10 Nil Gift
01, 2010 & Purnima Shah equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Lalita Ashok Shah Transfer of (600) 10 Nil Gift
01, 2010 & Purnima equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Sanjay Mohanlal Transfer of (600) 10 Nil Gift
01, 2010 & Purnima Shah equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Jyotsanaben S Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Patel equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Kaushik Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Bhikhbhai Patel & equity shares
Upendra Shah* Kamini by way of
Kaushikbhai gift
Patel*
December Upendra T Shah Ganpatbhai Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Ambalal Patel equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Komalben G Patel Transfer of (300) 10 Nil Gift
01, 2010 & Purnima equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Prahaldbhai Patel Transfer of (300) 10 Nil Gift
01, 2010 & Purnima equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Naresh Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Hargovindbhai equity shares
Upendra Shah* Patel by way of
gift
December Upendra T Shah Sonal Sanjay Shah Transfer of (300) 10 Nil Gift
01, 2010 & Purnima equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Truptiben Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Hiteshbhai Shah equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Rupa Sunil Shah Transfer of (300) 10 Nil Gift
01, 2010 & Purnima equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Kaushal Transfer of (500) 10 Nil Gift
01, 2010 & Purnima Kailaschandra equity shares
Upendra Shah* Dalal & Kajal by way of
Kaushal Dalal* gift
December Upendra T Shah Kajal Kaushal Transfer of (500) 10 Nil Gift
01, 2010 & Purnima Dalal & Kaushal equity shares
Upendra Shah* Kailaschandra by way of
Dalal* gift
209Date of Name of Name of Nature of Number of Face Transfe Nature of
transfer transferor transferee transaction equity value r price consideratio
shares per per n
transferre equit equity
d y share
share (₹)
(₹)
December Upendra T Shah Ashokbhai Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Prajapati & equity shares
Upendra Shah* Seemaben by way of
Prajapati* gift
December Upendra T Shah Seemaben Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Prajapati & equity shares
Upendra Shah* Ashokbhai by way of
Prajapati* gift
December Upendra T Shah Nayana Devendra Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Patel equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Davendra Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Somabhai Patel equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Jimil Chokshi Transfer of (300) 10 Nil Gift
01, 2010 & Purnima equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Amrutbhai R Transfer of (500) 10 Nil Gift
01, 2010 & Purnima Chaudhari equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Rajesh Pahlajrai Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Chellani equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Suman Rajesh Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Chellani equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Bhavana Manoj Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Dalal equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Manoj Ramchand Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Dalal equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Ramiben Transfer of (500) 10 Nil Gift
01, 2010 & Purnima Amrutbhai equity shares
Upendra Shah* Chaudhari & by way of
Amrutbhai gift
Ramanlal
Chaudhari*
December Upendra T Shah Kaushikbhai Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Dahyabhai Patel equity shares
Upendra Shah* & Parulben by way of
Kaushikbhai gift
Patel*
December Upendra T Shah Kamlesh Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Dahyabhai Patel equity shares
Upendra Shah* & Ragini Kamlesh by way of
Patel* gift
December Upendra T Shah Arvindbhai Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Dahyabhai Patel equity shares
Upendra Shah* & Renukaben by way of
Arvindbhai Patel* gift
210Date of Name of Name of Nature of Number of Face Transfe Nature of
transfer transferor transferee transaction equity value r price consideratio
shares per per n
transferre equit equity
d y share
share (₹)
(₹)
December Upendra T Shah Pohapsingh Yadav Transfer of (400) 10 Nil Gift
01, 2010 & Purnima & Daksha P equity shares
Upendra Shah* Yadav* by way of
gift
December Upendra T Shah Khurshidbanu Transfer of (400) 10 Nil Gift
01, 2010 & Purnima Parwala & equity shares
Upendra Shah* Parvesz Parwala* by way of
gift
December Upendra T Shah Vinoda Kirti Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Mehta equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Budhalal Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Chimanlal equity shares
Upendra Shah* Kuvadia & by way of
Manjula Budhlal gift
Kuvadia*
December Upendra T Shah Indiraben Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Jayantilal Shah & equity shares
Upendra Shah* Jayantilal Kantilal by way of
Shah* gift
December Upendra T Shah Vishal Jayantilal Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Shah equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Gemarbhai M Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Patel equity shares
Upendra Shah* by way of
gift
December Upendra T Shah KalpaN.A. Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Manish Mehta equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Sejal Ronakbhai Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Dalal & Ronak equity shares
Upendra Shah* Sarvadamanbhai by way of
Dalal* gift
December Upendra T Shah Minesh Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Indravadan Shah equity shares
Upendra Shah* & Nila Shah* by way of
gift
December Upendra T Shah Ajay Shah Transfer of (300) 10 Nil Gift
01, 2010 & Purnima equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Jawahar Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Gopichand equity shares
Upendra Shah* Kapoor by way of
gift
December Upendra T Shah Anuj Jain Transfer of (500) 10 Nil Gift
01, 2010 & Purnima equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Kanan Sanjay Transfer of (500) 10 Nil Gift
01, 2010 & Purnima Dalal & Sanjay equity shares
Upendra Shah* Sarabhai* by way of
gift
211Date of Name of Name of Nature of Number of Face Transfe Nature of
transfer transferor transferee transaction equity value r price consideratio
shares per per n
transferre equit equity
d y share
share (₹)
(₹)
December Upendra T Shah Sheela Ajay Dalal Transfer of (500) 10 Nil Gift
01, 2010 & Purnima & Ajay Sarabhai equity shares
Upendra Shah* Dalal* by way of
gift
December Upendra T Shah Kanubhai Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Hargovandas equity shares
Upendra Shah* Patel by way of
gift
December Upendra T Shah Sonal Deepakbhai Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Shah & Deepak equity shares
Upendra Shah* Sumtilal Shah* by way of
gift
December Upendra T Shah Naveen Kejriwal Transfer of (500) 10 Nil Gift
01, 2010 & Purnima equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Vimal Dairy Transfer of (600) 10 Nil Gift
01, 2010 & Purnima Limited equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Trivedi Sneha Transfer of (300) 10 Nil Gift
01, 2010 & Purnima equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Jitendra Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Chandulal Modi equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Bumika Kapadia Transfer of (300) 10 Nil Gift
01, 2010 & Purnima equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Kiritkumar Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Ramanlal Patel equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Siddharth Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Shantilal Dikshit equity shares
Upendra Shah* & Sheelaben by way of
Shantilal Dikshit* gift
December Upendra T Shah Dave Dhruva Transfer of (700) 10 Nil Gift
01, 2010 & Purnima Hardikkumar & equity shares
Upendra Shah* Hardik Kumar by way of
Dave* gift
December Upendra T Shah Dave Tilottama Transfer of (100) 10 Nil Gift
01, 2010 & Purnima Harvadan & Dave equity shares
Upendra Shah* Hardikkumar* by way of
gift
December Upendra T Shah Deepakbhai Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Sumitlal Shah & equity shares
Upendra Shah* Sonalben by way of
Dipakbhai Shah* gift
December Upendra T Shah Rutvi Transfer of (700) 10 Nil Gift
01, 2010 & Purnima Deepakkumar equity shares
Upendra Shah* Shah by way of
gift
December Upendra T Shah Sanjay Sumitlal Transfer of (700) 10 Nil Gift
01, 2010 & Purnima Shah & Rupalben equity shares
Upendra Shah* Sanjay Shah*
212Date of Name of Name of Nature of Number of Face Transfe Nature of
transfer transferor transferee transaction equity value r price consideratio
shares per per n
transferre equit equity
d y share
share (₹)
(₹)
by way of
gift
December Upendra T Shah Rupal Sanjay Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Shah equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Nalin Sumatilal Transfer of (700) 10 Nil Gift
01, 2010 & Purnima Shah & Rujula equity shares
Upendra Shah* Nalin Shah* by way of
gift
December Upendra T Shah Aman Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Nalinkumar Shah equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Manish Babulal Transfer of (700) 10 Nil Gift
01, 2010 & Purnima Vaghasia equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Sangeeta Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Manishbhai equity shares
Upendra Shah* Vaghasia by way of
gift
December Upendra T Shah Kanchan Transfer of (700) 10 Nil Gift
01, 2010 & Purnima Nareshbhai Patel equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Nikita Nareshbhai Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Patel equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Amit Ashokbhai Transfer of (700) 10 Nil Gift
01, 2010 & Purnima Parikh equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Ashokbhai Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Nemchand Parikh equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Trupti Mehta Transfer of (700) 10 Nil Gift
01, 2010 & Purnima equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Surekha Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Vinodchandra equity shares
Upendra Shah* Mehta by way of
gift
December Upendra T Shah Bhumita Transfer of (700) 10 Nil Gift
01, 2010 & Purnima Hiteshbhai equity shares
Upendra Shah* Sanghvi & Hitesh by way of
Batuklal Sanghvi* gift
December Upendra T Shah Dhwani Hitesh Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Sanghvi equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Vinod Mehta Transfer of (700) 10 Nil Gift
01, 2010 & Purnima equity shares
Upendra Shah* by way of
gift
213Date of Name of Name of Nature of Number of Face Transfe Nature of
transfer transferor transferee transaction equity value r price consideratio
shares per per n
transferre equit equity
d y share
share (₹)
(₹)
December Upendra T Shah Surekha Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Vinodchandra equity shares
Upendra Shah* Mehta by way of
gift
December Upendra T Shah Narendrakumar Transfer of (700) 10 Nil Gift
01, 2010 & Purnima Joshi equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Hansaben Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Narendrakumar equity shares
Upendra Shah* Joshi by way of
gift
December Upendra T Shah Janak Transfer of (700) 10 Nil Gift
01, 2010 & Purnima Narendrakumar equity shares
Upendra Shah Joshi by way of
gift
December Upendra T Shah Hiral Janakkumar Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Joshi equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Darshan Transfer of (700) 10 Nil Gift
01, 2010 & Purnima Bharatbhai Patel equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Priti Darshan Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Patel equity shares
Upendra Shah* by way of
gift
December Upendra T Shah J.D. Saraiya Transfer of (700) 10 Nil Gift
01, 2010 & Purnima equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Ushaben J. Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Saraiya & equity shares
Upendra Shah* Mamata J Saraiya by way of
gift
December Upendra T Shah Kamleshbhai Transfer of (700) 10 Nil Gift
01, 2010 & Purnima Patel equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Kevalbhai K. Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Patel equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Malaben B. Rohra Transfer of (700) 10 Nil Gift
01, 2010 & Purnima equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Bansilal Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Thakurdas Rohra equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Dharmesh Transfer of (700) 10 Nil Gift
01, 2010 & Purnima Odhavjibhai equity shares
Upendra Shah* Savani by way of
gift
December Upendra T Shah Bhaveshkumar Transfer of (400) 10 Nil Gift
01, 2010 & Purnima Odhavjibhai equity shares
Upendra Shah* Savani
214Date of Name of Name of Nature of Number of Face Transfe Nature of
transfer transferor transferee transaction equity value r price consideratio
shares per per n
transferre equit equity
d y share
share (₹)
(₹)
by way of
gift
December Upendra T Shah Nirmala Upendra Transfer of (700) 10 Nil Gift
01, 2010 & Purnima Savani equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Upendra Transfer of (500) 10 Nil Gift
01, 2010 & Purnima Odhavjibhai equity shares
Upendra Shah* Savani by way of
gift
December Upendra T Shah Piyush Doshi Transfer of (700) 10 Nil Gift
01, 2010 & Purnima equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Minal Piyush Transfer of (700) 10 Nil Gift
01, 2010 & Purnima Doshi equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Jayantibhai Transfer of (700) 10 Nil Gift
01, 2010 & Purnima Bhikhabhai Patel equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Vidhyaben Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Jayantibhai Patel equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Sunil Prahladbhai Transfer of (1,000) 10 Nil Gift
01, 2010 & Purnima Sevani equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Kiranben Transfer of (1,000) 10 Nil Gift
01, 2010 & Purnima Sunilbhai Sevani equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Bunty Hundraj Transfer of (1,000) 10 Nil Gift
01, 2010 & Purnima Devnani equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Hundraj Transfer of (1,000) 10 Nil Gift
01, 2010 & Purnima Govindram equity shares
Upendra Shah* Devnani by way of
gift
December Upendra T Shah Manoj Arjundas Transfer of (1,000) 10 Nil Gift
01, 2010 & Purnima Chhabadia equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Rajkumar Transfer of (1,000) 10 Nil Gift
01, 2010 & Purnima Devnani equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Dixitkumar Transfer of (700) 10 Nil Gift
01, 2010 & Purnima Dashrathbhai equity shares
Upendra Shah* Patel by way of
gift
December Upendra T Shah Priti Dixitkumar Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Patel equity shares
Upendra Shah* by way of
gift
215Date of Name of Name of Nature of Number of Face Transfe Nature of
transfer transferor transferee transaction equity value r price consideratio
shares per per n
transferre equit equity
d y share
share (₹)
(₹)
December Upendra T Shah Sanjaykumar Transfer of (700) 10 Nil Gift
01, 2010 & Purnima Rameshbhai Patel equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Anitaben Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Sanjaykumar equity shares
Upendra Shah* Patel by way of
gift
December Upendra T Shah Prahash Fin-Stock Transfer of (700) 10 Nil Gift
01, 2010 & Purnima Pvt Ltd equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Bharatbhai P. Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Patel equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Meghnaben Transfer of (700) 10 Nil Gift
01, 2010 & Purnima Kumarbhai Mehta equity shares
Upendra Shah* & Kumarbhai by way of
Pratapbhai gift
Mehta*
December Upendra T Shah Ansuya P. Mehta Transfer of (300) 10 Nil Gift
01, 2010 & Purnima equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Hansaben Transfer of (700) 10 Nil Gift
01, 2010 & Purnima Mahendrabhai equity shares
Upendra Shah* Mehta & by way of
Mahendrabhai gift
Chandulal Mehta*
December Upendra T Shah Ansuya P. Mehta Transfer of (300) 10 Nil Gift
01, 2010 & Purnima equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Mahendrbhai Transfer of (700) 10 Nil Gift
01, 2010 & Purnima Chandulal Mehta equity shares
Upendra Shah* & Hansaben by way of
Mahendrabhai gift
Mehta*
December Upendra T Shah Jasica M. Mehta Transfer of (300) 10 Nil Gift
01, 2010 & Purnima equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Chintan Transfer of (700) 10 Nil Gift
01, 2010 & Purnima Mahendrabhai equity shares
Upendra Shah* Mehta by way of
gift
December Upendra T Shah Jasica M. Mehta Transfer of (300) 10 Nil Gift
01, 2010 & Purnima equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Monali Transfer of (700) 10 Nil Gift
01, 2010 & Purnima Divyeshbhai Shah equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Divyeshbhai Shah Transfer of (300) 10 Nil Gift
01, 2010 & Purnima equity shares
Upendra Shah* by way of
gift
216Date of Name of Name of Nature of Number of Face Transfe Nature of
transfer transferor transferee transaction equity value r price consideratio
shares per per n
transferre equit equity
d y share
share (₹)
(₹)
December Upendra T Shah Sudhir Venkatesh Transfer of (1,000) 10 Nil Gift
01, 2010 & Purnima Kulkarni & equity shares
Upendra Shah* Pushpa Sudhir by way of
Kulkarni* gift
December Upendra T Shah Ajaykumar N Transfer of (1,000) 10 Nil Gift
01, 2010 & Purnima Chaudhari equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Alpa Bhaveshbhai Transfer of (1,000) 10 Nil Gift
01, 2010 & Purnima Patel equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Rajiv Narsinhbhai Transfer of (700) 10 Nil Gift
01, 2010 & Purnima Patel & Bindu equity shares
Upendra Shah* Rajiv Patel* by way of
gift
December Upendra T Shah Bindu R Patel & Transfer of (200) 10 Nil Gift
01, 2010 & Purnima Rajiv N Patel* equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Rajiv Narsinhbhai Transfer of (100) 10 Nil Gift
01, 2010 & Purnima Patel-HUF equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Shyamal T Rohra Transfer of (700) 10 Nil Gift
01, 2010 & Purnima equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Kanta Shyamlal Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Rohra equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Kumarbhai Transfer of (700) 10 Nil Gift
01, 2010 & Purnima Pratapbhai Mehta equity shares
Upendra Shah* & Meghanben by way of
Kumarbhai gift
Mehta*
December Upendra T Shah Pratapbhai C Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Mehta equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Sharad Transfer of (1,200) 10 Nil Gift
01, 2010 & Purnima Bipinchandra equity shares
Upendra Shah* Patel by way of
gift
December Upendra T Shah Rekha Doshi Transfer of (700) 10 Nil Gift
01, 2010 & Purnima equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Ujas Piyush Doshi Transfer of (700) 10 Nil Gift
01, 2010 & Purnima equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Harshad Vyas & Transfer of (700) 10 Nil Gift
01, 2010 & Purnima Kheemashanker equity shares
Upendra Shah* Vyas* by way of
gift
217Date of Name of Name of Nature of Number of Face Transfe Nature of
transfer transferor transferee transaction equity value r price consideratio
shares per per n
transferre equit equity
d y share
share (₹)
(₹)
December Upendra T Shah Manjula Transfer of (300) 10 Nil Gift
01, 2010 & Purnima Kheemashanker equity shares
Upendra Shah* Vyas by way of
gift
December Upendra T Shah Sheetal Vyas & Transfer of (700) 10 Nil Gift
01, 2010 & Purnima Arunkumar equity shares
Upendra Shah* Babulal Vyas* by way of
gift
December Upendra T Shah Arunkumar Transfer of (700) 10 Nil Gift
01, 2010 & Purnima Babulal Vyas- equity shares
Upendra Shah* HUF by way of
gift
December Upendra T Shah Shantiben Transfer of (700) 10 Nil Gift
01, 2010 & Purnima Narsinhbhai Patel equity shares
Upendra Shah* & Rajiv by way of
Narsinghbhai gift
Patel & Bindu
Rajiv Patel*
December Upendra T Shah Rajiv Narsinhbhai Transfer of (800) 10 Nil Gift
01, 2010 & Purnima Patel-HUF equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Shreyans Rasiklal Transfer of (700) 10 Nil Gift
01, 2010 & Purnima Doshi equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Riddhi Transfer of (700) 10 Nil Gift
01, 2010 & Purnima Shreyansbhai equity shares
Upendra Shah* Doshi by way of
gift
December Upendra T Shah Bijal Rakeshbhai Transfer of (600) 10 Nil Gift
01, 2010 & Purnima Doshi equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Swati Binod Transfer of (700) 10 Nil Gift
01, 2010 & Purnima Agarwal equity shares
Upendra Shah* by way of
gift
December Upendra T Shah Madhu Agrawal Transfer of (300) 10 Nil Gift
01, 2010 & Purnima equity shares
Upendra Shah* by way of
gift
August Kalpesh Thaker Upendra T Shah & Transfer 600 10 80 Cash
23, 2011 & Ila Thaker Purnima Upendra
Shah*
August Ila Thaker & Upendra T Shah & Transfer 600 10 80 Cash
23, 2011 Kalpesh Thaker Purnima Upendra
Shah*
July 04, Mayur Manubhai Upendra T Shah & Transfer 600 10 10 Cash
2012 Parikh Purnima Upendra
Shah*
July 04, Sushma Mayoor Upendra T Shah & Transfer 600 10 10 Cash
2012 Parikh Purnima Upendra
Shah*
July 10, Arvindbhai Upendra T Shah & Transfer 600 10 75 Cash
2012 Chandulal Purnima Upendra
Chokshi Shah*
218Date of Name of Name of Nature of Number of Face Transfe Nature of
transfer transferor transferee transaction equity value r price consideratio
shares per per n
transferre equit equity
d y share
share (₹)
(₹)
August 7, Jimil B. choksi Upendra T Shah & Transfer 600 10 75 Cash
2012 Purnima Upendra
Shah*
Septembe Harivadan Upendra T Shah & Transfer 600 10 75 Cash
r 22, 2012 Shivlal Bhavsar Purnima Upendra
Shah*
Septembe Shah Dakshaben Upendra T Shah & Transfer 600 10 75 Cash
r 22, 2012 pravinchandra Purnima Upendra
Shah*
October Sejal Ronakbhai Upendra T Shah & Transfer 600 10 10 Cash
19, 2012 Dalal & Ronak Purnima Upendra
Sarvadamanbhai Shah*
Dalal*
October Navin Kejrival Upendra T Shah & Transfer 500 10 10 Cash
19, 2012 Purnima Upendra
Shah*
October Archana Parikh Upendra T Shah & Transfer 600 10 10 Cash
19, 2012 & Ketan Parikh Purnima Upendra
Shah*
October Ganpatbhai Upendra T Shah & Transfer 600 10 10 Cash
19, 2012 Ambalal Patel Purnima Upendra
Shah*
October Komalben G Upendra T Shah & Transfer 600 10 10 Cash
19, 2012 Patel Purnima Upendra
Shah*
October Kalpeshbhai Upendra T Shah & Transfer 600 10 75 Cash
20, 2012 Rasiklal Purnima Upendra
Shah*
January Bharatkumar Upendra T Shah & Transfer 600 10 75 Cash
31, 2013 Amratlal Shah & Purnima Upendra
Pannaben Shah*
Bharatkumar*
March 9, Upendra T Shah Maulika N Gandhi Transfer of (400) 10 Nil Gift
2013 & Purnima equity shares
Upendra Shah* by way of
gift
March 9, Upendra T Shah Sanjay A. Mehta Transfer of (600) 10 Nil Gift
2013 & Purnima equity shares
Upendra Shah* by way of
gift
March 9, Upendra T Shah Jignesh N. Shukla Transfer of (600) 10 Nil Gift
2013 & Purnima equity shares
Upendra Shah* by way of
gift
March 9, Upendra T Shah Nilesh G. Modi Transfer of (600) 10 Nil Gift
2013 & Purnima equity shares
Upendra Shah* by way of
gift
March 9, Upendra T Shah Kaivan R. Shah Transfer of (600) 10 Nil Gift
2013 & Purnima equity shares
Upendra Shah* by way of
gift
March 9, Upendra T Shah Chirag V. Shah Transfer of (600) 10 Nil Gift
2013 & Purnima equity shares
Upendra Shah* by way of
gift
March 9, Upendra T Shah Hitesh C Patel Transfer of (600) 10 Nil Gift
2013 & Purnima equity shares
Upendra Shah*
219Date of Name of Name of Nature of Number of Face Transfe Nature of
transfer transferor transferee transaction equity value r price consideratio
shares per per n
transferre equit equity
d y share
share (₹)
(₹)
by way of
gift
March 9, Upendra T Shah Rekha D. Vohra Transfer of (600) 10 Nil Gift
2013 & Purnima equity shares
Upendra Shah* by way of
gift
March 9, Upendra T Shah Jayesh D. Transfer of (600) 10 Nil Gift
2013 & Purnima Pittalaya equity shares
Upendra Shah* by way of
gift
March 9, Upendra T Shah Samir R Shah Transfer of (600) 10 Nil Gift
2013 & Purnima equity shares
Upendra Shah* by way of
gift
March 9, Upendra T Shah Sanjay H. Mistry Transfer of (600) 10 Nil Gift
2013 & Purnima equity shares
Upendra Shah* by way of
gift
March 9, Upendra T Shah Kanubhai Transfer of (600) 10 Nil Gift
2013 & Purnima Prajapati equity shares
Upendra Shah* by way of
gift
March 9, Upendra T Shah Bhadresh h. Transfer of (600) 10 Nil Gift
2013 & Purnima Punjabi equity shares
Upendra Shah* by way of
gift
March 9, Upendra T Shah Vishal D. Parikh Transfer of (600) 10 Nil Gift
2013 & Purnima equity shares
Upendra Shah* by way of
gift
March 9, Upendra T Shah Umesh B. Transfer of (600) 10 Nil Gift
2013 & Purnima sathwara equity shares
Upendra Shah* by way of
gift
March 9, Upendra T Shah Jinal Shah Transfer of (600) 10 Nil Gift
2013 & Purnima equity shares
Upendra Shah* by way of
gift
March 9, Upendra T Shah Bhavini R. shah Transfer of (600) 10 Nil Gift
2013 & Purnima equity shares
Upendra Shah* by way of
gift
March 9, Upendra T Shah Paresh M. Jansari Transfer of (600) 10 Nil Gift
2013 & Purnima equity shares
Upendra Shah* by way of
gift
March 9, Upendra T Shah Hemant Roy Transfer of (600) 10 Nil Gift
2013 & Purnima equity shares
Upendra Shah* by way of
gift
March 9, Upendra T Shah Baiju M. Patel Transfer of (400) 10 Nil Gift
2013 & Purnima equity shares
Upendra Shah* by way of
gift
March 9, Upendra T Shah Janak Shah Transfer of (400) 10 Nil Gift
2013 & Purnima equity shares
Upendra Shah* by way of
gift
220Date of Name of Name of Nature of Number of Face Transfe Nature of
transfer transferor transferee transaction equity value r price consideratio
shares per per n
transferre equit equity
d y share
share (₹)
(₹)
March 9, Upendra T Shah Shah Bhavi A. Transfer of (400) 10 Nil Gift
2013 & Purnima equity shares
Upendra Shah* by way of
gift
March 9, Upendra T Shah Shah Shalvi R. Transfer of (400) 10 Nil Gift
2013 & Purnima equity shares
Upendra Shah* by way of
gift
March 9, Upendra T Shah Bharat I. Patel Transfer of (400) 10 Nil Gift
2013 & Purnima equity shares
Upendra Shah* by way of
gift
March 9, Upendra T Shah Shah Vatsal S. Transfer of (400) 10 Nil Gift
2013 & Purnima equity shares
Upendra Shah* by way of
gift
March 9, Upendra T Shah Nirav R. Patel Transfer of (400) 10 Nil Gift
2013 & Purnima equity shares
Upendra Shah* by way of
gift
March 9, Upendra T Shah Kamlesh M. Transfer of (400) 10 Nil Gift
2013 & Purnima Vaghela equity shares
Upendra Shah* by way of
gift
March 9, Upendra T Shah Rupang B. Shah Transfer of (400) 10 Nil Gift
2013 & Purnima equity shares
Upendra Shah* by way of
gift
March 12, Upendra T Shah Mukesh Transfer (600) 10 Nil N.A.
2013# & Purnima Naranbhai
Upendra Shah* Kanodia
March 12, Upendra T Shah Gaurang Transfer (600) 10 Nil N.A.
2013# & Purnima Madhubhai Shah
Upendra Shah*
March 20, Rakesh Upendra T Shah & Transfer 600 10 75 Cash
2013# Govindlal Purnima Upendra
Thaker Shah*
March 20, Upendra T Shah Pearl Shah Transfer (20,000) 10 Nil N.A.
2013# & Purnima
Upendra Shah*
March 20, Upendra T Shah Kenisha Tanmay Transfer (20,000) 10 Nil N.A.
2013# & Purnima Shah
Upendra Shah*
March 20, Upendra T Shah Aashna Utpal Transfer (10,000) 10 Nil N.A.
2013# & Purnima Shah
Upendra Shah*
March 20, Upendra T Shah Rehaan Utpal Transfer (10,000) 10 Nil N.A.
2013# & Purnima Shah
Upendra Shah*
March 20, Upendra T Shah Ruchira Tanmay Transfer (20,100) 10 Nil N.A.
2013# & Purnima Shah
Upendra Shah*
March 20, Upendra T Shah Shah Ritesh Transfer (200) 10 Nil N.A.
2013# & Purnima Pankajkumar
Upendra Shah*
March 20, Upendra T Shah Ankit P. Shah Transfer (200) 10 Nil N.A.
2013# & Purnima
Upendra Shah*
221Date of Name of Name of Nature of Number of Face Transfe Nature of
transfer transferor transferee transaction equity value r price consideratio
shares per per n
transferre equit equity
d y share
share (₹)
(₹)
March 20, Upendra T Shah Shah Khushali Transfer (200) 10 Nil N.A.
2013# & Purnima Pankajkumar
Upendra Shah*
March 20, Upendra T Shah Panchal Bhavin A. Transfer (200) 10 Nil N.A.
2013# & Purnima
Upendra Shah*
March 20, Upendra T Shah Saurin Transfer (200) 10 Nil N.A.
2013# & Purnima Pravinchandra
Upendra Shah* Shah
March 20, Upendra T Shah Shah Alap Transfer (200) 10 Nil N.A.
2013# & Purnima Sudhirbhai
Upendra Shah*
March 20, Upendra T Shah Sathvara Transfer (200) 10 Nil N.A.
2013# & Purnima Pradipkumar
Upendra Shah* Bakulbhai
March 21, Upendra T Shah Mehul D. Patel Transfer of (200) 10 Nil Gift
2013 & Purnima equity shares
Upendra Shah* by way of
gift
March 21, Shah Niraj Upendra T Shah & Transfer 1200 10 75 Cash
2013 Dilipkumar HUF Purnima Upendra
Shah*
March 21, Shah Dilip Upendra T Shah & Transfer 1200 10 75 Cash
2013 Rasiklal HUF Purnima Upendra
Shah*
March 21, Upendra T Shah Sameer Transfer of (200) 10 Nil Gift
2013 & Purnima Chiplankar equity shares
Upendra Shah* by way of
gift
March 21, Upendra T Shah Jaidev Singh Transfer of (200) 10 Nil Gift
2013 & Purnima Chundavat equity shares
Upendra Shah* by way of
gift
March 21, Upendra T Shah Kirit Macwan Transfer of (200) 10 Nil Gift
2013 & Purnima equity shares
Upendra Shah* by way of
gift
March 21, Upendra T Shah Avinash khanna Transfer of (200) 10 Nil Gift
2013 & Purnima equity shares
Upendra Shah* by way of
gift
April 8, Nikunj Ramanlal Upendra T Shah & Transfer 600 10 75 Cash
2013 Desai Purnima Upendra
Shah*
April 12, Indiraben Upendra T Shah & Transfer 600 10 75 Cash
2013 Jayantilal Shah Purnima Upendra
Shah*
April 22, Upendra T Shah A.C. Dalal Transfer of (300) 10 Nil Gift
2013 & Purnima equity shares
Upendra Shah* by way of
gift
April 22, Upendra T Shah Ashokumar Shah Transfer of (300) 10 Nil Gift
2013 & Purnima equity shares
Upendra Shah* by way of
gift
April 22, Upendra T Shah Poornima Shah Transfer of (300) 10 Nil Gift
2013 & Purnima equity shares
Upendra Shah* by way of
gift
222Date of Name of Name of Nature of Number of Face Transfe Nature of
transfer transferor transferee transaction equity value r price consideratio
shares per per n
transferre equit equity
d y share
share (₹)
(₹)
April 22, Upendra T Shah Darshan Aroon Transfer of (500) 10 Nil Gift
2013 & Purnima Shah equity shares
Upendra Shah* by way of
gift
April 22, Upendra T Shah Neha Patel Transfer of (300) 10 Nil Gift
2013 & Purnima equity shares
Upendra Shah* by way of
gift
April 22, Upendra T Shah Kajal Kaushal Transfer of (500) 10 Nil Gift
2013 & Purnima Dalal equity shares
Upendra Shah* by way of
gift
April 22, Upendra T Shah Kushal K. Dalal Transfer of (500) 10 Nil Gift
2013 & Purnima equity shares
Upendra Shah* by way of
gift
April 22, Upendra T Shah Bipinchandra B. Transfer of (300) 10 Nil Gift
2013 & Purnima Patel equity shares
Upendra Shah* by way of
gift
April 22, Upendra T Shah Rasiklal M. Doshi Transfer of (675) 10 Nil Gift
2013 & Purnima equity shares
Upendra Shah* by way of
gift
April 23, Upendra T Shah Akash Transfer of (500) 10 Nil Gift
2013 & Purnima Nalinkumar Shah equity shares
Upendra Shah* by way of
gift
April 23, Upendra T Shah Aman Transfer of (150) 10 Nil Gift
2013 & Purnima Nalinkumar Shah equity shares
Upendra Shah* by way of
gift
April 23, Upendra T Shah Anand Ashvin Transfer of (500) 10 Nil Gift
2013 & Purnima Dalal equity shares
Upendra Shah* by way of
gift
April 23, Upendra T Shah Anil Baldevbhai Transfer of (300) 10 Nil Gift
2013 & Purnima Patel equity shares
Upendra Shah* by way of
gift
April 23, Upendra T Shah Arvindbhai Transfer of (300) 10 Nil Gift
2013 & Purnima Prabhudas Patel equity shares
Upendra Shah* by way of
gift
April 23, Upendra T Shah Bhauben Transfer of (300) 10 Nil Gift
2013 & Purnima Natverlal Shah equity shares
Upendra Shah* by way of
gift
April 23, Upendra T Shah Bharat Natverlal Transfer of (300) 10 Nil Gift
2013 & Purnima Shah equity shares
Upendra Shah* by way of
gift
April 23, Upendra T Shah Bharati Dinesh Transfer of (600) 10 Nil Gift
2013 & Purnima Desai equity shares
Upendra Shah* by way of
gift
April 23, Upendra T Shah Bhavini Transfer of (300) 10 Nil Gift
2013 & Purnima Rupeshbhai Shah equity shares
Upendra Shah*
223Date of Name of Name of Nature of Number of Face Transfe Nature of
transfer transferor transferee transaction equity value r price consideratio
shares per per n
transferre equit equity
d y share
share (₹)
(₹)
by way of
gift
April 23, Upendra T Shah Bijal Rakeshbhai Transfer of (300) 10 Nil Gift
2013 & Purnima Doshi equity shares
Upendra Shah* by way of
gift
April 23, Upendra T Shah Bindu R Patel Transfer of (100) 10 Nil Gift
2013 & Purnima equity shares
Upendra Shah* by way of
gift
April 23, Upendra T Shah Bindu Rajiv patel Transfer of (500) 10 Nil Gift
2013 & Purnima equity shares
Upendra Shah* by way of
gift
April 23, Upendra T Shah Budhalal Transfer of (300) 10 Nil Gift
2013 & Purnima Chimanlal equity shares
Upendra Shah* Kuvadia by way of
gift
April 23, Upendra T Shah Chandrakant Transfer of (300) 10 Nil Gift
2013 & Purnima Dave equity shares
Upendra Shah* by way of
gift
April 23, Upendra T Shah Chandresh R Soni Transfer of (300) 10 Nil Gift
2013 & Purnima equity shares
Upendra Shah* by way of
gift
April 23, Upendra T Shah Chandubhai Transfer of (300) 10 Nil Gift
2013 & Purnima Haribhai Patel equity shares
Upendra Shah* by way of
gift
April 23, Upendra T Shah Chintan S Parikh Transfer of (300) 10 Nil Gift
2013 & Purnima equity shares
Upendra Shah* by way of
gift
April 23, Upendra T Shah Davendra Transfer of (300) 10 Nil Gift
2013 & Purnima Somabhai Patel equity shares
Upendra Shah* by way of
gift
April 23, Upendra T Shah Deviben M Pujara Transfer of (300) 10 Nil Gift
2013 & Purnima equity shares
Upendra Shah* by way of
gift
April 23, Upendra T Shah Dharmesh Transfer of (300) 10 Nil Gift
2013 & Purnima Rasiklal Shah equity shares
Upendra Shah* by way of
gift
April 23, Upendra T Shah Dhruva Transfer of (750) 10 Nil Gift
2013 & Purnima Hardikkumar equity shares
Upendra Shah* Dave by way of
gift
April 23, Upendra T Shah Dilip R. soni Transfer of (300) 10 Nil Gift
2013 & Purnima equity shares
Upendra Shah* by way of
gift
April 23, Upendra T Shah Dinesh Shah Transfer of (700) 10 Nil Gift
2013 & Purnima equity shares
Upendra Shah* by way of
gift
224Date of Name of Name of Nature of Number of Face Transfe Nature of
transfer transferor transferee transaction equity value r price consideratio
shares per per n
transferre equit equity
d y share
share (₹)
(₹)
April 23, Upendra T Shah Dipika Jayesh Transfer of (300) 10 Nil Gift
2013 & Purnima Shah equity shares
Upendra Shah* by way of
gift
April 23, Upendra T Shah Gemarbhai M Transfer of (300) 10 Nil Gift
2013 & Purnima Patel equity shares
Upendra Shah* by way of
gift
April 23, Upendra T Shah Girish Transfer of (300) 10 Nil Gift
2013 & Purnima Hasmukhlal equity shares
Upendra Shah* Kotak by way of
gift
April 23, Upendra T Shah Gitaben Girish Transfer of (300) 10 Nil Gift
2013 & Purnima Kumar Kotak equity shares
Upendra Shah* by way of
gift
April 23, Upendra T Shah Gitaben Transfer of (300) 10 Nil Gift
2013 & Purnima Hitendrabhai equity shares
Upendra Shah* Patel by way of
gift
April 23, Upendra T Shah Gopal Natverlal Transfer of (300) 10 Nil Gift
2013 & Purnima Shah equity shares
Upendra Shah* by way of
gift
April 23, Upendra T Shah Govind Transfer of (300) 10 Nil Gift
2013 & Purnima Rukmanbhai equity shares
Upendra Shah* Nama by way of
gift
April 23, Upendra T Shah Hansaben Transfer of (150) 10 Nil Gift
2013 & Purnima Narendrakumar equity shares
Upendra Shah* Joshi by way of
gift
April 23, Upendra T Shah Hetal Transfer of (500) 10 Nil Gift
2013 & Purnima Kamleshbhai equity shares
Upendra Shah* Shah by way of
gift
April 23, Upendra T Shah Hinaben Dinesh Transfer of (300) 10 Nil Gift
2013 & Purnima Shah equity shares
Upendra Shah* by way of
gift
April 23, Upendra T Shah Hiral Janakkumar Transfer of (150) 10 Nil Gift
2013 & Purnima Joshi equity shares
Upendra Shah* by way of
gift
April 23, Upendra T Shah Hitendra Patel Transfer of (300) 10 Nil Gift
2013 & Purnima equity shares
Upendra Shah* by way of
gift
April 23, Upendra T Shah Hitesh Vithalbhai Transfer of (300) 10 Nil Gift
2013 & Purnima Patel equity shares
Upendra Shah* by way of
gift
April 23, Upendra T Shah Indravadan Shah Transfer of (300) 10 Nil Gift
2013 & Purnima equity shares
Upendra Shah* by way of
gift
April 23, Upendra T Shah J.D.Saraiya Transfer of (850) 10 Nil Gift
2013 & Purnima equity shares
Upendra Shah*
225Date of Name of Name of Nature of Number of Face Transfe Nature of
transfer transferor transferee transaction equity value r price consideratio
shares per per n
transferre equit equity
d y share
share (₹)
(₹)
by way of
gift
April 23, Upendra T Shah Jagruti Pravin Transfer of (300) 10 Nil Gift
2013 & Purnima Master equity shares
Upendra Shah* by way of
gift
April 23, Upendra T Shah Janak Transfer of (850) 10 Nil Gift
2013 & Purnima Narendrakumar equity shares
Upendra Shah* Joshi by way of
gift
April 23, Upendra T Shah Sobhana Transfer of (300) 10 Nil Gift
2013 & Purnima Janakkumar equity shares
Upendra Shah* Babaria by way of
gift
April 23, Upendra T Shah Jankiben Transfer of (150) 10 Nil Gift
2013 & Purnima Dharmendra equity shares
Upendra Shah* Kumar Patel by way of
gift
April 23, Upendra T Shah Jayesh Indravadan Transfer of (300) 10 Nil Gift
2013 & Purnima Shah equity shares
Upendra Shah* by way of
gift
April 23, Upendra T Shah Jayshree Patel Transfer of (300) 10 Nil Gift
2013 & Purnima equity shares
Upendra Shah* by way of
gift
April 23, Upendra T Shah Jyotiben Dave Transfer of (300) 10 Nil Gift
2013 & Purnima equity shares
Upendra Shah* by way of
gift
April 23, Upendra T Shah Jyotsana Rajendra Transfer of (300) 10 Nil Gift
2013 & Purnima Shah equity shares
Upendra Shah* by way of
gift
April 23, Upendra T Shah Kajal Sandip Transfer of (300) 10 Nil Gift
2013 & Purnima Vasani equity shares
Upendra Shah* by way of
gift
April 23, Upendra T Shah Kamlesh Transfer of (300) 10 Nil Gift
2013 & Purnima Jayantibhai Shah equity shares
Upendra Shah* by way of
gift
April 23, Upendra T Shah Kamleshbhai Transfer of (500) 10 Nil Gift
2013 & Purnima Patel equity shares
Upendra Shah* by way of
gift
April 23, Upendra T Shah Kanubha1 Transfer of (300) 10 Nil Gift
2013 & Purnima Hargovandas equity shares
Upendra Shah* Patel by way of
gift
April 23, Upendra T Shah Kundan Transfer of (500) 10 Nil Gift
2013 & Purnima Rameshbhai equity shares
Upendra Shah* Gandhi by way of
gift
April 23, Upendra T Shah Leena Shah Transfer of (300) 10 Nil Gift
2013 & Purnima equity shares
Upendra Shah* by way of
gift
226Date of Name of Name of Nature of Number of Face Transfe Nature of
transfer transferor transferee transaction equity value r price consideratio
shares per per n
transferre equit equity
d y share
share (₹)
(₹)
April 23, Upendra T Shah Mahesh Ramanlal Transfer of (300) 10 Nil Gift
2013 & Purnima Gandhi equity shares
Upendra Shah* by way of
gift
April 23, Upendra T Shah Narendrakumar Transfer of (850) 10 Nil Gift
2013 & Purnima Joshi equity shares
Upendra Shah* by way of
gift
April 23, Upendra T Shah Naresh Transfer of (300) 10 Nil Gift
2013 & Purnima Hargovindbhai equity shares
Upendra Shah* Patel by way of
gift
April 23, Upendra T Shah Nareshchandra Transfer of (300) 10 Nil Gift
2013 & Purnima Shah equity shares
Upendra Shah* by way of
gift
April 23, Upendra T Shah Natverlal Shanker Transfer of (300) 10 Nil Gift
2013 & Purnima Lal Shah equity shares
Upendra Shah* by way of
gift
April 23, Upendra T Shah Navinchandra V Transfer of (500) 10 Nil Gift
2013 & Purnima Shah equity shares
Upendra Shah* by way of
gift
April 23, Upendra T Shah Nayana Devendra Transfer of (300) 10 Nil Gift
2013 & Purnima Patel equity shares
Upendra Shah* by way of
gift
April 23, Upendra T Shah Praful K Shah Transfer of (400) 10 Nil Gift
2013 & Purnima equity shares
Upendra Shah* by way of
gift
April 23, Upendra T Shah Prakash Transfer of (300) 10 Nil Gift
2013 & Purnima Hasmukhlal equity shares
Upendra Shah* Kotak by way of
gift
April 23, Upendra T Shah Prakash K Shah Transfer of (300) 10 Nil Gift
2013 & Purnima equity shares
Upendra Shah* by way of
gift
April 23, Upendra T Shah Prashant Ukabhai Transfer of (300) 10 Nil Gift
2013 & Purnima Patel equity shares
Upendra Shah* by way of
gift
April 23, Upendra T Shah Pravinchandra A Transfer of (300) 10 Nil Gift
2013 & Purnima Shah equity shares
Upendra Shah* by way of
gift
April 23, Upendra T Shah Rajendra Kantilal Transfer of (300) 10 Nil Gift
2013 & Purnima Shah equity shares
Upendra Shah* by way of
gift
April 23, Upendra T Shah Rajesh Maneklal Transfer of (300) 10 Nil Gift
2013 & Purnima Kotak equity shares
Upendra Shah* by way of
gift
April 23, Upendra T Shah Rajiv Narsinhbhai Transfer of (850) 10 Nil Gift
2013 & Purnima Patel equity shares
Upendra Shah*
227Date of Name of Name of Nature of Number of Face Transfe Nature of
transfer transferor transferee transaction equity value r price consideratio
shares per per n
transferre equit equity
d y share
share (₹)
(₹)
by way of
gift
April 23, Upendra T Shah Rajiv Narsinhbhai Transfer of (450) 10 Nil Gift
2013 & Purnima Patel-HUF equity shares
Upendra Shah* by way of
gift
April 23, Upendra T Shah Ramesh Sorathia Transfer of (300) 10 Nil Gift
2013 & Purnima equity shares
Upendra Shah* by way of
gift
April 23, Upendra T Shah Rashmiben Gajjar Transfer of (300) 10 Nil Gift
2013 & Purnima equity shares
Upendra Shah* by way of
gift
April 23, Upendra T Shah Rekhaben Transfer of (600) 10 Nil Gift
2013 & Purnima Rajeshkumar equity shares
Upendra Shah* Kotak by way of
gift
April 23, Upendra T Shah Renukaben Transfer of (300) 10 Nil Gift
2013 & Purnima Arvindkumar equity shares
Upendra Shah* Patel by way of
gift
April 23, Upendra T Shah Riddhi Transfer of (350) 10 Nil Gift
2013 & Purnima Shreyansbhai equity shares
Upendra Shah* Doshi by way of
gift
April 23, Upendra T Shah Roopa Transfer of (500) 10 Nil Gift
2013 & Purnima Manojkumar Shah equity shares
Upendra Shah* by way of
gift
April 23, Upendra T Shah Rupal Sanjay Transfer of (150) 10 Nil Gift
2013 & Purnima Shah equity shares
Upendra Shah* by way of
gift
April 23, Upendra T Shah Shantiben Transfer of (800) 10 Nil Gift
2013 & Purnima Narsimha Patel equity shares
Upendra Shah* by way of
gift
April 23, Upendra T Shah Shreyans Rasiklal Transfer of (675) 10 Nil Gift
2013 & Purnima Doshi equity shares
Upendra Shah* by way of
gift
April 23, Upendra T Shah Sudha Kamlesh Transfer of (300) 10 Nil Gift
2013 & Purnima Modi equity shares
Upendra Shah* by way of
gift
April 23, Upendra T Shah Suleman Khoja Transfer of (300) 10 Nil Gift
2013 & Purnima equity shares
Upendra Shah* by way of
gift
April 23, Upendra T Shah Surekha Suketu Transfer of (300) 10 Nil Gift
2013 & Purnima Javeri equity shares
Upendra Shah* by way of
gift
April 23, Upendra T Shah Sushma Mahesh Transfer of (300) 10 Nil Gift
2013 & Purnima Gandhi equity shares
Upendra Shah* by way of
gift
228Date of Name of Name of Nature of Number of Face Transfe Nature of
transfer transferor transferee transaction equity value r price consideratio
shares per per n
transferre equit equity
d y share
share (₹)
(₹)
April 23, Upendra T Shah Tapan Dinesh Transfer of (300) 10 Nil Gift
2013 & Purnima Shah equity shares
Upendra Shah* by way of
gift
April 23, Upendra T Shah Ushaben J. Transfer of (150) 10 Nil Gift
2013 & Purnima Saraiya equity shares
Upendra Shah* by way of
gift
April 23, Upendra T Shah Varshaben G Transfer of (500) 10 Nil Gift
2013 & Purnima Gadani equity shares
Upendra Shah* by way of
gift
April 23, Upendra T Shah Vishal Jayantilal Transfer of (300) 10 Nil Gift
2013 & Purnima Shah equity shares
Upendra Shah* by way of
gift
April 23, Upendra T Shah Patel Bhadresh P. Transfer of (300) 10 Nil Gift
2013 & Purnima equity shares
Upendra Shah* by way of
gift
April 26, Upendra T Shah Dilipbhai R Patel Transfer of (300) 10 Nil Gift
2013 & Purnima equity shares
Upendra Shah* by way of
gift
April 26, Upendra T Shah Sheelaben D Patel Transfer of (300) 10 Nil Gift
2013 & Purnima equity shares
Upendra Shah* by way of
gift
April 26, Upendra T Shah Chander Transfer of (300) 10 Nil Gift
2013 & Purnima Choithram equity shares
Upendra Shah* Vanvari by way of
gift
April 26, Upendra T Shah Indumati Chander Transfer of (300) 10 Nil Gift
2013 & Purnima Vanvari equity shares
Upendra Shah* by way of
gift
April 26, Upendra T Shah Bhavana Manoj Transfer of (300) 10 Nil Gift
2013 & Purnima Dalal equity shares
Upendra Shah* by way of
gift
April 26, Upendra T Shah Sanjay Sumatilal Transfer of (850) 10 Nil Gift
2013 & Purnima Shah equity shares
Upendra Shah* by way of
gift
April 26, Upendra T Shah Deepak Bhai Transfer of (650) 10 Nil Gift
2013 & Purnima Sumatilal Shah equity shares
Upendra Shah* by way of
gift
April 26, Upendra T Shah Sonal Deepakbhai Transfer of (150) 10 Nil Gift
2013 & Purnima Shah equity shares
Upendra Shah* by way of
gift
April 26, Upendra T Shah Manoj Ramchand Transfer of (300) 10 Nil Gift
2013 & Purnima Dalal equity shares
Upendra Shah* by way of
gift
April 26, Upendra T Shah Jawahar Transfer of (300) 10 Nil Gift
2013 & Purnima Gopichand equity shares
Upendra Shah* Kapoor
229Date of Name of Name of Nature of Number of Face Transfe Nature of
transfer transferor transferee transaction equity value r price consideratio
shares per per n
transferre equit equity
d y share
share (₹)
(₹)
by way of
gift
April 26, Upendra T Shah Rajesh Rohra Transfer of (500) 10 Nil Gift
2013 & Purnima equity shares
Upendra Shah* by way of
gift
April 26, Upendra T Shah Jignesh Maniar Transfer of (300) 10 Nil Gift
2013 & Purnima equity shares
Upendra Shah* by way of
gift
April 26, Upendra T Shah Shivani Maniar Transfer of (300) 10 Nil Gift
2013 & Purnima equity shares
Upendra Shah* by way of
gift
April 26, Upendra T Shah Vipul C Desai Transfer of (300) 10 Nil Gift
2013 & Purnima equity shares
Upendra Shah* by way of
gift
April 26, Upendra T Shah Kanta Shyamlal Transfer of (150) 10 Nil Gift
2013 & Purnima Rohra equity shares
Upendra Shah* by way of
gift
April 26, Upendra T Shah Bunty Hundraj Transfer of (1000) 10 Nil Gift
2013 & Purnima Devnani equity shares
Upendra Shah* by way of
gift
April 26, Upendra T Shah Piyushkumar Transfer of (600) 10 Nil Gift
2013 & Purnima Krishnachandra equity shares
Upendra Shah* Dani by way of
gift
April 26, Upendra T Shah Bhavana Transfer of (400) 10 Nil Gift
2013 & Purnima Piyushkumar equity shares
Upendra Shah* Dani by way of
gift
April 26, Upendra T Shah Chetna Vipul Transfer of (300) 10 Nil Gift
2013 & Purnima Desai equity shares
Upendra Shah* by way of
gift
April 26, Upendra T Shah Sarojben C Desai Transfer of (300) 10 Nil Gift
2013 & Purnima equity shares
Upendra Shah* by way of
gift
April 26, Upendra T Shah Suman Rajesh Transfer of (300) 10 Nil Gift
2013 & Purnima Chellani equity shares
Upendra Shah* by way of
gift
April 26, Upendra T Shah Pohapsingh Yadav Transfer of (400) 10 Nil Gift
2013 & Purnima equity shares
Upendra Shah* by way of
gift
April 26, Upendra T Shah Anuradha Transfer of (300) 10 Nil Gift
2013 & Purnima Bhavsar equity shares
Upendra Shah* by way of
gift
April 26, Upendra T Shah Rajiv Bhavsar Transfer of (300) 10 Nil Gift
2013 & Purnima equity shares
Upendra Shah* by way of
gift
230Date of Name of Name of Nature of Number of Face Transfe Nature of
transfer transferor transferee transaction equity value r price consideratio
shares per per n
transferre equit equity
d y share
share (₹)
(₹)
April 26, Upendra T Shah Dipika Nikul Patel Transfer of (300) 10 Nil Gift
2013 & Purnima equity shares
Upendra Shah* by way of
gift
April 26, Upendra T Shah Rita Kishanlal Transfer of (300) 10 Nil Gift
2013 & Purnima Shajwani equity shares
Upendra Shah* by way of
gift
April 26, Upendra T Shah Bhumika Mahesh Transfer of (300) 10 Nil Gift
2013 & Purnima Shajwani equity shares
Upendra Shah* by way of
gift
April 26, Upendra T Shah Mahesh Kishanlal Transfer of (300) 10 Nil Gift
2013 & Purnima Shajwani equity shares
Upendra Shah* by way of
gift
April 26, Upendra T Shah Ramesh C Shah Transfer of (300) 10 Nil Gift
2013 & Purnima equity shares
Upendra Shah* by way of
gift
April 26, Upendra T Shah Neeta Dipak Patel Transfer of (300) 10 Nil Gift
2013 & Purnima equity shares
Upendra Shah* by way of
gift
April 26, Upendra T Shah Yogeshchandra Transfer of (300) 10 Nil Gift
2013 & Purnima Manohar Neve equity shares
Upendra Shah* by way of
gift
April 26, Upendra T Shah Nilima Transfer of (300) 10 Nil Gift
2013 & Purnima Yogeshchandra equity shares
Upendra Shah* Neve by way of
gift
April 26, Upendra T Shah Shachish Piyush Transfer of (300) 10 Nil Gift
2013 & Purnima Doctor equity shares
Upendra Shah* by way of
gift
April 26, Upendra T Shah Shital Bihagbhai Transfer of (300) 10 Nil Gift
2013 & Purnima Angreji equity shares
Upendra Shah* by way of
gift
April 26, Upendra T Shah Jitendra Transfer of (400) 10 Nil Gift
2013 & Purnima Amarchand Desai equity shares
Upendra Shah* by way of
gift
April 26, Upendra T Shah Minal Piyush Transfer of (350) 10 Nil Gift
2013 & Purnima Doshi equity shares
Upendra Shah* by way of
gift
April 26, Upendra T Shah Rekha Doshi Transfer of (1050) 10 Nil Gift
2013 & Purnima equity shares
Upendra Shah* by way of
gift
April 26, Upendra T Shah Ujas Piyush Doshi Transfer of (350) 10 Nil Gift
2013 & Purnima equity shares
Upendra Shah* by way of
gift
April 26, Upendra T Shah Piyush Doshi Transfer of (1050) 10 Nil Gift
2013 & Purnima equity shares
Upendra Shah*
231Date of Name of Name of Nature of Number of Face Transfe Nature of
transfer transferor transferee transaction equity value r price consideratio
shares per per n
transferre equit equity
d y share
share (₹)
(₹)
by way of
gift
April 26, Upendra T Shah Rajesh Pahlajrai Transfer of (300) 10 Nil Gift
2013 & Purnima Chellani equity shares
Upendra Shah* by way of
gift
April 29, Heta Kalpesh Upendra T Shah & Transfer 500 10 Nil N.A.
2013# Shah Purnima Upendra
Shah
May 1, Upendra T Shah Rutvi Transfer of (350) 10 Nil Gift
2013 & Purnima Deepakkumar equity shares
Upendra Shah* Shah by way of
gift
May 1, Upendra T Shah Nalin Sumatilal Transfer of (850) 10 Nil Gift
2013 & Purnima Shah equity shares
Upendra Shah* by way of
gift
May 1, Upendra T Shah Amrutbhai R Transfer of (500) 10 Nil Gift
2013 & Purnima Chaudhari equity shares
Upendra Shah* by way of
gift
May 1, Upendra T Shah Asit Iitendrabhai Transfer of (300) 10 Nil Gift
2013 & Purnima Zaveri equity shares
Upendra Shah* by way of
gift
May 1, Upendra T Shah Swati Binod Transfer of (850) 10 Nil Gift
2013 & Purnima Agarwal equity shares
Upendra Shah* by way of
gift
May 1, Upendra T Shah Naveen Kejriwal Transfer of 10 Nil Gift
2013 & Purnima equity shares (250)
Upendra Shah* by way of
gift
May 1, Upendra T Shah Jigna Texas Dave Transfer of (600) 10 Nil Gift
2013 & Purnima equity shares
Upendra Shah* by way of
gift
May 1, Upendra T Shah Bharatkumar Transfer of (300) 10 Nil Gift
2013 & Purnima Daftary equity shares
Upendra Shah* by way of
gift
May 1, Upendra T Shah Shyamal T Rohra Transfer of (850) 10 Nil Gift
2013 & Purnima equity shares
Upendra Shah* by way of
gift
May 1, Upendra T Shah Bhikhalal H Soni Transfer of (300) 10 Nil Gift
2013 & Purnima equity shares
Upendra Shah* by way of
gift
May 1, Upendra T Shah Chintan Transfer of (300) 10 Nil Gift
2013 & Purnima Pankajkumar equity shares
Upendra Shah* Shah by way of
gift
May 1, Upendra T Shah Chandrakant A Transfer of (300) 10 Nil Gift
2013 & Purnima Desai equity shares
Upendra Shah* by way of
gift
232Date of Name of Name of Nature of Number of Face Transfe Nature of
transfer transferor transferee transaction equity value r price consideratio
shares per per n
transferre equit equity
d y share
share (₹)
(₹)
May 1, Upendra T Shah Nilay Transfer of (300) 10 Nil Gift
2013 & Purnima Bharatkumar equity shares
Upendra Shah* Contractor by way of
gift
May 1, Upendra T Shah Minesh Transfer of (300) 10 Nil Gift
2013 & Purnima Indravadan Shah equity shares
Upendra Shah* by way of
gift
May 1, Upendra T Shah Inaxi Nareshbhai Transfer of (300) 10 Nil Gift
2013 & Purnima Shah equity shares
Upendra Shah* by way of
gift
May 1, Upendra T Shah Shobhan S Parikh Transfer of (300) 10 Nil Gift
2013 & Purnima equity shares
Upendra Shah* by way of
gift
May 1, Upendra T Shah Kamlesh Transfer of (300) 10 Nil Gift
2013 & Purnima Dahyabhai Patel equity shares
Upendra Shah* by way of
gift
May 1, Upendra T Shah Dipal Rameshbhai Transfer of (600) 10 Nil Gift
2013 & Purnima Shah equity shares
Upendra Shah* by way of
gift
May 1, Upendra T Shah Malti Ashokbhai Transfer of (700) 10 Nil Gift
2013 & Purnima Parikh equity shares
Upendra Shah* by way of
gift
May 1, Upendra T Shah Amit Ashokbhai Transfer of (850) 10 Nil Gift
2013 & Purnima Parikh equity shares
Upendra Shah* by way of
gift
May 1, Upendra T Shah Krina Amit Parikh Transfer of (700) 10 Nil Gift
2013 & Purnima equity shares
Upendra Shah* by way of
gift
May 1, Upendra T Shah Ashokbhai Transfer of (150) 10 Nil Gift
2013 & Purnima Nemchand Parikh equity shares
Upendra Shah* by way of
gift
May 1, Upendra T Shah Ranjan Patwa Transfer of (300) 10 Nil Gift
2013 & Purnima equity shares
Upendra Shah* by way of
gift
May 1, Upendra T Shah Amitbhai Popatlal Transfer of (300) 10 Nil Gift
2013 & Purnima Shah equity shares
Upendra Shah* by way of
gift
May 1, Upendra T Shah Ketan Tejpal Transfer of (400) 10 Nil Gift
2013 & Purnima Parikh equity shares
Upendra Shah* by way of
gift
May 1, Upendra T Shah Rajiv Tejpal Transfer of (300) 10 Nil Gift
2013 & Purnima Parikh equity shares
Upendra Shah* by way of
gift
May 1, Upendra T Shah Sonal Rajiv Transfer of (300) 10 Nil Gift
2013 & Purnima Parikh equity shares
Upendra Shah*
233Date of Name of Name of Nature of Number of Face Transfe Nature of
transfer transferor transferee transaction equity value r price consideratio
shares per per n
transferre equit equity
d y share
share (₹)
(₹)
by way of
gift
May 1, Upendra T Shah Nilesh Kothari Transfer of (300) 10 Nil Gift
2013 & Purnima (Lopa + Nilesh) equity shares
Upendra Shah* by way of
gift
May 1, Upendra T Shah Sanjay Mohanlal Transfer of (600) 10 Nil Gift
2013 & Purnima Shah equity shares
Upendra Shah* by way of
gift
May 1, Upendra T Shah Shrenik Mohanlal Transfer of (600) 10 Nil Gift
2013 & Purnima Shah equity shares
Upendra Shah* by way of
gift
May 1, Upendra T Shah Sukesh Mohanlal Transfer of (600) 10 Nil Gift
2013 & Purnima Shah equity shares
Upendra Shah* by way of
gift
May 1, Upendra T Shah Monali Transfer of (850) 10 Nil Gift
2013 & Purnima Divyeshbhai Shah equity shares
Upendra Shah* by way of
gift
May 1, Upendra T Shah Divyeshbhai Shah Transfer of (150) 10 Nil Gift
2013 & Purnima equity shares
Upendra Shah* by way of
gift
May 1, Upendra T Shah Rashmika Shah Transfer of (500) 10 Nil Gift
2013 & Purnima equity shares
Upendra Shah* by way of
gift
May 1, Upendra T Shah Nikita Nareshbhai Transfer of (150) 10 Nil Gift
2013 & Purnima Patel equity shares
Upendra Shah* by way of
gift
May 1, Upendra T Shah Kanchan Transfer of (850) 10 Nil Gift
2013 & Purnima Nareshbhai Patel equity shares
Upendra Shah* by way of
gift
May 1, Upendra T Shah Bharatbhai P. Transfer of (150) 10 Nil Gift
2013 & Purnima Patel equity shares
Upendra Shah* by way of
gift
May 1, Upendra T Shah Prahash Fin-Stock Transfer of (850) 10 Nil Gift
2013 & Purnima Pvt Ltd equity shares
Upendra Shah* by way of
gift
May 1, Upendra T Shah Kamlesh Kothari Transfer of (300) 10 Nil Gift
2013 & Purnima equity shares
Upendra Shah* by way of
gift
May 1, Upendra T Shah Vaishali Shah Transfer of (300) 10 Nil Gift
2013 & Purnima equity shares
Upendra Shah* by way of
gift
May 1, Upendra T Shah Dipan Kothari Transfer of (700) 10 Nil Gift
2013 & Purnima equity shares
Upendra Shah* by way of
gift
234Date of Name of Name of Nature of Number of Face Transfe Nature of
transfer transferor transferee transaction equity value r price consideratio
shares per per n
transferre equit equity
d y share
share (₹)
(₹)
May 1, Upendra T Shah Jigar Modi Transfer of (500) 10 Nil Gift
2013 & Purnima equity shares
Upendra Shah* by way of
gift
May 1, Upendra T Shah Vidyaben Modi Transfer of (500) 10 Nil Gift
2013 & Purnima equity shares
Upendra Shah* by way of
gift
May 1, Upendra T Shah Darshan Patel Transfer of (850) 10 Nil Gift
2013 & Purnima equity shares
Upendra Shah* by way of
gift
May 1, Upendra T Shah Priti D. Patel Transfer of (150) 10 Nil Gift
2013 & Purnima equity shares
Upendra Shah* by way of
gift
May 1, Upendra T Shah Kaushik D. Patel Transfer of (300) 10 Nil Gift
2013 & Purnima equity shares
Upendra Shah* by way of
gift
May 1, Upendra T Shah Suresh M. Shah Transfer of (300) 10 Nil Gift
2013 & Purnima equity shares
Upendra Shah* by way of
gift
May 1, Upendra T Shah Kanan s. Dalal Transfer of (500) 10 Nil Gift
2013 & Purnima equity shares
Upendra Shah* by way of
gift
May 1, Upendra T Shah Sheela Ajay Dalal Transfer of (500) 10 Nil Gift
2013 & Purnima equity shares
Upendra Shah* by way of
gift
May 1, Upendra T Shah Nishant M. Shah Transfer of (300) 10 Nil Gift
2013 & Purnima equity shares
Upendra Shah* by way of
gift
May 1, Upendra T Shah Atul C. Shah Transfer of (300) 10 Nil Gift
2013 & Purnima equity shares
Upendra Shah* by way of
gift
May 1, Upendra T Shah Pathik A. Shah Transfer of (300) 10 Nil Gift
2013 & Purnima equity shares
Upendra Shah* by way of
gift
May 1, Upendra T Shah Hetal Kamlesh Transfer of (500) 10 Nil Gift
2013 & Purnima Shah equity shares
Upendra Shah* by way of
gift
May 1, Upendra T Shah Srujal Shah Transfer of (300) 10 Nil Gift
2013 & Purnima equity shares
Upendra Shah* by way of
gift
May 2, Upendra T Shah Nisith Shah Transfer of (300) 10 Nil Gift
2013 & Purnima equity shares
Upendra Shah* by way of
gift
May 2, Upendra T Shah Abdurrehman A Transfer of (400) 10 Nil Gift
2013 & Purnima Memon equity shares
Upendra Shah*
235Date of Name of Name of Nature of Number of Face Transfe Nature of
transfer transferor transferee transaction equity value r price consideratio
shares per per n
transferre equit equity
d y share
share (₹)
(₹)
by way of
gift
May 2, Upendra T Shah GulamMohamed Transfer of (300) 10 Nil Gift
2013 & Purnima A Memon equity shares
Upendra Shah* by way of
gift
May 2, Upendra T Shah Mohamed Yusuf Transfer of (300) 10 Nil Gift
2013 & Purnima Memon equity shares
Upendra Shah* by way of
gift
May 2, Upendra T Shah Usmangani A Transfer of (300) 10 Nil Gift
2013 & Purnima Memon equity shares
Upendra Shah* by way of
gift
May 2, Upendra T Shah Sarabai Transfer of (300) 10 Nil Gift
2013 & Purnima Usmangani equity shares
Upendra Shah* Memon by way of
gift
May 2, Upendra T Shah Ghanshyambhai Transfer of (600) 10 Nil Gift
2013 & Purnima Patel equity shares
Upendra Shah* by way of
gift
May 2, Upendra T Shah Kaushikkumar Transfer of (300) 10 Nil Gift
2013 & Purnima Ramanlal Patel equity shares
Upendra Shah* by way of
gift
May 2, Upendra T Shah Amita Kaushik Transfer of (300) 10 Nil Gift
2013 & Purnima Patel equity shares
Upendra Shah* by way of
gift
May 2, Upendra T Shah Dayma Ashok Transfer of (300) 10 Nil Gift
2013 & Purnima Babulal equity shares
Upendra Shah* by way of
gift
May 2, Upendra T Shah Monali Transfer of (400) 10 Nil Gift
2013 & Purnima Birenkumar Shah equity shares
Upendra Shah* by way of
gift
May 2, Upendra T Shah Surendra Popatlal Transfer of (300) 10 Nil Gift
2013 & Purnima Shah equity shares
Upendra Shah* by way of
gift
May 2, Upendra T Shah Bharatbhai Transfer of (300) 10 Nil Gift
2013 & Purnima Umedchand equity shares
Upendra Shah* Gopani by way of
gift
May 2, Upendra T Shah Prashant Transfer of (300) 10 Nil Gift
2013 & Purnima Shankerprasad equity shares
Upendra Shah* Vyas by way of
gift
May 2, Upendra T Shah Hemang Amrutlal Transfer of (500) 10 Nil Gift
2013 & Purnima Patel equity shares
Upendra Shah* by way of
gift
May 3, Upendra T Shah Raju Shankarbhai Transfer of (600) 10 Nil Gift
2013 & Purnima Thakur equity shares
Upendra Shah* by way of
gift
236Date of Name of Name of Nature of Number of Face Transfe Nature of
transfer transferor transferee transaction equity value r price consideratio
shares per per n
transferre equit equity
d y share
share (₹)
(₹)
May 7, Upendra T Shah Nachiketa bhatt Transfer of (300) 10 Nil Gift
2013 & Purnima equity shares
Upendra Shah* by way of
gift
May 7, Upendra T Shah Gita B Patel Transfer of (500) 10 Nil Gift
2013 & Purnima equity shares
Upendra Shah* by way of
gift
May 7, Upendra T Shah Jitendra G. modi Transfer of (150) 10 Nil Gift
2013 & Purnima equity shares
Upendra Shah* by way of
gift
May 7, Upendra T Shah Shamalbhai M. Transfer of (300) 10 Nil Gift
2013 & Purnima gajjar equity shares
Upendra Shah* by way of
gift
May 7, Upendra T Shah Khurshid banu Transfer of (400) 10 Nil Gift
2013 & Purnima equity shares
Upendra Shah* by way of
gift
May 7, Upendra T Shah Chirag A. patel Transfer of (500) 10 Nil Gift
2013 & Purnima equity shares
Upendra Shah* by way of
gift
May 7, Upendra T Shah Amratbhai H. Transfer of (500) 10 Nil Gift
2013 & Purnima patel equity shares
Upendra Shah* by way of
gift
May 7, Upendra T Shah Hasumati A. patel Transfer of (500) 10 Nil Gift
2013 & Purnima equity shares
Upendra Shah* by way of
gift
May 7, Upendra T Shah Amratbhai H. Transfer of (500) 10 Nil Gift
2013 & Purnima patel equity shares
Upendra Shah* by way of
gift
May 7, Upendra T Shah Pravin M. patel Transfer of (300) 10 Nil Gift
2013 & Purnima equity shares
Upendra Shah* by way of
gift
May 7, Upendra T Shah Champaben G. Transfer of (500) 10 Nil Gift
2013 & Purnima patel equity shares
Upendra Shah* by way of
gift
May 7, Upendra T Shah Bhavana patel Transfer of (300) 10 Nil Gift
2013 & Purnima equity shares
Upendra Shah* by way of
gift
May 7, Upendra T Shah Dipak N. shah Transfer of (600) 10 Nil Gift
2013 & Purnima equity shares
Upendra Shah* by way of
gift
May 7, Upendra T Shah Mrunalini patel Transfer of (300) 10 Nil Gift
2013 & Purnima equity shares
Upendra Shah* by way of
gift
May 7, Upendra T Shah Rajesh patel Transfer of (300) 10 Nil Gift
2013 & Purnima equity shares
Upendra Shah*
237Date of Name of Name of Nature of Number of Face Transfe Nature of
transfer transferor transferee transaction equity value r price consideratio
shares per per n
transferre equit equity
d y share
share (₹)
(₹)
by way of
gift
May 7, Upendra T Shah Rajesh c. shah Transfer of (400) 10 Nil Gift
2013 & Purnima equity shares
Upendra Shah* by way of
gift
May 7, Upendra T Shah Sharad B. patel Transfer of (1,200) 10 Nil Gift
2013 & Purnima equity shares
Upendra Shah* by way of
gift
May 7, Upendra T Shah Bharti D. desai Transfer of (600) 10 Nil Gift
2013 & Purnima equity shares
Upendra Shah* by way of
gift
May 7, Upendra T Shah Devang N. gandhi Transfer of (400) 10 Nil Gift
2013 & Purnima equity shares
Upendra Shah* by way of
gift
May 7, Upendra T Shah Harshad Vyas Transfer of (700) 10 Nil Gift
2013 & Purnima equity shares
Upendra Shah* by way of
gift
May 7, Upendra T Shah Sheetal Vyas Transfer of (1,050) 10 Nil Gift
2013 & Purnima equity shares
Upendra Shah* by way of
gift
May 7, Upendra T Shah Manjula K. Vyas Transfer of (300) 10 Nil Gift
2013 & Purnima equity shares
Upendra Shah* by way of
gift
May 7, Upendra T Shah Arunkumar B. Transfer of (350) 10 Nil Gift
2013 & Purnima Vyas equity shares
Upendra Shah* by way of
gift
May 7, Upendra T Shah Vinod Somabhai Transfer of (300) 10 Nil Gift
2013 & Purnima Patel equity shares
Upendra Shah* by way of
gift
May 7, Upendra T Shah Nilam S. Patel Transfer of (300) 10 Nil Gift
2013 & Purnima equity shares
Upendra Shah* by way of
gift
May 7, Upendra T Shah Sanjay v. Patel Transfer of (300) 10 Nil Gift
2013 & Purnima equity shares
Upendra Shah* by way of
gift
May 7, Upendra T Shah Prahalbhai Patel Transfer of (300) 10 Nil Gift
2013 & Purnima equity shares
Upendra Shah* by way of
gift
May 7, Upendra T Shah Kiritkumar R. Transfer of (300) 10 Nil Gift
2013 & Purnima Patel equity shares
Upendra Shah* by way of
gift
May 7, Upendra T Shah Hansaben N. Patel Transfer of (300) 10 Nil Gift
2013 & Purnima equity shares
Upendra Shah* by way of
gift
238Date of Name of Name of Nature of Number of Face Transfe Nature of
transfer transferor transferee transaction equity value r price consideratio
shares per per n
transferre equit equity
d y share
share (₹)
(₹)
May 7, Upendra T Shah Lalita A. Shah Transfer of (600) 10 Nil Gift
2013 & Purnima equity shares
Upendra Shah* by way of
gift
May 9, Upendra T Shah Nilay G. Pandya Transfer of (300) 10 Nil Gift
2013 & Purnima equity shares
Upendra Shah* by way of
gift
May 9, Upendra T Shah Bhupendra Shah Transfer of (300) 10 Nil Gift
2013 & Purnima equity shares
Upendra Shah* by way of
gift
May 9, Upendra T Shah Sudhir V. Kulkari Transfer of (1,000) 10 Nil Gift
2013 & Purnima equity shares
Upendra Shah* by way of
gift
May 9, Upendra T Shah Dasrathbhai Patel Transfer of (150) 10 Nil Gift
2013 & Purnima equity shares
Upendra Shah* by way of
gift
May 9, Upendra T Shah Hasmukh A. Transfer of (200) 10 Nil Gift
2013 & Purnima Belani equity shares
Upendra Shah* by way of
gift
May 9, Upendra T Shah Rima D. Patel Transfer of (200) 10 Nil Gift
2013 & Purnima equity shares
Upendra Shah* by way of
gift
May 9, Upendra T Shah Maulika Gandhi Transfer of (200) 10 Nil Gift
2013 & Purnima equity shares
Upendra Shah* by way of
gift
May 9, Upendra T Shah Jaidevsinh Transfer of (200) 10 Nil Gift
2013 & Purnima Chandavat equity shares
Upendra Shah* by way of
gift
May 9, Upendra T Shah Dhirajlal P. Transfer of (200) 10 Nil Gift
2013 & Purnima Kansara equity shares
Upendra Shah* by way of
gift
May 9, Upendra T Shah Premilaben A. Transfer of (300) 10 Nil Gift
2013 & Purnima Chauhan equity shares
Upendra Shah* by way of
gift
May 9, Upendra T Shah Jitenra C. Modi Transfer of (150) 10 Nil Gift
2013 & Purnima equity shares
Upendra Shah* by way of
gift
May 9, Upendra T Shah Swati Agrawal Transfer of (150) 10 Nil Gift
2013 & Purnima equity shares
Upendra Shah* by way of
gift
May 9, Upendra T Shah Jwelin Shah Transfer of (400) 10 Nil Gift
2013 & Purnima equity shares
Upendra Shah* by way of
gift
May 9, Upendra T Shah Shailesh Shah Transfer of (300) 10 Nil Gift
2013 & Purnima equity shares
Upendra Shah*
239Date of Name of Name of Nature of Number of Face Transfe Nature of
transfer transferor transferee transaction equity value r price consideratio
shares per per n
transferre equit equity
d y share
share (₹)
(₹)
by way of
gift
May 9, Upendra T Shah Amrut R. Transfer of (500) 10 Nil Gift
2013 & Purnima Chaudhary equity shares
Upendra Shah* by way of
gift
May 10, Upendra T Shah Anusyaben P. Transfer of (300) 10 Nil Gift
2013 & Purnima Mehta equity shares
Upendra Shah* by way of
gift
May 10, Upendra T Shah Daree V. Patel Transfer of (300) 10 Nil Gift
2013 & Purnima equity shares
Upendra Shah* by way of
gift
May 10, Upendra T Shah Kundan V. Patel Transfer of (300) 10 Nil Gift
2013 & Purnima equity shares
Upendra Shah* by way of
gift
May 10, Upendra T Shah Pratap Mehta Transfer of (150) 10 Nil Gift
2013 & Purnima equity shares
Upendra Shah* by way of
gift
May 10, Upendra T Shah Chintan Mehta Transfer of (850) 10 Nil Gift
2013 & Purnima equity shares
Upendra Shah* by way of
gift
May 10, Upendra T Shah Meghna Mehta Transfer of (850) 10 Nil Gift
2013 & Purnima equity shares
Upendra Shah* by way of
gift
May 10, Upendra T Shah Bhupendra shah Transfer of (300) 10 Nil Gift
2013 & Purnima equity shares
Upendra Shah* by way of
gift
May 11, Upendra T Shah Kirankumar Transfer (300) 10 Nil N.A.
2013# & Purnima Ambalal Patel
Upendra Shah*
May 11, Upendra T Shah Bina Transfer (300) 10 Nil N.A.
2013# & Purnima Kalpeshkumar
Upendra Shah* Shah
May 11, Upendra T Shah Bhumika Kapadia Transfer of (300) 10 Nil Gift
2013 & Purnima equity shares
Upendra Shah* by way of
gift
May 11, Upendra T Shah Harish Patel Transfer of (300) 10 Nil Gift
2013 & Purnima equity shares
Upendra Shah* by way of
gift
May 11, Upendra T Shah Jasica M. Mehta Transfer of (300) 10 Nil Gift
2013 & Purnima equity shares
Upendra Shah* by way of
gift
May 11, Upendra T Shah Hansaben M. Transfer of (850) 10 Nil Gift
2013 & Purnima Mehta equity shares
Upendra Shah* by way of
gift
May 11, Upendra T Shah Mahendrabhai C. Transfer of (850) 10 Nil Gift
2013 & Purnima Mehta equity shares
Upendra Shah*
240Date of Name of Name of Nature of Number of Face Transfe Nature of
transfer transferor transferee transaction equity value r price consideratio
shares per per n
transferre equit equity
d y share
share (₹)
(₹)
by way of
gift
May 11, Upendra T Shah Utpal P. Shah Transfer of (31,700) 10 Nil Gift
2013 & Purnima equity shares
Upendra Shah* by way of
gift
May 11, Upendra T Shah Rajiv N. Patel Transfer of (300) 10 Nil Gift
2013 & Purnima HUF equity shares
Upendra Shah* by way of
gift
June 12, Upendra T Shah Parul Hitesh Transfer of (200) 10 Nil Gift
2013 & Purnima Chauhan equity shares
Upendra Shah* by way of
gift
June 12, Upendra T Shah Hardik D. patel Transfer of (300) 10 Nil Gift
2013 & Purnima equity shares
Upendra Shah* by way of
gift
June 12, Upendra T Shah Rajendrakumar S. Transfer of (300) 10 Nil Gift
2013 & Purnima Shah equity shares
Upendra Shah* by way of
gift
June 12, Upendra T Shah Deepak H. Transfer of (800) 10 Nil Gift
2013 & Purnima Devanani equity shares
Upendra Shah* by way of
gift
July 27, Upendra T Shah Luv Vikram Transfer (1,500) 10 Nil N.A.
2017# & Purnima Kothari
Upendra Shah*
July 27, Upendra T Shah Tanmay U. Shah Transfer of (1,500) 10 Nil Gift
2017 & Purnima & Purnima U. equity shares
Upendra Shah* Shah* by way of
gift
July 27, Upendra T Shah Ruchira Tanmay Transfer of (1,500) 10 Nil Gift
2017 & Purnima Shah equity shares
Upendra Shah* by way of
gift
July 27, Upendra T Shah Preeti Upendra Transfer of (1,500) 10 Nil Gift
2017 & Purnima Shah equity shares
Upendra Shah* by way of
gift
July 27, Upendra T Shah Trupti Utpal Shah Transfer of (1,500) 10 Nil Gift
2017 & Purnima equity shares
Upendra Shah* by way of
gift
July 27, Upendra T Shah Utpal Praful Shah Transfer of (1,500) 10 Nil Gift
2017 & Purnima equity shares
Upendra Shah* by way of
gift
January Bharatkumar Upendra Transfer 1200 10 10 Cash
31, 2018 Vallabhdas Trikamlal Shah &
Preeti Upendra
Daftary
Shah & Utpal
Prafulbhai Shah &
Rajesh R Punjabi*
January Purnima Ashok Upendra Transfer 1,800 10 Nil N.A.
31, 2018# Kumar Shah Trikamlal Shah &
Preeti Upendra
Shah & Utpal
241Date of Name of Name of Nature of Number of Face Transfe Nature of
transfer transferor transferee transaction equity value r price consideratio
shares per per n
transferre equit equity
d y share
share (₹)
(₹)
Prafulbhai Shah &
Rajesh R Punjabi*
February N.A.$ Upendra Transfer 600 10 Nil N.A.
01, 2018# Trikamlal Shah &
Preeti Upendra
Shah & Utpal
Prafulbhai Shah &
Rajesh R Punjabi*
February Nikita Upendra Transfer 400 10 63 Cash
01, 2018 Bharatbhai Trikamlal Shah &
Chokshi Preeti Upendra
Shah & Utpal
Prafulbhai Shah &
Rajesh R Punjabi*
February Ranjan Narendra Upendra Transfer 1800 10 Nil N.A.
02, 2018# Patva Trikamlal Shah &
Preeti Upendra
Shah & Utpal
Prafulbhai Shah &
Rajesh R Punjabi*
February Rupa Sunil shah Upendra Transfer 1,200 10 Nil N.A.
03, 2018# Trikamlal Shah &
Preeti Upendra
Shah & Utpal
Prafulbhai Shah &
Rajesh R Punjabi*
February Upendra N.A.$ Transfer (3000) 10 10 Cash
06, 2018# Trikamlal Shah
& Preeti Upendra
Shah & Utpal
Prafulbhai Shah
& Rajesh R
Punjabi*
February Upendra Utpal Praful Shah Transfer (4000) 10 10 Cash
06, 2018 Trikamlal Shah
& Preeti Upendra
Shah & Utpal
Prafulbhai Shah
& Rajesh R
Punjabi*
July 16, Upendra T Shah Preeti Upendra Transfer of (50,000) 10 Nil Gift
2021 & Purnima Shah equity shares
Upendra Shah* by way of
gift
July 16, Upendra T Shah Ruchira Tanmay Transfer of (1,00,000) 10 Nil Gift
2021 & Purnima Shah equity shares
Upendra Shah* by way of
gift
July 16, Upendra T Shah Tanmay U. Shah Transfer of (3,55,000) 10 Nil Gift
2021 & Purnima & Purnima U. equity shares
Upendra Shah* Shah* by way of
gift
July 16, Upendra T Shah Utpal Praful Shah Transfer of (50,000) 10 Nil Gift
2021 & Purnima & Trupti Utpal equity shares
Upendra Shah* Shah* by way of
gift
March 23, Upendra T Shah Tanmay U. Shah Transfer of (3,45,000) 10 Nil Gift
2022 & Purnima & Purnima U. equity shares
Upendra Shah* Shah*
242Date of Name of Name of Nature of Number of Face Transfe Nature of
transfer transferor transferee transaction equity value r price consideratio
shares per per n
transferre equit equity
d y share
share (₹)
(₹)
by way of
gift
March 23, Upendra T Shah Ruchira Tanmay Transfer of (1,00,000) 10 Nil Gift
2022 & Purnima Shah equity shares
Upendra Shah* by way of
gift
March 23, Upendra T Shah Utpal Praful Shah Transfer of (50,000) 10 Nil Gift
2022 & Purnima equity shares
Upendra Shah* by way of
gift
March 23, Upendra T Shah Preeti Upendra Transfer of (50,000) 10 Nil Gift
2022 & Purnima Shah equity shares
Upendra Shah* by way of
gift
March 06, Upendra T Shah Tanmay U. Shah Transfer of (1,00,000) 10 Nil Gift
2023 & Purnima & Purnima U. equity shares
Upendra Shah* Shah* by way of
gift
March 06, Upendra T Shah Preeti Upendra Transfer of (1,00,000) 10 Nil Gift
2023 & Purnima Shah equity shares
Upendra Shah* by way of
gift
March 06, Upendra T Shah Ruchira Tanmay Transfer of (1,00,000) 10 Nil Gift
2023 & Purnima Shah equity shares
Upendra Shah* by way of
gift
March 06, Upendra T Shah Utpal Praful Shah Transfer of (1,00,000) 10 Nil Gift
2023 & Purnima equity shares
Upendra Shah* by way of
gift
March 06, Upendra T Shah Tanmay U. Shah Transfer of (1,00,000) 10 Nil Gift
2023 & Purnima HUF equity shares
Upendra Shah* by way of
gift
January Upendra T Shah Tanmay U. Shah Transfer of (2,10,000) 10 Nil Gift
20, 2024 & Purnima & Purnima U. equity shares
Upendra Shah* Shah* by way of
gift
January Upendra T Shah Ruchira Tanmay Transfer of (30,000) 10 Nil Gift
20, 2024 & Purnima Shah & Tanmay equity shares
Upendra Shah* Upendra Bhai by way of
Shah* gift
January Upendra T Shah Preeti Upendra Transfer of (30,000) 10 Nil Gift
20, 2024 & Purnima Shah equity shares
Upendra Shah* by way of
gift
January Upendra T Shah Utpal Praful Shah Transfer of (15,000) 10 Nil Gift
20, 2024 & Purnima equity shares
Upendra Shah* by way of
gift
January Upendra T Shah Trupti Utpal Shah Transfer of (15,000) 10 Nil Gift
20, 2024 & Purnima equity shares
Upendra Shah* by way of
gift
February Upendra T Shah Tanmay U. Shah Transfer of (3,50,000) 10 Nil Gift
21, 2024 & Purnima & Purnima U. equity shares
Upendra Shah* Shah* by way of
gift
243Date of Name of Name of Nature of Number of Face Transfe Nature of
transfer transferor transferee transaction equity value r price consideratio
shares per per n
transferre equit equity
d y share
share (₹)
(₹)
February Upendra T Shah Ruchira Tanmay Transfer of (50,000) 10 Nil Gift
21, 2024 & Purnima Shah equity shares
Upendra Shah* by way of
gift
February Upendra T Shah Preeti Upendra Transfer of (50,000) 10 Nil Gift
21, 2024 & Purnima Shah equity shares
Upendra Shah* by way of
gift
February Upendra T Shah Utpal Praful Shah Transfer of (25,000) 10 Nil Gift
21, 2024 & Purnima equity shares
Upendra Shah* by way of
gift
February Upendra T Shah Trupti Utpal Shah Transfer of (25,000) 10 Nil Gift
21, 2024 & Purnima equity shares
Upendra Shah* by way of
gift
July 24, Upendra T Shah Trupti Utpal Shah Transfer of (75,000) 10 Nil Gift
2024 & Purnima equity shares
Upendra Shah* by way of
gift
July 24, Upendra T Shah Utpal Praful Shah Transfer of (75,000) 10 Nil Gift
2024 & Purnima equity shares
Upendra Shah* by way of
gift
Upendra Trikamlal Shah HUF
March 31, Rajesh R Punjabi Upendra Transfer 5,000 10 10 Cash
1997 & Sandhya R Trikamlal Shah
Punjabi* HUF & Trikamlal
F Shah*
Septembe Vipul C Desai & Upendra Transfer 10,000 10 6 Cash
r 15, 1997 Chandrakant A Trikamlal Shah
Desai* HUF & Trikamlal
F Shah*
February Shantilal Upendra Transfer 500 10 6 Cash
28, 1998 Khimjibhai Patel Trikamlal Shah
& Shantaben HUF & Trikamlal
Shantilal Patel* F Shah*
February Shantilal R Patel Upendra Transfer 500 10 6 Cash
28, 1998 Trikamlal Shah
HUF & Trikamlal
F Shah*
February Lelaben S Patel Upendra Transfer 500 10 6 Cash
28, 1998 Trikamlal Shah
HUF & Trikamlal
F Shah*
Septembe Suman K Patel & Upendra Transfer 1,000 10 6 Cash
r 17, 1998 Chimanlal Patel* Trikamlal Shah
HUF & Trikamlal
F Shah*
Septembe Suman K Patel & Upendra Transfer 1,500 10 6 Cash
r 17, 1998 Chimanlal Patel* Trikamlal Shah
HUF & Trikamlal
F Shah*
Septembe Kantilal Patel & Upendra Transfer 500 10 6 Cash
r 17, 1998 Mogiben K Trikamlal Shah
Patel* HUF & Trikamlal
F Shah*
Septembe Mogiben Upendra Transfer 500 10 6 Cash
r 17, 1998 Kantilal Patel & Trikamlal Shah
244Date of Name of Name of Nature of Number of Face Transfe Nature of
transfer transferor transferee transaction equity value r price consideratio
shares per per n
transferre equit equity
d y share
share (₹)
(₹)
Kantilal HUF & Trikamlal
Nagjibhai Patel* F Shah*
Septembe Alka Sunil Upendra Transfer 3,000 10 6 Cash
r 17, 1998 Mehta & Sunil Trikamlal Shah
Mahendrabhai HUF & Trikamlal
Mehta* F Shah*
Septembe Arvind P Patel & Upendra Transfer 500 10 6 Cash
r 17, 1998 Jitendra R Patel* Trikamlal Shah
HUF & Trikamlal
F Shah*
Septembe Jayantilal Patel Upendra Transfer 500 10 6 Cash
r 17, 1998 & Manjulaben Trikamlal Shah
Patel* HUF & Trikamlal
F Shah*
Septembe Manjulaben Upendra Transfer 500 10 6 Cash
r 17, 1998 Jayantilal Patel Trikamlal Shah
& Jayantilal HUF & Trikamlal
Mavjibhai Patel* F Shah*
Septembe Jayaben Upendra Transfer 500 10 6 Cash
r 17, 1998 Vithalbhai Patel Trikamlal Shah
& Vithalbhai HUF & Trikamlal
Mavjibhai Patel* F Shah*
Septembe Vithalbhai Upendra Transfer 500 10 6 Cash
r 17, 1998 Mavjibhai Patel Trikamlal Shah
& Jayaben HUF & Trikamlal
Vithalbhai Patel* F Shah*
Septembe Kusum S Patel & Upendra Transfer 500 10 6 Cash
r 17, 1998 Shantilal R Trikamlal Shah
Patel* HUF & Trikamlal
F Shah*
Septembe Suraiya Upendra Transfer 2,000 10 Nil N.A.
r 17, Ranawadia & Trikamlal Shah
1998# Zubedabibi HUF & Trikamlal
Ranawadia* F Shah*
Septembe Nasimbibi Upendra Transfer 1,000 10 6 Cash
r 17, 1998 Mutvalli & Trikamlal Shah
Abdul Aziz HUF & Trikamlal
Mutvalli* F Shah*
Septembe Jagruti P Patel & Upendra Transfer 500 10 6 Cash
r 17, 1998 Parshotum R Trikamlal Shah
Patel* HUF & Trikamlal
F Shah*
Septembe Gangaben Ratilal Upendra Transfer 500 10 6 Cash
r 17, 1998 Patel & Ratilal Trikamlal Shah
Vishram Patel* HUF & Trikamlal
F Shah*
Septembe Bharti D Patel & Upendra Transfer 500 10 6 Cash
r 17, 1998 Dajaram R Trikamlal Shah
Patel* HUF & Trikamlal
F Shah*
Septembe Dhanjibhai Upendra Transfer 500 10 6 Cash
r 17, 1998 Mavjibhai Patel Trikamlal Shah
& Maniben HUF & Trikamlal
Dhanjibhai F Shah*
Patel*
Septembe Maniben Upendra Transfer 500 10 6 Cash
r 17, 1998 Dhanjibhai Patel Trikamlal Shah
& Dhanjibhai HUF & Trikamlal
Patel* F Shah*
245Date of Name of Name of Nature of Number of Face Transfe Nature of
transfer transferor transferee transaction equity value r price consideratio
shares per per n
transferre equit equity
d y share
share (₹)
(₹)
Septembe Ratilal Vishram Upendra Transfer 500 10 6 Cash
r 17, 1998 Patel & Trikamlal Shah
Gansuben Ratilal HUF & Trikamlal
Patel* F Shah*
Septembe Shantaben Upendra Transfer 1,500 10 10 Cash
r 17, 1998 Chimanlal Patel Trikamlal Shah
& Chimanlal HUF & Trikamlal
Patel* F Shah*
Septembe Shantaben Upendra Transfer 1,000 10 6 Cash
r 17, 1998 Chimanlal Patel Trikamlal Shah
& Chimanlal HUF & Trikamlal
Patel* F Shah*
Septembe C. N. Patel Huf Upendra Transfer 1,000 10 6 Cash
r 17, 1998 & S. C. Patel* Trikamlal Shah
HUF & Trikamlal
F Shah*
Septembe Bhavanji Patel & Upendra Transfer 1,000 10 6 Cash
r 17, 1998 Vanita Patel* Trikamlal Shah
HUF & Trikamlal
F Shah*
Septembe Pramodbhai N Upendra Transfer 500 10 6 Cash
r 17, 1998 Patel & Jayaben Trikamlal Shah
P Patel* HUF & Trikamlal
F Shah*
Septembe Arvind M Upendra Transfer 500 10 Nil N.A.
r 17, 1998 Thakkar & Trikamlal Shah
Prafulla A HUF & Trikamlal
Thakkar* F Shah*
Septembe Chhaganlal M Upendra Transfer 500 10 6 Cash
r 17, 1998 Patel & Bhagvati Trikamlal Shah
C Patel* HUF & Trikamlal
F Shah*
Septembe Nirupa Deepak Upendra Transfer 4,500 10 6 Cash
r 17, 1998 Mehta & Deepak Trikamlal Shah
Shantilal Mehta* HUF & Trikamlal
F Shah*
May 15, Chimanbhai N Upendra Transfer 7,500 10 10 Cash
1999 Patel & Trikamlal Shah
Shantaben C HUF & Tanmay U
Patel* Shah*
March 16, Trikamlal F. Upendra Transfer 14,700 10 10 Cash
2002 Shah (HUF) & Trikamlal Shah
Upendra T Shah* HUF & Tanmay U
Shah*
April 30, Ashwin R. Mehta Upendra Transfer 500 10 8 Cash
2003 & Purnima A. Trikamlal Shah
Mehta* HUF & Tanmay U
Shah*
April 30, Purnima A. Upendra Transfer 500 10 8 Cash
2003 Mehta & Ashwin Trikamlal Shah
R. Mehta* HUF & Tanmay U
Shah*
April 30, Atul M. Mehta & Upendra Transfer 500 10 8 Cash
2003 Leena Atul Trikamlal Shah
Mehta* HUF & Tanmay U
Shah*
April 30, Leena Atul Upendra Transfer 500 10 8 Cash
2003 Mehta & Atul Trikamlal Shah
246Date of Name of Name of Nature of Number of Face Transfe Nature of
transfer transferor transferee transaction equity value r price consideratio
shares per per n
transferre equit equity
d y share
share (₹)
(₹)
Mahendrabhai HUF & Tanmay U
Mehta* Shah*
April 30, Champaben Upendra Transfer 500 10 8 Cash
2003 Keshavlal Patel Trikamlal Shah
& Keshavlal HUF & Tanmay U
Changanlal Shah*
Patel*
April 30, Keshavlal Upendra Transfer 1,000 10 8 Cash
2003 Changanlal Patel Trikamlal Shah
& Champaben HUF & Tanmay U
Keshavlal Patel* Shah*
April 30, Paresh Manubhai Upendra Transfer 500 10 8 Cash
2003 Jansari Trikamlal Shah
HUF & Tanmay U
Shah*
April 30, Jajvalaya R. Upendra Transfer 500 10 8 Cash
2003 Shukla & Trikamlal Shah
Dhaivat R. HUF & Tanmay U
Shukla* Shah*
April 30, Dhaivat R. Upendra Transfer 500 10 8 Cash
2003 Shukla & Trikamlal Shah
Jajvalaya R. HUF & Tanmay U
Shukla* Shah*
April 30, Rajendra A. Upendra Transfer 500 10 8 Cash
2003 Shukla & Trikamlal Shah
Nayana K. Jani* HUF & Tanmay U
Shah*
April 30, Nayana K. Jani Upendra Transfer 500 10 8 Cash
2003 & Rajendra A. Trikamlal Shah
Shukla* HUF & Tanmay U
Shah*
April 30, Rekha Dipak Upendra Transfer 500 10 8 Cash
2003 Vora & Dipak Trikamlal Shah
Babubhai Vora* HUF & Tanmay U
Shah*
April 30, Bhartiben M. Upendra Transfer 500 10 8 Cash
2003 Patel & Pvan M. Trikamlal Shah
Patel* HUF & Tanmay U
Shah*
April 30, Bharti M. Patel Upendra Transfer 500 10 8 Cash
2003 & Ruta M. Patel* Trikamlal Shah
HUF & Tanmay U
Shah*
April 30, Sharvil H. Shah Upendra Transfer 1,500 10 8 Cash
2003 & Satyenra J. Trikamlal Shah
Shah* HUF & Tanmay U
Shah*
April 30, Sudhanshu K. Upendra Transfer 1,000 10 8 Cash
2003 Jani & Kalpana Trikamlal Shah
S. Jani* HUF & Tanmay U
Shah*
April 30, KalpaN.A. S. Upendra Transfer 1,000 10 8 Cash
2003 Jani & Trikamlal Shah
Sudhanshu K. HUF & Tanmay U
Jani* Shah*
April 30, Madhukanta K. Upendra Transfer 5,000 10 8 Cash
2003 Jani & Kanubhai Trikamlal Shah
Jani* HUF & Tanmay U
Shah*
247Date of Name of Name of Nature of Number of Face Transfe Nature of
transfer transferor transferee transaction equity value r price consideratio
shares per per n
transferre equit equity
d y share
share (₹)
(₹)
July 4, Vinod Mehta Upendra Transfer 1,700 10 77 Cash
2012 Trikamlal Shah
HUF
July 4, Surya Bhupendra Upendra Transfer 300 10 77 Cash
2012 Mehta & Trikamlal Shah
Bhupendra HUF
Jethalal Mehta*
July 4, Surya Bhupendra Upendra Transfer 300 10 77 Cash
2012 Mehta & Trikamlal Shah
Bhupendra HUF
Jethalal Mehta*
July 4, Bhumita Hitesh Upendra Transfer 1,700 10 77 Cash
2012 Sanghavi & Trikamlal Shah
Hitesh Batuklal HUF
Sanghavi*
July 4, Dhwani Hitesh Upendra Transfer 300 10 77 Cash
2012 Sanghvi Trikamlal Shah
HUF
July 4, Trupti Mehta Upendra Transfer 1,700 10 77 Cash
2012 Trikamlal Shah
HUF
July 4, Surekha Upendra Transfer 300 10 77 Cash
2012 Vinodchandra Trikamlal Shah
Mehta HUF
July 4, Surekha Upendra Transfer 300 10 77 Cash
2012 Vinodchandra Trikamlal Shah
Mehta HUF
July 4, Neha Jhaveri & Upendra Transfer 600 10 Nil N.A.
2012# Rajiv Jhaveri Trikamlal Shah
HUF
July# 4, Archana Parikh Upendra Transfer 600 10 Nil N.A.
2012 & Ketan Parikh* Trikamlal Shah
HUF
October Sneha Trivedi Upendra Transfer 600 10 10 Cash
19, 2012 Trikamlal Shah
HUF
March 20, Upendra Kalpesh Jhaveri Transfer of (200) 10 Nil Gift
2013 Trikamlal Shah equity shares
HUF by way of
gift
March 20, Upendra Pravin Banodha Transfer of (200) 10 Nil Gift
2013 Trikamlal Shah equity shares
HUF by way of
gift
March 20, Upendra Ajay R. Vakharia Transfer of (200) 10 Nil Gift
2013 Trikamlal Shah equity shares
HUF by way of
gift
March 20, Upendra Deval M. Shah Transfer of (200) 10 Nil Gift
2013 Trikamlal Shah equity shares
HUF by way of
gift
March 20, Upendra Hardik Pittalia Transfer of (200) 10 Nil Gift
2013 Trikamlal Shah equity shares
HUF by way of
gift
March 20, Upendra Heta k. Shah Transfer of (200) 10 Nil Gift
2013 Trikamlal Shah equity shares
HUF
248Date of Name of Name of Nature of Number of Face Transfe Nature of
transfer transferor transferee transaction equity value r price consideratio
shares per per n
transferre equit equity
d y share
share (₹)
(₹)
by way of
gift
March 20, Upendra Devendra Gandhi Transfer of (200) 10 Nil Gift
2013 Trikamlal Shah equity shares
HUF by way of
gift
March 20, Upendra Pradip Roy Transfer of (200) 10 Nil Gift
2013 Trikamlal Shah equity shares
HUF by way of
gift
March 20, Upendra Viral B. Shah Transfer of (200) 10 Nil Gift
2013 Trikamlal Shah equity shares
HUF by way of
gift
March 20, Upendra Rima Patel Transfer of (200) 10 Nil Gift
2013 Trikamlal Shah equity shares
HUF by way of
gift
March 20, Upendra Manisha P. Modi Transfer of (200) 10 Nil Gift
2013 Trikamlal Shah equity shares
HUF by way of
gift
March 20, Upendra Pritesh G. Shah Transfer of (200) 10 Nil Gift
2013 Trikamlal Shah equity shares
HUF by way of
gift
March 20, Upendra Janki S. Shah Transfer of (200) 10 Nil Gift
2013 Trikamlal Shah equity shares
HUF by way of
gift
March 20, Upendra Bhavin S. Shah Transfer of (200) 10 Nil Gift
2013 Trikamlal Shah equity shares
HUF by way of
gift
March 20, Upendra Sandhya Punjabi Transfer of (800) 10 Nil Gift
2013 Trikamlal Shah equity shares
HUF by way of
gift
March 20, Upendra Rajesh R. Punjabi Transfer of (800) 10 Nil Gift
2013 Trikamlal Shah equity shares
HUF by way of
gift
March 20, Upendra Sagar Punjabi Transfer of (800) 10 Nil Gift
2013 Trikamlal Shah equity shares
HUF by way of
gift
March 20, Upendra Shruti Punjabi Transfer of (800) 10 Nil Gift
2013 Trikamlal Shah equity shares
HUF by way of
gift
March 20, Upendra Tanmay Shah Transfer of (800) 10 Nil Gift
2013 Trikamlal Shah HUF equity shares
HUF by way of
gift
March 20, Upendra Utpal Shah HUF Transfer of (800) 10 Nil Gift
2013 Trikamlal Shah equity shares
HUF by way of
gift
249Date of Name of Name of Nature of Number of Face Transfe Nature of
transfer transferor transferee transaction equity value r price consideratio
shares per per n
transferre equit equity
d y share
share (₹)
(₹)
March 20, Upendra Sonal Bhatt Transfer of (200) 10 Nil Gift
2013 Trikamlal Shah equity shares
HUF by way of
gift
March 20, Upendra Bhumika Transfer of (200) 10 Nil Gift
2013 Trikamlal Shah Nanavati equity shares
HUF by way of
gift
March 20, Upendra Dixita Devang Transfer of (200) 10 Nil Gift
2013 Trikamlal Shah Bhatt equity shares
HUF by way of
gift
March 20, Upendra Kajal R. Shah Transfer of (200) 10 Nil Gift
2013 Trikamlal Shah equity shares
HUF by way of
gift
February Upendra Tanmay Upendra Transfer of (600) 10 Nil Gift
26, 2019 Trikamlal Shah Shah HUF equity shares
HUF by way of
gift
Purnima Upendra Shah
Septembe Vipul C Desai & Purnima Upendra Transfer 4,000 10 6 Cash
r 15, 1997 Chandrakant A Shah & Upendra T
Desai* Shah*
Septembe Chimanbhai N Purnima Upendra Transfer 20,000 10 6 Cash
r 15, 1997 Patel & Shah & Upendra T
Shantaben C Shah*
Patel*
Septembe Vipul C Desai & Purnima Upendra Transfer 10,000 10 6 Cash
r 15, 1997 Chandrakant A Shah & Upendra T
Desai* Shah*
January Biharilal C Patel Purnima Upendra Transfer 10,000 10 6 Cash
31, 1998 & Mira Shah & Upendra T
Kirankumar Shah*
Patel &
Kirankumar
Biharilal Patel*
January Pravinbhai J Purnima Upendra Transfer 500 10 6 Cash
31, 1998 Patel Shah & Upendra T
Shah*
January Dhiraj Patel & Purnima Upendra Transfer 500 10 6 Cash
31, 1998 Chimanlal Patel* Shah & Upendra T
Shah*
January Savitrai D Patel Purnima Upendra Transfer 500 10 6 Cash
31, 1998 & Dhanjibhai R Shah & Upendra T
Patel* Shah*
January Pravin D Patel & Purnima Upendra Transfer 2,000 10 6 Cash
31, 1998 Dhirajlal Shah & Upendra T
Devrambhai Shah*
Patel*
Septembe Maltiben R Purnima Upendra Transfer 5,000 10 6 Cash
r 17, 1998 Patwa & Kantilal Shah & Upendra T
Nagjibhai Patel* Shah*
Septembe Siddharth M Purnima Upendra Transfer 5,000 10 6 Cash
r 17, 1998 Mehta & Sunil M Shah & Upendra T
Mehta* Shah*
Septembe Prabhakur S Purnima Upendra Transfer 5,500 10 6 Cash
r 17, 1998 Khamar & Dilip Shah & Upendra T
S Khamar* Shah*
250Date of Name of Name of Nature of Number of Face Transfe Nature of
transfer transferor transferee transaction equity value r price consideratio
shares per per n
transferre equit equity
d y share
share (₹)
(₹)
Septembe Rajesh R Punjabi Purnima Upendra Transfer 15,000 10 Nil N.A.
r 17, & Sandhya R Shah & Upendra T
1998# Punjabi* Shah*
May 15, Chimanbhai N Purnima Upendra Transfer 10,000 10 10 Cash
1999 Patel & Shah & Upendra T
Shantaben C Shah*
Patel*
October Jitendra D. Purnima Upendra Transfer 5,000 10 7 Cash
15, 2001 Saraiya & Shah & Upendra T
Ushaben J Shah*
Saraiya & Nirav
J Saraiya*
October Shefali Siddharth Purnima Upendra Transfer 500 10 7 Cash
15, 2001 Mehta & Shah & Upendra T
Siddharth Shah*
Mahendrakumar
Mehta*
October Ranjanben Purnima Upendra Transfer 1000 10 7 Cash
15, 2001 Saraiya & Shah & Upendra T
Bharatkumar Shah*
Saraiya*
October Bharatkumar Purnima Upendra Transfer 1,000 10 7 Cash
15, 2001 Saraiya & Shah & Upendra T
Ranjanben Shah*
Saraiya*
October Trishla Bhimani Purnima Upendra Transfer 12,000 10 7 Cash
15, 2001 & Sandhya R Shah & Upendra T
Punjabi* Shah*
October Raju Shankarlal Purnima Upendra Transfer 500 10 7 Cash
15, 2001 Thakor Shah & Upendra T
Shah*
October Kusum Arvind Purnima Upendra Transfer 500 10 7 Cash
15, 2001 Modi & Arvind Shah & Upendra T
Chimanlal Shah*
Modi*
October Kashinath Purnima Upendra Transfer 500 10 7 Cash
15, 2001 Rambhau Shah & Upendra T
Borhade & Shah*
Shobha
KasHinath
Borhade*
October Shobha K. Purnima Upendra Transfer 2,500 10 7 Cash
15, 2001 Borhade & Shah & Upendra T
Kashinath Shah*
Rambhau
Borhade*
February Ajit M. Sheth & Purnima Upendra Transfer 2,000 10 7.5 Cash
11, 2002 Bhavna A Sheth* Shah & Upendra T
Shah*
March 16, Trikamlal F. Purnima Upendra Transfer 6,000 10 10 Cash
2002 Shah & Purnima Shah & Upendra T
U. Shah* Shah*
March 16, Trikamlal F. Purnima Upendra Transfer 13,500 10 10 Cash
2002 Shah & Purnima Shah & Upendra T
U. Shah* Shah*
March 16, Trikamlal F. Purnima Upendra Transfer 3,000 10 10 Cash
2002 Shah & Purnima Shah & Upendra T
U. Shah* Shah*
251Date of Name of Name of Nature of Number of Face Transfe Nature of
transfer transferor transferee transaction equity value r price consideratio
shares per per n
transferre equit equity
d y share
share (₹)
(₹)
July 01, Hansaben N. Purnima Upendra Transfer 1,000 10 8 Cash
2002 Joshi Shah & Upendra T
Shah*
July 01, Janak N. Joshi Purnima Upendra Transfer 1,000 10 8 Cash
2002 Shah & Upendra T
Shah*
July 01, Sanjay A. Mehta Purnima Upendra Transfer 500 10 8 Cash
2002 & Komal S. Shah & Upendra T
Mehta* Shah*
July 01, Kamlesh J. Shah Purnima Upendra Transfer 1,000 10 8 Cash
2002 & Pushpaben K Shah & Upendra T
Shah* Shah*
July 01, Harsha A. Purnima Upendra Transfer 1,000 10 8 Cash
2002 Trivedi & Shah & Upendra T
Amrish D Shah*
Trivedi*
July 01, Bharatbhai Purnima Upendra Transfer 1,000 10 8 Cash
2002 Gopani Shah & Upendra T
Shah*
July 01, Vijay B. Shah & Purnima Upendra Transfer 5,100 10 8 Cash
2002 Saroj V Shah* Shah & Upendra T
Shah*
July 01, Induben Gopani Purnima Upendra Transfer 1,000 10 8 Cash
2002 Shah & Upendra T
Shah*
July 31, Manjula N. Shah Purnima Upendra Transfer 1,000 10 8 Cash
2002 & Navinchandra Shah & Upendra T
V Shah* Shah*
July 31, Nikunj Desai & Purnima Upendra Transfer 500 10 8 Cash
2002 Dipti Desai* Shah & Upendra T
Shah*
July 31, Hitendra M. Purnima Upendra Transfer 10,000 10 10 Cash
2002 Patel & Shah & Upendra T
Manubhai P Shah*
Patel*
March 19, Siddharth Purnima Upendra Transfer 600 10 75 Cash
2013 Shantilal Dikshit Shah & Upendra T
& Sheelaben Shah*
Shantilal
Dikshit*
March 21, Purnima Kenisha Tanmay Transfer of (600) 10 Nil Gift
2013 Upendra Shah & Shah equity shares
Upendra T Shah* by way of
gift
January Purnima Tanmay U. Shah Transfer of (1,40,000) 10 Nil Gift
20, 2024 Upendra Shah & & Purnima U. equity shares
Upendra T Shah* Shah by way of
gift
January Purnima Ruchira Tanmay Transfer of (20,000) 10 Nil Gift
20, 2024 Upendra Shah & Shah equity shares
Upendra T Shah* by way of
gift
January Purnima Preeti Upendra Transfer of (20,000) 10 Nil Gift
20, 2024 Upendra Shah & Shah equity shares
Upendra T Shah* by way of
gift
January Purnima Utpal Praful Shah Transfer of (10,000) 10 Nil Gift
20, 2024 Upendra Shah & equity shares
Upendra T Shah*
252Date of Name of Name of Nature of Number of Face Transfe Nature of
transfer transferor transferee transaction equity value r price consideratio
shares per per n
transferre equit equity
d y share
share (₹)
(₹)
by way of
gift
January Purnima Trupti Utpal Shah Transfer of (10,000) 10 Nil Gift
20, 2024 Upendra Shah & equity shares
Upendra T Shah* by way of
gift
July 24, Purnima Trupti Utpal Shah Transfer of (75,000) 10 Nil Gift
2024 Upendra Shah & equity shares
Upendra T Shah* by way of
gift
July 24, Purnima Utpal Praful Shah Transfer of (75,000) 10 Nil Gift
2024 Upendra Shah & equity shares
Upendra T Shah* by way of
gift
Tanmay Upendra Shah
May 15, Tanmay Real Tanmay Upendra Transfer 15,600 10 10 Cash
1999 Estate & Finance Shah & Purnima
Limited Upendra Shah*
October Hasmukh M. Tanmay Upendra Transfer 5,000 10 7 Cash
15, 2001 Shah & Shah
Minaxiben H
Shah*
October Sanjay B. Tanmay Upendra Transfer 5,000 10 7 Cash
15, 2001 Bhimani & Shah
Trirala S.
Bhimani*
February Lalit A. parikh & Tanmay Upendra Transfer 2,000 10 7.5 Cash
11, 2002 Shyama L. Shah & Purnima
Parikh* Upendra Shah*
March 16, Tej Kishen Tanmay Upendra Transfer 300 10 10 Cash
2002 Kachra & Urmila Shah & Purnima
Kachra* Upendra Shah*
March 16, Rohitkumar Tanmay Upendra Transfer 500 10 10 Cash
2002 Chimanbhai Shah & Purnima
Shah & Mihir Upendra Shah*
Rohitkumar
Shah*
July 01, Sonal N. shah & Tanmay Upendra Transfer 23,000 10 8 Cash
2002 Purnima Shah & Purnima
Upendra Shah* Upendra Shah*
December Bhagubhai Tanmay Upendra Transfer 500 10 6 Cash
30, 2002 Mathurdas Patel Shah & Purnima
& Nileshkumar Upendra Shah*
Bhagubhai Patel
& Kalpanaben
Bhagubhai
Patel*
December Shobhanaben A. Tanmay Upendra Transfer 1,000 10 6 Cash
30, 2002 Vaghela & Shah & Purnima
Arjunsinh P. Upendra Shah*
Vaghela*
December Rajiben M. Patel Tanmay Upendra Transfer 5,000 10 6 Cash
30, 2002 & Madhavlal S. Shah & Purnima
patel Upendra Shah
December Madhavlal S. Tanmay Upendra Transfer 5,000 10 6 Cash
30, 2002 patel & Rajiben Shah & Purnima
M. Patel* Upendra Shah*
253Date of Name of Name of Nature of Number of Face Transfe Nature of
transfer transferor transferee transaction equity value r price consideratio
shares per per n
transferre equit equity
d y share
share (₹)
(₹)
December Ratna R. Parmar Tanmay Upendra Transfer 5,000 10 6 Cash
30, 2002 & Rajesh J. Shah & Purnima
Parmar* Upendra Shah*
December Vimlaben T. Tanmay Upendra Transfer 46,700 10 Nil N.A.
30, 2002# Shah Shah & Purnima
Upendra Shah*
December Trikamlal F. Tanmay Upendra Transfer 49,600 10 Nil N.A.
30, 2002# Shah Shah & Purnima
Upendra Shah*
April 30, Krupa Ashwin Tanmay Upendra Transfer 1,000 10 8 Cash
2003 Patel & Ashwin Shah & Purnima
Govindlal Patel* Upendra Shah*
April 30, Ashwin Tanmay Upendra Transfer 1,000 10 8 Cash
2003 Govindlal Patel Shah & Purnima
& Krupa Ashwin Upendra Shah*
Patel*
April 30, Ashwin Tanmay Upendra Transfer 1,000 10 8 Cash
2003 Govindlal Patel Shah & Purnima
& Krupa Ashwin Upendra Shah*
Patel*
April 30, Ashwin Tanmay Upendra Transfer 1,000 10 8 Cash
2003 Govindlal Patel Shah & Purnima
& Krupa Ashwin Upendra Shah*
Patel*
April 30, Ashwin Tanmay Upendra Transfer 1,000 10 8 Cash
2003 Govindlal Patel Shah & Purnima
& Krupa Ashwin Upendra Shah*
Patel*
April 30, Ashwin Tanmay Upendra Transfer 5,000 10 8 Cash
2003 Govindlal Patel Shah & Purnima
& Krupa Ashwin Upendra Shah*
Patel*
April 30, Jayshree Vikram Tanmay Upendra Transfer 500 10 8 Cash
2003 Shah & Vikram Shah & Purnima
C. Shah* Upendra Shah*
April 30, Sudhirkumar C. Tanmay Upendra Transfer 500 10 8 Cash
2003 Shah & Jayshree Shah & Purnima
Sudhir Shah* Upendra Shah*
April 30, Jayshree Sudhir Tanmay Upendra Transfer 500 10 8 Cash
2003 shah & Sudhir Shah & Purnima
Chinubhai Shah* Upendra Shah*
April 30, Vikram C. Shah Tanmay Upendra Transfer 500 10 8 Cash
2003 & Jayshree V Shah & Purnima
Shah* Upendra Shah*
April 30, Dipti V. Shah & Tanmay Upendra Transfer 1,000 10 8 Cash
2003 Nirmalaben V. Shah & Purnima
Shah* Upendra Shah*
April 30, Priti C. shah & Tanmay Upendra Transfer 1,000 10 8 Cash
2003 Nirmalaben Shah & Purnima
Vinodchandra Upendra Shah*
Shah*
April 30, Chirag V. Shah & Tanmay Upendra Transfer 2,000 10 8 Cash
2003 Devesh V Shah* Shah & Purnima
Upendra Shah*
July 27, Upendra T Shah Tanmay Upendra Transfer of 1,500 10 Nil Gift
2017 & Purnima Shah & Purnima equity shares
Upendra Shah* Upendra Shah* by way of
gift
254Date of Name of Name of Nature of Number of Face Transfe Nature of
transfer transferor transferee transaction equity value r price consideratio
shares per per n
transferre equit equity
d y share
share (₹)
(₹)
July 16, Upendra T Shah Tanmay Upendra Transfer of 3,55,000 10 Nil Gift
2021 & Purnima Shah & Purnima equity shares
Upendra Shah* Upendra Shah* by way of
gift
March 23, Upendra T Shah Tanmay U. Shah Transfer of 3,45,000 10 Nil Gift
2022 & Purnima & Purnima U. equity shares
Upendra Shah* Shah* by way of
gift
March 6, Upendra T Shah Tanmay U. Shah Transfer of 1,00,000 10 Nil Gift
2023 & Purnima & Purnima U. equity shares
Upendra Shah* Shah* by way of
gift
January Upendra T Shah Tanmay U. Shah Transfer of 2,10,000 10 Nil Gift
20, 2024 & Purnima & Purnima U. equity shares
Upendra Shah* Shah* by way of
gift
January Purnima Tanmay U. Shah Transfer of 1,40,000 10 Nil Gift
20, 2024 Upendra Shah & & Purnima U. equity shares
Upendra T Shah* Shah* by way of
gift
February Upendra T Shah Tanmay U. Shah Transfer of 3,50,000 10 Nil Gift
21, 2024 & Purnima & Purnima U. equity shares
Upendra Shah* Shah* by way of
gift
Tanmay Upendra Shah HUF
August Jitesh Suresh Tanmay Upendra Transfer 500 10 80 Cash
20, 2008 Shah Shah HUF
August Jayprakash Desai Tanmay Upendra Transfer 2,000 10 80 Cash
20, 2008 Shah HUF
August Palak Desai & Tanmay Upendra Transfer 2000 10 80 Cash
20, 2008 Jayprakash Shah HUF
Desai*
March 20, Upendra Tanmay Upendra Transfer of 800 10 Nil Gift
2013# Trikamlal Shah Shah HUF equity shares
(HUF) by way of
gift
February Upendra T Shah Tanmay Upendra Transfer of 600 10 Nil Gift
26, 2019 & Trikamlal F. Shah HUF equity shares
Shah* by way of
gift
February Ajaybhai Tanmay Upendra Transfer 600 10 55 Cash
09, 2021 Indravadanbhai Shah HUF
Shah
March 06, Upendra T Shah Tanmay Upendra Transfer of 1,00,000 10 Nil Gift
2023 & Purnima Shah HUF equity shares
Shah* by way of
gift
Trupti Utpal Shah
Septembe Sandhya R Trupti Utpal Shah Transfer 5,300 10 Nil N.A.
r Punjabi & Rajesh
17,1998# R Punjabi*
Septembe Upendra T Shah Trupti Utpal Shah Transfer 700 10 Nil N.A.
r & Purnima
17,1998# Shah*
April 30, Gargi R. Patel & Trupti Utpal Shah Transfer 1,000 10 8 Cash
2003 Ramesh D. & Purnima
Patel* Upendra Shah*
255Date of Name of Name of Nature of Number of Face Transfe Nature of
transfer transferor transferee transaction equity value r price consideratio
shares per per n
transferre equit equity
d y share
share (₹)
(₹)
April 30, Kapila R. Patel & Trupti Utpal Shah Transfer 1,000 10 8 Cash
2003 Ramesh D. & Purnima
Patel* Upendra Shah*
April 30, Jigar R. Patel & Trupti Utpal Shah Transfer 1,000 10 8 Cash
2003 Ramesh D. & Purnima
Patel* Upendra Shah*
April 30, Ramesh D. Patel Trupti Utpal Shah Transfer 2,000 10 8 Cash
2003 & Kapilaben & Purnima
Rameshchandra Upendra Shah*
Patel*
April 30, Tarunaben Trupti Utpal Shah Transfer 600 10 8 Cash
2003 Shantilal Lodha* & Purnima
Upendra Shah*
April 30, Ketan Trupti Utpal Shah Transfer 400 10 8 Cash
2003 Arvindbhai & Purnima
Nanavati Upendra Shah*
&Falguni Ketan
Nanavati*
April 30, Gauriben P. Shah Trupti Utpal Shah Transfer 6,000 10 8 Cash
2003 & Utpal P. Shah* & Purnima
Upendra Shah*
April 30, Rupal Pritish Trupti Utpal Shah Transfer 4,000 10 8 Cash
2003 Shah & Pritish & Purnima
Prafulbhai Shah* Upendra Shah*
March 31, Trupti Utpal Ruchira Tanmay Transfer (45,00) 10 10 Cash
2008 Shah & Purnima Shah
Upendra Shah*
March 31, Trupti Utpal Ruchira Tanmay Transfer (81,000) 10 10 Cash
2008 Shah & Purnima shah
Upendra Shah*
July 27, Upendra T Shah Trupti Utpal Shah Transfer of 1,500 10 Nil Gift
2017 & Purnima equity shares
Upendra Shah* by way of
gift
January Upendra T Shah Trupti Utpal Shah Transfer of 15,000 10 Nil Gift
20, 2024 & Purnima equity shares
Upendra Shah* by way of
gift
January Purnima Trupti Utpal Shah Transfer of 10,000 10 Nil Gift
20, 2024 Upendra Shah & equity shares
Upendra T Shah* by way of
gift
February Upendra T Shah Trupti Utpal Shah Transfer of 25,000 10 Nil Gift
21, 2024 & Purnima equity shares
Upendra Shah* by way of
gift
July 24, Purnima Trupti Utpal Shah Transfer of 75,000 10 Nil Gift
2024 Upendra Shah & equity shares
Upendra T Shah* by way of
gift
July 24, Upendra T Shah Trupti Utpal Shah Transfer of 75,000 10 Nil Gift
2024 & Purnima equity shares
Upendra Shah* by way of
gift
Utpal Praful Shah
February Lalit A Parikh & Utpal Praful Shah Transfer 2,000 10 10 Cash
11, 2002 Shyamal L. & Trupti Utpal
Parikh* Shah*
256Date of Name of Name of Nature of Number of Face Transfe Nature of
transfer transferor transferee transaction equity value r price consideratio
shares per per n
transferre equit equity
d y share
share (₹)
(₹)
July 25, Ghanshyam I Utpal Praful Shah Transfer 300 10 80 Cash
2009 Amin & Trupti Utpal
Shah*
July 25, Virenkumar Utpal Praful Shah Transfer 300 10 80 Cash
2009 Kanubhai Patel & Trupti Utpal
Shah*
July 25, Suraj Ghelabhai Utpal Praful Shah Transfer 300 10 80 Cash
2009 Dubal & Trupti Utpal
Shah
July 25, Madhukarbhai Utpal Praful Shah Transfer 500 10 80 Cash
2009 Kanjibhai Patel & Trupti Utpal
Shah*
July 25, Mangtilal Utpal Praful Shah Transfer 300 10 80 Cash
2009 Chothemal & Trupti Utpal
Gupta & Shah*
Bhagwandevi M
Gupta*
July 25, Jayantibhai Asari Utpal Praful Shah Transfer 1,000 10 80 Cash
2009 & Taraben & Trupti Utpal
Asari* Shah*
July 25, Manjulaben Utpal Praful Shah Transfer 300 10 80 Cash
2009 Mehta & Trupti Utpal
Shah*
July 25, Rupal Shah Utpal Praful Shah Transfer 300 10 80 Cash
2009 & Trupti Utpal
Shah*
July 25, Tushar Rawal Utpal Praful Shah Transfer 300 10 80 Cash
2009 & Trupti Utpal
Shah*
July 25, Amit Chinubhai Utpal Praful Shah Transfer 600 10 80 Cash
2009 Patel & & Trupti Utpal
Chinubhai Shah*
Kashibhai Patel*
July 25, Mandakini Utpal Praful Shah Transfer 500 10 80 Cash
2009 Shailesh Shah & & Trupti Utpal
Shailesh Shah*
Balkrasana
Shah*
July 25, Kalpana Nitin Utpal Praful Shah Transfer 500 10 80 Cash
2009 Shah & Nitin & Trupti Utpal
Balkrasna Shah* Shah*
July 25, Pramodbhai Utpal Praful Shah Transfer 300 10 80 Cash
2009 Shambhubhai & Trupti Utpal
Patel Shah*
July 25, Laxmiben Utpal Praful Shah Transfer 1,000 10 80 Cash
2009 Chauhan & & Trupti Utpal
Prakashbhai Shah*
Chauhan*
July 25, Priti Saurabh Utpal Praful Shah Transfer 900 10 80 Cash
2009 Shah & Saurabh & Trupti Utpal
Bhagvatprasad Shah*
Shah*
July 25, Lopa Shah Utpal Praful Shah Transfer 400 10 80 Cash
2009 & Trupti Utpal
Shah*
August Sarojben Bharat Utpal Praful Shah Transfer 2,000 10 100 Cash
10, 2009 Shah & Trupti Utpal
Shah*
257Date of Name of Name of Nature of Number of Face Transfe Nature of
transfer transferor transferee transaction equity value r price consideratio
shares per per n
transferre equit equity
d y share
share (₹)
(₹)
August Sejal Gopal Shah Utpal Praful Shah Transfer 3,000 10 100 Cash
10, 2009 & Trupti Utpal
Shah*
August Dinesh Natverlal Utpal Praful Shah Transfer 3,000 10 100 Cash
10, 2009 Shah & Trupti Utpal
Shah*
Septembe Rajeshkumar Utpal Praful Shah Transfer 600 10 80 Cash
r 01, 2009 Shankarlal Shah & Trupti Utpal
Shah*
May 11, Upendra T Shah Utpal Praful Shah Transfer of 31,700 10 Nil Gift
2013 & Purnima & Trupti Utpal equity shares
Upendra Shah* Shah* by way of
gift
May 27, N.A.$ Utpal Praful Shah Transfer 500 10 Nil N.A.
2013# & Trupti Utpal
Shah*
July 10, Parul Hiteshbhai Utpal Praful Shah Transfer 200 10 Nil N.A.
2013# Chauhan & Trupti Utpal
Shah*
August Utpal Praful Upendra O. Transfer of (250) 10 Nil Gift
10, Shah & Trupti Savani equity shares
2013 Utpal Shah* by way of
gift
August Utpal Praful Nirmala U. Savani Transfer of (950) 10 Nil Gift
10, 2013 Shah & Trupti equity shares
Utpal Shah* by way of
gift
August Utpal Praful Sanjaykumar R. Transfer of (850) 10 Nil Gift
10, 2013 Shah & Trupti Patel equity shares
Utpal Shah* by way of
gift
August Utpal Praful Anitaben S. Patel Transfer of (150) 10 Nil Gift
10, 2013 Shah & Trupti equity shares
Utpal Shah* by way of
gift
August Utpal Praful Kalpana M. Mehta Transfer of (300) 10 Nil Gift
10, 2013 Shah & Trupti equity shares
Utpal Shah* by way of
gift
August Utpal Praful Deepak Hundraj Transfer of (200) 10 Nil Gift
10, 2013 Shah & Trupti Devnani equity shares
Utpal Shah* by way of
gift
August Utpal Praful Sonal D. Shah Transfer of (150) 10 Nil Gift
10, 2013 Shah & Trupti equity shares
Utpal Shah* by way of
gift
August Utpal Praful Alpa B. Patel Transfer of (1,000) 10 Nil Gift
26, 2013 Shah & Trupti equity shares
Utpal Shah* by way of
gift
December Utpal Praful Vishnuprasad S. Transfer of (300) 10 Nil Gift
31, 2013 Shah & Trupti Patel equity shares
Utpal Shah* by way of
gift
December Utpal Praful Diritkumar D. Transfer of (850) 10 Nil Gift
31, 2013 Shah & Trupti Patel equity shares
Utpal Shah* by way of
gift
258Date of Name of Name of Nature of Number of Face Transfe Nature of
transfer transferor transferee transaction equity value r price consideratio
shares per per n
transferre equit equity
d y share
share (₹)
(₹)
December Utpal Praful Priti Dixit Patel Transfer of (150) 10 Nil Gift
31, 2013 Shah & Trupti equity shares
Utpal Shah* by way of
gift
December Utpal Praful Deepak Hundraj Transfer of (1,000) 10 Nil Gift
31, 2013 Shah & Trupti Devnani equity shares
Utpal Shah* by way of
gift
March 19, Utpal Praful Manish B. Transfer of (850) 10 Nil Gift
2014 Shah & Trupti Vaghasia equity shares
Utpal Shah* by way of
gift
March 19, Utpal Praful Sangeeta M. Transfer of (150) 10 Nil Gift
2014 Shah & Trupti Vaghasia equity shares
Utpal Shah* by way of
gift
March 19, Utpal Praful Jayantibhai B. Transfer of (850) 10 Nil Gift
2014 Shah & Trupti Patel equity shares
Utpal Shah* by way of
gift
March 19, Utpal Praful Vidhyaben J. Patel Transfer of (150) 10 Nil Gift
2014 Shah & Trupti equity shares
Utpal Shah* by way of
gift
March 19, Utpal Praful Viral R. Bhatt Transfer of (500) 10 Nil Gift
2014 Shah & Trupti equity shares
Utpal Shah* by way of
gift
January Utpal Praful Kirit Govindlal Transfer (400) 10 Nil N.A.
02, 2015# Shah & Trupti Shah
Utpal Shah*
April 27, Utpal Praful Hansaben Transfer (300) 10 Nil N.A.
2015# Shah & Trupti Ghanshayam
Utpal Shah* Khatri
April 27, Utpal Praful Manish Kishanlal Transfer (300) 10 Nil N.A.
2015# Shah & Trupti Shajwani (HUF)
Utpal Shah*
April 27, Utpal Praful Kishanlal Transfer (300) 10 Nil N.A.
2015# Shah & Trupti Ramchand
Utpal Shah* Shajwani (HUF)
Novembe Utpal Praful Sonal Sanjaybhai Transfer (300) 10 Nil N.A.
r Shah & Trupti Shah
21, 2015# Utpal Shah*
January Nishaben Utpal Praful Shah Transfer 200 10 Nil N.A.
01, 2016# Ajaybhai & Trupti Utpal
Vakharia Shah*
February Sonal Sanjaybhai Utpal Praful Shah Transfer 300 10 Nil N.A.
12, 2016# Shah & Trupti Utpal
Shah*
October Seemaben Utpal Praful Shah Transfer 600 10 10 Cash
03, 2016 ashokbhai & Trupti Utpal
Prajapati Shah*
October Ashokbhai Utpal Praful Shah Transfer 600 10 10 Cash
03, 2016 Govindbhai & Trupti Utpal
Prajapati Shah*
Novembe Bhatt Dixita Utpal Praful Shah Transfer 200 10 10 Cash
r 17, 2016 Devang & Trupti Utpal
Shah*
259Date of Name of Name of Nature of Number of Face Transfe Nature of
transfer transferor transferee transaction equity value r price consideratio
shares per per n
transferre equit equity
d y share
share (₹)
(₹)
July 27, Upendra T Shah Utpal Praful Shah Transfer of 1500 10 Nil Gift
2017 & Purnima & Trupti Utpal equity shares
Upendra Shah* Shah* by way of
gift
February Utpal Praful Kirtibhai Transfer of (600) 10 Nil Gift
06, 2018 Shah & Trupti Prahladbhai Modi equity shares
Utpal Shah* by way of
gift
February Upendra Utpal Praful Shah Transfer 4000 10 10 Cash
06, 2018 Trikamlal Shah & Trupti Utpal
& Preeti Upendra Shah*
Shah & Utpal
Prafulbhai Shah /
Rajesh R Punjabi
May 03, Utpal Praful Kaushik Transfer of (600) 10 Nil Gift
2018 Shah & Trupti Bhikhabhai Patel equity shares
Utpal Shah* by way of
gift
May 03, Utpal Praful Mukeshbhai Transfer of (600) 10 Nil Gift
2018 Shah & Trupti Govndbhai Patel equity shares
Utpal Shah* by way of
gift
June 06, Vishnu Prasad Utpal Praful Shah Transfer 1,800 10 10 Cash
2018 Shivlal Patel & Trupti Utpal
Shah*
Septembe Chintan S. Parikh Utpal Praful Shah Transfer 1,800 10 52 Cash
r 25, 2019 & Trupti Utpal
Shah*
Septembe Bhadraben Utpal Praful Shah Transfer 2,000 10 52 Cash
r 25, 2019 bachubhai parikh & Trupti Utpal
Shah*
Septembe Mita Sanjiv Utpal Praful Shah Transfer 2,000 10 52 Cash
r 25, 2019 Parikh & Trupti Utpal
Shah*
Septembe Bachubhai Utpal Praful Shah Transfer 2,000 10 52 Cash
r 26, 2019 Jesinghbhai & Trupti Utpal
Parikh Shah*
Septembe Sanjiv B. Parikh Utpal Praful Shah Transfer 2,000 10 52 Cash
r 26, 2019 & Trupti Utpal
Shah*
July 16, Upendra T Shah Utpal Praful Shah Transfer of 50,000 10 Nil Gift
2021 & Purnima & Trupti Utpal equity shares
Upendra Shah* Shah* by way of
gift
March 23, Upendra T Shah Utpal Praful Shah Transfer of 50,000 10 Nil Gift
2022 & Purnima & Trupti Utpal equity shares
Upendra Shah* Shah* by way of
gift
March 6, Upendra T Shah Utpal Praful Shah Transfer of 1,00,000 10 Nil Gift
2023 & Purnima & Trupti Utpal equity shares
Upendra Shah* Shah* by way of
gift
January Upendra T Shah Utpal Praful Shah Transfer of 15,000 10 Nil Gift
20, 2024 & Purnima & Trupti Utpal equity shares
Upendra Shah* Shah* by way of
gift
January Purnima Utpal Praful Shah Transfer of 10,000 10 Nil Gift
20, 2024 Upendra Shah & & Trupti Utpal equity shares
Upendra T Shah* Shah*
260Date of Name of Name of Nature of Number of Face Transfe Nature of
transfer transferor transferee transaction equity value r price consideratio
shares per per n
transferre equit equity
d y share
share (₹)
(₹)
by way of
gift
February Upendra T Shah Utpal Praful Shah Transfer of 25,000 10 Nil Gift
21, 2024 & Purnima & Trupti Utpal equity shares
Upendra Shah* Shah* by way of
gift
July 24, Upendra T Shah Utpal Praful Shah Transfer of 75,000 10 Nil Gift
2024 & Purnima & Trupti Utpal equity shares
Upendra Shah* Shah* by way of
gift
July 24, Purnima Utpal Praful Shah Transfer of 75,000 10 Nil Gift
2024 Upendra Shah & & Trupti Utpal equity shares
Upendra T Shah* Shah* by way of
gift
Utpal P. Shah HUF
March 20, Upendra Utpal P. Shah Transfer of 800 10 Nil Gift
2013 Trikamlal Shah HUF equity shares
HUF by way of
gift
August Doctor Shachish Utpal P. Shah Transfer 600 10 65 Cash
01, 2016 piyush HUF
December Jayesh Utpal P. Shah Transfer 400 10 55 Cash
17, 2020 Jitandrabhai HUF
Pitaliya
December Jinal Shah Utpal P. Shah Transfer 1,200 10 55 Cash
17, 2020 HUF
December Pradip Ashwin Utpal P. Shah Transfer 400 10 55 Cash
17, 2020 kumar Roy HUF
December Hemant Uday Utpal P. Shah Transfer 400 10 55 Cash
17, 2020 Kumar Roy HUF
December Samir Rajendra Utpal P. Shah Transfer 200 10 55 Cash
17, 2020 Shah HUF
December Shah Khushali Utpal P. Shah Transfer 400 10 55 Cash
17, 2020 Pankaj Kumar HUF
December Chokshi Jyotika Utpal P. Shah Transfer 400 10 55 Cash
17, 2020 Harivadan HUF
December Chirag Utpal P. Shah Transfer 1,200 10 55 Cash
17, 2020 Vinodchandra HUF
Shah
December Shah Deval Utpal P. Shah Transfer 100 10 55 Cash
17, 2020 Milan Kumar HUF
December Purvi Hitesh Utpal P. Shah Transfer 8,000 10 55 Cash
17, 2020 Patel HUF
December Sameer M Utpal P. Shah Transfer 400 10 55 Cash
17, 2020 Chiplunkar HUF
December Jignesh Utpal P. Shah Transfer 3,200 10 55 Cash
17, 2020 Naveenchandra HUF
Shukla
January Naveen Kejriwal Utpal P. Shah Transfer 1,500 10 55 Cash
29, 2021 HUF
March 23, Dr. Nirupama Utpal P. Shah Transfer 7,000 10 55 Cash
2021 Kirit Shah HUF
August Vishal Utpal P. Shah Transfer 1,200 10 Nil N.A.
11, 2022# Dipakkumar HUF
Parikh
261Date of Name of Name of Nature of Number of Face Transfe Nature of
transfer transferor transferee transaction equity value r price consideratio
shares per per n
transferre equit equity
d y share
share (₹)
(₹)
December Mahesh R Utpal P. Shah Transfer 1,800 10 72 Cash
06, 2023 Gandhi HUF
December Gandhi Sushma Utpal P. Shah Transfer 1,800 10 72 Cash
23, 2023 Mahesh HUF
June 20, Varshaben Utpal P. Shah Transfer 1,000 10 81 Cash
2024 Giriskumar HUF
Gadani
Novembe Modi Jigar Utpal P. Shah Transfer 3,000 10 85 Cash
r 18, 2024 HUF
Rehaan Utpal Shah
August Upendra T Shah Rehaan Utpal Transfer 1,00,000 10 10 Cash
20, 2008 & Purnima Shah
Upendra Shah*
March 20, Upendra T Shah Rehaan Utpal Transfer 10,000 10 Nil N.A.
2013# & Purnima Shah
Upendra Shah *
Aashna Utpal Shah
August Upendra T Shah Aashna Utpal Transfer 1,00,000 10 10 Cash
20, 2008 & Purnima Shah
Upendra Shah*
March 20, Upendra T Shah Aashna Utpal Transfer 10,000 10 Nil N.A.
2013# & Purnima Shah
Upendra Shah*
Pritish Praful Shah
July 19, Gaurangi Praful Pritish Praful Transmissio 1,650 10 Nil Transmission
2022 Shah Shah n due to
demise of
Gaurangi
Praful Shah
Nivedita Vijay Vyas
October Ashvin Nivedita Vijay Transfer 1,650 10 63.03 Cash
31, 2018 Chinubhai Vyas & Vijay
Broking Pvt. Ltd. Manubhai Vyas*
Preeti Upendra Shah
June 15, Jayantibhai K Preeti Upendra Transfer 4,000 10 10 Cash
1995 Patel & Kokila J Shah & Purnima
Patel* Upendra Shah*
October Vipul Preeti Upendra Transfer 20,000 10 10 Cash
30, 1996 Chandrakant Shah & Purnima
Desai & Upendra Shah*
Chandrakant A
Desai*
Septembe Vipul Preeti Upendra Transfer 5,000 10 6 Cash
r 15, 1997 Chandrakant Shah & Purnima
Desai & Upendra Shah*
Chandrakant A
Desai*
October Trishla Bhimani Preeti Upendra Transfer 6,000 10 7 Cash
15, 2001 & Sandhya R. Shah & Purnima
Punjabi* Upendra Shah*
February Ajitkumar M. Preeti Upendra Transfer 2,000 10 7.5 Cash
11, 2002 Sheth & Bhavna Shah & Purnima
Ajitkumar Upendra Shah*
Sheth*
March 16, Kanubhai N. Preeti Upendra Transfer 100 10 10 Cash
2002 prajapati Shah & Purnima
Upendra Shah*
262Date of Name of Name of Nature of Number of Face Transfe Nature of
transfer transferor transferee transaction equity value r price consideratio
shares per per n
transferre equit equity
d y share
share (₹)
(₹)
July 01, Mittal Preeti Upendra Transfer 1,000 10 8 Cash
2002 Narendrakumar Shah & Purnima
Joshi Upendra Shah*
July 01, Sheelaben D. Preeti Upendra Transfer 900 10 8 Cash
2002 Patel & Shah & Purnima
Dilipkumar R. Upendra Shah*
Patel*
July 01, Sheelaben D. Preeti Upendra Transfer 900 10 8 Cash
2002 Patel & Shah & Purnima
Dilipkumar R. Upendra Shah*
Patel*
July 01, Sheelaben D. Preeti Upendra Transfer 700 10 8 Cash
2002 Patel & Shah & Purnima
Dilipkumar R. Upendra Shah*
Patel*
July 01, Divya R. Dave & Preeti Upendra Transfer 500 10 8 Cash
2002 Raksheh V. Shah & Purnima
Dave* Upendra Shah*
July 01, Gitaben J. Patel Preeti Upendra Transfer 500 10 Nil N.A.
2002# Shah & Purnima
Upendra Shah*
July 01, Hiren J. Patel & Preeti Upendra Transfer 1,000 10 8 Cash
2002 Jitendra R. Patel* Shah & Purnima
Upendra Shah*
July 01, Sanket J. Patel Preeti Upendra Transfer 1,000 10 8 Cash
2002 Shah & Purnima
Upendra Shah*
July 01, ,Kashyap C. Preeti Upendra Transfer 500 10 8 Cash
2002 Sitwala & Shah & Purnima
Chandravadan C. Upendra Shah*
Sitwala*
July 01, Drigesh C. Preeti Upendra Transfer 500 10 8 Cash
2002 Sitwala Shah & Purnima
Upendra Shah*
July 01, Chandravadan C. Preeti Upendra Transfer 500 10 8 Cash
2002 Sitwala Shah & Purnima
Upendra Shah*
July 01, Manubhai L. Preeti Tej Shah & Transfer 5,000 10 8 Cash
2002 Shah & Snehlata Tej Jitendra Shah*
M. Shah*
July 01, Snehlata M. Shah Preeti Tej Shah & Transfer 5,000 10 8 Cash
2002 & Sachin M. Tej Jitendra Shah*
Shah*
July 01, Chirag M Shah & Preeti Tej Shah & Transfer 4,000 10 8 Cash
2002 Sachin M. Shah* Tej Jitendra Shah*
July 01, Sachin M. Shah Preeti Tej Shah & Transfer 2,000 10 8 Cash
2002 & Chirag M Tej Jitendra Shah*
Shah*
July 01, Prafulla A. Preeti Tej Shah & Transfer 1,000 10 8 Cash
2002 Thakkar & Tej Jitendra Shah*
Arvind M
Thakkar*
July 01, Prafulla A. Preeti Tej Shah & Transfer 500 10 8 Cash
2002 Thakkar & Tej Jitendra Shah*
Arvind M
Thakkar*
July 01, Arvind M Preeti Tej Shah & Transfer 1,500 10 8 Cash
2002 Thakkar & Tej Jitendra Shah*
263Date of Name of Name of Nature of Number of Face Transfe Nature of
transfer transferor transferee transaction equity value r price consideratio
shares per per n
transferre equit equity
d y share
share (₹)
(₹)
Prafulla A.
Thakkar*
April 30, Mahendra B. Preeti Tej Shah & Transfer 5,000 10 8 Cash
2003 Patel & Tej Jitendra Shah*
Vikrambhai J.
Patel & Mukesh
Madhusudan
chitre*
April 30, Jaswantbhai S. Preeti Tej Shah & Transfer 5,000 10 8 Cash
2003 Khamar Tej Jitendra Shah*
April 30, Sevantilal P. Preeti Tej Shah & Transfer 500 10 8 Cash
2003 Shah & Varsha S. Tej Jitendra Shah*
Shah*
April 30, Minaxiben M. Preeti Tej Shah & Transfer 500 10 8 Cash
2003 Shah Tej Jitendra Shah*
April 30, Kaivan Shah & Preeti Tej Shah & Transfer 500 10 8 Cash
2003 Shobhana Shah* Tej Jitendra Shah*
April 30, Pushpa Dilip Preeti Tej Shah & Transfer 500 10 8 Cash
2003 Shah & Dilip Tej Jitendra Shah*
Babulal Shah*
April 30, Charulata Preeti Tej Shah & Transfer 500 10 8 Cash
2003 Mangeshkumar Tej Jitendra Shah*
Shah &
Mangeshkumar
Shah*
April 30, Purnima Preeti Tej Shah & Transfer 500 10 8 Cash
2003 Rohitkumar Shah Tej Jitendra Shah*
& Rohit Shah*
April 30, Leenaben Preeti Tej Shah & Transfer 500 10 8 Cash
2003 Janakbhai Shah Tej Jitendra Shah*
April 30, Dharmendra V. Preeti Tej Shah & Transfer 500 10 8 Cash
2003 Shah Tej Jitendra Shah*
April 30, Bhupendra Preeti Tej Shah & Transfer 500 10 8 Cash
2003 Vastupal Shah & Tej Jitendra Shah*
Sangita Shah*
April 30, Narendra Preeti Tej Shah & Transfer 500 10 8 Cash
2003 Vastupal Shah & Tej Jitendra Shah*
Nandu Shah*
April 30, Vastupalbhai Preeti Tej Shah & Transfer 500 10 8 Cash
2003 Keshavlal Shah Tej Jitendra Shah*
& Narendra
Shah*
April 30, Devang H. Jani Preeti Tej Shah & Transfer 200 10 4 Cash
2003 Tej Jitendra Shah*
August Preeti Tej Shah & Ruchira Tanmay Transfer (4,500) 10 10 Cash
30, 2007 Tej Jitendra Shah
Shah*
March 31, Preeti Tej Shah & Ruchira Tanmay Transfer (23,000) 10 10 Cash
2008 Tej Jitendra Shah
Shah*
March 31, Preeti Tej Shah & Ruchira Tanmay Transfer (52,500) 10 10 Cash
2008 Tej Jitendra Shah
Shah*
March 31, Preeti Tej Shah & Ruchira Tanmay Transfer (5,500) 10 10 Cash
2008 Tej Jitendra Shah
Shah*
July 27, Upendra T Shah Preeti Upendra Transfer of 1,500 10 N.A. Gift
2017 & Purnima Shah equity shares
Upendra Shah*
264Date of Name of Name of Nature of Number of Face Transfe Nature of
transfer transferor transferee transaction equity value r price consideratio
shares per per n
transferre equit equity
d y share
share (₹)
(₹)
by way of
gift
Septembe Luv Vikram Preeti Upendra Transfer 3,000 10 Nil N.A.
r 12, Kothari Shah
2018#
July 16, Upendra T Shah Preeti Upendra Transfer of 50,000 10 N.A. Gift
2021 & Purnima Shah equity shares
Upendra Shah* by way of
gift
March 23, Upendra T. Shah Preeti Upendra Transfer of 50,000 10 N.A. Gift
2022 & Purnima U. Shah equity shares
Shah* by way of
gift
March 06, Upendra T. Shah Preeti Upendra Transfer of 1,00,000 10 N.A. Gift
2023 & Purnima U. Shah equity shares
Shah* by way of
gift
January Purnima Preeti Upendra Transfer of 20,000 10 N.A. Gift
20, 2024 Upendra Shah & Shah equity shares
Upendra T Shah* by way of
gift
January Upendra T. Shah Preeti Upendra Transfer of 30,000 10 N.A. Gift
20, 2024 & Purnima U. Shah equity shares
Shah* by way of
gift
February Upendra T. Shah Preeti Upendra Transfer of 50,000 10 N.A. Gift
21, 2024 & Purnima U. Shah equity shares
Shah* by way of
gift
Kenisha Tanmay Shah
December Upendra T Shah Kenisha Tanmay Transfer 1,00,000 10 10 Cash
01, 2010 & Purnima Shah
Upendra Shah*
March 20, Upendra T. Shah Kenisha Tanmay Transfer 20,000 10 Nil N.A.
2013# & Purnima U. Shah
Shah*
March 21, Purnima Kenisha Tanmay Transfer of 600 10 Nil Gift
2013 Upendra Shah & Shah equity shares
Upendra T Shah* by way of
gift
Ruchira Tanmay Shah
August Preeti Tej shah & Ruchira Tanmay Transfer 4,500 10 10 Cash
30, 2007 Tej Jitendra Shah
Shah*
March 31, Trupti Utpal Ruchira Tanmay Transfer 4,500 10 10 Cash
2008 Shah & Purnima Shah
Upendra Shah*
March 31, Preeti Tej shah & Ruchira Tanmay Transfer 23,000 10 10 Cash
2008 Tej Jitendra Shah
Shah*
March 31, Preeti Tej shah & Ruchira Tanmay Transfer 52,500 10 10 Cash
2008 Tej Jitendra Shah
Shah*
March 31, Preeti Tej shah & Ruchira Tanmay Transfer 5,500 10 10 Cash
2008 Tej Jitendra Shah
Shah*
March 31, Trupti Utpal Ruchira Tanmay Transfer 81,000 10 10 Cash
2008 Shah & Purnima Shah
Upendra Shah*
265Date of Name of Name of Nature of Number of Face Transfe Nature of
transfer transferor transferee transaction equity value r price consideratio
shares per per n
transferre equit equity
d y share
share (₹)
(₹)
March 20, Upendra T Shah Ruchira Tanmay Transfer 20,100 10 Nil N.A.
2013# & Purnima Shah
Upendra Shah*
July 27, Upendra T Shah Ruchira Tanmay Transfer 1,500 10 10 Cash
2017 & Purnima Shah
Upendra Shah*
July 16, Upendra T Shah Ruchira Tanmay Transfer of 1,00,000 10 N.A. Gift
2021 & Purnima Shah equity shares
Upendra Shah* by way of
gift
March 23, Upendra T. Shah Ruchira Tanmay Transfer of 1,00,000 10 N.A. Gift
2022 & Purnima U. Shah equity shares
Shah* by way of
gift
March 06, Upendra T. Shah Ruchira Tanmay Transfer of 1,00,000 10 N.A. Gift
2023 & Purnima U. Shah equity shares
Shah* by way of
gift
January Upendra T. Shah Ruchira Tanmay Transfer of 30,000 10 N.A. Gift
20, 2024 & Purnima U. Shah equity shares
Shah* by way of
gift
January Purnima Ruchira Tanmay Transfer of 20,000 10 N.A. Gift
20, 2024 Upendra Shah & Shah equity shares
Upendra T Shah* by way of
gift
February Upendra T. Shah Ruchira Tanmay Transfer of 50,000 10 N.A. Gift
21, 2024 & Purnima U. Shah equity shares
Shah* by way of
gift
Siddhartha Mahendrabhai Mehta
Septembe Siddharth Purnima Upendra Transfer (5,000) 10 6 Cash
r 17, 1998 Mahendrabhai Shah & Upendra T
Mehta & Sunil Shah*
M. Mehta*
Praful Kacharabhai Shah
December Upendra T Shah Praful K. Shah & Transfer of 400 10 Nil Gift
01, 2010 & Purnima Gauri P. Shah & equity shares
Upendra Shah* Pritish P. Shah* by way of
gift
April 23, Upendra T Shah Praful K. Shah Transfer of 400 10 Nil Gift
2013 & Purnima equity shares
Upendra Shah* by way of
gift
Note: N.A. refers to Not Available
*The shares our held jointly by the shareholders. The names of the transferor, transferee, and the transfer price per equity share as per the
details available from the stock broker’s Delivery Instruction Slip (DIS), SH-4 (share transfer from under companies act, 2013), and Form-
7B (share transfer from under companies act,1956). Except the transaction with#
#The DIS/SH-4/Form-7B could not be traced, we have referred to the list of transfers attached to the annual return filed by the company with
the Registrar of Companies (ROC), along with the Demat transaction statements, to identify the transferor and transferee names and their
Client-IDs. However, due to the unavailability of transfer price information in annual return/ Demat transaction statements, the transfer price
for these transactions could not be determined and has therefore been reported as NIL.
$ The name of the transferor could not be identified as the relevant DIS/SH-4/Form-7B for the said transactions are not available; however,
the Client ID has been identified from the demat transaction statement.
(b) Preference share capital
As on the date of this Draft Red Herring Prospectus, our Company does not have any outstanding preference
shares.
2662. Equity shares issued for consideration other than cash or by way of bonus issue
Except as detailed below, our Company has not issued any Equity Shares (i) by way of bonus issue; or (ii) for
consideration other than cash at any time, since incorporation.
Issue
No of Face Reason/ Form/Nature
Date of price per
Equity value Nature of Name of allottees of
allotment equity
Shares (₹) Allotment consideration
share (₹)
November 45,00,000 10 N.A. Bonus Number N.A.
Sr. Name of allottee /
01, 2007 issue in of equity
No. shareholder
the ratio of shares
(one) 1 1. Anila R. Patel & R.M.
20,000
equity Patel*
share for 2. Akshaya S. Shah 5,000
every 3. Avni Shah & Ashit Shah* 500
(one) 1
4. Bharat M. Shah 10,000
equity
5. Bachubhai Parikh &
share held. 1,000
Sanjiv Parikh*
6. Bhadraben Parikh & Mita
1,000
Parikh*
7. Bharti Shah & Parag
1,000
Shah*
8. Chandraben Madhubhai
1,000
Parmar & M.S. Parmar*
9. Dipak S. Shah & S.D.
5,000
Shah*
10. Dhawal Babubhai Patel &
500
Dipti Shah*
11. Girish Shah & Lata Shah* 500
12. Harshad B. Bhimani &
5,000
R.H. Bhimani*
13. Harish R. Punjabi & P.H.
2,000
Punjabi*
14. Hetal Jayesh Shah & J.G.
2,500
Shah*
15. Hetalben Patel 500
16. Shah Heeta Naraeshbhai
500
& B.N. Shah*
17. Hetal J. Shah & Jayesh G.
500
Shah*
18. Jayesh Girishbhai Shah &
2,500
H.J. Shah*
19. Jitendrakumar Amichand
500
Patel & P.J. Patel*
20. Jitendra Govindbhai Patel
500
& H.J. Patel*
21. Jignesh Shukla & Tushar
500
Shukla*
22. Jitendra Sariya &
Ushaben Sariya & 2,000
Mamataben Sariya*
23. Kirit Kantilal Shah &
3,500
N.K. Shah*
24. Kaushalya S. Madhyani &
500
S.T. Madhyani*
25. Kishori Nagori & K.N.
500
Nagori*
26. Kusumben Patel 500
27. Shah Kunal Satishbhai &
500
S.B. Shah*
267Issue
No of Face Reason/ Form/Nature
Date of price per
Equity value Nature of Name of allottees of
allotment equity
Shares (₹) Allotment consideration
share (₹)
28. Kirit Kantilal Shah &
N.K. Shah & Darshna K. 500
Shah*
29. Krishnajivan Bhikhalal
1,000
Mehta
30. Lata Shah & Girish Shah 500
31. Lilavatiben Patel &
500
Pravin Patel*
32. Maulik R. Patel &
10,000
Rameshchandra M. Patel*
33. Manisha Paresh Patel 500
34. Madhusudan Patel 500
35. Nirupama K. Shah &
3,500
K.K. Shah*
36. Nalin Sumtilal Shah &
3,000
R.N. Shah*
37. Jignesh N. Shukla 500
38. Navinchandra Patel &
500
K.J. Patel*
39. Nilesh Girishbhai Modi &
1,000
P.N. Modi*
40. Purnima Upendra Shah &
10,02,400
Upendra T. Shah*
41. Priti U. Shah & P.
1,61,000
Upendra Shah*
42. Preeti T. Shah & Tej J.
2,80,200
Shah*
43. Pankaj Jitendra Patel &
500
J.A. Patel*
44. Poonam H. Punjabi &
2,000
H.R. Punjabi*
45. Prakash L. Punjabi & A.P.
500
Punjabi*
46. Purvi Patel & Hitesh
2,000
Patel*
47. Pratik Rameshchandra
10,000
Patel & R.M. Patel*
48. Rajesh R. Punjabi & S.R.
2,73,600
Punjabi*
49. Rameshchandra M. Patel
20,000
& A.R. Patel*
50. Raksha J. Shah & R.N.
500
Shah*
51. Ramjibhai M. Patel
600
(Poonam H. Punjabi) *
52. Ranchhod N. Shah & R.J.
500
Shah*
53. Rekhaben Patel &
500
Madhusudan Patel*
54. Ruchira T. Shah &
9,000
Tanmay U. Shah*
55. Sandhya R. Punjabi &
1,32,500
R.R. Punjabi*
56. Sanjay Sumitlal Shah &
2,000
R.S. Shah*
57. Sonal Deepakbhai Shah &
6,000
D.S Shah*
58. Tej Jitendra Shah & Preeti
69,200
T. Shah*
268Issue
No of Face Reason/ Form/Nature
Date of price per
Equity value Nature of Name of allottees of
allotment equity
Shares (₹) Allotment consideration
share (₹)
59. Trupti U. Shah & P.
2,30,900
Upendra Shah*
60. Tej J. Shah 500
61. Tanmay Upendra Shah &
2,87,200
P. Upendra Shah*
62. Tej Shah 5,000
63. Upendra Trikamlal Shah
17,89,700
& P. Upendra Shah*
64. Utpal P. Shah & Trupti U.
12,000
Shah*
65. Upendra Trikamlal Shah
52,000
& Trikamlal F. Shah*
66. Upendra Trikamlal Shah
(HUF) & Tanmay 56,200
Upendra Shah*
67. Vipul C. Desai & C.A.
1,000
Desai*
68. Vinodiniben Sureshbhai
500
Shah & S.G. Shah*
69. Vidhyut Shah 1,000
70. Vimlaben V. Patel 500
71. Vithalbhai H. Patel 500
November 85,35,400 10 N.A. Bonus Number N.A.
Sr. Name of allottee /
21, 2017 issue in of equity
No. shareholder
the ratio of shares
(one) 1 1. Aashit Jitendrabhai
900
equity Jhaveri
share for 2. Aashna Utpal Shah 1,10,000
every 3. Abdur Rehman A.
(one) 1 Menon &
1,200
equity Gulammohamed A.
share. Menon*
4. Ajaykumar N Chaudhari 2,000
5. Akshaya Shah 10,000
6. Amit Ashokbhai Parikh 3,000
7. Amita Kaushik Patel &
Kaushikkumar Ramanlal 300
Patel*
8. Amrut Ramanlal
1,000
Chaudhari
9. Anand A. Dalal 1,500
10. Anil Baldevbhai Patel 1,050
11. Anila Rameshchandra
Patel & Rameshchandra 40,000
Motibhai Patel*
12. Anitaben Sanjaykumar
450
Patel
13. Anuradha & Rajiv 900
14. Arunaben Jitendrakumar
400
Desai
15. Arunakumar Babulal
350
Vyas
16. Arvind Maneklal Patel &
750
Renuka Arvind Patel*
269Issue
No of Face Reason/ Form/Nature
Date of price per
Equity value Nature of Name of allottees of
allotment equity
Shares (₹) Allotment consideration
share (₹)
17. Ashokkumar Bapulal
Shah & Purnima 900
Ashokkumar Shah*
18. Ashvin Chinubhai Dalal 600
19. Atul Chandrakant Shah 600
20. Atulbhai Chandrakant
300
Shah
21. Atulkumar
600
Vinodchandra Shah
22. Bachubhai Jesingbhai
2,000
Parikh
23. Baiju Manubhai Patel &
400
Kinal Baijubhai Patel*
24. Bhadraben Bachubhai
2,000
Parikh
25. Bhanuben Natverlal
900
Shah
26. Bharat Mohanlal Shah 10,000
27. Bharat Natverlal Shah 900
28. Bharat Jayantilal Patel 300
29. Bharat Pravinchandra
Daftary & Nayana 300
Bharat Daftary*
30. Bharatbhai Gopani 900
31. Bharati Suresh Shah 300
32. Bharatkumar I. Patel 400
33. Bharatkumar Vallabhdas
600
Daftary
34. Bharti Shah & Parag
2,000
Shah*
35. Bhavesh Jitendrakumar
800
Desai
36. Bhavi Shalin Shah &
Shah Hansaben 100
Anilkumar*
37. Bhavin Shaileshbhai
200
Shah
38. Bhavini R. Shah 200
39. Bhavna Piyushkumar
400
Dani
40. Bhavna Sanjay Patel &
900
Sanjay H. Patel*
41. Bhikhbhai T. Patel 600
42. Bhikhalal Hajarimal
900
Soni
43. Bhumika Vatsal Shah 100
44. Bhumika Mahesh
900
Shajwani
45. Bhumika Viral Kapadia 300
46. Bijal Rakeshbhai Doshi 900
47. Bina Kalpeshkumar
900
Shah
48. Bindu R. Patel & Rajiv
1,800
N. Patel*
49. Bipinchandra Popatlal
900
Patel
270Issue
No of Face Reason/ Form/Nature
Date of price per
Equity value Nature of Name of allottees of
allotment equity
Shares (₹) Allotment consideration
share (₹)
50. Bunty Hundraj 9,000
51. Chandraben Madhubhai
2,000
Parmar
52. Chandrakant Purshottam
Dave & Jyotiben 900
Chandrakant Dave*
53. Chandrikaben B. Patel 450
54. Chandubhai Haribhai
900
Patel
55. Chetnaben Arvindbhai
900
Patel
56. Chintan S. Parikh 900
57. Chirag Vinodchandra
600
Shah
58. Choksi Jyotika
200
Harivadan
59. Darshan B. Patel 850
60. Dave Dhruva Hardik &
Dave Hardikkumar 1,000
Harvadan*
61. Davendra Somabhai
900
Patel
62. Daxa Vallabhbhai Patel 900
63. Deepak Shah & Sonal
10,000
Shah*
64. Desai Vipul C. 2,300
65. Devang Navinchandra
1,200
Gandhi
66. Dhaval B. Patel &
1,000
Babubhai A. Patel*
67. Dilipbhai R. Patel 300
68. Dinesh Buddhibhai Shah
& Jayshree Dinesh 2,100
Shah*
69. Dipak Babubhai Vora &
200
Rekha Dipak Vora*
70. Dipika Nikul Patel &
600
Nikul Jitendra Patel*
71. Dipika Nikul Patel 300
72. Divya Prakash Gera 600
73. Divyesh Babulal Shah 450
74. Doctor Shachish Piyush 300
75. Dr. Kirit Kantilal Shah &
Dr. Nirupama Kirit 5,000
Shah*
76. Dr. Nirupama Kirit Shah
& Dr. Kirit Kantilal 6,000
Shah*
77. Gandhi Sushmaben
900
Mahesh
78. Gangarambhai
500
Tribhovandas Patel
79. Gemarbhai Muljibhai
900
Patel
80. Ghanshyambhai P. Patel 1,500
271Issue
No of Face Reason/ Form/Nature
Date of price per
Equity value Nature of Name of allottees of
allotment equity
Shares (₹) Allotment consideration
share (₹)
81. Girish Hasmukhlal
900
Kotak
82. Gita Girish Kotak 900
83. Gita Hitendrabhai Patel 900
84. Gita B. Patel 500
85. Gopal Natverlal Shah 900
86. Govind Rukmanbhai
900
Nama
87. Gulam Mohmed A.
Memon & Usmangani A. 900
Memon*
88. Hansa Niranjanbhai
300
Patel
89. Hansaben
450
Narendrakumar Joshi
90. Hansaben Ghanshayam
900
Khatri
91. Hansaben M. Mehta &
850
Mahendra C. Mehta*
92. Harish Patel 600
93. Harsha Lalbhai Shah 200
94. Harshad Babulal Vyas 2,400
95. Harshadbhai Bhogilal
10,000
Bhimani
96. Hemant Udaykumar Roy 200
97. Hetal Jayesh Shah 6,000
98. Hinaben Dineshkumar
900
Shah
99. Hiral Janak Joshi 3,000
100. Hitendra Natvarlal Patel 900
101. Hitesh Chandrakant
600
Patel
102. Hitesh Vitthalbhai Patel
900
& Parul Hitesh Patel*
103. Inaxi Nareshbhai Shah 900
104. Induben Dineshbhai
600
Bhavsar
105. Jagruti Pravin Master &
900
Pravin Devidas Master*
106. Janki Krutin Shah 50
107. Jasica Mehta 900
108. Jayantibhai Bhikhabhai
2,550
Patel
109. Jayesh Jitendrabhai
200
Pittaliya
110. Jayesh Girish Shah 5,000
111. Jayshree P. Kotak 900
112. Jayshree Utkal Patel 100
113. Jigna Tejash Dave 1,800
114. Jignesh A. Maniar &
1,200
Ashwin T. Maniar*
115. Jignesh Navinchandra
1,600
Shukla
116. Jinal Shah & Arpita Shah 600
272Issue
No of Face Reason/ Form/Nature
Date of price per
Equity value Nature of Name of allottees of
allotment equity
Shares (₹) Allotment consideration
share (₹)
117. Jitendra Chandulal Modi 900
118. Jitendrakumar Dhirajlal
4,000
Saraiya
119. Jyotiben Chandrakant
Dave & Chandrakant 900
Purshottam Dave*
120. Jyotsana Rajendra Shah 1,800
121. Kaivan R. Shah 600
122. Kajal Ramesh Shah 200
123. Kalpanaben Manishbhai
900
Mehta
124. Kamleshbhai Dahyabhai
Patel & Ragini 900
Kamleshbhai Patel*
125. Kanan Sanjaybhai Dalal
& Sanjay Sarabhai 1,000
Dalal*
126. Kanchan Nareshbhai
2,550
Patel
127. Kanta Shyamlal Rohra 150
128. Kanubhai Natvarlal
600
Prajapati
129. Kaushik Bhikhabhai
600
Patel
130. Kaushikbhai Dahyabhai
Patel & Parulben 900
Kaushikbhai Patel*
131. Kaushikkumar Ramanlal
Patel & Amita 300
Kaushikkumar Patel*
132. Kenisha Shah 1,20,600
133. Ketan Tejpal Parikh 1,200
134. Khurshid Banu Parwala
1,200
& Parvez Parwala*
135. Kinjal Paresh Jansari 600
136. Kirankumar Ambalal
300
Patel
137. Kirit Kanjibhai Macwan 100
138. Kirit M. Patel & Vina K.
150
Patel*
139. Kishanlal Ramchand
900
Shajwani
140. Kotak Rajesh Maneklal 900
141. Kotak Rekhaben
1,800
Rajeshkumar
142. Kothari Dipan
700
Chandreshkumar
143. Krina Amit Parikh 2,100
144. Krishnajivan Bhikhalal
2,000
Mehta
145. Kundan Rameshbhai
1,500
Gandhi
146. Kundan Vallabhbhai
900
Patel
147. Lalita Ashok Shah 1,800
148. Luv Vikram Kothari 1,500
273Issue
No of Face Reason/ Form/Nature
Date of price per
Equity value Nature of Name of allottees of
allotment equity
Shares (₹) Allotment consideration
share (₹)
149. Mahendrabhai
Chandulal Mehta & 850
Hansaben M Mehta*
150. Mahesh Ramanlal
900
Gandhi
151. Mahesh Kishanlal
900
Shajwani
152. Malti Ashokbhai Parikh 2,100
153. Manish Kishanlal
900
Shajwani
154. Manish Babulal
850
Vaghasia
155. Manish D. Kansara 600
156. Manju Prashant Vyas &
Prashant Shankerprasad 50
Vyas*
157. Manjula K. Vyas 600
158. Maulik Rameshchandra
Patel & Rameshchandra 20,000
Motibhai Patel*
159. Modi Manisha
100
Pinalkumar
160. Modi Jigar Hiralal &
Modi Vidhyaben 1,500
Mulchanddas*
161. Modi Vidhyaben
Mulchanddas & Modi 1,500
Jigar Hiralal*
162. Mohamedyusuf Memon
& Mohamedjuned 900
Memon*
163. Monali Biren Shah 1,200
164. Nachiket Avinash Bhatt 900
165. Nagori Kishori
1,000
Krishnachandra
166. Nalin Sumatilal Shah 6,000
167. Nanubhai Popatbhai
600
Patel
168. Naranlal Maneklal Patel
& Vimlagauri Naranlal 750
Patel*
169. Narendrakumar
2,550
Ramanlal Joshi
170. Naresh Hargovindbhai
900
Patel
171. Natverlal Shankerlal
900
Shah
172. Naveen Kejriwal 250
173. Navinchandra V. Shah &
1000
Manjula N. Shah*
174. Nayna Devendra Patel 900
175. Neeta Dipak Patel &
900
Dipak Ramanlal Patel*
176. Neha Tarun Patel 100
177. Nikita Bharatbhai
200
Choksi
274Issue
No of Face Reason/ Form/Nature
Date of price per
Equity value Nature of Name of allottees of
allotment equity
Shares (₹) Allotment consideration
share (₹)
178. Nilesh Girishbhai Modi
& Palak Nileshbhai 2,000
Modi*
179. Nilima Yogeshchandra
Neve & Yogeshchandra 1,500
Manohar Neve*
180. Nirav Ramanlal Patel &
Urmilaben Kalidas 250
Patel*
181. Nirmala U. Savani 2,850
182. Nishant M. Shah 600
183. Nishant M. Shah 300
184. Nishith Shah 900
185. Pankajkumar
1,000
Jitendrakumar Patel
186. Parikh Heeta Brijal 1,000
187. Parth Jitendra Patel 1,000
188. Patel Alpa Bhaveshbhai 1,000
189. Patel Bhadresh P. 300
190. Patel Dashrathbhai H. 450
191. Patel Dixitkumar
2,550
Dashrathbhai
192. Patel Hansaben P. 600
193. Patel Jankiben
450
Dharmendrakumar
194. Patel Kanubhai
450
Hargovindas
195. Patel Nikita Nareshbhai 450
196. Patel Rajeshkumar
1,000
Kevaldas
197. Patel Sanjaykumar
2,550
Rameshbhai
198. Pathik Atul Shah 300
199. Pathik Atulbhai Shah 600
200. Pearl Shah 1,20,000
201. Piyushkumar
600
Krishnachandra Dani
202. Poornima Ashokkumar
Shah & Ashokkumar 900
Bapulal Shah*
203. Pradip Ashwinkumar
200
Roy
204. Praful K. Shah & Gauri
1,200
P. Shah*
205. Prahash Fin-Stock PVT
3,000
LTD
206. Prakash Hasmukhlal
900
Kotak
207. Prashant Ukabhai Patel 900
208. Pratik Rameshchandra
Patel & Rameshchandra 20,000
Motibhai Patel*
209. Preeti Upendra Shah 2,80,900
210. Premilaben Anilkumar
900
Chauhan
275Issue
No of Face Reason/ Form/Nature
Date of price per
Equity value Nature of Name of allottees of
allotment equity
Shares (₹) Allotment consideration
share (₹)
211. Pritesh Gautam Shah &
50
Jagruti Pritesh Shah*
212. Priti Darshan Patel &
Darshan Bharatbhai 150
Patel*
213. Priti Upendra Shah &
3,22,000
Purnima Upendra Shah*
214. Pritiben Dixitkumar
450
Patel
215. Purnima Upendra Shah
& Upendra Trikamlal 20,04,800
Shah*
216. Purvi Hitesh Patel &
Hitesh Chandrakant 4,000
Patel*
217. Rajendra Chandulal
1,200
Shah
218. Rajesh Kishanchand
500
Rohra
219. Rajesh Ramchandra
Punjabi & Sandhya 5,700
Rajesh Punjabi*
220. Rajesh Kanitlal Patel 900
221. Rajesh Ramchand
4,47,200
Punjabi
222. Rajiv Bhavsar &
900
Anuradha Bhavsar*
223. Rajiv N. Patel 1,650
224. Rajiv N. Patel & Bindu
2,550
R. Patel*
225. Rajiv Tejpal Parikh 900
226. Ramesh C. Shah &
300
Shobhna R. Shah*
227. Rameshchandra
Motibhai Patel & Anila 40,000
Rameshchandra Patel*
228. Ranjan Narendra Patwa 900
229. Rashmiben P. Gujjar &
900
Pravinbhai M. Gujjar*
230. Rasiklal Manchandbhai
675
Doshi
231. Rehaan Utpal Shah 1,10,000
232. Renish Rajendrakumar
900
Shah
233. Renukaben
900
Arvindkumar Patel
234. Riddhiben Shreyansbhai
1,050
Doshi
235. Ritadevi Kishanlal
900
Shajwani
236. Roopa Monojkumar
Shah & Manojkumar L. 1,500
Shah*
237. Ruchira T. Shah 1,71,000
238. Ruchira Tanmay Shah &
30,600
Tanmay Upendra Shah*
239. Rupa Sunil Shah 600
240. Rupang Bharatbhai Shah 300
276Issue
No of Face Reason/ Form/Nature
Date of price per
Equity value Nature of Name of allottees of
allotment equity
Shares (₹) Allotment consideration
share (₹)
241. Sagar Rajesh Punjabi 24,850
242. Sameer M Chiplunkar 200
243. Samir Rajendra Shah &
100
Jyotsana Rajendra Shah*
244. Sandhya Rajesh Punjabi
& Rajesh Ramchandra 1,65,800
Punjabi*
245. Sangeeta Manishbhai
150
Vaghasia
246. Sanjay Hargovindbhai
300
Mistry
247. Sanjaybhai Sumtilal
4,000
Shah
248. Sarabai Usmangani
Memon & Usmangani A. 1,800
Memon*
249. Shah Alap Sudhirbhai 200
250. Shah Deval Milankumar 50
251. Shah Kamlesh
900
Jayantibhai
252. Shah Kaushali
200
Pankajkumar
253. Shah Minesh I. & Shah
900
Nila M. *
254. Shah Monali 2,550
255. Shah Sanjay Mohanlal 1,800
256. Shah Shrenik Mohanlal 1,800
257. Shah Sonalben
12,000
Dipakbhai
258. Shah Sukeshkumar
1,800
Mohanlal
259. Shah Vatsal Sudhirbhai 400
260. Shah Prakash
Kacharabhai & Shah 900
Sujay Prakash*
261. Shah Srujal
Nipamkumar & Pratibha 900
Shah*
262. Shailesh P. Shah 300
263. Shantiben N. Patel &
3,000
Rajiv N. Patel*
264. Sharad Bipinbhai Patel 3,600
265. Shardaben A. Shah &
Jaydip Arvindbhai 600
Shah*
266. Sheela Ajaybhai Dalal &
1,000
Ajay Sarabhai Dalal*
267. Sheelaben D. Patel 300
268. Sheetal Vyas 3,150
269. Shehjad Alam Naziralam
600
Shaikh
270. Shital Bihagbhai Angreji 900
271. Shobhan S. Parikh 300
272. Shobhna Janakkumar
900
Babaria
277Issue
No of Face Reason/ Form/Nature
Date of price per
Equity value Nature of Name of allottees of
allotment equity
Shares (₹) Allotment consideration
share (₹)
273. Shreyans Rasiklal Doshi 3,375
274. Shruti Rajesh Punjabi 1,04,800
275. Shweta Bhavin Kathiara 900
276. Shyamlal Thakurdas
850
Rohra
277. Sonal Rajiv Parikh 900
278. Soni Chandraeshkumar
900
Rasiklal
279. Soni Dilipkumar
900
Rasiklal
280. Sudha Kamlesh Modi 900
281. Sudhir Venkatesh
Kulkarni & Pushpa 1,000
Sudhir Kulkarni*
282. Sunny Amit Shah 300
283. Suresh Maneklal Shah &
900
Ramila Suresh Shah*
284. Swati Agrawal 1,000
285. Tanmay U Shah &
5,75,900
Purnima Upendra Shah*
286. Tanmay U Shah 5,300
287. Tapan Dineshbhai Shah 900
288. Tejas Nareshkumar Shah 300
289. Trupti Utpal Shah 2,32,300
290. Upendra Odhavjibhai
750
Savani
291. Upendra T Shah &
28,75,900
Purnima Upendra Shah*
292. Upendra Trikamlal Shah 1,16,400
293. Upendra Trikamlal Shah 1,00,000
294. Urmil Anubhai Shah 600
295. Utpal P. Shah 1,400
296. Utpal Praful Shah &
65,950
Trupti Utpal Shah*
297. Varshaben G. Gadani 1,000
298. Vasani Kajal Sandip 900
299. Vidhyaben Jayantibhai
450
Patel
300. Vidhyut Shah 2,000
301. Vimlaben Vitthalbhai
1,000
Patel
302. Vishal Dipakkumar
600
Parikh
303. Vishnuprasad Shivlal
900
Patel
304. Vitthalbhai Haribhai
1,000
Patel
305. Yogeshchandra Manohar
Neve & Nilima 300
Yogeshchandra Neve*
306. Avni Shah & Ashit Shah 500
307. Girish Shah & Lata Shah 1,000
278Issue
No of Face Reason/ Form/Nature
Date of price per
Equity value Nature of Name of allottees of
allotment equity
Shares (₹) Allotment consideration
share (₹)
308. Jitendrakumar
1,000
Amichand Patel
309. Ramjibhai M. Patel 1,200
310. Shah Kunal Satishbhai
Shah & Satishbhai 1,000
Bharatbhai Shah*
311. Vinodiniben Sureshbhai
Shah & Sureshbhai 1,000
Gokaldas Shah*
312. Lata Shah & Girish Shah 1,000
313. Lilavatiben Patel &
500
Pravin Patel*
314. Manisha Paresh Patel 1,000
315. Manish Babulal
1,700
Vaghasia
316. Alpa Bhaveshbhai Patel 2,000
317. Muskeshbhai
600
Govindbhai Patel
318. Vimal Dairy Limited 1,200
319. Nilay Bharatkumar
300
Contractor
320. Dinesh H Pande &
600
Santosh Dinesh Pande
321. Dipesh Sunilbhai Mehta 600
322. Yogesh Dilipbhai Patel 600
323. Paresh Mahendrakumar
600
Patel
324. Kiritkumar Modi 600
325. Amitbhai Popatlal Shah 600
326. Anjali Hiteshbhai Shah 600
327. Jignesh Maniar &
600
Shivani Maniar*
328. Piyush J. Vakil 600
329. Piyushkumar
Krishnachandra Dani &
1,200
Bhavana Piyushkumar
Dani*
330. Bhavana Piyushkumar
Dani & Piyushkumar 800
Krishnachandra Dani*
331. Sunil Prahladbhai Sevani 2,000
332. Kiranben Sunilbhai
2,000
Sevani
333. Mrunalini Patel 600
334. Rajesh Patel 300
335. Navinchandra V. Shah &
500
Manjulaben N. Shah*
336. Kaushikkumar Ramanlal
Patel & Amita 600
Kaushikkumar Patel*
337. Amita Kaushik &
Kaushikkumar Ramanlal 600
Patel*
338. Shobhan S. Parikh 600
279Issue
No of Face Reason/ Form/Nature
Date of price per
Equity value Nature of Name of allottees of
allotment equity
Shares (₹) Allotment consideration
share (₹)
339. Khodidas Prabhudas
600
Barot
340. Chander Murjani 2,000
341. Shyamlal T. Rohra 1,700
342. Dilipbhai R. Patel 600
343. Sheelaben D. Patel 600
344. Kanubhai M. Patel 600
345. Bhavesh Bhogilal Patel
600
& Hina Bhavesh Patel*
346. Nilam Mahesh Patel &
600
Mahesh Bhogilal Patel*
347. Renuben Manojbhai
2,000
Chhabadiya
348. Dipan Kothari 1,400
349. Rajesh Rohra 1,000
350. Sushilaben
600
Narendrabhai Dani
351. Bipin Vallabhbhai Patel 600
352. Nirav Dhansukhlal Shah 1,200
353. Samir Dashrathbhai
600
Patel
354. Bharti Dinesh Patel &
600
Dinesh Tulsidas Patel*
355. Sharadkumar Khodidas
600
Antala
356. Shamjibhai
1,000
Gangarambhai Vasova
357. Babubhai Premjibhai
600
Sukhadiya
358. Jagdishkumar Gopalbhai
600
Rakholiya
359. Kirankumar Patel &
600
Jyotsana Patel*
360. Sudhir Venkatesh
Kulkarni & Pushpa 2,000
Sudhir Kulkarni*
361. Bhumika Kapadia 600
362. Mittal N. Patel 500
363. Dharmesh Odhavjibhai
1,800
Savani
364. Jyotsanaben S. Patel 600
365. Truptiben Hiteshbhai
600
Shah
366. Arvindbhai Dahyabhai
Patel& Renukaben 600
Arvindbhai Patel*
367. Vinod Kirti Mehta 600
368. Sheela Ajay Dalal &
500
Ajay Sarabhai Dalal*
369. Kanan Sanjay Dalal &
500
Sanjay Sarabhai*
370. Shruti Agrawal 3,300
371. Hema J Kamdar 10,000
372. Swati Binod Agarwal 1,700
280Issue
No of Face Reason/ Form/Nature
Date of price per
Equity value Nature of Name of allottees of
allotment equity
Shares (₹) Allotment consideration
share (₹)
373. Ajay Shah 600
374. Anuj Jain 1,000
375. Ashvin Chinubhai Dalal 300
376. Harish Patel 300
377. Dharmesh K. Patel HUF 400
378. Varshaben G. Gadani 500
379. Naveen Kejriwal 500
380. Dhruva Hardikkumar
100
Dave
381. Sangeeta Manishbhai
300
Vaghasia
382. Kanta Shyamlal Rohra 300
383. Madhu Agrawal 300
384. Bhaveshkumar
400
Odhavjibhai Savani
385. Arunkumar Babulal
700
Vyas HUF
Note: N.A. refers to Not Applicable
*The shares our held jointly by the shareholders.
3. Issue of Equity Shares out of revaluation reserves
Our Company has not issued any Equity Shares or Preference Shares out of its revaluation reserves, since
incorporation.
4. Issue of Equity Shares pursuant to sections 391 to 394 of the Companies Act, 1956 or sections 230 to 234 of
the Companies Act, 2013
Our Company has not issued or allotted any Equity Shares or Preference Shares pursuant to any schemes of
arrangement approved under sections 391-394 of the Companies Act, 1956 or sections 230- 234 of the Companies
Act, 2013.
5. Issue of Equity Shares at a price lower than the Issue Price during the preceding one year
The Issue Price shall be determined by our Company, in consultation with the BRLM and in accordance with the
SEBI ICDR Regulations after the Bid / Issue Closing Date. Except as disclosed under “Capital Structure - Notes
to Capital Structure - Share Capital History of our Company” on page 105, our Company has not issued any
equity shares or preference shares in the preceding one year at a price that may be lower than the Issue Price.
6. Issue of Equity Shares under employee stock option scheme or a stock appreciation rights scheme
As on the date of this Draft Red Herring Prospectus, our Company does not have any employee stock options
scheme or a stock appreciation rights scheme.
7. Shareholding pattern of our Company
The table below presents the shareholding pattern of our Company, as on the date of this Draft Red Herring
Prospectus:
(The remainder of this page has been intentionally left blank)
281Categor Category of Number of Number Numbe Number Total Shareholdin Number of voting rights held in each class Number of Shareholding Number of Number of Equity Number of
y Shareholde Shareholder of fully r of of Equity number of g as a % of of securities Equity , as a % locked in Equity Shares pledged or Equity Shares
(I) r s paid-up partly Shares Equity total (IX) Shares assuming full Shares otherwise held in
(II) (III) Equity paid-up underlyin Shares number of underlying conversion of (XII) encumbered dematerialize
Shares Equity g held Equity outstandin convertible (XIII) d form
held Shares Depositor Shares g securities (as
(IV) held y Receipts (VII) = (calculated convertible a percentage (XIV)
(VI) (IV)+(V)+ as per Number of Voting Rights Total securities of diluted Numbe As a Numbe As a
(V) (VI) SCRR, as a (including Equity Share r (a) % of r (a) % of
1957) As a % of warrants) capital) total total
% of (A+B Equit Equit
Class
(A+B+C2) Class e.g. + C) (X) (XI)= y y
e.g.
(Equity Total (VII)+(X) As Share Share
(Others
(VIII) Shares) a % of s held s held
)
(A+B+C2) (b) (b)
Promoters 16 1,32,86,40 - - 1,32,86,40 84.33 1,32,86,40 - 1,32,86,40 84.33 - - - - - - 1,32,86,400
and 0 0 0 0
(A)
Promoter
Group
237 2,467,600 - - 2,467,600 15.67 2,467,600 - 2,467,600 15.67 - - - - - - 24,38,400^
(B) Public
Non- - - - - - - - - - - - - - - - - -
(C) Promoter-
Non-Public
Shares - - - - - - - - - - - - - - - - -
underlying
(C1)
depository
receipts
Shares held - - - - - - - - - - - - - - - - -
by
(C2)
Employee
Trusts
Total (A) + 253 15,754,000 - - 15,754,000 100 15,754,000 - - 100 - - - - - - 15,724,800
(B) + (C)
The above shareholding is based on the latest benpos available as of September 26, 2025
^As on date of the Draft Red Herring Prospectus 29,200 Equity Shares in the category Public are held in physical form
2828. Details of shareholding of the major Shareholders of our Company
(a) As on the date of this Draft Red Herring Prospectus, our Company has 253 Shareholders.
(b) Set forth below are details of Shareholders holding 1% or more of the paid-up Equity Share capital of our
Company, as on the date of this Draft Red Herring Prospectus:
Sr. Number of Equity Shares held of Percentage of pre-Issue Equity Share
Name of the Shareholder
No. face value of ₹10 each capital (%) *
1. Purnima Upendra Shah 3 4 , 5 0 , 0 0 0 21.90
2. Upendra T. Shah 3 0 ,0 0 ,0 0 0 19.04
3. Tanmay U. Shah 2 5 , 0 5 , 0 0 0 15.90
4. Preeti Upendra Shah 1 4 , 1 5 , 0 0 0 8.98
5. Rajesh Ramchand Punjabi 6 , 5 0 , 0 0 0 4.13
6. Trupti Utpal Shah 6 , 5 0 , 0 0 0 4.13
7. Ruchira Tanmay Shah 5 , 8 0 , 0 0 0 3.68
8. Utpal Praful Shah 5 , 3 0 , 0 0 0 3.36
9. Upendra Trikamlal Shah HUF 3 , 3 2 , 5 0 0 2.11
10. Shruti Rajesh Punjabi 3,00,000 1.90
11. Sandhya Rajesh Punjabi 2 , 5 0 , 0 0 0 1.59
12. Kenisha Shah 2 , 4 1 , 2 0 0 1.53
13. Pearl Tej Shah 2 , 4 0 , 0 0 0 1.52
14. Rehaan Utpal Shah 2 , 2 0 , 0 0 0 1.40
15. Aashna Utpal Shah 2 , 2 0 , 0 0 0 1.40
16. Sagar Rajesh Punjabi 1 , 7 1 , 7 0 0 1.09
Total 1,47,55,400 93.66
*Rounded Off
Based on the beneficiary position statement dated September 26, 2025
(c) Set forth below are details of Shareholders holding 1% or more of the paid-up Equity Share capital of our Company,
as of ten days prior to the date of this Draft Red Herring Prospectus:
Number of Equity Shares held of Percentage of pre-Issue Equity Share
Sr. No. Name of the Shareholder
face value of ₹10 each capital (%) *
1. Purnima Upendra Shah 3 4 ,5 0 ,0 0 0 21.90
2. Upendra T. Shah 3 0 , 0 0 , 0 0 0 19.04
3. Tanmay U. Shah 2 5 , 0 5 , 0 0 0 15.90
4. Preeti Upendra Shah 1 4 , 1 5 , 0 0 0 8.98
Rajesh Ramchand
5. 6,50,000 4.13
Punjabi
6. Trupti Utpal Shah 6 , 5 0 , 0 0 0 4.13
7. Ruchira Tanmay Shah 5 , 8 0 , 0 0 0 3.68
8. Utpal Praful Shah 5 , 3 0 , 0 0 0 3.36
9. Upendra Trikamlal Shah HUF 3 , 3 2 , 5 0 0 2.11
10. Shruti Rajesh Punjabi 3,00,000 1.90
11. Sandhya Rajesh Punjabi 2 , 5 0 , 0 0 0 1.59
12. Kenisha Shah 2 , 4 1 , 2 0 0 1.53
13. Pearl Tej Shah 2 , 4 0 , 0 0 0 1.52
14. Rehaan Utpal Shah 2 , 2 0 , 0 0 0 1.40
15. Aashna Utpal Shah 2 , 2 0 , 0 0 0 1.40
16. Sagar Rajesh Punjabi 1 , 7 1 , 7 0 0 1.09
283Total 1,47,55,400 93.66
*Rounded Off
Based on the beneficiary position statement dated September 19, 2025
(d) Set forth below are details of Shareholders holding 1% or more of the paid-up Equity Share capital of our
Company, as of one year prior to the date of this Draft Red Herring Prospectus:
Sr. Number of Equity Shares held of Percentage of pre- Issue Equity
Name of the Shareholder
No. face value of ₹10 each Share capital (%)
1. Purnima Upendra Shah 3 4 , 5 0 , 0 0 0 21.90
2. Upendra T. Shah 3 0 , 0 0 , 0 0 0 19.04
3. Tanmay U. Shah 2 5 , 0 5 , 0 0 0 15.90
4. Preeti Upendra Shah 1 4 , 1 5 , 0 0 0 8.98
5. Rajesh Ramchand Punjabi 6 , 5 0 , 0 0 0 4.13
6. Trupti Utpal Shah 6 , 5 0 , 0 0 0 4.13
7. Ruchira Tanmay Shah 5 , 8 0 , 0 0 0 3.68
8. Utpal Praful Shah 5 , 3 0 , 0 0 0 3.36
9. Upendra Trikamlal Shah
3,32,500 2.11
HUF
10. Shruti Rajesh Punjabi 3,00,000 1.90
11. Sandhya Rajesh Punjabi 2 , 5 0 , 0 0 0 1.59
12. Kenisha Shah 2 , 4 1 , 2 0 0 1.53
13. Pearl Tej Shah 2 , 4 0 , 0 0 0 1.52
14. Rehaan Utpal Shah 2 , 2 0 , 0 0 0 1.40
15. Aashna Utpal Shah 2 , 2 0 , 0 0 0 1.40
16. Sagar Rajesh Punjabi 1 , 6 8 , 7 0 0 1.07
Total 1,47,52,400 93.64
Based on the beneficiary position statement dated September 27, 2024.
(e) Set forth below are details of Shareholders holding 1% or more of the paid-up equity share capital of our Company
as of two years prior to the date of this Draft Red Herring Prospectus:
Sr. Number of Equity Shares held of Percentage of pre- Issue Equity
Name of the Shareholder
No. face value of ₹10 each Share capital (%)
1. Upendra T. Shah 39,50,000 25.07
2. Purnima Upendra Shah 38,00,000 24.12
3. Tanmay U. Shah 18,05,000 11.46
4. Preeti Upendra Shah 13,15,000 8.98
5. Rajesh Ramchand Punjabi 6,50,000 4.13
6. Ruchira Tanmay Shah 4,80,000 3.05
7. Trupti Utpal Shah 4,50,000 2.86
8. Upendra Trikamlal Shah HUF 3,32,500 2.11
9. Utpal Praful Shah 3,30,000 2.09
10. Shruti Rajesh Punjabi 3,00,000 1.90
11. Sandhya Rajesh Punjabi 2,50,000 1.59
12. Kenisha Shah 2,41,200 1.53
13. Pearl Tej Shah 2,40,000 1.52
14. Rehaan Utpal Shah 2,20,000 1.40
15. Aashna Utpal Shah 2,20,000 1.40
16. Sagar Rajesh Punjabi 1,68,700 1.07
284Sr. Number of Equity Shares held of Percentage of pre- Issue Equity
Name of the Shareholder
No. face value of ₹10 each Share capital (%)
Total 1,48,52,400 94.28
Note: Based on the beneficiary position statement dated September 29, 2023
9. Shareholding of our Directors, Key Managerial Personnel and Senior Managerial Personnel in our
Company
Except as disclosed below, none of our Directors and Key Managerial Personnel hold any Equity Shares of our
Company:
Name of the
Director / Key Percentage of Percentage of
Number of Equity Number of Equity
Sr. Managerial Pre – Issue Post- Issue
Shares of face value Shares of face value
No. Personnel / Senior Equity Share Equity Share
₹10 each ₹10 each
Managerial capital (%) capital (%) *
Personnel
1. Upendra Trikamlal 30,00,000 19.04 [●] [●]
Shah
2. Purnima Upendra 34,50,000 21.90 [●] [●]
Shah
3. Tanmay Upendra 25,05,000 15.90 [●] [●]
Shah
4. Trupti Utpal Shah 6,50,000 4.13 [●] [●]
5. Rajesh Ramchandra 6,50,000 4.13 [●] [●]
Punjabi
6. Shalvi Kharidia 400 0.00 [●] [●]
Total 1,02,55,400 65.10 [●] [●]
*To be updated at Prospectus stage
Further, our Senior Managerial Personnel do not hold any Equity Shares of our Company. For further details,
please see “Our Management - Shareholding of our Directors in our Company” and “Our Management-
Shareholding of the Key Managerial Personnel and Senior Management Personnel” on pages 481 and 494.
10. Details of shareholding of our Promoters, members of the Promoter Group, Directors, Key
Managerial Personnel and Senior Managerial Personnel in our Company
As on the date of this Draft Red Herring Prospectus, our Promoters, Upendra Trikamlal Shah, Purnima Upendra
Shah, Tanmay Upendra Shah and Trupti Utpal Shah collectively hold 96,05,000 Equity Shares in aggregate,
equivalent to 60.97% of the issued, subscribed and paid-up Equity Share capital of our Company.
Shareholding of our Promoters and member of our Promoter Group
Sr. Name Pre- Issue Equity Share capital Post- Issue Equity Share capital
No. Number of Equity Percentage of Number of Equity Percentage of Equity
Shares of face Equity Share Shares of face value Share capital (%)
value of ₹ 10 each capital (%) of ₹ 10 each
Promoters
1. Upendra Trikamlal 30,00,000 19.04 [●] [●]
Shah*
2. Purnima Upendra 34,50,000 21.90 [●] [●]
Shah*
3. Tanmay Upendra 25,05,000 15.90 [●] [●]
Shah*
4. Trupti Utpal Shah 6,50,000 4.13 [●] [●]
Promoter Group
5. Upendra Trikamlal 3,32,500 2.11 [●] [●]
Shah HUF
6. Tanmay Upendra Shah 1,00,600 0.64 [●] [●]
HUF*
7. Utpal Praful Shah 5,30,000 3.36 [●] [●]
8. Utpal Praful Shah 36,400 0.23 [●] [●]
HUF
285Sr. Name Pre- Issue Equity Share capital Post- Issue Equity Share capital
No. Number of Equity Percentage of Number of Equity Percentage of Equity
Shares of face Equity Share Shares of face value Share capital (%)
value of ₹ 10 each capital (%) of ₹ 10 each
9. Rehan Utpal Shah 2,20,000 1.40 [●] [●]
10. Aashna Utpal Shah 2,20,000 1.40 [●] [●]
11. Pritish Praful Shah 1,650 0.01 [●] [●]
12. Nivedita Vijay Vyas 1,650 0.01 [●] [●]
13. Preeti Upendra Shah 14,15,000 8.98 [●] [●]
14. Ruchira Tanmay Shah 5,80,000 3.68 [●] [●]
15. Kenisha Tanmay Shah 2,41,200 1.53 [●] [●]
16. Praful Kacharabhai 2400 0.02 [●] [●]
Shah
*The shares our held jointly by the shareholders
Build-up of our Promoters’ equity shareholding in our Company
Set forth below is the build-up of the equity shareholding of our Promoters, since incorporation of our Company:
Face Post-
value Pre-Issue Issue
Issue/transfe
Date of Number Nature of per equity equity
Nature of r price per
allotment/transfe of equity consideratio equit share share
transaction equity share
r shares n y capital capita
(in ₹)
share (in %) l (in
(in ₹) %)
Upendra Trikamlal Shah
October 12, 1994 Subscription to the 100 Cash 10 10 Negligibl [●]
memorandum of e
Association
December 30, 1994 Further 4,12,500 Cash 10 10 2.62 [●]
Allotment
June 17, 1996 Transfer of shares 69,000 Cash 10 10 0.44 [●]
from Trikamlal F
Shah & Vimlaben
T Shah*
June 17, 1996 Transfer of shares 79,000 Cash 10 10 0.50 [●]
from Vimlaben T
Shah & Trikamlal
F Shah*
October 31, 1996# Transfer of shares 1,000 N.A. 10 Nil 0.01 [●]
from Jayantibhai K
Patel & Kokila J
Patel*
November 1, 1996 Further 2,60,800 Cash 10 10 1.66 [●]
Allotment
September 17, Transfer of shares (700) N.A. 10 Nil Negligibl [●]
1998# to Trupti Utpal e
Shah
September 17, Transfer of shares (4,000) N.A. 10 Nil (0.03) [●]
1998# to Trikamlal F
Shah & Upendra T
Shah*
May15, 1999# Transfer of shares 20,000 N.A. 10 Nil 0.13 [●]
from Chimanbhai
N Patel &
Shantaben C
Patel*
May 15, 1999 Transfer of shares 5,000 Cash 10 10 0.03 [●]
from Ajitbhai M
Sheth & Bhavna A
Sheth*
October 31, 1999 Further 1,31,000 Cash 10 10 0.83 [●]
Allotment
286Face Post-
value Pre-Issue Issue
Issue/transfe
Date of Number Nature of per equity equity
Nature of r price per
allotment/transfe of equity consideratio equit share share
transaction equity share
r shares n y capital capita
(in ₹)
share (in %) l (in
(in ₹) %)
May 12, 2000 Transfer of shares 2,500 Cash 10 5 0.02 [●]
from Chhayaben
Jawahar Jethawa
& Jawahar
Tulsidas Jethawa*
May 12, 2000 Transfer of shares 2,500 Cash 10 5 0.02 [●]
from Chhayaben
Mahendrabhai
Shah &
Mahendrabhai
Chinubhai Shah*
August 01, 2000 Further 3,10,000 Cash 10 10 1.97 [●]
Allotment
May 21, 2001 Transfer of shares 1,000 Cash 10 10 0.01 [●]
from Padmaben B
Shah
September 15, Further 5,00,000 Cash 10 10 3.17 [●]
2005 Allotment
November 01, Bonus issue in the 5,01,700 N.A. 10 N.A. 3.18 [●]
2007 ratio of 1:1 (one for
every one equity
share held)
November 01, Bonus issue in the 12,88,000 N.A. 10 N.A. 8.18 [●]
2007 ratio of 1:1 (one for
every one equity
share held)
August 20, 2008 Transfer of shares (1,00,000) Cash 10 10 (0.63) [●]
to Pearl Tej Shah
August 20, 2008 Transfer of shares (1,00,000) Cash 10 10 (0.63) [●]
to Aashana Utpal
Shah
August 20, 2008 Transfer of shares (1,00,000) Cash 10 10 (0.63) [●]
to Rehaan Utpal
Shah
February 28, 2009 Transfer of shares 300 Cash 10 80 Negligibl [●]
from Nikunj e
Mahendrabhai
Shah
February 28, 2009 Transfer of shares 600 Cash 10 80 Negligibl [●]
from Dushyant e
Sureshbhai Shah
February 28, 2009 Transfer of shares 600 Cash 10 80 Negligibl [●]
from Alpesh e
Jayantilal Shah
February 28, 2009 Transfer of shares 400 Cash 10 80 Negligibl [●]
from Milanben e
Pareshbhai Mehta
February 28, 2009 Transfer of shares 400 Cash 10 80 Negligibl [●]
from Paresh e
Champaklal
Mehta
February 28, 2009 Transfer of shares 1,000 Cash 10 150 0.01 [●]
from Rajesh
Kapoor
February 28, 2009 Transfer of shares 300 Cash 10 80 Negligibl [●]
from e
Harshadkumar
Ravalji
287Face Post-
value Pre-Issue Issue
Issue/transfe
Date of Number Nature of per equity equity
Nature of r price per
allotment/transfe of equity consideratio equit share share
transaction equity share
r shares n y capital capita
(in ₹)
share (in %) l (in
(in ₹) %)
February 28, 2009 Transfer of shares 300 Cash 10 80 Negligibl [●]
from Indumati e
Vora
February 28, 2009 Transfer of shares 300 Cash 10 150 Negligibl [●]
from Priyata e
Haresh Jethva
February 28, 2009 Transfer of shares 300 Cash 10 150 Negligibl [●]
from Ramilaben e
Shamjibhai Jethva
February 28, 2009 Transfer of shares 1,000 Cash 10 150 0.01 [●]
from Sonia Rajesh
Kapoor
February 28, 2009 Transfer of shares 1,000 Cash 10 80 0.01 [●]
from Aanal M
Shah
February 28, 2009 Transfer of shares 300 Cash 10 80 Negligibl [●]
from Smitaben e
Maheshkumar
Patel
February 28, 2009 Transfer of shares 300 Cash 10 80 Negligibl [●]
from e
Maheshkumar
Somabhai Patel
February 28, 2009 Transfer of shares 300 Cash 10 80 Negligibl [●]
from Neha Parful e
Shah
February 28, 2009 Transfer of shares 400 Cash 10 150 Negligibl [●]
from Viral D Shah e
February 28, 2009 Transfer of shares 1,500 Cash 10 150 0.01 [●]
from Hasmukhray
Shah
February 28, 2009 Transfer of shares 300 Cash 10 80 Negligibl [●]
from Anita e
Alpeshkumar
Shah
February 28, 2009 Transfer of shares 300 Cash 10 150 Negligibl [●]
from Satish Ratilal e
Budhbhatti
February 28, 2009 Transfer of shares 300 Cash 10 150 Negligibl [●]
from Premila e
Jagdish Bhimani
February 28, 2009 Transfer of shares 300 Cash 10 150 Negligibl [●]
from Prashant J e
Bhimani
February 28, 2009 Transfer of shares 300 Cash 10 150 Negligibl [●]
from Dipikaben e
Upendrabhai
Prajapati
February 28, 2009 Transfer of shares 300 Cash 10 150 Negligibl [●]
from Divyaben Y e
Prajapati
February 28, 2009 Transfer of shares 1,000 Cash 10 150 0.01 [●]
from Shachi
Devang Patel
February 28, 2009 Transfer of shares 300 Cash 10 150 Negligibl [●]
from Hardik J e
Bhimani
288Face Post-
value Pre-Issue Issue
Issue/transfe
Date of Number Nature of per equity equity
Nature of r price per
allotment/transfe of equity consideratio equit share share
transaction equity share
r shares n y capital capita
(in ₹)
share (in %) l (in
(in ₹) %)
February 28, 2009 Transfer of shares 400 Cash 10 150 Negligibl [●]
from Rajnikant e
Harilal Patel
February 28, 2009 Transfer of shares 600 Cash 10 150 Negligibl [●]
from Amitbhai e
Bhagvandas
Chokshi
February 28, 2009 Transfer of shares 300 Cash 10 150 Negligibl [●]
from Sangita Patel e
February 28, 2009 Transfer of shares 300 Cash 10 150 Negligibl [●]
from Rameshbhai e
N. Sojitra
February 28, 2009 Transfer of shares 300 Cash 10 150 Negligibl [●]
from Upendra T e
Prajapati
February 28, 2009 Transfer of shares 300 Cash 10 80 Negligibl [●]
from Devang C e
Mehta
February 28, 2009 Transfer of shares 1,000 Cash 10 80 0.01 [●]
from Induben R
Patel
February 28, 2009 Transfer of shares 600 Cash 10 80 Negligibl [●]
from Mina N Patel e
February 28, 2009 Transfer of shares 6,000 Cash 10 150 0.04 [●]
from Mukundbhai
Shambhubhai
Patel
February 28, 2009 Transfer of shares 500 Cash 10 150 Negligibl [●]
from Babiben N e
Solanki
February 28, 2009 Transfer of shares 300 Cash 10 150 Negligibl [●]
from Bhavana e
Dasharath Shah
February 28, 2009 Transfer of shares 300 Cash 10 80 Negligibl [●]
from Ragini Modi e
February 28, 2009 Transfer of shares 300 Cash 10 150 Negligibl [●]
from Narendra e
Chimanlal Shah
February 28, 2009 Transfer of shares 300 Cash 10 80 Negligibl [●]
from Manisha B e
Patel
February 28, 2009 Transfer of shares 300 Cash 10 80 Negligibl [●]
from Bharvi Patel e
February 28, 2009 Transfer of shares 300 Cash 10 80 Negligibl [●]
from Manubhai e
Ambalal Patel
February 28, 2009 Transfer of shares 800 Cash 10 80 0.01 [●]
from Govindbhai
S. Patel
February 28, 2009 Transfer of shares 1,000 Cash 10 80 0.01 [●]
from Sunitaben G
Patel
February 28, 2009 Transfer of shares 300 Cash 10 80 Negligibl [●]
from Alaknanda N e
Patel
February 28, 2009 Transfer of shares 300 Cash 10 150 Negligibl [●]
from Naynaben e
Shah
289Face Post-
value Pre-Issue Issue
Issue/transfe
Date of Number Nature of per equity equity
Nature of r price per
allotment/transfe of equity consideratio equit share share
transaction equity share
r shares n y capital capita
(in ₹)
share (in %) l (in
(in ₹) %)
February 28, 2009 Transfer of shares 300 Cash 10 80 Negligibl [●]
from Mukund e
Modi
February 28, 2009 Transfer of shares 300 Cash 10 80 Negligibl [●]
from Saurabh e
Modi
February 28, 2009 Transfer of shares 500 Cash 10 80 Negligibl [●]
from Tilottama e
Yewley
February 28, 2009 Transfer of shares 300 Cash 10 80 Negligibl [●]
from Hansaben e
Girjashankar
Raval
February 28, 2009 Transfer of shares 300 Cash 10 80 Negligibl [●]
from Anilkumar e
Popatlal Raval
February 28, 2009 Transfer of shares 300 Cash 10 80 Negligibl [●]
from Avinash e
Gupte
February 28, 2009 Transfer of shares 4,100 Cash 10 150 0.03 [●]
from Atash Shah
February 28, 2009 Transfer of shares 1,000 Cash 10 80 0.01 [●]
from Minal
Kiritbhai Parikh
February 28, 2009 Transfer of shares 1,000 Cash 10 80 0.01 [●]
from Pranavbhai
Khambhati
February 28, 2009 Transfer of shares 3,100 Cash 10 150 0.02 [●]
from Sanjay
Bhimani
February 28, 2009 Transfer of shares 500 Cash 10 80 Negligibl [●]
from Narendra D. e
Patel
March 7, 2009 Transfer of shares 300 Cash 10 80 Negligibl [●]
from Sushila e
Babubhai Patel *
Babubhai Ambalal
Patel & Ambalal
Maganlal Patel
March 7, 2009 Transfer of shares 1,000 Cash 10 150 0.01 [●]
from Manjulaben
Patel
March 7, 2009 Transfer of shares 1,200 Cash 10 150 0.01 [●]
from Kruti Jatin
Patel
March 7, 2009 Transfer of shares 300 Cash 10 80 Negligibl [●]
from Babubhai e
Ambalal Patel &
Sushila Babubhai*
Patel
March 7, 2009 Transfer of shares 300 Cash 10 80 Negligibl [●]
from Jyotsna e
Laxesh Chudgar
& Laxesh
Harshadrai
Chudgar*
March 7, 2009 Transfer of shares 300 Cash 10 80 Negligibl [●]
from e
Ambalalmaganlal
290Face Post-
value Pre-Issue Issue
Issue/transfe
Date of Number Nature of per equity equity
Nature of r price per
allotment/transfe of equity consideratio equit share share
transaction equity share
r shares n y capital capita
(in ₹)
share (in %) l (in
(in ₹) %)
Patel & Babubhai
Ambalal Patel &
Sushila Babubhai
Patel*
March 7, 2009 Transfer of shares 500 Cash 10 80 Negligibl [●]
from Chaturbhai H e
Patel
March 7, 2009 Transfer of shares 600 Cash 10 80 Negligibl [●]
from Ramilaben D e
Patel & Divyakant
C Patel*
March 7, 2009 Transfer of shares 500 Cash 10 80 Negligibl [●]
from Divyakant C e
Patel
March 7, 2009 Transfer of shares 600 Cash 10 80 Negligibl [●]
from Bharatkumar e
C Patel &
Shilpaben B
Patel*
March 7, 2009 Transfer of shares 400 Cash 10 80 Negligibl [●]
from Sitaben C e
Patel& Chaturbhai
H Patel*
March 7, 2009 Transfer of shares 900 Cash 10 80 0.01 [●]
from Chaturbhai
Harjivandas Patel
& Sitaben C
Patel*
March 7, 2009 Transfer of shares 500 Cash 10 80 Negligibl [●]
from Shilpaben B e
Patel &
Bharatkumar C
Patel*
March 7, 2009 Transfer of shares 1,200 Cash 10 150 0.01 [●]
from Jatin
Vinodchandra
Patel
March 7, 2009 Transfer of shares 1,200 Cash 10 150 0.01 [●]
from Neeta Jatin
Patel & Jatin
Vindochandra
Patel*
March 7, 2009 Transfer of shares 1,400 Cash 10 150 0.01 [●]
from Jatin
Vinodchandra
Patel &. Neeta
Jatin Patel*
March 7, 2009 Transfer of shares 300 Cash 10 80 Negligibl [●]
from Lilaben e
Satishbhai Patel
March 7, 2009 Transfer of shares 300 Cash 10 80 Negligibl [●]
from Babubhai e
Dolatsinh Darbar
March 7, 2009 Transfer of shares 300 Cash 10 80 Negligibl [●]
from Bahnumati e
Indravadan Bhatt
March 7, 2009 Transfer of shares 300 Cash 10 80 Negligibl [●]
from Kinjal e
Harshad Patel &
291Face Post-
value Pre-Issue Issue
Issue/transfe
Date of Number Nature of per equity equity
Nature of r price per
allotment/transfe of equity consideratio equit share share
transaction equity share
r shares n y capital capita
(in ₹)
share (in %) l (in
(in ₹) %)
Harshad
Harikrishna Patel*
March 7, 2009 Transfer of shares 300 Cash 10 80 Negligibl [●]
from Janardan e
Induprasad Patel
March 7, 2009 Transfer of shares 1,000 Cash 10 150 0.01 [●]
from Mahendra
Hargovandas Patel
& Taraben
Mahendrabhai
Patel*
March 7, 2009 Transfer of shares 300 Cash 10 150 Negligibl [●]
from Taraben e
Mahendrabhai
Patel & Mahendra
Hargovandas
Patel*
March 7, 2009 Transfer of shares 500 Cash 10 80 Negligibl [●]
from Manokkumar e
Lalbhai Shah
March 7, 2009 Transfer of shares 500 Cash 10 80 Negligibl [●]
from Harshadbhai e
Keshavlal Patel
March 7, 2009 Transfer of shares 500 Cash 10 80 Negligibl [●]
from Premilaben e
Harshadbhai Patel
March 7, 2009 Transfer of shares 300 Cash 10 80 Negligibl [●]
from Bhumika e
Bharatkuamar
Patel
March 7, 2009 Transfer of shares 300 Cash 10 80 Negligibl [●]
from Smitaben e
Keshavlal Patel
March 7, 2009 Transfer of shares 400 Cash 10 80 Negligibl [●]
from Hiren e
Harshadbhai Patel
& Premilaben
Harshadbahi Patel
& Harshadbhai
Keshavlal Patel*
March 7, 2009 Transfer of shares 1,000 Cash 10 80 0.01 [●]
from Rajendra
Kantilal Patel &
Kantilal Ambalal
Patel*
March 7, 2009 Transfer of shares 1,000 Cash 10 80 0.01 [●]
from Kantilal
Ambalal Patel &
Rajendra Kantilal
Patel*
March 7, 2009 Transfer of shares 1,000 Cash 10 80 0.01 [●]
from Vidya
Kantilal Patel &
Kantilal Ambalal
Patel*
March 7, 2009 Transfer of shares 300 Cash 10 80 Negligibl [●]
from Bipin e
Shankerlal Vyas
292Face Post-
value Pre-Issue Issue
Issue/transfe
Date of Number Nature of per equity equity
Nature of r price per
allotment/transfe of equity consideratio equit share share
transaction equity share
r shares n y capital capita
(in ₹)
share (in %) l (in
(in ₹) %)
March 7, 2009 Transfer of shares 300 Cash 10 80 Negligibl [●]
from Mandakini e
Nimesh Desai &
Nimesh
Jagdishbhai
Desai*
March 7, 2009 Transfer of shares 300 Cash 10 80 Negligibl [●]
from Harshadbhai e
Keshavlal Patel
March 7, 2009 Transfer of shares 300 Cash 10 80 Negligibl [●]
from Sangita S e
Desai &
Suryakant R
Desai*
March 7, 2009 Transfer of shares 300 Cash 10 80 Negligibl [●]
from Jaimini Jatin e
Patel & Jatin
Bhanuprasad
Patel*
March 7, 2009 Transfer of shares 300 Cash 10 80 Negligibl [●]
from Vishnubhai e
Chhaganlal Patel
& Kokila
Vishnubhai Patel*
March 7, 2009 Transfer of shares 300 Cash 10 80 Negligibl [●]
from Jaydeep e
Dhananjay Patel
& Dhananjay H
Patel*
March 7, 2009 Transfer of shares 300 Cash 10 80 Negligibl [●]
from Darshan A e
Desai &
Arvindkumar P
Desai*
March 7, 2009 Transfer of shares 300 Cash 10 80 Negligibl [●]
from Varsha e
Jagdishchandra
Purani
March 7, 2009 Transfer of shares 300 Cash 10 80 Negligibl [●]
from Kaushilk e
Purani
March 7, 2009 Transfer of shares 300 Cash 10 80 Negligibl [●]
from Dinesh e
Ambalal Modi &
Rashmika
Dineshkumar
Modi*
March 7, 2009 Transfer of shares 300 Cash 10 80 Negligibl [●]
from Dwipal D e
Patel & Devang G
Patel*
March 7, 2009 Transfer of shares 300 Cash 10 80 Negligibl [●]
from Janak e
Natverlal Patel &
Natverlal
Keshavlal Patel*
March 7, 2009 Transfer of shares 300 Cash 10 80 Negligibl [●]
from e
Rashmikaben
293Face Post-
value Pre-Issue Issue
Issue/transfe
Date of Number Nature of per equity equity
Nature of r price per
allotment/transfe of equity consideratio equit share share
transaction equity share
r shares n y capital capita
(in ₹)
share (in %) l (in
(in ₹) %)
Dineshkumar
Modi
March 7, 2009 Rashmika Janak 300 Cash 10 80 Negligibl [●]
kumar Patel & e
Janak Natverlal
Patel*
March 7, 2009 Transfer of shares 2,000 Cash 10 150 0.01 [●]
from Renuka
Arvind Patel &
Arvind M Patel &
Krunal A Patel*
March 7, 2009 Transfer of shares 300 Cash 10 80 Negligibl [●]
from Ashish e
Dhanjibhai Davda
March 7, 2009 Transfer of shares 300 Cash 10 80 Negligibl [●]
from Mehal e
Ashish Davda
March 7, 2009 Transfer of shares 400 Cash 10 80 Negligibl [●]
from Ankur e
Harshadray
Pandya
March 7, 2009 Transfer of shares 500 Cash 10 80 Negligibl [●]
from Krunal D e
Shah & Rakhi
Krunal Shah*
March 7, 2009 Transfer of shares 300 Cash 10 80 Negligibl [●]
from Indira Piyush e
Dalal & Piyush
Dalal*
March 7, 2009 Transfer of shares 300 Cash 10 80 Negligibl [●]
from Sandip e
Bharatkumar Patel
& Bhartiben
Bharatkumar
Patel*
March 7, 2009 Transfer of shares 300 Cash 10 80 Negligibl [●]
from Vimlagauri e
Naranlal Patel &
Naranlal Maneklal
Patel & Hiren
Naranlal Patel*
March 7, 2009 Transfer of shares 400 Cash 10 150 Negligibl [●]
from Vishvajit M e
Patel & Mahendra
H Patel*
March 7, 2009 Transfer of shares 300 Cash 10 80 Negligibl [●]
from Naranlal e
Maneklal Patel &
Vimlagauri
Naranlal Patel &
Hiren Naranlal
Patel*
October 01, 2009 Transfer of shares 300 Cash 10 80 Negligibl [●]
from e
Rupeshkumar
Rameshchandra
Patel & Nitu
Rupeshkumar
Patel*
294Face Post-
value Pre-Issue Issue
Issue/transfe
Date of Number Nature of per equity equity
Nature of r price per
allotment/transfe of equity consideratio equit share share
transaction equity share
r shares n y capital capita
(in ₹)
share (in %) l (in
(in ₹) %)
October 01, 2009 Transfer of shares 300 Cash 10 80 Negligibl [●]
from Sharad e
Kanaiyalal
Acharya
October 01, 2009 Transfer of shares 300 Cash 10 80 Negligibl [●]
from Bhagwandas e
Bababahi Desai
November 02, Transfer of shares 300 Cash 10 80 Negligibl [●]
2009 from Babubhai e
Shah
November 02, Transfer of shares 500 Cash 10 80 Negligibl [●]
2009 from Tarun V e
Sharma
November 02, Transfer of shares 300 Cash 10 80 Negligibl [●]
2009 from Atulbhai e
Patel
December 01, 2009 Transfer of shares 2,000 Cash 10 80 0.01 [●]
from Gauri P
Rohra
February 01, 2010 Transfer of shares 300 Cash 10 80 Negligibl [●]
from e
Sureshchandra
Chandulal Shah &
Krunal
Sureshkumar Shah
March 02, 2010 Transfer of shares 300 Cash 10 80 Negligibl [●]
from Raju Shah e
March 02, 2010 Transfer of shares 300 Cash 10 80 Negligibl [●]
from lalit Shah e
September 01, Transfer of shares 600 Cash 10 80 Negligibl [●]
2010 from Hemal e
Vipinchandra
Karbhari
September 01, Transfer of shares 300 Cash 10 80 Negligibl [●]
2010 from Avanti e
Vinodchandra
Karbhari
September 01, Transfer of shares 300 Cash 10 80 Negligibl [●]
2010 from Kunj Sanjay e
Shah & Sanjay
Shantilal Shah*
September 01, Transfer of shares 300 Cash 10 80 Negligibl [●]
2010 from Ashok e
Nanakram Ramtri
September 01, Transfer of shares 300 Cash 10 80 Negligibl [●]
2010 from Jitendra e
Shantilal Shah
September 01, Transfer of shares 500 Cash 10 80 Negligibl [●]
2010 from Upendra e
Vithalani & Hina
Vithalani*
September 01, Transfer of shares 800 Cash 10 80 0.01 [●]
2010 from Hina
Vithalani &
Upendra
Vithalani*
September 01, Transfer of shares 300 Cash 10 80 Negligibl [●]
2010 from Chirag Shah e
295Face Post-
value Pre-Issue Issue
Issue/transfe
Date of Number Nature of per equity equity
Nature of r price per
allotment/transfe of equity consideratio equit share share
transaction equity share
r shares n y capital capita
(in ₹)
share (in %) l (in
(in ₹) %)
& Nareshchandra
Shah*
September 01, Transfer of shares 300 Cash 10 80 Negligibl [●]
2010 from Mauli Anal e
Dave
October 01, 2010 Transfer of shares 500 Cash 10 80 Negligibl [●]
from Manish e
Gopalkrishna
Patwari &
Gopalkrishna
Ranchhodlal
Patwari*
Transfer of shares 300 Cash 10 80 Negligibl [●]
November 01, from Aatishkumar e
2010 Dhirajlal Chokshi
& Meetaben A.
Chokshi*
December 01, Transfer of shares (1,00,000 Cash 10 10 (0.63) [●]
2010 to Kenisha )
Tanmay Shah
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Srujal Shah
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Chintan S Parikh
December 01, Transfer of share (400) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Jwellin Shah
December 01, Transfer of share (700) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Dinesh Shah
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Leena Shah
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Kundan Vallabhai
Patel
December 01, Transfer of share (600) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Dipakbhai
Navinchandra
Shah
December 01, Transfer of share (500) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Akash
Nalinkumar Shah
December 01, Transfer of share (500) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Hetal
Kamleshbhai Shah
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Kamlesh
Jayantibhai Shah
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Bharatbhai
296Face Post-
value Pre-Issue Issue
Issue/transfe
Date of Number Nature of per equity equity
Nature of r price per
allotment/transfe of equity consideratio equit share share
transaction equity share
r shares n y capital capita
(in ₹)
share (in %) l (in
(in ₹) %)
Umedchand
Gopani
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Kalpeshbhai
Rasiklal Shah
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Mukeshbhai
Govindbhai Patel
December 01, Transfer of share (700) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Malti Ashokbhai
Parikh
December 01, Transfer of share (700) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Krina Amit Parikh
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Chander
Choithram
Vanvari
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Indumati Chander
Vanvari
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Nilay
Bharatkumar
Contractor
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Bina
Kalpeshkumar
Shah
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Surya Bhupendra
Mehta
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Inaxi Nareshbhai
Shah
December 01, Transfer of share (400) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Ketan Tejpal
Parikh
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Rajiv Tejpal
Parikh
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Sonal Rajiv Parikh
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Atul Chandrakant
Shah
297Face Post-
value Pre-Issue Issue
Issue/transfe
Date of Number Nature of per equity equity
Nature of r price per
allotment/transfe of equity consideratio equit share share
transaction equity share
r shares n y capital capita
(in ₹)
share (in %) l (in
(in ₹) %)
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Pathik Atulbhai
Shah
December 01, Transfer of share (600) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Jigna Tejas Dave
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Shachish Piyush
Doctor
December 01, Transfer of share (400) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Devang
Navinchandra
Gandhi
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Bhanuben
Natverlal Shah
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Natverlal
Shankerlal Shah
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Dinesh H Pande
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Dipesh Sunilbhai
Mehta
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Tapan Dinesh
Shah
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Bharat Natverlal
Shah
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Hinaben Dinesh
Shah
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Hansaben
Ghanshyam
Khatri
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Gopal Natverlal
Shah
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Premilaben
Anilkumar
Chauhan
December 01, Transfer of share (500) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
298Face Post-
value Pre-Issue Issue
Issue/transfe
Date of Number Nature of per equity equity
Nature of r price per
allotment/transfe of equity consideratio equit share share
transaction equity share
r shares n y capital capita
(in ₹)
share (in %) l (in
(in ₹) %)
Roopa
Manojkumar Shah
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Avanish Niranjan
Patel
December 01, Transfer of share (500) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Bindu Rajiv Patel
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Yogesh Dilipbhai
Patel
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Paresh
Mahendrakumar
Patel
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Mayur Manubhai
Parikh
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Sushma Mayoor
Parikh
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Nisith Shah
December 01, Transfer of share (500) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Kundan
Rameshbhai
Gandhi
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Hardik
Dharmendrabhai
Patel
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Kirtikumar Modi
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Amitbhai Popatlal
Shah
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Janak kumar
Bhanubhai
Babaria
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Anuradha Bhavsar
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Rajiv Bhavsar
299Face Post-
value Pre-Issue Issue
Issue/transfe
Date of Number Nature of per equity equity
Nature of r price per
allotment/transfe of equity consideratio equit share share
transaction equity share
r shares n y capital capita
(in ₹)
share (in %) l (in
(in ₹) %)
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Ranjan Patwa
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Naziralam
Dinmohmmed
Sheikh
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Suresh Maneklal
Shah
December 01, Transfer of share (400) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Jitendra
Amarchand Desai
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Pratimaben
Shanabhai Patel
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Neha Jhaveri
December 01, Transfer of share (500) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Rashmika Shah
December 01, Transfer of share (400) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Monali
Birenkumar Shah
December 01, Transfer of share (400) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Kiritkumar
Govindlal Shah
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Shardaben A.
Shah
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Anjali Hiteshbhai
Shah
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Vinodchandra
Keshavlal Shah
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Bharatkumar
Amaratlal Shah
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Induben
Dineshbhai
Bhavsar
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Dipika Jayesh
Shah
300Face Post-
value Pre-Issue Issue
Issue/transfe
Date of Number Nature of per equity equity
Nature of r price per
allotment/transfe of equity consideratio equit share share
transaction equity share
r shares n y capital capita
(in ₹)
share (in %) l (in
(in ₹) %)
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Jayesh Indravadan
Shah
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Indravadan Shah
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Chintan
Pankajkumar Shah
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Surendra Popatlal
Shah
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Jignesh Maniar
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Shivani Maniar
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Piyusha J Vakil
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Deviben M Pujara
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Yogeshchandra
Manohar Neve
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Nilima
Yogeshchandra
Neve
December 01, Transfer of share (600) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Piyushkumar
Krishnachandra
Dani
December 01, Transfer of share (400) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Bhavana
Piyushkumar Dani
December 01, Transfer of share (500) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Anand Ashvin
Dalal
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Ashvin Chinubhai
Dalal
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Asit Jitendrabhai
Zaveri
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
301Face Post-
value Pre-Issue Issue
Issue/transfe
Date of Number Nature of per equity equity
Nature of r price per
allotment/transfe of equity consideratio equit share share
transaction equity share
r shares n y capital capita
(in ₹)
share (in %) l (in
(in ₹) %)
Hitesh Vithalbhai
Patel
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Harish Patel
December 01, Transfer of share (500) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Varshaben G
Gadani
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Rashmiben Gajjar
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Harivadan Shivlal
Bhavsar
December 01, Transfer of share (400) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Dhirajlal
Prabhudas
Kansara
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Dilip R Soni
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Rajendrakumar S
Shah
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Chandresh R Soni
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Gitaben
Girishkumar
Kotak
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Rajesh Maneklal
Kotak
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Prakash
Hasmukhlal Kotak
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Govind
Rukmanbhai
Nama
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Girish
Hasmukhlal Kotak
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Arvindbhai
Prabhudas Patel
302Face Post-
value Pre-Issue Issue
Issue/transfe
Date of Number Nature of per equity equity
Nature of r price per
allotment/transfe of equity consideratio equit share share
transaction equity share
r shares n y capital capita
(in ₹)
share (in %) l (in
(in ₹) %)
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Neha Patel
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Jayshree Patel
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Suleman Khoja
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Ramesh Sorathia
December 01, Transfer of share (600) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Bharati Dinesh
Desai
December 01, Transfer of share (600) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Shachi Dinesh
Desai
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Dakshaben Shah
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Neeta Dipak Patel
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Bhavini
Rupeshbhai Shah
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Mrunalini Patel
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Sudha Kamlesh
Modi
December 01, Transfer of share (600) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Rekhaben
Rajeshkumar
Kotak
December 01, Transfer of share (500) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Bharat J Patel
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Poornima Shah
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Ashokkumar Shah
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Rajesh Patel
December 01, Transfer of share (500) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Navinchandra V
Shah
303Face Post-
value Pre-Issue Issue
Issue/transfe
Date of Number Nature of per equity equity
Nature of r price per
allotment/transfe of equity consideratio equit share share
transaction equity share
r shares n y capital capita
(in ₹)
share (in %) l (in
(in ₹) %)
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Nareshchandra
Shah
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Rajendra Kantilal
Shah
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Jyotsana Rajendra
Shah
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Jankiben
Dharmendrakuma
r Patel
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Anil Baldevbhai
Patel
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Shital Bihagbhai
Angreji
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Kaushik kumar
Ramanlal Patel
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Amita Kaushik
Patel
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Shobhan S Parikh
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Khodidas
Prabhudas Barot
December 01, Transfer of share (400) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Praful K. Shah &
Gauri P. Shah &
Pritish P. Shah*
December 01, Transfer of share (600) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Ghanshyambhai
Patel
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Mahesh Ramanlal
Gandhi
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Jagruti Pravin
Master
304Face Post-
value Pre-Issue Issue
Issue/transfe
Date of Number Nature of per equity equity
Nature of r price per
allotment/transfe of equity consideratio equit share share
transaction equity share
r shares n y capital capita
(in ₹)
share (in %) l (in
(in ₹) %)
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Vipul C Desai
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Chetna Vipul
Desai
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Sarojben C Desai
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Chandrakant A
Desai
December 01, Transfer of share (600) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Dipal Rameshbhai
Shah
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Surekha Suketu
Javeri
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Shaileshbhai Shah
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Bharatkumar
Daftary
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Dharmesh
Rasiklal Shah
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Dilipbhai R Patel
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Sheelaben D Patel
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Ila Thaker
December 01, Transfer of share (600) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Niraj Dilipkumar
Shah
December 01, Transfer of share (600) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Dilipkumar
Rasiklal Shah
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Sushma Mahesh
Gandhi
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Pushpaben P Shah
305Face Post-
value Pre-Issue Issue
Issue/transfe
Date of Number Nature of per equity equity
Nature of r price per
allotment/transfe of equity consideratio equit share share
transaction equity share
r shares n y capital capita
(in ₹)
share (in %) l (in
(in ₹) %)
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Nishant M Shah
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Vaishali Shah
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Bhavana Patel
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Mohamed Yusuf
Memon
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Usmangani A.
Memon
December 01, Transfer of share (400) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Abdurrehman A
Memon
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Gulammohamed
A. Memon
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Sarabai
Usmangani
Memon
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Kanubhai M Patel
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Pushpa Shah
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Bhupendra Shah
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Arvind C Chokshi
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Bhavesh Bhogilal
Patel
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Nilam Mahesh
Patel
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Prashant
Shankerprasad
Vyas
December 01, Transfer of share (500) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Chirag Amrutlal
Patel
306Face Post-
value Pre-Issue Issue
Issue/transfe
Date of Number Nature of per equity equity
Nature of r price per
allotment/transfe of equity consideratio equit share share
transaction equity share
r shares n y capital capita
(in ₹)
share (in %) l (in
(in ₹) %)
December 01, Transfer of share (500) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Hemang Amrutlal
Patel
December 01, Transfer of share (500) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Amratbhai
Harjivandas Patel
December 01, Transfer of share (500) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Hasumatiben
Amratlal Patel
December 01, Transfer of share (500) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Amratbhai
Harjivandas Patel
December 01, Transfer of share (600) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Archana Parikh
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Hitendra Patel
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Rakesh Thaker
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Renukaben
Arvindkumar
Patel
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Kamlesh Kothari
December 01, Transfer of share (700) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Dipan Kothari
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Nikunj Desai
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Nilesh Kothari
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Kalpesh Thaker
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Bhikhalal H Soni
December 01, Transfer of share (500) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Rajesh Rohra
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Sushilaben
Narendrabhai
Dani
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
307Face Post-
value Pre-Issue Issue
Issue/transfe
Date of Number Nature of per equity equity
Nature of r price per
allotment/transfe of equity consideratio equit share share
transaction equity share
r shares n y capital capita
(in ₹)
share (in %) l (in
(in ₹) %)
Prashant Ukabhai
Patel
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Bipin Vallabhbhai
Patel
December 01, Transfer of share (600) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Nirav
Dhansukhlal Shah
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Nachiket Avinash
Bhatt
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Samir
Dashrathbhai
Patel
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Daxa Vallabhbhai
Patel
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Bipinchandra
Popatlal Patel
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Bharti Dinesh
Patel
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Pravin Maneklal
Patel
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Sharadkumar
Khodidas Antala
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Bhadreshkumar
Purshottambhai
Patel
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Nanubhai
Popatbhai Patel
December 01, Transfer of share (500) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Shamjibhai
Gangarambhai
Vasoya
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Babubhai
Premjibhai
Sukhadiya
308Face Post-
value Pre-Issue Issue
Issue/transfe
Date of Number Nature of per equity equity
Nature of r price per
allotment/transfe of equity consideratio equit share share
transaction equity share
r shares n y capital capita
(in ₹)
share (in %) l (in
(in ₹) %)
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Jagdishkumar
Gopalbhai
Rakholiya
December 01, Transfer of share (500) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Viral
Rameshchandra
Bhatt
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Kirankumar Patel
December 01, Transfer of share (500) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Champaben G
Patel
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Bhikhabhai
Trikambhai Patel
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Nilay
Ghanshyambhai
Pandya
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Shamalbhai
Mulchandbhai
Gajjar
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Kajal Sandip
Vasani
December 01, Transfer of share (400) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Rajendra
Chandulal Shah
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Prakash K Shah
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Urmil Anubhai
Shah
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Gitaben
Hitendrabhai Patel
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Dayma Ashok
Babulal
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Chandubhai
Haribhai Patel
309Face Post-
value Pre-Issue Issue
Issue/transfe
Date of Number Nature of per equity equity
Nature of r price per
allotment/transfe of equity consideratio equit share share
transaction equity share
r shares n y capital capita
(in ₹)
share (in %) l (in
(in ₹) %)
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Dipika Nikul Patel
December 01, Transfer of share (500) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Darshan Aroon
Shah
December 01, Transfer of share (500) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Jigar Modi
December 01, Transfer of share (500) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Vidyaben Modi
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Vinodbhai
Somabhai Patel
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Nilam Sanjaybhai
Patel
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Sanjay Vinodbhai
Patel
December 01, Transfer of share (500) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Mittal N Patel
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Visnuprasad
Shivlal Patel
December 01, Transfer of share (500) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Savitaben
Natverbhai Patel
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Krishna Natubhai
Patel
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Natverlal Haribhai
Patel
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Chandrakant Dave
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Jyotiben Dave
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Divya Prakash
Gera
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Ramesh C Shah
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
310Face Post-
value Pre-Issue Issue
Issue/transfe
Date of Number Nature of per equity equity
Nature of r price per
allotment/transfe of equity consideratio equit share share
transaction equity share
r shares n y capital capita
(in ₹)
share (in %) l (in
(in ₹) %)
Kishanlal
Ramchand
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Manishkumar
Kishanlal
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Rita Kishanlal
Shajwani
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Bhumika Mahesh
Shajwani
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Mahesh Kishanlal
Shajwani
December 01, Transfer of share (600) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Shrenik Mohanlal
Shah
December 01, Transfer of share (600) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Sukesh Mohanlal
Shah
December 01, Transfer of share (600) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Lalita Ashok Shah
December 01, Transfer of share (600) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Sanjay Mohanlal
Shah
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Jyotsanaben S
Patel
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Kaushik
Bhikhbhai Patel
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Ganpatbhai
Ambalal Patel
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Komalben G Patel
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Prahaldbhai Patel
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Naresh
Hargovindbhai
Patel
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Sonal Sanjay Shah
311Face Post-
value Pre-Issue Issue
Issue/transfe
Date of Number Nature of per equity equity
Nature of r price per
allotment/transfe of equity consideratio equit share share
transaction equity share
r shares n y capital capita
(in ₹)
share (in %) l (in
(in ₹) %)
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Truptiben
Hiteshbhai Shah
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Rupa Sunil Shah
December 01, Transfer of share (500) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Kaushal
Kailaschandra
Dalal
December 01, Transfer of share (500) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Kajal Kaushal
Dalal
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Ashokbhai
Prajapati
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Seemaben
Prajapati
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Nayana Devendra
Patel
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Davendra
Somabhai Patel
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Jimil Chokshi
December 01, Transfer of share (500) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Amrutbhai R
Chaudhari
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Rajesh Pahlajrai
Chellani
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Suman Rajesh
Chellani
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Bhavana Manoj
Dalal
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Manoj Ramchand
Dalal
December 01, Transfer of share (500) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Ramiben
312Face Post-
value Pre-Issue Issue
Issue/transfe
Date of Number Nature of per equity equity
Nature of r price per
allotment/transfe of equity consideratio equit share share
transaction equity share
r shares n y capital capita
(in ₹)
share (in %) l (in
(in ₹) %)
Amrutbhai
Chaudhari
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Kaushikbhai
Dahyabhai Patel
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Kamlesh
Dahyabhai Patel
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Arvindbhai
Dahyabhai Patel
December 01, Transfer of share (400) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Pohapsingh Yadav
December 01, Transfer of share (400) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Khurshidbanu
Parwala
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Vinoda Kirti
Mehta
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Budhalal
Chimanlal
Kuvadia
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Indiraben
Jayantilal Shah
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Vishal Jayantilal
Shah
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Gemarbhai M
Patel
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Kalpana. Manish
Mehta
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Sejal Ronakbhai
Dalal
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Minesh
Indravadan Shah
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Ajay Shah
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
313Face Post-
value Pre-Issue Issue
Issue/transfe
Date of Number Nature of per equity equity
Nature of r price per
allotment/transfe of equity consideratio equit share share
transaction equity share
r shares n y capital capita
(in ₹)
share (in %) l (in
(in ₹) %)
Jawahar
Gopichand
Kapoor
December 01, Transfer of share (500) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Anuj Jain
December 01, Transfer of share (500) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Kanan Sanjay
Dalal
December 01, Transfer of share (500) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Sheela Ajay Dalal
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Kanubhai
Hargovandas Patel
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Sonal Deepakbhai
Shah
December 01, Transfer of share (500) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Naveen Kejriwal
December 01, Transfer of share (600) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Vimal Dairy
Limited
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Trivedi Sneha
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Jitendra Chandulal
Modi
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Bumika Kapadia
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Kiritkumar
Ramanlal Patel
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Siddharth
Shantilal Dikshit
December 01, Transfer of share (700) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Dave Dhruva
Hardikkumar
December 01, Transfer of share (100) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Dave Tilottama
Harvadan
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Deepakbhai
Sumitlal Shah
314Face Post-
value Pre-Issue Issue
Issue/transfe
Date of Number Nature of per equity equity
Nature of r price per
allotment/transfe of equity consideratio equit share share
transaction equity share
r shares n y capital capita
(in ₹)
share (in %) l (in
(in ₹) %)
December 01, Transfer of share (700) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Rutvi
Deepakkumar
Shah
December 01, Transfer of share (700) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Sanjay Sumitlal
Shah
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Rupal Sanjay
Shah
December 01, Transfer of share (700) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Nalin Sumatilal
Shah
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Aman Nalinkumar
Shah
December 01, Transfer of share (700) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Manish Babulal
Vaghasia
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Sangeeta
Manishbhai
Vaghasia
December 01, Transfer of share (700) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Kanchan
Nareshbhai Patel
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Nikita Nareshbhai
Patel
December 01, Transfer of share (700) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Amit Ashokbhai
Parikh
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Ashokbhai
Nemchand Parikh
December 01, Transfer of share (700) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Trupti Mehta
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Surekha
Vinodchandra
Mehta
December 01, Transfer of share (700) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Bhumita
Hiteshbhai
Sanghvi
315Face Post-
value Pre-Issue Issue
Issue/transfe
Date of Number Nature of per equity equity
Nature of r price per
allotment/transfe of equity consideratio equit share share
transaction equity share
r shares n y capital capita
(in ₹)
share (in %) l (in
(in ₹) %)
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Dhwani Hitesh
Sanghvi
December 01, Transfer of share (700) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Vinod Mehta
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Surekha
Vinodchandra
Mehta
December 01, Transfer of share (700) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Narendrakumar
Joshi
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Hansaben
Narendrakumar
Joshi
December 01, Transfer of share (700) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Janak
Narendrakumar
Joshi
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Hiral Janakkumar
Joshi
December 01, Transfer of share (700) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Darshan
Bharatbhai Patel
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Priti Darshan Patel
December 01, Transfer of share (700) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
J.D. Saraiya
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Ushaben J.
Saraiya
December 01, Transfer of share (700) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Kamleshbhai Patel
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Kevalbhai K. Patel
December 01, Transfer of share (700) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Malaben B. Rohra
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Bansilal
Thakurdas Rohra
December 01, Transfer of share (700) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
316Face Post-
value Pre-Issue Issue
Issue/transfe
Date of Number Nature of per equity equity
Nature of r price per
allotment/transfe of equity consideratio equit share share
transaction equity share
r shares n y capital capita
(in ₹)
share (in %) l (in
(in ₹) %)
Dharmesh
Odhavjibhai
Savani
December 01, Transfer of shares (400) Transfer 10 N.A. Negligibl [●]
2010# to Bhaveshkumar e
Odhavjibhai
Savani
December 01, Transfer of share (700) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Nirmala Upendra
Savani
December 01, Transfer of share (500) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Upendra
Odhavjibhai
Savani
December 01, Transfer of share (700) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Piyush Doshi
December 01, Transfer of share (700) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Minal Piyush
Doshi
December 01, Transfer of share (700) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Jayantibhai
Bhikhabhai Patel
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Vidhyaben
Jayantibhai Patel
December 01, Transfer of share (1,000) Gift 10 Nil (0.01) [●]
2010 by way of gift to
Sunil Prahladbhai
Sevani
December 01, Transfer of share (1,000) Gift 10 Nil (0.01) [●]
2010 by way of gift to
Kiranben
Sunilbhai Sevani
December 01, Transfer of share (1,000) Gift 10 Nil (0.01) [●]
2010 by way of gift to
Bunty Hundraj
Devnani
December 01, Transfer of share (1,000) Gift 10 Nil (0.01) [●]
2010 by way of gift to
Hundraj
Govindram
Devnani
December 01, Transfer of share (1,000) Gift 10 Nil (0.01) [●]
2010 by way of gift to
Manoj Arjundas
Chhabadia
December 01, Transfer of share (1,000) Gift 10 Nil (0.01) [●]
2010 by way of gift to
Rajkumar
Devnani
December 01, Transfer of share (700) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Dixitkumar
317Face Post-
value Pre-Issue Issue
Issue/transfe
Date of Number Nature of per equity equity
Nature of r price per
allotment/transfe of equity consideratio equit share share
transaction equity share
r shares n y capital capita
(in ₹)
share (in %) l (in
(in ₹) %)
Dashrathbhai
Patel
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Priti Dixitkumar
Patel
December 01, Transfer of share (700) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Sanjaykumar
Rameshbhai Patel
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Anitaben
Sanjaykumar Patel
December 01, Transfer of share (700) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Prahash Fin-Stock
Pvt Ltd
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Bharatbhai P. Patel
December 01, Transfer of share (700) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Meghnaben
Kumarbhai Mehta
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Ansuya P. Mehta
December 01, Transfer of share (700) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Hansaben
Mahendrabhai
Mehta
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Ansuya P. Mehta
December 01, Transfer of share (700) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Mahendrbhai
Chandulal Mehta
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Jasica M. Mehta
December 01, Transfer of share (700) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Chintan
Mahendrabhai
Mehta
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Jasica M. Mehta
December 01, Transfer of share (700) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Monali
Divyeshbhai Shah
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Divyeshbhai Shah
318Face Post-
value Pre-Issue Issue
Issue/transfe
Date of Number Nature of per equity equity
Nature of r price per
allotment/transfe of equity consideratio equit share share
transaction equity share
r shares n y capital capita
(in ₹)
share (in %) l (in
(in ₹) %)
December 01, Transfer of share (1,000) Gift 10 Nil (0.01) [●]
2010 by way of gift to
Sudhir Venkatesh
Kulkarni
December 01, Transfer of share (1,000) Gift 10 Nil (0.01) [●]
2010 by way of gift to
Ajaykumar N
Chaudhari
December 01, Transfer of share (1,000) Gift 10 Nil (0.01) [●]
2010 by way of gift to
Alpa Bhaveshbhai
Patel
December 01, Transfer of share (700) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Rajiv Narsinhbhai
Patel
December 01, Transfer of share (200) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Bindu R Patel
December 01, Transfer of share (100) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Rajiv Narsinhbhai
Patel-Huf
December 01, Transfer of share (700) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Shyamal T Rohra
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Kanta Shyamlal
Rohra
December 01, Transfer of share (700) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Kumarbhai
Pratapbhai Mehta
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Pratapbhai C
Mehta
December 01, Transfer of share (1,200) Gift 10 Nil (0.01) [●]
2010 by way of gift to
Sharad
Bipinchandra
Patel
December 01, Transfer of share (700) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Rekha Doshi
December 01, Transfer of share (700) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Ujas Piyush Doshi
December 01, Transfer of share (700) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Harshad Vyas
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Manjula
Kheemashanker
Vyas
319Face Post-
value Pre-Issue Issue
Issue/transfe
Date of Number Nature of per equity equity
Nature of r price per
allotment/transfe of equity consideratio equit share share
transaction equity share
r shares n y capital capita
(in ₹)
share (in %) l (in
(in ₹) %)
December 01, Transfer of share (700) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Sheetal Vyas
December 01, Transfer of share (700) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Arunkumar
Babulal Vyas-Huf
December 01, Transfer of share (700) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Shantiben
Narsinhbhai Patel
December 01, Transfer of share (800) Gift 10 Nil (0.01) [●]
2010 by way of gift to
Rajiv Narsinhbhai
Patel-Huf
December 01, Transfer of share (700) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Shreyans Rasiklal
Doshi
December 01, Transfer of share (700) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Riddhi
Shreyansbhai
Doshi
December 01, Transfer of share (600) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Bijal Rakeshbhai
Doshi
December 01, Transfer of share (700) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Swati Agarwal
December 01, Transfer of share (300) Gift 10 Nil Negligibl [●]
2010 by way of gift to e
Madhu Agrawal
August 23, 2011 Transfer of shares 600 Cash 10 80 Negligibl [●]
from Kalpesh e
Thaker
August 23, 2011 Transfer of shares 600 Cash 10 80 Negligibl [●]
from Ila Thaker e
July 04, 2012 Transfer of shares 600 Cash 10 10 Negligibl [●]
from Mayur e
Manubhai Parikh
July 04, 2012 Transfer of shares 600 Cash 10 10 Negligibl [●]
from Sushma e
Mayoor Parikh
July 10, 2012 Transfer of shares 600 Cash 10 75 Negligibl [●]
from Arvindbhai e
Chandulal
Chokshi
August 7, 2012 Transfer of shares 600 Cash 10 75 Negligibl [●]
from Jimil B. e
Choksi
September 22, Transfer of shares 600 Cash 10 75 Negligibl [●]
2012 from Harivadan e
shivlal Bhavsar
September 22, Transfer of shares 600 Cash 10 75 Negligibl [●]
2012 from Shah e
Dakshaben
pravinchandra
320Face Post-
value Pre-Issue Issue
Issue/transfe
Date of Number Nature of per equity equity
Nature of r price per
allotment/transfe of equity consideratio equit share share
transaction equity share
r shares n y capital capita
(in ₹)
share (in %) l (in
(in ₹) %)
October 19, 2012 Transfer of shares 600 Cash 10 10 Negligibl [●]
from Sejal e
Ronakbhai Dalal
& Ronak
Sarvadamanbhai
Dalal
October 19, 2012 Transfer of shares 500 Cash 10 10 Negligibl [●]
from Navin e
Kejrival
October 19, 2012 Transfer of shares 600 Cash 10 10 Negligibl [●]
from Archana e
Parikh & Ketan
Parikh*
October 19, 2012 Transfer of shares 600 Cash 10 10 Negligibl [●]
from Ganpatbhai e
Ambalal Patel
October 19, 2012 Transfer of shares 600 Cash 10 10 Negligibl [●]
from Komalben G e
Patel
October 20, 2012 Transfer from 600 Cash 10 75 Negligibl [●]
Kalpeshbhai e
Rasiklal
January 31, 2013 Transfer from 600 Cash 10 75 Negligibl [●]
Bharatkumar e
Amratlal Shah &
Pannaben
Bharatkumar*
March 09, 2013 Transfer of shares (400) Gift 10 Nil Negligibl [●]
by way of gift to e
Maulika N Gandhi
March 09, 2013 Transfer of shares (600) Gift 10 Nil Negligibl [●]
by way of gift to e
Sanjay A. Mehta
March 09, 2013 Transfer of shares (600) Gift 10 Nil Negligibl [●]
by way of gift to e
Jignesh n. Shukla
March 09, 2013 Transfer of shares (600) Gift 10 Nil Negligibl [●]
by way of gift to e
Nilesh G. Modi
March 09, 2013 Transfer of shares (600) Gift 10 Nil Negligibl [●]
by way of gift to e
kaivan R. Shah
March 09, 2013 Transfer of shares (600) Gift 10 Nil Negligibl [●]
by way of gift to e
Chirag V. Shah
March 09, 2013 Transfer of shares (600) Gift 10 Nil Negligibl [●]
by way of gift to e
Hitesh C Patel
March 09, 2013 Transfer of shares (600) Gift 10 Nil Negligibl [●]
by way of gift to e
Rekha D. Vohra
March 09, 2013 Transfer of shares (600) Gift 10 Nil Negligibl [●]
by way of gift to e
Jayesh D.
Pittalaya
March 09, 2013 Transfer of shares (600) Gift 10 Nil Negligibl [●]
by way of gift to e
Samir R Shah
321Face Post-
value Pre-Issue Issue
Issue/transfe
Date of Number Nature of per equity equity
Nature of r price per
allotment/transfe of equity consideratio equit share share
transaction equity share
r shares n y capital capita
(in ₹)
share (in %) l (in
(in ₹) %)
March 09, 2013 Transfer of shares (600) Gift 10 Nil Negligibl [●]
by way of gift to e
Sanjay H. Mistry
March 09, 2013 Transfer of shares (600) Gift 10 Nil Negligibl [●]
by way of gift to e
Kanubhai
Prajapati
March 09, 2013 Transfer of shares (600) Gift 10 Nil Negligibl [●]
by way of gift to e
Bhadresh h.
Punjabi
March 09, 2013 Transfer of shares (600) Gift 10 Nil Negligibl [●]
by way of gift to e
Vishal D. Parikh
March 09, 2013 Transfer of shares (600) Gift 10 Nil Negligibl [●]
by way of gift to e
Umesh B. athwara
March 09, 2013 Transfer of shares (600) Gift 10 Nil Negligibl [●]
by way of gift to e
Jinal Shah
March 09, 2013 Transfer of shares (600) Gift 10 Nil Negligibl [●]
by way of gift to e
Bhavini R. Shah
March 09, 2013 Transfer of shares (600) Gift 10 Nil Negligibl [●]
by way of gift to e
Paresh M. Jansari
March 09, 2013 Transfer of shares (600) Gift 10 Nil Negligibl [●]
by way of gift to e
Hemant Roy
March 09, 2013 Transfer of shares (400) Gift 10 Nil Negligibl [●]
by way of gift to e
Baiju M. Patel
March 09, 2013 Transfer of shares (400) Gift 10 Nil Negligibl [●]
by way of gift to e
Janak Shah
March 09, 2013 Transfer of shares (400) Gift 10 Nil Negligibl [●]
by way of gift to e
Shah Bhavi A.
March 09, 2013 Transfer of shares (400) Gift 10 Nil Negligibl [●]
by way of gift to e
Shah Shalvi R.
March 09, 2013 Transfer of shares (400) Gift 10 Nil Negligibl [●]
by way of gift to e
Bharat I. Patel
March 09, 2013 Transfer of shares (400) Gift 10 Nil Negligibl [●]
by way of gift to e
Shah Vatsal S.
March 09, 2013 Transfer of shares (400) Gift 10 Nil Negligibl [●]
by way of gift to e
Nirav R. Patel
March 09, 2013 Transfer of shares (400) Gift 10 Nil Negligibl [●]
by way of gift to e
Kamlesh M,
Vaghela
March 09, 2013 Transfer of shares (400) Gift 10 Nil Negligibl [●]
by way of gift to e
Rupang B. Shah
March 12, 2013# Transfer of shares (600) Transfer 10 N.A. Negligibl [●]
by way of gift to e
322Face Post-
value Pre-Issue Issue
Issue/transfe
Date of Number Nature of per equity equity
Nature of r price per
allotment/transfe of equity consideratio equit share share
transaction equity share
r shares n y capital capita
(in ₹)
share (in %) l (in
(in ₹) %)
Mukesh
Naranbhai
Kanodia
March 12, 2013# Transfer of shares (600) Transfer 10 N.A. Negligibl [●]
by way of gift to e
Gaurang
Madhubhai Shah
March 20, 2013 Transfer of shares 600 Cash 10 75 Negligibl [●]
from Rakesh e
Govindlal Thaker
March 20, 2013 Transfer of shares (20,000) Gift 10 Nil (0.13) [●]
by way of gift to
Pearl Shah
March 20, 2013 Transfer of shares (20,000) Gift 10 Nil (0.13) [●]
by way of gift to
Kenisha Tanmay
Shah
March 20, 2013 Transfer of shares (10,000) Gift 10 Nil (0.06) [●]
by way of gift to
Aashna Utpal
Shah
March 20, 2013 Transfer of shares (10,000) Gift 10 Nil (0.06) [●]
by way of gift to
Rehaan Utpal
Shah
March 20, 2013 Transfer of shares (20,100) Gift 10 Nil (0.13) [●]
by way of gift to
Ruchira Tanmay
Shah
March 20, 2013 Transfer of shares (200) Gift 10 Nil Negligibl [●]
by way of gift to e
Shah Ritesh
Pankajkumar
March 20, 2013 Transfer of shares (200) Gift 10 Nil Negligibl [●]
by way of gift to e
Ankit P. Shah
March 20, 2013 Transfer of shares (200) Gift 10 Nil Negligibl [●]
by way of gift to e
Shah Khushali
Pankajkumar
March 20, 2013 Transfer of shares (200) Gift 10 Nil Negligibl [●]
by way of gift to e
Panchal Bhavin A.
March 20, 2013 Transfer of shares (200) Gift 10 Nil Negligibl [●]
by way of gift to e
Saurin
Pravinchandra
Shah
March 20, 2013 Transfer of shares (200) Gift 10 Nil Negligibl [●]
by way of gift to e
Shah Alap
Sudhirbhai
March 20, 2013 Transfer of shares (200) Gift 10 Nil Negligibl [●]
by way of gift to e
Sathvara
Pradipkumar
Bakulbhai
323Face Post-
value Pre-Issue Issue
Issue/transfe
Date of Number Nature of per equity equity
Nature of r price per
allotment/transfe of equity consideratio equit share share
transaction equity share
r shares n y capital capita
(in ₹)
share (in %) l (in
(in ₹) %)
March 21, 2013 Transfer of shares (200) Gift 10 Nil Negligibl [●]
by way of gift to e
Mehul D. Patel
March 21, 2013 Transfer of shares 1,200 Cash 10 75 0.01 [●]
from Shah Niraj
Dilipkumar HUF
March 21, 2013 Transfer of shares 1,200 Cash 10 75 0.01 [●]
from Shah Dilip
Rasiklal HUF
March 21, 2013 Transfer of shares (200) Gift 10 Nil Negligibl [●]
by way of gift to e
Sameer
Chiplankar
March 21, 2013 Transfer of shares (200) Gift 10 Nil Negligibl [●]
by way of gift to e
Jaidev singh
Chundavat
March 21, 2013 Transfer of shares (200) Gift 10 Nil Negligibl [●]
by way of gift to e
Kirit Macwan
March 21, 2013 Transfer of shares (200) Gift 10 Nil Negligibl [●]
by way of gift to e
Avinash Khanna
April 08, 2013 Transfer of shares 600 Cash 10 75 Negligibl [●]
from Nikunj e
Ramanlal Desai
April 12, Transfer of shares 600 Cash 10 75 Negligibl [●]
2013 from Indiraben e
Jayantilal Shah
April 22, 2013 Transfer of shares (300) Gift 10 Nil Negligibl [●]
by way of gift to e
A.C. Dalal
April 22, 2013 Transfer of shares (300) Gift 10 Nil Negligibl [●]
by way of gift to e
Ashokumar Shah
April 22, 2013 Transfer of shares (300) Gift 10 Nil Negligibl [●]
by way of gift to e
Poornima Shah
April 22, 2013 Transfer of shares (500) Gift 10 Nil Negligibl [●]
by way of gift to e
Darshan Aroon
Shah
April 22, 2013 Transfer of shares (300) Gift 10 Nil Negligibl [●]
by way of gift to e
Neha Patel
April 22, 2013 Transfer of shares (500) Gift 10 Nil Negligibl [●]
by way of gift to e
Kajal Kaushal
Dalal
April 22, 2013 Transfer of shares (500) Gift 10 Nil Negligibl [●]
by way of gift to e
Kushal K. Dalal
April 22, 2013 Transfer of shares (300) Gift 10 Nil Negligibl [●]
by way of gift to e
Bipinchandra B.
Patel
April 22, 2013 Transfer of shares (675) Gift 10 Nil Negligibl [●]
by way of gift to e
Rasiklal M. Doshi
324Face Post-
value Pre-Issue Issue
Issue/transfe
Date of Number Nature of per equity equity
Nature of r price per
allotment/transfe of equity consideratio equit share share
transaction equity share
r shares n y capital capita
(in ₹)
share (in %) l (in
(in ₹) %)
April 23, 2013 Transfer of shares (500) Gift 10 Nil Negligibl [●]
by way of gift to e
Akash
Nalinkumar Shah
April 23, 2013 Transfer of shares (150) Gift 10 Nil Negligibl [●]
by way of gift to e
Aman Nalinkumar
Shah
April 23, 2013 Transfer of shares (500) Gift 10 Nil Negligibl [●]
by way of gift to e
Anand Ashvin
Dalal
April 23, 2013 Transfer of shares (300) Gift 10 Nil Negligibl [●]
by way of gift to e
Anil Baldevbhai
Patel
April 23, 2013 Transfer of shares (300) Gift 10 Nil Negligibl [●]
by way of gift to e
Arvindbhai
Prabhudas Patel
April 23, 2013 Transfer of shares (300) Gift 10 Nil Negligibl [●]
by way of gift to e
Hauben Natverlal
Shah
April 23, 2013 Transfer of shares (300) Gift 10 Nil Negligibl [●]
by way of gift to e
Bharat Natverlal
Shah
April 23, 2013 Transfer of shares (600) Gift 10 Nil Negligibl [●]
by way of gift to e
Bharati Dinesh
Desai
April 23, 2013 Transfer of shares (300) Gift 10 Nil Negligibl [●]
by way of gift to e
Bhavini
Rupeshbhai Shah
April 23, 2013 Transfer of shares (300) Gift 10 Nil Negligibl [●]
by way of gift to e
Bijal Rakeshbhai
Doshi
April 23, 2013 Transfer of shares (100) Gift 10 Nil Negligibl [●]
by way of gift to e
Bindu R Patel
April 23, 2013 Transfer of shares (500) Gift 10 Nil Negligibl [●]
by way of gift to e
Bindu Rajiv patel
April 23, 2013 Transfer of shares (300) Gift 10 Nil Negligibl [●]
by way of gift to e
Budhalal
Chimanlal
Kuvadia
April 23, 2013 Transfer of shares (300) Gift 10 Nil Negligibl [●]
by way of gift to e
Chandrakant Dave
April 23, 2013 Transfer of shares (300) Gift 10 Nil Negligibl [●]
by way of gift to e
Chandresh R Soni
April 23, 2013 Transfer of shares (300) Gift 10 Nil Negligibl [●]
by way of gift to e
325Face Post-
value Pre-Issue Issue
Issue/transfe
Date of Number Nature of per equity equity
Nature of r price per
allotment/transfe of equity consideratio equit share share
transaction equity share
r shares n y capital capita
(in ₹)
share (in %) l (in
(in ₹) %)
Chandubhai
Haribhai Patel
April 23, 2013 Transfer of shares (300) Gift 10 Nil Negligibl [●]
by way of gift to e
Chintan S Parikh
April 23, 2013 Transfer of shares (300) Gift 10 Nil Negligibl [●]
by way of gift to e
Davendra
Somabhai Patel
April 23, 2013 Transfer of shares (300) Gift 10 Nil Negligibl [●]
by way of gift to e
Deviben M Pujara
April 23, 2013 Transfer of shares (300) Gift 10 Nil Negligibl [●]
by way of gift to e
Dharmesh
Rasiklal Shah
April 23, 2013 Transfer of shares (750) Gift 10 Nil Negligibl [●]
by way of gift to e
Dhruva
Hardikkumar
Dave
April 23, 2013 Transfer of shares (300) Gift 10 Nil Negligibl [●]
by way of gift to e
Dilip R. soni
April 23, 2013 Transfer of shares (700) Gift 10 Nil Negligibl [●]
by way of gift to e
Dinesh Shah
April 23, 2013 Transfer of shares (300) Gift 10 Nil Negligibl [●]
by way of gift to e
Dipika Jayesh
Shah
April 23, 2013 Transfer of shares (300) Gift 10 Nil Negligibl [●]
by way of gift to e
Gemarbhai M
Patel
April 23, 2013 Transfer of shares (300) Gift 10 Nil Negligibl [●]
by way of gift to e
Girish
Hasmukhlal Kotak
April 23, 2013 Transfer of shares (300) Gift 10 Nil Negligibl [●]
by way of gift to e
Gitaben Girish
Kumar Kotak
April 23, 2013 Transfer of shares (300) Gift 10 Nil Negligibl [●]
by way of gift to e
Gitaben
Hitendrabhai Patel
April 23, 2013 Transfer of shares (300) Gift 10 Nil Negligibl [●]
by way of gift to e
Gopal Natverlal
Shah
April 23, 2013 Transfer of shares (300) Gift 10 Nil Negligibl [●]
by way of gift to e
Govind
Rukmanbhai
Nama
April 23, 2013 Transfer of shares (150) Gift 10 Nil Negligibl [●]
by way of gift to e
Hansaben
326Face Post-
value Pre-Issue Issue
Issue/transfe
Date of Number Nature of per equity equity
Nature of r price per
allotment/transfe of equity consideratio equit share share
transaction equity share
r shares n y capital capita
(in ₹)
share (in %) l (in
(in ₹) %)
Narendrakumar
Joshi
April 23, 2013 Transfer of shares (500) Gift 10 Nil Negligibl [●]
by way of gift to e
Hetal
Kamleshbhai Shah
April 23, 2013 Transfer of shares (300) Gift 10 Nil Negligibl [●]
by way of gift to e
Hinaben Dinesh
Shah
April 23, 2013 Transfer of shares (150) Gift 10 Nil Negligibl [●]
by way of gift to e
Hiral Janakkumar
Joshi
April 23, 2013 Transfer of shares (300) Gift 10 Nil Negligibl [●]
by way of gift to e
Hitendra Patel
April 23, 2013 Transfer of shares (300) Gift 10 Nil Negligibl [●]
by way of gift to e
Hitesh Vithalbhai
Patel
April 23, 2013 Transfer of shares (300) Gift 10 Nil Negligibl [●]
by way of gift to e
Indravadan Shah
April 23, 2013 Transfer of shares (850) Gift 10 Nil (0.01) [●]
by way of gift to
J.D.Saraiya
April 23, 2013 Transfer of shares (300) Gift 10 Nil Negligibl [●]
by way of gift to e
Jagruti Pravin
Master
April 23, 2013 Transfer of shares (850) Gift 10 Nil (0.01) [●]
by way of gift to
Janak
Narendrakumar
Joshi
April 23, 2013 Transfer of shares (300) Gift 10 Nil Negligibl [●]
by way of gift to e
Sobhana
Janakkumar
Babaria
April 23, 2013 Transfer of shares (150) Gift 10 Nil Negligibl [●]
by way of gift to e
Jankiben
Dharmendra
Kumar Patel
April 23, 2013 Transfer of shares (300) Gift 10 Nil Negligibl [●]
by way of gift to e
Jayesh Indravadan
Shah
April 23, 2013 Transfer of shares (300) Gift 10 Nil Negligibl [●]
by way of gift to e
Jayshree Patel
April 23, 2013 Transfer of shares (300) Gift 10 Nil Negligibl [●]
by way of gift to e
Jyotiben Dave
April 23, 2013 Transfer of shares (300) Gift 10 Nil Negligibl [●]
by way of gift to e
327Face Post-
value Pre-Issue Issue
Issue/transfe
Date of Number Nature of per equity equity
Nature of r price per
allotment/transfe of equity consideratio equit share share
transaction equity share
r shares n y capital capita
(in ₹)
share (in %) l (in
(in ₹) %)
Jyotsana Rajendra
Shah
April 23, 2013 Transfer of shares (300) Gift 10 Nil Negligibl [●]
by way of gift to e
Kajal Sandip
Vasani
April 23, 2013 Transfer of shares (300) Gift 10 Nil Negligibl [●]
by way of gift to e
Kamlesh
Jayantibhai Shah
April 23, 2013 Transfer of shares (500) Gift 10 Nil Negligibl [●]
by way of gift to e
Kamleshbhai Patel
April 23, 2013 Transfer of shares (300) Gift 10 Nil Negligibl [●]
by way of gift to e
Kanubha1
Hargovandas Patel
April 23, 2013 Transfer of shares (500) Gift 10 Nil Negligibl [●]
by way of gift to e
Kundan
Rameshbhai
Gandhi
April 23, 2013 Transfer of shares (300) Gift 10 Nil Negligibl [●]
by way of gift to e
Leena Shah
April 23, 2013 Transfer of shares (300) Gift 10 Nil Negligibl [●]
by way of gift to e
Mahesh Ramanlal
Gandhi
April 23, 2013 Transfer of shares (850) Gift 10 Nil (0.01) [●]
by way of gift to
Narendrakumar
Joshi
April 23, 2013 Transfer of shares (300) Gift 10 Nil Negligibl [●]
by way of gift to e
Naresh
Hargovindbhai
Patel
April 23, 2013 Transfer of shares (300) Gift 10 Nil Negligibl [●]
by way of gift to e
Nareshchandra
Shah
April 23, 2013 Transfer of shares (300) Gift 10 Nil Negligibl [●]
by way of gift to e
Natverlal Shanker
Lal Shah
April 23, 2013 Transfer of shares (500) Gift 10 Nil Negligibl [●]
by way of gift to e
Navinchandra V
Shah
April 23, 2013 Transfer of shares (300) Gift 10 Nil Negligibl [●]
by way of gift to e
Nayana Devendra
Patel
April 23, 2013 Transfer of shares (400) Gift 10 Nil Negligibl [●]
by way of gift to e
Praful K. Shah
April 23, 2013 Transfer of shares (300) Gift 10 Nil Negligibl [●]
by way of gift to e
328Face Post-
value Pre-Issue Issue
Issue/transfe
Date of Number Nature of per equity equity
Nature of r price per
allotment/transfe of equity consideratio equit share share
transaction equity share
r shares n y capital capita
(in ₹)
share (in %) l (in
(in ₹) %)
Prakash
Hasmukhlal Kotak
April 23, 2013 Transfer of shares (300) Gift 10 Nil Negligibl [●]
by way of gift to e
Prakash K Shah
April 23, 2013 Transfer of shares (300) Gift 10 Nil Negligibl [●]
by way of gift to e
Prashant Ukabhai
Patel
April 23, 2013 Transfer of shares (300) Gift 10 Nil Negligibl [●]
by way of gift to e
Pravinchandra A
Shah
April 23, 2013 Transfer of shares (300) Gift 10 Nil Negligibl [●]
by way of gift to e
Rajendra Kantilal
Shah
April 23, 2013 Transfer of shares (300) Gift 10 Nil Negligibl [●]
by way of gift to e
Rajesh Maneklal
Kotak
April 23, 2013 Transfer of shares (850) Gift 10 Nil (0.01) [●]
by way of gift to
Rajiv Narsinhbhai
Patel
April 23, 2013 Transfer of shares (450) Gift 10 Nil Negligibl [●]
by way of gift to e
Rajiv Narsinhbhai
Patel-Huf
April 23, 2013 Transfer of shares (300) Gift 10 Nil Negligibl [●]
by way of gift to e
Ramesh Sorathia
April 23, 2013 Transfer of shares (300) Gift 10 Nil Negligibl [●]
by way of gift to e
Rashmiben Gajjar
April 23, 2013 Transfer of shares (600) Gift 10 Nil Negligibl [●]
by way of gift to e
Rekhaben
Rajeshkumar
Kotak
April 23, 2013 Transfer of shares (300) Gift 10 Nil Negligibl [●]
by way of gift to e
Renukaben
Arvindkumar
Patel
April 23, 2013 Transfer of shares (350) Gift 10 Nil Negligibl [●]
by way of gift to e
Riddhi
Shreyansbhai
Doshi
April 23, 2013 Transfer of shares (500) Gift 10 Nil Negligibl [●]
by way of gift to e
Roopa
Manojkumar Shah
April 23, 2013 Transfer of shares (150) Gift 10 Nil Negligibl [●]
by way of gift to e
Rupal Sanjay
Shah
329Face Post-
value Pre-Issue Issue
Issue/transfe
Date of Number Nature of per equity equity
Nature of r price per
allotment/transfe of equity consideratio equit share share
transaction equity share
r shares n y capital capita
(in ₹)
share (in %) l (in
(in ₹) %)
April 23, 2013 Transfer of shares (800) Gift 10 Nil (0.01) [●]
by way of gift to
Shantiben
Narsimha Patel
April 23, 2013 Transfer of shares (675) Gift 10 Nil Negligibl [●]
by way of gift to e
Shreyans Rasiklal
Doshi
April 23, 2013 Transfer of shares (300) Gift 10 Nil Negligibl [●]
by way of gift to e
Sudha Kamlesh
Modi
April 23, 2013 Transfer of shares (300) Gift 10 Nil Negligibl [●]
by way of gift to e
Suleman Khoja
April 23, 2013 Transfer of shares (300) Gift 10 Nil Negligibl [●]
by way of gift to e
Surekha Suketu
Javeri
April 23, 2013 Transfer of shares (300) Gift 10 Nil Negligibl [●]
by way of gift to e
Sushma Mahesh
Gandhi
April 23, 2013 Transfer of shares (300) Gift 10 Nil Negligibl [●]
by way of gift to e
Tapan Dinesh
Shah
April 23, 2013 Transfer of shares (150) Gift 10 Nil Negligibl [●]
by way of gift to e
Ushaben J.
Saraiya
April 23, 2013 Transfer of shares (500) Gift 10 Nil Negligibl [●]
by way of gift to e
Varshaben G
Gadani
April 23, 2013 Transfer of shares (300) Gift 10 Nil Negligibl [●]
by way of gift to e
Vishal Jayantilal
Shah
April 23, 2013 Transfer of shares (300) Gift 10 Nil Negligibl [●]
by way of gift to e
Patel Bhadresh P
April 26, 2013 Transfer of shares (300) Gift 10 Nil Negligibl [●]
by way of gift to e
Dilipbhai R Patel
April 26, 2013 Transfer of shares (300) Gift 10 Nil Negligibl [●]
by way of gift to e
Sheelaben D Patel
April 26, 2013 Transfer of shares (300) Gift 10 Nil Negligibl [●]
by way of gift to e
Chander
Choithram
Vanvari
April 26, 2013 Transfer of shares (300) Gift 10 Nil Negligibl [●]
by way of gift to e
Indumati Chander
Vanvari
April 26, 2013 Transfer of shares (300) Gift 10 Nil Negligibl [●]
by way of gift to e
330Face Post-
value Pre-Issue Issue
Issue/transfe
Date of Number Nature of per equity equity
Nature of r price per
allotment/transfe of equity consideratio equit share share
transaction equity share
r shares n y capital capita
(in ₹)
share (in %) l (in
(in ₹) %)
Bhavana Manoj
Dalal
April 26, 2013 Transfer of shares (850) Gift 10 Nil (0.01) [●]
by way of gift to
Sanjay Sumatilal
Shah
April 26, 2013 Transfer of shares (650) Gift 10 Nil Negligibl [●]
by way of gift to e
Deepak Bhai
Sumatilal Shah
April 26, 2013 Transfer of shares (150) Gift 10 Nil Negligibl [●]
by way of gift to e
Sonal Deepakbhai
Shah
April 26, 2013 Transfer of shares (300) Gift 10 Nil Negligibl [●]
by way of gift to e
Manoj Ramchand
Dalal
April 26, 2013 Transfer of shares (300) Gift 10 Nil Negligibl [●]
by way of gift to e
Jawahar
Gopichand
Kapoor
April 26, 2013 Transfer of shares (500) Gift 10 Nil Negligibl [●]
by way of gift to e
Rajesh Rohra
April 26, 2013 Transfer of shares (300) Gift 10 Nil Negligibl [●]
by way of gift to e
Jignesh Maniar
April 26, 2013 Transfer of shares (300) Gift 10 Nil Negligibl [●]
by way of gift to e
Shivani Maniar
April 26, 2013 Transfer of shares (300) Gift 10 Nil Negligibl [●]
by way of gift to e
Vipul C Desai
April 26, 2013 Transfer of shares (150) Gift 10 Nil Negligibl [●]
by way of gift to e
Kanta Shyamlal
Rohra
April 26, 2013 Transfer of shares (1,000) Gift 10 Nil (0.01) [●]
by way of gift to
Bunty Hundraj
Devnani
April 26, 2013 Transfer of shares (600) Gift 10 Nil Negligibl [●]
by way of gift to e
Piyushkumar
Krishnachandra
Dani
April 26, 2013 Transfer of shares (400) Gift 10 Nil Negligibl [●]
by way of gift to e
Bhavana
Piyushkumar Dani
April 26, 2013 Transfer of shares (300) Gift 10 Nil Negligibl [●]
by way of gift to e
Chetna Vipul
Desai
April 26, 2013 Transfer of shares (300) Gift 10 Nil Negligibl [●]
by way of gift to e
Sarojben C Desai
331Face Post-
value Pre-Issue Issue
Issue/transfe
Date of Number Nature of per equity equity
Nature of r price per
allotment/transfe of equity consideratio equit share share
transaction equity share
r shares n y capital capita
(in ₹)
share (in %) l (in
(in ₹) %)
April 26, 2013 Transfer of shares (300) Gift 10 Nil Negligibl [●]
by way of gift to e
Suman Rajesh
Chellani
April 26, 2013 Transfer of shares (400) Gift 10 Nil Negligibl [●]
by way of gift to e
Pohapsingh Yadav
April 26, 2013 Transfer of shares (300) Gift 10 Nil Negligibl [●]
by way of gift to e
Anuradha Bhavsar
April 26, 2013 Transfer of shares (300) Gift 10 Nil Negligibl [●]
by way of gift to e
Rajiv Bhavsar
April 26, 2013 Transfer of shares (300) Gift 10 Nil Negligibl [●]
by way of gift to e
Dipika Nikul Patel
April 26, 2013 Transfer of shares (300) Gift 10 Nil Negligibl [●]
by way of gift to e
Rita Kishanlal
Shajwani
April 26, 2013 Transfer of shares (300) Gift 10 Nil Negligibl [●]
by way of gift to e
Bhumika Mahesh
Shajwani
April 26, 2013 Transfer of shares (300) Gift 10 Nil Negligibl [●]
by way of gift to e
Mahesh Kishanlal
Shajwani
April 26, 2013 Transfer of shares (300) Gift 10 Nil Negligibl [●]
by way of gift to e
Ramesh C Shah
April 26, 2013 Transfer of shares (300) Gift 10 Nil Negligibl [●]
by way of gift to e
Neeta Dipak Patel
April 26, 2013 Transfer of shares (300) Gift 10 Nil Negligibl [●]
by way of gift to e
Yogeshchandra
Manohar Neve
April 26, 2013 Transfer of shares (300) Gift 10 Nil Negligibl [●]
by way of gift to e
Nilima
Yogeshchandra
Neve
April 26, 2013 Transfer of shares (300) Gift 10 Nil Negligibl [●]
by way of gift to e
Shachish Piyush
Doctor
April 26, 2013 Transfer of shares (300) Gift 10 Nil Negligibl [●]
by way of gift to e
Shital Bihagbhai
Angreji
April 26, 2013 Transfer of shares (400) Gift 10 Nil Negligibl [●]
by way of gift to e
Jitendra
Amarchand Desai
April 26, 2013 Transfer of shares (350) Gift 10 Nil Negligibl [●]
by way of gift to e
Minal Piyush
Doshi
332Face Post-
value Pre-Issue Issue
Issue/transfe
Date of Number Nature of per equity equity
Nature of r price per
allotment/transfe of equity consideratio equit share share
transaction equity share
r shares n y capital capita
(in ₹)
share (in %) l (in
(in ₹) %)
April 26, 2013 Transfer of shares (1,050) Gift 10 Nil (0.01) [●]
by way of gift to
Rekha Doshi
April 26, 2013 Transfer of shares (350) Gift 10 Nil Negligibl [●]
by way of gift to e
Ujas Piyush Doshi
April 26, 2013 Transfer of shares (1,050) Gift 10 Nil (0.01) [●]
by way of gift to
Piyush Doshi
April 26, 2013 Transfer of shares (300) Gift 10 Nil Negligibl [●]
by way of gift to e
Rajesh Pahlajrai
Chellani
April 29, 2013# Transfer from Heta 500 Transfer 10 N.A. Negligibl [●]
Kalpesh Shah e
May 1, 2013 Transfer of shares (350) Gift 10 Nil Negligibl [●]
by way of gift to e
Rutvi
Deepakkumar
Shah
May 1, 2013 Transfer of shares (850) Gift 10 Nil (0.01) [●]
by way of gift to
Nalin Sumatilal
Shah
May 1, 2013 Transfer of shares (500) Gift 10 Nil Negligibl [●]
by way of gift to e
Amrutbhai R
Chaudhari
May 1, 2013 Transfer of shares (300) Gift 10 Nil Negligibl [●]
by way of gift to e
Asit Iitendrabhai
Zaveri
May 1, 2013 Transfer of shares (850) Gift 10 Nil (0.01) [●]
by way of gift to
Swati Binod
Agarwal
May 1, 2013 Transfer of shares (250) Gift 10 Nil Negligibl [●]
by way of gift to e
Naveen Kejriwal
May 1, 2013 Transfer of shares (600) Gift 10 Nil Negligibl [●]
by way of gift to e
Jigna Texas Dave
May 1, 2013 Transfer of shares (300) Gift 10 Nil Negligibl [●]
by way of gift to e
Bharatkumar
Daftary
May 1, 2013 Transfer of shares (850) Gift 10 Nil (0.01) [●]
by way of gift to
Shyamal T Rohra
May 1, 2013 Transfer of shares (300) Gift 10 Nil Negligibl [●]
by way of gift to e
Bhikhalal H Soni
May 1, 2013 Transfer of shares (300) Gift 10 Nil Negligibl [●]
by way of gift to e
Chintan
Pankajkumar Shah
May 1, 2013 Transfer of shares (300) Gift 10 Nil Negligibl [●]
by way of gift to e
333Face Post-
value Pre-Issue Issue
Issue/transfe
Date of Number Nature of per equity equity
Nature of r price per
allotment/transfe of equity consideratio equit share share
transaction equity share
r shares n y capital capita
(in ₹)
share (in %) l (in
(in ₹) %)
Chandrakant A
Desai
May 1, 2013 Transfer of shares (300) Gift 10 Nil Negligibl [●]
by way of gift to e
Nilay
Bharatkumar
Contractor
May 1, 2013 Transfer of shares (300) Gift 10 Nil Negligibl [●]
by way of gift to e
Minesh
Indravadan Shah
May 1, 2013 Transfer of shares (300) Gift 10 Nil Negligibl [●]
by way of gift to e
Inaxi Nareshbhai
Shah
May 1, 2013 Transfer of shares (300) Gift 10 Nil Negligibl [●]
by way of gift to e
Shobhan S Parikh
May 1, 2013 Transfer of shares (300) Gift 10 Nil Negligibl [●]
by way of gift to e
Kamlesh
Dahyabhai Patel
May 1, 2013 Transfer of shares (600) Gift 10 Nil Negligibl [●]
by way of gift to e
Dipal Rameshbhai
Shah
May 1, 2013 Transfer of shares (700) Gift 10 Nil Negligibl [●]
by way of gift to e
Malti Ashokbhai
Parikh
May 1, 2013 Transfer of shares (850) Gift 10 Nil (0.01) [●]
by way of gift to
Amit Ashokbhai
Parikh
May 1, 2013 Transfer of shares (700) Gift 10 Nil Negligibl [●]
by way of gift to e
Krina Amit Parikh
May 1, 2013 Transfer of shares (150) Gift 10 Nil Negligibl [●]
by way of gift to e
Ashokbhai
Nemchand Parikh
May 1, 2013 Transfer of shares (300) Gift 10 Nil Negligibl [●]
by way of gift to e
Ranjan Patwa
May 1, 2013 Transfer of shares (300) Gift 10 Nil Negligibl [●]
by way of gift to e
Amitbhai Popatlal
Shah
May 1, 2013 Transfer of shares (400) Gift 10 Nil Negligibl [●]
by way of gift to e
Ketan Tejpal
Parikh
May 1, 2013 Transfer of shares (300) Gift 10 Nil Negligibl [●]
by way of gift to e
Rajiv Tejpal
Parikh
May 1, 2013 Transfer of shares (300) Gift 10 Nil Negligibl [●]
by way of gift to e
Sonal Rajiv Parikh
334Face Post-
value Pre-Issue Issue
Issue/transfe
Date of Number Nature of per equity equity
Nature of r price per
allotment/transfe of equity consideratio equit share share
transaction equity share
r shares n y capital capita
(in ₹)
share (in %) l (in
(in ₹) %)
May 1, 2013 Transfer of shares (300) Gift 10 Nil Negligibl [●]
by way of gift to e
Nilesh Kothari
(Lopa + Nilesh)
May 1, 2013 Transfer of shares (600) Gift 10 Nil Negligibl [●]
by way of gift to e
Sanjay Mohanlal
Shah
May 1, 2013 Transfer of shares (600) Gift 10 Nil Negligibl [●]
by way of gift to e
Shrenik Mohanlal
Shah
May 1, 2013 Transfer of shares (600) Gift 10 Nil Negligibl [●]
by way of gift to e
Sukesh Mohanlal
Shah
May 1, 2013 Transfer of shares (850) Gift 10 Nil (0.01) [●]
by way of gift to
Monali
Divyeshbhai Shah
May 1, 2013 Transfer of shares (150) Gift 10 Nil Negligibl [●]
by way of gift to e
Divyeshbhai Shah
May 1, 2013 Transfer of shares (500) Gift 10 Nil Negligibl [●]
by way of gift to e
Rashmika Shah
May 1, 2013 Transfer of shares (150) Gift 10 Nil Negligibl [●]
by way of gift to e
Nikita Nareshbhai
Patel
May 1, 2013 Transfer of shares (850) Gift 10 Nil (0.01) [●]
by way of gift to
Kanchan
Nareshbhat Patel
May 1, 2013 Transfer of shares (150) Gift 10 Nil Negligibl [●]
by way of gift to e
Bharatbhni P.
Patel
May 1, 2013 Transfer of shares (850) Gift 10 Nil (0.01) [●]
by way of gift to
Prahash Fin-Stock
Pvt Ltd
May 1, 2013 Transfer of shares (300) Gift 10 Nil Negligibl [●]
by way of gift to e
Kamlesh Kothari
May 1, 2013 Transfer of shares (300) Gift 10 Nil Negligibl [●]
by way of gift to e
Vaishali Shah
May 1, 2013 Transfer of shares (700) Gift 10 Nil Negligibl [●]
by way of gift to e
Dipan Kothari
May 1, 2013 Transfer of shares (500) Gift 10 Nil Negligibl [●]
by way of gift to e
Jigar Modi
May 1, 2013 Transfer of shares (500) Gift 10 Nil Negligibl [●]
by way of gift to e
Vidyaben Modi
335Face Post-
value Pre-Issue Issue
Issue/transfe
Date of Number Nature of per equity equity
Nature of r price per
allotment/transfe of equity consideratio equit share share
transaction equity share
r shares n y capital capita
(in ₹)
share (in %) l (in
(in ₹) %)
May 1, 2013 Transfer of shares (850) Gift 10 Nil (0.01) [●]
by way of gift to
Darshan Patel
May 1, 2013 Transfer of shares (150) Gift 10 Nil Negligibl [●]
by way of gift to e
Priti D. patel
May 1, 2013 Transfer of shares (300) Gift 10 Nil Negligibl [●]
by way of gift to e
Kaushik D. patel
May 1, 2013 Transfer of shares (300) Gift 10 Nil Negligibl [●]
by way of gift to e
Suresh M. shah
May 1, 2013 Transfer of shares (500) Gift 10 Nil Negligibl [●]
by way of gift to e
Kanan s. dalal
May 1, 2013 Transfer of shares (500) Gift 10 Nil Negligibl [●]
by way of gift to e
Sheela Ajay dalal
May 1, 2013 Transfer of shares (300) Gift 10 Nil Negligibl [●]
by way of gift to e
Nishant M. shah
May 1, 2013 Transfer of shares (300) Gift 10 Nil Negligibl [●]
by way of gift to e
Srujal Shah
May 1, 2013 Transfer of shares (300) Gift 10 Nil Negligibl [●]
by way of gift to e
Atul C. shah
May 1, 2013 Transfer of shares (300) Gift 10 Nil Negligibl [●]
by way of gift to e
Pathik A. shah
May 1, 2013 Transfer of shares (500) Gift 10 Nil Negligibl [●]
by way of gift to e
Hetal Kamlesh
shah
May 2, 2013 Transfer of shares (300) Gift 10 Nil Negligibl [●]
by way of gift to e
Nisith Shah
May 2, 2013 Transfer of shares (400) Gift 10 Nil Negligibl [●]
by way of gift to e
Abdurrehman A
Memon
May 2, 2013 Transfer of shares (300) Gift 10 Nil Negligibl [●]
by way of gift to e
GulamMohamed
A Memon
May 2, 2013 Transfer of shares (300) Gift 10 Nil Negligibl [●]
by way of gift to e
Mohamed Yusuf
Memon
May 2, 2013 Transfer of shares (300) Gift 10 Nil Negligibl [●]
by way of gift to e
Usmangani A
Memon
May 2, 2013 Transfer of shares (300) Gift 10 Nil Negligibl [●]
by way of gift to e
Sarabai
Usmangani
Memon
336Face Post-
value Pre-Issue Issue
Issue/transfe
Date of Number Nature of per equity equity
Nature of r price per
allotment/transfe of equity consideratio equit share share
transaction equity share
r shares n y capital capita
(in ₹)
share (in %) l (in
(in ₹) %)
May 2, 2013 Transfer of shares (600) Gift 10 Nil Negligibl [●]
by way of gift to e
Ghanshyambhai
Patel
May 2, 2013 Transfer of shares (300) Gift 10 Nil Negligibl [●]
by way of gift to e
Kaushikkumar
Ramanlal Patel
May 2, 2013 Transfer of shares (300) Gift 10 Nil Negligibl [●]
by way of gift to e
Amita Kaushik
Patel
May 2, 2013 Transfer of shares (300) Gift 10 Nil Negligibl [●]
by way of gift to e
Dayma Ashok
Babulal
May 2, 2013 Transfer of shares (400) Gift 10 Nil Negligibl [●]
by way of gift to e
Monali
Birenkumar Shah
May 2, 2013 Transfer of shares (300) Gift 10 Nil Negligibl [●]
by way of gift to e
Surendra Popatlal
Shah
May 2, 2013 Transfer of shares (300) Gift 10 Nil Negligibl [●]
by way of gift to e
Bharatbhai
Umedchand
Gopani
May 2, 2013 Transfer of shares (300) Gift 10 Nil Negligibl [●]
by way of gift to e
Prashant
Shankerprasad
Vyas
May 2, 2013 Transfer of shares (500) Gift 10 Nil Negligibl [●]
by way of gift to e
Hemang Amrutlal
Patel
May 03, 2013 Transfer of shares (600) Gift 10 Nil Negligibl [●]
by way of gift to e
Raju Shankarbhai
Thakur
May 7, Transfer of shares (300) Gift 10 Nil Negligibl [●]
2013 by way of gift to e
Nachiketa Bhatt
May 7, Transfer of shares (500) Gift 10 Nil Negligibl [●]
2013 by way of gift to e
Gita B Patel
May 7, Transfer of shares (150) Gift 10 Nil Negligibl [●]
2013 by way of gift to e
Jitendra G. Modi
May 7, Transfer of shares (300) Gift 10 Nil Negligibl [●]
2013 by way of gift to e
Shamalbhai M.
Gajjar
May 7, Transfer of shares (400) Gift 10 Nil Negligibl [●]
2013 by way of gift to e
Khurshid Banu
337Face Post-
value Pre-Issue Issue
Issue/transfe
Date of Number Nature of per equity equity
Nature of r price per
allotment/transfe of equity consideratio equit share share
transaction equity share
r shares n y capital capita
(in ₹)
share (in %) l (in
(in ₹) %)
May 7, Transfer of shares (500) Gift 10 Nil Negligibl [●]
2013 by way of gift to e
Chirag A. Patel
May 7, Transfer of shares (500) Gift 10 Nil Negligibl [●]
2013 by way of gift to e
Amratbhai H.
Patel
May 7, Transfer of shares (500) Gift 10 Nil Negligibl [●]
2013 by way of gift to e
Hasumati A. patel
May 7, Transfer of shares (500) Gift 10 Nil Negligibl [●]
2013 by way of gift to e
Amratbhai H.
Patel
May 7, Transfer of shares (300) Gift 10 Nil Negligibl [●]
2013 by way of gift to e
Pravin M. patel
May 7, Transfer of shares (500) Gift 10 Nil Negligibl [●]
2013 by way of gift to e
Champaben G.
Patel
May 7, Transfer of shares (300) Gift 10 Nil Negligibl [●]
2013 by way of gift to e
Bhavana Patel
May 7, Transfer of shares (600) Gift 10 Nil Negligibl [●]
2013 by way of gift to e
Dipak N. Shah
May 7, Transfer of shares (300) Gift 10 Nil Negligibl [●]
2013 by way of gift to e
Mrunalini Patel
May 7, Transfer of shares (300) Gift 10 Nil Negligibl [●]
2013 by way of gift to e
Rajesh Patel
May 7, Transfer of shares (400) Gift 10 Nil Negligibl [●]
2013 by way of gift to e
Rajesh c. shah
May 7, Transfer of shares (1,200) Gift 10 Nil (0.01) [●]
2013 by way of gift to
Sharad B. patel
May 7, Transfer of shares (600) Gift 10 Nil Negligibl [●]
2013 by way of gift to e
Bharti D. desai
May 7, Transfer of shares (400) Gift 10 Nil Negligibl [●]
2013 by way of gift to e
Devang N. gandhi
May 7, Transfer of shares (700) Gift 10 Nil Negligibl [●]
2013 by way of gift to e
Harshad vyas
May 7, Transfer of shares (1,050) Gift 10 Nil (0.01) [●]
2013 by way of gift to
Sheetal vyas
May 7, Transfer of shares (300) Gift 10 Nil Negligibl [●]
2013 by way of gift to e
Manjula K. vyas
May 7, Transfer of shares (350) Gift 10 Nil Negligibl [●]
2013 by way of gift to e
Arunkumar B.
vyas
338Face Post-
value Pre-Issue Issue
Issue/transfe
Date of Number Nature of per equity equity
Nature of r price per
allotment/transfe of equity consideratio equit share share
transaction equity share
r shares n y capital capita
(in ₹)
share (in %) l (in
(in ₹) %)
May 7, Transfer of shares (300) Gift 10 Nil Negligibl [●]
2013 by way of gift to e
Vinod somabhai
patel
May 7, Transfer of shares (300) Gift 10 Nil Negligibl [●]
2013 by way of gift to e
Nilam S. patel
May 7, Transfer of shares (300) Gift 10 Nil Negligibl [●]
2013 by way of gift to e
Sanjay v. patel
May 7, Transfer of shares (300) Gift 10 Nil Negligibl [●]
2013 by way of gift to e
Prahalbhai patel
May 7, Transfer of shares (300) Gift 10 Nil Negligibl [●]
2013 by way of gift to e
Kiritkumar R.
patel
May 7, Transfer of shares (300) Gift 10 Nil Negligibl [●]
2013 by way of gift to e
Hansaben N. patel
May 7, Transfer of shares (600) Gift 10 Nil Negligibl [●]
2013 by way of gift to e
Lalita A. shah
May 9, Transfer of shares (300) Gift 10 Nil Negligibl [●]
2013 by way of gift to e
Nilay G. pandya
May 9, Transfer of shares (300) Gift 10 Nil Negligibl [●]
2013 by way of gift to e
Bhupendra shah
May 9, Transfer of shares (1,000) Gift 10 Nil (0.01) [●]
2013 by way of gift to
Sudhir V. kulkari
May 9, Transfer of shares (150) Gift 10 Nil Negligibl [●]
2013 by way of gift to e
Dasrathbhai patel
May 9, Transfer of shares (200) Gift 10 Nil Negligibl [●]
2013 by way of gift to e
Hasmukh A.
belani
May 9, Transfer of shares (200) Gift 10 Nil Negligibl [●]
2013 by way of gift to e
Rima D. patel
May 9, Transfer of shares (200) Gift 10 Nil Negligibl [●]
2013 by way of gift to e
Maulika Gandhi
May 9, Transfer of shares (200) Gift 10 Nil Negligibl [●]
2013 by way of gift to e
Jaidevsinh
chandavat
May 9, Transfer of shares (200) Gift 10 Nil Negligibl [●]
2013 by way of gift to e
Dhirajlal P.
kansara
May 9, Transfer of shares (300) Gift 10 Nil Negligibl [●]
2013 by way of gift to e
Premilaben A.
chauhan
339Face Post-
value Pre-Issue Issue
Issue/transfe
Date of Number Nature of per equity equity
Nature of r price per
allotment/transfe of equity consideratio equit share share
transaction equity share
r shares n y capital capita
(in ₹)
share (in %) l (in
(in ₹) %)
May 9, Transfer of shares (150) Gift 10 Nil Negligibl [●]
2013 by way of gift to e
Jitenra C. modi
May 9, Transfer of shares (150) Gift 10 Nil Negligibl [●]
2013 by way of gift to e
Swati agrawal
May 9, Transfer of shares (400) Gift 10 Nil Negligibl [●]
2013 by way of gift to e
Jwelin shah
May 9, Transfer of shares (300) Gift 10 Nil Negligibl [●]
2013 by way of gift to e
Shailesh shah
May 9, Transfer of shares (500) Gift 10 Nil Negligibl [●]
2013 by way of gift to e
Amrut R.
chaudhary
May 10, 2013 Transfer of shares (300) Gift 10 Nil Negligibl [●]
by way of gift to e
Anusyaben P.
Mehta
May 10, 2013 Transfer of shares (300) Gift 10 Nil Negligibl [●]
by way of gift to e
Daree v. patel
May 10, 2013 Transfer of shares (300) Gift 10 Nil Negligibl [●]
by way of gift to e
Kundan V. patel
May 10, 2013 Transfer of shares (150) Gift 10 Nil Negligibl [●]
by way of gift to e
Pratap mehta
May 10, 2013 Transfer of shares (850) Gift 10 Nil (0.01) [●]
by way of gift to
Chintan Mehta
May 10, 2013 Transfer of shares (850) Gift 10 Nil (0.01) [●]
by way of gift to
Meghna Mehta
May 10, 2013# Transfer of shares (300) Gift 10 Nil Negligibl [●]
by way of gift to e
Bhupendra shah
May 11, 2013# Transfer of shares (300) Gift 10 Nil Negligibl [●]
by way of gift to e
Kirankumar
Ambalal Patel
May 11, 2013 Transfer of shares (300) Gift 10 Nil Negligibl [●]
by way of gift to e
Bina
Kalpeshkumar
Shah
May 11, 2013 Transfer of shares (300) Gift 10 Nil Negligibl [●]
by way of gift to e
Bhumika kapadia
May 11, 2013 Transfer of shares (300) Gift 10 Nil Negligibl [●]
by way of gift to e
Harish patel
May 11, 2013 Transfer of shares (300) Gift 10 Nil Negligibl [●]
by way of gift to e
Jasica M. mehta
May 11, 2013 Transfer of shares (850) Gift 10 Nil (0.01) [●]
by way of gift to
340Face Post-
value Pre-Issue Issue
Issue/transfe
Date of Number Nature of per equity equity
Nature of r price per
allotment/transfe of equity consideratio equit share share
transaction equity share
r shares n y capital capita
(in ₹)
share (in %) l (in
(in ₹) %)
Hansaben M.
mehta
May 11, 2013 Transfer of shares (850) Gift 10 Nil (0.01) [●]
by way of gift to
Mahendrabhai C.
mehta
May 11, 2013 Transfer of shares (31,700) Gift 10 Nil (0.20) [●]
by way of gift to
Utapl P. shah
May 11, 2013 Transfer of shares (300) Gift 10 Nil Negligibl [●]
by way of gift to e
Rajiv N. patel
HUF
June 12, 2013 Transfer of shares (200) Gift 10 Nil Negligibl [●]
by way of gift to e
Parul Hitesh
Chauhan
June 12, 2013 Transfer of shares (300) Gift 10 Nil Negligibl [●]
by way of gift to e
Hardik D. patel
June 12, 2013 Transfer of shares (300) Gift 10 Nil Negligibl [●]
by way of gift to e
Rajendrakumar S.
shah
June 12, 2013 Transfer of shares (800) Gift 10 Nil (0.01) [●]
by way of gift to
Deepak H.
Devanani
July 27, 2017# Transfer of shares (1,500) Transfer 10 N.A. (0.01) [●]
to Luv Vikram
Kothari
July 27, 2017 Transfer of shares (1,500) Gift 10 Nil (0.01) [●]
by way of gift to
Tanmay U. Shah
& Purnima U.
Shah*
July 27, 2017 Transfer of shares (1,500) Gift 10 Nil (0.01) [●]
by way of gift to
Ruchira Tanmay
Shah & Tanmay
Upendra Bhai
Shah*
July 27, 2017 Transfer of shares (1,500) Gift 10 Nil (0.01) [●]
by way of gift to
Preeti Upendra
Shah
July 27, 2017 Transfer of shares (1,500) Gift 10 Nil (0.01) [●]
by way of gift to
Trupti Utpal Shah
July 27, 2017# Transfer of shares (1,500) Gift 10 Nil (0.01) [●]
by way of gift to
Utpal Praful Shah
November 21, Bonus issue in the 28,75,900 N.A. 10 Nil 18.26 [●]
2017 ratio of 1:1 (one
for every one
equity share held)
January 31, 2018 Transfer of shares 1,200 Transfer 10 10 0.01 [●]
from Bharatkumar
341Face Post-
value Pre-Issue Issue
Issue/transfe
Date of Number Nature of per equity equity
Nature of r price per
allotment/transfe of equity consideratio equit share share
transaction equity share
r shares n y capital capita
(in ₹)
share (in %) l (in
(in ₹) %)
Vallabhdas
Daftary
January 31, 2018# Transfer of shares 1,800 Transfer 10 N.A. 0.01 [●]
from Purnima
Ashok Kumar
Shah
February 01, Transfer of shares 600 Transfer 10 N.A. Negligibl [●]
2018# from N.A.$ e
February 01, 2018 Transfer of shares 400 Transfer 10 63 Negligibl [●]
from Nikita e
Bharatbhai
Chokshi
February 02, 2018 Transfer of shares 1,800 Transfer 10 N.A. 0.01 [●]
from Ranjan
Narendra Patva#
February 03, 2018 Transfer of shares 1,200 Transfer 10 N.A. 0.01 [●]
from Rupa Sunil
Shah#
February 06, 2018 Transfer of shares (3,000) Transfer 10 10 (0.02) [●]
to N.A.$
February 06, 2018 Transfer of shares (4,000) Transfer 10 10 (0.03) [●]
to Utpal Praful
Shah
February 17, 2021 Buy back of shares (2,01,800) Buyback 10 55 (1.28) [●]
by the Company
July 16, 2021 Transfer of shares (50,000) Gift 10 Nil (0.32) [●]
by way of gift to
Preeti Upendra
Shah
July 16, 2021 Transfer of shares (1,00,000 Gift 10 Nil (0.63) [●]
by way of gift to )
Ruchira Tanmay
Shah & Tanmay
Upendrabhai Shah
July 16, 2021 Transfer of shares (3,55,000 Gift 10 Nil (2.25) [●]
by way of gift to )
Tanmay U. Shah
& Purnima U.
Shah*
July 16, 2021 Transfer of shares (50,000) Gift 10 Nil (0.32) [●]
by way of gift to
Utpal Praful Shah
March 23, 2022 Transfer of shares (3,45,000 Gift 10 Nil (2.19) [●]
by way of gift to )
Tanmay U. Shah
& Purnima U.
Shah*
March 23, 2022 Transfer of shares (1,00,000 Gift 10 Nil (0.63) [●]
by way of gift to )
Ruchira Tanmay
Shah & Tanmay
Upendra Bhai
Shah*
March 23, 2022 Transfer of shares (50,000) Gift 10 Nil (0.32) [●]
by way of gift to
Utpal Praful Shah
March 23, 2022 Transfer of shares (50,000) Gift 10 Nil (0.32) [●]
by way of gift to
342Face Post-
value Pre-Issue Issue
Issue/transfe
Date of Number Nature of per equity equity
Nature of r price per
allotment/transfe of equity consideratio equit share share
transaction equity share
r shares n y capital capita
(in ₹)
share (in %) l (in
(in ₹) %)
Preeti Upendra
Shah
March 6, 2023 Transfer of shares (1,00,000 Gift 10 Nil (0.63) [●]
by way of gift to )
Tanmay U. Shah
& Purnima U.
Shah*
March 6, 2023 Transfer of shares (1,00,000 Gift 10 Nil (0.63) [●]
by way of gift to )
Preeti Upendra
Shah
March 6, 2023 Transfer of shares (1,00,000 Gift 10 Nil (0.63) [●]
by way of gift to )
Ruchira Tanmay
Shah & Tanmay
Upendra Bhai
Shah*
March 6, 2023 Transfer of shares (1,00,000 Gift 10 Nil (0.63) [●]
by way of gift to )
Utpal Praful Shah
March 6, 2023 Transfer of shares (1,00,000 Gift 10 Nil (0.63) [●]
by way of gift to )
Tanmay U. Shah
January 20, 2024 Transfer of shares (2,10,000 Gift 10 Nil (1.33) [●]
by way of gift to )
Tanmay U. Shah
& Purnima U.
Shah*
January 20, 2024 Transfer of shares (30,000) Gift 10 Nil (0.19) [●]
by way of gift to
Ruchira Tanmay
Shah & Tanmay
Upendra Bhai
Shah*
January 20, 2024 Transfer of shares (30,000) Gift 10 Nil (0.19) [●]
by way of gift to
Preeti Upendra
Shah
January 20, 2024 Transfer of shares (15,000) Gift 10 Nil (0.10) [●]
by way of gift to
Utpal Praful Shah
January 20, 2024 Transfer of shares (15,000) Gift 10 Nil (0.10) [●]
by way of gift to
Trupti Utpal Shah
February 21, 2024 Transfer of shares (3,50,000 Gift 10 Nil (2.22) [●]
by way of gift to )
Tanmay U. Shah
& Purnima U.
Shah*
February 21, 2024 Transfer of shares (50,000) Gift 10 Nil (0.32) [●]
by way of gift to
Ruchira Tanmay
Shah & Tanmay
Upendra Bhai
Shah*
February 21, 2024 Transfer of shares (50,000) Gift 10 Nil (0.32) [●]
by way of gift to
Preeti Upendra
Shah
343Face Post-
value Pre-Issue Issue
Issue/transfe
Date of Number Nature of per equity equity
Nature of r price per
allotment/transfe of equity consideratio equit share share
transaction equity share
r shares n y capital capita
(in ₹)
share (in %) l (in
(in ₹) %)
February 21, 2024 Transfer of shares (25,000) Gift 10 Nil (0.16) [●]
by way of gift to
Utpal Praful Shah
February 21, 2024 Transfer of shares (25,000) Gift 10 Nil (0.16) [●]
by way of gift to
Trupti Utpal Shah
July 24, 2024 Transfer of shares (75,000) Gift 10 Nil (0.48) [●]
by way of gift to
Trupti Utpal Shah
July 24, 2024 Transfer of shares (75,000) Gift 10 Nil (0.48) [●]
by way of gift to
Utpal Praful Shah
(A) Sub Total 30,00,000 19.04
Purnima Upendra Shah
October 12, 1994 Subscription to the 100 Cash 10 10 Negligibl [●]
Memorandum of e
Association
December 30, Further Issue 1,70,000 Cash 10 10 1.08 [●]
1994
November 01, Further Issue 42,800 Cash 10 10 0.27 [●]
1996
September 15, Transfer of shares 4,000 Cash 10 6 0.03 [●]
1997 from Vipul C
Desai &
Chandrakant A
Desai*
September 15, Transfer of shares 20,000 Cash 10 6 0.13 [●]
1997 from Chimanbhai
N Patel &
Shantaben C
Patel*
September 15, Transfer of shares 10,000 Cash 10 6 0.06 [●]
1997 from Vipul C
Desai &
Chandrakant A
Desai*
January 31, 1998 Transfer of shares 10,000 Cash 10 6 0.06 [●]
from Biharilal C
Patel & Mira
Kirankumar Patel
& Kirankumar
Biharilal Patel*
January 31, 1998 Transfer of shares 500 Cash 10 6 Negligibl [●]
from Pravinbhai J e
Patel
January 31, 1998 Transfer of shares 500 Cash 10 6 Negligibl [●]
from Dhiraj Patel e
& Chimanlal
Patel*
January 31, 1998 Transfer of shares 500 Cash 10 6 Negligibl [●]
from Savitrai D e
Patel &
Dhanjibhai R
Patel*
January 31, 1998 Transfer of shares 2,000 Cash 10 6 0.01 [●]
from Pravin D
Patel & Dhirajlal
Devrambhai Patel
344Face Post-
value Pre-Issue Issue
Issue/transfe
Date of Number Nature of per equity equity
Nature of r price per
allotment/transfe of equity consideratio equit share share
transaction equity share
r shares n y capital capita
(in ₹)
share (in %) l (in
(in ₹) %)
September 17, Transfer of shares 5,000 Cash 10 6 0.03 [●]
1998 from Maltiben R
Patwa & Kantilal
Nagjibhai Patel*
September 17, Transfer of shares 5,000 Cash 10 6 0.03 [●]
1998 from Siddharth M
Mehta & Sunil M
Mehta
September 17, Transfer of shares 5,500 Cash 10 6 0.03 [●]
1998 from Prabhakur S
Khamar & Dilip S
Khamar*
September 17, Transfer of shares 15,000 Transfer 10 N.A. 0.10 [●]
1998# from Rajesh R
Punjabi &
Sandhya R
Punjabi *
May 15, 1999 Transfer of shares 10,000 Cash 10 10 0.06 [●]
from Chimanbhai
N Patel &
Shantaben C
Patel*
October 31, 1999 Further Issue 37,000 Cash 10 10 0.23 [●]
Ausgust 01, 2000 Further Issue 93,400 Cash 10 10 0.59 [●]
October 15, 2001 Transfer of shares 5,000 Cash 10 7 0.03 [●]
from Jitendra D.
Saraiya, Ushaben
J. Saraiya and
Nirav J. Saraiya*
October 15, 2001 Transfer of shares 500 Cash 10 7 Negligibl [●]
from Shefali e
Siddharth Mehta
and Siddharth
Mahendrakumar
Mehta*
October 15, 2001 Transfer of shares 1,000 Cash 10 7 0.01 [●]
from Ranjanaben
Saraiya and
Bharatkumar
Saraiya*
October 15, 2001 Transfer of shares 1,000 Cash 10 7 0.01 [●]
from Bharatkumar
Saraiya and
Ranjanaben
Saraiya*
October 15, 2001 Transfer of shares 12,000 Cash 10 7 0.08 [●]
from Trishla
Bhimani and
Sandhya R.
Punjabi*
October 15, 2001 Transfer of shares 500 Cash 10 7 Negligibl [●]
from Raju e
Shankerlal Thakor
October 15, 2001 Transfer of shares 500 Cash 10 7 Negligibl [●]
from Kusum e
Arvind Modi and
Arvind Chimanlal
Modi*
345Face Post-
value Pre-Issue Issue
Issue/transfe
Date of Number Nature of per equity equity
Nature of r price per
allotment/transfe of equity consideratio equit share share
transaction equity share
r shares n y capital capita
(in ₹)
share (in %) l (in
(in ₹) %)
October 15, 2001 Transfer of shares 500 Cash 10 7 Negligibl [●]
from Kashinath e
Rambhau Borhade
and Shobha
Kashinath
Borhade*
October 15, 2001 Transfer of shares 2,500 Cash 10 7 0.02 [●]
from Shobha
Kashinath
Borhade and
Kashinath Shobha
Borhade*
February 11, 2002 Transfer of shares 2,000 Cash 10 7.5 0.01 [●]
from Ajitkumar
M. Sheth and
Bhavna A. Sheth*
March 16, 2002 Transfer of shares 6,000 Cash 10 10 0.04 [●]
from Trikamlal F.
Shah and Purnima
Upendra Shah*
March 16, 2002 Transfer of shares 13,500 Cash 10 10 0.09 [●]
from Trikamlal F.
Shah and Purnima
Upendra Shah*
March 16, 2002 Transfer of shares 3,000 Cash 10 10 0.02 [●]
from Trikamlal F.
Shah and Purnima
Upendra Shah*
July 1, 2002 Transfer of shares 1,000 Cash 10 8 0.01 [●]
from Hansaben
Narendrakumar
Joshi
July 1, 2002 Transfer of shares 1,000 Cash 10 8 0.01 [●]
from Janak
Narendrakumar
Joshi
July 1, 2002 Transfer of shares 500 Cash 10 8 Negligibl [●]
from Sanjay A. e
Mehta and Komal
S. Mehta*
July 1, 2002 Trasfer of shares 1,000 Cash 10 8 0.01 [●]
from Kamlesh J.
Shah and
Pushpaben K.
Shah*
July 1, 2002 Transfer of shares 1,000 Cash 10 8 0.01 [●]
from Harsha
Amrish Trivedi
and Amrish D.
Trivedi*
July 1, 2002 Transfer of shares 1,000 Cash 10 8 0.01 [●]
from Bharatbhai
Gopani
July 1, 2002 Transfer of shares 5,100 Cash 10 8 0.03 [●]
from Vijay B.
Shah and Saroj V.
Shah*
346Face Post-
value Pre-Issue Issue
Issue/transfe
Date of Number Nature of per equity equity
Nature of r price per
allotment/transfe of equity consideratio equit share share
transaction equity share
r shares n y capital capita
(in ₹)
share (in %) l (in
(in ₹) %)
July 1, 2002 Transfer of shares 1,000 Cash 10 8 0.01 [●]
from Induben
Gopani
July 31, 2002 Transfer of shares 1,000 Cash 10 8 0.01 [●]
from Manjula N.
Shah and
Navinchandra V.
Shah*
July 31, 2002 Transfer of shares 500 Cash 10 8 Negligibl [●]
from Nikunj Desai e
and Dipti Desai*
July 31, 2002 Transfer of shares 10,000 Cash 10 10 0.06 [●]
from Hitendra M.
Patel and
Manubhai P.
Patel*
September 15, Further Issue 5,00,000 Cash 10 10 3.17 [●]
2005
November 01, Bonus issue in the 10,02,400 N.A. 10 N.A. 6.36 [●]
2007 ratio of 1:1 (one
for every one
equity share held)
March 19, 2013 Transfer of shares 600 Cash 10 75 Negligibl [●]
from Siddharth e
Shantilal Dikshit
and Sheela
Shantilal Dikshit*
March 21, 2013 Transfer of shares (600) Gift 10 Nil Negligibl [●]
by way of gift to e
Kesnisha Shah
November 21, Bonus issue in the 20,04,800 N.A. 10 N.A. 12.73 [●]
2017 ratio of 1:1 (one
for every one
equity share held)
February 17, 2021 Buy-back of (2,09,600 Buy-back 10 55 (1.33) [●]
shares by the )
Company
January 20, 2024 Transfer of shares (1,40,000 Gift 10 Nil (0.89) [●]
by way of gift to )
Tanmay Upendra
Shah & Purnima
Upendra Shah*
January 20, 2024 Transfer of shares (20,000) Gift 10 Nil (0.13) [●]
by way of gift to
Ruchira Tanmay
Shah Tanmay
Upendra Bhai
Shah
January 20, 2024 Transfer of shares (20,000) Gift 10 Nil (0.13) [●]
by way of gift to
Preeti Upendra
Shah
January 20, 2024 Transfer of shares (10,000) Gift 10 Nil (0.06) [●]
by way of gift to
Utpal Praful Shah
January 20, 2024 Transfer of shares (10,000) Gift 10 Nil (0.06) [●]
by way of gift to
Trupti Utpal Shah
347Face Post-
value Pre-Issue Issue
Issue/transfe
Date of Number Nature of per equity equity
Nature of r price per
allotment/transfe of equity consideratio equit share share
transaction equity share
r shares n y capital capita
(in ₹)
share (in %) l (in
(in ₹) %)
July 24, 2024 Transfer of shares (75,000) Gift 10 Nil (0.48)
by way of gift to
Utpal Praful Shah
July 24, 2024 Transfer of shares (75,000) Gift 10 Nil (0.48) [●]
by way of gift to
Trupti Utpal Shah
(B) Sub Total 34,50,000 21.90 [●]
Tanmay Upendra Shah
May 15, 1999 Transfer of shares 15,600 Cash 10 10 0.10 [●]
from Tanmay Real
Estate and Finance
Limited
October 31, 1999 Further Issue 19,000 Cash 10 10 0.12 [●]
August 01, 2000 Further Issue 28,000 Cash 10 10 0.18 [●]
October 15, 2001 Transfer of shares 5,000 Cash 10 7 0.03 [●]
from Hasmukh M.
Shah and
Minaxiben H.
Shah*
October 15, 2001 Transfer of shares 5,000 Cash 10 7 0.03 [●]
from Sanjay B.
Bhimani and
Trishala S.
Bhimani*
February 11, 2001 Transfer of shares 2,000 Cash 10 7.5 0.01 [●]
from Lalit A
Parikh and
Shyama L.
Parikh*
March 16, 2002 Transfer of shares 300 Cash 10 10 Negligibl [●]
from Tej Kishen e
Kachra and
Urmila Kachra*
March 16, 2002 Transfer of shares 500 Cash 10 10 Negligibl [●]
from Rohitkumar e
Chimanbhai Shah
and Mihir
Rohitkumar Shah*
June 24, 2002 Sonal N. Shah and 23,000 Cash 10 8 0.15 [●]
Purnima Upendra
Shah*
December 30, Transfer of shares 500 Cash 10 6 Negligibl [●]
2002 from Bhagubhai e
Mathurdas Patel
and Nileshkumar
Bhagubhai Patel
and Kalpanaben
Bhagubhai Patel*
December 30, Transfer of shares 1,000 Cash 10 6 0.01 [●]
2002 from
Shobhanaben A.
Vaghela and
Arjunsinh P.
Vaghela*
December 30, Transfer of shares 5,000 Cash 10 6 0.03 [●]
2002 from Rajiben M.
Patel and
Madhavlal S.
Patel*
348Face Post-
value Pre-Issue Issue
Issue/transfe
Date of Number Nature of per equity equity
Nature of r price per
allotment/transfe of equity consideratio equit share share
transaction equity share
r shares n y capital capita
(in ₹)
share (in %) l (in
(in ₹) %)
December 30, Transfer of shares 5,000 Cash 10 6 0.03 [●]
2002 from Madhavlal S.
patel and Rajiben
M. Patel*
December 30, Transfer of shares 5,000 Cash 10 6 0.03 [●]
2002 from Ratna R.
Parmar and Rajesh
J. Parmar*
December 30, Transfer of shares 46,700 Transfer 10 N.A. 0.30 [●]
2002# from Vimlaben T.
Shah
December 30, Transfer of shares 49,600 Transfer 10 N.A. 0.31 [●]
2002# from Trikamlal F.
Shah
April 30, 2003 Transfer of shares 1,000 Cash 10 8 0.01 [●]
from Krupa
Ashwin Patel and
Ashwin Govindlal
Patel*
April 30, 2003 Transfer of shares 1,000 Cash 10 8 0.01 [●]
from Ashwin
Govindlal Patel
and Krupa Ashwin
Patel*
April 30, 2003 Transfer of shares 1,000 Cash 10 8 0.01 [●]
from Ashwin
Govindlal Patel
and Krupa Ashwin
Patel*
April 30, 2003 Transfer of shares 1,000 Cash 10 8 0.01 [●]
from Ashwin
Govindlal Patel
and Krupa Ashwin
Patel*
April 30, 2003 Transfer of shares 1,000 Cash 10 8 0.01 [●]
from Ashwin
Govindlal Patel
and Krupa Ashwin
Patel*
April 30, 2003 Transfer of shares 5,000 Cash 10 8 0.03 [●]
from Ashwin
Govindlal Patel
and Krupa Ashwin
Patel*
April 30, 2003 Transfer of shares 500 Cash 10 8 Negligibl [●]
from Jayshree e
Vikram Shah &
Vikram C. Shah*
April 30, 2003 Transfer of shares 500 Cash 10 8 Negligibl [●]
from Sudhirkumar e
C. Shah &
Jayshree Sudhir
Shah*
April 30, 2003 Transfer of shares 500 Cash 10 8 Negligibl [●]
from Jayshree e
Sudhir shah &
Sudhir Chinubhai
Shah*
349Face Post-
value Pre-Issue Issue
Issue/transfe
Date of Number Nature of per equity equity
Nature of r price per
allotment/transfe of equity consideratio equit share share
transaction equity share
r shares n y capital capita
(in ₹)
share (in %) l (in
(in ₹) %)
April 30, 2003 Transfer of shares 500 Cash 10 8 Negligibl [●]
from Vikram C. e
Shah & Jayshree
V Shah*
April 30, 2003 Transfer of shares 1,000 Cash 10 8 0.01 [●]
from Dipti V. Shah
& Nirmalaben V.
Shah*
April 30, 2003 Transfer of shares 1,000 Cash 10 8 0.01 [●]
from Priti C. shah
& Nirmalaben
Vinodchandra
Shah*
April 30, 2003 Transfer of shares 2,000 Cash 10 8 0.01 [●]
from Chirag V.
Shah*
September 15, Further Issue 60,000 Cash 10 10 0.38 [●]
2005
November 01, Bonus issue in the 2,87,200 N.A. 10 Nil 1.82 [●]
2007 ratio of 1:1 (one
for every one
equity share held)
July 27, 2017 Transfer of shares 1,500 Gift 10 Nil 0.01 [●]
by way of gift
from Upendra
Trikamlal Shah
November 21, Bonus issue in the 5,75,900 N.A. 10 N.A. 3.66 [●]
2017 ratio of 1:1 (one
for every one
equity share held)
February 17, 2021 Buy-back of (1,46,800 Buy-back 10 55 (0.93) [●]
shares by the )
Company
July 16, 2021 Transfer of shares 3,55,000 Gift 10 Nil 2.25 [●]
by way of gift
from Upendra
Trikamlal Shah
March 23, 2022 Transfer of shares 3,45,000 Gift 10 Nil 2.19 [●]
by way of gift
from Upendra
Trikamlal Shah
March 06, 2023 Transfer of shares 1,00,000 Gift 10 Nil 0.63 [●]
by way of gift
from Upendra
Trikamlal Shah
January 20, 2024 Transfer of shares 1,40,000 Gift 10 Nil 1.33 [●]
by way of gift
from Purnima
Upendra Shah
January 20, 2024 Transfer of shares 2,10,000 Gift 10 Nil 0.89 [●]
by way of gift
from Upendra
Trikamlal Shah
February 21, 2024 Transfer of shares 3,50,000 Gift 10 Nil 2.22 [●]
by way of gift
from Upendra
Trikamlal Shah
(C) Sub Total 25,05,000 15.90
Trupti Utpal Shah
350Face Post-
value Pre-Issue Issue
Issue/transfe
Date of Number Nature of per equity equity
Nature of r price per
allotment/transfe of equity consideratio equit share share
transaction equity share
r shares n y capital capita
(in ₹)
share (in %) l (in
(in ₹) %)
December 30, Further Issue 40,000 Cash 10 10 0.25 [●]
1994
November 01, Further Issue 50,900 Cash 10 10 0.32 [●]
1996
September 17, Transfer of shares 5,300 N.A. 10 N.A. 0.03 [●]
1998# from Sandhya R
Punjabi & Rajesh
R Punjabi*
September 17, Transfer of shares 700 N.A. 10 N.A. Negligibl [●]
1998# from Upendra T e
shah & Purnima
Shah*
October 31, 1999 Further Issue 29,500 Cash 10 10 0.19 [●]
August 01, 2000 Further Issue 13,000 Cash 10 10 0.08 [●]
April 30, 2003 Transfer of shares 1,000 Cash 10 8 0.01 [●]
from Gargi R.
Patel &
Rameshchandra
D. Patel*
April 30, 2003 Transfer of shares 1,000 Cash 10 8 0.01 [●]
from Kapila R.
Patel &
Rameshchandra
D. Patel
April 30, 2003 Transfer of shares 1,000 Cash 10 8 0.01 [●]
from Jigar R Patel
& Rameshchandra
D. Patel*
April 30, 2003 Transfer of shares 2,000 Cash 10 8 0.01 [●]
from Ramesh D.
Patel & Kapilaben
Rameshchandra
Patel*
April 30, 2003 Transfer of shares 600 Cash 10 8 Negligibl [●]
from Tarunaben e
Shantilal Lodha*
April 30, 2003 Transfer of shares 400 Cash 10 8 Negligibl [●]
from Ketan e
Arvindbhai
Nanavati &
Falguni Ketan
Nanavati*
April 30, 2003 Transfer of shares 6,000 Cash 10 8 0.04 [●]
from Gauriben P.
Shah & Utpal
Shah*
April 30, 2003 Transfer of shares 4,000 Cash 10 8 0.03 [●]
from Rupal Pritish
Shah & Pritish
Prafulbhai Shah*
September Further Issue 80,000 Cash 10 10 0.51 [●]
15, 2005
November 01, Bonus issue in the 2,30,900 N.A. 10 N.A. 1.47 [●]
2007 ratio of 1:1 (one
for every one
equity share held)
March 31, 2008 Transfer of shares (4,500) Cash 10 10 (0.03) [●]
to Ruchira
Tanmay Shah
351Face Post-
value Pre-Issue Issue
Issue/transfe
Date of Number Nature of per equity equity
Nature of r price per
allotment/transfe of equity consideratio equit share share
transaction equity share
r shares n y capital capita
(in ₹)
share (in %) l (in
(in ₹) %)
March 31, 2008 Transfer of shares (81,000) Cash 10 10 (0.51) [●]
to Ruchira
Tanmay shah
May 10, 2013 Buy-back of (1,50,000 Buy-back 10 50 (0.95) [●]
shares by the )
Company
July 27, 2017 Transfer of shares 1,500 Gift 10 Nil 0.01 [●]
by way of gift by
Upendra T Shah &
Purnima Upendra
Shah*
November 21, Bonus issue in the 2,32,300 N.A. 10 Nil 1.47 [●]
2017 ratio of 1:1 (one
for every one
equity share held)
February 17, 2021 Buy-back of share (14,600) Buy-back 10 55 (0.09) [●]
by the Company
January 20, 2024 Transfer of shares 15,000 Gift 10 Nil 0.10 [●]
by way of gift by
Upendra T. Shah
& Purnima
Upendra Shah*
January 20, 2024 Transfer of shares 10,000 Gift 10 Nil 0.06 [●]
by way of gift by
Purnima Upendra
Shah & Upendra
T. Shah*
February 21, 2024 Transfer of shares 25,000 Gift 10 Nil 0.16 [●]
by way of gift by
Upendra T. Shah
July 24, 2024 Transfer of shares 75,000 Gift 10 Nil 0.48 [●]
by way of gift by
Upendra T. Shah
& Purnima
Upendra Shah*
July 24, 2024 Transfer of shares 75,000 Gift 10 Nil 0.48 [●]
by way of gift by
Purnima Upendra
Shah & Upendra
T. Shah*
(D) Sub-Total 6,50,000 4.13 [●]
TOTAL 96,05,000 60.97 [●]
(A+B+C+D)
*The shares are held jointly by the shareholders. The names of the transferor, transferee, and the transfer price per equity share is as per the
details available from the stock broker’s Delivery Instruction Slip (DIS), SH-4 (share transfer from under companies act, 2013), and Form-
7B (share transfer from under companies act,1956). Except the transaction with#
#The DIS/SH-4/Form-7B could not be traced, we have referred to the list of transfers attached to the annual return filed by the company
with the Registrar of Companies (ROC), along with the Demat transaction statements, to identify the transferor and transferee names and
their Client-IDs. However, due to the unavailability of transfer price information in annual return/ Demat transaction statements, the
transfer price for these transactions could not be determined and has therefore been reported as NIL.
$ The name of the transferor could not be identified as the relevant DIS/SH-4/Form-7B for the said transactions are not available; however,
the Client ID has been identified from the demat transaction statement.
All Equity Shares held by our Promoters were fully paid-up on the respective dates of allotment of such Equity
Shares.
As on the date of this Draft Red Herring Prospectus, none of the Equity Shares held by our Promoters are
subject to any pledge or otherwise encumbered.
352Further, all the Equity Shares held by our Promoters are held in dematerialized form prior to the filing of this
Draft Red Herring Prospectus.
Details of Promoters’ Contribution and Lock-in
Pursuant to regulations 14 and 16 of the SEBI ICDR Regulations, an aggregate of at least 20% of the fully diluted
post- Issue Equity Share capital of our Company held by the Promoters shall be locked in for a period of eighteen
months as minimum Promoters’ contribution (“Minimum Promoters’ Contribution”) from the date of Allotment.
Our Promoters’ shareholding in excess of the Minimum Promoters’ Contribution shall be locked in for a period
of six months from the date of Allotment.
The Promoters have given consent to include such number of Equity Shares held by them and as disclosed in the
table mentioned below, in aggregate, as may constitute 20% of the fully diluted post- Issue Equity Share capital
of our Company, as Minimum Promoters’ Contribution.
a) Set forth below are the details of Equity Shares that will be locked-in for eighteen months as Minimum Promoters’
Contribution from the date of Allotment*:
Name of Number Number Date of Face Allotment Nature of Date up % of fully
the of Equity of Equity allotment value per / Transacti to which diluted
Promoter Shares Shares of Equity Equity Acquisitio on the post-
held locked-in Shares/ Share (₹) n price Equity Issue
Transfer per Shares paid-up
of Equity Equity are capital*#
Shares Share (₹) subject to
and when lock-in
made
Fully
Paid-up /
Transfer
[●] [●] [●] [●] [●] [●] [●] [●] [●]
[●] [●] [●] [●] [●] [●] [●] [●] [●]
[●] [●] [●] [●] [●] [●] [●] [●] [●]
Total [●] [●] [●] [●] [●] [●] [●] [●]
Notes To be updated at the Prospectus stage.
* Subject to finalisation of the Basis of Allotment.
#Equity shares were fully paid-up on the date of allotment/acquisition
b) Our Promoters have agreed not to dispose of, sell, transfer, charge, pledge or otherwise encumber in any manner,
the Minimum Promoter’s Contribution from the date of filing of this Draft Red Herring Prospectus, until the
expiry of the lock-in period specified above, or for such other time as required under SEBI ICDR Regulations,
except as may be permitted, in accordance with the SEBI ICDR Regulations.
c) Our Company undertakes that the Equity Shares that are being locked-in are not and will not be, ineligible for
computation of Minimum Promoters’ contribution in terms of regulation 15 of the SEBI ICDR Regulations. In
this connection, we confirm the following:
i. The Equity Shares offered for Minimum Promoters’ Contribution do not include Equity Shares acquired during
the three years immediately preceding the date of filing of this Draft Red Herring Prospectus (a) for consideration
other than cash and revaluation of assets or capitalisation of intangible assets involved in such transactions; or (b)
which have resulted from bonus issue by utilisation of revaluation reserves or unrealised profits of our Company
or from bonus issue against Equity Shares which are otherwise ineligible for computation of Minimum Promoters’
Contribution;
ii. The Minimum Promoters’ Contribution does not include any Equity Shares acquired during the one year
immediately preceding the date of filing of this Draft Red Herring Prospectus, at a price lower than the price at
which the Equity Shares are being offered to the public in the Issue;
iii. Our Company has not been formed by conversion of one or more partnership firms or limited liability partnership
firm and there is no change in management;
353iv. The Equity Shares forming part of the Minimum Promoters’ Contribution are not pledged or are not subject to
any other encumbrance.
v. All the Equity Shares held by the members of our Promoter Group are in dematerialised form.
Other requirements in respect of lock-in
i. In addition to the Minimum Promoters’ Contribution and the Promoters’ Six months Lock-in as specified above,
the entire pre-Issue Equity Share capital of our Company will be locked in for a period of six months from the
date of Allotment pursuant to Regulation 17 of the SEBI ICDR Regulations, except for (i) the Equity Shares
Allotted pursuant to the Issue; and (ii) the Equity Shares held by VCFs, Category I or II AIFs or FVCIs, subject
to certain conditions set out in Regulation 17 of the SEBI ICDR Regulations, provided that such Equity Shares
will be locked-in for a period of at least 6 (six) months from the date of purchase by the VCF or Category I or II
AIF or FVCI.
ii. As required under Regulation 20 of the SEBI ICDR Regulations, our Company shall ensure that the details of the
Equity Shares being locked-in shall be recorded by the relevant Depository.
iii. Pursuant to regulation 21 of the SEBI ICDR Regulations, the locked-in Equity Shares held by our Promoters (as
mentioned above) may be pledged as a collateral security for a loan granted by a scheduled commercial bank or
a public financial institution or a systemically important non-banking finance company or a housing finance
company, subject to the following:
a) If the Equity Shares are locked-in in terms of sub-regulation (a) of Regulation 16(1) of the SEBI ICDR
Regulations, the loan has been granted for the purpose of financing one or more of the objects of the Issue
and the pledge of Equity Shares is one of the terms of sanction of the loan;
b) If the Equity Shares are locked-in in terms of sub-regulation (b) of Regulation 16(1) of the SEBI ICDR
Regulations and the pledge of Equity Shares is one of the terms of sanction of the loan.
However, the relevant lock-in period shall continue post the invocation of the pledge referenced above, and the
relevant transferee shall not be eligible to transfer the Equity Shares till the relevant lock-in period has expired in
terms of the SEBI ICDR Regulations.
iv. Pursuant to regulation 22 of the SEBI ICDR Regulations, the Equity Shares held by our Promoters and locked-in,
may be transferred to another Promoter or any person of our Promoter Group or to a new promoter or person in
control of the Issuer, subject to continuation of lock-in in the hands of transferees for the remaining period and
compliance of SEBI Takeover Regulations, as applicable.
v. Further, in terms of regulation 22 of the SEBI ICDR Regulations, the Equity Shares held by persons other than
our Promoters prior to the Issue and locked-in for a period of six (6) months, may be transferred to any other
person holding Equity Shares which are locked-in along with the Equity Shares proposed to be transferred, subject
to continuation of the lock-in in the hands of the transferee for the remaining period and compliance with the SEBI
Takeover Regulations, as applicable.
vi. Any Equity Shares Allotted to Anchor Investors in the Anchor Investor Portion shall be locked in the following
manner: there shall be a lock-in of 90 days on 50% of the Equity Shares Allotted to each of the Anchor Investors
from the date of Allotment, and a lock-in of 30 days on the remaining 50% of the Equity Shares Allotted to each
of the Anchor Investors from the date of Allotment.
11. There is no proposal or intention, negotiations and consideration of our Company to alter its capital structure,
within a period of six months from the Bid/Issue Opening Date, by way of split or consolidation of the
denomination of Equity Shares, or issue of specified securities on a preferential basis or issue of bonus or rights
or by way of further public offer of Equity Shares (including issue of securities convertible into or exchangeable
for, directly or indirectly into Equity Shares). However, if our Company enters into acquisitions, joint ventures or
other arrangements, our Company may, subject to necessary approvals, consider raising additional capital to fund
such activity or use Equity Shares as consideration for acquisitions or participation in such joint ventures or other
arrangements.
35412. There will be no further issue of Equity Shares whether by way of issue of bonus shares, preferential allotment,
rights issue or in any other manner during the period commencing from the date of filing of this Draft Red Herring
Prospectus with SEBI until the Equity Shares have been listed on the Stock Exchanges pursuant to the Issue or
refund of application monies in the event there is failure of the Issue.
13. All Equity Shares issued pursuant to the Issue shall be fully paid-up at the time of Allotment and there are no
partly paid-up Equity Shares as on the date of this Draft Red Herring Prospectus.
14. As on the date of this Draft Red Herring Prospectus, the BRLM or its associates (as defined under the SEBI
Merchant Bankers Regulations), do not hold any Equity Shares of our Company. However, the BRLM and its
associates may engage in the transactions with and perform services for our Company in the ordinary course of
business or may in the future engage in commercial banking and investment banking transactions with our
Company for which they may in the future receive customary compensation.
15. As on the date of this Draft Red Herring Prospectus, the Company does not have any shareholders entitled with
right to nominate Directors or any other rights.
16. Except as disclosed in the sections titled “Capital Structure - Build-up of our Promoters’ equity shareholding in
our Company” and “Capital Structure - Details of shareholding of our Promoters, members of the Promoter
Group, Directors, Key Managerial Personnel and Senior Managerial Personnel in our Company” on pages 285
and 494, respectively, none of our Promoters, the members of our Promoter Group, directors of our Corporate
Promoter, our Directors, or any of their relatives has purchased or sold any securities of our Company during the
period of six months immediately preceding the date of this Draft Red Herring Prospectus.
17. There have been no financing arrangements whereby our Directors or their respective relatives have financed the
purchase by any other person of securities of our Company other than in the normal course of business of the
financing entity, during the six months immediately preceding the date of this Draft Red Herring Prospectus.
18. Our Company shall ensure that all transactions in the Equity Shares by our Promoters and the members of our
Promoter Group during the period between the date of filing of this Draft Red Herring Prospectus with SEBI and
the date of closure of the Issue shall be reported to the Stock Exchanges within twenty-four hours of such
transactions.
19. Our Company, Directors and the Book Running Lead Manager have not entered into any buy-back arrangements
for the purchase of Equity Shares or specified securities of our Company being offered through the Issue.
20. Our Company has no outstanding convertible securities, warrants, options to be issued or rights to convert
debentures, loans or other convertible instruments into, or which would entitle any person any option to receive
Equity Shares of our Company, as on the date of this Draft Red Herring Prospectus.
21. There shall be only one denomination of the Equity Shares, unless otherwise permitted by law. Our Company will
comply with such disclosure and accounting norms as may be specified by SEBI from time to time.
22. No person connected with the Issue, including, but not limited to, the Book Running Lead Manager, the members
of the Syndicate, our Company, our Directors, our Promoters, members of our Promoter Group, shall offer any
incentive, whether direct or indirect, in any manner, whether in cash or kind or services or otherwise to any Bidder
for making a Bid, except for fees or commission for services rendered in relation to the Issue.
23. The BRLM and any associates of the BRLM (except for Mutual Funds sponsored by entities which are associates
of the BRLM or insurance companies promoted by entities which are associates of the BRLM or AIFs which are
sponsored by entities that are associates of the BRLM or FPIs (other than individuals, corporate bodies and family
offices) which are associates of the BRLM or pension funds sponsored by entities which are associate of the
BRLM) shall not apply in the Issue under the Anchor Investor Portion. Further, no person related to our Promoter
or members of our Promoter Group shall apply in the Issue under the Anchor Investor Portion.
24. None of our Promoters or members of our Promoter Group will participate in the Issue
35525. Except as disclosed in this section, our Company has not undertaken any public issue of securities or any rights
issue of any kind or class of securities in terms of SEBI ICDR Regulations, since its incorporation.
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356OBJECTS OF THE ISSUE
The Issue comprises a Fresh Issue of up to 54,00,000 Equity Shares for cash at a price of ₹ [●] per Equity Share
(including a premium of ₹ [●] per Equity Share) aggregating up to ₹ [●] lakhs by our Company.
Utilisation of Net Proceeds
Our Company proposes to utilise the Net Proceeds from the Issue towards the following objects:
1. Funding working capital requirements of our Company; and
2. General corporate purposes.
(Collectively, referred to herein as ‘Objects’)
In addition, our Company expects to receive the benefits of listing of Equity Shares on the Stock Exchanges
including enhancing our Company’s visibility and brand image and creating a public market for our Company’s
Equity Shares in India.
The main objects and objects incidental and ancillary to the main objects, as set out in our Company’s
Memorandum of Association, enable our Company to undertake our existing business activities and the activities
proposed to be funded from the Net Proceeds.
Net Proceeds
The details of the proceeds from the Issue are set forth in the table below:
Particulars Estimated amount (in ₹ lakhs)
Gross proceeds from the Issue [●]*
(Less) Issue related expenses in relation to the Issue [●]
Net Proceeds [●]*
* To be finalised upon determination of the Issue Price and updated in the Prospectus prior to filing with the RoC.
Requirement of funds and utilisation of Net Proceeds
The Net Proceeds are proposed to be utilised for the Objects in accordance with the details provided in the
following table:
Sr. Particulars Estimated utilisation from Net % of Gross Issue Proceeds
No. Proceeds (in ₹ lakhs)
1. Funding working capital 7,000.00 [●]
requirements of our Company
2. General corporate purposes^ [●] [●]
Net Proceeds [●] [●]
^ To be finalised upon determination of the Issue Price and updated in the Prospectus prior to filing with the RoC. The amount
utilised for general corporate purposes shall not exceed 25% of the Gross Proceeds.
Proposed schedule of implementation and deployment of Net Proceeds
The following table sets forth the details of the schedule of the expected deployment of the Net Proceeds:
(In ₹ lakhs)
Sr. Particulars Amount to be Estimated Estimated
No. funded from the deployment (in deployment (in
Net Proceeds Fiscal 2026) Fiscal 2027)
1. Funding working capital requirements of our 7,000.00 3,000.00 4,000.00
Company
2. General corporate purposes (1) [●] [●] [●]
Net Proceeds [●] [●] [●]
(1) To be finalised upon determination of the Issue Price and updated in the Prospectus prior to filing with the RoC. The amount utilised for
general corporate purposes shall not exceed 25% of the Gross Proceeds.
The fund requirements, the deployment of funds and the intended use of the Net Proceeds as described herein are
based on our Company’s current business plan, management estimates, prevailing market conditions and other
357commercial and technical factors. However, such fund requirements and deployment of funds have not been
appraised by any bank, or financial institution. See “Risk Factor - Objects of the Issue for which the funds are
being raised have not been appraised by any bank or financial institutions. Any variation in the utilization of our
Net Proceeds as disclosed in this Draft Red Herring Prospectus would be subject to certain compliance
requirements, including prior Shareholders’ approval” on page 70. Our Company may have to revise its funding
requirements and deployment on account of a variety of factors such as financial and market conditions, macro-
economic factors, change in government policy, changes in business and strategy, competition, and other external
factors such as changes in the business environment and interest or exchange rate fluctuations, which may not be
within the control of our Company’s management. This may entail rescheduling or revising the planned
expenditure and funding requirements, including the expenditure for a particular purpose at the discretion of our
Company’s management, subject to compliance with applicable laws.
If the estimated utilisation of the Net Proceeds in a scheduled fiscal year is not completely met, such unutilised
amounts shall be utilised (in part or full) in the next fiscal year, as may be determined by our Company, in
accordance with applicable laws. We may, however, utilize the proceeds prior to the specific periods mentioned
in the schedule of deployment, in accordance with the requirements of our Company. Subject to applicable laws,
in the event of any increase in the actual utilization of funds earmarked for the purposes set forth above, such
additional funds for a particular activity will be met by way of funding means available to us, including from
internal accruals and any additional equity and/or debt arrangements. Further, if the actual utilisation towards any
of the Objects is lower than the proposed deployment such balance will be used towards general corporate
purposes, provided that the total amount to be utilised towards general corporate purposes will not exceed 25% of
the Gross Proceeds in accordance with Regulation 7(2) of the SEBI ICDR Regulations.
Means of finance
Our Company proposes to fund the requirements of the entire Objects of the Issue from the Net Proceeds,
borrowings and internal accruals. The Net Proceeds will not be utilised for financing a particular Project,
accordingly, there is no requirement to make firm arrangements of finance through verifiable means towards at
least 75% of the stated means of finance, excluding the amount to be raised from the Fresh Issue and existing
identifiable internal accruals, as required under Regulation 7(1)(e) of the SEBI ICDR Regulations.
Details of objects of the Issue
Our Board at its meeting held on September 29, 2025, approved the proposed Objects and the respective amounts
proposed to be utilized from the Net Proceeds for each Object.
1. Funding working capital requirements of our Company
We are an established full-service brokerage house in India with over 30 years of experience. We provide broking
services, margin trading facility and distribution of financial products to a diverse set of clients across retail and
high net worth individuals. Our investment offerings span across a wide array of asset classes like equity,
derivatives, commodities, and currency markets. Our Company funds a majority of its working capital
requirements in the ordinary course of business from banks, financial institutions and internal accruals. As on
August 31, 2025, our Company had sanctioned working capital facilities on standalone basis aggregating to ₹
23,098.82 lakhs comprising ₹ 11,500.00 lakhs of fund-based limits, ₹ 11,500.00 lakhs of non-fund based limits
and ₹ 98.82 lakhs of unsecured borrowings. For further details, see ‘Financial Indebtedness’ on page 612.
We propose to utilise ₹ 7,000.00 lakhs from the Net Proceeds to fund the working capital requirements of our
Company in Fiscal 2026 and Fiscal 2027. The Board pursuant to their resolution dated September 29, 2025 have
approved the business plan and financial projections for the Fiscal 2026 and Fiscal 2027 and the estimated working
capital requirements and funding pattern for the respective financial years. The details of our Company’s working
capital as at March 31, 2023, March 31, 2024 and March 31, 2025 derived from the restated standalone financial
statements of our Company, and source of funding of the same are provided in the table below:
(₹ in lakhs)
Particulars As at March 31, 2025 As at March 31, 2024 As at March 31, 2023
Current assets
Trade receivables 1684.29 752.92 1074.84
Cash and cash equivalents 8,012.48 12,691.32 2,613.89
Other Balances with Banks 7,332.27 4,534.83 7,404.53
Loans (Including Margin Trading
965.07 1.25 5.09
Facility Book)
358Particulars As at March 31, 2025 As at March 31, 2024 As at March 31, 2023
Current tax assets (Net) 185.29 185.79 245.28
Other current non-financial assets 81.24 97.74 57.09
Total current assets (A) 18,260.64 18,263.85 11,400.72
Current liabilities
Trade payables 13,587.56 13,990.46 8,339.73
Other financial liabilities 1.60 1.49 2.02
Provisions 162.95 198.31 87.09
Other non-financial liabilities 66.74 111.01 55.31
Total current liabilities (B) 13,818.85 14,301.27 8,484.15
Net working capital (A-B) 4,441.79 3,962.58 2,916.57
Funding pattern
Borrowings & Internal accruals 4,441.79 3,962.58 2,916.57
As certified by the Independent Chartered Accountant, Dhrumil A. Shah & Co., Chartered Accountants (FRN: 145163W) by way of their
certificate dated September 29, 2025.
Estimated Working Capital Requirements
On the basis of our Company’s existing working capital requirements and the projected working capital
requirements, our Company’s Board of Directors has approved the projected working capital requirements of our
Company for Fiscal 2026 and Fiscal 2027 as stated below:
(₹ in lakhs)
Particulars As at March 31, 2027 As at March 31, 2026
Current assets
Trade receivables 3,030.85 2,261.00
Cash and cash equivalents 9,400.77 7,927.45
Other Balances with Banks 11,605.79 8,631.80
Loans (Including Margin Trading Facility
11,239.59 7,025.06
Book)
Current tax assets (Net) 416.40 280.89
Other current non-financial assets 232.79 147.79
Total current assets (A) 35,926.19 26,273.99
Current liabilities
Trade payables 18,094.47 15,819.70
Other financial liabilities 1.60 1.60
Provisions 358.14 295.57
Other non-financial liabilities 66.74 66.74
Total current liabilities (B) 18,520.95 16,183.61
Net working capital (A-B) 17,405.24 10,090.38
Funding pattern
Borrowings & Internal accruals 10,405.24 7,090.38
Proceeds from IPO 7,000.00* 3,000.00
Total 17,405.24 10,090.38
As certified by the Independent Chartered Accountant, Dhrumil A. Shah & Co., Chartered Accountants (FRN: 145163W) by way of their
certificate dated September 29, 2025.
*The balance is cumulative of funds to be utilised in the year ended March 31, 2026
Rationale for Working Capital Requirement from IPO Proceeds:
Our Company is an established full-service brokerage house providing a wide range of financial and investment
services including equity and derivatives broking, MTF, and distribution of financial products. As part of our
growth strategy, we intend to scale our operations and enhance client servicing capabilities, which necessitates
higher levels of working capital to support increased transaction volumes and client exposures, particularly under
our Margin Trading Facility (MTF) book. Given the capital-intensive nature of the broking business and the need
to maintain adequate liquidity to meet regulatory and client obligations, we propose to utilise ₹7,000.00 lakhs
from the Net Proceeds of the issue to fund our working capital requirements in Fiscal 2026 and Fiscal 2027. The
359infusion of IPO proceeds will enable us to improve operational flexibility, and support business expansion while
maintaining a strong liquidity profile.
Our Company’s working capital requirements are primarily utilised towards (a) margin trading facility (MTF) (b)
our trade receivables; and (c) other balances with banks. These are funds that are required for our day-to-day
operations and are critical for revenue generation, and consequently, are classified as working capital. These terms
are further elaborated below:
(a) Margin trading facility (MTF): In terms of the applicable SEBI regulatory framework, brokers are permitted
to provide margin trade facility to their clients in the cash segment. Our margin trading facility book in the year
ended March 31, 2025, was ₹ 964.22 lakhs. Further, interest income on margin trading facility for Fiscal 2025,
was ₹ 105.79 lakhs. Investors can invest their core capital in long-term investments while using MTF leverage for
trading.
b) Trade receivables: The trade receivables of our Company are primarily the amount due towards the positions
taken by the clients in the cash segment. Trade Receivables are cleared off based on the receipt of Funds from the
clients. The Company’s trade receivables increased from ₹ 1,074.84 lakhs as on March 31, 2023 to ₹ 1,684.29
lakhs as on March 31, 2025.
c) Other balances with banks: In terms of the requirement as per SEBI’s circular bearing reference number
SEBI/HO/MRD2_DCAP/CIR/2021/0598 dated July 20, 2021 read with SEBI’s Master Circular for Stock Brokers
bearing reference number SEBI/HO/MIRSD/MIRSD-PoD-1/P/CIR/2024/110 dated August 9, 2024 “CMs are
required to maintain at least 50% of the total collateral in the form of cash or cash equivalents. At individual
client level, a client may have allocation of cash equivalent, less than the value of non-cash collateral provided
by the client. In other words, the minimum 50% cash equivalent collateral requirement may not be applied at the
client level. For the purpose of monitoring of at least 50% cash equivalent collateral at the level of CM, the excess
cash-equivalent collateral of a client shall not be considered for other client or for proprietary account of TM/CM.
However, the excess cash-equivalent collateral of proprietary account of TM/CM can be considered for clients
trading/clearing through them, for the purpose of monitoring minimum 50% cash-equivalent requirement”, clients
are required to maintain a 50% cash margin (where there is sufficient non-cash collateral). Where the clients do
not maintain such margin, the funds of the broker i.e. our Company’s funds are blocked to such extent / lien is
created on such amounts, and in such an event, the Company issues bank guarantees (with Company’s fixed
deposits as underlying for such bank guarantees) in favor of stock exchanges/clearing corporations
The table below contains the details of the holding levels (in times or percentage of cash ADTO/ Total ADTO as
applicable) considered and is derived from the restated standalone financial statement of the Company for Fiscal
2023, Fiscal 2024 and Fiscal 2025, and the projected holding period for Fiscal 2026 and Fiscal 2027, and the
assumptions based on which the working capital requirements have been calculated:
Particulars Fiscal 2027 Fiscal 2026 Fiscal 2025 Fiscal 2024 Fiscal 2023 Basis for
(Estimated) (Estimated) (Actual) (Actual) (Actual) Calculation
Trade receivables Times of Cash
0.17 0.16 0.15 0.09 0.18
ADTO
Loans (Margin
Times of Cash
Trading Facility 0.62 0.50 0.09 0.00 0.00
ADTO
Book - MTF Book)
Cash and cash % of Total
25.98% 27.56% 33.56% 65.60% 15.81%
equivalents ADTO
Other Balances % of Total
32.07% 30.01% 30.71% 23.44% 44.78%
with Bank ADTO
Other current non- % of Total
0.64% 0.51% 0.34% 0.51% 0.35%
financial assets ADTO
Trade Payables % of Total
50.00% 55.00% 56.91% 72.32% 50.44%
ADTO
As certified by the Independent Chartered Accountant, Dhrumil A. Shah & Co., Chartered Accountants (FRN: 145163W) by way of their
certificate dated September 29, 2025
360For the year For the year For the year For the year For the year
ended March 31, ended March 31, ended March 31, ended March 31, ended March 31,
Particulars
2027 2026 2025 2024 2023
(Estimate) (Estimate) (Actual) (Actual) (Actual)
Cash ADTO
18,203.34 14,009.58 11,258.42 8,770.27 6,111.00
(in ₹ lakhs)
Total ADTO
36,188.94 28,763.09 23,874.31 19,346.47 16,533.55
(in ₹ lakhs)
As certified by the Independent Chartered Accountant, Dhrumil A. Shah & Co., Chartered Accountants (FRN: 145163W) by way of their
certificate dated September 29, 2025.
Our Company proposes to utilize ₹ 7,000.00 lakhs out of the Net Proceeds upto Fiscal 2027 towards our working
capital requirements. The balance portion of our Company’s working capital requirement will be arranged from
existing equity, internal accruals and existing borrowings from banks.
2. General corporate purposes
We propose to utilise up to ₹ [●] lakhs of the Net Proceeds for general corporate purposes and business
requirements of our Company as approved by the Board, from time to time, subject to such utilisation for general
corporate purposes not exceeding 25% of the Gross Proceeds, in compliance with the SEBI ICDR Regulations.
The general corporate purposes for which our Company proposes to utilise the Net Proceeds include, without
limitation, meeting ongoing general corporate contingencies, meeting our business requirements, funding growth
opportunities, including funding strategic initiatives domestically and internationally, capital expenditure,
investment in subsidiaries and any other purpose, as may be approved by our Board or a duly constituted
committee thereof from time to time, subject to compliance with applicable law, including provisions of the
Companies Act. In the event our Company is unable to utilise the Net Proceeds towards any of the Objects of the
Issue for any of the reasons as aforementioned, our Company may utilise such Net Proceeds towards general
corporate purposes, provided that the aggregate amount deployed towards general corporate purposes shall not
exceed 25% of the Gross Proceeds.
The quantum of utilisation of funds towards each of the above purposes will be determined by our Board, based
on the amount available under this head and the business requirements of our Company, from time to time. Our
Company’s management shall have flexibility in utilising surplus amounts, if any. In the event that we are unable
to utilise the entire amount that we have currently estimated for use out of Net Proceeds in a Fiscal, we will utilise
such unutilised amount(s) in the subsequent Fiscals.
Issue related expenses
The total expenses of the Issue are estimated to be approximately ₹ [●] lakhs. The expenses of this Issue include,
among others, listing fees, underwriting fees, selling commission, fees payable to the BRLM, fees payable to legal
counsels, Registrar to the Issue, Bankers to the Issue, processing fee to the SCSBs for processing Bid cum
Application Forms, brokerage and selling commission payable to members of the Syndicate, Registered Brokers,
Collecting RTAs and CDPs, printing and stationery expenses, advertising and marketing expenses and all other
incidental and miscellaneous expenses for listing the Equity Shares on the Stock Exchanges.
The break-up of the estimated Issue expenses is set forth below:
Activity Estimated As a % of total As a % of
expenses(1) (₹ in estimated Issue related Issue size(1)
lakhs) expenses(1)
Fees payable to the BRLM and commissions (including [●] [●] [●]
underwriting commission, brokerage and selling
commission)
Commission/ processing fee for SCSBs and Bankers to the [●] [●] [●]
Issue and fees payable to the Sponsor Bank(s) for Bids
made by UPI Bidders. Brokerage, selling commission and
bidding charges for the members of the Syndicate,
Registered Brokers, RTAs and CDPs(2)(3)(4)(5)(6)
Fees payable to Registrar to the Issue [●] [●] [●]
Others:
361Listing fees, SEBI filing fees, book building software fees, [●] [●] [●]
NSDL and CDSL fee and other regulatory expenses
Printing and stationery expenses [●] [●] [●]
Advertising and marketing expenses [●] [●] [●]
Fees payable to other advisors to the Issue, including but [●] [●] [●]
not limited to professional service provider, industry
service provider and Monitoring Agency
Fees payable to the legal counsels to the Issue [●] [●] [●]
Miscellaneous expenses [●] [●] [●]
Total estimated Issue expenses [●] [●] [●]
1. The Issue expenses will be incorporated in the Prospectus on finalization of the Issue Price.
2. Selling commission payable to the SCSBs on the portion for RIIs and Non-Institutional Investors which are directly procured and
uploaded by the SCSBs, would be as follows:
Portion for RIIs [●]% of the Amount Allotted* (plus applicable taxes)
Portion for Non-Institutional Investors [●]% of the Amount Allotted* (plus applicable taxes)
*Amount Allotted is the product of the number of Equity Shares Allotted and the Issue Price.
Selling commission payable to the SCSBs will be determined on the basis of the bidding terminal ID as captured in the bid book of BSE or
NSE. No additional processing fees shall be payable to the SCSBs on the applications directly procured by them.
3. Processing fees payable to the SCSBs for capturing Syndicate Member/Sub-syndicate (Broker)/Sub-broker code on the ASBA Form for
Non-Institutional Investors and Qualified Institutional Investors with bids above ₹5.00 lakhs would be ₹ [●] plus applicable taxes, per
valid application.
Notwithstanding anything contained above the total processing fee payable under this clause will not exceed ₹[●] lakhs (plus applicable
taxes) and in case if the total processing fees exceeds ₹ [●]lakhs (plus applicable taxes) then processing fees will be paid on pro-rata
basis for portion of (i) Non-Institutional Investors and (ii) Qualified Institutional Investors, as applicable.
4. Selling commission on the portion for RIIs (using the UPI Mechanism), Non-Institutional Investors which are procured by members of
the Syndicate (including their sub-Syndicate Members), RTAs and CDPs or for using 3-in-1 type accounts- linked online trading, demat
& bank account provided by some of the brokers which are members of Syndicate (including their Sub-Syndicate Members) would be as
follows:
Portion for RIIs [●]% of the Amount Allotted* (plus applicable taxes)
Portion for Non-Institutional Investors [●]% of the Amount Allotted* (plus applicable taxes)
*Amount Allotted is the product of the number of Equity Shares Allotted and the Issue Price.
The Selling commission payable to the Syndicate / sub-Syndicate Members will be determined:
The Selling Commission payable to the Syndicate / Sub-Syndicate Members will be determined on the basis of the application form number /
series, provided that the application is also bid by the respective Syndicate / Sub-Syndicate Member. For clarification, if a Syndicate ASBA
application on the application form number / series of a Syndicate / Sub-Syndicate Member, is bid by an SCSB, the Selling Commission will
be payable to the SCSB and not the Syndicate / Sub-Syndicate Member.
5. Uploading charges:
Uploading charges payable to members of the Syndicate (including their sub-Syndicate Members), RTAs and CDPs on the applications made
by RIIs using 3-in-1 accounts and Non-Institutional Investors which are procured by them and submitted to SCSB for blocking or using 3-in-
1 accounts, would be as follows: ₹ [●] plus applicable taxes, per valid application bid by the Syndicate (including their sub-Syndicate
Members), RTAs and CDPs.
The selling commission and bidding charges payable to Registered Brokers, the RTAs and CDPs will be determined on the basis of the bidding
terminal id as captured in the Bid Book of BSE or NSE.
6. Selling commission/ uploading charges payable to the Registered Brokers on the portion for RIIs procured through UPI Mechanism and
Non-Institutional Investors which are directly procured by the Registered Broker and submitted to SCSB for processing, would be as
follows:
Portion for RIIs* ₹ [●] per valid application (plus applicable taxes)
Portion for Non-Institutional Investors* ₹ [●] per valid application (plus applicable taxes)
*Based on valid applications
7. Uploading charges/ Processing fees for applications made by UPI Bidders using the UPI Mechanism would be as under:
Payable to members of the Syndicate (including their sub- ₹ [●] per valid application (plus applicable taxes)
Syndicate Members)/ RTAs / CDPs
Payable to Sponsor Banks ₹ [●] per valid application (plus applicable taxes)
362The processing fees for applications made by UPI Bidders using the UPI Mechanism may be released to the
remitter banks (SCSBs) only after such banks provide a written confirmation on compliance with SEBI ICDR
Master Circular read with the SEBI circular no. SEBI/HO/CFD/DIL2/P/CIR/2021/570 dated June 2, 2021, SEBI
circular no. SEBI/HO/CFD/DIL2/CIR/P/2021/2480/1/M dated March 16, 2021, SEBI circular no.
SEBI/HO/CFD/DIL2/CIR/P/2022/51 dated April 20, 2022, SEBI Circular No.
SEBI/HO/CFD/DIL2/P/CIR/2022/75 dated May 30, 2022, and SEBI Master Circular no.
SEBI/HO/MIRSD/POD1/P/CIR/2023/70 dated May 17, 2023, each to the extent applicable, and not rescinded by
the SEBI ICDR Master Circular in relation to the SEBI ICDR Regulations
All such commissions and processing fees set out above shall be paid as per the timelines in terms of the Syndicate
Agreement and Cash Escrow and Sponsor Bank Agreement.
The Book Running Lead Manager shall ensure that the payment of processing fee or selling commission to the
intermediaries shall be released only after ascertaining that there are no pending complaints pertaining to block
or unblock of Bids by UPI Bidders, receiving the confirmation on completion of unblocks from Sponsor Banks
or SCSBs and certification from RTA/ SCSBs.
Interim use of the Net Proceeds
Our Company, in accordance with the applicable law, policies established by our Board from time to time and in
order to attain the Objects set out above, will have flexibility to deploy the Net Proceeds. Pending utilisation of
the Net Proceeds for the purposes described in this section, our Company may temporarily invest the Net Proceeds
in deposits in one or more scheduled commercial banks included in the Second Schedule of the Reserve Bank of
India Act, 1934, as may be approved by our Board. In accordance with Section 27 of the Companies Act, our
Company confirms that, other than as specified in this section for the purposes of the Objects, it shall not use the
Net Proceeds for buying, trading or otherwise dealing in equity securities or any equity linked securities.
Appraising entity
None of the Objects for which the Net Proceeds will be utilised have been appraised by any agency.
Bridge financing facilities
Our Company has not raised any bridge loans from any bank or financial institution as of the date of this Draft
Red Herring Prospectus, which are proposed to be repaid from the Net Proceeds.
Monitoring of utilisation of funds
In terms of Regulation 41 of the SEBI ICDR Regulations, prior to filing the Red Herring Prospectus with the RoC,
In case, the Fresh Issue size will be in excess of ₹ 10,000.00 lakhs we will appoint a monitoring agency to monitor
the utilization of the Gross Proceeds. Our Audit Committee and the Monitoring Agency will monitor the utilisation
of the Gross Proceeds. Our Company undertakes to place the report(s) of the Monitoring Agency upon receipt
before the Audit Committee without any delay.
Our Company will disclose the utilisation of the Gross Proceeds, including interim, use under a separate head in
our balance sheet for such fiscals as required under applicable law, specifying the purposes for which the Net
Proceeds have been utilised. Our Company will also, in its balance sheet for the applicable fiscals, provide details,
112if any, in relation to all such Gross Proceeds that have not been utilised, if any, of such unutilised Gross
Proceeds. Our Company will indicate investments, if any, of unutilised Gross Proceeds in the balance sheet of our
Company for the relevant fiscals subsequent to receipt of listing and trading approvals from the Stock Exchanges.
Pursuant to Regulation 18(3) and Regulation 32(3) of the SEBI Listing Regulations, our Company shall on a
quarterly basis disclose to the Audit Committee the uses and application of the Gross Proceeds. Additionally, the
Audit Committee shall review the report submitted by the Monitoring Agency and make recommendations to our
Board for further action, if appropriate. Our Company shall, on an annual basis, prepare a statement of funds
utilised for purposes other than those stated in this Draft Red Herring Prospectus and place it before the Audit
Committee. Such disclosure shall be made only till such time that all the Gross Proceeds have been utilised in
full. The statement shall be certified by the statutory auditors of our Company. Furthermore, in accordance with
the SEBI Listing Regulations, our Company shall furnish to the Stock Exchanges, on a quarterly basis, a statement
including deviations, if any, in the utilization of the Gross Proceeds of the Issue from the Objects as stated above.
363The information will also be published in newspapers simultaneously with the interim or annual financial results
and explanation for such variation (if any) will be included in our Directors’ report, after placing the same before
the Audit Committee. We will disclose the utilization of the Gross Proceeds under a separate head along with
details in our balance sheet(s) until such time as the Gross Proceeds remain unutilized clearly specifying the
purpose for which such Gross Proceeds have been utilized. In the event that we are unable to utilize the entire
amount that we have currently estimated for use out of the Gross Proceeds in a Fiscal, we will utilize such
unutilized amount in the next Fiscal.
Variation in Objects
In accordance with Sections 13(8) and 27 of the Companies Act, and Regulation 59 and Schedule XX of the SEBI
ICDR Regulations, any material deviation in the Objects of the Issue will require our Company to obtain the
approval of the Shareholders by way of a special resolution. In addition, the notice issued to the Shareholders in
relation to the passing of such special resolution (Postal Ballot Notice) shall specify the prescribed details and be
published in accordance with the Companies Act. The Postal Ballot Notice shall simultaneously be published in
the newspapers, one in English and one in Gujarati, the vernacular language of the jurisdiction where our
Registered Office is situated. Pursuant to the Companies Act, our Promoters will be required to provide an exit
opportunity to the Shareholders who do not agree to such material deviation of the Objects, subject to the
provisions of the Companies Act and in accordance with such terms and conditions, including in respect of pricing
of the Equity Shares, in accordance with the Companies Act and provisions of Schedule XX of the SEBI ICDR
Regulations.
Other confirmations
No part of the Net Proceeds will be utilized by our Company as consideration to our Promoters, members of our
Promoter Group, our directors, our group companies or Key Managerial Personnel, Senior Management or Group
Companies. Our Company has not entered into or is not planning to enter into any arrangement/ agreements with
our Directors, our Promoters, the members of our Promoter Group, the Key Managerial Personnel or Senior
Management in relation to the utilization of the Net Proceeds of the Issue. Further, except in the ordinary course
of business, there is no existing or anticipated interest of such individuals and entities in the Objects of the Fresh
Issue as set out above.
364BASIS OF ISSUE PRICE
The Price Band, Floor Price and Issue Price will be determined by our Company in consultation with the Book
Running Lead Manager, on the basis of assessment of market demand for the Equity Shares issue through the
Book Building Process and on the basis of the qualitative and quantitative factors as described below. The face
value of the Equity Shares is ₹ 10 each and the Floor Price is [●] times the face value of Equity Shares and Cap
Price is [●] times the face value of Equity Shares.
Investors should also refer to the sections “Risk Factors”, “Our Business”, “Financial Information” and
“Management’s Discussion and Analysis of Financial Condition and Results of Operations” beginning on pages
40, 438, 503 and 578 respectively, to have an informed view before making an investment decision.
Qualitative Factors
We believe that some of the qualitative factors and our strengths which form the basis for computing the Issue
Price are as follows:
1. Sizeable clientele across Gujarat, with a strong regional presence
2. Strong track record of financial performance and operating efficiency
3. Leveraging technology to enhance client satisfaction
4. Integrated brokerage model with long term client relationships
5. Experienced Promoters and Management Team
For further details, please see “Our Business – Our Strengths” on page 440
Certain information presented in this section relating to our Company is based on and derived from the Restated
Consolidated Financial Information. For details, see “Financial Information” beginning on page 503503
Some of the quantitative factors, which may form the basis for computing the Issue Price, are as follows:
1. Basic and diluted earnings per Share (“EPS”), as adjusted for changes in capital
As derived from the Restated Consolidated Financial Information of our Company:
Weighted Average EPS:
Financial Period Basic and Diluted EPS (in ₹) Weight
Financial Year ended March 31, 2025 14.84 3
Financial Year ended March 31, 2024 11.38 2
Financial Year ended March 31, 2023 4.84 1
Weighted Average EPS 12.02
Notes:
i. Weighted average = Aggregate of year - wise weighted EPS divided by the aggregate of weights i.e. (EPS x Weight) for each year/Total of
weights.
ii. Basic Earnings per Equity Share = Net profit after tax attributable to owners of the Company, as restated / weighted average no. of Equity
Shares outstanding during the year/ period.
iii. Diluted Earnings per Equity Share = Net Profit after tax attributable to owners of the Company, as restated / Weighted average no. of
potential Equity Shares outstanding during the year/ period, as adjusted to reflect the effect of all potential dilutive Equity Shares.
iv. Earnings per Share calculations are in accordance with the notified Indian Accounting Standard 33 ‘Earnings per share’
2. Price/Earning (“P/E”) ratio in relation to Price Band of ₹ [●] to ₹ [●] per Equity Share:
P/E at the lower end of Price P/E at the higher end of Price
Particulars
Band (number of times) * Band (number of times) *
Based on Basic and Diluted EPS for the Financial
[●] [●]
Year ended March 31, 2025
*To be computed after finalization of price band
3. Industry Peer Group P/E ratio
Based on the peer group information (excluding our Company) given below in this section are, the highest,
the lowest and the industry average P/E ratio:
P/E Ratio (Basic P/E Ratio (Diluted Face value of Equity
Particulars Name of Company
EPS) EPS) Shares (₹)
Arihant Capital
Highest 12.15 12.77 1
Markets Limited
SMC Global
Lowest 7.49 7.49 2
Securities Limited
365P/E Ratio (Basic P/E Ratio (Diluted Face value of Equity
Particulars Name of Company
EPS) EPS) Shares (₹)
Average 10.08 10.45
Source: Based on peer set provided below.
Notes:
i.The industry high and low has been considered from the peers set provided later in this chapter. The industry average has been calculated
as the arithmetic average of P/E of the industry peers set disclosed in this section. For further details, see para 6 below – “Comparison of
Accounting Ratios with Listed Industry Peers” on page 366.
ii.P/E Ratio has been computed based on the closing market price of equity shares on NSE on March 28, 2025 divided by the Basic/Diluted
EPS provided.
4. Return on Net Worth (“RoNW”)
As derived from the Restated Consolidated Financial Information of our Company:
Fiscal / Period Ended RoNW % Weight
Financial Year ended March 31, 2025 13.91% 3
Financial Year ended March 31, 2024 11.91% 2
Financial Year ended March 31, 2023 6.50% 1
Weighted Average 12.01%
Notes:
1. Weighted average = Aggregate of year-wise weighted RoNW divided by the aggregate of weights i.e. (RoNW x Weight) for each
year/Total of weights.
2. Return on Net Worth refers to the profit for the year/period attributable to equity shareholders of our Company, as restated divided by
Net Worth as at end of the relevant year/period.
3. Net Worth means the aggregate value of the paid-up share capital and all reserves created out of the profits and securities premium
account and debit or credit balance of profit and loss account, after deducting the aggregate value of the accumulated losses, deferred
expenditure and miscellaneous expenditure not written off, as per the audited balance sheet, but does not include reserves created out
of revaluation of assets, write-back of depreciation and amalgamation.
5. Net Asset Value per Equity Share of face value of ₹ 10 each, as adjusted for changes in capital
As derived from the Restated Consolidated Financial Information of our Company:
Period NAV (₹)
As on March 31, 2025 106.70
As on March 31, 2024 95.56
As on March 31, 2023 74.56
At Floor Price: [●]
After the completion of the Issue
At Cap Price: [●]
Issue Price [●]
Notes:
i. Issue Price per Equity Share will be determined on conclusion of the Book Building Process.
ii. Net assets value per share (in ₹): Net Asset Value per equity share represents net worth as at the end of the fiscal year, as restated,
divided by the number of Equity Shares outstanding at the end of the period/year.
6. Comparison of accounting ratios with listed industry peers
Following is the comparison with our peer group companies listed in India and in the same line of business as
our Company:
NAV Revenue
Current P/E P/E
Face per from
Name of the Market Basic Diluted Ratio Ratio RoNW
Value Equity operations
company Price EPS (₹) EPS (₹) (Basic (Diluted (%)
(₹) Share (₹ in
(₹) EPS) EPS)
(₹) Lakhs)
Shah Investor’s
10.00 [●] 14.84 14.84 [●] [●] 13.91% 106.70 9,427.39
Home Limited
Peer Group*
SMC Global
Securities 2.00 104.24 13.92 13.92 7.49 7.49 11.97% 116.25 1,77,574.15
Limited
Share India
Securities 10.00 165.18 15.58 14.90 10.60 11.09 14.04% 534.79 1,44,856.84
Limited
Arihant Capital
1.00 68.55 5.64 5.37 12.15 12.77 15.27% 36.93 24,731.70
Markets Limited
Source:
366The financial information for our Company is based on the Restated Consolidated Financial Statements as at and for the financial year ended
March 31, 2025.
The financial information for listed industry peers mentioned above is sourced from the consolidated financial statements of the respective
company for the financial year ended March 31, 2025, submitted to the Stock Exchanges and Markert Price is Closing market Price as on
March 28, 2025 on www.nseindia.com.
Notes:
1. Basic EPS and Diluted EPS refer to the Basic EPS and Diluted EPS sourced from the financial statements of the respective company.
2. P/E Ratio has been computed based on the closing market price of equity shares on NSE on March 28, 2025 divided by the Basic/Diluted
EPS provided.
3. Return on Net Worth for equity shareholders (%) (RONW) = Profit for the year attributable to the equity shareholders of our Company
divided by total net worth.
4. Net Worth means the aggregate value of the paid-up share capital and all reserves created out of the profits and securities premium account
and debit or credit balance of profit and loss account, after deducting the aggregate value of the accumulated losses, deferred expenditure
and miscellaneous expenditure not written off, as per the audited balance sheet, but does not include reserves created out of revaluation of
assets, write-back of depreciation and amalgamation.
5. For listed peers, NAV is computed as equity attributable to owners (total equity) divided by the number of equity shares outstanding at the
end of the year.
7. Key Performance Indicators (“KPIs”)
The KPIs disclosed below have been used historically by our Company to understand and analyse our business
performance, which in result, help us in analysing the growth of business verticals in comparison to our peers.
Our Company considers that the KPIs set forth below are the ones that may have a bearing for arriving at the basis
for the Issue Price. The KPIs disclosed below have been approved and confirmed by a resolution of our Audit
Committee dated September 29, 2025. Further, the members of our Audit Committee have confirmed that there
are no KPIs pertaining to our Company that have been disclosed to any investors at any point of time during the
three years prior to the date of filing of this Draft Red Herring Prospectus. Further, the KPIs disclosed herein have
been certified by the Independent Chartered Accountant, by their certificate dated September 29, 2025.
For details of our other operating metrics disclosed elsewhere in this Draft Red Herring Prospectus, see “Our
Business”, and “Management’s Discussion and Analysis of Financial Position and Results of Operations” on
pages 438 and 578 respectively.
Our Company confirms that it shall continue to disclose all the KPIs included in this section on a periodic basis,
at least once in a year (or any lesser period as determined by the Board of Directors of our Company), until the
later of (a) one year after the date of listing of the Equity Shares on the Stock Exchanges; and (b) complete
utilisation of the proceeds of the Issue as disclosed in “Objects of the Issue” on page 357, or for such other duration
as may be required under the SEBI ICDR Regulations.
The list of our KPIs along with brief explanation of the relevance of the KPI for our business operations are set
forth below. We have also described and defined the KPIs, as applicable, in “Definitions and Abbreviations”
beginning on page 1.
Details of our KPIs as at/ for the financial year ended March 31, 2025, March 31, 2024, and March 31, 2023.
Financial Year Financial Year Financial Year
Particulars ended March 31, ended March 31, ended March 31,
2025 2024 2023
GAAP Measures
Revenue from operations (₹lakhs) 9,427.39 7,782.36 5,168.30
Profit before Tax (₹lakhs) 3,140.22 2,400.68 988.70
Profit After Tax (₹lakhs) 2,338.50 1,793.38 763.17
Net Worth (₹lakhs) 16,808.98 15,054.13 11,745.98
Non-GAAP Measures
Growth in Revenue from Operations (%) 21.14% 50.58% -
Profit After Tax Margin (%) 24.76% 22.69% 14.58%
EBITDA (₹lakhs) 3,531.31 2,512.97 1,114.59
EBITDA Margin (%) 37.46% 32.29% 21.57%
EBIT (₹lakhs) 3,367.18 2,368.73 982.57
EBIT Margin (%) 35.72% 30.44% 19.01%
RoE (%) 14.68% 13.38% 6.56%
RoCE (%) 20.35% 16.77% 8.13%
Debt to Equity Ratio 0.03 0.02 0.07
Operating Cash Flows (₹ in lakhs) (3,186.22) 11,019.42 0.45
Notes:
(1) Revenue from Operations means the revenue from operations as appearing in the Restated Consolidated Financial Information.
(2) Profit Before Tax means profit/(loss) before tax as appearing in the Restated Consolidated Financial Information including profit /
(loss) from discontinued operation.
367(3) Profit after Tax means profit / (loss) for the period/ year from continuing and discontinued operations attributable to the owners of the
parent company as appearing in the Restated Consolidated Financial Information.
(4) Net Worth means the aggregate value of the paid-up share capital and all reserves created out of the profits and securities premium
account and debit or credit balance of profit and loss account, after deducting the aggregate value of the accumulated losses, deferred
expenditure and miscellaneous expenditure not written off, as per the audited balance sheet, but does not include reserves created out
of revaluation of assets, write-back of depreciation and amalgamation.
(5) Growth in revenue from operations (%) is calculated as a percentage of revenue from operations of the relevant period/year minus
Revenue from Operations of the preceding period/year, divided by revenue from operations of the preceding period/year.
(6) Profit after Tax Margin refers to the percentage margin derived by dividing profit after tax by revenue from operations.
(7) EBITDA is calculated as profit / (loss) before tax for the period / year including share in profit/ (loss) from associates/ joint ventures,
finance costs and depreciation and amortization expenses, excluding other Income.
(8) EBITDA Margin (%) is computed as EBITDA divided by revenue from operations.
(9) EBIT is calculated as profit / (loss) before tax for the period / year including share in profit/ (loss) from associates/ joint ventures plus
finance costs excluding other Income.
(10) EBIT Margin (%) is computed as EBIT divided by revenue from operations.
(11) Return on Equity refers to the profit for the year/period attributable to equity shareholders of our Company divided by average Equity
attributable to owners of the parent company as at end of the relevant year/period.
(12) Return on Capital Employed (ROCE): Calculated as earnings before Interest and tax including share in profit/ (loss) from associates/
joint ventures for the year/period excluding other income divided by Capital Employed (Total Equity + borrowings including lease
liability + Deferred Tax (Asset)/ Liability - Intangible Assets including Intangible Assets under Development).
(13) Debt-equity ratio calculated as total debt (current and non-current borrowings including lease liability) divided by total Equity.
As at and for Financial As at and for Financial As at and for Financial
Particulars Year ended March 31, Year ended March 31, Year ended March 31,
2025 2024 2023
Operating metrics:
Total number of clients 80,391 76,337 71,690
Active Clients 37,814 35,535 31,372
Growth in Active Clients
6.41% 13.27% -13.16%
(%)
Active clients as a % of
47.04% 46.55% 43.76%
Total number of clients
Average tenor of client
relationship
Up to 1 year 2,469 1,893 1,022
1 to 2 years 3,720 3,819 4,142
3 to 5 years 4,061 2,852 2,671
More than 5 Years 27,564 26,971 23,537
Total Customer Asset (₹ in
42,41,110.67 44,12,085.83 26,31,095.13
lakhs)
Broking Revenue (₹ in
6,491.13 5,570.20 3,702.79
lakhs)
Average broking revenue
17,165.95 15,675.24 11,802.85
per active client (in ₹)
Margin Trading Facility
964.22 N.A N.A
Book (₹ in lakhs)
Growth in Margin Trading
N.A N.A N.A
Facility Book (%)
Total Assets Under
Distribution
Mutual Funds (₹) (in lakhs) 4,916.92 3,753.15 2,626.16
Explanation for the Financial Key Performance Indicators
KPI Explanation
Revenue from Operations is used by the management to track the revenue profile of the
Revenue from operations business and in turn helps assess the overall financial performance of the Company and size
of the business.
The amount that remains after a company has paid off all of its operating and non-operating
Profit before Tax
expenses. It provides information regarding the profitability before tax of our Company.
The amount that remains after a company has paid off all of its operating and non-operating
Profit/ (Loss) after tax
expenses and taxes. It provides information regarding the profitability of our Company.
Net Worth means the aggregate value of the paid-up share capital and all reserves created
out of the profits and securities premium account and debit or credit balance of profit and
Net Worth
loss account, after deducting the aggregate value of the accumulated losses, deferred
expenditure and miscellaneous expenditure not written off, as per the audited balance sheet,
368KPI Explanation
but does not include reserves created out of revaluation of assets, write-back of depreciation
and amalgamation. This is helpful in evaluating current financial standing of the Company
Growth in revenue from Growth in Revenue from Operations provides information regarding the growth of the
operations (%) business for the respective period.
Percentage of the amount that remains after a company has paid off all of its operating and
Profit/ (Loss) after tax
non-operating expenses, other liabilities and taxes. It provides information regarding the
margin (%)
profitability of our Company.
Earnings before interest, tax, depreciation and amortization and is calculated as the restated
profit before tax for the period, finance cost, depreciation and amortization expenses less
EBITDA
other income. EBITDA provides information regarding operational profitability and
efficiency of our Company.
EBITDA Margin (%) is computed as EBITDA divided by revenue from operations. This
EBITDA Margin (%) metric helps in benchmarking the operating profitability against the historical performance
of our Company.
Earnings before interest and tax is calculated as the restated profit before tax for the period
EBIT
or year plus finance cost less other income.
EBIT Margin (%) helps in keeping track of the operational efficiency of our company after
EBIT Margin (%) the depreciation and amortization expenses calculated as EBIT as a percentage of revenue
from operations.
Return on Equity is calculated on the basis of net profit after tax divided by shareholder’s
RoE (%) equity and is calculated by profit after tax divided by our net worth (share capital and other
equity). It indicates our Company’s ability to turn equity investments into profits.
Return on Capital Employed is calculated as earnings before interest and tax divided by
Capital Employed. Earnings before interest and tax is calculated as profit / (loss) for the
period / year plus total tax expense / (credit) plus finance costs excluding other income.
RoCE (%) Capital Employed is calculated as total equity plus total borrowings, Deferred Tax
liability/(Asset), but excluding Intangible Assets (including Intangible Assets under
Development). This provides us information on efficiency of our capital deployment and
utilization.
Debt To Equity Ratio Debt-to-equity (D/E) ratio is used to evaluate a company’s financial leverage.
Operating cash flows provides how efficiently our company generates cash through its core
Operating Cash Flows
business activities.
Explanations for Operational Key Performance Indicators
KPI Explanation
It represents the total number of clients registered with the Company across all products
Total number of clients
i.e. Broking, Margin Trading Facility and Distribution.
It represents total Active Clients i.e., clients who have executed any trade during the in the
Active number of clients last twelve months of the reporting period. This is across all products i.e. Broking, Margin
Trading Facility and Distribution.
Growth in Active clients It represents year on year growth in active clients.
Active clients as a % of
It represents Active clients as a percentage of total clients registered with the Company
Total Clients
Average Tenor of client It represents tenor of association of active client with the Company. This is calculated
relationship from the date of activation to the end of the period.
It represents the value of the aggregate of all customer’s portfolio as at the end of the
Total Customer Assets
reporting period.
Average broking revenue
It represents average revenue per client in Broking Segment.
per active client
Margin Trading Facility
It represents outstanding Margin Trading Facility Book at the end of the period.
Book
Growth in Margin Trading
It represents year on year growth in Margin Trading Facility Book.
Facility Book
Total Assets Under It represents outstanding Asset under Distribution at the end of the period on which
Distribution company earns trail revenue.
For further details on the Key Performance Indicators, please see the section “Management’s Discussion and
Analysis of Financial Condition and Results of Operations” on page 578.
8. Description on the historic use of the KPIs by our Company to analyse, track or monitor the operational
and/or financial performance of our Company.
In evaluating our business, we consider and use certain KPIs, as stated above, as a supplemental measure to review
and assess our financial and operating performance. The presentation of these KPIs is not intended to be
considered in isolation or as a substitute for the Restated Consolidated Financial Statements. We use these KPIs
369to evaluate our financial and operating performance. Some of these KPIs are not defined under Ind AS and are
not presented in accordance with Ind AS. These KPIs have limitations as analytical tools. Further, these KPIs may
differ from the similar information used by other companies and hence their comparability may be limited.
Therefore, these metrics should not be considered in isolation or construed as an alternative to Ind AS measures
of performance or as an indicator of our operating performance, liquidity or results of operation. Although these
KPIs are not a measure of performance calculated in accordance with applicable accounting standards, our
management believes that it provides an additional tool for investors to use in evaluating our ongoing operating
results and trends and in comparing our financial results with other companies in our industry because it provides
consistency and comparability with past financial performance, when taken collectively with financial measures
prepared in accordance with Ind AS. Bidders are encouraged to review the Ind AS financial measures and to not
rely on any single financial or operational metric to evaluate our business.
9. Comparison with Listed Industry Peers
Set forth below is a comparison of our KPIs with our peer group companies listed in India and operating in the
same industry as our Company, whose business profile is comparable to our business in terms of our size, scale
and our business model:
Fiscal 2025
Arihant
SMC Global Share India
Shah Investor’s Capital
Particulars Securities Securities
Home Limited Markets
Limited Limited
Limited
Consolidated Consolidated Consolidated Consolidated
Total Income (₹ in lakhs) 9,446.51 1,78,572.01 1,46,950.09 24,801.08
Total revenue from operation (₹ in lakhs) 9,427.39 1,77,574.15 1,44,856.84 24,731.70
Growth in Revenue from Operations (%) 21.14% 8.38% (2.31%) 5.18%
EBITDA (₹ in lakhs) 3,531.31 41,938.99 51,690.60 9,953.95
EBITDA margins (%) 37.46% 23.62% 35.68% 40.25%
PAT (₹ in lakhs) 2,338.50 14,569.45 32,761.88 5,870.28
PAT Margin (%) 24.76% 8.16% 22.29% 23.67%
Growth in PAT (%) 30.40% (22.20%) (22.99%) (16.75%)
RoE(%) 14.68% 12.60% 16.06% 16.61%
RoCE (%) 20.35% 14.40% 19.98% 21.46%
Debt Equity Ratio 0.03 1.39 0.22 0.25
Operating Cash Flows (₹ in lakhs) (3,186.22) 2,353.68 584.88 3,157.61
Note:
1. All the financial information for listed industry peers mentioned above is on a consolidated basis and is sourced from the annual report of
the respective company for the years ended March 31, 2024 and March 31,2023 and the audited financial information of the respective
company for the financial year ended March 31, 2025 as available on the website of the stock exchange.
2. All metrics are calculated to the extent ascertainable using publicly disclosed information as on date of this Draft Red Herring Prospectus.
Fiscal 2024
Shah SMC Global Share India Arihant
Investor’s Securities Securities Capital
Particulars
Home Limited Limited Markets
Limited Limited
Consolidated Consolidated Consolidated Consolidated
Total Income (₹ in lakhs) 7,905.29 1,64,458.54 1,48,874.88 23,560.57
Total revenue from operation (₹ in lakhs) 7,782.36 1,63,840.87 1,48,281.45 23,514.36
Growth in Revenue from Operations (%) 50.58% 35.23% 36.26% 70.95%
EBITDA (₹ in lakhs) 2,512.97 42,590.09 65,596.49 10,720.81
EBITDA margins (%) 32.29% 25.99% 44.24% 45.59%
PAT (₹ in lakhs) 1,793.38 18,727.65 42,541.89 7,051.04
PAT Margin (%) 22.69% 11.39% 28.58% 29.93%
Growth in PAT (%) 134.99% 55.99% 29.37% 142.16%
RoE(%) 13.38% 18.46% 30.92% 24.35%
RoCE (%) 16.77% 17.95% 38.24% 28.52%
Debt Equity Ratio 0.02 1.34 0.23 0.31
Operating Cash Flows (₹ in lakhs) 11,019.42 (19,279.43) (31,045.02) (2,963.17)
Note:
1. All the financial information for listed industry peers mentioned above is on a consolidated basis and is sourced from the annual report of
the respective company for the years ended March 31, 2024 and March 31,2023 and the audited financial information of the respective
company for the financial year ended March 31, 2025 as available on the website of the stock exchange.
3702. All metrics are calculated to the extent ascertainable using publicly disclosed information as on date of this Draft Red Herring Prospectus
Fiscal 2023
Arihant
SMC Global Share India
Shah Investor’s Capital
Particulars Securities Securities
Home Limited Markets
Limited Limited
Limited
Consolidated Consolidated Consolidated Consolidated
Total Income (₹ in lakhs) 5,232.96 1,21,565.46 1,09,970.24 13,776.03
Total revenue from operation (₹ in lakhs) 5,168.30 1,21,157.33 1,08,823.41 13,754.77
Growth in Revenue from Operations (%) - 9.51% 26.30% (18.97%)
EBITDA (₹ in lakhs) 1,114.59 26,989.67 49,408.89 5,011.42
EBITDA margins (%) 21.57% 22.28% 45.40% 36.43%
PAT (₹ in lakhs) 763.17 12,005.47 32,883.17 2,911.76
PAT Margin (%) 14.58% 9.88% 29.90% 21.14%
Growth in PAT (%) (41.31%) (31.15%) 63.47% (42.18%)
RoE(%) 6.56% 12.92% 45.30% 12.00%
RoCE (%) 8.13% 15.10% 51.94% 15.39%
Debt Equity Ratio 0.07 1.03 0.20 0.23
Operating Cash Flows (₹ in lakhs) 0.45 (26,008.43) (16,952.16) 1,469.16
Note:
1. All the financial information for listed industry peers mentioned above is on a consolidated basis and is sourced from the annual report of
the respective company for the years ended March 31, 2024 and March 31,2023 and the audited financial information of the respective
company for the financial year ended March 31, 2025 as available on the website of the stock exchange.
2. All metrics are calculated to the extent ascertainable using publicly disclosed information as on date of this Draft Red Herring Prospectus.
Fiscal 2025
Arihant
SMC Global Share India
Particulars Shah Investors Capital
Securities Securities
Home Limited Markets
Limited Limited
Limited
Operating metrics:
Total number of clients 80,391 NA NA NA
Active Clients on NSE 37,814 1,79,621 7,828 56,572
Growth in Active Clients (%) 6.41% 0.50% 37.80% 11.90%
Active clients as a % of Total number of clients 47.04% NA NA NA
Average tenor of client relationship
· Up to 1 year 2,469 NA NA NA
· 1 to 2 years 3,720 NA NA NA
· 3 to 5 years 4,061 NA NA NA
· More than 5 Years 27,564 NA NA NA
Total Customer Assets (₹ in Lakhs) 42,41,110.67 NA NA NA
Broking Revenue (Rs. Lakhs) 6,491.13 1,04,454.40 1,36,667.00 24,458.00
Average broking active client (in ₹) 17,165.95 58,152.70 17,45,870.20 43,233.40
Margin Trading Facility Book (Rs. Lakhs) 964.22 27,989.90 23,705.60 12,972.70
Growth in Margin Trading Facility Book (%) N.A. 20.20% 233.30% -25.60%
Total Assets Under Distribution
Mutual Funds (Rs. Lakhs) 4,916.92 ~4,17,800.00 17,400.00 NA
Note: NA in the table above indicates that the amount is not available.
371Fiscal 2024
Arihant
SMC Global Share India
Particulars Shah Investors Capital
Securities Securities
Home Limited Markets
Limited Limited
Limited
Operating metrics:
Total number of clients 76,337 NA NA 2,48,294
Active Clients on NSE 35,535 1,78,712 5,679 50,542
Growth in Active Clients (%) 13.27% 16.70% -14.30% 24.20%
Active clients as a % of Total number of clients 46.55% NA NA 32.30%
Average tenor of client relationship
· Up to 1 year 1,893 NA NA NA
· 1 to 2 years 3,819 NA NA NA
· 3 to 5 years 2,852 NA NA NA
· More than 5 Years 26,971 NA NA NA
Total Customer Assets (₹ in Lakhs) 44,12,085.83 NA NA NA
Broking Revenue (Rs. Lakhs) 5,570.20 96,144.90 1,37,500.00 23,341.90
Average broking active client (in ₹) 15,675.24 53,798.80 24,21,193.70 46,183.10
Margin Trading Facility Book (Rs. Lakhs) - 23,285.10 7,112.10 17,447.00
Growth in Margin Trading Facility Book (%) - 24.90% 100.00% 162.00%
Total Assets Under Distribution
Mutual Funds (Rs. Lakhs) 3,753.15 ~3,80,100.00 NA NA
Note: NA in the table above indicates that the amount is not available.
Fiscal 2023
Arihant
SMC Global Share India
Particulars Shah Investors Capital
Securities Securities
Home Limited Markets
Limited Limited
Limited
Operating metrics:
Total number of clients 71,690 NA NA 2,23,000
Active Clients on NSE 31,372 1,53,078 6,628 40,697
Growth in Active Clients (%) -13.16% NA 70.30% -3.80%
Active clients as a % of Total number of clients 43.76% NA NA NA
Average tenor of client relationship
· Up to 1 year 1,022 NA NA NA
· 1 to 2 years 4,142 NA NA NA
· 3 to 5 years 2,671 NA NA NA
· More than 5 Years 23,537 NA NA NA
Total Customer Assets (₹ in Lakhs) 26,31,095.13 NA NA NA
Broking Revenue (Rs. Lakhs) 3,702.79 76,779.30 98,915.00 13,605.70
Average broking active client (in ₹) 11,802.85 50,157.00 14,92,379.10 33,431.60
Margin Trading Facility Book (Rs. Lakhs) - 18,638.10 NA 6,658.70
Growth in Margin Trading Facility Book (%) - NA NA NA
Total Assets Under Distribution
· Mutual Funds (Rs. Lakhs) 2,626.16 ~2,99,200.00 NA NA
Note: NA in the table above indicates that the amount is not available
Comparison of KPIs based on additions or dispositions to our business
Our Company has not undertaken a material acquisition or disposition of assets / business for the periods that are
covered by the KPIs and accordingly, no comparison of KPIs over time based on additions or dispositions to the
business, have been provided.
37210. Weighted Average Cost of Acquisition
a. The price per share of our Company based on primary issuances of Equity Shares or convertible
securities (excluding Equity Shares issued under employee stock option schemes and issuance of Equity
Shares pursuant to a bonus issue) during the 18 months preceding the date of this Draft Red Herring
Prospectus, where such issuance is equal to or more than 5% of the fully diluted paid-up share capital
of our Company (calculated based on the pre-Issue capital before such transaction(s) and excluding
employee stock options granted but not vested) in a single transaction or multiple transactions
combined together over a span of rolling 30 days (“Primary Issuances”)
There has been no issuance of Equity Shares or convertible securities during the 18 months preceding the date of
this Draft Red Herring Prospectus where such issuance is equal to or more than 5% of the fully diluted paid-up
share capital of our Company (calculated based on the pre-Issue capital before such transaction(s) and excluding
employee stock options granted but not vested), in a single transaction or multiple transactions combined together
over a span of rolling 30 days.
b. The price per share of our Company (as adjusted for corporate actions, including bonus issuances)
based on secondary sale or acquisition of equity shares or convertible securities (excluding gifts)
involving any of the Promoters, members of the Promoter Group or other Shareholders of our
Company with rights to nominate directors during the 18 months preceding the date of filing of the
this Draft Red Herring Prospectus, where the acquisition or sale is equal to or more than 5% of the
fully diluted paid-up share capital of our Company (calculated based on the pre-Issue capital before
such transaction(s) and excluding employee stock options granted but not vested), in a single
transaction or multiple transactions combined together over a span of rolling 30 days (“Secondary
Transactions”)
There have been no secondary sale/transfers or acquisition of any Equity Shares or convertible securities
(excluding gifts) , where the Promoters, members of the Promoter Group or shareholders having the right to
nominate Directors to the Board of our Company are a party to the transactions, during the 18 months preceding
the date of this Draft Red Herring Prospectus, where either acquisition or sale is equal to or more than 5% of the
fully diluted paid up share capital of our Company (calculated based on the pre-Issue capital before such
transaction(s)), in a single transaction or multiple transactions combined together over a span of rolling 30 days.
Since there are no such transactions to report under (a) and (b), the following are the details, based on the
last five primary or secondary transactions (secondary transactions where Promoters, members of the
Promoter Group, or Shareholder(s) having the right to nominate Director(s) on our Board are a party to
the transaction), not older than three years prior to the date of this Draft Red Herring Prospectus,
irrespective of the size of transactions.
Other than as disclosed below, there have been no primary or secondary transactions (secondary transactions
where Promoters, members of the Promoter Group, or Shareholder(s) having the right to nominate Director(s) on
our Board are a party to the transaction), not older than three years prior to the date of this Draft Red Herring
Prospectus.
Face
No. of Value Transaction
Date of Name of Name of Equity per Price per Total
Sr no
Transaction transferor transferee Shares Equity Equity Consideration
transferred Shares Shares*
(Rs.)
1. February 21, Upendra Ruchira 50,000 10 Nil Nil
2024 Trikamal Tanmay
Shah Shah
2. February 21, Upendra Preeti 50,000 10 Nil Nil
2024 Trikamal Upendra
Shah Shah
3. February 21, Upendra Utpal 25,000 10 Nil Nil
2024 Trikamal Praful Shah
Shah
4. July 24, 2024 Upendra Utpal 75,000 10 Nil Nil
Trikamal Praful Shah
Shah
5. July 24, 2024 Purnima Utpal 75,000 10 Nil Nil
Upendra Praful Shah
Shah
*Note:
3731. Inter‑promoter share transfers were effected at nil consideration, resulting in changes to individual promoter holdings. Notwithstanding
these changes, the aggregate weighted‑average cost of the transfers remains nil. The said Inter-promoter transfers have not been
included among the last five transactions, as the aggregate number of shares transferred pursuant thereto is nil
2. All other transfers, excluding those among promoters, were effected as gifts in past 3 years and were also made without any
consideration.
c. Based on the above transactions, below are the details of the weighted average cost of acquisition, as
compared to the Floor Price and the Cap Price:
Weighted average cost of
Past Transactions Floor Price (i.e., ₹ [●])* Cap Price (i.e., ₹ [●])*
acquisition (in ₹)
WACA of Primary N.A. [●] [●]
Transactions
WACA of N.A. [●] [●]
Secondary
Transactions
WACA based on the NIL [●] [●]
last five primary or
secondary
transactions**
*To be updated at Prospectus stage
** Inter‑promoter share transfers were effected at nil consideration, resulting in changes to individual promoter holdings. Notwithstanding
these changes, the aggregate weighted‑average cost of the transfers remains nil.
d. Detailed explanation for Issue Price/ Cap Price being [●] times of weighted average cost of acquisition
of primary issuances /secondary transactions of Equity Shares (as disclosed above) along with our
Company’s KPIs and financial ratios for Financial Year ended 2025, 2024 and 2023
[●]*
*To be included on finalisation of Price Band
e. Explanation for the Issue Price/ Cap Price, being [●] times of weighted average cost of acquisition of
primary issuances/secondary transactions of Equity Shares (as disclosed above) in view of the external
factors which may have influenced the pricing of the Issue
[●]*
*To be included on finalisation of Price Band
f. Justification of the Cap Price
[●]*
*To be included on finalisation of Price Band
11. The Issue Price is [●] times of the face value of the Equity Shares.
The Issue Price of ₹ [●] has been determined by our Company in consultation with the BRLM, on the basis of
assessment of demand from investors for Equity Shares through the Book Building Process and, is justified in
view of the above qualitative and quantitative parameters.
Investors should read the above-mentioned information along with “Risk Factors”, “Our Business”, “Financial
Information” and “Management’s Discussion and Analysis of Financial Condition and Results of Operations” on
pages 40, 438, 503 and 578, respectively, to have a more informed view. The trading price of the Equity Shares
could decline due to the factors mentioned in the “Risk Factors” on page 40 and you may lose all or part of your
investments
374STATEMENT OF SPECIAL TAX BENEFITS
To,
The Board of Directors,
Shah Investor’s Home Limited
810, X-Change Plaza,
DSCCSL (53E), Road 5E,
Block 53, Zone 5, Gift City,
Gandhinagar-382355, Gujarat, India
Re: Proposed initial public offering of equity shares of face value of ₹ 10.00 each (the “Equity Shares” and
such offering, the “Issue”) of Shah Investor’s Home Limited (“Company”)
We, Dhrumil A. Shah & Co, Chartered Accountants, the Independent Chartered Accountant of the Company have
been informed by the Company that it proposes to undertake the proposed Issue in accordance with the provisions
of the Securities and Exchange Board of India (Issue of Capital and Disclosure Requirements) Regulations, 2018,
as amended (“ICDR Regulations”) and the Companies Act, 2013, as amended (“Companies Act”).
We have reviewed the restated financial statements of the Company for the financial years ended March 31, 2025,
March 31, 2024 and March 31, 2023 (“Review Period”) which was audited in accordance with the Companies
Act, 2013, as amended and the rules framed thereunder, the Indian Accounting Standards prescribed under Section
133 of the Companies Act, 2013 read with the Companies (Indian Accounting Standards) Rules, 2015 and other
accounting principles generally accepted in India and restated in accordance with the Securities and Exchange
Board of India (Issue of Capital and Disclosure Requirements) Regulations, 2018, as amended (the “Restated
Consolidated Financial Statements”)and the examination report dated September 05, 2025 in respect of the
Restated Financial Statements (“Examination Report”).
Management Responsibility
The preparation of the information relied on for the purpose of this certificate / the preparation of this statement
is the responsibility of the Management of the Company. This responsibility also includes maintenance of all
accounting & other records supporting its contents; designing, implementing & maintaining adequate internal
control relevant to the size & nature of company that were operating effectively for ensuring the accuracy,
authenticity & completeness of the accounting records; making estimates that are reasonable in the circumstances
and providing data for verification which is free from any kind of misstatements & errors for reliance by Auditor.
The Management is also responsible for ensuring, with respect to matters disclosed in the certificate, correct
identification of details / information required, true & correct determination of facts and figures and accuracy &
authenticity in the content and intent so that the certificate serves the desired purpose to the users.
The management is also responsible for ensuring that the Company complies with the requirements of the
Companies Act, 2013 (the “Companies Act”); the Securities and Exchange Board of India (Issue of Capital and
Disclosure Requirements) Regulations, 2018, as amended from time to time (the “ICDR Regulations”) and the
Guidance Note on Reports in Company Prospectuses (Revised 2019) issued by ICAI, amended from time to time
(the “Guidance Note”) and other relevant regulations in connection with the proposed Issue.
Auditor’s Responsibilities
We have conducted my examination in accordance with the “Guidance Note on Reports or Certificates for Special
Purposes (Revised 2016)” and “Guidance Note on Certificates in Company Prospectus (Revised 2019)”
(“Guidance Notes”) issued by the Institute of Chartered Accountants of India. The Guidance Note requires that
we comply with ethical requirements of the Code of Ethics issued by the Institute of Charted Accountants of India.
We have also complied with the relevant applicable requirements of the Standard on Quality Control (SQC) 1,
Quality Control for Firms that Perform Audits and Reviews of Historical Financial information, and Other
Assurance and Related Services Engagements.
We further report that the information above is true and correct and is in accordance with the requirements of the
Companies Act, 2013 as amended, the SEBI (ICDR) Regulations and other applicable law and there is no untrue
statement or omission which would render the contents of this certificate misleading in its form or context.
375We undertake to immediately communicate, in writing, any changes to the above information / confirmations, as
and when: (i) made available to us; or (ii) we become aware of any such changes, to the BRLM and the Company
until the Equity Shares issued by the company pursuant to the issue commence trading on the Stock Exchanges.
In the absence of any communication from us the above information should be considered as updated information
until the Equity Shares issued pursuant to the Issue, commence trading on the Stock Exchanges.
Conclusion
We hereby report that the enclosed Annexure I prepared by the Company, initiated by us and the Company for
identification purpose, states the possible special tax benefits available to the Company and its shareholders, under
direct and indirect taxes (together “the Tax Laws”), presently in force in India as on the signing date, which are
defined in Annexure I. These possible special tax benefits are dependent on the Company and its shareholders
fulfilling the conditions prescribed under the relevant provisions of the Tax Laws. Hence, the ability of the
Company and its shareholders to derive these possible special tax benefits is dependent upon their fulfilling such
conditions, which is based on business imperatives the Company may face in the future and accordingly, the
Company and its shareholders may or may not choose to fulfill.
The benefits discussed in the enclosed Annexure II cover the possible special tax benefits available to the
Company and its shareholders but does not cover any general tax benefits available to the Company and its
shareholders. Further, the preparation of the enclosed Annexure II and its contents is the responsibility of the
management of the Company and is not exhaustive. I was informed that the Statement is only intended to provide
general information to the investors and is neither designed nor intended to be a substitute for professional tax
advice. In view of the individual nature of the tax consequences and the changing Tax Laws, each investor is
advised to consult his or her own tax consultant with respect to the specific tax implications arising out of their
participation in the proposed initial public offering of equity shares of the Company comprising a fresh issue of
the Equity Shares by the Company particularly in view of the fact that certain recently enacted legislation may
not have a direct legal precedent or may have a different interpretation on the possible special tax benefits, which
an investor can avail. Neither we are suggesting nor advising the investors to invest money based on this
Statement.
Restriction on use
This certificate is for information and for inclusion (in part or full) in the draft red herring prospectus (“DRHP”)
of the Company to be submitted/filed with the Securities and Exchange Board of India (“SEBI”) and any relevant
Stock Exchanges, and the red herring prospectus (“RHP”) and the prospectus (“Prospectus”) which the Company
intends to file with the Registrar of Companies, Gujarat at Ahmedabad (“RoC”) and thereafter file with the SEBI
and the Stock Exchanges and in any other document in relation to the Issue (collectively, the “Issue Documents”)
or any other Issue related material, and may be relied upon by the Company, the BRLM and the Legal counsel to
the Issue. We hereby consent to the submission of this certificate as may be necessary to the SEBI, the RoC, the
Stock Exchanges and any other regulatory authority and/or for the records to be maintained by the BRLM and in
accordance with applicable law. We hereby consent to this certificate being disclosed by the Book Running Lead
Manager, if required (i) by reason of any law, regulation or order of a court or by any governmental or competent
regulatory authority, or (ii) in seeking to establish a defence in connection with, or to avoid, any actual, potential
or threatened legal, arbitral or regulatory proceeding or investigation.
We confirm that the information in this certificate is true, accurate, not misleading and without omission of any
matter that is likely to mislead and is adequate to enable investors to make a well-informed decision.
This certificate may be relied upon by the Company, the BRLM, and the legal counsel appointed by the Company
and the BRLM in relation to the Issue and to assist the BRLM in conducting and documenting their investigation
of the affairs of the Company in connection with the Issue. We hereby consent to extracts of, or reference to, this
certificate being used in the Issue Documents or any other documents in connection with the Issue. We also
consent to the submission of this certificate as may be necessary, to any regulatory authority and/or for the records
to be maintained by the BRLM in connection with the Issue and in accordance with applicable law.
Further, We consent to this certificate being uploaded, as may be necessary, as part of the back-up documents to
be retained in relation to the Issue on the online document repository platform established by each of the Stock
Exchanges, in accordance with SEBI Circular No. SEBI/HO/CFD/CFD-TPD-1/P/CIR/2024/170 dated December
5, 2024, as amended.
376This certificate has been prepared at the request of the company solely for the purpose of the Issue and addressed
to intended & identified users. This certificate should not be used by any other person or for any other purpose.
Accordingly, we do not accept or assume any liability or any duty of care for any other purpose or to any other
person to whom this report is shown or into whose hands it may come without my prior consent in writing.
For, Dhrumil A. Shah & Co,
FRN Number: 145163W
Independent Chartered Accountant
Dhrumil A. Shah
Proprietor
Membership No.: 166079
UDIN: 25166079BMLJBZ7695
Place of Signature: Ahmedabad
Date: September 29, 2025
Encl: As above
377ANNEXURE I
STATEMENT OF POSSIBLE TAX BENEFITS AVAILABLE TO COMPANY, ITS SHAREHOLDERS AND
ITS MATERIAL SUBSIDIARY UNDER THE INCOME TAX ACT, 1961
The statement of possible direct tax benefits enumerated below is as per the Income-tax Act, 1961 (“the Act”) as
amended by the Finance Act, 2024 applicable for the Financial Year 2025-26 relevant to the Assessment Year 2026-
27, presently in force in India.
This statement sets out below the possible tax benefits available to the Company, its material subsidiary and its
Shareholders to whom shares may be allotted in terms of proposed Issue under the tax laws presently in force in India.
Several of these benefits are dependent on fulfilling various conditions prescribed under the relevant tax laws.
Accordingly, the ability of the Company, its material subsidiary and its shareholders to derive the tax benefits is
dependent upon fulfilling such conditions, which are based on the business imperatives, the Company, its material
subsidiary or the shareholders may or may not choose to fulfil.
A. Possible tax benefits available to the Company and its material subsidiary
1) Benefit of lower tax rate under Section 115BAA of the Act
Section 115BAA of the Act provides an option to a domestic company to pay corporate tax at a reduced rate of
22% (plus applicable surcharge of 10% and health & education cess of 4% on tax and surcharge). In case the
Company and its material subsidiary opts for concessional income tax rate as prescribed under section 115BAA
of the Act, it will not be allowed to claim any of the following deductions/ exemptions:
(i) Deduction under the provisions of section 10AA (deduction for units in Special Economic Zone)
(ii) Deduction under clause (iia) of sub-section (1) of section 32 (Additional depreciation)
(iii) Deduction under section 32AD or section 33AB or section 33ABA (Investment allowance in backward areas,
Investment deposit account, site restoration fund)
(iv) Deduction under sub-clause (ii) or sub-clause (iia) or sub-clause (iii) of sub-section (1) or subsection (2AA)
or sub-section (2AB) of section 35 (Expenditure on scientific research)
(v) Deduction under section 35AD or section 35CCC (Deduction for specified business, agricultural extension
project)
(vi) Deduction under section 35CCD (Expenditure on skill development)
(vii) Deduction under any provisions of Chapter VI-A other than the provisions of section 80JJAA
(Deduction in respect of employment of new employees) and 80M (Deduction in respect of certain inter-corporate
dividends)
(viii) No set-off of any loss carried forward or depreciation from any earlier assessment year, if such loss or
depreciation is attributable to any of the deductions referred above.
(ix) No set-off of any loss or allowance for unabsorbed depreciation deemed so under section 72A, if such loss or
depreciation is attributable to any of the deductions referred from point i to vii above.
The provisions of section 115JB with respect to Minimum Alternate Tax (“MAT”) are not applicable where the
Company and its material subsidiary opt for the concessional income tax rate as prescribed under section 115BAA
of the Act. Further, the Company and its material subsidiary will not be entitled to claim tax credit relating to MAT
u/s 115JAA of the Act. As per the provisions of the Act, once such option has been exercised for any previous
year, it cannot be subsequently withdrawn for the same or any other previous year.
Note: The Company and its material subsidiary have opted the lower tax rate u/s 115BAA of the Act in the FY
2020-21 relevant to the AY 2021-22 as mentioned in the Section 115BAA for which declaration (Form 10-IC) has
already been filed with the tax authorities within the prescribed due date. Hence, the Company and its material
subsidiary shall continue to pay tax for the subsequent assessment years at the concessional tax rate as prescribed
u/s 115BAA.
2) Deduction in respect of inter-corporate dividends – Section 80M of the IT Act:
378With respect to a shareholder which is a domestic company as defined in section 2(22A), and section 80M of the
IT Act inter-alia provides that where the gross total income of a domestic company in any previous year includes
any income by way of dividends from any other domestic company or a foreign company or a business trust, there
shall, in accordance with and subject to the provisions of this section, be allowed in computing the total income
of such domestic company, a deduction of an amount equal to so much of the amount of income by way of
dividends received from such other domestic company or foreign company or business trust as does not exceed
the amount of dividend distributed by it on or before the due date. The "due date" means the date one month prior
to the date for furnishing the return of income under sub-section (l) of section 139 of the IT Act.
B. Possible tax benefits available to the Shareholders
1) Resident shareholder
Tax on dividend income
- Dividend income earned by the shareholders should be taxable in their hands at the rates applicable to such
shareholders, in accordance with the provisions of the Act.
- In the case of domestic corporate shareholders, deduction under section 80M of the Act should be available on
fulfilling the conditions by such shareholder.
- In the case of buy-back of shares by the company, the sale consideration received shall be treated as deemed dividend
as per section 2(22)(f) of the Act. Further, consideration received by the shareholders pursuant to the buy-back will
be deemed as ‘NIL’ and the cost of acquisition of the shares bought back would result in a ‘capital loss’ for the
shareholders. Such ‘capital loss’ will be available to be carried forward for eight (8) subsequent financial years and
eligible for set-off in accordance with the applicable set-off provisions.
The Company will withhold tax at the rate of 10% on payment of dividend to shareholders.
Tax on Long-term capital gains
- Where the shares of a company listed on recognised stock exchange in India are held for more than 12 months, the
same shall qualify as long-term capital asset.
- As per section 112A of the Act, long-term capital gains in excess of INR 1,25,000 arising inter-alia from transfer of
an equity share through the recognized stock exchange which takes place on or after July 23, 2024, shall be taxed at
12.5% (plus applicable surcharge and cess), without indexation subject to fulfilment of prescribed conditions under
the Act.
Tax on Short-term capital gains
- Where the shares of a company listed on recognised stock exchange in India are held for less than or equal to 12
months, the same shall qualify as short-term capital asset.
As per section 111A of the Act, short-term capital gains arising inter-alia from transfer of an equity share through the
recognized stock exchange which takes place on or after July 23, 2024, shall be taxed at 20% (plus applicable
surcharge and cess) subject to fulfilment of prescribed conditions under the Act.
2) Non-Resident shareholder
In respect of non-residents, the tax rates and the consequent taxation mentioned above shall be further subject to any
benefits available under the applicable double taxation avoidance agreement, if any, between India and the country in
which the non-resident has fiscal domicile and also subject to non-resident having necessary documentation as
required under the IT Act.
Notes:
3791. This statement sets out below the provisions of law in a summary manner only and is not a complete analysis or
listing of all potential tax consequences/implications of the subscription, ownership and disposal of equity shares
pursuant to the proposed Issue. This statement is only intended to provide general information to the shareholders and
is neither exhaustive or comprehensive nor designed or intended to be a substitute for professional/legal tax advice.
In view of the individual nature of tax consequences and the changing tax laws, each shareholder is advised to consult
their own tax consultant with respect to the specific tax implications arising out of their participation in the issue.
2. In respect of non-residents, the tax rates and the consequent taxation, mentioned in this section shall be further
subject to any benefits available under the Double Taxation Avoidance Agreement (DTAA), if any, read with the
relevant Multi-Lateral Instrument (MLI) between India and the country in which the non-resident is resident for tax
purposes.
3. The above Statement covers possible tax benefits under the Act, read with the relevant rules, circulars and
notifications and does not cover any benefit under any other law in force in India. This Statement also does not discuss
any tax consequences, in the country outside India, of an investment in the shares of an Indian company. The above
Statement of possible tax benefits sets out the provisions of Indian tax laws in a summary manner only and is not a
complete analysis or listing of all potential tax consequences of the purchase, ownership and disposal of shares.
4. This statement is only intended to provide general information to the shareholder and is neither designed nor
intended to be a substitute for professional tax advice. In view of the individual nature of the tax consequences, the
changing tax laws, each shareholder is advised to consult his or her own tax consultant with respect to the specific tax
implications arising out of their participation in the proposed issue.
5. No assurance is given that the revenue authorities/courts will concur with the views expressed herein. The
Company’s views are based on the existing provisions of law and its interpretation, which are subject to changes from
time to time. The Company do not assume responsibility to update the views consequent to such changes. The above
views are basis the provisions of law, their interpretation and applicability as on date, which may be subject to change
from time to time.
380ANNEXURE II
STATEMENT OF POSSIBLE TAX BENEFITS AVAILABLE TO COMPANY, ITS MATERIAL
SUBSIDIARY AND ITS SHAREHOLDERS UNDER THE INDIRECT TAX LAWS
Outlined below are the possible tax benefits available to the Company, its material subsidiary and its shareholders
under the Indirect tax laws in force in India. This statement is as per the Central Goods and Services Tax Act,
2017, the Integrated Goods and Services Tax Act, 2017, respective State Goods and Services Tax Act, 2017, the
Customs Act, 1962 and the Customs Tariff Act, 1975, as amended by Finance Act 2024 including the relevant
rules, notifications and circulars issued there under applicable for the Financial Year 2024-25 and Foreign Trade
Policy, 2023 presently in force in India.
There is no Special Tax Benefits available to the company, its material subsidiary and its Shareholders.
381SECTION IV – ABOUT THE COMPANY
INDUSTRY OVERVIEW
Economic Outlook
Trends in global economy
Global growth, which reached 3.5% in CY23, is estimated to stabilize at 3.3% for CY24 and projected to decrease at 2.8% for
CY25. Global trade is expected to be disrupted by new US tariffs and countermeasures from trading partners, leading to
historically high tariff rates and negatively impacting economic growth projections. The global landscape is expected to change
as countries rethink their priorities and policies in response to these new developments. Central banks priority will be to adjust
policies, while smart fiscal planning and reforms are key to handling debt and reducing global inequalities.
Chart 1: Global Growth Outlook Projections (Real GDP, Y-o-Y change in %)
CY20 CY21 CY22 CY23 CY24E CY25P CY26P CY27P CY28P CY29P CY30P
World -2.7% 6.6% 3.6% 3.5% 3.3% 2.8% 3.0% 3.2% 3.2% 3.2% 3.1%
Advanced Economies -4.0% 6.0% 2.9% 1.7% 1.8% 1.4% 1.5% 1.7% 1.7% 1.7% 1.7%
Emerging Market and Developing
-1.7% 7.0% 4.1% 4.7% 4.3% 3.7% 3.9% 4.2% 4.1% 4.1% 4.0%
Economies
Source: IMF – World Economic Outlook, July 2025; Notes: P-Projections, E-Estimated
GDP growth rates of key developed and emerging economies
Table 1: GDP growth trend comparison - India v/s Other Economies
Real GDP (Y-o-Y change in %)
CY20 CY21 CY22 CY23 CY24 CY25P CY26P CY27P CY28P CY29P CY30P
India -5.8 9.7 7.6 9.2 6.5 6.4 6.4 6.5 6.5 6.5 6.5
China 2.3 8.6 3.1 5.4 5 4.8 4.2 4.2 4.1 3.7 3.4
Indonesia -2.1 3.7 5.3 5 5 4.8 4.8 4.9 5 5.1 5.1
Saudi Arabia -3.6 5.1 7.5 -0.8 1.3 3.6 3.9 3.6 3.2 3.2 3.3
Brazil -3.3 4.8 3 3.2 3.4 2.3 2.1 2.2 2.3 2.4 2.5
Euro Area -6 6.3 3.5 0.4 0.9 1 1.2 1.3 1.3 1.2 1.1
United States -2.2 6.1 2.5 2.9 2.8 1.9 2 2 2.1 2.1 2.1
Middle East -2.2 4.4 5.5 2.2 2.4 3.4 3.5 4 3.7 3.7 3.7
Latin America -6.9 7.4 4.2 2.4 2.4 2.2 2.4 2.7 2.7 2.7 2.6
Source: IMF- World Economic Outlook Database (July 2025)
Note: P- Projections, E-Estimated; India's fiscal year (FY) aligns with the IMF's calendar year (CY). For instance, FY24
corresponds to CY23.
382
)%
Y-o-Y(
htworg
PDGIndia focus – one of the fastest growing major economies in the world
Chart 2: Trend in Indian Real GDP growth rate
2,50,000 12.0%
9.7%
9.2%
10.0%
7.6% 7.8%
2,00,000 6.5% 6.50% 6.5% 6.5% 8.0%
0 6.0%
11 ,, 05 00 ,, 00 00 00 9 2 9 ,9 3 ,1 3. 6 4 3 ,5 4 ,19% 9 4 9 ,6 3 ,1 8 1 2 ,0 5 ,1 9 4 6 ,1 6 ,1 6 0 5 ,6 7 ,1 7 9 ,7 8 ,1 8 8 1 ,0 0 ,2 7 1 4 ,4 6 8 8 ,7 -024 2... 000 .0%%% %
4 4
50,000 -5.8% -4.0%
-6.0%
- -8.0%
FY19 FY20 FY21 FY22 FY23 FY24 FY25 FY26F Q1FY25 Q1FY26
(FE) (FRE) (PE)
Real GDP (in Rs billion) Y-o-Y growth (in %)
Source: MOSPI; Note: SAE – Second Advance Estimates, FE – Final Estimate, FAE- First Advance Estimate
India's real GDP grew by 9.2% in FY24 (Rs. 176,506 billion) which is the highest in the previous 12 years (excluding FY22
being 9.7% on account of end of pandemic) and is estimated to grow by 6.5% in FY25 (Rs. 187,970 billion), driven by
double digit growth particularly in the Manufacturing sector, Construction sector and Financial, Real Estate & Professional
Services. This growth is also led by private consumption increasing by 7.6% and government spending increasing by 3.8%
Y-o-Y.
In Q1FY26, real GDP grew by 7.8% y-o-y as compared to 6.5% y-o-y in the previous year’s quarter. Real GDP growth is
projected at 6.5% in FY26 as well, driven by strong rural demand, improving employment, and robust business activity.
Macroeconomic outlook (August 2025)
GDP Growth Outlook
FY26 GDP Outlook: The RBI projects real GDP growth at 6.5% for 2025–26, driven by strong private consumption,
steady investment, and resilient rural and urban demand. A favourable monsoon, robust services sector and improving
corporate balance sheets support this outlook.
However, risks from prolonged geopolitical tensions, global trade disruptions, and weather-related uncertainties
remain. Taking these into account, the RBI has reaffirmed its growth projections
Table 2: RBI's GDP Growth Outlook (Y-o-Y %)
FY26P (complete year) Q1FY26P Q2FY26P Q3FY26P Q4FY26P Q1FY27P
6.5% 6.5% 6.7% 6.6% 6.3% 6.6%
Source: Reserve Bank of India; Note: P-Projected
Key structural reforms: long term positives for the Indian economy
• Foreign Direct Investment (FDI)
383FDI is a critical non-debt financial resource for India’s economic growth, contributing long-term capital and technological
expertise. Post-liberalization, FDI inflows have risen consistently, positioning India among the top global recipients with
cumulative inflows surpassing USD 1 trillion by 2024. As of Aug’25, India's forex reserves stood at USD 690.72 billion,
contributing to more than 90% of its external debt of USD 736.3 billion (as at Mar-25). The renewable energy sector attracted
USD 21.33 billion in FDI between April 2000 to March 2025, bringing in advanced technology and enabling cost-effective,
efficient solutions.
• Make in India
Launched in 2014, the Make in India initiative aimed to transform India into a global manufacturing hub. The country emerged
as the world’s second-largest mobile phone manufacturer, with domestic production rising from 26% in FY15 to 99.2% by
Mar’25 (from Rs 4.22 lakh crore in FY24 to Rs 5.25 lakh crore in FY25), and the number of units increasing from 2 to over
300 units. The initiative bolstered capital goods and defence manufacturing, with the latter reaching Rs. 146 lakh crore in
FY25, including exports to over 90 countries demonstrating rising indigenous capabilities and competitiveness.
• Privatization
India’s privatization and asset monetization strategies have significantly enhanced operational efficiency, attracted private
sector capital, and generated funds for infrastructure. The 2021 policy shift towards privatizing PSEs in non-core sectors was
a structural move aimed at reducing government footprint while strengthening strategic sectors. Proceeds from disinvestment
have supported various public welfare and infrastructure programs.
• Direct Benefit Transfer (DBT)
Introduced in 2013, the DBT scheme has transformed welfare delivery by leveraging digital infrastructure to transfer benefits
directly into beneficiaries' bank or postal accounts. This mechanism has led to cumulative savings of Rs.3.48 lakh crore by
eliminating leakages and ghost beneficiaries. The subsidy’s share in total expenditure reduced from 16% to 9%, reflecting
better targeting and fiscal prudence.
• JAM Trinity
The Jan Dhan–Aadhaar–Mobile (JAM) Trinity underpins digital governance in India. It has enabled seamless, real-time
delivery of subsidies through DBT, minimized fraud via Aadhaar-based authentication, and promoted financial inclusion. By
bringing millions into the banking ecosystem, JAM has enhanced access to credit, facilitated digital payments, and accelerated
the transition towards a cashless economy.
• Union Budget 2025-26
With the growing population, the long-term need for robust infrastructure is necessary for economic development. This
generates the need for massive investments in the development and modernization of infrastructure facilities, which will not
only cater to the growing demand but will also ensure competitiveness in the global market.
384Chart 3: Budgetary outlay towards infrastructure
11,111 11,211
9,502
7,283
n 5,929
o
illiB
.s
4,263
R
3,357
FY20 FY21 FY22 FY23 FY24 FY25 FY26
Others 1,914 2,197 3,533 3,061 3,831 5,086 5,358
Power 16 4 28 0 1 11 7
Ports 3 2 6 7 11 13 18
Oil & Gas 6 23 3 0 0 3 66
Telecom 57 53 53 562 594 750 518
Railways 678 1,093 1,173 1,593 2,426 2,522 2,522
Roads and Highways 684 892 1,133 2,060 2,639 2,725 2,722
Total 3,357 4,263 5,929 7,283 9,502 11,111 11,211
Source: Union Budget FY26 document
Some of the key government infrastructure schemes include:
The government has announced plans for the National Monetization Pipeline (NMP) and Development Finance Institution
(DFI) to improve the financing of infrastructure projects.
The government has helped the growth of urbanization through several schemes and projects, including the Smart Cities
Mission, the Atal Mission for Rejuvenation and Urban Transformation (AMRUT), and the Pradhan Mantri Awas Yojana
(Urban).
Key growth drivers for India
1. Favourable Demographics
The trajectory of economic growth of India and private consumption is driven by socio-economic factors such as demographics
and urbanization. According to the world bank, India’s population in 2022 surpassed 1.42 billion slightly higher than China’s
population 1.41 billion and became the most populous country in the world.
Age Dependency Ratio is the ratio of dependents to the working age population, i.e., 15 to 64 years, wherein dependents are
population younger than 15 and older than 64. This ratio has been on a declining trend. It was as high as 76% in 1983, which
has reduced to 47% in 2023. Declining dependency means the country has an improving share of working-age population
generating income, which is a good sign for the economy.
385Chart 4: Trend of India Population vis-à-vis dependency ratio
2.5 76% 71% 80%
63%
2.0 54% 54%
47% 47% 46% 46% 45% 60%
1.5
40%
1.0
0.5 5 7 .0 3 9 .0 2 1 .1 9 2 .1 3 4 .1 5 4 .1 6 4 .1 7 4 .1 9 4 .1 2 5 .1 20%
0.0 0%
1983 1993 2003 2013 2023 2024 2025 2026 2027 2036
Population (Billion) Dependency Ratio (%)
Source: World Bank Database
Despite a projected rise in the dependency ratio to 54% by 2036, India’s young and growing workforce, especially in newly
urbanised towns, will continue to drive income growth and consumer demand. This presents strong opportunities for sectors
like consumer electronics, transportation, and railways. Rising employment, urbanisation, and government investment in rural
development and digital infrastructure will further boost demand, while increased tech adoption supports long-term
consumption growth across both urban and rural markets.
Chart 5: Age-Wise Break Up of Indian population
6.0% 6.3% 6.5% 6.7% 6.8% 6.9% 6.9% 7.1% 7.4% 7.6% 7.8%
66.4% 66.7% 66.9% 67.2% 67.5% 67.8% 68.0% 68.2% 68.4% 68.6% 68.8%
27.6% 27.1% 26.6% 26.1% 25.7% 25.3% 25.1% 24.9% 24.4% 24.0% 23.6%
2017 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027
Population ages 0-14 Population ages 15-64 Population ages 65 and above
Source: World Bank Database
2. Urbanisation: Largest population, Large demographic dividend with high share of young population
The urban population is significantly growing in India. The urban population in India is estimated to have increased from 41.3
crore (32% of total population) in 2013 to 51.95 crore (36.4% of total population) in the year 2023. India is undergoing a
significant urban transformation, with the urban population projected to rise to 40% by 2036. This shift is driven by factors
such as improved living standards, increased employment opportunities in urban areas, and government initiatives aimed at
urban development. This rapid urbanisation might necessitate substantial investments in infrastructure, housing, and
transportation.
Chart 6: Urbanisation Trend in India
386la 40.0%
t
o
t 38.5%
f o 37.9%
37.4%
% ) 36.90%
(n 36.4%
n o it a luo it a lu p
o 33.6%
34.0% 34.5% 34.9% 35.4% 35.9%
pp
o
p
n
a
b
r
U
2017 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 2036
Source: World Bank Database
3. Increasing per capita GDP
Gross National Disposable Income (GNDI) is a measure of the income available to the nation for final consumption
and gross savings. Between the period FY15 to FY25, per capita GNDI at current prices registered a CAGR of 9.0%.
More disposable income drives more consumption, thereby driving economic growth.
With increase in disposable income, there has been a gradual change in consumer spending behaviour as well. Per
capita Private Final Consumption Expenditure (PFCE) which is measure of consumer spending has also showcased
significant growth from FY15 to FY25 at a CAGR of 9.7%.
Chart 7: Trend of Per Capita GNDI and Per Capita PFCE (Current Price)
3,00,000
2,50,000
0
2,00,000 2 7 2
7
1
3
,8
s
R n I 11 ,, 505 000 ,,, 000 000 000 9 3 4 ,0
0
,1
1 0 2
,7
5
5 1 3 ,9
0
,1
9 3 3
,3
6
2 5 0 ,0 2
,1
8 5 2
,0
7
3 4 7 ,1 3 ,1 9 7 3
,6
7
0 2 6 ,4 4 ,1 1 4 4
,4
8
4 0 5 ,2 5 ,1 5 1 3
,1
9
8 0 4 ,8 4 ,1 1 4 6
,9
8
6 1 8 ,4 7 ,1 2 9 0 ,5
0
,1
9
6 ,7 9 ,1 6 1 5 ,9 1
,1
,9
1 ,2 7 6 9 ,9 2 ,1
3
,2 5 6 1 ,4 4 ,1
-
FY15 FY16 FY17 FY18 FY19 FY20 FY21 FY22 FY23 [FE] FY24 FY25 [PE]
[FRE]
Per Capita GNDI Per capita PFCE
Source: MOSPI; Note: FRE – First Revised Estimates, FE – Final Estimate, SAE-Second Advance Estimate
3874. Household savings
Household savings in India have grown at an 8.8% CAGR since FY18, reaching Rs. 54.6 billion in FY24, a 9% y-o-y increase.
A shift toward physical assets, particularly housing and gold/silver ornaments, reflects a preference for tangible investments
amid high inflation and slow growth in monetary assets.
This trend is driven by heavy borrowing, especially in housing, auto, and personal loans, leading to a six-year high in
household financial liabilities. Savings in mutual funds and life insurance also grew, with an 11.5% and 13.6% y-o-y increase,
respectively, while investment in equities and capital market instruments rose as they offer higher returns than bank deposits.
Chart 8: Household Savings (at Current Prices)
54.6
50.1
47.4
45.1
38.4 38.5
n
o 33.0
illiB
s
R
FY18 FY19 FY20 FY21 FY22 FY23 FY24
Source: MOSPI
In recent years, India has witnessed growth in household savings and shift of savings from physical assets like real estate to
financial instruments. This trend, often referred to as financialization, is reshaping the landscape of domestic savings and
investments. Several factors have facilitated this transition towards financial assets.
The increased financialization aids in infrastructure development and economic stability, as it helps fund capital expenditure
(capex) cycles without exacerbating the current account deficit (CAD) or heightening external vulnerabilities.
Furthermore, financial inclusion efforts, enhanced digital infrastructure, the demonetization initiative, and innovations in
financial products have all played a role in financialization. The growth of financial savings has been robust, with retirement
savings, insurance, and mutual funds showing an impressive average annual growth rate over the past decade. Additionally,
the rising participation of youth in India's capital markets also reflect a significant shift in financial behaviour.
5. Digitalization
Digital payments in India grew in volume from 4,371 crores in FY21 to 22,198 crores in FY25, with a CAGR of 50.1%.
Digital payments in value grew from Rs 1,415 lakh crores in FY21 to Rs 2,862 lakh crores in FY25, with a CAGR of 19.3%.
388Chart 9: Digital payment transactions by value and volume
By value
s
e
r
o 2,862
r
C 2,428
2,087
h 1,744
k 1,415
a
L
s
R
FY21 FY22 FY23 FY24 FY25
By volume
e
r
o
r
C 22,198
n
i 16,443
s
e 11,395
r
u 7,195
g 4,371
iF
FY21 FY22 FY23 FY24 FY25
Source: RBI
India's digital transformation is driven by factors like expanding broadband, affordable data, and government initiatives. The
launch of UPI revolutionized payments in turn enhancing financial inclusion. With over 647 banks integrated and more than
35 crore unique users, UPI has become the country’s largest digital payment network BHIM further advanced cashless
transactions, while platforms like COWIN showcased digital infrastructure's role in public health. Furthermore, DigiLocker
improved paperless governance by securely storing documents and FASTag automated toll payments, supporting the cashless
economy.
The Digital India initiative, launched in 2015, focuses on digital infrastructure, governance, and empowerment, making
services more accessible and promoting financial inclusion. Additionally, this initiative has also made stock market and mutual
fund investments more accessible, efficient, and transparent for a wider audience. As of March 2025, the RBI's Digital
Payments Index (DPI) reached 493.22, reflecting a 6.0% growth, driven by advancements in payment performance and
infrastructure.
389Chart 10: Digital Payment Index
600 30.0%
500 25.0%
24.3%
2
2
34 00 00 19.8%
3
.9
14.9%6 4 .7
7
7
5 .5 9
3
7 7 .8
1 4
5 .5 4 4
3
3 .5 6 4
.3
9 4 12 50 .. 00 %%
4 3
6 3
0
9 .4 12.4%
5 0
200 4
.0
7
3
10.0%
4 7 2
8 .7 .7
1
8.1%
0 2 2 5.9% 6.4% 6.0%
100 4.8% 4.8% 4.5% 5.0%
0 0.0%
Mar-20 Sep-20 Mar-21 Sep-21 Mar-22 Sep-22 Mar-23 Sep-23 Mar-24 Sep-24 Mar-25
Source: RBI
6. Financial awareness and literacy
Financial literacy is crucial for fostering economic stability and prosperity, particularly in a rapidly developing nation like
India. As urbanization and economic growth accelerate, understanding financial concepts such as risk diversification,
compound interest, savings discipline, and credit management becomes increasingly important. Despite recent advancements
in technology and media coverage, there is great potential for improving India's financial literacy rate, which could lead to
positive outcomes for individuals and strengthen the broader economy.
The Indian government and various regulators are implementing financial literacy courses, workshops, and schemes aimed at
enhancing financial awareness. Promoting financial education is vital for empowering individuals, reducing financial
vulnerabilities, and fostering economic resilience.
• National Centre for Financial Education (NCFE): promoted by the Financial Literacy and Education Initiative (FLEI)
of the government, aims to enhance financial literacy across India through various educational programs and initiatives.
• Financial Literacy Centre (FLC): FLCs, set up by commercial banks at the district level, conduct monthly camps to
promote financial literacy in rural communities.
RBI Kehta Hai Initiative & PFRDA's 'Pension Sanchay' website: The RBI’s financial literacy campaign uses multiple
media to educate the public on banking services, digital banking, and CBDC, while PFRDA’s Annuity Literacy Program helps
subscribers understand retirement annuity options.
7. Growing financial inclusion in India
Number of accounts opened through Pradhan Mantri Jan Dhan Yojana (PMJDY) grew at a CAGR of 7% between Mar’20 to
Aug’25, reflecting steady growth and improving financial inclusion. Notably, deposit amount in PMJDY accounts grew at a
CAGR of 13.1% over the same period, indicating strong and consistent growth in funds.
390Chart 11: Pradhan Mantri Jan Dhan Yojayana number of accounts and deposits
n
o
illiM
n
i
s
t
n
u
o
c
c
a
f
o
o
N
Mar'20 Mar'21 Mar'22 Mar'23 Mar'24 Mar'25 Aug'25
PMJDY accounts
2.6
n
o 2.3 2.3
illir
2.0
T
1.7
s R 1.5
n 1.2
i
s
t
is
o
p
e
D
Mar'20 Mar'21 Mar'22 Mar'23 Mar'24 Mar'25 Aug'25
Deposits under PJDMY
Source: PMJDY; Note: FY25 data is as on 2nd April 2025
Overview of Capital Market in India
Overview of performance of capital markets in India in the last few years
India's capital markets, including stock, bond, derivative markets, and mutual funds, have significantly influenced the nation’s
financial system and economic development. Notably, the Bombay Stock Exchange (BSE) Limited is ranked as 6th largest
stock exchange and National Stock Exchange of India Limited (NSE) ranked as 7th largest stock exchange in the world by
market capitalisation as of Jun’25.
Reforms introduced by the Securities and Exchange Board of India (SEBI) have significantly enhanced transparency, protected
investor interests, and boosted market efficiency. The primary market has recorded significant growth especially in the
contributions from Initial Public Offerings (IPOs) segment, driven by investor trust, efficiency, and transparency of capital
markets. Additional, commodity and currency market have also witnessed remarkable traction.
Favourable macroeconomic fundamentals—including sustained corporate earnings growth, a young demographic profile, and
rising consumer expenditure—have bolstered investor participation, both domestic and international. Foreign Portfolio
Investments (FPIs) have enhanced market liquidity and valuations, with the Nifty 50 registering healthy earnings growth over
the past two decades, outperforming several major global indices.
The mutual fund sector has also expanded due to greater financial literacy and digital adoption, with number of folios reaching
24.1 crore as of Jun’25, indicating a CAGR of 20.7% between FY20-Q1FY26. Net inflows in mutual funds stood at Rs 3.6
lakh crore as of Jun’25. New instruments, such as Real Estate Investment Trusts (REITs) and Infrastructure Investment Trusts
(INVITs), have created additional investment opportunities.
Overall, India's capital markets are becoming increasingly dynamic and inclusive through technological advancements,
regulatory changes, and a growing investor base. However, capital markets around the world are susceptible to macroeconomic
391risks and geo-political tensions. Episodes such as the COVID-19 pandemic, general elections, and international conflicts have
led to heightened volatility, emphasising the need for robust risk management frameworks and policy consistency.
Indian stock markets on growth trajectory
Chart 12: BSE (Sensex) and NSE (Nifty) performance trends
Mar-25; 77,415
Bottom of Covid-19
Mar-20; 29,468 Mar-25; 23,519 x
y e
t s
f iN n
e
S
Mar-20; 8,598
9 9 9 0 0 0 0 1 1 1 1 2 2 2 2 3 3 3 3 4 4 4 4 5 5
1 1 1 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2
- - - - - - - - - - - - - - - - - - - - - - - - -
n p c r n p c r n p c r n p c r n p c r n p c r n
u e e a u e e a u e e a u e e a u e e a u e e a u
J S D M J S D M J S D M J S D M J S D M J S D M J
Source: NSE, BSE, CareEdge Research
From bottom of Covid-19 (Mar’20) till Jun’25, both the BSE Sensex and NSE Nifty indices witnessed significant growth at a
CAGR of 21.9% and 23.0% respectively, despite encountering periods of fluctuation. This impressive post-pandemic recovery
can be linked to economic rebound, and strong corporate earnings, although there were some setbacks related to inflation and
global economic uncertainties. Additionally, a growing interest from investors in capital markets has contributed to this upward
trend.
Nifty 50 recorded highest five-year CAGR return
Table 3: CAGR returns of major indices between Mar’20 to Jun’25
Indices CAGR return
Nifty 50 23.0%
DAX 18.2%
BRAZIL IBOVESPA INDEX 13.0%
Shanghai SE composite 4.4%
Hang Seng index 0.7%
Nikkei 225 15.6%
FTSE 100 Index 8.6%
Dow Jones 13.8%
Source: SEBI Bulletin
From Mar’20 to Jun’25, the Nifty 50 delivered the best returns among global indices, rising from 8,598 to 25,518, reflecting a
strong 23% CAGR. This growth has been largely driven by India’s economic expansion, increasing corporate profitability, and
growing foreign investor interest in emerging markets. The Nifty 50’s robust performance of last five years (Mar’20 to Jun’25)
underscores the resilience and growth potential of the Indian market, outperforming many developed market indices. However,
Nifty 50 has been witnessing volatility amid uncertainty surrounding US tariffs, geopolitical uncertainties, and FIIs withdrawing
from Indian capital markets.
Trends in Market Capitalization
Over the years, India's robust economic growth amid global financial challenges, ample liquidity from the influx of domestic
investors post-pandemic, and strong foreign portfolio investor (FPI) inflows have fuelled sharp growth in market capitalization.
Chart 13: Trends in India’s market capitalization listed on NSE
392459
411
384
e
r
o
r C 262 256
h 203
k
a
L
. 112
s
R
FY20 FY21 FY22 FY23 FY24 FY25 Q1FY26
Source: NSE Market Pulse
Chart 14: Trend in Market Capitalization to GDP
213%
206%
195%
179%
157% 157%
147%
136% 136%
124% 129% 126%
113%
95% 105%
79%80%
65%61%65%
China India Japan USA
2020 2021 2022 2023 2024
Source: Economic Survey 2024-25 Note: The data has been revised based on the 1st advance estimate of GDP released on 7
January 2025. Projected figures: GDP figures are taken from IMF projections, and market capitalisation is taken as at the
end of Q2 of FY25 (i.e., Sep-24 end) for the US, India, Japan, and China market cap figures are as on the end of December
2024. Market capitalisation was taken country-wise as China (Shanghai and Shenzhen Stock Exchange), All India, Japan
(Japan Exchange Group Inc.), and USA (NYSE and NASDAQ)
As at end of CY24, in terms of market capitalization to GDP, India ranks favourably among both developed and emerging
economies. Post-pandemic economic growth, favourable demographics, rising foreign investment, and strong corporate
performance bodes well for India. As one of the fastest-growing major economies, India is expected to remain an attractive
investment destination, despite the high market capitalization to GDP ratio. India’s GDP growth is likely to be supported by
an under-penetrated capital market, increasing investor participation, a growing workforce, the China+1 strategy, and
government’s focus on economic growth.
Overview of performance of capital markets in India vs other major economies
Chart 15: Trend in P/E ratio for major indices
39335
30
25
20
15
10
5
0
India US Japan Hong Kong Germany China Brazil UK
Jun'25 23.0 23.4 18.7 11.5 20.5 15.9 10.8 13.2
Mar'25 21.9 22.1 18.1 11.6 18.2 15.8 10.9 12.7
Mar'24 23.1 22.8 28.5 9.3 15.4 12.9 9.4 12.2
Mar'23 20.4 20 15.4 11.4 13.5 12 6 11.5
Mar'22 22.9 18.2 15.2 10.6 14.5 12 7.4 14.3
Mar'21 33.2 25 24.6 14.6 23.2 13.8 17.8 19
Mar'20 19.4 15.6 18 9.6 17.2 13 13.6 16.3
Source: SEBI bulletin
In comparison to other global indices, Indian benchmark index (Nifty 50) is trading at a higher PE multiple. This indicates
that investors are willing to attribute a premium to the Indian markets owing to the country's promising economic trajectory,
robust corporate earnings growth, a large consumer market, and favourable reforms. Notably, as per IMF, India is the fastest
growing major economy in the world with real GDP growth rate estimated at CAGR of 6.4% for next 5 years. Further, Nifty
50 has witnessed healthy earning growth over the last two decades, registering EPS growth of almost 19% CAGR from FY20
to FY25. While a high P/E ratio may indicate elevated expectations, they are also a testament to the optimism surrounding
India's long-term economic story. However, it should be noted that recent correction phase of the market may have an impact
on the PE multiple to some extent.
Trend in Foreign Institutional Investors (FIIs) & Domestic Institutional Investors (DIIs) investments in Indian
capital markets
Over the years dominance of FII investments in Indian markets has faded, as DIIs and retail investors have become driving
force of the capital markets
In the Indian capital markets, FIIs and DIIs - Mutual funds have displayed different patterns over the past five years. FIIs
showed fluctuation, experiencing net inflows in FY20 and FY21, but significant outflows in FY22 caused by worldwide
economic uncertainties like inflation, increasing interest rates, and geopolitical tensions. In FY24, FIIs came back to Indian
stocks due to better economic conditions.
Chart 16: Net investments by FIIs, DIIs vs trends in BSE Sensex
5 68.0% 4.6 80%
4
60%
2.7
3
e r o r C 2 1.7 1.6 2.1 2.0 40% e g n a
h k 0.9 18.3% 24.9% 5.1% 5.6%1.2 20% h C
a L 1 0.7% 0.4 Y -
s R 0.1 0% Yo -
0
-23.8%
-1 -0.3 -20%
-1.2
-1.4 -1.4
-2 -40%
FY20 FY21 FY22 FY23 FY24 FY25 Q1FY26
394Source: CMIE, CareEdge Research
Note: Net investments = Purchase – Sales; Figures have been round-off to the nearest integer
In FY25, FIIs net outflows were Rs. 1.4 lakh crore, while DIIs continued to significantly invest in Indian Equities, indicating
growth potential, trust, and efficiency of capital markets with their net inflows growing to Rs. 4.6 lakh crore in FY25. The
growth in DIIs net investments presents significant opportunities for mutual fund distributors and brokerage houses to expand
their reach in the growing market.
Overview of Primary Market Issuances in India
India's primary market has witnessed significant traction from FY20 to FY25, with increased contributions from Initial Public
Offerings (IPOs), Follow-On Public Offerings (FPOs) Qualified institutional placements (QIPs)/ Institutional Placement
Programmes (IPPs), rights issues, and offer for sale (OFS).
Table 4: Rising trend in primary market issue volumes
Product FY22 FY23 FY24 FY25 Q1FY25 Q1FY26
IPO 120 164 272 320 74 45
FPO 1 1 1 2 1 0
Right Issue 43 73 67 142 36 28
Preferential Issue 349 454 689 988 282 324
QIPs/IPPs 29 11 61 91 19 10
OFS through Exchanges 20 17 51 26 6 9
Total 562 720 1,141 1,569 418 416
Source: SEBI Bulletin
Note: All issues include aggregate volume of main board and SME segment issues
The Indian stock market has experienced bullish trends, largely witnessing upward momentum in stock indices between FY22-
FY25. This favourable sentiment, particularly amongst institutional investors, encourages more companies to take advantage
of market conditions and go public. Hence, companies are increasingly turning to IPOs to raise capital for expansion, pay off
debts, and provide exit to private equity and institutional investors.
Table 5: Rising trend in primary market issues value (in Rs. Crores)
Product FY22 FY23 FY24 FY25 Q1FY25 Q1FY26
IPO 112,552 54,772 67,955 172,328 18,381 15,464
FPO 15 4,300 27 18,150 18,000 -
Right Issue 26,327 6,751 15,110 19,712 4,849 7,594
Preferential Issue 60,697 83,832 45,155 84,084 39,691 51,943
QIPs/IPPs 31,441 8,212 68,971 135,597 17,287 16,210
OFS through Exchanges 14,557 12,693 24,535 30,798 325 8,325
Total 245,588 170,560 221,754 460,668 98,533 99,536
Source: SEBI Bulletin
Raising capital through IPOs has become a key strategy for Indian companies seeking funds for growth, and expansion.
Between FY22 to FY25, the Indian market saw a notable increase in IPO activity, particularly post-pandemic in 2020-2021,
as companies took advantage of favourable market conditions and abundant liquidity.
While the total capital raised (equity) grew over 2x to Rs. 4,60,668 crore in FY25 from Rs. 2,21,754 crore in FY24 and the
number of primary market issuances (equity) increased significantly to 1,569 in FY25 from 1,141 issuances a year ago. This
trend reflects fewer large-value issuances but a higher volume of smaller transactions, indicating broader participation in
fundraising activities at lower deal sizes. Further, during Q1FY26, the total number of primary market issuances (equity)
reached 416 (418 during Q1FY25) and total capital raised from these issuances reached Rs 99,536 crore (Rs 98,533 crore in
Q1FY25).
Trend in number of demat accounts in India
395Chart 17: Investor Accounts
1,991
1,924
s
h 1,514
k
a
L
n 1,145
i
s 897
e
r
u
g 551
iF 409
Mar-20 Mar-21 Mar-22 Mar-23 Mar-24 Mar-25 Jun'25
Source: SEBI Bulletin
Retail investors’ preference is becoming more mature as they get more informed regarding potential of capital markets and
risk associated with investing in it. This increasing awareness has led to significant growth in retail participation, with investor
accounts registered with NSDL and CDSL reaching 1991 lakhs as of Jun’25.
Trend in NSE Average Daily Turnover
Chart 18: Segment-wise NSE ADTO– By Value (Rs. Crores)
FY20 FY21 FY22 FY23 FY24 FY25 Q1FY25 Q1FY26
Stock Futures 60,222 72,684 84,834 76,596 103,849 150,752 168,621 132,662
Y-o-Y growth 20.7% 16.7% -9.7% 35.6% 45.2%
Cash Market 36,432 61,839 66,799 53,434 81,721 112,963 122,842 108,542
Y-o-Y growth 69.7% 8.0% -20.0% 52.9% 38.2%
Index Options 4,371 10,560 23,558 43,998 56,177 54,516 63,209 47,836
Y-o-Y growth 141.6% 123.1% 86.8% 27.7% -3.0%
Index Futures 27,034 36,336 33,989 38,236 30,151 35,149 40,722 35,768
Y-o-Y growth 34.4% -6.5% 12.5% -21.1% 16.6%
Stock Options 925 2,327 4,189 3,746 5,602 7,933 8,753 7,677
Y-o-Y growth 151.6% 80.0% -10.6% 49.5% 41.6%
Others* 21,495 23,819 29,504 41,590 30,156 5,805 7,702 3,549
Y-o-Y growth 10.8% 23.9% 41.0% -27.5% -80.7%
Total 150,479 207,565 242,873 257,600 307,656 367,118 411,849 336,034
Source: NSE
Note: Options ADTO is derived based on premium turnover, Others include currency derivatives, interest rate derivatives and
commodity derivatives
From FY20 to Q1FY26, the average daily turnover across all segments of the NSE grew significantly. The total turnover
increased from ~Rs. 1,50,679 crore in FY20 to ~Rs 3,67,118 crore in FY25. This rise is driven primarily by the sharp growth
in the cash market, stock futures, and index options segments. While stock options and index futures recorded moderate
increases, the cash market surged from ~Rs. 36,432 crore in FY20 to ~Rs. 1,12,963 crore in FY25, stock futures increased to
Rs. 1,50,752 crore in FY25 from Rs 60,222 crore in FY20 and index options rose from Rs. 4,371 crore in FY20 to Rs. 54,516
crore in FY25. The ADTO has declined a bit in Q1FY26 on account of increased volatility in the market.
Overall, the growth of ADTO can be attributed to increased retail participation as investors seek to diversify their savings.
Furthermore, with rising awareness, deeper penetration in Tier2/3 Cities, rise of brokers, financial planners, and wealth
management firms, investors began to utilize their savings for better returns.
Cash Market Segment ADTO Trends
396Chart 19: Trends in average daily turnover in NSE cash market segment
1,40,000 69.7% 52.9% 80.0%
1,22,842
70.0%
1,12,963
1,20,000 1,08,542
60.0%
1,00,000 38.2% 50.0%
80,0e r o r00 66,799 h t w o34 00 .. 00 %%
C 61,839 r
60,0 . s R00
13.7%
8.0% 53,434 81,721
G
Y20.0%
-
o10.0%
36,432 -
Y
40,000 -20.0% -11.6% 0.0%
-10.0%
20,000
-20.0%
0 -30.0%
FY20 FY21 FY22 FY23 FY24 FY25 Q1FY25 Q1FY26
Source: NSE, CareEdge Research
In FY25, ADTO of cash market reached Rs 1,12,963 crore, a 38.2% increase over FY24 at Rs. 81,721 crore. This growth in
cash market can be attributed to rise in retail participants. With the increasing penetration of digital trading platforms and
greater financial literacy, retail investors have become key growth drivers of the market. Their involvement supports the
diversification of investment sources, making the Indian financial markets more resilient. In Q1FY26 ADTO of cash market
declined to Rs. 1,08,542 crore from Rs.1,22,842 crore in Q1FY25, a 11.6% decrease over Q1FY25.
Equity derivative (Futures and Options) ADTO trends
India’s equity derivatives market plays a crucial role in offering investors a range of instruments for managing risk and
engaging in speculative activities, increasing the efficiency of the overall market. Investors use diverse strategies such as
hedging, arbitrage, and speculative trading to mitigate risks and optimize their returns when investing in the futures and options
market. The market operates under the regulatory oversight of SEBI, which enforces a robust framework to ensure fairness,
transparency, and investor protection. By enabling risk transfer and price discovery, the equity derivatives segment
significantly contributes to the overall depth and stability of India’s capital markets.
Chart 20: ADTO of Equity -Futures
38.7%
16.7%
24.9%
h
t
e w
r 9.0% o
o r
r G
C
. s
R
-0.4%
-3.4% 1,85,901 2,09,343
1,68,430
Y o-
-
1,34,000 Y
1,09,020 1,18,824 1,14,831 -19.5%
87,255
FY20 FY21 FY22 FY23 FY24 FY25 Q1FY25 Q1FY26
Futures ADTO Y-o-Y Growth
Source: NSE, CareEdge Research
In FY25, equity derivative futures ADTO reached Rs 1,85,901 crore, a 38.7% increase from FY24. In Q1FY26, ADTO of
equity derivative futures reached Rs 1,68,430 crore, indicating decline of 19.5% over Q1FY25.
397Chart 21: ADTO of Equity – Options
143.4% 71,962
61,779 62,449
115.3%
55,514
47,744
e
r h
o t
r w
C 53.7% 27,747 o
. s 72.1% r G
R 12,887 29.4% Y
-
5,295 1.1% Yo -
FY20 FY21 FY22 FY23 FY24 FY25 Q1FY25 Q1FY26
Options ADTO Y-o-Y Growth
Source: NSE, CareEdge Research
Note: Turnover includes Premium turnover
The options segment’s ADTO reached Rs. 62,449 crore during FY25, up 11.7x over FY20. The uptick in F&O segment is led
by strong retail interest that drives growth, especially in derivatives amid greater accessibility through mobile apps and online
resources. During Q1FY26, the option segment’s ADTO reached Rs 55,514 crore, indicating a ~23% decline over same quarter
of the previous year. This decline can be attributed to changes in SEBI’s evolving F&O framework that aims to safeguard
retail investors from risky derivatives.
Share of retail participation across market segments
Retail Individuals account for lions share in Cash Market Segment
Chart 22: Share of client participation in Cash Market Segment as of Jun’25 (%)
-
3.9%
4.4%
13.5% Individuals
34.4%
Prop
Foreign Investors
DIIs
15.3%
Others
Corporates
28.6%
Source: NSE Market Pulse, CareEdge Research
Note: 1. As per NSE pulse, DIIs: Domestic Institutional Investors include Banks, Mutual Funds, Insurance Companies,
NBFCs, Domestic VC Funds, AIFs, PMS clients etc., Foreign investors: Foreign Institutional Investors include FPIs, FDIs,
Foreign VC Funds, OCB and Foreign Nationals etc., Prop: PRO Trades, Individual investors: individual domestic investors,
NRIs, sole proprietorship firms and HUFs, Others: Partnership Firms/LLP, Trust / Society, Depository Receipts and Statutory
Bodies, etc. Client categories are based on the information provided by trading members in UCC database. 2. Above data
represents share in turnover
As of Jun,’25, Individual investors accounts for a major chunk of participation in the cash market segment at over 34.4%,
followed by Prop and foreign investors at 28.6% and 15.3%, respectively.
Retail Individuals account for over 26.6% of equity derivative market segment participants
398Chart 23: Share of client participation in Equity Derivatives Market Segment as of Jun’25 (%)
2.4%2.2% 0.3%
8.1%
Prop
Individuals
Foreign Investors
Corporates
26.6%
Others
60.4%
DIIs
Source: NSE Market Pulse, CareEdge Research
Note: Above data represents share in notional turnover
As of Jun’25, Prop investors account for ~60% of equity derivative market participants. Individual investors are the second
largest equity derivative market participants, accounting for 26.6% of total market participants in the equity market segment.
Individuals accounted for over 30% of Index Futures market participants
Chart 24: Share of client participation in Index Futures Market Segment as of Jun’25 (%)
5.6%
6.0%
31.6% Prop
10.0%
Individuals
Foreign Investors
Corporates
15.1%
Others
DIIs
31.7%
Source: NSE Market Pulse, CareEdge Research
Note: Above data represents share in turnover
Prop and Individual investors combined accounted for over 63% of Index Futures market participants, indicating high interest
in future growth prospects of the economy and high retail participation.
Retail Individuals account for over 15% of stock futures market participants
399Chart 25: Share of client participation in Stock Futures Market Segment as of Jun’25 (%)
4.3%
5.7%
12.6% 33.5% Prop
Foreign Investors
Individuals
DIIs
14.1% Corporates
Others
29.7%
Source: NSE Market Pulse, CareEdge Research
Note: Above data represents share in turnover
As of Jun’25, Prop accounts for largest chunk in stock future segment at 33.5%, followed by foreign investors and individual
investors at 29.7% and 14.1% respectively.
Individuals account for more than a quarter of stock option segment participants
Chart 26: Share of client participation in Stock Options Segment as of Jun’25 (%)
2.2%1.8%0.2%
13.8%
Prop
Individuals
Foreign Investors
Corporates
55.9%
Others
26.0%
DIIs
Source: NSE Market Pulse, CareEdge Research
Note: Above data represents share in turnover
Prop and Individual investors are the largest participants in stock options segment, combined accounting for over 80% of
market participants within the segment.
Individuals account of over a third of index option segment participant
400Chart 27: Share of client participation in Index Options Segment as of Jun’25 (%)
2.3% 0.1%
2.3%
8.0%
Prop
Individuals
Foreign Investors
50.8% Corporates
Others
36.5%
DIIs
Source: NSE Market Pulse, CareEdge Research
Note: Above data represents share in turnover
Prop and Individual investors combined accounted for over 87% of Index options market participants, while FIIs and DIIs
combined accounted for a little over 10% of Index options market participants.
Trends in volume trades across top cities in India
Mumbai accounts for lion’s share of India’s trade volumes on NSE
While Mumbai remained the leading city, followed by Ahmedabad showed the most impressive growth, with other cities
accounting for smaller shares.
Mumbai consistently dominated participation, especially in NSE, accounting for 63.0% of NSE trading volumes for Q1FY26.
Ahmedabad saw significant growth, particularly in NSE, where its share surged from 1.7% in FY20 to 16.8% in Q1FY26.
Kolkata, while strong in early years, declined on NSE from 5.2% in FY20 to 1.3% in Q1FY26. Cities like Bengaluru,
Hyderabad, and Chennai had minor but fluctuating participation. Notably, proprietary trading hubs like Rajkot and Vadodara
saw a steady presence across the years.
Table 6: City-wise share in trading volumes on NSE (%)
City FY20 FY21 FY22 FY23 FY24 FY25 Q1FY25 Q1FY26
Tier 1 Cities
Mumbai 64 67 67.6 68 66.2 63.4 64.1 63.0
Ahmedabad 1.7 4.1 9.1 11.2 15.6 17.1 16.3 16.8
New Delhi 5.9 5.2 0.1 3.7 2.2 2.0 2.2 1.6
Chennai 0.9 0.6 5 0.9 0.9 0.8 1.1 0.3
Hyderabad 3.1 3.5 0 2.5 2.5 2.5 2.8 2.5
Pune 0.1 0.1 0.3 0.4 0.4 0.4 0.4 0.4
Kolkata 5.2 4.3 0.2 4.2 1.8 1.4 1.6 1.3
Bangaluru 3.2 2 1.2 0.8 1.9 3.7 2.3 5.2
Tier 2 Cities
Bhubaneswar 0 0 0 0 0 0.0 0.0 0.0
Patna 0 0 0 0 0 0.0 0.0 0.0
Coimbatore 0.1 0.1 0.5 0.1 0 0.0 0.1 0.0
Guwahati 0 0 5.4 0 0 0.0 0.0 0.0
Indore 0.3 0.4 2.7 0.3 0.1 0.2 2.8 0.1
Ludhiana 0.1 0.1 0.1 0.1 0 0.0 0.0 0.0
Vadodara 0.2 0.2 0.2 0.1 0.1 0.1 0.1 0.1
Jaipur 0.3 0.3 0.4 0.2 0.2 0.2 0.2 0.1
Rajkot 1.1 0.9 0.8 1 0.5 0.5 0.5 0.4
Kanpur 0.1 0.1 0.3 0.3 0.1 0.1 0.2 0.1
Mangalore 0 0 0 0 0 0.0 0.0 0.0
Ernakulam 0.7 0.7 0.7 0.4 0.3 0.3 0.3 0.3
401Others 13 10.6 5.6 6 7.1 7.4 7.7 7.7
Total 100 100 100 100 100 100 100 100
Source: SEBI Bulletin, the turnover is of Cash Segment Only
Mumbai continued to lead in terms of trading volume, followed by Ahmedabad has shown strong growth, rising from 1.7 in
FY20 to 17.1 in FY25, driven by urbanisation and industrial expansion. Vadodara has remained stable around 0.1–0.2,
contributing modestly. Ahmedabad is emerging as Gujarat’s primary growth hub, supported by urbanisation and business
development. Vadodara’s future growth is likely to depend on strategic initiatives to enhance its industrial and economic base.
Trend in commodity derivatives
Commodity derivatives are financial instruments whose value is based on underlying commodities, such as oil, gold, wheat,
or natural gas. These derivatives allow investors to profit from price movements in these commodities without owning them.
In terms of percentage share of commodity derivatives turnover among exchanges, MCX has the highest market share of
97.5%, followed by NSE (2.3%) and NCDEX (0.3%) as of FY25.
Chart 28: Total turnover of Commodity Derivatives Market (in Rs. Lakh crore)
700 120.0%
106.6%
580
600
100.0%
86.9%
500 75.9%
80.0%
h
e t
34 00 00r o r C
h k a
49.7%
281
60.0%w o r G
Y o-
L
.s
203 40.0%Y-
200R 150
116
92 100
20.0%
100
0.4% 8.7%
0 0.0%
FY21 FY22 FY23 FY24 FY25 Q1FY25 Q1FY26
All-India Total Turnover Y-o-Y Growth
Source: SEBI, CareEdge Research
The Indian financial market has experienced notable fluctuations in turnover across various exchanges in recent years. From
FY20 to FY25, the combined turnover for all exchanges has shown impressive growth, with a CAGR of approximately 44.5%
and Q-o-Q growth of 75.9% from Rs 116 lakh crore in Q1FY25 to Rs 203 lakh crore in Q1FY26. This growth trend highlights
the performance of key exchanges, including the BSE, NSE, Multi Commodity Exchange (MCX), and National Commodity
and Derivatives Exchange (NCDEX).
The growth of commodity derivatives in India can be attributed to several key factors:
• Diversification of Investment: Investors seek diversification beyond traditional equities and fixed income, and commodity
derivatives offer exposure to different asset classes.
• Hedging Opportunities: Producers and consumers use commodity derivatives to hedge against price volatility, protecting their
profit margins and ensuring stable cash flows.
• Increased Participation: With greater awareness and participation from retail investors, institutional investors, and corporate
players, the market has seen significant growth.
• Technological Advancements: Improvements in trading technology and platforms have made it easier for participants to access
commodity markets, facilitating higher trading volumes.
• Rising Demand for Commodities: Economic growth and urbanization have led to increased demand for various commodities,
driving interest in derivatives for speculative and hedging purposes.
402• Global Integration: As Indian markets become more integrated with global markets, domestic investors gain access to
international commodity trends, enhancing trading strategies.
Country wise percentage of population investing in stock market
The Indian equity market has historically seen low participation rates compared to developed countries. Near about 4-5% of
Indians invest in the stock market, compared to United States (~55%), United Kingdom (~33%) and China (~13%). This
leaves significant room for growth as awareness and financial inclusion efforts expand. With increasing digital literacy and
initiatives to encourage investments, market penetration is expected to rise significantly in the coming years.
Chart 29: Country-wise percentage of population investing in stock market
Source: CareEdge Research, figures are approximate
Key Growth Drivers for Capital Market Linked Businesses
The growth drivers for capital market-linked businesses are linked to overall economic growth, as both are interconnected.
Here are few key factors driving growth in India's capital markets:
403•India's youthful demographic drives significant capital market growth. As of
June 2025, the median age of NSE registered investors stands at 33 years,
Demographics of India with 39% under 30. As of Mar-20, the median age was 38. This young
demographic shows a strong inclination towards digital solutions and
wealth creation.
•India’s per capita GDP at current prices is expected to increase by 8.8% y-
Rising Per Capita
o-y in FY25 over FY24, prompting an increase in financial investments in
Income
stocks, bonds, and mutual funds.
•The rising household savings in India augments the domestic capital pool,
thereby enhancing participation in equity and debt markets. Households
Increasing penetration
are diversifying their portfolios and shifting away from traditional
of Capital Markets
instruments such as bank deposits to equities, small savings, provident
funds, pension funds and mutual funds.
•Growing financial literacy and awareness encourage more people to invest
Increase in Financial
in equities, supported by increasing incomes and technological
Literacy
advancements.
•The surge in digital payments facilitates market participation, providing
Digital Payments Boom
easier access to financial markets for individuals.
•Internet penetration in India increased from 54.2% in 2019 to 68.9% in
2024 and is expected to reach 85%-86% by 2028. Government initiatives
Internet Penetration
like Digital India and BharatNet contribute to bridging the digital divide
between urban and rural areas.
•The rise in smartphone usage makes capital markets more accessible
Smartphone Penetration
through mobile trading platforms, particularly for younger, tech-savvy
Driving Mobile Trading
investors.
•India has implemented key reforms, such as faster settlement cycles and
Structural and
SEBI regulations, to improve market efficiency, transparency, and investor
Regulatory Reforms
protection.
Key Risks Related to Capital Markets
Capital markets face the following risks that can impact both investors and overall financial system.
• Market risk –Market risk is frequently influenced by shifts in economic circumstances, investor attitudes, or geopolitical
incidents, which are challenging to foresee and manage. Also, large trades can have a significant impact on stock prices as
the size of Indian market is small as compared to markets on a global scale. Hence, it is crucial for institutional traders to be
vigilant about how they execute the orders in the market to minimize the costs due to market impact.
• Credit risk - Bond investors face losses when issuers default on debt obligations, as seen in the IL&FS crisis.
• Liquidity risk – Low liquidity during financial instability forces asset sales at reduced values, affecting market prices.
• Regulatory Risk – Policy changes, trade regulations, or political instability disrupt markets, especially globally exposed
industries, can have adverse impact on the market.
404• Operational and systemic risks - Breakdowns, like cyberattacks or fraud disrupt operations, while systemic risks threaten
financial system collapse, as seen in the 2008 crisis. Natural disasters or technological disruptions further amplify risks.
The significance of strong risk management plans and diversification is underscored by these risks in guiding investors through
uncertainties of the capital markets.
Overview of broking industry in India
Introduction to Broking Industry in India
The broking industry plays a crucial role in the Indian financial markets by acting as an intermediary between buyers and
sellers of securities such as stocks, bonds, commodities, and other investment assets. Brokers facilitate the trading of these
financial products, ensuring liquidity, efficient price discovery, and proper capital allocation across the markets. India's
brokerage industry is highly competitive and particularly crowded. The market features numerous large and small players,
resulting in intense competition. Additionally, the brokerage landscape is fragmented, comprising a considerable number of
entities registered with SEBI. Over time, the industry has evolved significantly, largely due to technological advancements,
with online trading platforms revolutionizing the way trades are executed.
To strengthen their market positioning, brokers often offer enhanced graphical user interfaces with modern charting
techniques, strategy-building tools to trade in derivatives, offer margin and credit facilities, high-frequency data feed, etc.
These modern-day facilities require significant infrastructure and technological capability in which these players have actively
invested.
As players have scaled up their technology infrastructure significantly, additional expenses, such as manpower, branches, and
costs associated with scaling up in newer geographies, etc., have come down because of the digitalization of their operations.
The broking industry is continuously adapting to changing regulations, technological innovations, and evolving investor needs,
ensuring that it remains a key player in the financial ecosystem.
Type of Brokers in India
The Indian financial services industry is intensely competitive, and the Broking Business is particularly competitive with a
sizeable number of large and small operators.
Brokers in India are classified into two types based on the services they offer:
Brokers in India
Full Service
Discount Broker
Broker
• Full-Service Broker
Full-service brokers are licensed intermediaries offering a wide range of services, including investment advisory, wealth
management, mutual fund distribution, Portfolio Management Services (PMS), and Margin Trade Financing (MTF). Operating
both online and offline, they provide personalised support through branch networks and Relationship Managers (RMs). These
brokers deliver in-depth research via dedicated teams, offering insights through technical and fundamental analysis. They cater
to diverse investor needs—supporting beginners with guidance and offering advanced tools to experienced clients. Known for
regulatory compliance, strong security, and comprehensive services, full-service brokers remain key players in the evolving
financial landscape, even as discount brokers have expanded access to low-cost, digital trading.
• Discount Broker
The shift to online stock trading has given rise to discount brokers in India. These brokers are gaining popularity due to their
low, fixed brokerage fees, which apply regardless of trade value. Discount brokers focus on executing orders at reduced costs
but do not provide personal consultations, advisory services, research, tax planning, or estate planning for clients.
405Table 7: Full-Service Vs Discount Brokers
Services Full - Services Brokers Discount Brokers
Does not provide a personal dedicated RM, only
Offers personalized relationship managers
offers a call and trade facility on a charge basis, and
Service Offerings (RMs), market research, portfolio analysis,
lacks investment advice and research reports,
call and trade facility, and more.
focusing solely on trading
Charges are based on a percentage of total
Charges a flat rate or fixed monthly brokerage for
Cost Structure trade value, typically less than 1% of trade
unlimited equity trading
volume
Most accounts incur annual maintenance fees
AMC No or minimal AMC for trading accounts.
(AMCs)
Provides personalized investment advice to
Investment Advice their clients with use of their Relationship Does not provide investment advice
Mangers
Has branches in various cities as channel Lacks branches, relying majorly on its own online
Local Presence
partners or sub-brokers to assist clients platform or business development partners
Offers standardized and advanced technology Provides advanced technology with customization
Technology
without customization options options through APIs
Build relationships through personal Focuses solely on trading relations without personal
Relationship Building
Relationship Managers relationship management
Offers financial planning, estate planning, or
tax preparation services. Full-Service Broker
Generally, offers basic trading services and research
Allied services also provides basket of Distribution products
tools
like MF, PMS, AIF, Fixed Income distribution
etc.
Source: CareEdge Research
Split between Discount Brokers and Full-Service Brokers
Chart 30: Share of Discount Brokers and Full-Service Brokers (Active Clients)
21.9%
Discount Broker
Full-Service Broker
78.1%
Source: NSE, CareEdge Research
Note: Market Share (of top 25 brokers) a percentage of total active clients as on 30st June 2025
The brokerage market is divided between discount and full-service brokers, each catering to varied client needs. Discount
brokers, offer modern trading platforms with low fees, attract a significant share of young and first-time investors, resulting
in a higher client base as compared to full-service brokers. Over time, brokers have expanded their offering to include
investment advisory, AIF/PMS, and distribution of financial products like mutual funds.
406Number of active client accounts in India
Chart 31: Number of Total Active Accounts in India
s
h
k
a
L
n
i
s
r e 495 479
b 435
m 355
u 323
N
189
108
FY20 FY21 FY22 FY23 FY24 FY25 Q1FY26
Source: NSE, CareEdge Research
In Q1FY26, NSE active clients witnessed rise in active clients supported by influx of retail investors with active clients
reaching 479 lakhs. The number of NSE registered active clients increased at a CAGR of 32.8% between FY20-Q1FY26,
despite the marginal decline in FY23 owing to inactivity of clients onboarded in earlier years. Key factors driving this surge
included enhanced digitalization, the ease of opening accounts, and improving financial literacy, which encouraged greater
participation in stock trading. Furthermore, the pandemic highlighted the importance of savings and investments, and coupled
with low interest rates, prompted investors to move away from traditional savings options and turn to equity markets in search
of higher returns, resulting in a significant increase in stock market investments and maintaining a prominent level of active
accounts.
Chart 32: State-wise Share of Total NSE Registered Investors
a FY20 FY21 FY22 FY23 FY24 FY25 FY26TD
Maharashtra 19.2% 19.5% 18.8% 18.2% 17.2% 16.3% 16.2%
Uttar Pradesh 7.4% 7.8% 8.9% 9.9% 10.8% 11.4% 11.5%
Gujarat 12.2% 11.4% 9.9% 9.3% 8.9% 8.8% 8.7%
West Bengal 6.4% 5.9% 5.5% 5.5% 5.7% 5.9% 5.9%
Rajasthan 4.3% 4.7% 5.4% 5.5% 5.6% 5.7% 5.7%
Others 50.4% 50.8% 51.5% 51.7% 51.8% 51.9% 52.1%
Source: NSE, CareEdge Research
Maharashtra continues to hold the largest share of registered investors, though it has declined steadily from 19.2% in FY20 to
16.2% in Q1FY26. Uttar Pradesh has shown consistent growth, rising from 7.4% to 11.5% over the same period, indicating
increasing retail participation from the state.
Although Gujarat’s share in total registered investors has declined from 12.2% in FY20 to 8.7% in Q1FY26, this trend can be
seen as an opportunity rather than a setback. The state still remains among the top contributors, consistently holding a
significant share, which reflects a solid base of retail investors. while West Bengal, Rajasthan, and other states have either
remained stable or shown slight increases. The “Others” category has steadily increased, reaching 52.1% in Q1FY26, reflecting
broader geographical diversification in investor registration across India.
407India’s Broking Industry projected to cross Rs. 810 billion by Mar’28
Chart 33: Size of Broking Industry in India
0.81-0.86
e
r o 0.52
r
C 0.45
h k 0.37
a L 0.3
. 0.24
s
R 0.19
Mar-20 Mar-21 Mar-22 Mar-23 Mar-24 Mar-25 Mar-28P
Source: CareEdge Research Estimates
The broking industry in India is estimated to be valued at ~ Rs 0.52 lakh crore as of FY25 and expected to grow at a CAGR
of 16-18% over the next 2-3 years. The increase in financial literacy and reduced cost of investing due to emergence of discount
brokers has contributed significantly to this growth. Moreover, these factors are expected to continue leading to healthy growth
in the long term.
Margin Trading Funding (MTF) Industry Size
The Margin Trading Facility (MTF) provides greater flexibility than traditional trading methods, primarily because it enhances
an investors’ purchasing power by allowing them to borrow funds. This enables them to invest in more assets compared to
investments through owned capital. Investors can invest their core capital in long-term investments while using MFT leverage
for trading. This approach allows investors to trade without diluting their core capital. The increased investing capacity
supports greater diversification and the potential for higher returns, even with limited own capital.
In Jun’25, the MTF book grew significantly, reaching Rs. 0.88 lakh crore, a 23.7% increase over Mar’25, the MTF book grew
at a CAGR of 87% from last trading day of Mar’20 to last trading day of Jun’25. This growth is driven by rising investor
awareness of MTF's benefits in boosting buying power and potential returns, along with a bullish stock market. Interest income
from MTF ranges between 15% to 35% of total revenue for leading players.
MTF industry size grew at a CAGR of 87% between Mar’20-Jun’25
408Chart 34: Margin Trading Funding (MTF) Industry Size
e
r
o
r
C
h
k a 0.57 0.88
L 0.71
.
s
R
0.26
0.03 0.12 0.25
Mar'20 Mar'21 Mar'22 Mar'23 Mar'24 Mar'25 Jun'25
As of
MTF book
Source: NSE, BSE
Note: Figures have been round-off to the nearest integer
In Sep’24, SEBI updated its policy thereby allowing cash-collateralized securities as part of the MTF maintenance margin,
which is expected to increase participation by simplifying margin requirements and promoting efficiency. Going forward,
strong investor interest and supportive regulations are set to boost brokerage revenues and margins through increased margin
funding opportunities.
SEBI’s initiative is expected to boost participation in margin trading by easing margin requirements and enhancing trading
efficiency. This move reflects SEBI’s commitment to a supportive regulatory framework that fosters market growth and
investor engagement. Looking ahead, strong investor interest and favourable regulations are anticipated to drive revenue and
margin growth for the brokerage industry, presenting firms with new opportunities from margin funding.
The Surge of Algorithmic Trading in India’s Capital Markets
Algorithmic trading, also known as algo trading, refers to the use of computer programs and pre-defined instructions
(algorithms) to execute trading strategies automatically. These instructions are based on various factors such as timing, price,
quantity, or complex mathematical models. Unlike traditional manual trading, algo trading allows for high-speed, high-
frequency, and emotionless execution of trades across markets and instruments.
In India, the rise of algorithmic trading has been notable since SEBI introduced direct market access in 2008, followed by the
rollout of co-location services and smart order routing. Initially limited to institutional players like foreign portfolio investors,
mutual funds, and proprietary desks, the adoption has now expanded to retail investors due to the increasing availability of
APIs and low-latency platforms from brokers and fintech providers.
API trading allows traders to connect directly with a broker’s system to automate order execution through algorithms and
models, ensuring speed, efficiency, and instant reaction to market signals. It is widely adopted in algorithmic and high-
frequency trading by institutions and advanced retail investors. For brokers, offering APIs attracts high-volume traders, boosts
transaction revenues, enhances client relations, and enables integration with fintech ecosystems, opening ancillary income
streams. Strategically, API trading reflects the digitisation of markets, with adoption expected to rise as data-driven strategies
and regulatory support expand retail algo participation, positioning brokers as technology partners in the evolving trading
landscape.
409Chart 35: Annual trend by modes of trading in NSE’s equity cash market turnover
49.2% 45.4% 46.8% 49.2% 49.5% 54.0% 54.0%
50.8% 54.6% 53.2% 50.8% 50.5% 46.0% 46.0%
FY20 FY21 FY22 FY23 FY24 FY25 Q1FY26
Non-Algo Algo
Source: NSE, CareEdge Research
The share of algorithmic trading has seen a consistent upward trend, growing from 49.2% in FY20 to 54.0% in Q1FY26. This shift
reflects increasing retail and institutional adoption of API-driven platforms and automated strategies. In FY25, algo trading
surpassed non-algo activity for the first time, indicating a structural change in the way equity transactions are executed in the cash
segment.
Chart 36: Annual trend by modes of trading in NSE’s equity derivatives market turnover
41.0% 39.0% 38.0% 37.0% 33.0% 30.0% 31.0%
59.0% 61.0% 62.0% 63.0% 67.0% 70.0% 69.0%
FY20 FY21 FY22 FY23 FY24 FY25 Q1FY26
Algo Non-Algo
Source: NSE, CareEdge Research
As of Q1FY26, algorithmic trading accounted for 69% of NSE’s equity derivatives market turnover, indicating a structural shift in
trading behaviour.
Share of client concentration in cash & derivative markets
Split in active investors in cash and F&O segment
410Chart 37: Individual investors’ participation in cash and equity derivatives-NSE
377 369
h
k 307
a 274
L 249
n
i
s
r 152
o
t s e 91 96 106 98
v 51 67
n I 14 26
la
u
d
iv Mar'20 Mar'21 Mar'22 Mar'23 Mar'24 Mar'25 Jun'25
id
n For the year ended
I
Cash Segment F&O Segment
Source: NSE, CareEdge Research
Between Mar’20-Mar’25, participation of individual investors in the cash segment grew at a CAGR of 32.9% and has reached
377 lakhs as on Mar’25, while participation in the equity derivatives segment surged at a remarkable CAGR of 49.9% and
have reached 106 lakhs as on Mar’25. This significant growth in derivatives can be attributed to the increasing popularity of
trading strategies among retail investors, fuelled by the rise of digital trading platforms that make derivatives trading more
accessible. Additionally, heightened market volatility and a growing interest in leveraged trading have encouraged investors
to explore equity derivatives for potential higher returns. However, as per SEBI study released on 07th July 2025, 91% of
individual traders incurred net loss in Equity Derivatives Segment (EDS) in FY25. This has come after the equity F&O segment
witnessed strict guidelines for individual investors, which impacted the investor participation within the segment.
Chart 38: Ownership pattern by free float market cap (%)
FY25 Domestic Mutual Funds
4.9% 0.9%
20.8% Foreign Portfolio Investors
19.1% Banks, Financial Institutions & Insurance
Other institutional non-promoters
Non-promoter corporate
3.7%
4.4% Individual investors
Other non-institutional non-promoters
11.2% 35.0%
Non-promoter Govt.
Source: NSE, CareEdge Research
Foreign Portfolio Investors (FPIs) account for 35% of free float market cap as of Mar’25, followed by Domestic Mutual Funds
at 20.8%, indicating growing confidence among retail investors in professionally managed investment vehicles.
GIFT City role in broking
Gujarat International Finance Tec-City (GIFT City) is India’s first and only International Financial Services Centre (IFSC),
envisioned to position the country as a competitive global financial hub. Designed as a vertical smart city to optimise land
usage, GIFT City spans a total area of 886 acres—comprising a 261-acre Multi-Service Special Economic Zone (SEZ) and an
adjoining 625-acre Domestic Tariff Area (DTA). This strategic bifurcation enables seamless integration of both global-facing
411and domestic operations. With world-class infrastructure, tax and regulatory incentives, and ease of doing business, GIFT City
has increasingly emerged as a preferred destination for global institutions seeking to establish cross-border financial
operations. Its strategic location, policy support, and innovation focus position it as a critical enabler in India’s ambition to be
a global financial powerhouse.
With regulatory bodies like the International Financial Services Centres Authority (IFSCA) implementing progressive norms
and initiatives such as GIFT IFSC Stock Exchanges and aircraft/ship leasing ecosystems, brokers play a pivotal role in the
operational and strategic framework acting as key conduit for offshore fund flows, global listings, and cross-border financial
services. Registered brokers at GIFT City provide access to international financial markets, enabling investors to trade in a
variety of instruments, including foreign equities, derivatives, and debt securities. They also support non-resident investors,
such as NRIs and foreign portfolio investors, by offering services aligned with global compliance standards.
Additionally, brokers in GIFT City enjoy a 100% income tax exemption on business income for any 10 consecutive years out
of a 15-year period, as per Income Tax Act, 1961. They are also exempt from Securities Transaction Tax (STT), Commodities
Transaction Tax (CTT), and stamp duty on transactions conducted on IFSC exchanges. Furthermore, there is no GST on
services received by IFSC units or provided to offshore clients. This makes GIFT City an attractive destination for brokers
seeking to expand their international operations while benefiting from a favourable regulatory and tax environment.
Changing Trends in the Broking Industry
8. Increase in share of non-broking Value-added services, and financial planning, Fund based activity
Brokerage firms are actively diversifying their revenue streams by expanding into non-broking services such as wealth
management, financial advisory, and investment products. Emerging brokerages are attracting clients through zero-
commission trading, while established full-service brokers transform into comprehensive financial service providers., These
firms now offer an extensive suite of services, including equity research, funding solutions, mutual funds, insurance, and
retirement planning, thereby positioning themselves as one-stop financial solutions for their clients.
As of Jun-25, the portfolio management industry managed assets totalling ~Rs. 39.3 lakh crore, primarily from discretionary
services, with advisory services contributing over Rs 3.0 lakh crore. This indicates a preference for personalised investment
strategies, driven by enhanced financial literacy.
Segments such as margin funding and loans against shares are witnessing popularity, reflecting the growing demand for non-
broking services, as clients seek holistic comprehensive solutions beyond trading. Brokerages investing in technology and
expanding their service offerings are well positioned in a competitive market.
Rising Importance of Relationship Based Broking
Traditionally, broking focused on executing transactions, with brokers executing trades and offering minimal guidance.
However, as the investment landscape grows more complex and competitive, investors increasingly seek personalized,
comprehensive services that align with their individual financial goals and risk preferences. This shift has driven the demand
for relationship-based broking, which prioritizes long-term client-broker partnerships.
Relationship-based broking is redefining client engagement by moving beyond transactional interactions towards a more
customised service model. It focuses on cultivating trust, enhancing client satisfaction, and fostering enduring relationships—
factors that drive sustainable growth and create meaningful differentiation in a crowded market. The recent market correction,
beginning in October 2024, and ongoing volatility have further amplified the demand for bespoke research and advisory
services—areas where traditional brokers continue to hold a competitive edge. By adopting a relationship-driven approach,
brokers are investing time in understanding their clients’ aspirations, concerns, and financial circumstances. This deeper
engagement enables the provision of tailored advice, thereby strengthening trust and improving client retention.
Brokers adopting this approach invest time in understanding clients' aspirations, concerns, and financial situations, enabling
them to offer tailored advice. This personalization builds trust and enhances client satisfaction, leading to stronger loyalty.
Amid the proliferation of online trading platforms, the human connection offered by relationship-based broking helps
distinguishes firms from competitors.
Overall, relationship-based broking is essential for building trust, offering tailored investment strategies, gaining market
insights, and standing out in a competitive marketplace. This approach enhances client satisfaction but can also lead to
412sustainable business growth, as long-term relationships often yield higher value compared to one-off transactions.
Furthermore, relationship-based broking plays a critical role in the financial services industry, significantly influencing how
brokers interact with clients and manage their investments.
9. Rising Importance of Technology in Trading
The digital/online broking market is expanding, driven by widespread internet access and technological advancements. The
internet enables trading anytime from anywhere and broadens access to financial markets, democratizing investment
opportunities.
The rise of app-based trading has significantly contributed to the expansion of the digital broking market. Mobile applications
offer seamless access to trading platforms, allowing users to execute trades, monitor markets, and manage portfolios in real
time from their smartphones. With intuitive designs and personalised notifications, these apps attract tech-savvy investors and
new entrants alike, making financial markets more accessible.
Furthermore, technological innovations, such as advanced trading algorithms, real-time data analytics, and user-friendly
interfaces, enhance trading platforms and attract a wider range of investors, including beginners. Mergers and acquisitions
within the industry foster innovation and consolidation, allowing firms to offer comprehensive services and optimise
operations. Investors increasingly prioritise customisation, seeking platforms that provide tailored portfolios and strategies.
E-brokerages offering features like automated rebalancing and personalised advice are better equipped to meet these demands.
At the same time, firms need to implement robust cybersecurity measures to maintain client trust and protect sensitive
information against cyber threats, which could harm both reputation and operations.
The Path Forward: Emerging Trends in Indian Broking
India’s capital markets are witnessing a rise in retail investment and an increase in assets under management in mutual funds,
reflecting a positive investor outlook. The broking industry is expected to register moderate growth over the medium term,
supported by economic expansion, growing retail participation, and continued technological advancement. The industry is
likely to attract new clients, particularly from underpenetrated retail segments, driven by favourable demographics and
improved financial literacy. The widespread use of smartphones, faster internet connectivity, and user-friendly trading
applications will further facilitate broader participation in trading and investing across diverse age groups. Regulatory
developments, particularly those introduced by the Securities and Exchange Board of India (SEBI), significantly influence the
industry’s trajectory. SEBI’s initiatives aimed at safeguarding investors and enhancing market transparency—such as recent
revisions to margin trading norms—require brokers to adapt swiftly. While these reforms strengthen market integrity, they
may pose compliance challenges for smaller firms.
Key trends shaping the future of stockbroking include AI-powered tools like algorithmic trading, robo-advisors, chatbots, and
virtual assistants. These innovations will personalize investment recommendations and improve user experience, fostering
stronger client relationships. India has considerable potential for growth in the broking industry (Chart 3938), as only 4-5%
of India's population actively participating in stock trading, compared to significantly higher rates in countries like the United
States (55%), the United Kingdom (33%), and China (13%).
Retail and HNI broking in India
India’s broking landscape is undergoing a structural transformation, led by a generational shift in retail investor behaviour and
digital adoption. The younger, tech-native investor cohort is increasingly prioritising accessibility, low costs, and convenience
over traditional relationship-based broking. Retail investors, particularly in Tier 2 and Tier 3 cities, are gravitating towards
mobile-first platforms offered by brokers, which provide ease of onboarding and direct market access with minimal human
intervention. Conversely, HNIs remain relationship-driven, with a clear preference for research-backed advisory, portfolio-
level insights, and integrated offerings such as wealth management, PMS, and lending solutions are services typically anchored
within full-service broker models.
413The regulatory environment has become a key pivot point for broking business models. Recent directives by SEBI to
standardise pass-through charges and restrict misaligned incentives in the F&O space are aimed at promoting market integrity
but pose near-term headwinds to broker profitability especially for firms that relied heavily on high-frequency retail trades.
This is particularly true for discount brokers that monetised through transaction-linked revenues. Full-service brokers, though
relatively insulated due to diversified revenue streams, are not immune to margin compression. There is a growing emphasis
on compliance, risk-based profiling, and suitability frameworks, which may constrain aggressive customer acquisition but
improve long-term sustainability and client trust.
The competitive landscape is being reshaped by the aggressive market share gains of discount brokers, which are
commoditising core broking services and forcing full-service firms to reassess their positioning. In response, full-service
brokers are adopting a dual strategy: expanding premium advisory for affluent clients while launching digital arms to engage
cost-sensitive investors. As zero-brokerage models erode traditional revenue streams, brokers are increasingly monetising
through ancillary offerings like research subscriptions, asset distribution, and lending solutions.
Key Growth Drivers for the Indian Broking Industry
• Favourable Demographics
India has one of the youngest populations globally, with around 55% population under 35 years of age in 2021. This young
demographic is inclined towards digital solutions and wealth creation, with growing interest in investing in capital markets.
With a median age of 28, compared to 38 in China and 39 in the US, India’s young population presents a long-term growth
opportunity for the broking industry as they begin investing early in their careers. This trend is expected to continue, with the
median age remaining below 35, maintaining favourable demographics for the country.
Indicator 2011 2016 2021 2026P 2031P 2036P
Population by broad age- group (000’)
18 years and above 7,62,839 8,51,653 9,38,959 10,16,567 10,85,563 11,48,803
0-14 3,73,893 3,62,202 3,49,990 3,39,222 3,23,258 3,06,374
15-59 7,35,424 8,10,687 8,75,446 9,23,857 9,62,091 9,88,476
60+ 1,01,538 1,18,185 1,37,570 1,62,829 1,93,426 2,27,438
Proportion (percent)
0-14 30.9 28.1 25.7 23.8 21.9 20.1
15-59 60.7 62.8 64.2 64.8 65.1 64.9
60+ 8.4 9.2 10.1 11.4 13.1 14.9
Median age (years) 24.92 26.55 28.34 30.27 32.38 34.48
Source: National Health Profile Statistics, CareEdge Research; P: Projected
• Low Penetration of Capital Markets
The Indian equity market has historically seen low participation rates compared to developed countries. Near about 4-5% of
Indians invest in the stock market, compared to United States (~55%), United Kingdom (~33%) and China (~13%). This
leaves significant room for growth as awareness and financial inclusion efforts expand. With increasing digital literacy and
initiatives to encourage investments, market penetration is expected to rise significantly in the coming years.
Chart 39: Country-wise percentage of population investing in stock market
414Source: CareEdge Research, figures are approximate
• Increasing Investment in Shares & Mutual Funds (as % of Savings)
The proportion of household savings allocated to shares and mutual funds is on the rise. As per NSE analysis, it is estimated
to have been at 8% each for Equity and Mutual Funds in FY24E and is expected to rise to reach ~12% until FY33. This shift
will be significant given the traditional preference for physical assets like gold and real estate in India. The increased allocation
to financial assets reflects changing investment behaviour, driven by higher awareness and attractive returns offered by equities
and mutual funds over the long-term period.
Chart 40: Split of Household Financial Savings by asset class
330-360 480–520 700–750 1,000–1,100
6% 6% 6% 6%
8% 9% 10% 12%
20% ~20% ~20% ~20%
6%
8% 7% 8% 9%
9%
11%
12%
52% 48% 44% 41%
FY24E FY27P FY30P FY33P
Total Housing Financial Assets (Rs.
Cash & Deposit Mutual Fund Pension Life Insurance Equity Others Trillion)
Source: NSE Analysis, RBI, MOSPI Statistics, CareEdge Research; P: Projected
• Penetration in Tier 2 Cities and Beyond
• India’s asset management industry, including mutual funds, PMS, and Alternative Investment Funds (AIFs), has grown by
over 20% in the past decade (FY15 – FY25) The rise of digital trading platforms has enabled brokerage firms to expand beyond
major cities, with over 60% of investments now coming from Tier 2 and Tier 3 cities. This growth is driven by improved
internet connectivity, increasing financial literacy, and targeted marketing efforts.
• Role of Technology and Tech Platforms
415The rise of fintech platforms, algorithmic trading, and AI-driven investment advisory tools has simplified the trading process,
attracting younger, tech-savvy investors. Cloud computing, real-time data analytics, and secure digital payments are
transforming broker operations, making trading more accessible and cost-effective.
• Rising Retail Participation
• Retail participation in India’s trading markets has surged, fuelled by the growing use of mobile trading platforms and awareness
of derivatives as hedging tools. Retail traders’ share of derivatives trading volumes has increased dramatically, from 2% in
2018 to 41% in 2023, establishing India as a global leader in derivatives trading. During FY25, the notional turnover of equity
derivatives traded on NSE reached Rs. 78,359 lakh crore. Additionally, SEBI’s introduction of more derivative products has
enhanced market liquidity and depth, creating new revenue opportunities for brokers.
Key Risks and Challenges
Challenge Area Details
Evolving SEBI regulations—such as higher margin requirements and stricter compliance
Regulatory Changes
norms—are increasing operational burdens, particularly for smaller brokerage firms.
The shift toward uniform transaction fees and the removal of volume-based discounts is
Revenue Pressures
expected to compress profit margins, especially for discount brokers.
Growing digitalization has heightened exposure to cyber threats and data breaches,
Cybersecurity Risks
necessitating substantial investments in cybersecurity infrastructure.
The inherent volatility in Indian capital markets—especially in the derivatives segment—poses
Market Volatility
challenges for brokers in managing margins and ensuring client liquidity.
Rising regulatory and compliance costs may lead to market consolidation, with smaller brokers
Consolidation Pressure
struggling to compete with larger, well-capitalised players.
The Indian financial services sector is highly competitive and fragmented. As of September
Intense Competition
03, 2025, nearly 4,900 brokers are registered with SEBI under the equity segment.
Key Strengths and Weaknesses
Strengths Weaknesses
Technology and Innovation: Adoption of advanced High Competition: Numerous players offering similar
platforms, algorithmic trading, and real-time data services lead to price wars, thinner margins, and low
improves efficiency and user experience. differentiation.
Financial Advisory & Research Services: Full- Lack of Awareness in Rural Areas: Limited
service brokers provide valuable insights and advice, understanding of capital markets in rural/semi-urban
increasing client loyalty. Rapid Growth of Retail regions restricts market penetration. Cybersecurity
Investors: Increase in retail participation driven by Risks: Increased digital exposure heightens risk of
literacy, accessibility, and policy support. cyber threats, affecting investor confidence.
Regulatory Framework and its potential impact on the Broking Industry
1. QSB Framework
Objective & Framework
The Qualified Stock Broker (QSB) framework, introduced by the Securities and Exchange Board of India (SEBI), aims to
identify and regulate key brokerage firms that are vital to the market infrastructure. QSBs are selected based on specific
thresholds and criteria and are subject to stricter regulatory requirements due to their systemic importance.
The framework evaluates stockbrokers based on four key parameters:
4161. Active Clients: The number of active clients maintained by the broker.
2. Total Assets: The total value of assets held by the broker’s clients.
3. Trading Volumes: The total trading volume executed by the broker, excluding proprietary trading.
4. End-of-Day Margin Obligations: The margin obligations of the broker's clients at the end of the trading day, excluding
proprietary margins.
Each broker’s score for these parameters is calculated relative to the overall market, using a proportional method. For example,
a broker's score for active clients is based on their share of the total active clients across all brokers, and the same method
applies to the other parameters.
The total score for each broker is derived by summing the individual scores across all parameters. The data for scoring is taken
as of December 31st of the respective financial year. Exchanges assign scores to brokers based on their relative performance,
ensuring transparency, and helping investors make informed decisions.
Potential Impact of Qualified Stock Broker (QSB) framework on the Broking Industry
Increased Investor Protection: QSBs, with stricter risk management and compliance requirements, are better equipped to
protect investor assets and reduce the risk of fraud or mismanagement. Higher capital reserve requirements ensure these
brokers can absorb market shocks, safeguarding both retail and institutional investors. This added protection is especially
important for retail investors, who are more vulnerable to market volatility.
Improved Transparency and Governance: QSBs must adhere to higher governance standards, leading to improved
transparency in their operations and decision-making. This includes clearer disclosures of financial health, risks, and conflicts
of interest, benefiting all market participants. Enhanced governance practices, such as independent oversight and stringent
internal audits, increase corporate accountability, making QSBs more reliable.
Investor Confidence: The enhanced regulations and oversight around QSBs are likely to bolster investor confidence, as
clients will have greater assurance in the broker’s ability to manage risks and operate transparently.
Rise of Discount Brokers: Emerging discount brokers may seek QSB status as they expand their client base and market share.
This could spur further industry innovation, as digital platforms strive to meet regulatory standards while continuing to provide
low-cost, tech-driven services.
2. Recent SEBI guidelines on F&O trading
SEBI has introduced a set of new measures to restructure the equity derivatives trading framework in India:
Regulatory Measure Objective / Impact
SEBI increased the minimum contract value for derivatives trading
from the current range of Rs. 0.5 to Rs. 15 lakh. This adjustment
To ensure investors maintain
ensures that investors are exposed to appropriate levels of risk in
appropriate exposure to risk in the
the derivatives market. SEBI also announced plans to eventually
derivatives segment.
adjust the contract size further, setting the value between Rs 15 lakh
and Rs. 20 lakh in the future.
To tackle market volatility on expiry days, starting November
2024, SEBI has enforced an additional extreme loss margin (ELM) To protect investors from sharp
of 2% on all open short option positions on the day of expiry. This market fluctuations during volatile
measure is designed to protect investors against extreme market trading sessions.
fluctuations, particularly during high-volume trading periods.
Starting November 20, 2024, SEBI has limited weekly expiries for
index derivatives to one per benchmark index per exchange, To reduce speculative trading and
reducing the total from 18 to 6 contracts per month. This move aims manage risks from uncovered option
to reduce speculative trading and manage risks related to uncovered selling.
or naked option selling.
417Regulatory Measure Objective / Impact
To discourage speculative expiry-day
Removal of Calendar Spread Benefits Calendar spread margin
trading and strengthen market
benefits removed for contracts expiring on the same day.
discipline.
Starting February 2025, SEBI has eliminated calendar spread
To curb excessive intraday leverage
benefits for contracts of the same underlying assets but with
and ensure investors have adequate
different expiring dates, a change that seeks to minimize
collateral.
speculative trading, particularly on expiry days.
From April 1, 2025, stock exchanges have begun to conduct
intraday monitoring of position limits in equity index derivatives. To prevent unnoticed breaches of
This means that position limits will be tracked and checked regulatory limits and enhance
multiple times throughout the trading day, preventing traders from compliance.
exceeding their permissible limits unnoticed.
Starting October 1, 2024, SEBI introduced a new rule mandating
uniform transaction fee for market infrastructure institutions
(MIIs), including stock exchanges. This rule could diminish the
competitive edge of discount brokers, who typically thrive on high
trading volumes and offer low fees. Traditionally, discount brokers To level the playing field, potentially
charged lower fees to attract high-frequency traders, leveraging affecting the pricing advantage of
their high volumes to maintain profitability. However, with SEBI's discount brokers.
new rule enforcing a standardized fee structure across the board,
these brokers will lose their ability to offer significantly cheaper
rates, reducing their pricing advantage over full-service brokers
and potentially impacting their market share.
As per SEBI study released on 07th July’25, 9 out of 10 individual
traders in the equity futures and options segment continued to incur To protect retail investors and
significant losses. Way forward the equity F&O segment is likely potentially limit their participation in
to witness strict guidelines for individual investors, which may high-risk F&O trading.
impact investor participation within the segment.
3. Impact of upcoming regulatory changes on Assisted and Non-Assisted Brokers
Below are some upcoming regulatory changes that could affect both assisted mode brokers (those offering advisory services
and personal interaction) and non-assisted mode brokers (digital platforms and discount brokers with minimal human
intervention):
• Stricter Compliance and Reporting Standards
Assisted Brokers (Full-Service Brokers): SEBI’s heightened compliance requirements, such as quarterly audits
and higher capital ratios, will prompt full-service brokers to invest in regulatory technology and compliance teams.
While this will increase operational costs, it will also enhance their credibility, particularly with high-net-worth
and institutional clients, boosting trust and loyalty.
Non-Assisted Brokers (Digital and Discount Brokers): Non-assisted brokers will need to strengthen cybersecurity
and data protection measures, leading to higher tech investments, which may reduce their cost advantage.
• Fee Structures and Transparency
Assisted Brokers: With the move towards uniform transaction fees, assisted brokers may adjust service fees or
advisory charges to offset the elimination of volume-based discounts. This will allow them to maintain elevated
levels of personalized service, appealing to clients who value tailored advice.
418Non-Assisted Brokers: Operating with thin margins, non-assisted brokers may pass on higher costs to users,
potentially reducing their low-cost appeal.
• Customer Due Diligence (KYC/AML Updates)
Assisted Brokers: Stricter KYC and AML norms will require more robust due diligence, adding operational
complexity. However, these measures will strengthen client trust, particularly among high-net-worth individuals
who seek personalized services for managing complex portfolios.
Non-Assisted Brokers: The automation of real-time KYC and verification will be key, but this will require
significant tech upgrades.
• Derivative and Margin Norms
Assisted Brokers: New margin rules for F&O trading will encourage assisted brokers to advise clients on risk
management, reinforcing their advisory role and making them essential for navigating complex derivatives strategies.
Non-Assisted Brokers: Non-assisted brokers (discount brokers) are largely dependent on F&O transactions for their
broking revenue as most of them offer zero or minimal brokerage for equity delivery transactions. Due to changes and
restrictions in derivative contracts, margin norms, etc. retail-focused brokers may see reduced F&O volumes as fewer
retail clients will be able to meet the new margin requirements. Further, fewer expiry days will also lead to reduced
F&O volumes and therefore is expected to have negative impact on the revenue of non-assisted brokers (discount
brokers).
Asset Management & Distribution
Size and Growth of HNIs in India
High net-worth individual (HNI) is someone with a net worth of USD 1 million or more, including their primary residence,
while Ultra HNI is someone who has a net worth of USD 30 million or more across financial and physical assets. India has
one of the world’s fastest growing HNI population both in terms of the number of individuals and the wealth levels.
Chart 41: HNII and Ultra HNIs Population in India
2,000
d 1,657
n
a
s u 1,500
o
h
T
n 1,000 809 797
i
n
o
it
a 500
lu
p 12 12 19
o
P -
2017 2022 2027(P)
HNI UHNI
Source: Industry Sources, CareEdge Research, Data are provisional
Note: P indicates that the data projected
In 2022, the UHNI population grew by around 5% CAGR over 2017. The number of UHNIs in India increased exponentially
and reached around 12 thousand in 2022. By 2027, HNI population is projected to grow at a CAGR of 6.5% over 2022.
In the medium to long term, UHNI, HNI and affluents segment are likely to see tremendous growth on the back of growth in
Indian economic, rising affluence and financialization of assets. India’s HNI population is expected to grow more than double
by 2027 over 2022, making it one of the world's fastest-growing wealth markets.
419Investment advisory services
Investment advisory services enable individuals, businesses, and institutions to manage their investments effectively. These
services typically involve evaluating a client’s financial goals, risk tolerance, and investment timeline, and managing a
customized investment strategy. Over time, brokers have expanded their offerings to include investment advisory, AIF/PMS,
and distribution of financial products like mutual funds.
The main elements of investment advisory services include:
• Financial Planning: Advisors develop a comprehensive plan to meet financial objectives, such as retirement,
education savings, purchasing a home, or estate planning.
• Portfolio Management: Advisors create, implement, and monitor an investment portfolio of assets (like stocks,
bonds, or mutual funds) that aligns with the client's risk profile and goals.
• Investment Selection and Advice: Based on market research and analysis, advisors recommend investments suited
to the client’s needs and objectives.
• Ongoing Reviews and Adjustments: Advisors regularly update clients on portfolio performance and adjust
strategies as necessary based on changes in the market or the client’s circumstances.
• Education and Client Support: Advisors help clients understand financial markets, investment products, and
strategies to enable informed decision-making.
• Foreign Investing Through Indian Brokers: With the expansion of investment advisory services, brokers now
support foreign investing through structures like the Foreign Portfolio Investor (FPI) framework. They assist global
clients including individuals, foreign institutions, etc in accessing India’s equity, debt, derivatives, and alternative
markets while ensuring compliance with SEBI and RBI regulations. Services include onboarding, KYC, tax planning,
reporting, portfolio construction, risk management, and currency hedging. Despite challenges like currency
fluctuations, taxation, and compliance requirements, advisory support helps investors navigate these complexities.
With liberalised norms and growing global allocations to emerging markets, Indian brokers play a crucial role in
enabling foreign participation in India’s capital markets.
Investment advisors can be human professionals, automated robot-advisors (providing algorithm-driven recommendations),
or hybrid models combining both approaches. In India, SEBI regulates these services to ensure transparency and protect client
interests.
Alternative Investment Funds
Overview
As per SEBI, Alternative Investment Fund or AIF refers to any fund established or incorporated in India that operates as a
privately pooled investment vehicle which collects funds from sophisticated investors, whether Indian or foreign, to invest
them in accordance with a defined investment policy for the investors benefit. AIFs does not include funds covered under the
SEBI (Mutual Funds) Regulations, 1996, SEBI (Collective Investment Schemes) Regulations, 1999 or any other regulations
of the Board governing fund management activities.
Types of AIFs
Funds can seek registration under three categories – Category I, Category II and Category III.
• Category I: Invests in start-up or early-stage ventures or social ventures or SMEs or infrastructure or other sectors or areas
which the government or regulators consider as socially or economically desirable and shall include venture capital
funds, SME Funds, social impact funds, infrastructure funds, special situation fund.
• Category II: Category II are those funds which do not fall in Category I and III and which does not undertake leverage or
borrowing other than to meet day-to-day operational requirements and as permitted in these regulations.
• Category III: Category III are those funds which employ diverse or complex trading strategies and may employ leverage
including through investment in listed or unlisted derivatives.
Growth of AIFs in India
420Chart 42: AIFs Commitments have surged annually (Rs. Lakh crore)
13.5
11.3
s
e
r
o
r 8.3
C
h 6.4
k a 5.6 5.4
L 4.5 4.5
. s 3.7 3.1 2.8 3.7 3.4
4.1
R 1.9 1.5 2.3 2.0
Mar-20 Mar-21 Mar-22 Mar-23 Mar-24 Mar-25
Commitments Raised Funds Raised Investments Made
Source: SEBI, CareEdge Research
AIFs commitments have grown sharply with the annual growth rate remaining in high double digits. As of Mar’25, AIFs have
received commitments worth Rs. 13.5 lakh crore growing at a CAGR of 29.5% between FY20-FY25. Of these commitments
received, ~42% of the funds have been raised and of these funds ~96% investments have been made. Category II funds are
the highest contributor in terms of commitments for AIF, accounting for over 76% of total commitments, indicating the
popularity of private equity funds or debt funds. Followed by Category III and Category I funds accounting for 17% and 6.6%
share in total commitments respectively, in FY25.
Portfolio Management Services (PMS)
PMS is a category of professional financial services governed by the SEBI Portfolio Manager Regulations. A professional
portfolio manager offers customised investment solutions to high net-worth individuals (HNIs) who are seeking to invest in
instruments such as equity, debt, gold and more. The minimum investment limit for PMS is Rs 50 lakh. PMS invests on behalf
of its clients in separately managed accounts in various securities including listed equities, unlisted equities, fixed income
instruments, hybrid, or structured products and others. A PMS can be primarily structured in three ways – Discretionary
Portfolio Management, Non-Discretionary Portfolio Management, and Advisory Portfolio.
Portfolio Management Services Grows at a Steady Pace
Chart 43: PMS AUM Grows at a CAGR of 15.8% between Mar’20 to Jun’25
45 25%
40 19.4%
35 17.0% 14.9% 20%
s 30 13.9% 13.9% h
e r 13.0% 12.4% 15% t w
o 25
r o
c r
h k 20 37.8 39.3 10% G Y
a 15 -
L 27.8 o
. s R 10 18.1 20.7 24.2 33.2 5% Y-
5
0 0%
Mar'20 Mar'21 Mar'22 Mar'23 Mar'24 Mar'25 Jun'25
Source: SEBI, CareEdge Research
Services under Portfolio Management Services
421Discretionary: Services where the choice and the timings of the investment decisions rest solely with the Portfolio
Manager are termed as discretionary service.
Non-Discretionary: Services where the Investor is responsible to choose the investment and the time of investment.
While the role of portfolio manager is only to suggest the investment ideas and execute the trade are termed as Non-
Discretionary Services.
Advisory: Services where the role of portfolio manager is only to suggest the investment ideas. While the Investor is
responsible to choose the investment and execute his investment decisions.
Chart 44: AUM by Services under PMS
n
o
illiB
s
R
7 7 0 ,5 2 5 1 ,1 5 1 9 ,1 5 1 5 ,7 1 1 3 ,1 6 4 8 ,1 1 5 3 ,0 9 5 7 ,1 2 8 0 ,2 7 0 3 ,3 0 9 2 ,2 8 9 1 ,2 2 5 6 ,7 0 1 7 ,2 3 2 8 ,2 2 2 7 7 ,1 1 3 0 ,3 0 6 9 ,2 8 7 6 0 ,3 5 7 1 ,3 8 3 0 ,3 8
1 0 1 0 2 0 2 1 2 1 3 3 3 4
Mar-20 Mar-21 Mar-22 Mar-23 Mar-24 Mar-25 Jun-25
Discretionary Non-Discretionary Advisory Co-Investment
Source: SEBI, CareEdge Research
As of Jun’25, the AUM of the portfolio management industry reached nearly Rs. 39 lakh crore of which discretionary service
category contributed the most (~84.1%) followed by non-discretionary services (~8.1%). While the Advisory service
contributed to around Rs. 3 lakh crore of the total AUM which is 7.7% of the AUM of portfolio management industry.
There were over 1.95 lakh clients in portfolio management industry as of Jun’25. Of these, ~96% clients were of discretionary
services category 3.3% clients in non-discretionary services category, and 0.6% clients availed advisory services of portfolio
managers.
Securities Lending and Borrowing (SLBM)
Securities Lending and Borrowing Mechanism (SLBM) is an established market framework that facilitates the temporary
transfer of securities between two market participants (a lender and a borrower) through an approved intermediary such as a
recognised stock exchange or clearing corporation. Under this structure, while institutional investors like mutual funds,
insurance companies, and pension funds are major participants to lend securities from their portfolio. Retail investors can also
lend securities from their demat accounts, thereby broadening access to this mechanism and creating additional income
opportunities. Borrowers typically trading entities or individuals, for a predefined period and at an agreed fee. The mechanism
provides a regulated, efficient, and secure process for such transactions, allowing participants to generate short term gains, with
easy and quick settlement.
Distribution Services (Depository Services, FD, Bonds)
Depository Services
Depository services facilitate the electronic holding and transfer of securities, eliminating the need for physical certificates.
They ensure secure, efficient, and transparent transactions while supporting faster settlement cycles. Brokers offering
depository services act as intermediaries between investors and the depository, helping clients open and manage demat
accounts. They enable electronic transactions, ensure compliance with regulatory requirements, and assist with account
maintenance and security.
422Chart 45: Investor Accounts
1,991
1,924
s
h
k 1,514
a
L
n 1,145
i
s 897
e
r
u 551
g
iF 409
Mar-20 Mar-21 Mar-22 Mar-23 Mar-24 Mar-25 Jun'25
Source: SEBI Bulletin, CareEdge Research
Note: The above data indicates investors accounts are registered with NSDL and CDSL
Retail investors’ preference is becoming more mature as they get more informed regarding potential of capital markets and
risk associated with investing in it. This increasing awareness has led to significant growth in retail participation, with investor
accounts registered with NSDL and CDSL reaching 1991 lakhs as of Jun’25.
Fixed Deposit Services
Fixed deposits (FDs) facilitate the mobilisation of retail and institutional savings into term deposit instruments offered by
banks and deposit taking NBFCs. Fixed deposit service providers act as intermediaries, enabling customers to access a wide
range of deposit products with varying tenures and interest rates, while ensuring regulatory compliance, documentation, and
ease of account management. FDs remain a popular investment option due to their capital protection, predictable returns, and
lower risk profile.
Chart 46: SCBs Deposits
203.5
198.8
180.3
s 158.6
e
r 143.9
o r 132.5
C 119.5
h
k
a
L
.
s
R
Mar-20 Mar-21 Mar-22 Mar-23 Mar-24 Mar-25 Jun-25
Source: RBI, CareEdge Research
Term deposits of SCBs have shown steady growth from Rs. 119.5 lakh crore in Mar-20 to Rs. 203.5 lakh crore in Jun-25,
reflecting a CAGR of 10.7%. This consistent increase highlights investors’ preference for secure and predictable returns,
especially during periods of economic uncertainty and fluctuating markets. The upward trend suggests that term deposits
continue to be a key savings instrument, supported by regulatory policies and fixed interest rates.
Bond distribution services
In addition to this, bond distribution services play a critical role in connecting issuers such as corporations, government
bodies, and financial institutions with investors seeking fixed-income instruments. These services provide advisory support,
423pricing insights, and access to primary and secondary bond markets, helping investors diversify portfolios and manage interest
rate or credit risk. By streamlining issuance, underwriting, and settlement processes, distribution platforms enhance liquidity
and participation in debt markets.
Chart 47: Outstanding Corporate Bonds Issued
53.6
47.2
43.2
40.2
s 38.1
e
r 34.1
o
r
C
h
k
a
L
.
s
R
Mar-20 Mar-21 Mar-22 Mar-23 Mar-24 Mar-25
Source: SEBI, CareEdge Research
Note: Data indicates outstanding corporate bonds issued by financial and non-financial corporations held in NSDL and CDSL
system.
Corporate bonds have shown a steady growth trend from Rs. 34.1 lakh crore as of Mar-20 to Rs. 53.6 lakh crore as of Mar-
25, growing at a CAGR of 9.5%. This growth reflects increasing corporate borrowing as businesses source funds from debt
markets for capital expenditure, refinancing, and expansion purposes. The consistent rise also signals improving market depth,
investor participation, and regulatory support. While credit quality and interest rate volatility challenges persist.
Domestic Mutual Fund Industry
A mutual fund is a collective investment vehicle that collects & pools money from several investors and invests the same in
equities, bonds, government securities, and money market instruments. The money collected in a mutual fund scheme is
invested by professional fund managers in stocks and bonds etc. in line with the scheme’s investment objective. The income
or gains generated from this collective investment scheme are distributed proportionately amongst the investors, after
deducting applicable expenses and levies, by calculating a scheme’s “Net Asset Value” or NAV. In return, mutual fund charges
a small management fee.
Domestic Mutual Fund Industry Has Grown Rapidly
424Chart 48: Growth in Domestic Mutual Fund Industry AUM and outlook
112-115
n
o 74.4
illir 66.9 65.7
T 53.4
.
s
R 37.6 39.4
31.4
22.3
FY20 FY21 FY22 FY23 FY24 9MFY25 FY25 Q1FY26 FY29
Source: AMFI, CareEdge Research Estimates
Note: AUM as of the last day of the month; FY- financial year ended March
The outlook for mutual fund AUM growth remains positive, driven by factors such as rising financial literacy, increased
awareness, and a growing preference for mutual funds as a wealth-building tool. The expansion of digital platforms has made
mutual fund access more convenient, while government initiatives promoting systematic investment plans (SIPs) and long-
term savings support further growth. With India’s economy continuing to expand, a rising middle class, and an increased focus
on financial planning, mutual funds are expected to see AUM grow at 12-15% annually between FY25 and FY29.
Chart 49: Share in Domestic Mutual Fund AUM
46.2% 44.9% 42.7% 39.9% 36.6% 37.2%
35.5% 35.1%
32.6% 32.7% 34.5%
34.8%
19.0% 22.4% 24.6% 25.6% 28.0% 27.7%
FY20 FY21 FY22 FY23 FY24 FY25
Retail HNI Institutional*
Source: AMFI, CareEdge Research
Note: Institutional includes Corporate, Banks/FIs, FIIs share in industry AUM;
AUM as of the last day of the month; FY- financial year ended March
Between FY20 and FY25, retail AUM has grown at a CAGR of 34%, reaching Rs. 18.2 lakh crore as of FY25 and accounting
for 27.7% of industry AUM. This growth in retail AUM reflects an increasing preference for mutual fund investments amongst
retail investors. HNIs AUM grew at a CAGR of 24.4% between FY20-FY25, reaching Rs. 23.1 lakh crore as of Mar’25.
Institutional AUM also grew albeit at a slower pace than retail & HNI AUM, at a CAGR of 18.9% between FY20-FY25,
reaching Rs. 24.5 lakh crore as of Mar’25.
FY25 was a standout year for the Indian mutual funds industry, with assets under management (AUM) increasing by Rs 12.3
lakh crore, reaching a record 65.7 lakh crore as of Mar’25 up from Rs. 53.4 lakh crore as of Mar’24, demonstrating strong
market performance and investor confidence.
Penetration of mutual funds in India
425India continues to be underpenetrated with a mutual fund penetration rate (the ratio of period ending mutual fund AUM
to GDP) reached nearly 35% as of Mar-25, as compared to global average of 70-80%. India accounts for less than 2%
of the global mutual fund industry, representing a significant growth opportunity.
Chart 50: Mutual fund penetration
35.0%
P
D 30.1%
G
o t 22.9% 24.6% 24.2%
M
U
Ao
dit
a 15.3%
nr
u
F
la
u
t
u
M
FY20 FY21 FY22 FY23 FY24 FY25
Source: AMFI, MOSPI, CareEdge Research
T-30 and B-30 statistics
Increase in Retail participation and mass affluent
Chart 51: Growth in B30 and T30 Assets (Rs. Lakh crore)
18.7
Mar-20
3.6
26.9
Mar-21
5.2
31.5
Mar-22
6.2 T30 B30
33.2
Mar-23
6.8
45.2
Mar-24
9.8
54.5
Mar-25
12.2
61.0
Jun-25
13.8
Source-AMFI, CareEdge Research
426Chart 52: B30 and T30 Asset Mix
21% 16% 14% 14%
52% 47% 46%
54%
79% 84% 86% 86%
46% 48% 53% 54%
B30 T30 B30 T30 B30 T30 B30 T30
Mar-23 Mar-24 Mar-25 Jun-25
Equity oriented scheme Debt oriented scheme
Source-AMFI, CareEdge Research
Earlier there was lack of healthy participation from investors in B30 (beyond top 30) locations. Recently, the mutual fund sector
is witnessing rising activity from B30 locations, especially in the equity segment due to improved distribution and regulatory
changes in fee structure. Furthermore, increasing mobile phone penetration and wealth managers integration towards technology
to service transparent and systematic products in an efficient manner has enabled distributors to penetrate deeper to serve clients
across the wealth management space.
Chart 53: Individual investors' assets – Overall Composition – Jun-25
B30 Direct, 7%
T30 Direct, 20%
T30 Distributors,
52%
B30 Distributors,
21%
Source-AMFI, CareEdge Research
Note: Individual investors include HNIs
Individual assets are primarily distributor driven. Distribution channels accounted for 73% of total mutual fund assets under
management (AUM) as of Jun’25, of which 52% belongs to the top 30 cities. Direct investments amount to 27% of individual
assets, of which 7% of individual assets were from B30 and 20% of individual assets were from T30.
Indian mutual fund number of folios (retail)
The growth in retail folios in mutual funds reflects an increasing trend of individual investors seeking portfolio diversification
and long-term financial goals. Retail investors are recognizing the advantages of mutual funds, including professional
management and liquidity. Additionally, initiatives promoting SIPs have further spurred participation, leading to substantial
427growth in retail folios. As of the first nine months of FY25, the total number of folios stood at 225 million, with over 206
million under equity, hybrid, and solution-oriented schemes—where retail investment is most prominent.
Chart 54: Indian Mutual Fund number of Folio Basis (Retail)
22.0
21.5
s
e
r 16.3
o
r
C
n 13.3
i
s 11.8
o
ilo
F 8.8
8.1
f
o
.
o
N
Mar-20 Mar-21 Mar-22 Mar-23 Mar-24 Mar-25 Jun-25
Source: CMIE, CareEdge Research
Note: Figures have been round-off to the nearest integer
Retail participation in Indian mutual funds has seen a sharp and consistent uptick, with the number of folios growing at a CAGR
of ~21.7% between Mar’20-Jun’25, reaching 22 crore by Mar’25. This strong growth reflects increasing retail investor
confidence, growing financial savings, and increasing penetration of mutual fund products across Tier II and III cities. Over the
years, retail participation has been supported by digital onboarding, SIP culture, financial awareness, and regulatory initiatives
that promote transparency, trust and focus on financial inclusion.
SIP contribution
The significant increase in retail folios is attributed by positive sentiments of retail investors, participating in a disciplined
manner through SIPs. Post COVID-19, India’s capital markets have experienced influx of retail investor leading to increase
in asset allocation towards mutual funds. Mutual Fund outstanding SIPs accounts stood at 10 crore accounts as of FY25 and
at ~9.2 crore accounts as of Q1FY26. The total contribution through SIPs was Rs 2,89,352 crore during FY25, indicating a
CAGR of 23.7% between FY20-FY25. and Rs 80,589 crore as on Q1FY26. As of Q1FY26, the contribution reached Rs 80,589
crore, while it was Rs 62,537 crore as of Q1FY25, indicating a y-o-y growth rate of 28.9%.
Chart 55: SIP Contribution
2,89,352
1,99,219
e
r
o
r 1,55,972
C
. s 1,24,566
R
1,00,084 96,080
80,589
62,537
FY20 FY21 FY22 FY23 FY24 FY25 Q1FY25 Q1FY26
Source: CMIE, CareEdge Research
428Trends in Mutual Fund Distributors Commission
The commissions paid by mutual funds to distributors grew from around Rs. 0.06 lakh crore in FY20 to around Rs.
0.21 lakh crore in FY25, indicating a CAGR of around 28%. Increased financial savings, superior returns from mutual
funds, greater reliance on distributors and government policies functioned as key catalysts in driving the distribution
revenue growth.
Chart 56: Mutual Fund Distributor Commission (Rs. Billion)
0.21
58%
e
r o 0.15
r 42%
C 0.12
h 8% 0.10
k
a
L 24%
. 0.06 0.07 15%
s
R
-22%
FY20 FY21 FY22 FY23 FY24 FY25
Distribution Commison Y-o-Y Growth
Source-AMFI, CareEdge Research
As the Indian mutual fund industry expands, driven by rising assets under management and a broader investor base, the demand
for professional advisory and distribution services is expected to increase. Regulatory changes promoting fee transparency
may lead to a shift toward fee-based advisory models, allowing distributors to earn ongoing commissions rather than one-time
sales fees. As financial literacy improves, more investors are likely to seek guidance, offering distributors opportunities to
build long-term relationships and enhance revenue. Furthermore, with the growth of digital platforms and robo-advisors,
traditional distributors providing personalized, value-added services may see increased commissions from managing larger,
diversified portfolios.
Key Growth Drivers for Mutual Fund Distributors
Drivers Details
Investor participation from B30 (Beyond Top 30) locations has traditionally remained
limited. However, improved distribution networks and revised fee structures have driven
growth in the equity mutual fund segment. By March 2025, distributors managed
Increasing Penetration of the
approximately 73% of total individual investors’ assets, with 52% originating from Top 30
Mutual Fund Market in India
(T30) cities. Direct investments accounted for 27%, including 20% from T30 and 7% from
B30 locations. These trends reflect a gradual increase in investor activity from non-metro
regions.
Asset management companies and distributors have accelerated digital transformation by
adopting mobile applications and online platforms. These innovations have simplified
Driving Digital Transformation
transactions, improved investor convenience, and reduced operational costs. Digital
solutions have also extended mutual fund access to underserved geographies.
SEBI has implemented regulatory reforms to enhance transparency, safeguard investors,
Strengthening Regulatory Support and maintain market integrity. These initiatives have fostered fair competition, improved
disclosures, and strengthened investor confidence across the mutual fund industry.
Distributors have formed strategic partnerships with banks, insurance firms, and fintech
Expanding Through Strategic platforms to expand their market reach. These collaborations have promoted financial
Partnerships literacy, enabled the delivery of integrated financial services, and supported sustainable
growth in the mutual fund sector.
429SWOT Analysis of Mutual Fund Industry
Strength Weakness
• Asset managers provide diversified portfolios,
• Clients may switch if returns are inconsistent, or they
reducing risk by spreading investments across
find better-performing funds.
assets and sectors.
• The rise of passive investing and competition
• Advanced analytics, AI, and algorithmic
pressures firms to cut fees, affecting profitability of
trading help optimize strategies and offer real-
the funds.
time insights.
Opportunity Threat
• Tax policy changes, fiduciary regulations, and
• Partnering with fintech and banks helps asset
increased scrutiny can raise compliance costs and
managers expand offerings, reach new
impact operations.
markets, and boost digital capabilities.
• Investment avenues for investors such as equity
• ESG investing opens opportunities for asset
markets, debt market instruments, Mutual Funds,
managers to create specialized funds.
Gold, and other physical assets.
Regulatory scenario in Mutual Funds and Mutual Funds Distribution
Regulatory framework of Mutual funds:
SEBI regulates mutual funds to ensure transparency and investor protection. Mutual fund houses must register with SEBI,
appoint qualified fund managers, and follow guidelines such as diversification, risk management, and disclosures. SEBI also
mandates mutual fund distributors (MFDs) to comply with KYC norms, disclose fees and commissions, and meet regulatory
standards.
Some of Restriction on Investment made by Mutual Funds are as follows:
• A mutual fund scheme shall not invest more than 10% of its NAV in debt instruments, including money market instruments
and non-money market instruments, issued by a single issuer which are rated not below investment grade by an authorised
credit rating agency. This limit may be extended to 12% of the NAV of the scheme with the prior approval of the Board
of Trustees and Board of Directors of the AMC.
• Limits on investments in debt instruments from a single issuer.
• Prohibitions on investing in unlisted debt instruments, except for government securities.
• Restrictions on investing in other mutual funds under the same AMC.
• Mandatory delivery of securities for purchases and sales.
• Restrictions on investments in unlisted securities or private placements by sponsor companies.
• No mutual fund [scheme] shall make any investment in,
• Any unlisted security of an associate or group company of the sponsor; or
a. Any security issued by way of private placement by an associate or group company of the sponsor; or
b. The listed securities of group companies of the sponsor, exceeding 25% of the net assets [except for investments by
equity-oriented exchange traded funds and index funds and subject to such conditions as may be specified by the Board]
• A mutual fund may invest in the units of REITs and InvITs subject to the following:
a. No mutual fund under all its schemes shall own more than 10% of units issued by a single issuer of REIT and InvIT;
b. A mutual fund scheme shall not invest –
i. more than 10% of its NAV in the units of REIT and InvIT; and
ii. more than 5% of its NAV in the units of REIT and InvIT issued by a single issuer.
Regulatory framework of Mutual fund distributor:
430As per SEBI regulations, any person/entity who wants to become a Mutual Fund Distributor is required to fulfil the following
pre-requisites – 1. pass ‘NISM Series V- A: Mutual Fund Distributors Certification Examination’ conducted by NISM and 2.
register with AMFI and obtain AMFI Registration Number (ARN).
In the above context, a non-individual entity applying for ARN should have at least one employee / sales personnel who has
passed the above mentioned NISM examination and register with AMFI & obtained Employee Unique identification Number
(EUIN), to be eligible for allotment of the ARN.
At the time of empanelling distributors and during the review process, the AMC must undertake due diligence process of the
distributor on several factors including business model, experience, proficiency in business, track record, regulatory record /
statutory levies, organizational controls, capacity for customer risk evaluation, ability to customize solutions, and MF scheme
evaluation.
The AMC shall also review the compliance and risk management functions of the distributor, such as:
• The criteria used for review of products and the periodicity of reviews.
• Parameters to consider while evaluating risk appetite of clients and the investment categorization.
• Review of transactions, exceptions identification, escalation, and resolution process by internal audit.
• Recruitment, training, certification, and performance review of all personnel engaged in this business.
• Customer on-boarding and relationship management process
• Servicing standards and grievance handling mechanism
• Internal / external audit processes their comments / observations as it relates to MF distribution business.
• Findings of ongoing review from sample survey of investors.
Further, the SEBI has mandated AMCs are required to undertake the due diligence process of the MFDs satisfying one or
more of the following four criteria at the time of their empanelment and during the review period:
a. Multiple point presence (More than 20 locations)
b. AUM rose over Rs. 1000 million in the non-institutional category but including HNIs.
c. Commission received of over Rs.10 million annually across industry.
d. Commission received of over Rs.5 million from a single mutual fund.
Mutual fund distributors earn trail commissions based on investments mobilized under regular plans of mutual fund schemes.
AMCs follow a full trail commission model, with no upfront commissions or incentives in any form other than trail
commissions. These payments are made monthly, based on the AMC's business policy.
In summary, SEBI enforces strict regulations for mutual fund houses, fund managers, and distributors to ensure transparency,
investor protection, and compliance with industry standards.
Key Threats & Challenges
Particulars Details
Full-service brokers in India face intense competition from discount brokers and foreign
banks. Discount brokers offer low trading fees, which exert downward pressure on
Lower Broking Margins
margins. As a result, full-service brokers struggle to cover fixed costs, leading to practices
such as over-trading, which can cause significant financial losses for retail investors.
Brokers must continuously invest in advanced technologies, trading platforms, and
algorithms to retain clients. Expanding into segments such as commodities and currencies
Increasing Costs and
demands further infrastructure investments. Additionally, the adoption of mobile
Additional Investments
technologies and portfolio management systems increases operational expenses, alongside
mandatory costs such as exchange memberships.
431The complexity of India’s financial markets presents significant risk management
challenges. Economic uncertainty reduces investor confidence, which negatively impacts
fee-based income, including advisory services. Market volatility also affects asset
Risk Management
valuations. To mitigate these risks, brokers must adopt advanced strategies such as
hedging, diversification, and real-time market analysis. Nevertheless, market
unpredictability remains a persistent concern.
Online trading platforms have intensified competition, particularly for mid-sized brokers,
by offering lower fees and diversified investment options such as mutual funds, ETFs, and
Increased Competition
robo-advisory services. These offerings attract investors seeking low-risk alternatives to
and Economic
direct equity trading, prompting client attrition. Moreover, the brokerage industry remains
Uncertainties
highly sensitive to market volatility, economic downturns, and geopolitical developments,
all of which affect investor behaviour and revenue.
The evolving regulatory framework aims to protect investors and enhance transparency.
However, compliance with new reporting and disclosure requirements compels brokers
Regulatory Challenges to invest in advanced systems, increasing operational costs. Furthermore, regulatory
restrictions on margin trading and exposure limits, though intended to reduce volatility,
constrain brokers’ revenue-generating potential.
Peer Comparison
Business Profile
Company Name Business Profile
Shah Investors Home Ltd (SIHL) was incorporated in 1994 and headquartered
Shah Investors Home Limited in Mumbai. SIHL is a retail brokering firm that offers a range of services
(SIHL) covering equity brokerage services and derivatives brokerage services, with over
three decades of experience. These services facilitate the buying and selling of
financial products such as equities, IPO investing, mutual funds distribution, and
other securities. While the core operations of the Company include equity and
derivatives brokerage, it also focuses on providing secondary market brokering
services to retail customers, comprising both resident and non-resident Indians.
SIHL have served over 100,000 demat accounts, with more than 37,810 active
clients and partnerships with over 184 authorised persons and conducts
operations through 11 branches in India, located in Mumbai, Ahmedabad,
Vadodara, Junagadh, Gandhinagar and Rajkot.
Share India Securities Limited Share India Securities Limited (SISL) was incorporated in 1994 and
headquartered in Gujarat, and it has 121 offices across India. The company is
primarily engaged in strategy-based trading business, provides algo-trading
solutions. The company also offers various kinds of financial products and
services, including equity, futures and options (F&O), commodity and currency
broking services, research, lending services, mutual fund (MF) advisory and
distribution, portfolio management services, merchant banking services and
insurance broking services that primarily cater to HNIs.
432SMC Global Securities Limited SMC Global was incorporated in 1990 and headquartered in New Delhi. The
(SMC Global) company offers equity brokerage, commodities and currency trading,
investment banking, wealth management, distribution of third-party financial
products, research, financing, depository services, insurance broking, clearing
services, mortgage advisory, and real estate advisory. The company has served
over 2 million unique customers through its network of 2,550 authorized persons
and franchises. The company operates in 455 cities across India, supported by
over 4,000 employees and a distribution network of 13,600 independent
distributors.
Arihant Capital Markets Arihant Capital Markets Limited (ACML), established in 1992, it offers
Limited (ACML) comprehensive financial services, focusing on retail equity broking. It also
operates in institutional equities, commodities broking, and merchant banking,
while distributing mutual funds and insurance products. With a client base of
over 2.5 lakh individuals and 1,000+ corporate entities, ACML is trusted by over
120 institutions for fund management and trade execution. With spread over 800
investment centres and more than 300 cities in India, ACML showcases
extensive reach and accessibility.
Key Financial Metrics of Shah Investors Home Limited
Financial Financial Financial
Year ended Year ended Year ended
Particulars
March 31, March 31, March 31,
2025 2024 2023
Revenue from operations (Rs. Lakhs) 9,427.39 7,782.36 5,168.30
Profit before Tax (Rs. Lakhs) 3,140.22 2,400.68 988.70
Profit After Tax (Rs. Lakhs) 2,338.50 1,793.38 763.17
Net Worth (Rs. Lakhs) 16,808.98 15,054.13 11,745.98
Ratios
Growth in Revenue from Operations (%) 21.14% 50.58% N.A.
Profit After Tax Margin (%) 24.76% 22.69% 14.58%
EBITDA (Rs. Lakhs) 3,531.31 2,512.97 1,114.59
EBITDA Margin (%) 37.46% 32.29% 21.57%
EBIT (Rs. Lakhs) 3,367.18 2,368.73 982.57
EBIT Margin (%) 35.72% 30.44% 19.01%
RoE (%) 14.68% 13.38% 6.56%
RoCE (%) 20.35% 16.77% 8.13%
Debt to Equity Ratio 0.03 0.02 0.07
Operating Cash Flows (Rs. Lakhs) -3,186.22 11,019.42 0.45
Source: Company reports, CareEdge Research
Operation Metrics:
Shah Investors Home Ltd (SIHL)
Particulars
FY25 FY24 FY23
Operating metrics:
Total number of clients 80,391 76,337 71,690
Active Clients 37,814 35,535 31,372
Growth in Active Clients (%) 6.41% 13.27% -13.16%
Active clients as a % of Total number of clients 47.04% 46.55% 43.76%
Average tenor of client relationship
· Up to 1 year 2,469 1,893 1,022
433Shah Investors Home Ltd (SIHL)
Particulars
FY25 FY24 FY23
· 1 to 2 years 3,720 3,819 4,142
· 3 to 5 years 4,061 2,852 2,671
· More than 5 Years 27,564 26,971 23,537
Total Customer Asset (Rs. lakhs) 42,41,110.67 44,12,085.83 26,31,095.13
Broking Revenue (Rs. Lakhs) 6,491.13 5,570.20 3,702.79
Average broking active client (in ₹) 17,165.95 15,675.24 11,802.85
Margin Trading Facility Book (Rs. Lakhs) 964.22 NA NA
Growth in Margin Trading Facility Book (%) 100.00% NA NA
Total Assets Under Distribution
· Mutual Funds (Rs. Lakhs) 4,916.92 3,753.15 2,626.16
Source: Company reports, CareEdge Research
Peer Competitive Analysis
FY25
Shah Arihant
SMC Global Share India
Particulars Investors Capital
Securities Securities
Home Markets
Limited Limited
Limited Limited
Total Income (Rs. Lakhs)
9,446.51 1,78,572.01 1,46,950.09 24,801.08
Total revenue from operation (Rs. Lakhs)
9,427.39 1,77,574.15 1,44,856.84 24,731.70
Growth in Revenue from Operations (%) 21.14% 8.38% -2.31% 5.18%
EBITDA (Rs. Lakhs)
3,531.31 41,938.99 51,690.60 9,953.95
EBITDA margins (%) 37.46% 23.62% 35.68% 40.25%
PAT (Rs. Lakhs)
2,338.50 14,569.45 32,761.88 5,870.28
PAT Margin (%) 24.76% 8.16% 22.29% 23.67%
Growth in PAT (%) 30.40% -22.20% -22.99% -16.75%
RoE(%) 14.68% 12.60% 16.06% 16.61%
RoCE (%) 20.35% 14.40% 19.98% 21.46%
Debt Equity Ratio 1.39 0.22 0.25
0.03
-
Operating Cash Flows (Rs. Lakhs)
3,186.22 2,353.68 584.88 3,157.61
Note: All the financial information for listed industry peers mentioned above is on a consolidated basis and is
sourced from the annual report of the respective company for the year ended March 31, 2025.
FY24
Shah Arihant
SMC Global Share India
Particulars Investors Capital
Securities Securities
Home Markets
Limited Limited
Limited Limited
Total Income (Rs. Lakhs)
7,905.29 1,64,458.54 1,48,874.88 23,560.57
Total revenue from operation (Rs. Lakhs)
7,782.36 1,63,840.87 1,48,281.45 23,514.36
Growth in Revenue from Operations (%) 50.58% 35.23% 36.26% 70.95%
EBITDA (Rs. Lakhs)
2,512.97 42,590.09 65,596.49 10,720.81
434FY24
Shah Arihant
SMC Global Share India
Particulars Investors Capital
Securities Securities
Home Markets
Limited Limited
Limited Limited
EBITDA margins (%) 32.29% 25.99% 44.24% 45.59%
PAT (Rs. Lakhs)
1,793.38 18,727.65 42,541.89 7,051.04
PAT Margin (%) 22.69% 11.39% 28.58% 29.93%
Growth in PAT (%) 134.99% 55.99% 29.37% 142.16%
RoE(%) 13.38% 18.46% 30.92% 24.35%
RoCE (%) 16.77% 17.95% 38.24% 28.52%
Debt Equity Ratio 1.34 0.23 0.31
0.02
- - -
Operating Cash Flows (Rs. Lakhs)
11,019.42 19,279.43 31,045.02 2,963.17
Note: All the financial information for listed industry peers mentioned above is on a consolidated basis and is
sourced from the annual report of the respective company for the year ended March 31, 2024.
FY23
Shah Arihant
SMC Global Share India
Particulars Investors Capital
Securities Securities
Home Markets
Limited Limited
Limited Limited
Total Income (Rs. Lakhs)
5,232.96 1,21,565.46 1,09,970.24 13,776.03
Total revenue from operation (Rs. Lakhs)
5,168.30 1,21,157.33 1,08,823.41 13,754.77
Growth in Revenue from Operations (%) N.A. 9.51% 26.30% -18.97%
EBITDA (Rs. Lakhs)
1,114.59 26,989.67 49,408.89 5,011.42
EBITDA margins (%) 21.57% 22.28% 45.40% 36.43%
PAT (Rs. Lakhs)
763.17 12,005.47 32,883.17 2,911.76
PAT Margin (%) 14.58% 9.88% 29.90% 21.14%
Growth in PAT (%) -41.31% -31.15% 63.47% -42.18%
RoE(%) 6.56% 12.92% 45.30% 12.00%
RoCE (%) 8.13% 15.10% 51.94% 15.39%
Debt Equity Ratio 1.03 0.20 0.23
0.07
- -
Operating Cash Flows (Rs. Lakhs)
0.45 26,008.43 16,952.16 1,469.16
All the financial information for listed industry peers mentioned above is on a consolidated basis and is sourced
from the annual report of the respective company for the year ended March 31,2023.
Operating Metrics
Share India Securities Limited
Particulars
FY25 FY24 FY23
Operating metrics:
Total number of clients NA NA NA
Active Clients on NSE 7,828 5,679 6,628
Growth in Active Clients (%) 37.8% -14.3% 70.3%
Active clients as a % of Total number of clients NA NA NA
Average tenor of client relationship
· Up to 1 year NA NA NA
435· 1 to 2 years NA NA NA
· 3 to 5 years NA NA NA
· More than 5 Years NA NA NA
Total Customer Asset (Rs. lakhs) NA NA NA
Broking Revenue (Rs. Lakhs) 136,667 137,500 98,915
Average broking active client (in ₹) 1,745,870.2 2,421,193.7 1,492,379.1
Margin Trading Facility Book (Rs. Lakhs) 23,705.6 7,112.1 NA
Growth in Margin Trading Facility Book (%) 233.3% 100.0% NA
Total Assets Under Distribution
· Mutual Funds (Rs. Lakhs) 17,400.00 NA NA
SMC Global Securities Ltd
Particulars
FY25 FY24 FY23
Operating metrics:
Total number of clients NA NA NA
Active Clients on NSE 179,621 178,712 153,078
Growth in Active Clients (%) 0.5% 16.7% NA
Active clients as a % of Total number of clients NA NA NA
Average tenor of client relationship
· Up to 1 year NA NA NA
· 1 to 2 years NA NA NA
· 3 to 5 years NA NA NA
· More than 5 Years NA NA NA
Total Customer Asset (Rs. lakhs) NA NA NA
Broking Revenue (Rs. Lakhs) 104,454.4 96,144.9 76,779.3
Average broking active client (in ₹) 58,152.7 53,798.8 50,157.0
Margin Trading Facility Book (Rs. Lakhs) 27,989.9 23,285.1 18,638.1
Growth in Margin Trading Facility Book (%) 20.2% 24.9% NA
Total Assets Under Distribution
· Mutual Funds (Rs.Lakhs) ~4,17,800.00 ~3,80,100.00 ~2,99,200.00
Arihant Capital Markets Ltd (ACML)
Particulars
FY25 FY24 FY23
Operating metrics:
Total number of clients NA 2,48,294 2,23,000
Active Clients on NSE 56,572 50,542 40,697
Growth in Active Clients (%) 11.9% 24.2% -3.8%
Active clients as a % of Total number of clients NA 32.3% NA
Average tenor of client relationship
· Up to 1 year NA NA NA
· 1 to 2 years NA NA NA
· 3 to 5 years NA NA NA
· More than 5 Years NA NA NA
Total Customer Asset (Rs. lakhs) NA NA NA
Broking Revenue (Rs. Lakhs) 24,458.0 23,341.9 13,605.7
Average broking active client (in ₹) 43,233.4 46,183.1 33,431.6
Margin Trading Facility Book (Rs. Lakhs) 12,972.7 17,447.0 6,658.7
Growth in Margin Trading Facility Book (%) -25.6% 162.0%
Total Assets Under Distribution
· Mutual Funds (Rs. Lakhs) NA NA NA
Note for Peer Competitive Analysis
• All figures are on Consolidated basis
436• EBITDA = Profit Before Tax (incl. share in profit/ (loss) from associates/ joint ventures) + Depreciation & Amortization
+ Finance Cost - Other income
• EBIT= Profit Before Tax (incl. share in profit/ (loss) from associates/ joint ventures) + Finance Cost - other income
• PAT = Profit attributable to Owners of the equity
• Capital Employed = Total Equity + Borrowings + Lease Liability + Deferred Tax (Asset)/ Liability - [Other Intangible
assets + Intangible assets under development + Goodwill]
• EBITDA Margin = EBITDA/Total Revenue from Operation
• PAT Margin = PAT/Total Income
• Debt Equity Ratio = Total Debt (current and non-current borrowings including lease liability)/Total Equity
• Return on Equity = Profit for the year/period attributable to equity shareholders of our Company/Average of Total Equity
• Return on Capital Employed = (EBIT + profit/(loss) from joint venture or associates)/Average of Capital Employed
• Return on Net worth = Profit for the year/period attributable to equity shareholders of our Company/Average of Net Worth
• Net worth= Equity + Reserves & Surplus
437OUR BUSINESS
Some of the information in this section, including information with respect to our business plans and strategies,
contain forward-looking statements that involve risks and uncertainties. You should read “Forward-Looking
Statements” on page 16 for a discussion of the risks and uncertainties related to those statements and also “Risk
Factors”, “Financial Information” and “Management’s Discussion and Analysis of Financial Condition and
Results of Operations” beginning on pages 40, 503 and 578, respectively, for a discussion of certain factors that
may affect our business, financial condition or results of operations. Our actual results may differ materially from
those expressed in or implied by these forward-looking statements.
Our Company’s financial year commences on April 1 and ends on March 31 of the immediately subsequent year,
and references to a particular financial year are to the 12 months ended March 31 of that particular year. Unless
otherwise indicated or the context otherwise requires, the financial information included herein is based on or
derived from our Restated Consolidated Financial Information included in this Draft Red Herring Prospectus.
For further information, see “Restated Consolidated Financial Information” beginning on page 503.
Additionally, please refer to “Definitions and Abbreviations” on page 1 for certain terms used in this section.
Unless the context otherwise requires, in this section, references to “we”, “us” and “our” refer to our Company
and its Subsidiaries on a consolidated basis while “our Company” or “the Company”, refers to our Company on
a standalone basis.
Unless otherwise indicated, industry and market data used in this section has been derived from the industry
report titled “Broking Industry in India” dated September 2025 (the “CARE Report”) prepared and issued by
CARE Analytics and Advisory Private Limited, appointed by us on April 16, 2025, and exclusively commissioned
and paid for by us to enable the investors to understand the industry in which we operate in connection with the
Issue. The data included herein includes excerpts from the Care Report and may have been re-ordered by us for
the purposes of presentation. There are no parts, data or information (which may be relevant for the proposed
Issue), that has been left out or changed in any manner. Unless otherwise indicated, financial, operational,
industry and other related information derived from the Care Report and included herein with respect to any
particular year refers to such information for the relevant calendar year. A copy of the Care Report is available
on the website of our Company at https://www.sihl.in/investor-relations. For more information, see “Risk Factors –
Certain sections in this Draft Red Herring Prospectus contain information from the CARE Report, which was
prepared by CARE Analytics and Advisory Private Limited and exclusively commissioned and paid for by our
Company for the purposes of the Issue, and any reliance on such information for making an investment decision
in the Issue is subject to inherent risks” on page 75. Also see, “Certain Conventions, Use of Financial Information
and Market Data and Currency of Presentation – Industry and Market Data” on page 13.
Overview
We are a retail brokering company that offers a range of services covering equity brokerage services and
derivatives brokerage services, with over three decades of experience. Our services facilitate the buying and
selling of financial products such as equities, IPO investing, mutual funds distribution, and other securities. While
our core operations include equity and derivatives brokerage, we primarily focus on providing secondary market
brokering services to retail customers, comprising both resident and non-resident Indians. In addition to executing
buy and sell orders, our business extends to offering mutual fund distribution, margin funding, and stock lending
and borrowing services, which are carried out under the brand name “Shah Investors”.
As of March 31, 2025, we have served over 100,000 demat accounts, with more than 37,810 active clients and
partnerships with over 184 authorised persons. We conduct our operations through 11 branches in India, located
in Mumbai, Ahmedabad, Vadodara, Junagadh, Gandhinagar and Rajkot. Our multi-channel presence, through our
various branches, and network of authorised persons enables us to service our clients across Gujarat and
Maharashtra. Our focus on these two key geographies can be attributed to the efforts at diversifying the clientele
by garnering new opportunities from HNIs & retail customers.
In the year 1995, our company started its operations as Trading Member (Stock Broker) of National Stock
Exchange of India Limited. After completion of two years of its trading operations as a Stock Broker, in the year
1997, our company Registered as Depository Participant Member of National Securities Depository Limited
(NSDL); becoming the first Depository Participant in Gujarat. Our Company by taking steps towards integrating
technology has digitalised its business operations. In the year 2007, we implemented a VMWare-based virtualized
environment to streamline trading and back-office operations. In the year 2023, our Company launched our digital
app-based platform ‘SIHL Moneymaker’. As on March 31, 2025, the app has over 11,462 active registered users.
We have developed an in-house ERP system, rolled out across branches and franchises with a dedicated module
438for client interaction such active steps help us to enhance our client engagement and extend a broader range of
services to the clients.
Key Business Verticals
We provide various financial services to our clients including:
Shah Investor's Home Limited
Margin Trading Depository Distribution
Broking Services
Facility Services Services
1. Broking services: This forms the primary segment of our business operations. Our brokerage fee is
contingent on the volume of the transactions executed by us for our clients. Our retail client brokerage
covers equity delivery, futures and options, currency derivative and commodity brokerage services. Our
Company is currently a member of NSE, BSE and MCX. Our revenue from broking services for financial
year ended 2025, 2024 and 2023 was 6,491.13 lakhs, 5,570.20 lakhs and 3,702.79 lakhs, respectively.
Our traded value for the year ended on March 31, 2025, are as follows:
(₹ in lakhs)
Traded value
Exchange
Equity (Trading) Equity (Delivery) Derivatives Total
NSE 15,62,244.81 12,40,571.45 31,41,356.20 59,44,172.46
BSE - 531.56 - 531.56
Total 15,62,244.81 12,41,103.01 31,41,356.20 59,44,704.02
Our traded value for the year ended on March 31, 2024, are as follows:
(₹ in lakhs)
Traded value
Exchange
Equity (Trading) Equity (Delivery) Derivatives Total
NSE 11,57,082.30 9,93,883.38 26,01,741.85 47,52,707.53
BSE - 6,523.18 - 6,523.18
Total 11,57,082.30 10,00,406.55 26,01,741.85 47,59,230.71
Our traded value for the year ended on March 31, 2023, are as follows:
(₹ in lakhs)
Traded value
Exchange
Equity (Trading) Equity (Delivery) Derivatives Total
NSE 9,85,549.19 5,41,730.27 26,05,634.37 41,32,913.83
BSE - 472.98 - 472.98
Total 9,85,549.19 5,42,203.25 26,05,634.37 41,33,386.81
4392. Margin Trading: This service is aimed at enhancing the purchasing power of the investor to leverage
their collateral, by funding their trading requirements. This allows them to trade without any dilution of
core capital (CARE Report). This funding is however subjected to the margins that are set by the stock
exchange, with the margin representing a portion of the total trade value that the client must maintain
with the broker. Set forth is the size of our Margin trading facility book as on March 31, 2025:
(₹ in lakhs)
Particulars Fiscal 2025
Margin trading facility book 964.22
Revenue from Margin Trading Facility 105.79
3. Depository Services: Depository Participant is an agent of the depository and can offer depository
related services. We offer depository facility to our equity trading clients as a part of integrated service
offering through NDSL, where our Company is registered as depository participant. The total number of
active clients for which we have provided depository services for last three fiscals:
Depository Total number of active client
Fiscal 2025 Fiscal 2024 Fiscal 2023
NSDL 37,814 35,535 31,372
4. Distribution Services: This segment comprises of the distribution of financial products. We are
registered as a distributor with Association of Mutual Funds in India (“AMFI”) and undertake
distribution of mutual funds, to our customers for commission income. Further, we are registered as a
distributor with Association of Portfolio Managers in India (“APMI”) and undertake distribution of
third-party PMS schemes for our customers looking for customised investment solutions. This service is
carried out through both our online and offline platforms.
Our consolidated total revenue from operations was ₹9,427.39 lakhs, ₹7,782.36 lakhs, and ₹5,168.30 lakhs for the
fiscal 2025, 2024 and 2023 respectively. Further our profit after tax from continuing operations attributable to
owners of the parent company was ₹2,338.50 lakhs, ₹1,793.38 lakhs, and ₹763.17 lakhs for the fiscal 2025, 2024
and 2023 respectively. Further, our return on net worth for equity shareholders (RoNW) was 13.91%, 11.91%,
and 6.50% for fiscal 2025, 2024 and 2023 respectively.
Our Company had commenced its operations as a Trading Member (Stockbroker) of National Stock Exchange of
India Limited in 1995 and had subsequently in 1997, registered itself as a depository participant member of
National Securities Depository Ltd (NSDL), becoming the first depository participant in Gujarat. Our Company
acquired the membership of the capital market segment of the Bombay Stock Exchange Limited in 2004. We
became a trading member of the F&O segment of BSE and of the currency derivative segment of NSE, in 2007
and 2008 respectively.
Our growth has been stirred by the effective management skills of our Chairman Upendra Trikamlal Shah who
have experience of 30 years, our Whole-time Director Purnima Upendra Shah who have experience of 30 years,
our Managing Director Tanmay Upendra Shah who have experience of 20 years and our Whole-time Director
Trupti Utpal Shah who have experience of over 17 years in the field of stock broking and depository services.
Our Strengths
Sizeable clientele across Gujarat, with a strong regional presence
As of March 31, 2025 we have served over 100,000 demat accounts, with more than 37,810 active trading accounts
and partnerships with over 184 authorised person. We conduct our operations through 11 branches in India,
located in Mumbai, Ahmedabad, Rajkot, Vadodara, Junagadh, Gandhinagar. Our vast network of 184 Authorised
Persons enables us to capture the growing clientele. This decentralised model has enabled us to maintain strong
relationships with our clients, facilitate deeper market penetration, and adapt to region-specific investment
preferences and behavioural trends. We have witnessed a notable growth in our customers with an addition of
4,552, 3,658 and 2,328 customers, in fiscal 2025, 2024 and 2023, representing 39.83 % of CAGR over the period
from fiscal 2023 to fiscal 2025. In fiscal 2025, NSE active clients witnessed rise in active clients supported by
influx of retail investors with active clients reaching 49.5 million (CARE Report). We have also experienced an
increase our active accounts from 31,372 in March 2023 to 37,814 in March 2025. The image set forth below
represents our presence in various cities of Gujarat:
440Our client centric focus has enhanced our customer support capabilities. In order to assist our clients better we
have established an in-house helpdesk centre to ensure timely resolution and comprehensive assistance for any
customer queries or concerns. The geographic breadth of our services not only provides revenue stability but also
mitigates over-reliance on any single market segment. Our ability to cater to diverse investor profiles, ranging
from retail investors, High Networth Individual's (“HNI’s”), to corporate and NRI clients, reinforces our
positioning as a trusted and scalable retail broking partner.
Please see below the geographical bifurcation of the clients across various cities:
(in ₹ lakhs)
Location As at March 31, 2025 As at March 31, 2024 As at March 31, 2023
No. of Active As a % of No. of Active As a % of No. of Active As a % of
Clients Active Clients Active Clients Active
Clients Clients Clients
In India:
Gujarat 36,423 96.33 34,305 96.53 30,327 96.67
Maharashtra 913 2.41 844 2.38 751 2.39
Others 478 1.26 386 1.09 294 0.94
Total 37,814 100.00 35,535 100.00 31,372 100.00
Strong track record of financial performance and operating efficiency
Over the years we have exhibited a strong track record of financial performance and have achieved optimal
operating efficiency by maintaining high rates of customer retention, strategic expansion in Gujarat and
Maharashtra, and prudent risk management strategies. We have witnessed an increase in the total revenue from
operation and profit after tax which increased from ₹ 5,168.30 lakhs and ₹ 763.17 lakhs, respectively, in fiscal
2023 to ₹ 9,427.39 lakhs and ₹ 2,338.50 lakhs in fiscal 2025, respectively, representing a CAGR of 35.06% and
75.05%, respectively. For fiscal 2025, our return on equity was 14.68% as compared to Fiscal 2023 which was
6.56%. We also have a consistent record for paying dividend and our dividend pay-out ratio was 6.74% in fiscal
2025.
Disbursements in our Mutual Funds product grew at a CAGR of 36.83% from ₹ 2,626.16 lakhs in Fiscal 2023 to
₹ 4,916.92 lakhs in Fiscal 2025.
Key Financial Information
Details of KPIs for the Fiscal 2025, 2024 and 2023:
441Particulars Fiscal 2025 Fiscal 2024 Fiscal 2023
GAAP Measures
Revenue from operations (₹lakhs) 9,427.39 7,782.36 5,168.30
Profit before Tax (₹lakhs) 3,140.22 2,400.68 988.70
Profit After Tax (₹lakhs) 2,338.50 1,793.38 763.17
Net Worth (₹lakhs) 16,808.98 15,054.13 11,745.98
Non-GAAP Measures
Growth in Revenue from Operations (%) 21.14% 50.58% -
Profit After Tax Margin (%) 24.76% 22.69% 14.58%
EBITDA (₹lakhs) 3,531.31 2,512.97 1,114.59
EBITDA Margin (%) 37.46% 32.29% 21.57%
EBIT (₹lakhs) 3,367.18 2,368.73 982.57
EBIT Margin (%) 35.72% 30.44% 19.01%
RoE (%) 14.68% 13.38% 6.56%
RoCE (%) 20.35% 16.77% 8.13%
Debt to Equity Ratio 0.03 0.02 0.07
Operating Cash Flows (₹ in lakhs) (3,186.22) 11,019.42 0.45
Operational Measures:
Total number of clients 80,391.00 76,337.00 71,690.00
Active Clients 37,814.00 35,535.00 31,372.00
Growth in Active Clients (%) 6.41% 13.27% (13.16%)
Active clients as a % of Total number of clients 47.04% 46.55% 43.76%
Average tenor of client relationship
· Up to 1 year 2,469 1,893 1,022
· 1 to 2 years 3,720 3,819 4,142
· 3 to 5 years 4,061 2,852 2,671
· More than 5 Years 27,564 26,971 23,537
Total Customer Asset (₹ in lakhs) 42,41,110.67 44,12,085.83 26,31,095.13
Broking Revenue (₹ in lakhs) 6,491.13 5,570.20 3,702.79
Average broking revenue per active client (in ₹) 17,165.95 15,675.24 11,802.85
Margin Trading Facility Book (₹ in lakhs) 964.22 N.A N.A
Growth in Margin Trading Facility Book (%) N.A N.A N.A
Total Assets Under Distribution
· Mutual Funds (₹) (in lakhs) 4,916.92 3,753.15 2,626.16
Notes:
(1) Revenue from Operations means the revenue from operations as appearing in the Restated Consolidated Financial Information.
(2) Profit Before Tax means profit/(loss) before tax as appearing in the Restated Consolidated Financial Information including profit /
(loss) from discontinued operation.
(3) Profit after Tax means profit / (loss) for the period/ year from continuing and discontinued operations attributable to the owners of the
parent company as appearing in the Restated Consolidated Financial Information.
(4) Net Worth means the aggregate value of the paid-up share capital and all reserves created out of the profits and securities premium
account and debit or credit balance of profit and loss account, after deducting the aggregate value of the accumulated losses, deferred
expenditure and miscellaneous expenditure not written off, as per the audited balance sheet, but does not include reserves created out
of revaluation of assets, write-back of depreciation and amalgamation.
(5) Growth in revenue from operations (%) is calculated as a percentage of revenue from operations of the relevant period/year minus
Revenue from Operations of the preceding period/year, divided by revenue from operations of the preceding period/year.
(6) Profit after Tax Margin refers to the percentage margin derived by dividing profit after tax by revenue from operations.
(7) EBITDA is calculated as profit / (loss) before tax for the period / year including share in profit/ (loss) from associates/ joint ventures,
finance costs and depreciation and amortization expenses, excluding other Income.
(8) EBITDA Margin (%) is computed as EBITDA divided by revenue from operations.
(9) EBIT is calculated as profit / (loss) before tax for the period / year including share in profit/ (loss) from associates/ joint ventures plus
finance costs excluding other Income.
442(10) EBIT Margin (%) is computed as EBIT divided by revenue from operations.
(11) Return on Equity refers to the profit for the year/period attributable to equity shareholders of our Company divided by average Equity
attributable to owners of the parent company as at end of the relevant year/period.
(12) Return on Capital Employed (ROCE): Calculated as earnings before Interest and tax including share in profit/ (loss) from associates/
joint ventures for the year/period excluding other income divided by Capital Employed (Total Equity + borrowings including lease
liability + Deferred Tax (Asset)/ Liability - Intangible Assets including Intangible Assets under Development).
(13) Debt-equity ratio calculated as total debt (current and non-current borrowings including lease liability) divided by total Equity.
Our consistent growth can be attributed to our ability to capture the market by leveraging the efficiencies of our
business, on both online and offline platforms. We also operate our business model in manner which allows us to
capture a higher market share with asset-light structure. As can be evidenced in our cost ratio which we define as
the ratio of total expenses to total revenue, has decreased from 81.11 % in fiscal 2023 to 66.76 % in fiscal 2025.
Leveraging technology to enhance client satisfaction
Investor expectations are also evolving towards hyper-personalisation, with increasing demand for tailored
portfolios, automated rebalancing, and predictive insights (CARE Report). We have remained at the forefront of
adopting technological innovation in our operations. In 2007, we transitioned to a VMware-based virtual platform,
to streamline trading and back-office operations. This commitment to technological advancement has been
integral to our growth and service delivery.
In the year 2023, our Company launched our digital app-based platform ‘SIHL Moneymaker’. As on March 31,
2025, the app has over 11,462 trading clients and offers wide range of features such as real time streaming quotes,
charts and offer trade across all assest classes such as equities, derivatives, currencies and commodities. The app
has over 24,261 downloads as of March 31, 2025, enabling our customers to digitally access our services. Further,
in the year 2024 we have launched another platform ‘SIHL Fundspro’ designed specifically for simplifying and
digitizing mutual fund investments.
Our proprietary Enterprise Resource Planning (ERP) system, developed and maintained by our in-house software
development team, is central to our operations. Our technological infrastructure not only supports our current
operations but also positions us for future growth, enabling us to adapt swiftly to market changes and continue
delivering service to our clients. Our ability to retain clients over the years has been bolstered by our quick
transition to digital platforms and investment in data analytics that enabled us to cater the evolving needs of the
customers. The increase in the executions of trades by our clients through our digital platform has been provided
below:
(in ₹ lakhs)
Particulars As at March 31, 2025 As at March 31, 2024 As at March 31, 2023
Brokerage As a % of Brokerage As a % of Brokerage As a % of
Income Brokerage Income Brokerage Income Brokerage
Income Income Income
Digital Platform 1,451.89 22.37% 980.74 17.61% 497.61 13.44%
Non – Digital
5,039.25 77.63% 4,589.45 82.39% 3,205.18 86.56%
Platform
Total 6,491.13 100.00% 5,570.20 100.00% 3,702.79 100.00%
Integrated brokerage model with long term client relationships
The broking industry in India is estimated to be valued at ~ Rs 0.52 lakh crore as of FY25 and expected to grow
at a CAGR of 16-18% over the next 2-3 years. The increase in financial literacy and reduced cost of investing due
to emergence of discount brokers has contributed significantly to this growth. Moreover, these factors are expected
to continue leading to healthy growth in the long term. (CARE Report).
We have been actively operating in the broking industry for the last three decades. The Company focuses on
building long term client relationships, with the average tenure of investor’s account with our Company being
more than 5 years which constitutes 72.89% of the total active clientele. Set out below are the details of the period
for which clients have been associated with our Company:
Average tenure of Number of active clients
investor’s account Fiscal 2025 Fiscal 2024 Fiscal 2023
Up to 1 year 2,469 1,893 1,022
1 year to 3 years 3,720 3,819 4,142
3 years to 5 years 4,061 2,852 2,671
443Average tenure of Number of active clients
investor’s account Fiscal 2025 Fiscal 2024 Fiscal 2023
More than 5 years 27,564 26,971 23,537
Total 37,814 35,535 31,372
Between March 2020-March 2025, participation of individual investors in the cash segment grew at a CAGR of
32.9% and has reached 377.00 lakh as on March 2025, while participation in the equity derivatives segment surged
at a remarkable CAGR of 49.9% and have reached 106.00 lakh as on March, 2025. This significant growth in
derivatives can be attributed to the increasing popularity of trading strategies among retail investors, fuelled by
the rise of digital trading platforms that make derivatives trading more accessible (CARE Report).
While our revenue from operations for the broking segment increased from ₹ 3,702.79 lakhs in fiscal 2023 to ₹
6,491.13 lakhs in fiscal 2025, with a CAGR of 32.40%. Within our Broking Segment, for the periods set out
below, the majority of our Active Clients traded in equity cash and derivatives segment. Set out below are the
details of our Active Clients and their contribution to our income from trading in cash equity segment:
Particulars As at March 31, 2025 As at March 31, 2024 As at March 31, 2023
Active Clients in the Broking
37,814 35,535 31,372
Segment
Total of Active Clients trading in
35,816 33,792 29,989
equity cash segment
% of Active Clients 94.72% 95.09% 95.59%
Total of Active Clients trading in
1,998 1,743 1,383
derivatives segment
% of Active Clients 5.28% 4.91% 4.41%
Total Brokerage Income (in
6,491.13 5,570.20 3,702.79
lakhs)
Income from equity cash segment
3,956.08 3,376.35 2,047.62
(in lakhs)
Income from equity cash as % of
60.95% 60.61% 55.30%
total Brokerage Income (%)
Income from derivatives segment
2,535.05 2,193.84 1,655.17
(in lakhs)
Income from derivatives as % of
39.05% 39.39% 44.70%
total Brokerage Income (%)
Notes:
1. Total active clients in Derivative segment means the clients who have traded only in derivatives from their Demat Account.
2. Total active clients in Equity Cash Segment means the clients who have traded either in equity segment only or in derivative and equity
segment both.
Experienced Promoters and Management Team
Our growth has been stirred by the effective management skills of our Promoters Upendra Shah, Purnima Upendra
Shah, Tanmay Upendra Shah and Trupti Utpal Shah who have a combined experience of over years in this sector.
Our senior management comprises of Rajesh Punjabi (Chief Operating Officer and General Manager) has over
30 years of experience in operations, Jinal Shah (IT Manager) have over 20 years of experience in IT operations,
Shalvi Kharidia (Compliance Officer) has over 20 years of experience in compliance and Kamal Thakkar (Chief
Business Officer) with over 25 years of experience in business and sales operations.
The extensive experience of our management has helped us stay abreast with the technological development in
the sector by digitising the services offered. Their experience has helped us to strengthen our risk management,
compliance and governance framework.
We believe that our Promoters have been instrumental in our growth, and that their vision and expertise will
continue to provide us with a significant competitive advantage as we seek to expand our clientele. For further
details, see “Our Management” and “Our Promoters and Promoter Group” on pages 475 and 496, respectively.
STRATEGIES
Expand our brokerage business and geographical presence through marketing, authorised person and branch
network
444We intend to increase and strengthen our presence in brokerage business. Our focus is on capturing a greater
market share through increase in our client base. We aim to build long-term client-broker relationship by providing
investors with personalised and comprehensive services that align with their financial goals.
We plan to grow our retail broking business by offering by client-focused relationship management, product
innovation, enrolling new users on our mobile application with help of our physical network, leveraging our
margin trading facility to increase the number of trades and transactions and retaining our customers. These
offerings will help us to grow our active customer base which will lead to high retail broking revenues.
Our multi-channel presence, through our various branches, and network of authorised persons enables us to
service our clients across Gujarat and Maharashtra. With a strong presence in Gujarat, we plan to expand our
presence in other states by adding up new clients through marketing campaigns, opening new branches and
creating a network of authorised persons in other states. Additionally, we have started referral schemes like “Ezee
Partner” which allows individuals to join us on a short-term basis and introducing new clients to our Company.
We intend to promote our mobile application with a focus on tier 2 and tier 3 cities through marketing campaigns,
conducting seminars and round table conferences. Retail investors, particularly in Tier 2 and Tier 3 cities, are
gravitating towards mobile-first platforms offered by brokers, which provide ease of onboarding and direct market
access with minimal human intervention (CARE Report).
Continue investing to augment technology and innovation
On our mobile application we have over 25,528 downloads as of August 31, 2025. We plan to offer more
technology-based products and services and to improve our processes to enhance customer satisfaction. In order
to allow to our customers to effectively trade on our digital platforms we need to deploy strong technology systems
that enable us to respond to market opportunities and challenges swiftly, increase customer satisfaction and
improve our risk management capabilities.
Further, we have started providing API based trading services to our clients in financial year 2025-2026.
Strategically, API trading reflects the digitisation of markets, with adoption expected to rise as data-driven
strategies and regulatory support expand retail algo participation, positioning brokers as technology partners in
the evolving trading landscape. This shift reflects increasing retail and institutional adoption of API-driven
platforms and automated strategies. In FY25, algo trading surpassed non-algo activity for the first time, indicating
a structural change in the way equity transactions are executed in the cash segment (CARE Report). We aim to
grow to our API based trading revenue and onboard new clients through returns generated via algorithmic trading.
The digital/online broking market is undergoing rapid expansion, driven by widespread internet access,
technological innovation, and the democratisation of investment opportunities. Enhanced by real-time analytics,
user friendly interfaces, and AI-driven personalisation, trading platforms are attracting a broader and increasingly
diverse investor base, including first-time participants. One of the most significant shift is the rising adoption of
algorithmic systems, which automate trade execution, optimise speed, and reduce market impact (CARE Report).
To maintain our operational efficiency and improve cyber security we intend to use artificial intelligence and data
management systems. By leveraging machine learning and behavioural analytics we aim to meet needs of the
clients and enhance client loyalty.
Focus on improving fee-based revenue
Our Company plans to increase the fee-based revenue through expansion of wealth management and financial
planning services. We intend to increase the amount of assets under management and distribution of mutual funds
scheme. Our Company through SIHL AIF Investment Trust have applied with SEBI for setting a Category III
Alternate Investment Fund by the name of “SIHL Dynamic Growth Fund” on July 23, 2025. As on March 31,
2025, we have over 37,810 active accounts, through which give us access to large number of investors to whom
we can cater through distribution of mutual fund and portfolio management schemes. This aim of expanding into
insurance business is to meet the growing protection needs of clients, supported by digital tools and a seamless
onboarding experience.
In addition to distribution of mutual funds, we plan to register our Company as distributor of Specialized
Investment Fund (“SIF”) schemes. As of March 25, the AUM of the portfolio management industry reached nearly
Rs. 31 trillion of which discretionary service category contributed the most (84.1%) followed by non-discretionary
445services (~8.0%). While the Advisory service contributed to nearly Rs. 2.9 trillion of the total AUM which is
7.8% of the AUM of portfolio management industry (CARE Report). Providing these services alongside our
brokerage business will enable us to cater to corporate and institutional clients.
Enabling clients to access global equities
Brokers in GIFT City enjoy a 100% income tax exemption on business income for any 10 consecutive years out
of a 15-year period, as per Income Tax Act, 1961. They are also exempt from Securities Transaction Tax (STT),
Commodities Transaction Tax (CTT), and stamp duty on transactions conducted on IFSC exchanges.
Furthermore, there is no GST on services received by IFSC units or provided to offshore clients. This makes GIFT
City an attractive destination for brokers seeking to expand their international operations while benefiting from a
favourable regulatory and tax environment (CARE Report). Our Subsidiary, SIHL Global Investments (IFSC)
Private Limited, is established to carry on the business as International Financial Service Centre Unit (“IFSC”)
and as investment advisor or Portfolio management consultant in IFSC.
The overall financial services industry is undergoing a transformation—driven by digitization, regulatory clarity,
global market access via platforms like GIFT City, and evolving investor behaviour. Our Company, through its
presence in GIFT City, is also expanding its international business, enabling clients to access global equities,
ETFs, and thematic portfolios from developed markets in a regulated manner.
Our Business
Our primary business includes broking services, depository services, margin trading facility along with which we
provide services like third-party products and value-added services. The revenue derived from the various services
offered have been tabulated as follows:
(₹ in lakhs)
% of % of % of
revenue revenue revenue
Particulars Fiscal 2025 Fiscal 2024 Fiscal 2023
from from from
operation operation operation
Brokerage Income* 6,491.13 68.85 5,570.20 71.57 3,702.79 71.64
Margin Trading Interest
105.79 1.12 - - - -
Income
Depository Services 268.06 2.84 273.00 3.51 229.67 4.44
Other revenue** 2,562.41 27.18 1,939.17 24.92 1,235.82 23.91
Total revenue from
9,427.39 100.00 7,782.36 100.00 5,168.30 100.00
operation
* Brokerage Income includes income earned from distribution services.
**Other revenue majorly includes interest income, Dividend income, Rental income, net gain on fair value changes and others.
I. Brokerage
This forms the primary segment of our business operations. Our brokerage fee is contingent on the volume of the
transactions executed by us for our clients. Our retail client brokerage covers equity brokerage services,
derivatives (futures & options) and commodity brokerage services. Our Company is currently a member of NSE,
BSE and MCX. Further, in the year 2023 we expanded our offering by providing services through our digital
platform “SIHL Moneymaker”.
446IPO
s Equity
e
c
i
v
r API BasedTrading
e
S
g Futures &
n
i Options
k
o
r
B SLBM
Commodities
The table below sets forth the breakdown of the revenue from our brokerage business as percentage of our total
revenue from operations for the periods indicated therein:
(in ₹ lakhs)
Particulars Fiscal 2025 Fiscal 2024 Fiscal 2023
Revenue from Brokerage Income 6,491.13 5,570.20 3,702.79
Total Revenue from Operations 9,427.39 7,782.36 5,168.30
Revenue from broking services as % of total revenue from
68.85 71.57 71.64
operations
The following table shows our ADTO for brokerage services for the periods indicated:
(in ₹ lakhs)
Particulars Fiscal 2025 Fiscal 2024 Fiscal 2023
ADTO – Overall 23,874.31 19,346.47 16,533.55
ADTO - Cash 11,258.42 8,770.27 6,111.00
ADTO- F&O 12,615.88 10,576.18 10,422.53
The following table provides are client base/operational accounts over different time periods:
Year Ended March 31
Particulars
2025 2024 2023
Client Base / Operational Accounts 37,814 35,535 31,372
A. Product Offerings
i. Equity: We offer our customers option to invest in the shares of listed companies on recognised stock
exchanges.
ii. IPO: We offer our customers option to participate in initial public offerings of equity shares of
companies. Between FY22 to FY25, the Indian market saw a notable increase in IPO activity,
particularly post-pandemic in 2020-2021, as companies took advantage of favourable market
conditions and abundant liquidity. (CARE Report)
iii. SLBM: In the year 2020, we registered in Stock Lending and Borrowing Mechanism (“SLBM”),
diversifying our services. Securities Lending and Borrowing is a scheme that is a temporary loan of
securities between Lender & Borrower. It describes the market practice whereby securities are
temporarily transferred by one party (the lender) to another (the borrower) via an approved intermediary
for a fee. The scheme allows investors to generate short term gains, with easy and quick settlement
(CARE Report)
447iv. Future & Options: We provide platform for our customers to deal in futures and options related to
stocks and indices that are traded on the NSE and the BSE. In financial year 2025, equity derivative
futures ADTO reached Rs 1,85,901 crore, a 38.7% increase from financial year 2024.(CARE Report).
v. Commodities: We facilitate our customers to deal in commodities futures and options listed on MCX.
In terms of percentage share of commodity derivatives turnover among exchanges, MCX has the
highest market share of 97.5%, followed by NSE (2.3%) and NCDEX (0.3%) as of FY25 (CARE
Report).
vi. API Based Trading: We provide this facility to the investors through our digital platform. API trading
allows traders to connect directly with a broker’s system to automate order execution through
algorithms and models, ensuring speed, efficiency, and instant reaction to market signals. For brokers,
offering APIs attracts high-volume traders, boosts transaction revenues, enhances client relations, and
enables integration with fintech ecosystems, opening ancillary income streams. (CARE Report).
B. Platforms
i. SIHL Moneymaker
The SIHL Moneymaker platform provides our customers with a platform to invest and trade their
securities digitally. The app provides our customers with various features such as charts for technical
analysis, buy & sell from option chain and moving average indicator data. We provide live data &
interactive charts along with comprehensive analysis to our customers to assist them with their trades.
As on August 31, 2025, the app has 25,528 downloads and a rating 4.7 on the google play store.
Below mentioned are the images of ‘SIHL Moneymaker’ app:
448ii. SIHL Fundspro
The SIHL Fundspro is an investment and insurance portfolio management app wherein we provide various
features to our customers such as summary view of the current status of all investments across asset classes,
and SIP due. Further, through the app our customers can get services of mutual funds advisory and digital
vault wherein they can access there important documents anytime from the app.
II. Margin Trading Facility
Our Company, in the year 2023, registered for Margin Trading Facility (MTF) to enabling our customers to
capitalize on market opportunities with limited upfront capital by leveraging their eligible collaterals. We provide
margin trading facility to our customers in equity cash segment.
In June 2025, the MTF book grew significantly, reaching Rs. 0.88 lakh crore, a 23.7% increase over March 2025,
the MTF book grew at a CAGR of 87% from last trading day of March 2020 to last trading day of June 2025. This
growth is driven by rising investor awareness of MTF's benefits in boosting buying power and potential returns,
along with a bullish stock market. Interest income from MTF ranges between 15% to 35% of total revenue for
leading players (CARE Report).
Our margin trading facility book in the year ended March 31, 2025, was ₹ 964.22 lakhs. Further, interest income
on margin trading facility for Fiscal 2025, was ₹ 105.79 lakhs. Investors can invest their core capital in long-term
investments while using MTF leverage for trading.
III. Depository Services
Depository Participant is an agent of the depository and can offer depository related services only after obtaining
a certificate of registration from SEBI (CARE Report). We offer depository facility to our equity trading clients
as a part of integrated service offering through NSDL, where our Company is registered as depository participant.
The following table provides the number of newly opened accounts and the total number of active accounts in last
three fiscals:
S. No. Financial Year New Accounts Opened No. of Active Accounts
1. Financial year ended March 31, 2025 4,552 37,814
449S. No. Financial Year New Accounts Opened No. of Active Accounts
2. Financial year ended March 31, 2024 3,658 35,535
3. Financial year ended March 31, 2023 2,328 31,372
Set out below are the details of the revenue from depository services:
(in ₹ lakhs)
Particulars Fiscal 2025 Fiscal 2024 Fiscal 2023
Revenue from depository
268.06 273.00 229.67
services
Total Revenue from
9,427.39 7,782.36 5,168.30
Operations
Revenue from depository
services as % of total
2.84 3.51 4.44
revenue from operations
(%)
IV. Distribution Services
Investment advisory services enable individuals, businesses, and institutions to manage their investments
effectively. These services typically involve evaluating a client’s financial goals, risk tolerance, and investment
timeline, and managing a customized investment strategy. Over time, brokers have expanded their offerings to
include investment advisory, AIF/PMS, and distribution of financial products like mutual funds (CARE Report).
We undertake the distribution of mutual funds both through offline and online, through our digital platform, i.e.
SIHL Funds Pro. We provide various types of mutual funds to our customers, these include (i) equity mutual
funds (ii) debt mutual funds (iii) hybrid mutual fund. We use our network of authorised persons, branches and our
relationship with clients for marketing mutual funds.
We have entered into agreements with third party service providers and act as distributors for their PMS and
advisory services. PMS invests on behalf of its clients in separately managed accounts in various securities
including listed equities, unlisted equities, fixed income instruments, hybrid, or structured products and others.
Branches and Authorised Persons
As of March 31, 2025, we have a network of total 11 branches and 184 Authorised Persons spread across 10 cities
in India. Set out below are the details of the revenue from branches and Authorised Persons as of March 31, 2025,
March 31, 2024 and March 31, 2023:
(in ₹ lakhs)
Particulars Fiscal 2025 Fiscal 2024 Fiscal 2023
Revenue from branches and
1,386.74 1,028.64 704.74
Head Office
Revenue from Authorised
5,104.39 4,541.55 2,998.05
Persons
Total Brokerage Income 6,491.13 5,570.20 3,702.79
Revenue from branches as
% of total broking income 21.36 18.47 19.03
(%)
Revenue from Authorised
Persons as % of total 78.64 81.53 80.97
broking income (%)
Clientele:
Our personalised client management approach with our clients has been one of the cornerstones of our growth.
We have over the years built long term relationship with our clients. Set out below are the details of our total
clients during the period set out below:
450Particulars Fiscal 2025 Fiscal 2024 Fiscal 2023
Active Clients 37,814 35,535 31,372
Traded value per client
157.21 133.93 131.75
(Quantum in lakhs) (1)
Sustained Client
27,564 26,971 23,537
Relationships (5+ Years) (2)
(1) Total Value of transactions traded in Equity and Derivatives divided by active clients as on March 31 2025, 2024 and 2023.
(2) Clients having ageing of more than 5 years divided by active clients as on March 31 2025, 2024 and 2023.
The service provided by us allows our customers to diversify their investments through a single channel. Due to
this multi-service approach our customers have invested in various segments through us, this is reflected through
consistent growth in our customer assets. The chart set forth below, represents our total customer assets in previous
fiscals:
Total Customer Asset (₹ in lakhs)
44,12,086
42,41,111
26,31,095
24,46,931
2021-22 2022-23 2023-24 2024-25
Set forth below is flow-chart of client account opening at our Company:
451Trading Activity and Order Book Representation
The Company represents and warrants that it maintains an active client base which regularly undertakes trading
activities, with the average trade book comprising transactions of significant quantum. The trading volumes and
order flow evidence the depth of the Company’s market engagement and the robustness of its client relationships.
The order book of the Company, in terms of order counts across equity (“Eq”), derivatives (“Dr”), and currency
(“Cu”) segments, for the last three financial years, is as under:
Particulars 2025 2024 2023
Order Count Eq 40,17,637 33,22,081 25,12,777
Order Count Dr 8,88,259 6,93,692 5,76,162
Order Count Cu - 22,455 36,428
Furthermore, the order book in terms of the average order ticket size per client across the respective segments of
equities, derivatives, and currencies, is set out below:
Particulars 2025 2024 2023
Order Ticket Size Eq 69,776 64,944 60,799
Order Ticket Size Dr 3,53,094 3,69,699 4,43,526
Order Ticket Size Cu - 1,50,452 1,28,952
The aforesaid data evidences a consistent growth in market participation and reflects the sustained trading interest
of the Company’s clients across different asset classes.
Risk Management
452We have formulated a risk management policy for identification and mitigation of various risks we are exposed
to in relation to our business operations. The policy helps up to manage risks and have internal control in our daily
operations. We ensure risk management through:
1. Client Onboarding & Categorisation
• Strict KYC and due diligence processes, including verification of identity, financials, and beneficial
ownership.
• Clients are classified into High, Medium, and Low risk categories based on profile, turnover, and
regulatory alerts.
• Additional scrutiny for NRIs, politically exposed persons (PEPs), and high-volume traders.
2. Surveillance & Monitoring
• Live surveillance systems monitor exposure, order limits, and client risk profiles in real time.
• Continuous surveillance reports (alerts from exchanges, penny stock monitoring, high turnover clients).
• Penny stock restrictions and policies under GSM/ASM frameworks to prevent speculative/abnormal
trading.
3. Financial Controls & Risk Containment
• Margins & Obligations: 100% margin collection, ageing debit square-off (T+1+5), and auto
reconciliation through client bank accounts.
• Exposure Limits: Defined separately for Cash, F&O, and CDS segments with additional margins for
volatile securities.
• Liquidation Policy: Right to square-off client positions in case of defaults.
• Daily Margin Reporting: Shortfall penalties passed to clients as per SEBI/Exchange norms.
4. Governance, Testing & Safeguards
• Kill Switch: Member-level and user-level order cancellation to prevent catastrophic losses.
• Systemic Risk Preparedness: Policies for volatility, liquidity, spreads, news/rumors, and network issues.
• General Risk Coverage: Insurance cover, segregation of client and proprietary collaterals, cash vs. non-
cash ratio monitoring.
• Governance: Regular board review, MIS reporting, compliance monitoring, and awareness-building
across employees.
Information Technology
Information technology and digital services are indispensable to our efficient operations. We utilize efficient
technologies, robust infrastructure, and advanced automation to manage business processes. Our technology
infrastructure is aimed at ensuring that our trading and information systems are reliable and performance
enhancing and that client data are protected. Data back-up is taken on an incremental basis on external HDDs and
sent to another location. Our system is a complex multiproduct/multi-architecture system as per the needs of our
retail and HNI clients. We use our in-house software for our daily business operations.
Human Resources
As of August 31, 2025, we have 174 permanent employees. The following table provides information about our
full-time employees:
Department No. of employees
Accounts 9
Compliance 7
Demat 29
Helpdesk 6
Human Resource 3
Internal Research Team 10
IT 13
Marketing 2
453Department No. of employees
MTF & SLB 6
Office support 29
Sales 22
Trading 38
Total 174
The table below sets forth the details of the statutory dues paid by our Company in relation to our employees for
the periods indicated below:
Particulars Fiscal 2025 Fiscal 2024 Fiscal 2023
22.02 18.76 18.80
Provident Fund (₹ in Lakhs)
Number of Employees for whom provident fund has been paid 55 58 62
2.15 2.31 2.21
Employee State Insurance Corporation (₹ in Lakhs)
41 45 47
Number of Employees for whom ESIC has been paid
2.99 2.62 2.47
Professional Tax (₹ in Lakhs)
142 114 108
Number of Employees for whom PT has been paid
121.99 148.73 139.20
Tax deducted at source on salary (₹ in Lakhs)
18 15 15
Number of Employees for whom TDS has been paid
262.67 239.49 144.06
Tax deducted at source other than salary (₹ in Lakhs)
During the fiscal 2025, 2024 and 2023, there has been no delay in filing GST returns and deposit statutory dues
with regards to Provident Fund, Professional Tax and Employee State Insurance Corporation, as a result of which
we have to pay the late filing fees along with interest on delayed deposit of due taxes and statutory dues.
Intellectual Property Rights
Details of our key trademarks registered in our Company’s name are as set out below:
Sr. No. Description Class of trademark Registration No. Validity
under the Trade
Marks Act
1. Class 36 1596312 Upto August 30,
2027
2. Class 36 1596314 Upto August 30,
2027
Further, as on the date of this Draft Red Herring Prospectus, our Company has applied for the following
trademarks;
Sr. No. Description Class of trademark under Application Date of application
the Trade Marks Act number
1. Class 36 7239764 September 16, 2025
Property
The following table sets forth details of our properties as on the date of this Draft Red Herring Prospectus:
454Sr. Location Purpose Period/Validity Owned / Lease
No. rental
1. 810, X-Change Plaza, DSCCSL (53E), Road 5E, Registered NA Owned
Block 53, Zone 5, Gift City, Gandhinagar – Office
382050, Gujarat, India
2. SIHL House, Opp. Ambawadi Jain Temple, Corporate Office NA Owned
Nehru Nagar Cross Road, Ahmedabad Gujarat-
380015
3. Office No:005A Ground Floor, Building No. 6, Branch Office NA Owned
Western Edge II, Borivali (East) Mumbai 400066
4. 103, Silicon Tower, Nr. Samtheshwar Mahadev, Branch Office NA Owned
Law Garden, Ahmedabad - 380 006.
5. 2nd Floor, Office No. 6, Shaily Complex, Opp. Branch Office NA Owned
Surdhara Bunglow Nr Sal Hospital, Memnagar,
Ahmedabad
6. SF/203 & 204, Agrawal Arcade, Nr. Saffron Branch Office NA Owned
Building, Near Ambawadi Circle, Ahmedabad –
380015
7. Office No. F-19 & F-20, Samrudhi Complex, Branch Office NA Owned
Opp. Sarjan Bunglow-2, New C.G Road,
Chandkheda, Ahmedabad – 382424
8. Office No. F-123, First Floor, Shubh Business Branch Office NA Owned
Park, Pethapur, Gandhinagar
9. 104, Platinum II, Opp. S.T. colony, College Road, Branch Office NA Owned
Moti Baug, Junagadh -362001
10. A 506, The One World - WING A, Sheetal Park, Branch Office December 15 2023 to License fees is ₹
15ft Ring Road, Rajkot – 360006 December 14, 2026 21,000/- +
applicable GST
11. F-144, Sumel -11, Opp. National Handloom, Branch Office NA Owned
Namaste Circle, Shahibaug, Ahemdabad –
380004
12. 1st Floor, Mangal Bhuvan, Opp. Ichchhaben's Branch Office NA Owned
Wadi, Rambaug Road, Maninagar, Ahmedabad –
38008
13. 401,402 Profit Centre, nr. Kalaghoda Circle, Branch Office NA Owned
Sayajiganj, Vadodara – 390005
14. 53, Urmi Society, BPC Road, Alkapuri, Vadodra Branch Office NA Owned
- 390007 (under
construction)
15. Office No 317, 3rd Floor, Spectrum Shopping Storage premises April 01, 2025 to March ₹12,000 per month
Centre No.4, Relief Road, Ahmedabad – 380001 30, 2026
16. SIHL House 2, Near Nehrunagar Cross Road, Other Office NA Owned
Behind Shakti Electronics, Nehrunagar,
Ahmedabad-380015
Insurance
We have insurance policies providing coverage for our assets against losses from fire, burglary and certain other
risks. We also maintain insurance policies required for operations as a stock broker such as the stock broker
indemnity policy. The table below sets forth details of our insurance coverage:
(₹ in lakhs)
March 31, March 31, March 31,
Particulars
2025 2024 2023
Amount of insurable assets (A) 1,465.99 1,454.67 1,350.38
Aggregate coverage under the insurance policies (B)* 907.05 873.04 855.05
Insurance Cover as a % of Insurable Assets [(B) / (A)] 61.87% 60.02% 63.32%
As certified by the Independent Chartered Accountant, Dhrumil A. Shah & Co., Chartered Accountants (FRN: 145163W) by way of their
certificate dated September 29, 2025.
455Competition
The Indian financial services sector is highly competitive and fragmented. As of September 03, 2025, nearly 4,900
brokers are registered with SEBI under the equity segment. We face competition from various national as well as
regional brokers such as Arihant Capital Markets Limited, SMC Global Securities Limited and Share India
Securities Limited (CARE Report). For risks in relation to our competition, see “Risk Factor – Competition from
existing and new market participants in our line of business may affect our market share, or results of operations”
on page 77. For details regarding our competitors, see, ‘Industry Overview’ on page 382.
Corporate Social Responsibility
We have constituted a Corporate and Social Responsibility Committee of our Board of Directors and have adopted
and implemented a CSR policy which encapsulates our Company’s philosophy for defining its responsibility as a
corporate citizen and lays down the mechanism for undertaking socially useful activities for the benefit of the
community at large.
Set forth below are details of amount spent by our company towards CSR activities in the Fiscal 2025, Fiscal 2024
and Fiscal 2023:
(₹ in lakhs)
Particulars Fiscal 2025 Fiscal 2024 Fiscal 2023
Expenditure on Corporate Social Responsibility 41.31 36.63 29.54
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456KEY REGULATIONS AND POLICIES
The following is an overview of the important laws and regulations which are applicable in India, which we
consider relevant to our business and operations. This overview is only intended to provide general information
to investors and is neither exhaustive nor is designed or intended to substitute for professional legal advice.
Investors are advised that the current provisions of Indian law and the judicial and administrative interpretations
thereof, are subject to change or modification by subsequent legislative, regulatory, administrative, or judicial
decisions. For details of government approvals obtained or applied for by us, see “Government and Other
Approvals” on page 619.
LAWS RELATED TO OUR BUSINESS
Security and Exchange Board of India Act, 1992 (SEBI Act)
The main legislation governing the activities in relation to the securities markets in India is the SEBI Act and the
rules, regulations and notifications framed thereunder. The SEBI Act was enacted to provide for the establishment
of SEBI whose function is to protect the interests of investors and to promote the development of, and to regulate,
the securities market. The SEBI Act also provides for the registration and regulation of the function of various
market intermediaries including stockbrokers, depository participants, merchant bankers, portfolio managers,
investment advisers, and research analysts. Pursuant to the SEBI Act, SEBI has formulated various rules and
regulations to govern the functions and working of these intermediaries. SEBI also issues various circulars,
notifications and guidelines from time to time in accordance with the powers vested with it under the SEBI Act.
SEBI has the power to impose (i) monetary penalty under the SEBI Act and the regulations made thereunder, and
(ii) penalties prescribed under various regulations, including suspending or cancelling the certificate of registration
of an intermediary and initiating prosecution under the SEBI Act. Further, SEBI has the power to conduct
inspection of all intermediaries in the securities market, including, stockbrokers, investment advisers, merchant
bankers, underwriters, research analysts, to ensure, amongst others, that the books of account are maintained in
the manner required in accordance with applicable law.
In addition to the SEBI Act, the key activities of our Company are also governed by the following acts,
rules, regulations, notifications and circulars:
Securities and Exchange Board of India (Intermediaries) Regulations, 2008 (SEBI Intermediaries
Regulations)
The SEBI Intermediaries Regulations provide amongst other things, the manner of application for registration as
an intermediary with SEBI, and the period of validity of the registration certificate. Further, the SEBI
Intermediaries Regulations provides the general obligations of intermediaries, the appointment of compliance
officer and the manner of redressal of investor grievances. All intermediaries are required to compulsorily abide
by the code of conduct as specified under the SEBI Intermediaries Regulations. The SEBI Intermediaries
Regulations also provide the criteria for determining “fit and proper person” for the purpose of other SEBI
regulations, including the SEBI Merchant Bankers Regulations, the SEBI Stockbrokers Regulations, the SEBI
Portfolio Managers Regulations, the SEBI Investment Advisers Regulations and the SEBI Research Analysts
Regulations.
Securities Contracts (Regulation) Act, 1956 (SCRA)
The SCRA was enacted to prevent undesirable transactions in securities by regulating the business of dealing in
securities and providing for certain matters connected therewith. The SCRA provides, amongst other things, the
definition of ‘securities’, the manner and procedure for recognition of stock exchanges, and provides recognized
stock exchanges the powers to make bye laws for regulation and control of contracts for, or relating to, the
purchase or sale of securities.
Securities Contract (Regulation) Rules, 1957 (SCRR)
The SCRR provides, among other things, the requirements with respect to listing of securities on a recognized
stock exchange, the manner of submitting applications for recognition of stock exchanges, and the qualifications
for membership of a recognized stock exchange. It also empowers SEBI to appoint people to inspect the books of
accounts and other documents to be maintained and preserved by every member of a recognized stock exchange,
in terms of these rules.
Securities and Exchange Board of India (Stock Brokers) Regulations, 1992 (SEBI Stock broker Regulations)
The SEBI Stock brokers Regulations governs the registration and functioning of stock brokers and clearing
members. As per the SEBI Stockbroker Regulations, no person shall act as a stockbroker or clearing member
unless he holds a certificate granted by SEBI under these regulations and every person holding a registration shall
457abide by the code of conduct issued under the SEBI Stockbroker Regulations. The SEBI Stock broker Regulations
lays down, amongst other things, the eligibility criteria, the conditions for grant of certificate to a stock broker or
clearing member and their general obligations and responsibilities. Further, every stock broker or clearing member
shall be subject to penalties for non-compliance of the rules and regulations applicable to them.
SEBI master circular for stock brokers dated June 17, 2025.
The SEBI master circular for stock brokers dated June 17, 2025 as amended from time to time, prescribes
comprehensive guidelines for stock brokers. It provides for, among other things, a registration mechanism for
stock brokers along with a registration mechanism for members of commodity derivatives exchanges. It also
prescribes an online registration process for securities market intermediaries along with mechanisms for investor
grievance redressal.
Stock Exchange Rules, Regulation, Bye laws and Notices issued from time to time
Being a trading and clearing member of BSE, NSE, MCX, we are governed by the rules and regulations, bye laws
and notices of such exchanges, as amended from time to time. The relevant exchange is empowered under the
SCRA to make its own bye laws and rules to deal with its members and regulations to govern/ regulate the relations
between the members and the constituents. Further, the SEBI master circular bearing reference number
SEBI/HO/MRD2/PoD-2/CIR/P/2023/171 dated October 16, 2023, regarding stock exchanges and clearing
corporations provides for, amongst other things, the manner of trading, trading software and technology,
settlement, exchange traded derivatives, the administration of stock exchanges and client-broker dispute resolution
mechanism. Stock exchanges may undertake inspection of stockbrokers based on the inspection policy specified
by SEBI.
Securities and Exchange Board of India (Certification of Associated Persons in the Securities Markets)
Regulations, 2007 (SEBI Certification of Associated Persons Regulations)
The SEBI Certification of Associated Persons Regulations provide that any category of associated persons (as
defined in terms of these regulations) may be required to obtain the requisite certifications for engagement or
employment with intermediaries by SEBI. Through several notifications, SEBI has required approved users and
sales personnel of trading members in currency derivative and equity derivative segments, distributors of mutual
fund products, key managerial personnel of merchant bankers, compliance officers of intermediaries, research
analysts and certain persons associated with stock brokers, trading members or clearing members to obtain the
prescribed certification from National Institute of Securities Markets.
Securities and Exchange Board of India (Depositories and Participants) Regulations, 2018 (SEBI Depositories
and Participants Regulations)
The SEBI Depositories and Participants Regulations provide, amongst other things, the manner of application for
registration as a depository and a participant with SEBI. It provides the criteria for determining “fit and proper
person” for the purposes of being considered as a depository. Further, the SEBI Depositories and Participants
Regulations provide for the prescribed equity shareholding of a sponsor, a person or a participant in the capital of
the depository. All depositories that have been granted a certificate of registration are required to make an
application to SEBI for commencement of business. The SEBI Depositories and Participants Regulations provide
for rights and obligations of depositories, participants, issuers, manner of surrender of certificate and creation of
pledge. It further prescribes the mechanism for investor protection, evaluation of internal systems, manner for
handling share registry work and liability of a participant or a depository in case of default.
Securities and Exchange Board of India Mutual Funds Regulations, 1996 (SEBI Mutual Funds Regulations)
The SEBI Mutual Funds Regulations govern the law pertaining to the business of mutual funds in India. SEBI has
made it mandatory for all mutual funds to appoint agents/distributors who are registered with AMFI. In case of
firms/companies, the requirement of certification from National Institute of Securities Markets is made applicable
to the persons engaged in sales or distribution of mutual fund products.
Revised Code of Conduct for Intermediaries of Mutual Funds by Association for Mutual Funds in India (AMFI
Guidelines)
Association for Mutual Funds in India (AMFI) has issued guidelines for intermediaries in consonance with the
SEBI Master Circular for Mutual Funds dated July 10, 2018. The primary objective of the AMFI Guidelines is to
ensure that mutual fund intermediaries do not use unethical means to sell, market or induce any investor to buy
units of their scheme(s) and mobilize funds on the strength of professional fund management and good practices.
The AMFI Guidelines are mandatory, and all such intermediaries are required to strictly comply with the code of
conduct prescribed by AMFI.
458Revised Code of Conduct for Mutual Fund Distributors by AMFI
AMFI issued the revised guidelines for mutual fund distributors in April 2022. It prescribes certain fiduciary
obligations on mutual fund distributors including, among others, avoidance of conflict of interest, exercising due
diligence, protecting investor rights, avoiding conflict of interest and certain compliance obligations with ‘know
your distributor’ norms, scheme information document prescribed by AMFI and other obligations such as
maintaining confidentiality and ensuring proper education and training of their representatives. Additionally, the
code of conduct prescribes that mutual fund distributors shall have a strong physical and digital infrastructure and
ensure that their internal control and financial mechanisms are built to detect and mitigate losses arises from fraud.
Securities and Exchange Board of India (Portfolio Managers) Regulations, 2020 read with SEBI Circular on
Facilitating collective oversight of distributors for Portfolio Management Services (PMS) through Association
of Portfolio Managers in India (APMI) having reference number SEBI/HO/IMD/IMD-PoD-1/P/CIR/2024/32
dated May 02, 2024 read with the SEBI Circular having reference number SEBI/HO/IMD-POD-
1/P/OW/2025/10669/1 dated April 09, 2025.
Regulation 23 (11) of SEBI (Portfolio Managers) Regulations, 2020, inter-alia states that the portfolio manager
shall ensure that any person or entity involved in the distribution of its services is carrying out the distribution
activities in compliance with the SEBI (Portfolio Managers) Regulations, 2020 and circulars issued thereunder
from time to time. The Regulations require portfolio managers to ensure that distributors abide by the Code of
Conduct as specified in Annexure 2B to the Master Circular dated March 20, 2023 for Portfolio Managers. To
order to facilitate collective oversight of PMS distributors at the industry level, it has been decided that any person
or entity involved in the distribution of portfolio management services shall obtain registration with APMI.
Portfolio Managers shall ensure that any person or entity engaged in the distribution of its services has obtained
registration with APMI, in accordance with the criteria laid down by APMI and SEBI Circular having reference
number SEBI/HO/IMD-POD-1/P/OW/2025/10669/1 dated April 09, 2025 which provided for registration as a
distributor with APMI till July 31, 2025.
SEBI (Prohibition of Insider Trading) Regulations, 2015 (SEBI Insider Trading Regulations)
The SEBI Insider Trading Regulations prohibits an insider from trading in securities that are listed or proposed to
be listed on a stock exchange when in possession of unpublished price sensitive information, relating to a company
or securities listed or proposed to be listed. ‘Insider’ includes a connected person or a person in possession of
unpublished price sensitive information. An insider can trade in the securities of the Company by formulating a
trading plan and presenting it to the compliance officer, designated by the Board of Directors for ensuring
compliance with the Insider Trading Regulations, for his approval and public disclosure pursuant to which trades
may be carried out by the insider in accordance with the trading plan.
SEBI master circular on Know Your Customer (KYC) norms for the securities market dated October 12, 2023
(KYC master circular)
On October 12, 2023, SEBI has issued the master circular for KYC norms for all intermediaries registered with it
which, inter alia, mandates all SEBI registered intermediaries to use the same KYC form and supporting
documents so as to establish a unified framework, and further directs them to use Permanent Account Number
(PAN) as the unique identification number to register and identify all participants of the market, except in case of
mutual fund investments below the specified threshold. Moreover, it provides additional supporting document
requirements for identification of non-individuals including body corporates, societies, and HUFs. SEBI master
circular for Online Dispute Resolution dated December 28, 2023 (ODR master circular) The SEBI master circular
for online dispute resolution prescribes comprehensive guidelines for online dispute resolution. It provides for
two frameworks: Disputes between Investors/Clients and listed companies (including their registrar and share
transfer agents) or any of the specified intermediaries /regulated entities in securities market (as specified in
Schedule A to ODR master circular) arising out of latter’s activities in the securities market, will be resolved in
accordance with the master circular and by harnessing online conciliation and/or online arbitration. Institutional
or corporate clients have the option of resolving disputes with specified intermediaries / regulated entities in
securities market (specified in Schedule B to the ODR master circular): a) in accordance with the ODR master
circular by harnessing online conciliation and/or arbitration; or b) by harnessing any independent institutional
mediation, conciliation and/or online arbitration institution in India.
SEBI (Prohibition of Fraudulent and Unfair Trade Practices relating to Securities Market) Regulations, 2003
(Unfair Trade Practices Regulations)
The Unfair Trade Practices Regulations aim to regulate, investigate and penalize fraudulent activities and unfair
trade practices by SEBI’s registered intermediaries, with a view to ensure investor protection in the market. The
Unfair Trade Practices Regulations provide the classification and criteria for dealings or activities that would be
459considered as manipulative, fraudulent or unfair to the investors and also confers powers to investigating
authorities to investigate and penalize the registered intermediaries in case of defaults.
SEBI circular dealing with conflicts of interests
The SEBI circular bearing reference number CIR/MIRSD/5/2013 dated August 27, 2013, on general guidelines
for dealing with conflicts of interest of intermediaries, recognized stock exchanges, recognized clearing
corporations, depositories and their associated persons in Securities Market, prescribes comprehensive guidelines
to intermediaries and their associated persons for elimination of conflicts of interest. It prescribes guidelines for
avoiding, dealing with, or managing, conflict of interest, including, developing internal procedures, maintaining
high standards of integrity in conduct of business and developing an internal code of conduct to govern operations,
appropriately disclosing potential sources or areas of conflict to clients and formulating standards of appropriate
conduct in performance of their activities, which are in addition to the codes of conduct prescribed under relevant
regulations governing intermediaries.
The Prevention of Money Laundering Act, 2002
The Prevention of Money Laundering Act was enacted to prevent money laundering and to provide for
confiscation of property derived from, or involved in money laundering, and for incidental matters connected
therewith. Section 12 of the Prevention of Money Laundering Act casts certain obligations on, inter alia, banking
companies in relation to preservation and reporting of customer account information. The RBI has advised all
banks to go through the provisions of the Prevention of Money Laundering Act and the rules notified thereunder
and to take all steps considered necessary to ensure compliance with the requirements of section 12 of the
Prevention of Money Laundering Act.
The Information Technology Act, 2000 (IT Act)
The IT Act creates liability on a body corporate which is negligent in implementing and maintaining reasonable
security practices and procedures, and thereby causing wrongful loss or wrongful gain to any person, while
possessing, dealing, or handling any sensitive personal data or information in a computer resource which is owned,
controlled, or operated by it, but affords protection to intermediaries with respect to third party information
liability. The Information Technology Act also provides for civil and criminal liability including compensation,
fines, and imprisonment for various offences. These include offences relating to unauthorized access to computer
systems, damaging such systems or modifying their contents without authorization, unauthorized disclosure of
confidential information and commission of fraudulent acts through computers. In April 2011, the Ministry of
Electronics and Information Technology, Government of India notified the Information Technology (Reasonable
Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 (IT Personal Data
Protection Rules) under Section 43A of the Information Technology Act and again in February 2021 notified the
Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021 (Intermediary
Guidelines) under Section 87 of the Information Technology Act. The IT Personal Data Protection Rules prescribe
directions for the collection, disclosure, transfer, and protection of sensitive personal data. The Intermediary
Guidelines provide for a thorough due diligence to be done by the intermediaries and provide a grievance redressal
mechanism for resolving complaints from users.
The Digital Personal Data Protection Act, 2023
The Digital Personal Data Protection Act, 2023 which was recently promulgated provides for collection and
processing of digital personal data by companies collecting data in digital form or in non-digital form which is
digitised subsequently. The Digital Personal Data Protection Act, 2023 is also applicable to processing of digital
personal data outside the territory of India, if such processing is in connection with any activity related to offering
of goods or services to data principals within the territory of India. The Digital Personal Data Protection Act, 2023
stipulates obligations in relation to collection, recording, organisation, structuring, storage, adaptation, retrieval,
use, alignment or combination, indexing, sharing, disclosure by transmission, dissemination or otherwise making
available, restriction, erasure or destruction of personal data and appointment of a data protection officer for
grievance redressal. In addition, significant data fiduciaries, as defined in the Digital Personal Data Protection
Act, 2023 are required to appoint an independent data auditor who will evaluate their compliance with the Data
Protection Act.
Shops and Establishment Legislations
Under the provisions of local Shops and Establishments laws applicable in various states, establishments are
required to be registered. Such laws regulate the working and employment conditions of the workers employed in
shops and establishments including commercial establishments and provide for fixation of working hours, rest
intervals, overtime, holidays, leave, termination of service, maintenance of shops and establishments and other
460rights and obligations of the employers and employees. Our offices are required to be registered under the shops
and establishments legislations of the states where they are located.
Labour Laws
In addition to the aforementioned legislations which are applicable to our Company and Subsidiaries, other
legislation that may be applicable to the operations of our Company and Subsidiaries include:
• Child Labour (Prohibition and Regulation) Act, 1986;
• Employees’ Provident Funds and Miscellaneous Provisions Act, 1952;
• Employees’ State Insurance Act, 1948;
• Maternity Benefit Act, 1961;
• Minimum Wages Act, 1948;
• Payment of Bonus Act, 1965;
• Payment of Gratuity Act, 1972;
• Payment of Wages Act, 1936;
• Equal Remuneration Act, 1976;
• Employee’s Compensation Act, 1923;
• Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act and Rules, 2013
In order to rationalize and reform labour laws in India, the Government has enacted the following codes, which
will be brought into force on a date to be notified by the Central Government:
(a) Code on Wages, 2019, which amends and consolidates the laws relating to wage and bonus payments and
subsumes four existing laws namely – the Payment of Wages Act, 1936, the Minimum Wages Act, 1948, the
Payment of Bonus Act, 1965 and the Equal Remuneration Act, 1976. It regulates, interalia, the minimum wages
payable to employees, the manner of payment and calculation of wages and the payment of bonus to employees.
The Central Government has notified certain provisions of the Code on Wages, mainly in relation to the
constitution of the central advisory board.
(b) Industrial Relations Code, 2020, which consolidates and amends laws relating to trade unions, the conditions
of employment in industrial establishments or undertakings, the investigation and settlement of industrial disputes.
It subsumes and simplifies the Trade Unions Act, 1926, the Industrial Employment (Standing Orders) Act, 1946
and the Industrial Disputes Act, 1947.
(c)Code on Social Security, 2020, which amends and consolidates laws relating to social security, and subsumes
various social security related legislations, interalia including the Employee’s State Insurance Act, 1948, the
Employees’ Provident Funds and Miscellaneous Provisions Act, 1952, the Maternity Benefit Act, 1961, Building
and Other Construction Workers’ Welfare Cess Act, 1996 and the Payment of Gratuity Act, 1972. It governs the
constitution and functioning of social security organisations such as the Employee’s Provident Fund Organisation
and the Employee’s State Insurance Corporation, regulates the payment of gratuity, the provision of maternity
benefits for unorganised workers and compensation in the event of accidents that employees may suffer, among
others.
(d) The Occupational Safety, Health and Working Conditions Code, 2020, consolidates and amends the laws
regulating the occupational safety and health and working conditions of the persons employed in an establishment.
It replaces 13 old central labour laws including the Factories Act, 1948, Contract Labour (Regulation and
Abolition) Act, 1970, the Building and Other Construction Workers (Regulation of Employment and Conditions
of Service) Act, 1996 and the Inter-State Migrant Workmen (Regulation of Employment and Conditions of
Service) Act, 1979.
Intellectual Property Laws
Intellectual Property in India enjoys protection under both common law and statute. Under statute, India provides
for trademark protection under the Trade Marks Act, 1999. The above enactment provides for protection of
intellectual property by imposing civil and criminal liability for infringement.
Foreign Exchange Regulations
461Foreign investment in Indian securities is governed by the provisions of the Foreign Exchange Management Act,
1999, as amended (“FEMA”) read with the applicable Foreign Exchange Management (Non-Debt Instruments)
Rules, 2019 as amended (“FEM Rules”). FEMA replaced the erstwhile Foreign Exchange Regulation Act, 1973.
Foreign investment is permitted (except in the prohibited sectors) in Indian companies, either through the
automatic route or the government approval route, depending upon the sector in which foreign investment is
sought to be made. The DPIIT makes policy pronouncements on FDI through press notes and press releases which
are notified by the RBI as amendments to the FEM Rules. In case of any conflict, the FEM Rules prevail.
Therefore, the regulatory framework, over a period of time consists of acts, regulations, press notes, press releases,
and clarifications among other amendments. The DPIIT issued the FDI Policy which consolidates the policy
framework on FDI issued by DPIIT, in force on October 15, 2020, and reflects the FDI policy as on October 15,
2020. The FDI Policy consolidates and subsumes all the press notes, press releases, and clarifications on FDI
issued by DPIIT. As per the FDI Policy, 100% FDI is permitted in our Company under the automatic route, subject
to compliance with prescribed conditions. In this Issue, foreign investment is limited to investments by FPIs and
NRIs. For further details, see “Issue Procedure” on page 647.
Other Legislations
Additionally, we are required to comply with the provisions of the Companies Act, 2013 and the relevant rules,
regulations, and orders framed thereunder, the Arbitration and Conciliation Act, 1996, Indian Contract Act, 1872,
the Sale of Goods Act, 1930 also other legislations such as the laws governing taxation aspects of our business,
Goods and services tax legislations (including Central Goods and Services Tax Act, 2017, Integrated Goods and
Services Tax Act, 2017, States Goods and Services Tax Act, 2017 and Union Territory Goods and Services Tax
Act, 2017) are applicable to us..
462HISTORY AND CERTAIN CORPORATE MATTERS
Brief history of our Company
Our Company was incorporated as “Shah Investors Home Private Limited”, a private limited company under the
Companies Act, 1956, pursuant to the certificate of incorporation dated October 12, 1994, issued by the Assistant
Registrar of Companies, Gujarat at Dadra & Nagar Haveli (“RoC”). Subsequently, our Company was converted
into a public company, pursuant to a special resolution passed by shareholders in their extra-ordinary general
meeting on February 14, 1995 and the name of our Company was changed to “Shah Investors Home Limited”. A
fresh certificate of incorporation dated March 09, 1995, was issued by the RoC upon conversion of our Company
to a public limited company. Thereafter, the name of our Company was changed to “Shah Investor’s Home
Limited”, pursuant to a shareholder resolution dated October 10, 2000, and a fresh certificate of incorporation
consequent on change of name dated October 13, 2000, was issued by the RoC.
Changes in the registered office of our Company
Except as disclosed below, there has been no change in the registered office of our Company since the date of its
incorporation:
Effective date Details of the change in address of our registered office Reasons for change
of change
October 01, Change in registered address from 1459, New Madhavpura, Ahmedabad- Administrative efficiency
1996 380004 to 17/343 Satyagrah Chhavnisociety Jodhpur Tekra, Ahmedabad –
380054
December 01, Change in registered address from 17/343 Satyagrah Chhavnisociety Jodhpur Administrative efficiency
2006 Tekra, Ahmedabad – 380054, Gujarat, India to SIHL House, Opp.
Ambawadi Jain Temple, Nehru Nagar Cross Road, Ahmedabad – 380015,
Gujarat, India.
October 20, Change in registered address from SIHL House, Opp. Ambawadi Jain To avail fiscal, taxation and
2020 Temple, Nehru Nagar Cross Road, Ahmedabad – 380015, Gujarat, India to other benefits.
P04-0lE, Tower A, World Trade Center, Block No 51, Road 5E, Zone-5,
Gyan Marg, GIFT City, Gandhinagar - 382355, Gujarat,India
September 22, Change in registered address from P04-0lE, Tower A, World Trade Center, Operational efficiency
2022 Block No 51, Road 5E, Zone-5, Gyan Marg, GIFT City, Gandhinagar -
382355, Gujarat, India to 810, X-Change Plaza, DSCCSL (53E), Road 5E,
Block 53, Zone 5, Gift City, Gandhinagar - 382355, Gujarat, India.
Main Objects of our Company
The main objects contained in the Memorandum of Association of our Company are as mentioned below:
1. To carry on the Business in India and abroad as share and stock brokers, sub-brokers, dealers, jobbers,
agents, underwriters, sub-underwriters, investors, sellers, purchasers, market makers and brokers for taking,
holding dealing in, converting stocks, shares and securities of all kinds, brokers for units of Unit Trust of
India, debenture, debenture-stocks, negotiable instruments, bonds, Government Securities, Government
Loans, National Saving Certificates, Small Saving Scheme, Euro or Dollar Issues, commercial papers,
hundies, promissory notes and to deal in all type of shares, stocks and securities.
2. To manage the funds of the investors and to render portfolio management service and portfolio advisory services
by investment in shares, debentures, stocks, debenture-stocks, bonds, company deposits, Government Securities,
Government Loans, National Savings, Post Office Saving Schemes, Units, G.R. Receipts and to pass on the benefit
of portfolio investment to investors as dividend, interest, bonus and to act as brokers/ underwriters, managers,
financial consultants to the issue of shares, debenture, debenture-stocks, bonds, securities, and to provide a
complete range of financial and management consultancy services like investment planning.
3. To carry on the business in India and abroad as a Depository Participant, as an agent of any Depository,
registered with the Securities and Exchange Board of India (SEBI) or any other authorities and to provide
Stock /Securities / Insurance and any other related depository services to the Investors under the regulations,
buy-laws and business rules framed under the Depositary Act, SEBI or such other authorities and to carry
out above business by way of having branches and/ or giving franchisee to any person or persons, anywhere
in India and abroad and also to provide will range of consultancy services for the above matter.
4. To carry on and undertake the business of investment advisory services, custodial services, asset management
services and to act as Merchant Bankers, Portfolio Investment Managers, Lead Managers or Co-Managers,
Book runners, and to act as an Issue House, Financial consultant, Registrar and Transfer Agent, Trustee of
Mutual Funds & Debentures, Research Analyst, Investment Advisor, Underwriters to Issue of Securities,
Insurance Corporate Agent, Insurance Broker and to undertake venture capital funding, clearing houses
463services for the securities, credit rating, credit appraisal and depository participant services and to perform
any other kind of role as an Intermediary or Advisor in the Securities Market directly or through its subsidiary
(ies) and to do all such activities which are ancillary and incidental to the same subject to necessary
Governmental or Regulatory approvals such as Securities and Exchange Board of India or any other
authority for the time being in force.
5. To render directly or through its subsidiary (ies), services as brokers, commission agents, trustees,
administrators, managers, agents and to carry on the business of retail and institutional distribution of the
schemes of the Mutual Funds or any other financial products issued by Banks, Mutual Funds, Insurance
Company or any other financial intermediary.
6. To become a member of Commodity Exchange/s and to carry on business as Commodity broker, sub-brokers,
authorised person, market makers, traders, investors/hedgers in all kind of commodities and to act as clearing
and forwarding agent and to provide services of every kind in this connection.
7. To engage in the business of margin trading, including but not limited to providing margin funding and
related financial facilities to clients for trading in securities, commodities, derivatives, and other permissible
financial instruments, subject at all times to compliance with the applicable laws, rules, regulations,
guidelines, and directions issued by the Securities and Exchange Board of India (SEBI), Reserve Bank of
India (RBI), stock exchanges, and any other competent authority, as amended from time to time and may
engage into all incidental and ancillary activities for achievement of the main business.
8. To act as a settlor, sponsor, and Investment Manager to the Alternative Investment Funds and to engage in
such other activities relating to the Alternative Investment Fund business as permitted under the applicable
laws in India and/or outside India and to undertake and carry on the business of raising or acquiring funds,
investing, advising, and managing funds, pools of capital, including but not limited to alternative investment
funds, offshore funds, pension funds, provident funds, insurance funds, or any other funds and to act as
investment managers, consultants, investment advisors, administrators, agents, or representatives of or for
all said funds formed or established in India or elsewhere by the Company (in accordance with the applicable
law) as may be relevant in this regard and any other related activities. The Company will be entitled to
commence and run any other business (whether or not incidental) as it may be deemed expedient and as may
be permitted by law and may engage into all incidental and ancillary activities for achievement of the main
business.
The main objects as contained in our Memorandum of Association enable our Company to carry on the business
presently being carried on and proposed to be carried on by our Company.
Amendments to our Memorandum of Association in the last 10 years
Set out below are the amendments to our Memorandum of Association in the last 10 years immediately preceding
the date of this Draft Red Herring Prospectus:
Date of Shareholders’ Particulars
resolution
September 09, 2017 Clause V of our Memorandum of Association was amended to reflect the change in the authorised
share capital of our Company from ₹ 20,00,00,000 divided into 2,00,00,000 equity shares of face
value of ₹ 10 each to ₹ 30,00,00,000 divided into 3,00,00,000 Equity Shares of face value of ₹ 10
each.
April 21, 2023 Company adopted a new set of Memorandum of Association as per the Companies Act, 2013 and
other applicable laws and Clause IV was added as following;
“The liability of the member(s) is limited and this liability is limited to the amount unpaid, if any,
on the shares held by them.”
Further, existing Clause III (B) containing the “Objects Incidental or Ancillary to the attainment
of Main Objects” sub – clause mo. 1 to 58 was deleted and substituted with the following;
“
1. To enter into contracts and agreements of lands with builders, tenants, occupiers and others
for the attainment of main object of the Company.
2. To get approvals from various authorities either government, semi government or private
authorities, required for purpose of attainment of main object of the Company.
3. To maintain, alter, extend, purchase, sell, give or take on lease, warehouses, and houses for
employees and other buildings, on any land, purchased, leased or otherwise acquired by or
for the Company.
464Date of Shareholders’ Particulars
resolution
4. To enter into partnership or into arrangement for sharing profits, union of interest, co-
operation, joint venture or reciprocal concessions or for limiting competition with any
person, firm, corporation or company and to enter into Collaboration, Joint ventures,
Agreements, or arrangements for furthering the functions, activities and interest of the
Company.
5. Subject to Section 230 to 234 of the Companies Act, 2013, to amalgamate, merge any other
company or companies with the Company or merge, demerge with any other company or
companies having all or any of their objects similar to the objects of this company or
otherwise, in any manner, whether with or without the liquidation of the Company.
6. To sell, lease, mortgage, or otherwise deal with or dispose of the undertaking, property,
assets, rights and effects of the company or any part thereof for such consideration as the
company may think fit and in particular for shares, stocks, debentures or other securities of
any other company whether or not having objects altogether or in part similar to those of the
company.
7. To establish, provide, maintain and conduct or otherwise subsidies research and
development laboratories and experimental workshops for scientific and technical research
and experiments and to undertake and carry on all scientific and technical research,
experiments and test of all kinds and to promote studies and research, both scientific and
technical investigations, experiments, tests and inventions of any kind that may be considered
likely to assist any of the business which the Company is authorised to carry on.
8. To purchase, take on lease or in exchange, hire, construct or otherwise acquire any movable
or immovable property or any rights privileges which the Company may think necessary or
convenient for purpose of its business.
9. To sell, improve, manage, develop, exchange, lease, dispose off, turn to account, or otherwise
deal with all or any of the property and rights of the company.
10. To apply for, secure, acquire by grant, legislative enactment, assignment, transfer, purchase,
or otherwise and to exercise, carry out and enjoy any charter, power, authority franchise,
concession, right, privilege which any Government or authority or any corporation or other
public body may be empowered to grant, and to pay for, aid and contribute towards carrying
the same into effect, and to appropriate any of the company’s shares, debentures, or other
securities and assets to defray the necessary costs, charges and expenses thereof.
11. To promote any other company or companies for the purpose of acquiring or taking over all
or any of the property, rights and liabilities of the company or for any other purpose.
12. To open accounts with any bank or financial institution and to draw make, accept, endorse,
discount, execute and issue promissory notes, bills of exchange, hundies, bills of lading,
warrants, debentures and such other negotiable or transferable instruments of all types and
to buy the same.
13. Subject to the provisions of the Companies Act, 2013 including the rules and regulations
made thereunder and the directions issued by Reserve Bank of India to borrow, raise or
secure the payment of money or to receive money as loan, at interest for any of the objects
of the company and at such time or times as may be expedient, by promissory notes, bills of
exchange, hundies, bills of lading, warrants or such other negotiable instruments of all types
or by taking credit in or opening current accounts or over-draft accounts with any person,
firm, bank or company and whether with or without any security or by such other means, as
may deem expedient and in particular by the issue of debentures or debenture stock,
perpetual or otherwise and in security for any such money so borrowed, raised or received
and of any such debentures or debenture stock so issued, to mortgage, pledge or charge the
whole or any part of the property and assets of the Company both present and future,
including its uncalled capital, by special assignment or otherwise or to transfer or convey
the same absolutely or in trust and to give the lenders power of sale and other powers as may
seem expedient and to purchase, redeem or pay off such securities provided that the
Company.
14. To establish and support or aid in the establishment and support of associations, institutions,
funds, trusts, and conveniences calculated to benefit employees or directors, or past
465Date of Shareholders’ Particulars
resolution
employees, or directors of the company or its predecessors in the business or the dependents
or connections of any such persons, and to grant pensions, allowances and to make payments
towards insurance and to subscribe or guarantee money for charitable or benevolent objects
or for any public general or useful object.
15. To become member of and to communicate with Chamber of Commerce and other mercantile
and public bodies throughout the world and to advice on, concert, promote and support
measures for protection, advancement, growth of commerce and industry and for protection
and welfare of persons engaged therein.
16. To hold administrator, sell, realize invest disposed off the monies and properties, both real
and personal and to carry on, sell, realize, dispose off and deal with any estate of which the
Company is executor or administrator or in any trust of which the company is the trustee or
of which the company is administrator receiver, liquidator or agent.
17. To enter into arrangements with Government or authority supreme, municipal or local or
otherwise that may seem conducive to the company’s objects or any of them and to obtain
from any such Government or authority any rights, privileges and concessions which the
company may think it desirable to obtain and to carry out, exercise, and comply with any
such arrangement, rights, privileges and concessions.
18. To lend and advance money or give credit to any person or company, to guarantee and give
guarantees or indemnities for the payment of money or the performance of contracts, or
obligations by any person or company, to secure or undertake in any way the repayment of
money lent or advanced to or the liabilities incurred by any person or company and otherwise
to assist any person or the company.
19. To take or hold mortgages, liens and charges to secure payment of purchase price or any
unpaid balance of the purchase price of any part of Company’s property of whatsoever kind
sold by the company or any money due to the company from purchasers and others.
20. To receive money on deposits or loans and to borrow or raise money in the manner permitted
under the Companies Act, 2013 read with rules framed thereunder and the directions issued
by Reserve Bank of India and secure the payment of money in such manner as the company
may think fit and to secure the same or repayment or performance of any debt, liability,
contract guarantee or other engagement entered or to be entered into by the company in any
way and in particular by issue of debentures charged upon all or any of company’s
undertaking or property including its uncalled capital, and to purchase, redeem or pay off
such debentures.
21. To remunerate any person or company for services rendered or to be rendered in placing or
assisting to place or guaranteeing placing of any shares in the company’s capital or any
debentures, or other securities of the companies or in or about the organisation, formation
or promotion of the company or conduct of its business.
22. To sell or dispose off the undertaking of the company or any part thereof for such
consideration as the company may think fit and in particular for shares, debentures or
securities of any other company having objects altogether or in parts similar to those of the
company.
23. Subject to Section 182 of the Companies Act, 2013 to make donations to such persons or
institutions and in such cases and either in cash or any other asset as may be through directly
or indirectly conducive to any of the company’s objects or otherwise expedient or in the
public interest and in particular to remunerate any person or corporation introducing
business to the company and to subscribe, contribute, or otherwise assist or guarantee money
for charitable scientific, religious or benevolent, national, public, cultural, educational or
political or other institution or objects and to establish and support or aid establishment and
support of associations, institutions, funds, trusts, conveniences for the benefit of the
employees or ex-employees (including Directors) or of persons having dealings with the
company or their dependents, relatives or connections of such persons and in particular
friendly or other benefit societies and to grant pensions allowances, gratuities and bonuses
either by way of annual payment or lump sum and to make payments towards insurance, and
to form and contribute to provident & benefit funds and other welfare funds of or for such
persons and to undertake, promote and sponsor any activity for publication of any books
literature, newspapers in furtherance of the aforesaid and other causes or objects.
466Date of Shareholders’ Particulars
resolution
24. To invest and deal with the monies of the company in shares, debentures loans and/or in such
other manner as may from time to time be deemed expedient and in particular to invest any
monies of the company not immediately required for its business, including lending of the
same to such parties and on such terms with or without security as may be thought to be in
the interest of the company and in particular to customers of and persons having dealings
with the company or carrying on any business which may be useful or beneficial to the
company.
25. To acquire by purchase, lease, assignment or otherwise lands, tenements, buildings,
basements, rights, and advantage of any kind whatsoever and resell, mortgage and let on
lease the same.
26. To insure the whole or any part of the property and personnel’s of the company either full
or partially, to protect and indemnify any part or portion thereof either on mutual, principal
or otherwise.
27. To create any depreciation fund, reserve fund, sinking fund or any other special fund whether
for redemption of debentures or debenture-stock, for special dividends, for repairing,
improving, extending and maintenance of any property rights or assets of the company for
any other purpose.
28. In the event of winding up, distributing any of the assets or property of the company among
the members or otherwise subject to the provisions of the Companies Act 2013.
29. To refer or agree to refer any claims, demands, disputes or any other question by or against
the company in which the company is interested or concerned and whether between the
company and or any third party for arbitration in India or at any place outside India and to
observe and perform and do all acts, deeds, matters and things to carry out or enforce the
awards.
30. To pay out of the funds of the company all expenses which the company may lawfully pay
with respect to the promotion, formation and registration of the company or the issue of its
capital including brokerage and commissions for obtaining applications for or taking,
placing or underwriting or procuring the underwriting of shares, or debentures or other
securities of the company.
31. To undertake and execute any trusts the undertaking of which may seem to the company
desirable either gratuitously or otherwise.
32. To pay for any rights or property acquired by the company and to remunerate any person or
compensate for services rendered or to be rendered in placing or assisting to place or
guaranteeing the placing of shares in the company’s capital or any debentures or debenture
stock in the company’s capital or other securities of the company or in or about the formation
or promotion of the company or the acquisition of the property by the company or the conduct
of its business whether by cash payment or by allotment of shares, debentures or other
securities of the company, credited as paid-up in full or in part otherwise.
33. To provide for the welfare of employees or ex-employees (including Directors and other
officers) of the Company and the wives and families or the dependents or connections of such
persons, by building or contributing to the building of houses, or dwellings or chawls or by
grants of money, pensions, allowances, bonus or other such payments or be creating and
from time to time, subscribing or contributing to provident fund and other associations,
institutions, funds or trusts, and/or by providing or subscribing or contributing towards
places of instruction and recreation, hospitals and dispensaries, medical and such other
attendances and assistance as the Company shall determine.
34. To procure the Company to be registered or recognised in or under the laws of any place
outside India and to do all acts necessary for carrying on in any foreign country any business
or profession of the Company.
35. To undertake and transact all kinds of business related activities deemed incidental or
conducive to the attainment of the above objects or any of them for the business of the
Company.”
467Date of Shareholders’ Particulars
resolution
Clause III(A) 1 and 2 of our Memorandum of Association was modified and substituted with the
following;
(1) To carry on the Business in India and abroad as share and stock brokers, sub-brokers,
dealers, jobbers, agents, underwriters, sub-underwriters, investors, sellers, purchasers,
market makers and brokers for taking, holding dealing in, converting stocks, shares and
securities of all kinds, brokers for units of Unit Trust of India, debenture, debenture-
stocks, negotiable instruments, bonds, Government Securities, Government Loans,
National Saving Certificates, Small Saving Scheme, Euro or Dollar Issues, commercial
papers, hundies, promissory notes and to deal in all type of shares, stocks and securities.
(2) To manage the funds of the investors and to render portfolio management service and
portfolio advisory services by investment in shares, debentures, stocks, debenture-
stocks, bonds, company deposits, Government Securities, Government Loans, National
Savings, Post Office Saving Schemes, Units, G.R. Receipts and to pass on the benefit of
portfolio investment to investors as dividend, interest, bonus and to act as brokers/
underwriters, managers, financial consultants to the issue of shares, debenture,
debenture-stocks, bonds, securities, and to provide a complete range of financial and
management consultancy services like investment planning.
Clause III(A) our Memorandum of Association was amended for insertion of the following objects
to the existing Clause III (A);
(3) To carry on the business in India and abroad as a Depository Participant, as an agent
of any Depository, registered with the Securities and Exchange Board of India (SEBI)
or any other authorities and to provide Stock / Securities / Insurance and any other
related depository services to the Investors under the regulations, buy-laws and
business rules framed under the Depositary Act, SEBI or such other authorities and to
carry out above business by way of having branches and/ or giving franchisee to any
person or persons, anywhere in India and abroad and also to provide will range of
consultancy services for the above matter.
(4) To carry on and undertake the business of investment advisory services, custodial
services, asset management services and to act as Merchant Bankers, Portfolio
Investment Managers, Lead Managers or Co-Managers, Book runners, and to act as an
Issue House, Financial consultant, Registrar and Transfer Agent, Trustee of Mutual
Funds & Debentures, Research Analyst, Investment Advisor, Underwriters to Issue of
Securities, Insurance Corporate Agent, Insurance Broker and to undertake venture
capital funding, clearing houses services for the securities, credit rating, credit
appraisal and depository participant services and to perform any other kind of role as
an Intermediary or Advisor in the Securities Market directly or through its subsidiary
(ies) and to do all such activities which are ancillary and incidental to the same subject
to necessary Governmental or Regulatory approvals such as Securities and Exchange
Board of India or any other authority for the time being in force.
(5) To render directly or through its subsidiary (ies), services as brokers, commission
agents, trustees, administrators, managers, agents and to carry on the business of retail
and institutional distribution of the schemes of the Mutual Funds or any other financial
products issued by Banks, Mutual Funds, Insurance Company or any other financial
intermediary.
(6) To become a member of Commodity Exchange/s and to carry on business as Commodity
broker, sub-brokers, authorised person, market makers, traders, investors/hedgers in
all kind of commodities and to act as clearing and forwarding agent and to provide
services of every kind in this connection.
September 29, 2025 Clause III(A) our Memorandum of Association was amended for insertion of the following objects
to the existing Clause III (A);
(7) To engage in the business of margin trading, including but not limited to providing
margin funding and related financial facilities to clients for trading in securities,
commodities, derivatives, and other permissible financial instruments, subject at all
468Date of Shareholders’ Particulars
resolution
times to compliance with the applicable laws, rules, regulations, guidelines, and
directions issued by the Securities and Exchange Board of India (SEBI), Reserve Bank
of India (RBI), stock exchanges, and any other competent authority, as amended from
time to time and may engage into all incidental and ancillary activities for achievement
of the main business.
(8) To act as a settlor, sponsor, and Investment Manager to the Alternative Investment
Funds and to engage in such other activities relating to the Alternative Investment Fund
business as permitted under the applicable laws in India and/or outside India and to
undertake and carry on the business of raising or acquiring funds, investing, advising,
and managing funds, pools of capital, including but not limited to alternative investment
funds, offshore funds, pension funds, provident funds, insurance funds, or any other
funds and to act as investment managers, consultants, investment advisors,
administrators, agents, or representatives of or for all said funds formed or established
in India or elsewhere by the Company (in accordance with the applicable law) as may
be relevant in this regard and any other related activities. The Company will be entitled
to commence and run any other business (whether or not incidental) as it may be
deemed expedient and as may be permitted by law and may engage into all incidental
and ancillary activities for achievement of the main business.
Major events and milestones of our Company
The table below sets forth some of the major events and milestones of our Company:
Calendar Year Milestone
1995 Registration as a “Trading Member” with NSE
1997 Registration as “Depository Participant” with NSDL
2000 Registration as “Trading & Clearing Member” with NSE
2006 Registration with AMFI as a “Registered Mutual Fund Advisor”
2008 Registration as “Trading and Clearing Membership” of NSE Currency Derivatives segment
2016 Received registration for distribution of BSE Star mutual fund
2020 Enablement of the SLBM segment with NSE
2023 Launch of our mobile application “Moneymaker”
2024 Launch of our second mobile application “FundsPro”
2025 Registration as a APMI PMS distributor
Registration as “Trading and Self Clearing Membership” of MCX and MCXCCL
Awards, accreditations, and recognition
The table below sets forth some of the key awards, accreditations or recognitions received by us:
Calendar Year Milestone
2014 Recognised as the “Top Performer- Highest Asset Value” in the NSDL Star Performer Awards.
2015 Recognised as the “Top Performer- Highest Asset Value” in the NSDL Star Performer Awards.
2016 Recognised as the “Top Performer- Highest Asset Value” in the NSDL Star Performer Awards.
2017 Recognised as the “Top Performer in Active Accounts and Highest Asset Value” in the NSDL
Star Performer Awards.
2018 Recognised as the “Top Performer- Highest Asset Value” and awarded the 2nd position in “Active
Accounts” in the NSDL Star Performer Awards.
2019 Recognised as the “Top Performer in Active Accounts and Highest Asset Value” in the NSDL
Star Performer Awards.
Significant financial and strategic partnerships
Our Company does not have any significant financial or strategic partnerships as on the date of this Draft Red
Herring Prospectus.
Time/cost overrun in setting up projects
There has been no time or cost overrun in respect of our business operations since our incorporation as on the date
of this Draft Red Herring Prospectus.
Defaults or rescheduling/ restructuring of borrowings with financial institutions/ banks
As on the date of this Draft Red Herring Prospectus, our Company has not defaulted on repayment of any
outstanding loan availed from any banks or financial institutions and there has been no instance of
469rescheduling/restructuring of borrowings with financial institutions/ banks in respect of our outstanding
borrowings from lenders.
Launch of key products or services, entry into new geographies or exit from existing markets,
capacity/facility creation, location of facilities
For details in relation to our corporate profile including details of our business, activities, growth, competition,
launch of key products, entry into new geographies or exit from existing markets, suppliers, customers,
technology, and managerial competence, see “Risk Factors” “Our Business”, and “Management’s Discussion and
Analysis of Financial Condition and Results of Operations” beginning on pages 40, 438, and 578, respectively.
Details regarding material acquisitions or divestments of business/undertakings, mergers, amalgamation,
any revaluation of assets, etc. in the last 10 years
Except as disclosed below, our Company has not acquired any material business or undertaken any mergers or
amalgamations or divestments of business or undertaking since its incorporation, any revaluation of assets, etc. in
the last ten (10) immediately years preceding the date of this Draft Red Herring Prospectus:
Relationship of the
Sr.
Particulars* Transferee Promoters with the Date
No.
Entity
1. Our Promoters Upendra Shah Investor’s Home Individual Shareholder September 23,
Trikamlal Shah, Tanmay Limited 2020
Upendra Shah, Purnima
Upendra Shah along with the
Preeti Upendra Shah, Ruchira
Shah, Rajesh Ramachandra
Punjabi, Sandhya Rajesh
Punjabi and Harish Rajesh
Punjabi had transferred their
respective shareholding
amounting to 1.51%
shareholding i.e. 1,09,994 of
face value of ₹10 each, held in
SIHL Fincap Limited.
2. Our Promoters Upendra Shah Investor’s Home Individual Shareholder September 23,
Trikamlal Shah, Tanmay Limited 2020
Upendra Shah, Purnima
Upendra Shah along with
Preeti Upendra Shah, Ruchira
Shah had transferred their
respective shareholding
amounting to 22.46%
shareholding i.e. 6,85,000 of
face value of ₹10 each, held in
SIHL Consultancy Limited.
*No valuation report was taken for the said transfers
Details of shareholders’ agreements
Our Company has not entered into any shareholders’ agreement or investment agreements as on the date of this
Draft Red Herring Prospectus.
Lock-out and strikes
As on the date of this Draft Red Herring Prospectus, there have been no lockouts or strikes at any time in our
Company.
Material Agreements
As of the date of this Draft Red Herring Prospectus, there are no arrangements or agreements, deeds of assignment,
acquisition agreements, shareholders’ agreements, inter se agreements, any agreements between our Company,
our Promoters and Shareholders, agreements of like nature or agreements comprising any clauses/ covenants
which are material to our Company, and which are required to be disclosed, or the non-disclosure of which may
have a bearing on the investment decision of prospective investors in the Offer. There are no clauses/ covenants
470that are adverse or prejudicial to the interest of the minority and public shareholders of our Company, or which
may have a bearing on any investment decision.
Agreements with Key Managerial Personnel, Senior Management, Directors, Promoters, or any other
employee
Our Company has not entered into any agreements with Key Managerial Personnel, Senior Management,
Directors, Promoters, or any other employee with regard to compensation or profit sharing in connection with
dealings in the securities of our Company.
Guarantees given by the Promoters offering Equity Shares in the Offer
The Issue consists of a fresh issue of Equity Shares only, our Promoters are not offering their Equity Shares in the
Issue.
Key terms of other subsisting material agreements
As on the date of this Draft Red Herring Prospectus, our Company has not entered into any other subsisting
material agreements including with strategic partners, and/or financial partners other than in the ordinary course
of business of our Company.
Holding company
As on the date of this Draft Red Herring Prospectus, our Company does not have a holding company.
Our Subsidiaries
For details with respect to our Subsidiaries, see “Our Subsidiaries” on page 472.
Our Joint Ventures and Associate Companies
Our Company does not have any joint ventures or associate companies as on the date of this Draft Red Herring
Prospectus.
Other Confirmations
There are no material clauses of our Articles of Association that have been left out from disclosures that have any
bearing on the Issue or this Draft Red Herring Prospectus.
As on the date of this Draft Red Herring Prospectus, except as disclosed in “Restated Consolidated Financial
Information –Note 48- Related Party Disclosures” on page 503, none of our Subsidiaries have, (i) any business
interest in our Company; or (ii) related business transactions between our Company.
Except as disclosed in “Our Promoters and Promoter Group – Interest of our Promoters” and “Our Management
– Interest of our Directors” on page no 496 and 481. respectively, there is no conflict of interest between any of
our Promoters, Promoter Group, Key Managerial Personnel, Directors, Group Companies and their directors and
license or of the immovable properties, which are crucial for the operations of our Company:
471OUR SUBSIDIARIES
Our Subsidiaries
As on the date of this Draft Red Herring Prospectus, our Company has four subsidiaries, the details of which are
below:
1. SIHL Consultancy Limited
2. SIHL Fincap Limited
3. SIHL Global Investments (IFSC) Private Limited
4. SIHL Strategic Advisors Private Limited
1. SIHL Consultancy Limited
Corporate Information
SIHL Consultancy Limited is our Company’s subsidiary. It was incorporated on December 28, 2006, as a public
limited company under the Companies Act, 1956. The CIN of SIHL Consultancy Limited is
U74140GJ2006PLC049662. The registered office of SIHL Consultancy Limited is located at SIHL House, Opp.
Ambawadi Jain Temple, Nehru Nagar Cross Road, Ahmedabad – 380015, Gujarat, India.
SIHL Consultancy Limited is a company that offers specialized consultancy services to businesses on various
corporate matters and corporate finance transactions.
Capital Structure
The authorized share capital of SIHL Consultancy Limited is ₹5,00,00,000 divided into 50,00,000 equity shares
of face value of ₹10 each. Its issued, subscribed, and paid-up equity share capital is ₹3,05,00,000 divided into
30,50,000 equity shares of face value of ₹10 each.
Shareholding pattern
Sr. Number of equity shares Percentage of the total
Name of the Shareholder
No. of face value of ₹10 each Shareholding (%)
1.
Shah Investor’s Home Limited 27,65,000 90.66
2.
Trupti Utpal Shah 75,000 2.46
3.
Utpal Praful Shah 75,000 2.46
4.
Rajesh Ramchandra Punjabi 62,150 2.04
5.
Sandhya Rajesh Punjabi 62,150 2.04
6.
Upendra Trikamlal Shah 2,100 0.07
7.
Purnima Upendra Shah 2,150 0.07
8.
Preeti Upendra Shah 2,150 0.07
9.
Tanmay Upendra Shah 2,150 0.07
10.
Ruchira Shah 2,150 0.07
Total 30,50,000 100.00
2. SIHL Fincap Limited
Corporate Information
SIHL Fincap Limited is our Company’s wholly owned and material unlisted subsidiary, as defined under the SEBI
Listing Regulations. It was incorporated on December 28, 2006, as a public limited company under the Companies
Act, 1956. The CIN of SIHL Fincap Limited is U65923GJ2006PLC049661. The registered office of SIHL Fincap
Limited is located at SIHL House, Opp. Ambawadi Jain Temple, Nehru Nagar Cross Road, Ahmedabad - 380015,
Gujarat, India.
472SIHL Fincap Limited is a registered Non-Banking Financial Company (NBFC) with the Reserve Bank of India
(RBI) having registration no. N.01.00487 dated June 19, 2008. The company offers loans and credit products,
catering to individuals, businesses, and other entities.
Capital Structure
The authorized share capital of SIHL Fincap Limited is ₹ 10,00,00,000 divided into 1,00,00,000 equity shares of
face value of ₹10 each. Its issued, subscribed, and paid-up equity share capital is ₹ 7,26,68,000 divided into
72,66,800 equity shares of face value of ₹10 each.
Shareholding pattern
Sr. Number of equity shares Percentage of the total
Name of the Shareholder
No. of face value of ₹10 each Shareholding (%)
1.
Shah Investor’s Home Limited 72,66,794 99.94
2.
Upendra Trikamlal Shah 1 0.01
3.
Purnima Upendra Shah 1 0.01
4.
Rajesh Ramchandra Punjabi 1 0.01
5.
Tanmay Upendra Shah 1 0.01
6.
Ruchira Shah 1 0.01
7.
Sandhya Rajesh Punjabi 1 0.01
Total 72,66,800 100.00
3. SIHL Global Investments (IFSC) Private Limited
Corporate Information
SIHL Global Investments (IFSC) Private Limited is our Company’s wholly owned subsidiary. It was incorporated
on November 21, 2016, as a private company limited under the Companies Act, 2013. The CIN of SIHL Global
Investments (IFSC) Private Limited is U67190GJ2016PTC094444. The registered office of SIHL Global
Investments (IFSC) Private Limited is located at 903, 9th Floor Signature Building Block 13, Zone 1, SEZ area,
Gift City, Gandhinagar - 382355, Gujarat, India.
SIHL Global Investments (IFSC) Private Limited registered as a stock broker with SEBI, having registration
number INZ000156833 dated October 5, 2017, in the International Finance Service Center Authority (IFSCA). It
provides a range of broking services to clients, trading of securities. The company operates within the International
Financial Services Centre (IFSC) located in Gandhinagar, Gujarat, offering a strategic location for international
financial transactions.
Capital Structure
The Authorized share capital of SIHL Global Investments (IFSC) Private Limited is ₹ 5,00,00,000 divided into
50,00,000 equity shares of face value of ₹10 each. Its issued, subscribed, and paid-up equity share capital is ₹
3,50,00,000 divided into 35,00,000 equity shares of face value of ₹10 each.
Shareholding pattern
Number of equity shares
Sr. Percentage of the total
Name of the Shareholder of face value of ₹10 each
No. Shareholding (%)
1. Shah Investor’s Home Limited 34,99,999 99.99
2. Tanmay Upendra Shah 1 0.01
Total 35,00,000 100.00
4. SIHL Strategic Advisors Private Limited
Corporate Information
SIHL Strategic Advisors Private Limited is our Company’s wholly owned subsidiary. It was incorporated on April
18, 2019, as a private company limited under the Companies Act, 2013. The CIN of SIHL Strategic Advisors
Private Limited is U74140GJ2019PTC107689. The registered office of SIHL Strategic Advisors Private Limited
473is located at SIHL House, Opp. Ambawadi Jain Temple, Nehru Nagar Cross Road, Ahmedabad - 380015, Gujarat,
India.
SIHL Strategic Advisors Private Limited main objects are to act as a management consultants or advisors of any
firm, body corporate, association or other undertaking and generally subject as aforesaid, to act as consultants or
advisors and to undertake part in the management supervision or control of the business or operation of any person,
firm including LLP , body corporate, association or other undertaking and, if necessary, for such purpose or
purpose to invest or subscribe for purchase or otherwise acquire and sell, dispose of, exchange, hold and otherwise
deal in stake of the firm or shares or other securities issued by any companies, corporates or any other authorized
to issue securities.
Capital Structure
The Authorized share capital of SIHL Strategic Advisors Private Limited is ₹3,00,00,000 divided into 30,00,000
equity shares of face value of ₹10 each. Its issued, subscribed, and paid-up equity share capital is ₹ 1,80,00,000
divided into 18,00,000 equity shares of face value of ₹10 each.
Shareholding pattern
Sr. Number of equity shares Percentage of the total
Name of the Shareholder
No. of face value of ₹10 each Shareholding (%)
1. Shah Investor’s Home Limited 17,99,999 99.99
2. Tanmay Upendra Shah 1 0.01
Total 18,00,000 100.00
Common pursuits
Our Subsidiary, SIHL Global Investments (IFSC) Private Limited is in the business of stock broking and other
allied services. In the event any conflict situation arises in the future, our Company shall ensure necessary
procedures and practices are permitted by laws and regulatory guidelines to address any conflict situations as and
when they arise. Our Company has not encountered any instances of conflict in the past.
Accumulated profits or losses
As on the date of this Draft Red Herring Prospectus, there are no accumulated profits or losses of Subsidiaries,
which are not accounted for by our Company.
Business interest between our Company and our Subsidiaries
None of our Subsidiaries have any business interest in our Company other than as stated in “Our Business” and
“Restated Consolidated Financial Information-Related Party Transactions–Note 48”, on pages 438 and 503
respectively.
Other confirmations
Listing
None of our Subsidiaries are listed on any stock exchange in India or abroad. Further, neither have any of our
Subsidiaries been refused listing in the last ten years by any stock exchange in India or abroad, nor have any of
our Subsidiaries failed to meet the listing requirements of any stock exchange in India or abroad.
Conflict of Interest
Except as disclosed below, there is no conflict of interest between the Subsidiaries or any of their directors and
the lessors of immovable properties of our Company (who are crucial for the operations of our Company).
SIHL Consultancy Limited , SIHL Fincap Limited SIHL Strategic Advisors Private Limited having the same
registered office situated at “SIHL House, Opp. Ambawadi Jain Temple, Nehru Nagar Cross Road, Ahmedabad
- 380015, Gujarat, India” which is also the Corporate Office of our Company.
.
474OUR MANAGEMENT
Board of Directors
The Companies Act, 2013 and the Articles of Association of our Company require that our Board shall comprise
of not less than three (3) Directors and not more than fifteen (15) Directors, provided that our Shareholders may
appoint more than fifteen (15) Directors after passing a special resolution in a general meeting.
As on the date of filing this Draft Red Herring Prospectus, we have eight (8) directors on our Board, including
four (4) executive directors and four (4) independent directors.
The following table sets forth details regarding our Board as of the date of this Draft Red Herring Prospectus:
Name, designation, date of birth, address, occupation, Age
Other directorships
current term, period of directorship and DIN (years)
Tanmay Upendra Shah 44 Indian Companies:
1. SIHL Strategic Advisors Private Limited
Designation: Managing Director and Chief Financial 2. SIHL Consultancy Limited
Officer 3. SIHL Global Investments (IFSC) Private
Limited
Date of birth: October 10, 1980 4. SIHL Fincap Limited
5. SIHL Commodities Limited
Address: 17/345, Satyagrah Chhavani Society, Jodhpur 6. Ficus Food Lab Private Limited
Tekra, Satellite Road, Manekbag, Ahmedabad, Gujarat-
380015
Foreign Companies:
Occupation: Business
Nil
Current term: For a period of 3 years from September 9,
2023, and liable to retire by rotation
Period of directorship: Director since December 01, 2020
DIN: 00023067
Upendra Trikamlal Shah 72 Indian Companies:
Designation: Chairman and Whole-time Director 1. SIHL Consultancy Limited
Date of birth: February 21, 1953 Foreign Companies:
Address: 17/345, Satyagrah Chhavani Society, Jodhpur Nil
Tekra, Satellite Road, Manekbag, Ahmedabad, Gujarat-
380015
Occupation: Business
Current term: For a period of 3 years from October 1,
2023, and liable to retire by rotation
Period of directorship: Director since October 01, 2011
DIN: 00023057
Purnima Upendra Shah 75 Indian Companies:
Designation: Whole-time Director 1. SIHL Fincap Limited
Date of birth: July 29, 1950 Foreign Companies:
Address: 17/345, Satyagrah Chhavani Society, Jodhpur Nil
Tekra, Satellite Road, Manekbag, Ahmedabad, Gujarat-
380015
Occupation: Business
475Name, designation, date of birth, address, occupation, Age
Other directorships
current term, period of directorship and DIN (years)
Current term: For a period of 3 years from August 25,
2024, and liable to retire by rotation.
Period of directorship: Director since October 12, 1994
DIN: 00023091
Trupti Utpal Shah 49 Indian Companies:
Designation: Whole-time Director 1. SIHL Consultancy Limited
Date of birth: January 03, 1976 Foreign Companies:
Address: 22/522, Satyagrah Chhavani, behind Shivnand Nil
Ashram Satellite, Manekbag, Ahmedabad City, Gujarat-
380015
Occupation: Business
Current term: For a period of 3 years from October 1,
2023, and liable to retire by rotation
Period of directorship: Director since July 01, 2008
DIN: 02342717
Darshan Bharatbhai Patel 48 Indian Companies:
Designation: Independent Director Nil
Date of birth: October 17, 1976 Foreign Companies:
Address: 31, Vrindavan Inquilab Society, Near Akshar Nil
Flat, Gulbai Tekara Polytechnic, Ahmedabad City,
Gujarat- 380015
Occupation: Professional
Current term: For a period of 5 years from January 28,
2025 and not liable to retire by rotation
Period of directorship: Director since January 28, 2025
DIN: 08708073
Bhushan Chelaram Punani 71 Indian Companies:
Designation: Independent Director 1. Torchit Electronics Private Limited
2. Gujarat Tea Processors and Packers Limited
Date of birth: January 3, 1954
3. Harsha Engineers International Limited
Address: 34, Spring Field, Judges Bunglows Road,
Foreign Companies:
Vastrapur, Ahmedabad, Gujarat- 380015
Nil
Occupation: Professional
Current term: For a period of 5 years from February 12,
2025 and not liable to retire by rotation
Period of directorship: Director since February 12, 2025
DIN: 00119874
Amit Lalitkumar Doshi 65 Indian Companies:
476Name, designation, date of birth, address, occupation, Age
Other directorships
current term, period of directorship and DIN (years)
Designation: Independent Director 1. IRM Energy Limited
Date of birth: February 4, 1960 Foreign Companies:
Address: 112, Nobles Antrix, near Commerce Six Road, Nil
Navarangpura, Ahmedabad City, Gujarat-380009
Occupation: Professional
Current term: For a period of 5 years from July 1, 2022
and not liable to retire by rotation
Period of directorship: Director since July 1, 2022
DIN: 01603380
Abhinav Mahesh Kapadia 45 Indian Companies:
Designation: Independent Director 1. PDEU Innovation and Incubation Centre
Date of birth: February 21, 1980 Foreign Companies:
Address: 102, Shyamal Flat, Near Red Cross, 12 Gujarat Nil
Society, Ahmedabad City, Paldi, Gujarat -380007
Occupation: Professional
Current term: For a period of 5 years from May 28,
2025 and not liable to retire by rotation
Period of directorship: Director since May 28, 2025
DIN: 07889492
Brief profiles of our Directors
Tanmay Upendra Shah is the Managing Director and Chief Financial Officer of our Company. He has obtained
his bachelor’s degree in Commerce from Gujarat University. He has an experience of over 20 years in the field of
stock broking and depository services. He is one of our Promoters and has been associated with our Company
since December 01, 2020.
Upendra Trikamlal Shah is the Chairman and Whole-time Director of our Company. He has obtained his
bachelor’s degree in Commerce from Gujarat University. He has an experience of 30 years in the field of stock
broking and depository services. He is one of our Promoters since the incorporation of our Company and has been
associated with our Company as a director since October 01, 2011.
Purnima Upendra Shah is the Whole-time Director of our Company. She has obtained her bachelor’s degree in
and a master’s degree in Arts from Gujarat University. She has an experience of 30 years in the field of stock
broking and depository services. She is one of our Promoters and has been associated with our Company since its
incorporation.
Trupti Utpal Shah is the Whole-time Director of our Company. She has obtained her bachelor's degree in
Mechanical Engineering from Gujarat University and a master’s degree in science, with a major in Computer
Engineering from Florida Atlantic University. She is responsible for managing the human resources operations of
our Company. She has an experience of 17 years in the field of stock broking and depository services. She is one
of our Promoters and has been associated with our Company as a Director since July 01, 2008.
Darshan Bharatbhai Patel is the Independent Director of our Company. He has obtained his bachelor’s degree
in Commerce from Gujarat University. He has completed his post qualification course in Information Systems
Audit (ISA) and diploma in Insurance and Risk Management conducted by the Institute of Chartered Accountants
of India. He is a fellow member of the Institute of Chartered Accountants of India, a valuer and an insolvency
477professional registered with the Insolvency and Bankruptcy Board of India. He is also the Managing Partner of
BJ Patel & JL Shah. He has an experience of over 25 years in the field of audit and taxation. He has been associated
with our Company from January 28, 2025.
Bhushan Chelaram Punani is the Independent Director of our Company. He has obtained his bachelor’s degree
in science (dairy husbandry) and law from B.R Chakrabarty University, Kurukshetra and Gujarat University,
respectively. He has also completed a post graduate programme in management from Indian Institute of
Management, Ahmedabad. He also holds a Doctorate in Philosophy in commerce from Gujarat University. He is
also associated as a General Secretary with Blind People’s Association (India), Ahmedabad. He was also a
member of the Central Advisory Board on Disability, National Advisory Committee on Accessible Election and
Committee on Drafting of National Law on Disability. He has an experience of over 45 years in the public policy.
He has been associated with our Company from February 12, 2025.
Amit Lalitkumar Doshi is the Independent Director of our Company. He has obtained his bachelor’s degree in
Mechanical Engineering from Maharaja Sayajirao University of Baroda and a diploma in Business Management
from Rajendra Prasad Institute of Communication & Management, Bombay. He has completed the International
Management Course from Hitachi Home & Life Solutions (India) Ltd. He also participated in the Senior
Management Programme of the 3-Tier Programme for Management Development conducted by Indian Institute
of Management, Ahmedabad. He has an experience of more than 28 years in the field of strategic planning and
business development. He has been associated with our Company from July 1, 2022. He has previously served as
the Chief Operating Officer of Dainik Bhaskar, Karnavati Engineering Limited and IRM Private Limited.
Abhinav Mahesh Kapadia is the Independent Director of our Company. He has obtained his bachelor’s degree
and master’s degree in business administration from Gujarat University. He is also registered member of the
Institute of the Company Secretaries of India. He has an experience of over 15 years in the field of finance and
accounts. He has been associated with our Company from May 28, 2025. He has previously served as manager
(finance and accounts) at Gujarat State Petroleum Corporation and Chief Finance Officer at Pandit Deendayal
Petroleum University.
Arrangement or understanding with major shareholders, customers, suppliers or others
None of our Directors have been appointed to our Board pursuant to any arrangement or understanding with major
shareholders, customers, suppliers or others.
Service contract with Directors
None of our Directors have entered into a service contract with our Company pursuant to which they are entitled
to any benefits upon termination of employment.
Details of directorships in companies suspended or delisted
None of our Directors is or was, during the last five years preceding the date of this Draft Red Herring Prospectus,
a director of any listed company whose shares have been or were suspended from being traded on the stock
exchanges during their tenure as a director in such company.
None of our Directors is or was a director of any listed company which has been or was delisted from any stock
exchange, during their tenure as a director in such company.
Confirmations
None of our Directors have given any guarantees to any third party, with respect to the Equity Shares, as of the
date of this Draft Red Herring Prospectus.
No consideration in cash or shares or otherwise has been paid or agreed to be paid to any of our Directors or to
the firms or companies in which they are interested by any person either to induce them to become or to help them
qualify as a Director, or otherwise for services rendered by them or by the firm or company in which they are
interested, in connection with the promotion or formation of our Company.
Further, none of our Directors has been identified as Wilful Defaulters or Fraudulent Borrower as defined under
the SEBI ICDR Regulations.
478None of our Directors has been declared a fugitive economic offender in accordance with the Fugitive Economic
Offenders Act, 2018.
None of our Directors is prohibited from accessing the capital market or debarred from buying, selling or dealing
in securities under any order or direction passed by SEBI or any securities market regulator in any other
jurisdiction or any other authority/court.
None of our Directors are or have been on the board of directors of any company that was or has been directed by
any registrar of companies to be struck off from the rolls of such registrar of companies under Section 248 of the
Companies Act.
All our Independent Directors are registered with the Indian Institute of Corporate Affairs and are in compliance
with Section 149(6) of the Companies Act, 2013.
Relationships between our Directors, Key Managerial Personnel and Senior Managerial Personnel
Except as disclosed below, none of our Directors are related to each other or to any of our Key Managerial
Personnel or Senior Managerial Personnel:
Sr. No. Name of Director Relative Relationship
1. Tanmay Upendra Shah, Managing Upendra Trikamlal Shah Father
Director and Chief Financial Officer Purnima Upendra Shah Mother
Trupti Utpal Shah Sister
2. Upendra Trikamlal Shah, Chairman and Tanmay Upendra Shah Son
Whole-time Director Purnima Upendra Shah Spouse
Trupti Utpal Shah Daughter
3. Purnima Upendra Shah, Whole-time Tanmay Upendra Shah Son
Director Upendra Trikamlal Shah Spouse
Trupti Utpal Shah Daughter
4. Trupti Utpal Shah, Whole-time Director Tanmay Upendra Shah Brother
Upendra Trikamlal Shah Father
Purnima Upendra Shah Mother
Terms of Appointment of our Executive Directors
Tanmay Upendra Shah, Managing Director and Chief Financial Officer
Tanmay Upendra Shah is the Managing Director and Chief Financial Officer of our Company, he has been
appointed on the Board of our Company pursuant to the resolution passed by the Board and Shareholders dated
August 10, 2023 and September 9, 2023, respectively for a period of three (3) years effective from September 9,
2023. He has been a Director in our Company since December 01, 2020. He was appointed as the Chief Financial
Officer, pursuant to a resolution passed by the Board dated, February 23, 2024. No employment agreement has
been entered into to this effect. Pursuant to the Shareholders’ resolution dated September 30, 2024, Tanmay
Upendra Shah is eligible for the following remuneration in the Financial Year 2025:
Not exceeding ₹ 144 lakhs with full liberty to the Board of Directors, including the
Nomination and Remuneration Committee, to revise/ alter/ modify/ amend/ change
the terms and conditions as may be agreed to by the Board and Mr. Tanmay Upendra
Shah within the applicable provisions of the Companies Act. 2013.
Remuneration
In any financial year during the tenure of the said Managing Director, if the Company
has no profits or its profit are inadequate, the remuneration by way of salary, benefits,
perquisites and allowances, commission as mentioned above from time to time shall
be paid as minimum remuneration without any further approval from Shareholders
of the company.
Trupti Utpal Shah, Whole-time Director
Trupti Utpal Shah is the Whole-time Director of our Company, she has been appointed on the Board of our
Company pursuant to the resolution passed by the Board and Shareholders resolution dated August 10, 2023 and
September 9, 2023, respectively for a period of three (3) years effective from October 1, 2023 upto September 30,
4792026. She has been a Director in our Company since July 01, 2008. No employment agreement has been entered
into to this effect. Pursuant to the Shareholders’ resolution dated September 30, 2024, Trupti Utpal Shah is eligible
for the following remuneration in the Financial Year 2025:
Not exceeding ₹ 144 lakhs with full liberty to the Board of Directors, including the
Nomination and Remuneration Committee, to revise/ alter/ modify/ amend/ change
the terms and conditions as may be agreed to by the Board and Mrs. Trupti Utpal
Shah within the applicable provisions of the Companies Act. 2013.
Remuneration
In any financial year during the tenure of the said Director, if the Company has no
profits or its profit are inadequate, the remuneration by way of salary, benefits,
perquisites and allowances, commission as mentioned above from time to time shall
be paid as minimum remuneration without any further approval from Shareholders
of the company.
Upendra Trikamlal Shah, Chairman and Whole-time Director
Upendra Trikamlal Shah is the Chairman and Whole-time Director of our Company, he has been appointed on
the Board of our Company pursuant to the resolution passed by the Board and Shareholders resolutions dated
August 10, 2023 and September 09, 2023, respectively for a period of three (3) years effective from October 1,
2023 upto September 30, 2026. He has been a Director in our Company since October 01, 2011. No employment
agreement has been entered into to this effect. Pursuant to the Shareholders’ resolution dated September 30, 2024,
Upendra Trikamlal Shah is eligible for the following remuneration in the Financial Year 2025:
Not exceeding ₹ 144 lakhs with full liberty to the Board of Directors, including the
Nomination and Remuneration Committee, to revise/ alter/ modify/ amend/ change
the terms and conditions as may be agreed to by the Board and Mr. Upendra
Trikamlal Shah within the applicable provisions of the Companies Act. 2013.
Remuneration
In any financial year during the tenure of the said Director, if the Company has no
profits or its profit are inadequate, the remuneration by way of salary, benefits,
perquisites and allowances, commission as mentioned above from time to time shall
be paid as minimum remuneration without any further approval from Shareholders
of the company.
Purnima Upendra Shah, Whole-time Director
Purnima Upendra Shah is the Whole-time Director of our Company, she has been appointed on the Board of our
Company pursuant to the resolution passed by the Board and Shareholders resolutions dated August 29, 2024 and
September 30, 2024, respectively for a period of three (3) consecutive years effective from August 25, 2024 upto
August 25, 2027. She has been a Director in our Company since its incorporation. No employment agreement has
been entered into to this effect. Pursuant to the Shareholders’ resolution dated September 30, 2024, Purnima
Upendra Shah is eligible for the following remuneration effective from September 30, 2024.
Not exceeding ₹ 144 lakhs with full liberty to the Board of Directors, including the
Nomination and Remuneration Committee, to revise/ alter/ modify/ amend/ change
the terms and conditions as may be agreed to by the Board and Mr. Purnima Upendra
Shah within the applicable provisions of the Companies Act. 2013.
Remuneration
In any financial year during the tenure of the said Director, if the Company has no
profits or its profit are inadequate, the remuneration by way of salary, benefits,
perquisites and allowances, commission as mentioned above from time to time shall
be paid as minimum remuneration without any further approval from Shareholders
of the company.
Terms of Appointment of our Independent Directors
Pursuant to the Board resolution dated March 24, 2025, the sitting fees payable to our Independent Directors for
the Financial Year 2025, for attending meetings of our Board and meetings of various Committees of our Board
within the limits prescribed under the Companies Act, 2013, and the rules notified are hereunder:
(in ₹ lakhs)
480Name For the year ended March 31, 2025
Darshan Bharatbhai Patel 0.07
Bhushan Chelaram Punani 0.07
Amit Lalitkumar Doshi 0.28
Abhinav Mahesh Kapadia Nil*
*Abhinav Mahesh Kapadia was appointed as an Independent Director in Fiscal 2026, accordingly no sitting fees was paid to him during
Fiscal 2025.
As certified by the Independent Chartered Accountant, Dhrumil A. Shah & Co., Chartered Accountants (FRN: 145163W) by way of their
certificate dated September 29, 2025.
Remuneration to our Executive Directors
Details of the remuneration paid to our Executive Directors in Fiscal 2025 are set forth below:
(in ₹ lakhs)
Name For the year ended March 31, 2025*
Tanmay Upendra Shah 60.00
Upendra Trikamlal Shah 36.00
Purnima Upendra Shah 36.00
Trupti Utpal Shah 48.00
*As certified by the Independent Chartered Accountant, Dhrumil A. Shah & Co., Chartered Accountants (FRN: 145163W) by way of their
certificate dated September 29, 2025.
Shareholding of Directors in our Company
Our Articles of Association do not require our Directors to hold any qualification shares.
Except as disclosed below, none of our Directors hold any Equity Shares in our Company:
Name of Director Number of Equity Shares held
Upendra Trikamlal Shah 30,00,000
Purnima Upendra Shah 34,50,000
Tanmay Upendra Shah 25,05,000
Trupti Utpal Shah 6,50,000
Contingent and deferred compensation payable to Directors
There is no contingent or deferred compensation which accrued to our Directors for Fiscal 2025, which does not
form part of their remuneration for such period.
Bonus or profit-sharing plan of our Directors
None of our Directors is a party to any profit-sharing plan by our Company.
Interest of Directors
Our Independent Directors are interested to the extent of sitting fees and commission, if any, payable to them for
attending meetings of our Board and committees and other remuneration or benefits, if any, to which they are
entitled in accordance with the terms of their appointment or reimbursement of expenses incurred by them during
the ordinary course of business by our Company.
Interest in promotion of our Company
Except Tanmay Upendra Shah, Trupti Utpal Shah, Upendra Trikamlal Shah and Purnima Upendra Shah who are
the Promoters of our Company, none of our Directors have any interest in the promotion or formation of our
Company.
481Loans to Directors
No loans have been availed by our Directors from our Company.
Interest in land and property
Our Directors have no interest in any property acquired or proposed to be acquired of our Company or by our
Company, including any property acquired in the three years immediately preceding the date of this Draft Red
Herring Prospectus or proposed to be acquired by our Company, except as disclosed below:
Interest of the
Location Primary Purpose Sale Consideration
Sr. No. Directors
1. Office No. F-19 & F-20, Branch Office The branch office was ₹62.00 lakhs
1st Floor, Samrudhi acquired from
Complex, Opp. Sarjan Tanmay Upendra
Bunglow-2, New C.G Shah, Managing
Road, Chandkheda, Director & Chief
Ahmedabad -382424, Financial Officer,
Gujarat, India vide two sale deeds
both dated June 07,
2023
2. Office No. F-123, First Branch Office The branch office was ₹145.00 lakhs
Floor, Shubh Business acquired from Trupti
Park, Pethapur 382610, Utpal Shah, our
Gandhinagar, Gujarat, Whole Time Director,
India vide a sale deed dated
April 12, 2025
Our directors do not have any direct or indirect interest in any property taken on a rental basis by our Company
during the three years immediately preceding the date of this Draft Red Herring Prospectus, except as disclosed
below:
Date of
Leave and
Interest of License
Primary Date of License
Sr. No. Particulars our Agreement/ Licensor
Purpose cessation Fees
Directors Rent
Consent
Letter
1. Office No. F- Branch Tanmay October 01, June 07, Tanmay ₹19,000 per
19 & F-20, Office Upendra 2017 (for a 2023 Upendra month (for a
1st Floor, Shah, our period of 69 Shah, our period of 69
Samrudhi Managing months Managing months
Complex, Director & commencing Director & commencing
Opp. Sarjan Chief from Chief from
Bunglow-2, Financial October 01, Financial October 01,
New C.G Officer was 2017 upto Officer 2017 upto
Road, the previous June 30, June 30,
Chandkheda, owner of the 2026) 2023).
Ahmedabad said property
-382424,
Gujarat,
India
2. Office No. F- Branch Trupti Utpal October 01, May 01, Trupti Utpal ₹25,000 per
123, First Office Shah, our 2017 (for a 2024 Shah, our month (for a
Floor, Shubh Whole Time period of 79 Whole Time period of 79
Business Director was months Director months
Park, the previous commencing commencing
Pethapur - owner of the from from
382610, said October 01, October 01,
Gandhinagar property. 2017) 2017)
482Date of
Leave and
Interest of License
Primary Date of License
Sr. No. Particulars our Agreement/ Licensor
Purpose cessation Fees
Directors Rent
Consent
Letter
, Gujarat,
India
3. Office No. Storage Upendra September - Upendra ₹12,000 per
317, 3rd premises Trikamlal 25, 2025 (for Trikamlal month (for a
Floor, Shah, our a period of Shah, our period of 11
Spectrum Whole-time 11 months Whole-time months and
Shopping Director is and 29 days) Director 29 days)
Centre No 4, the owner of
Relief Road, the said
Ahmedabad property.
- 380001,
Gujarat
Changes in the Board in the last three years
Except as stated below, there has been no change in the Board in the three (3) preceding years:
Name Date of change Reason for change
Preeti Upendra Shah May 5, 2025 Resignation of Director
Bhismak Manojbhai Soni May 2, 2025 Resignation of Director
Ruchira Tanmay Shah May 2, 2025 Resignation of Director
Abhinav Mahesh Kapadia May 28, 2025 Appointment of Director
Bhushan Chelaram Punani February 12, 2025 Appointment of Director
Darshan Bharatbhai Patel January 28, 2025 Appointment of Director
Utpal Prafulbhai Shah January 7, 2025 Resignation of Director
Siddharth Bharatkumar Shah July 1, 2022 Resignation of Director
Amit Lalitkumar Doshi July 1, 2022 Appointment of Director
Ruchira Shah December 1, 2022 Appointment of Director
Note - This table does not include details of regularisations of additional Directors and changes in designation
Borrowing powers of Board
In accordance with the Articles of Association and applicable provisions of the Companies Act, 2013, and
pursuant to the special resolution dated September 29, 2025, passed by the Shareholders, the Board may borrow
money from time to time, any sum or sums of monies which together with the monies already borrowed by the
Company (apart from temporary loans obtained or to be obtained from the Company’s bankers in the ordinary
course of business) may exceed the aggregate of the paid up capital of the Company and its free reserves, provided
that the total amount so borrowed by the Board shall, outstanding at any time, not at any time exceed ₹ 25,000
lakhs.
Corporate Governance
The corporate governance provisions of the SEBI Listing Regulations will be applicable to us immediately upon
the listing of the Equity Shares on the Stock Exchanges. We are in compliance with the requirements of the
applicable regulations, including the SEBI Listing Regulations and the Companies Act, in respect of corporate
governance including constitution of the Board and committees thereof, as applicable. The corporate governance
framework is based on an effective independent Board and constitution of the Board committees, as required
under law.
In terms of the SEBI Listing Regulations and the provisions of the Companies Act, 2013, our Company has
constituted the following committees of the Board of directors:
(a) Audit Committee;
483(b) Nomination and Remuneration Committee;
(c) Stakeholders’ Relationship Committee;
(d) Corporate Social Responsibility Committee; and
(e) IPO Committee.
Audit Committee
The Audit Committee was constituted pursuant to resolution of our board dated April 01, 2009 reconstituted
pursuant to resolution of our Board dated September 05, 2025.
The composition of the Audit Committee and its terms of reference are in compliance with Regulation 18 of the
SEBI Listing Regulations and Section 177 of the Companies Act, 2013. The current constitution of the Audit
Committee is as follows:
Name of Director Position in the committee Designation
Darshan Bharatbhai Patel Chairperson Independent Director
Bhushan Chelaram Punani Member Independent Director
Upendra Trikamlal Shah Member Chairman and Whole Time Director
The Company Secretary and the Compliance Officer of the Company shall act as the Secretary of the Committee.
The terms and reference of the Audit Committee include:
Powers of Audit Committee
(a) to investigate any activity within its terms of reference;
(b) to seek information from any employee of the Company;
(c) to obtain outside legal or other professional advice; and
(d) to secure attendance of outsiders with relevant expertise, if it considers necessary.
(e) such powers as may be prescribed under the Companies Act and SEBI Listing Regulations
Role of Audit Committee
1. Overseeing the Company’s financial reporting process, examination of the financial statement and the
auditors’ report thereon and the disclosure of its financial information to ensure that the financial statement
is correct, sufficient and credible;
2. Recommendation to the Board for appointment, re-appointment, replacement, remuneration and terms of
appointment of auditors of the Company including the internal auditor, cost auditor and statutory auditor of
the Company, and fixation of the audit fee;
3. Approval of payment to statutory auditors for any other services rendered by the statutory auditors;
4. Reviewing, with the management, the annual financial statements and auditor's report thereon before
submission to the Board for approval, with particular reference to:
a) matters required to be included in the director’s responsibility statement to be included in the Board’s report
in terms of clause (c) of sub-section (3) of Section 134 of the Companies Act, 2013;
b) changes, if any, in accounting policies and practices and reasons for the same;
c) major accounting entries involving estimates based on the exercise of judgment by management;
d) significant adjustments made in the financial statements arising out of audit findings;
e) compliance with listing and other legal requirements relating to financial statements;
f) disclosure of any related party transactions; and
g) modified opinion(s) in the draft audit report;
5. Reviewing, with the management, the quarterly financial statements before submission to the Board for
approval;
6. reviewing, with the management, the statement of uses / application of funds raised through an issue (public
issue, rights issue, preferential issue, etc.), the statement of funds utilized for purposes other than those stated
in the issue document / prospectus / notice and the report submitted by the monitoring agency monitoring the
utilisation of proceeds of a public or rights issue, and making appropriate recommendations to the Board to
take up steps in this matter;
4847. Reviewing and monitoring the auditor’s independence and performance, and effectiveness of audit process;
8. Formulating a policy on related party transactions, which shall include materiality of related party
transactions;
9. Approval or any subsequent modification of transactions of the Company with related parties; All related
party transactions shall be approved by only Independent Directors who are the members of the committee
and the other members of the committee shall reuse themselves on the discussions related to related party
transactions;
Explanation: The term "related party transactions" shall have the same meaning as provided in Clause 2(zc)
of the SEBI Listing Regulations and/or the applicable Accounting Standards and/or the Companies Act,
2013.
10. Review, at least on a quarterly basis, the details of related party transactions entered into by the Company
pursuant to each of the omnibus approvals given;
11. Scrutiny of inter-corporate loans and investments;
12. Valuation of undertakings or assets of the Company, wherever it is necessary; Appointment of Registered
Valuer under Section 247 of the Companies Act, 2013.
13. Evaluation of internal financial controls and risk management systems;
14. Reviewing, with the management, performance of statutory and internal auditors, adequacy of the internal
control systems;
15. Reviewing the adequacy of internal audit function, if any, including the structure of the internal audit
department, staffing and seniority of the official heading the department, reporting structure coverage and
frequency of internal audit;
16. Discussion with internal auditors of any significant findings and follow up thereon;
17. Reviewing the findings of any internal investigations by the internal auditors into matters where there is
suspected fraud or irregularity or a failure of internal control systems of a material nature and reporting the
matter to the Board;
18. Discussion with statutory auditors before the audit commences, about the nature and scope of audit as well
as post-audit discussion to ascertain any area of concern;
19. To look into the reasons for substantial defaults in the payment to the depositors, debenture holders,
shareholders (in case of non-payment of declared dividends) and creditors;
20. To review the functioning of the whistle blower mechanism;
21. Approval of appointment of chief financial officer (i.e., the whole-time finance director or any other person
heading the finance function or discharging that function) after assessing the qualifications, experience and
background, etc. of the candidate;
22. Carrying out any other function as is mentioned in the terms of reference of the audit committee; and
23. Reviewing the utilization of loans and/ or advances from/investment by the holding company in the
subsidiary exceeding rupees 100 crore or 10% of the asset size of the subsidiary, whichever is lower including
existing loans / advances / investments existing as on the date of coming into force of this provision.
24. To formulate, review and make recommendations to the Board to amend the Terms of Reference of Audit
Committee from time to time;
25. Establishing a vigil mechanism for directors and employees to report their genuine concerns or grievances;
26. Reviewing the utilization of loans and/or advances from/investment by the Company in the subsidiaries
exceeding rupees 100 crore or 10% of the asset size of the subsidiary, whichever is lower including existing
loans / advances / investments existing as on the date of coming into force of this provision;
27. the Audit Committee shall review compliance with the provisions of the SEBI Insider Trading Regulations,
at least once in a financial year and shall verify that the systems for internal control under the said regulations
are adequate and are operating effectively;
28. to consider the rationale, cost benefits and impact of schemes involving merger, demerger, amalgamation
etc. of the Company and provide comments to the Company’s shareholders; and
48529. Carrying out any other functions as provided under the provisions of the Companies Act, the SEBI Listing
Regulations and other applicable laws, and carrying out any other functions as may be required / mandated
and/or delegated by the Board as per the provisions of the Companies Act, 2013, SEBI Listing Regulations,
uniform listing agreements and/or any other applicable laws or by any regulatory authority and performing
such other functions as may be necessary or appropriate for the performance of its duties.
The Audit Committee shall mandatorily review the following information:
1. management discussion and analysis of financial condition and results of operations;
2. statement of significant related party transactions (as defined by the audit committee), submitted by
management;
3. management letters / letters of internal control weaknesses issued by the statutory auditors;
4. internal audit reports relating to internal control weaknesses; and
5. the appointment, removal and terms of remuneration of the chief internal auditor shall be subject to review by
the audit committee.
6. statement of deviations:
a) quarterly statement of deviation(s) including report of monitoring agency, if applicable, submitted to stock
exchange(s) in terms of Regulation 32(1) of SEBI Listing Regulations; and
b) annual statement of funds utilized for purposes other than those stated in the issue
document/prospectus/notice in terms of Regulation 32(7) of SEBI Listing Regulations.
7. the financial statements, in particular, the investments made by any unlisted subsidiary; and
8. such information as may be prescribed under the Companies Act and SEBI Listing Regulations.
Nomination and Remuneration Committee (“NRC”)
The NRC was reconstituted pursuant to resolution of our Board dated April 01, 2009 and reconstituted pursuant
to resolution of our Board dated April 01, 2025. The composition of the NRC and its terms of reference are in
compliance with Regulation 19 of the SEBI Listing Regulations and Section 178 of the Companies Act, 2013.
The current constitution of the NRC is as follows:
Name of Director Position in the committee Designation
Darshan Bharatbhai Patel Chairperson Indpendent Director
Amit Lalitkumar Doshi Member Indpendent Director
Bhushan Chelaram Punani Member Indpendent Director
The terms of reference of the Nomination and Renumeration Committee is as follows:
1. Formulating the criteria for determining qualifications, positive attributes and independence of a director and
recommend to the Board a policy, relating to the remuneration of the directors, key managerial personnel and
other employees.
2. For every appointment of an independent director, the Nomination and Remuneration Committee shall
evaluate the balance of skills, knowledge and experience on the Board and on the basis of such evaluation,
prepare a description of the role and capabilities required of an independent director. The person
recommended to the Board for appointment as an independent director shall have the capabilities identified
in such description. For the purpose of identifying suitable candidates, the Committee may
a. use the services of an external agencies, if required;
b. consider candidates from a wide range of backgrounds, having due regard to diversity; and
c. consider the time commitments of the candidates;
The Nomination and Remuneration Committee, while formulating the above policy, should ensure that:
(i) the level and composition of remuneration be reasonable and sufficient to attract, retain and motivate
directors of the quality required to run our Company successfully;
(ii) relationship of remuneration to performance is clear and meets appropriate performance benchmarks; and
486(iii) remuneration to directors, key managerial personnel and Senior Management Personnel involves a balance
between fixed and incentive pay reflecting short and long term performance objectives appropriate to the
working of the Company and its goals.
3. Formulating criteria for evaluation of performance of independent directors and the Board;
4. Devising a policy on diversity of Board;
5. Identifying persons who are qualified to become directors and who may be appointed in senior management
in accordance with the criteria laid down, and recommend to the Board their appointment and removal and
shall specify the manner for effective evaluation of performance of the Board, its committees and individual
directors to be carried out either by the Board, by the Nomination and Remuneration Committee or by an
independent external agency and review its implementation and compliance. The Company shall disclose
the remuneration policy and the evaluation criteria in its annual report;
6. Extending or continuing the term of appointment of the independent director, on the basis of the report of
performance evaluation of independent directors;
7. Recommending to the board, all remuneration, in whatever form, payable to senior management;
8. Analysing, monitoring and reviewing various human resource and compensation matters, including the
compensation strategy;
9. Determining the Company’s policy on specific remuneration packages for executive directors including
pension rights and any compensation payment, and determining remuneration packages of such directors;
10. Recommending the remuneration, in whatever form, payable to non-executive directors and the senior
management personnel and other staff (as deemed necessary);
11. Reviewing and approving compensation strategy from time to time in the context of the then current Indian
market in accordance with applicable laws;
12. Administering, monitoring and formulating detailed terms and conditions of the Employees Stock Option
Scheme of the Company;
13. Framing suitable policies and systems to ensure that there is no violation, as amended from time to time, of
any securities laws or any other applicable laws in India or overseas, including:
a) The Securities and Exchange Board of India (Prohibition of Insider Trading) Regulations, 2015, as
amended; and
b) The Securities and Exchange Board of India (Prohibition of Fraudulent and Unfair Trade Practices
relating to the Securities Market) Regulations, 2003, as amended;
14. Carrying out any other function as is mandated by the Board from time to time and / or enforced/mandated
by any statutory notification, amendment or modification, as may be applicable;
15. Performing such other functions as may be necessary or appropriate for the performance of its duties;
16. Perform functions as are required to be performed by the Compensation Committee under the SEBI (Share
Based Employee Benefits and Sweat Equity) Regulations, 2022.
Corporate Social Responsibility Committee (“CSR Committee”)
The CSR Committee constituted pursuant to resolution of our Board dated July 22, 2016 and reconstituted
pursuant to resolution of our Board dated April 01, 2025. The composition of the CSR Committee and its terms
of reference are in compliance with Section 135 of the Companies Act, 2013. The current constitution of the CSR
Committee is as follows:
Name of Director Position in the committee Designation
Bhushan Chelaram Punani Chairperson Independent Director
Amit Lalitkumar Doshi Member Independent Director
Trupti Utpal Shah Member Whole Time Director
Upendra Trikamlal Shah Member Chairman and Whole Time Director
The terms of reference of the CSR Committee are as follows:
487a. To formulate and recommend to the Board, a Corporate Social Responsibility Policy stipulating, amongst
others, the guiding principles for selection, implementation and monitoring the activities as well as
formulation of the annual action plan which shall indicate the activities to be undertaken by the Company as
specified in Schedule VII of the Companies Act and the rules made thereunder and make any revisions therein
as and when decided by the Board;
b. To review and recommend the amount of expenditure to be incurred on the activities referred to in (a) and
amount to be incurred for such expenditure shall be as per the applicable law;
c. To identify corporate social responsibility policy partners and corporate social responsibility policy
programmes;
d. To review and recommend the amount of expenditure to be incurred for the corporate social responsibility
activities and the distribution of the same to various corporate social responsibility programmes undertaken
by the Company;
e. To delegate responsibilities to the corporate social responsibility team and supervise proper execution of all
delegated responsibilities;
f. To review and monitor the Corporate Social Responsibility Policy of the company and its implementation
from time to time, and issuing necessary directions as required for proper implementation and timely
completion of corporate social responsibility programmes;
g. To do such other acts, deeds and things as may be required to comply with the applicable laws; and;
h. To take note of the Compliances made by implementing agency (if any) appointed for the corporate social
responsibility of the Company.
i. The Corporate Social Responsibility Committee shall formulate and recommend to the Board, an annual
action plan in pursuance of its corporate social responsibility policy, which shall include the following:
a) the list of corporate social responsibility projects or programmes that are approved to be undertaken in
areas or subjects specified in Schedule VII of the Companies Act;
b) the manner of execution of such projects or programmes as specified in the rules notified under the
Companies Act;
c) the modalities of utilisation of funds and implementation schedules for the projects or programmes;
d) monitoring and reporting mechanism for the projects or programmes; and
e) details of need and impact assessment, if any, for the projects undertaken by the Company;
j. To perform such other activities as may be delegated by the Board or specified/ provided under the
Companies Act, 2013 or by the SEBI Listing Regulations or statutorily prescribed under any other law or by
any other regulatory authority.
Stakeholders Relationship Committee (“SRC”)
The SRC was constituted pursuant to resolution of our Board dated May 5, 2017 and reconstituted pursuant to
resolution of our Board dated April 01, 2025. The composition of the SRC and its terms of reference are in
compliance with Regulation 20 of the SEBI Listing Regulations and Section 178 of the Companies Act, 2013.
The current constitution of the SRC is as follows:
Name of Director Position in the committee Designation
Darshan Bharatbhai Patel Chairperson Independent Director
Bhushan Chelaram Punani Member Independent Director
Upendra Trikamlal Shah Member Chairman and Whole Time Director
The terms of reference of the SRC committee are as follows:
1. Redressal of all security holders’ and investors’ grievances such as complaints related to transfer of shares,
including non-receipt of share certificates and review of cases for refusal of transfer/transmission of shares
and debentures, dematerialisation and re-materialisation of shares, non-receipt of balance sheet, non-receipt
of declared dividends, non-receipt of annual reports, etc., assisting with quarterly reporting of such
complaints and formulating procedures in line with statutory guidelines to ensure speedy disposal of various
requests received from shareholders;
4882. Resolving the grievances of the security holders of the Company including complaints related to allotment
of shares, approval of transfer or transmission of shares, debentures or any other securities, non-receipt of
annual report, non-receipt of declared dividends, issue of new/duplicate certificates, general meetings, etc.;
3. Giving effect to all transfer/transmission of shares and debentures, dematerialisation of shares and re-
materialisation of shares, split and issue of duplicate/consolidated share certificates, compliance with all the
requirements related to shares, debentures and other securities from time to time;
4. Reviewing the adherence to the service standards by the Company with respect to various services rendered
by the registrar and transfer agent of our Company and to recommend measures for overall improvement in
the quality of investor services;
5. Review of measures taken for effective exercise of voting rights by shareholders;
6. Review of adherence to the service standards adopted by the Company in respect of various services being
rendered by the registrar & share transfer agent;
7. To approve allotment of shares, debentures or any other securities as per the authority conferred / to be
conferred to the Committee by the Board of Directors from time to time;
8. To approve requests for transfer, transposition, deletion, consolidation, sub-division, change of name,
dematerialization, rematerialisation etc. of shares, debentures and other securities;
9. To monitor and expedite the status and process of dematerialization and rematerialisation of shares,
debentures and other securities of the Company; and
10. Review of the various measures and initiatives taken by the Company for reducing the quantum of
unclaimed dividends and ensuring timely receipt of dividend warrants/annual reports/statutory notices by
the shareholders of the Company.
11. Such terms of reference as may be prescribed under the Companies Act and SEBI Listing Regulations.
IPO Committee
The IPO Committee was constituted pursuant to resolution of our Board dated August 26, 2025. The current
constitution of the IPO Committee is as follows:
Position in the
Name of Director Designation
committee
Upendra Trikamlal Shah Chairman Chairman and Whole Time Director
Tanmay Upendra Shah Member Managing Director and Chief Financial
Officer
Trupti Utpal Shah Member Whole Time Director
The terms of reference of the IPO Committee are as follows:
a) To decide, negotiate and finalize, in consultation with the book running lead manager appointed in relation
to the Issue (the “BRLM”), all matters regarding the Pre-Issue Placement, if any, out of the fresh issue of
Equity Shares by the Company in the Issue, decided by the Board, including entering into discussions and
execution of all relevant documents with Investors;
b) To decide on other matters in connection with or incidental to the Issue, including the pre-Issue placement,
timing, pricing and terms of the Equity Shares, the Issue price, the price band, the size and all other terms and
conditions of the Issue including the number of Equity Shares to be issued in the Issue, the bid / Issue opening
and bid/Issue closing date, discount (if any), reservation, determining the anchor investor portion, issue price
for anchor investors and allocating such number of Equity Shares to anchor investors in consultation with the
BLRMs and in accordance with the SEBI ICDR Regulations and to do all such acts and things as may be
necessary and expedient for, and incidental and ancillary to the Issue including to make any amendments,
modifications, variations or alterations in relation to the Issue and to constitute such other committees of the
Board, as may be required under Applicable Laws, including as provided in the SEBI Listing Regulations;
c) To make applications, seek clarifications, obtain approvals and seek exemptions from, where necessary,
SEBI, the RoC and any other governmental or statutory authorities as may be required in connection with the
Issue and accept on behalf of the Company such conditions and modifications as may be prescribed or
imposed by any of them while granting such approvals, permissions and sanctions as may be required and
wherever necessary, incorporate such modifications / amendments as may be required in the draft red herring
prospectus (the “DRHP”), the red herring prospectus (the “RHP”) and the Prospectus as applicable;
489d) To finalize, settle, approve, adopt and file in consultation with the BRLMs where applicable, the DRHP, the
RHP the Prospectus, the preliminary and final international wrap and any amendments (including dating of
such documents), supplements, notices, addenda or corrigenda thereto, and take all such actions as may be
necessary for the submission and filing of these documents including incorporating such
alterations/corrections/ modifications as may be required by SEBI, the RoC or any other relevant
governmental and statutory authorities or in accordance with Applicable Laws;
e) To approve the relevant restated financial statements to be issued in connection with the Issue;
f) To appoint and enter into and terminate arrangements with the BRLMs, and appoint and enter into and
terminate arrangements in consultation with the BRLMs with underwriters to the Issue, syndicate members
to the Issue, brokers to the Issue, escrow collection bankers to the Issue, refund bankers to the Issue, registrars,
public issue account bankers to the Issue, sponsor bank, legal advisors, auditors, independent chartered
accountants, advertising agency, registrar to the Issue, depositories, custodians, grading agency, monitoring
agency, industry expert, credit rating agencies, printers, and any other agencies or persons or intermediaries
whose appointment is required in relation to the Issue including any successors or replacements thereof, and
to negotiate, finalise and amend the terms of their appointment, including but not limited to the execution of
the mandate letter with the BRLMs and negotiation, finalization, execution and, if required, amendment or
termination of the Issue agreement with the BRLMs;
g) To decide the total number of Equity Shares to be reserved for allocation to eligible categories of investors,
if any;
h) To negotiate, finalise and settle and to execute and deliver or arrange the delivery of the DRHP, the RHP, the
Prospectus, Issue agreement, syndicate agreement, underwriting agreement, share escrow agreement, cash
escrow and sponsor bank agreement, ad agency agreement, agreements with the registrar to the issue and all
other documents, deeds, agreements and instruments whatsoever with the registrar to the Issue, legal advisors,
auditors, stock exchange(s), BRLMs and any other agencies/intermediaries in connection with the Issue with
the power authorize one or more officers of the Company to execute all or any of the aforesaid documents or
any amendments thereto as may be required or desirable in relation to the Issue;
i) To authorise the maintenance of a register of holders of the Equity Shares;
j) To seek, if required, the consent and/or waiver of the lenders of the Company, customers, suppliers, parties
with whom the Company has entered into various commercial and other agreements, all concerned
government and regulatory authorities in India or outside India, and any other consents and/or waivers that
may be required in relation to the Issue or any actions connected therewith;
k) To open and operate bank accounts in terms of the escrow agreement and to authorize one or more officers
of the Company to execute all documents/deeds as may be necessary in this regard;
l) To open and operate bank accounts of the Company in terms of Section 40(3) of the Companies Act, 2013,
as amended, and to authorize one or more officers of the Company to execute all documents/deeds as may be
necessary in this regard;
m) To authorize and approve incurring of expenditure and payment of fees, commissions, brokerage,
remuneration and reimbursement of expenses in connection with the Issue;
n) To accept and appropriate the proceeds of the Issue in accordance with the Applicable Laws;
o) To approve code of conduct as may be considered necessary or as required under Applicable Laws,
regulations or guidelines for the Board, officers of the Company and other employees of the Company;
p) To implement any corporate governance requirements that may be considered necessary by the Board or the
any other committee or as may be required under the Applicable Laws, including the SEBI Listing
Regulations and listing agreements to be entered into by the Company with the relevant stock exchanges, to
the extent allowed under law;
q) To issue receipts/allotment letters/confirmation of allotment notes either in physical or electronic mode
representing the underlying Equity Shares in the capital of the Company with such features and attributes as
may be required and to provide for the tradability and free transferability thereof as per market practices and
regulations, including listing on one or more stock exchanges, with power to authorize one or more officers
of the Company or the Registrar to the Issue to sign all or any of the aforestated documents;
r) To authorize and approve notices, advertisements in relation to the Issue, in accordance with the SEBI ICDR
Regulations and other Applicable Laws, in consultation with the relevant intermediaries appointed for the
Issue;
490s) To do all such acts, deeds, matters and things and execute all such other documents, etc., as may be deemed
necessary or desirable for such purpose, including without limitation, to finalise the basis of allocation and to
allot the shares to the successful allottees as permissible in law, issue of allotment letters/confirmation of
allotment notes, share certificates in accordance with the relevant rules, in consultation with the BRLMs;
t) To do all such acts, deeds and things as may be required to dematerialise the Equity Shares and to sign and /
or modify, as the case maybe, agreements and/or such other documents as may be required with the National
Securities Depository Limited, the Central Depository Services (India) Limited, registrar and transfer agents
and such other agencies, authorities or bodies as may be required in this connection and to authorize one or
more officers of the Company to execute all or any of the afore-stated documents;
u) To make applications for listing of the Equity Shares in one or more stock exchanges for listing of the Equity
Shares and to execute and to deliver or arrange the delivery of necessary documentation to the concerned
stock exchanges in connection with obtaining such listing including without limitation, entering into listing
agreements and affixing the common seal of the Company where necessary;
v) To settle all questions, difficulties or doubts that may arise in regard to the Issue, including such issues or
allotment, terms of the Issue, utilisation of the Issue proceeds and matters incidental thereto as it may deem
fit;
w) To authorize any concerned person on behalf of the Company to give such declarations, affidavits,
undertakings, certificates, consents and authorities as may be required from time to time in relation to the
Issue or provide clarifications to the SEBI, the RoC and the relevant stock exchanges where the Equity Shares
are to be listed;
x) To negotiate, finalize, settle, execute and deliver any and all other documents or instruments and to do or
cause to be done any and all acts or things as the Board or any other committee thereof may deem necessary,
appropriate or advisable in order to carry out the purposes and intent of this resolution or in connection with
the Issue and any documents or instruments so executed and delivered or acts and things done or caused to
be done by the Board or any other committee thereof shall be conclusive evidence of their authority in so
doing;
y) To approve suitable policies on insider trading, whistle-blowing, risk management, and any other policies as
may be required under the SEBI Listing Regulations or any other Applicable Laws;
z) To approve the list of ‘group companies’ of the Company, identified pursuant to the materiality policy
adopted by the Board, for the purposes of disclosure in the DRHP, RHP and Prospectus;
aa) To withdraw the DRHP or the RHP or to decide to not proceed with the Issue at any stage in accordance with
Applicable Laws and in consultation with the BRLMs; and
bb) executing and delivering any and all documents, papers or instruments and doing or causing to be done any
and all acts, deeds, matters or things as it may deem necessary, desirable or expedient in order to carry out
the purposes and intent of the foregoing resolutions or the Issue; and any documents so executed and delivered
or acts, deeds, matters and things done or caused to be done by the IPO Committee shall be conclusive
evidence of the authority of the IPO Committee in so doing;
cc) To settle all questions, difficulties or doubts that may arise in regard to the Issue, including allotment, terms
of the Issue, utilisation of the Issue proceeds and matters incidental thereto as it may deem fit;
dd) To take such action, give such directions, as may be necessary or desirable as regards the Issue and to do all
such acts, matters. deeds and things, including but not limited to the allotment of Equity Shares against the
valid applications received in the Issue, as are in the best interests of the Company; and
ee) To take all actions as may be necessary or authorized in connection with the lssue; and
ff) To delegate any of its powers set out under (a) to (ee) hereinabove, as may be deemed necessary and
permissible under Applicable Laws to the officials of the Company.
491Management Organization Chart
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492Key Managerial Personnel
In addition to Tanmay Upendra Shah, Managing Director and Chief Financial Officer, Trupti Utpal Shah, Upendra
Trikamlal Shah and Purnima Upendra Shah, our Whole-time Directors whose details are provided in “Brief
profiles of our Directors” on page 477, the details of the Key Managerial Personnel of our Company are as
follows:
Hiral Bhawsar is the Company Secretary and Compliance Officer of our Company. She obtained her bachelor’s
degree of law and commerce from Devi Ahilya University, Indore. She is an Associate Member of the Institute
of Company Secretaries of India. She has an experience of over 3 years in the compliance and secretarial domain.
Before her association with our Company, she had held the position of Assistant Manager –Secretarial Department
at IRM Energy Limited. She has been associated with our Company from September 2025.
Senior Management
Rajesh Ramchandra Punjabi is the General Manager and Chief Operating Officer of our Company. He has
completed his education till matriculation level. He has been associated with our Company since October 12,
1994. He has been associated with our Company since the beginning of his carrier. He has over 30 years of
experience in the field of stock broking and depository services.
Kamal Lalitkumar Thakkar is Chief Business Officer of our Company. He has obtained his bachelor’s degree
in Commerce and Law from Gujarat University, and a master’s degree in Business Administration from National
Institute of Management. He has also completed a higher diploma in computer & database programme from
Gujarat State Co-Operative Consumer Federation Limited. He has been associated with our Company from
January 14, 2025. Before his association with our Company, he had held the position of Vice President – Prodcut
Head (BP Channel) at Religare Broking Limited, Vice President (State Head – Franchisee Biz.) at Motilal Oswal
Financial Servies Limited and Deputy Vice President at HDFC Securities Limited. He has over 17 years of
experience in the field of stock broking and financial services.
Shalvi Ritesh Kharidia is the Compliance Officer (Stockbroker and Depository Participant) of our Company.
She has obtained her bachelor’s degree in Commerce, a master’s Commerce and her post graduate diploma in
Investment & Financial Analysis, from Gujarat University. She has also cleared the NISM Series IIIA : Securities
Intermediaries Compliance (Non-Fund) Certification Examination, NISM Series VI: Depository Operations
Continuing Professional Education Program, NISM Series VII: Securities Operations and Risk Management
Continuing Professional Education Program, NISM Series VIII: Equity Derivatives Continuing Professional
Education Program. She has been associated with our Company since May 1, 2005. She has been associated with
our Company since the beginning of her carrier. She has over 20 years of experience in the field of stock broking
and compliance.
Jinal Amrish Shah is the Chief Technology Officer of our Company. He has obtained his bachelor’s degree in
Commerce from Gujarat University. He has also completed a programme on Strategic Management from Indian
Institute of Management, Ahmedabad. He has been associated with our Company since June 01, 2001. He has
been associated with our Company since the beginning of his carrier. He has over 24 years of experience in the
field of software development.
Status of Key Managerial Personnel and Senior Management
All of our Key Managerial Personnel and Senior Management are permanent employees of our Company.
Relationship among Key Managerial Personnel and Senior Management Personnel and Directors
Except as disclosed in “Relationships between our Directors, Key Managerial Personnel and Senior Managerial
Personnel” on page 479, none of our Key Managerial Personnel and Senior Management Personnel are related to
each other.
Arrangements and understanding with major shareholders
None of our Key Managerial Personnel and Senior Management Personnel have been selected pursuant to any
arrangement or understanding with any major shareholders, customers or suppliers of our Company, or others.
493Retirement and termination benefit
Except for applicable statutory benefits, none of our Key Managerial Personnel and Senior Management would
receive any benefits on their retirement or on termination of their employment with our Company.
Shareholding of the Key Managerial Personnel and Senior Management Personnel
Other than as disclosed under “Capital Structure – Shareholding of Directors in our Company” on page 481 and
covered below, none of our Key Managerial Personnel or Senior Management Personnel hold any Equity Shares
as on the date of this Draft Red Herring Prospectus.
Name of KMP/SMP Number of Equity Shares held
Rajesh Ramchandra Punjabi 6,50,000
Shalvi Ritesh Kharidia 400
Service contracts with Key Managerial Personnel and Senior Management Personnel
None of our Key Managerial Personnel or Senior Management Personnel have entered into a service contract with
our Company pursuant to which they are entitled to any benefits upon termination of employment.
Contingent and deferred compensation payable to Key Managerial Personnel and Senior Management
Personnel
There is no contingent or deferred compensation which accrued to our Key Managerial Personnel and Senior
Management Personnel for Fiscal 2025, which does not form part of their remuneration for such period.
Bonus or profit-sharing plan of the Key Managerial Personnel and Senior Management Personnel
None of the Key Managerial Personnel or Senior Management Personnel is party to any bonus or profit-sharing
plan of our Company. The management may from time to time decide to give performance bonus to its employees.
Payment of non-salary related benefits to officers of the Company
None of the Key Managerial Personnel or Senior Management Personnel is party to any non-salary related benefits
of our Company.
Other confirmations
None of our Key Managerial Personnel and Senior Management Personnel have any conflict of interest with the
suppliers of raw materials, third party service providers or lessors of immovable properties, crucial to our business
and operations of our Company.
Remuneration paid to Key Managerial Personnel and Senior Management Personnel for Financial Year
2025:
(in ₹ lakhs)
Name of Key Managerial Personnel/ Senior
Particulars Remuneration
Management Personnel
Upendra Trikamlal Shah 36.00
Purnima Upendra Shah 36.00
Key Managerial Personnel Tanmay Upendra Shah 60.00
Trupti Utpal Shah 48.00
Hiral Bhawsar* Nil
Rajesh Ramchandra Punjabi 60.00
Jinal Amrish Shah 19.01
Senior Management Personnel
Shalvi Ritesh Kharidia 7.23
Kamal Lalitkumar Thakkar** 9.97
*She was appointed in the Fiscal 2026
**He was appointed on January 14, 2025
Interest of our Key Managerial Personnel and Senior Management Personnel
494Our Key Managerial Personnel and Senior Management Personnel are interested in our Company to the extent of
the remuneration or benefits to which they are entitled to as per their terms of appointment and reimbursement of
expenses incurred by them during the ordinary course of their service.
Our Key Managerial Personnel may also be deemed to be interested to the extent of any dividend payable to them
and other distributions in respect of Equity Shares held by them in our Company.
For further details please see the section titled “Our Management – Interest of Directors” on page 481.
Attrition of Key Managerial and Senior Management vis-à-vis industry
The rate of attrition of our Key Managerial Personnel and our Senior Managerial Personnel is not high in
comparison to the industry in which we operate.
Changes in the Key Managerial Personnel and Senior Management Personnel in last three years
Other than as disclosed under “Changes in the Board in the last three years” on page 483, the details of the
changes in the Key Managerial Personnel and Senior Management Personnel of our Company in the last three (3)
years are as follows:
Name Designation Date of change Reason of change
Hiral Bhawsar Company Secretary and Compliance September 10, 2025 Appointment
Officer
Preeti Upendra Shah Company Secretary September 10, 2025 Resignation
Shalvi Ritesh Kharidia Compliance Officer August 29, 2024 Appointment
Tanmay Upendra Shah Chief Financial Officer February 23, 2024 Appointment
Shamik Harivadanbhai Chief Financial Officer September 09, 2023 Resignation
Chokshi
Kamal LalitkumarThakkar Chief Business Officer January 14, 2025 Appointment
Utpal Prafulbhai Shah Compliance Officer August 29, 2024 Resignation
Employee stock option plan/ Stock appreciation right scheme
Our Company does not have any employee stock option scheme or stock appreciation right scheme as on the date
of this Draft Red Herring Prospectus.
495OUR PROMOTERS AND PROMOTER GROUP
Our Promoters
The Promoters of our Company are Tanmay Upendra Shah, Upendra Trikamlal Shah, Purnima Upendra Shah and
Trupti Utpal Shah.
As on date of this Draft Red Herring Prospectus, our Promoters, in aggregate, hold 96,05,000 Equity Shares in
our Company, representing 60.97 % of the issued, subscribed and paid-up Equity Share capital of our Company.
For details of the build-up of the Promoters’ shareholding in our Company, see “Capital Structure – History of
the Equity Share capital held by our Promoters” on page 286.
Details of our Promoters:
1. Upendra Trikamlal Shah
Upendra Trikamlal Shah, aged 72 years, is one of our Promoters and is
also the Chairman and Whole-time Director of our Company.
Date of Birth: February 21, 1953
Address: 17/345, Satyagrah Chhavani Society, Jodhpur Tekra, Satellite
Road, Manekbag, Ahmedabad, Gujarat-380015
For a complete profile of Upendra Trikamlal Shah i.e., his educational
qualifications, professional experience, positions and posts held in the
past and other directorships, interest in other entities, special
achievements, business and financial activities, see “Our Management”
on page 475.
His permanent account number is ACIPS6606E.
2. Tanmay Upendra Shah
Tanmay Upendra Shah, aged 44 years, is one of our Promoters and is
also the Managing Director and Chief Financial Officer of our
Company.
Date of Birth: October 10, 1980
Address: 17/345, Satyagrah Chhavani Society, Jodhpur Tekra, Satellite
Road, Manekbag, Ahmedabad, Gujarat-380015
For a complete profile of Tanmay Upendra Shah i.e., his educational
qualifications, professional experience, positions / posts held in the past
and other directorships, interest in other entities, special achievements,
business and financial activities, see “Our Management” on page 475.
His permanent account number is AJZPS0534R
3. Purnima Upendra Shah
Purnima Upendra Shah, aged 75 years is one of our Promoters and is
also a Whole-time Director on the Board.
Date of Birth: July 29, 1950
Address: 17/345, Satyagrah Chhavani Society, Jodhpur Tekra, Satellite
Road, Manekbag, Ahmedabad, Gujarat-380015
For a complete profile of Purnima Upendra Shah i.e., her educational
qualifications, professional experience, positions and posts held in the
past and other directorships, interest in other entities, special
achievements, business and financial activities, see “Our Management”
on page 475.
496Her permanent account number is ACKPS0415K.
4. Trupti Utpal Shah
Trupti Utpal Shah, aged 49 years is one of our Promoters and is also a
Whole-time Director on the Board.
Date of Birth: January 3, 1976
Address: 22/525, Satyagrah Chhavani, behind Shivnand Ashram
Satellite, Manekbag, Ahmedabad City, Gujarat- 380015
For a complete profile of Trupti Utpal Shah i.e., his educational
qualifications, professional experience, positions and posts held in the
past and other directorships, interest in other entities, special
achievements, business and financial activities, see “Our Management”
on page 475.
Her permanent account number is ALXPS4957N.
Our Company confirms that the permanent account number, Aadhaar Card Number, bank account number(s), the
passport number, and driving license number of each of our Promoters will be submitted to the Stock Exchanges
at the time of filing of this Draft Red Herring Prospectus.
Other ventures of our Promoters
Other than as disclosed in “Our Promoters and Promoter Group – Entities forming part of our Promoter Group”
below and in section “Our Management – Other Directorships” on page 475, our Promoters are not involved in
any other ventures.
Change in the control of our Company
While there has been no change in control of our Company in the last five years immediately preceding the date
of this Draft Red Herring Prospectus, Tanmay Upendra Shah, Upendra Trikamlal Shah, Purnima Upendra Shah
and Trupti Utpal Shah have been identified as the Promoter of our Company pursuant to the resolution dated
September 05, 2025 approved by our Board.
Interests of Promoters
Our Promoters are interested in our Company to the extent that they have promoted our Company and to the extent
of their respective shareholding and the shareholding of the members of the Promoter Group in our Company,
directly and indirectly, the dividend payable, if any, and any other distributions in respect of the Equity Shares
held by them in our Company, directly or indirectly, from time to time. For details of the shareholding of our
Promoters in our Company, please see the section entitled “Capital Structure” and “Our Management – Interests
of Directors” on page 104 and 481 respectively.
Our Promoters, who are also Directors, may be deemed to be interested to the extent of their remuneration/fees
and reimbursement of expenses, payable to them, if any. For further details, please see the section entitled “Our
Management – Details of Remuneration paid to the Directors of our Company for the Financial Year 2025” on
page 481.
Our Promoters and members of the Promoter Group do not have any direct or indirect interest in any property
acquired by our Company during the three years immediately preceding the date of this Draft Red Herring
Prospectus, except as disclosed below:
497Interest of the
Promoter / members
Location Primary Purpose Sale Consideration
Sr. No. of the Promoter
Group
1. Office No. F-19 & F-20, Branch Office The branch office was ₹62.00 lakhs
1st Floor, Samrudhi acquired from
Complex, Opp. Sarjan Tanmay Upendra
Bunglow-2, New C.G Shah, our Promoter
Road, Chandkheda, and Managing
Ahmedabad -382424, Director & Chief
Gujarat, India Financial Officer,
vide two sale deeds
both dated June 07,
2023
2. Office No. F-123, First Branch Office The branch office was ₹145.00 lakhs
Floor, Shubh Business acquired from Trupti
Park, Pethapur - 382610, Utpal Shah, our
Gandhinagar, Gujarat, Promoter and Whole
India Time Director, vide a
sale deed dated April
12, 2025
3. 104, Platinum II, Opp. Branch Office The branch office was ₹70.00 lakhs
S.T. colony, College acquired from
Road, Moti Baug, Ruchira Shah, spouse
Junagadh -362001, of Tanmay Upendra
Gujarat, India Shah who is our
Promoter and
Managing Director, &
Chief Financial
Officer vide a sale
deed dated September
11, 2023.
* N.A. denotes Not Applicable
Our Promoters and members of the Promoter Group do not have any direct or indirect interest in any property
taken on a rental basis by Company during the three years immediately preceding the date of this Draft Red
Herring Prospectus, except as disclosed below:
Date of
Leave and
Interest of License
Primary Date of License
Sr. No. Particulars our Agreement/ Licensor
Purpose cessation Fees
Directors Rent
Consent
Letter
1. Office No. F- Branch Tanmay October 01, June 07, Tanmay ₹19,000 per
19 & F-20, Office Upendra 2017 (for a 2023 Upendra month (for a
1st Floor, Shah, our period of 69 Shah, our period of 69
Samrudhi Managing months Managing months
Complex, Director & commencing Director & commencing
Opp. Sarjan Chief from Chief from
Bunglow-2, Financial October 01, Financial October 01,
New C.G Officer was 2017 upto Officer 2017 upto
Road, the previous June 30, June 30,
Chandkheda, owner of the 2023) 2023).
Ahmedabad said property
-382424,
Gujarat,
India
498Date of
Leave and
Interest of License
Primary Date of License
Sr. No. Particulars our Agreement/ Licensor
Purpose cessation Fees
Directors Rent
Consent
Letter
2. Office No. F- Branch Trupti Utpal October 01, May 01, Trupti Utpal ₹25,000 per
123, First Office Shah, our 2017 (for a 2024 Shah, our month (for a
Floor, Shubh Whole Time period of 79 Whole Time period of 79
Business Director was months Director months
Park, the previous commencing commencing
Pethapur - owner of the from from
382610, said property October 01, October 01,
Gandhinagar 2017) 2017)
, Gujarat,
India
3. 104, Branch Ruchira April 01, June 30, Ruchira ₹19,000 per
Platinum II, Office Shah, spouse 2017 (for a 2023 Shah, spouse month (for a
Opp. S.T. of Tanmay period of 75 of Tanmay period of 75
colony, Upendra months Upendra months
College Shah, our commencing Shah, our commencing
Road, Moti Managing from April Managing from April
Baug, Director & 01, 2017 to Director & 01, 2017 to
Junagadh - Chief June 30, Chief June 30,
362001, Financial 2023) Financial 2023)
Gujarat, Officer was Officer
India the previous
owner of the
said
property.
4. Office No. Storage Upendra September - Upendra ₹12,000 per
317, 3rd Premises Trikamlal 25, 2025 (for Trikamlal month (for a
Floor, Shah, our a period of Shah, our period of 11
Spectrum Whole-time 11 months Whole-time months and
Shopping Director is and 29 days) Director 29 days)
Centre No 4, the owner of
Relief Road, the said
Ahmedabad property.
- 380001,
Gujarat
Payment or benefits to Promoters or Promoter Group
Except in the ordinary course of business and as disclosed in the sections entitled “Other Financial Information -
Related Party Disclosures” and “Financial Information –Notes to Restated Financial Information” on page 575
and 503, respectively, no amount or benefit has been paid or given to our Promoters or any of the members of the
Promoter Group during the two years preceding the filing of this Draft Red Herring Prospectus nor is there any
intention to pay or give any amount or benefit to our Promoters or any of the members of the Promoter Group
other than in the ordinary course of business.
Disassociation by our Promoters in the last three years
Our Promoters have not disassociated themselves from any companies or firms during the preceding three years
from the date of filing of this Draft Red Herring Prospectus.
Material guarantees given by our Promoters to third parties with respect to Equity Shares of our Company
Our Promoters have not given any material guarantee to any third party with respect to the Equity Shares as on
the date of this Draft Red Herring Prospectus.
Confirmations
499Our Promoters have not been declared Wilful Defaulters or Fraudulent Borrowers by any bank or financial
institution or consortium thereof, in accordance with the guidelines on Wilful Defaulters or Fraudulent Borrowers
issued by Reserve Bank of India.
Our Promoters have not been declared a fugitive economic offender under section 12 of the Fugitive Economic
Offenders Act, 2018.
Our Promoters and members of our Promoter Group have not been prohibited or debarred from accessing the
capital markets or debarred from buying, selling or dealing in securities under any order or direction passed by
SEBI or any other securities market regulator or any other authority, court or tribunal inside and outside India.
Our Promoters are not and have not been promoters or directors of any other company which is debarred from
accessing or operating in capital markets under any order or direction passed by SEBI or any other regulatory or
governmental authority.
Promoter Group
In addition to our Promoters, the individuals and entities that form part of the Promoter Group of our Company
in terms of the SEBI ICDR Regulations are set out below:
Individuals forming part of the Promoter Group
The individuals forming a part of our Promoter Group are as follows:
Members of the Promoter Group Relationship with the Promoter
Tanmay Upendra Shah
Upendra Trikamlal Shah Father
Purnima Upendra Shah Mother
Trupti Utpal Shah Sister
Preeti Upendra Shah Sister
Ruchira Shah Spouse
Kenisha Shah Daughter
Vijay Manubhai Vyas Spouse’s Father
Nivedita Vijay Vyas Spouse’s Mother
Shashin Vijaybhai Vyas Spouse’s Brother
Upendra Trikamlal Shah
Purnima Upendra Shah Spouse
Tanmay Upendra Shah Son
Trupti Utpal Shah Daughter
Preeti Upendra Shah Daughter
Sunilbhai Mahendrabhai Mehta Spouse’s Brother
Siddharth Mahendrabhai Mehta Spouse’s Brother
Snehalata Manubhai Shah Spouse’s Sister
Jayshri Sudhirkumar Shah Spouse’s Sister
Meena Deepak Shah Spouse’s Sister
Malvika Ketanbhai Shah Spouse’s Sister
Purnima Upendra Shah
Upendra Trikamlal Shah Spouse
Tanmay Upendra Shah Son
Trupti Utpal Shah Daughter
Preeti Upendra Shah Daughter
Sunilbhai Mahendrabhai Mehta Brother
Siddharth Mahendrabhai Mehta Brother
Snehalata Manubhai Shah Sister
Jayshri Sudhirkumar Shah Sister
Meena Deepak Shah Sister
Malvika Ketanbhai Shah Sister
Trupti Utpal Shah
Upendra Trikamlal Shah Father
Purnima Upendra Shah Mother
Tanmay Upendra Shah Brother
Preeti Upendra Shah Sister
500Members of the Promoter Group Relationship with the Promoter
Utpal Praful Shah Spouse
Rehaan Utpal Shah Son
Aashna Utpal Shah Daughter
Prafulbhai Kacharabhai Shah Spouse’s Father
Pritish Praful Shah Spouse’s Brother
Entities forming part of the Promoter Group:
Companies/LLPs
1. Infinium Mines and Minerals LLP*
2. Arthika Quantomics Private Limited
3. SIHL Commodities Limited
4. Ficus Food Lab Private Limited
5. Trinity Edutech LLP
6. Stock Book LLP
7. P & S Space Developers LLP
8. Plera Wellness Plus LLP
9. Arbor Park LLP
10. Arbor Fund Management (IFSC) LLP
*Pursuant to the form FiLLiP dated August 29, 2025, Infinium Mines & Minerals LLP had been converted into a limited liability partnership
having a LLP IN – ACQ-9815, from a private limited company, as on the date of this Draft Red Herring Prospectus.
HUFs
1. Upendra T Shah HUF
2. Tanmay U Shah HUF
3. Utpal P Shah HUF
4. Vijay Manubhai Vyas HUF
5. Siddharth Mahendrabhai Mehta (HUF)
Firms/Trusts
1. Vimal Jyot Charitable Trust
2. Shree Mahavir Swami Jinalay Trust
3. Playqid
4. SIHL Properties
5. PK Traders
6. Laxmi Textiles;
7. Moon Trade
8. Juniors Club
501DIVIDEND POLICY
The declaration and payment of dividends on our Equity Shares, if any, will be recommended by our Board and
approved by our Shareholders, at their discretion, subject to the provisions of the Articles of Association and the
applicable laws including the Companies Act, read with the rules notified thereunder, each as amended. We may
retain all our future earnings, if any, for purposes to be decided by our Company, subject to compliance with the
provisions of the Companies Act. The quantum of dividend, if any, will depend on a number of factors, including
but not limited to profits earned and available for distribution during the relevant Financial Year, accumulated
reserves including retained earnings, expected future capital/expenditure requirements, organic growth
plans/expansions, proposed long-term investment, capital restructuring, debt reduction, crystallization of
contingent liabilities, cash flows, current and projected cash balance, and external factors, including but not
limited to the macro-economic environment, regulatory changes, technological changes and other factors like
statutory and contractual restrictions.
Our Company has, by way of a resolution of the Board of Directors dated September 05, 2025, adopted a formal
dividend distribution policy.
In addition, our ability to pay dividends may be impacted by a number of factors, including restrictive covenants
under our current or future loan or financing documents. The amounts declared as dividends in the past are not
necessarily indicative of our dividend amounts, if any, in the future. For more information on restrictive covenants
under our current loan agreements, see “Financial Indebtedness” on page 612. Our Company may pay dividend
by cheque, or electronic clearance service, as will be approved by our Board in the future. Our Board may also
declare interim dividend from time to time.
Details of the dividend declared and paid by our Company on the Equity Shares during the last three Fiscals and
the period from April 1, 2025, till the date of this Draft Red Herring Prospectus are set forth below:
For the period April
Particulars 1, 2025 until the Fiscal 2025 Fiscal 2024 Fiscal 2023
date of the DRHP
No. of Equity Shares 1,57,54,000 1,57,54,000 1,57,54,000 1,57,54,000
Face value per Equity Share (in 10 10 10 10
₹)
Aggregate Dividend (in ₹ lakhs) 157.54 157.54 157.54 78.77
(Interim + Final)
Dividend per Equity Share (in ₹) 1 1 1 0.50
(Interim + Final)
Rate of dividend (%) 10 10 10 5
Mode of Payment of Dividend -* National National National Electronic
Electronic Funds Electronic Funds Funds
Transfer(“NEFT”) Transfer(“NEFT”) Transfer(“NEFT”)/
/Demand /Demand Demand
Draft(“DD”) Draft(“DD”) Draft(“DD”)
*The Board of Director has proposed dividend on September 05, 2025 which is approved by the Shareholders in the Annual General Meeting
held on September 29, 2025 and the company is in the process of distributing the same in accordance with the Companies Act, 2013.
The amount of dividend paid in the past is not necessarily indicative of the dividend policy of our Company or
dividend amounts, if any, in the future. Investors are cautioned not to rely on past dividends as an indication of
the future performance of our Company or for an investment in the Equity Shares offered in the Issue. There is
no guarantee that any dividends will be declared or paid in future. For details, see “Risk Factors -Our company
cannot assure payment of dividends on the Equity Shares in the future.” on page 502.
502SECTION V – FINANCIAL INFORMATION
Sr. No. Particulars
1. Examination Report on Restated Consolidated Financial Information
2. Restated Consolidated Financial Information
(The remainder of this page has intentionally been left blank)
503Dhrumil A. Shah & Co Phone: 2640 3811
1, S hantinath.
Chartered Accountants Shantisadan Society
B/H. Doctor House.
CA Dhrumil A. Shah Ellisbridge, Ahrnedabad-
B.Corn., F.C.A., DISA 380 006.
Independent Auditors' Examination Report on the Restated Consolidated Statement of Assets and Liabilities as at
March 31, 2025, March 31, 2024 and March 31, 2023, and the Restated Consolidated Statement of Profit and Loss
(including Other Comprehensive Income), Restated Consolidated Statement of Changes in Equity and Restated
Consolidated Statement of Cash Flows for the years ended March 31, 2025, March 31, 2024 and March 31, 2023,
and Summary of material accounting policies and other explanatory information (collectively, the "Restated
Consolidated Financial Information") of Shah Investor's Home Limited and its Subsidiaries as mentioned in
AnnexureA
To,
The Board of Directors
Shah Investor's Home Limited
Dear Sirs,
I) We, Dhrumil A Shah & Co, Chartered Accountants have examined the attached Restated Consolidated Financial
Information of Shah Investor's Horne Limited (the "Parent Company" or "Issuer") and its subsidiaries as mentioned in
Annexure A annexed to this report and prepared by the Parent Company for the purpose of inclusion in the Draft Red
Herring Prospectus ("DRHP") proposed to be filed with the Securities and Exchange Board of India ("SEEi"), BSE
Limited and National Stock Exchange of India Limited (collectively, the "Stock Exchanges") in connection with its
proposed initial public offer of equity shares of face value of Rs. 10 each of the Company (the "!PO"). The Restated
Consolidated Financial Information, which have been approved by the board of directors of the Parent Company at their
meeting held on September 5, 2025, have been prepared in accordance with the requirements of:
a) Section 26 of Part I of Chapter III of the Companies Act, 2013 as amended (the "Act"):
b) The Securities and Exchange Board of India (Issue of Capital and Disclosure Requirements) Regulations,
2018, as amended (the "SEEi ICDR Regulations"):
c) The Guidance Note on Reports in Company Prospectuses (Revised 2019) (as amended) issued by the Institute
of Chartered Accountants oflndia ("!CAI"), (the "Guidance Note"): and
Responsibilities of Management and those charged with Governance for the Restated Consolidated Financial
Information
2) The Parent Company's Management and Board of Directors are responsible for the preparation of the Restated
Consolidated Financial Information for the purpose of inclusion in the DRHP to be filed with SEEi and Stock
Exchanges in connection with the proposed !PO.
504The Restated Consolidated Financial Information have been prepared by the management of the Parent Company based
on Note l. l(i) "Basis of Preparation" stated in the Restated Consolidated Financial Information.
The respective Board of Directors of the companies included in the Group and of its associate are responsible for
designing, implementing, and maintaining adequate internal control relevant to the preparation and presentation of the
Restated Consolidated Financial Information. The respective Board of Directors are also responsible for identifying and
ensuring that the Group and its subsidiaries complies with the Act, the SEEi ICDR Regulations, the Guidance Note and
SEEi correspondences.
Auditors' Responsibilities for the Restated Consolidated Financial Information
3) We have examined such Restated Consolidated Financial Information taking into consideration:
a) The terms of reference and terms of our engagement agreed upon with you in accordance with our engagement
letter dated July 22, 2025 in connection with the proposed !PO of equity shares of the Issuer;
b) The Guidance Note also requires that we comply with the ethical requirements of the Code of Ethics issued by the
!CAI;
c) Concepts of test checks and materiality to obtain reasonable assurance based on verification of evidence
supporting the Restated Consolidated Financial Information; and
d) The requirements of Section 26 of the Act and the SEEi ICDR Regulations.
Our work was performed solely to assist you in meeting your responsibilities in relation to your compliance with
the Act, the SEEi ICDR Regulations, the Guidance Note and SEEi E-mail in connection with the !PO.
Restated Consolidated Financial Information
4) These Restated Consolidated Financial Information have been compiled by the management of Parent company from:
a) The Audited consolidated Ind AS financial statements of the Parent company and its subsidiaries as at and for the
year ended March 31, 2025 prepared in accordance with the Indian Accounting Standards as prescribed under
Section 133 of the Act read with Companies (Indian Accounting Standards) Rules 2015, (as amended) along with
the presentation requirements of Division III of Schedule III to the Act (Ind-AS compliant Schedule III), as
applicable, and other accounting principles generally accepted in India, which have been approved by the Board of
Directors at their meeting held on September 5, 2025. The comparative information for the year ended March 31,
2024 included in such financial statements have been prepared by making Ind AS adjustments to the audited
financial statements of the Company as at and for the year ended March 31, 2024, prepared in accordance with the
accounting standards notified under the section 133 of the Act read with the Companies (Accounting Standards)
Rules, 2021 (as amended).
505For the financial year ended March 31, 2023, the Parent company and its subsidiaries prepared its statutory
financial statements in accordance with accounting principles generally accepted in India, including the
Companies (Accounting Standards) Rules, 2021, as amended, specified under Section 133 of the Act ("Indian
GAAP") due to which the special purpose consolidated financial statements were prepared to comply with the
SEEi ICDR Regulations, the Guidance Note and SEEi Correspondence. The audited special purpose consolidated
Ind AS financial statements have been prepared after making suitable adjustments to the audited Indian GAAP
financial statements of the Parent company and its subsidiaries as at and for the year ended March 31, 2023
prepared in accordance with the accounting standards notified under the section 133 of the Act ("Indian GAAP").
Auditor's Report
5) For the purpose of our examination, we have relied on:
a) Auditors' report issued by us dated September 5, 2025 on the Consolidated Ind AS Financial Statements of the
Group as at and for the year ended March 31, 2025 and corresponding restated figures of previous year ended on
March 31, 2024 as referred in Paragraph 4( a) above; and
b) Auditors' report issued by us dated September 5, 2025 on the special purpose consolidated Ind AS financial
statements of the Group for the period ended on March 31, 2023 as referred in Paragraph 4(a) above; and
c) The Statutory Audit of the consolidated financial statements of the Parent Company and its subsidiaries as at and
for the year ended March 31, 2024 and March 31, 2023 prepared in accordance with the accounting standards
notified under the section 133 of the Act ("Indian GAAP"), which has been approved by the Board of directors at
their meeting held on August 29, 2024 and August 10, 2023 respectively, were conducted by us.
6) As indicated in our audit reports referred above:
We did not audit the financial statements of subsidiary, whose share of total assets, total revenues, net cash inflows
/ (outflows) and share of profit/ loss included in the consolidated financial statements, for the relevant years is
tabulated below, which have been audited by other auditors, and whose reports have been furnished to us by the
Company's management and our opinion on the consolidated financial statements, in so far as it relates to the
amounts and disclosures included in respect of these components, is based solely on the reports of the other
auditors:
(~ in Lakhs)
Particulars For the year ended For the year ended For the year ended
March 31, 2025 March 31, 2024 March 31, 2023
Total Assets 1702.66 1662.74 871.23
Total Revenue 211.77 383.48 407.57
Net cash inflow/( outflow) 183 02 91.87 (904 87)
Share of profit/(loss) 93.47 698.45 (2833)
506Our report is intended solely for the use of Parent Company to comply with the requirements of the SEEi ICDR
Regulations and Guidance Note. Hence, this report should not be distributed to or used by any other parties.
Further, we do not accept or assume any liability or any duty of care for any other purpose or to any other person
to whom this report is shown or into whose hands it may come without our prior consent in writing.
Our opinion is not modified in respect of this matter.
7) Based on our examination and according to the information and explanations given to us we report that the Restated
Consolidated Financial Information:
a) have been prepared after incorporating adjustments for the changes in accounting policies, material errors and
regrouping/reclassifications retrospectively m the financial years ended March 31, 2024 and
March 31, 2023 to reflect the same accounting treatment as per the accounting policies and
grouping/classifications followed as at and for the period ended March 31, 2025;
b) There are no qualifications in the independent auditor's reports on the (i) Special Purpose Consolidated Financial
Statements of the Group and (ii) Audited Consolidated Financial Statements of Parent company and its
subsidiaries as at and for the year ended March 31, 2025, March 31, 2024 and March 31, 2023 which require any
adjustments to the Restated Consolidated Financial Information; and
c) have been prepared in accordance with the Act, the SEEi ICDR Regulations, the Guidance Note and SEEi
Communication.
8) The Restated Consolidated Financial Information do not reflect the effects of events that occurred subsequent to the
respective dates of the reports on the special purpose interim consolidated Ind AS financial statements and audited
consolidated financial statements mentioned in paragraph 4(a) above.
9) This report should not in any way be construed as a reissuance or re-dating of any of the previous audit reports issued
by us, nor should this report be construed as a new opinion on any of the financial statements referred to herein.
10) We have no responsibility to update our report for events and circumstances occurring after the date of the report.
507Restriction on use
11) Our report is intended solely for use of the Board of Directors of Parent company for inclusion in the DRHP to be filed
with SEEi and Stock Exchanges in connection with the proposed !PO. Our report should not be used, referred to, or
distributed for any other purpose except with our prior consent in writing. Accordingly, we do not accept or assume
any liability or any duty of care for any other purpose or to any other person to whom this report is shown or into
whose hands it may come without our prior consent in writing.
For Dhrumil A. Shah & Co
Chartered Accountants
(Finn's Registration Number: 145163W)
Dhrumil A. Shah
Proprietor
Place of Signature: Ahmedabad Membership No: 166079
Date: 5th September, 2025 UDIN:25166079BMLJBJ8436
508AnnexureA
Name of Entity Relationship Name of Audit Firm Financial years audited
SIHL Fincap Limited Subsidiary Ashil N Shah & Co April I, 2022 to March 31, 2023
April I, 2023 to March 31, 2024
April I, 2024 to March 31, 2025
SIHL CONSULTANCY LIMITED Subsidiary Ashil N Shah & Co April I, 2022 to March 31, 2023
April I, 2023 to March 31, 2024
April I, 2024 to March 31, 2025
SIHL GLOBAL INVESTMENTS (IFSC) Subsidiary April I, 2022 to March 31, 2023
PRIVATE LIMITED Dhrumil A Shah & Co April I, 2023 to March 31, 2024
April I, 2024 to March 31, 2025
SIHL STRATEGIC ADVISORS PRIVATE Subsidiary Ashil N Shah & Co April I, 2022 to March 31, 2023
LIMITED April I, 2023 to March 31, 2024
April I, 2024 to March 31, 2025
509Shah Investor's Home Limited
CIN: U67120GJ1994PLC0232S7
Restated Consolidated Balance Sheet as at 31 March, 2025
I" in lakhs)
Note As at 31 March, As at 31 March, As at 31 March,
Particulars
No. 2025 2024 2023
ASSETS
1 Financial Assets
a Cash and Cash Equivalents 5 8,511.14 13,006.98 2,837.68
b Bank Balance other than (a) above 6 7,342.30 4,544.86 7,444.71
C Receivables 7 1,685.59 778.48 1,095.75
d Loans 8 1,897.30 1,319.24 1,817.24
e Investments 9 7,730.27 7,223.65 4,972.85
f Other Financial assets 10 267.47 282.80 308.38
Sub Total -Financial Assets 27,434.07 27,156.01 18,476.61
2 Non-Financial Assets
a Current tax assets (Net) 11 220.30 217.72 256.47
b Investment Property 12(a) 86.35 90.77
C Property, Plant and Equipment 12(b) 2,103.74 2,085.66 2,067.15
d Capital work-in-progress 12(c) 107.54 39.84 7.23
e Intangible assets under development 12(d) 13.94 13.94 1.50
f Other Intangible asset 12(b) 4.06 6.41 11.40
g Goodwill on Consolidation 54.07 54.07 54.07
h Other non -financial assets 13 232.44 211.69 312.46
Sub Total -Non-Financial Assets 2,822.44 2,720.10 2,710.28
Total Assets 30,256.51 29,876.11 21,186.89
LIABILITIES AND EQUITY
Liabilities
1 Financial Liabilities
a Payables
(l)Trade Payables
(i) total outstanding dues of micro
enterprises and small enterprises 14
3.11
(ii) total outstanding dues of creditors
other than micro enterprises and small 14
enterprises 12,411.80 13,655.46 8,339.73
(II) Other Payables
(i) total outstanding dues of micro
enterprises and small enterprises 14
(ii) total outstanding dues of
creditors other than micro enterprises 14
and small enterprises 5.54 2.89 3.01
Borrowings (Other than Debt
b 15
Securities) 570.81 353.52 803.42
C Other financial liabilities 16 13.77 11.15 2.02
Sub Total -Financial Liabilities 13,005.03 14,023.02 9,148.18
2 Non-Financial Liabilities
a Current tax liabilities (Net) 17 35.05 15.77 7.16
b Deferred tax liabilities (Net) 18 78.70 367.47 71.02
C Provisions 19 166.76 200.03 91.07
d Other non-financial liabilities 20 64.74 121.09 58.03
Sub Total -Non-Financial Liabilities 345.25 704.36 227.28
5103 EQUITY
a Equity Share capital 21 1,575.40 1,575.40 1,575.40
b Other Equity 22 15,233.58 13,478.73 10,170.58
C Non-Controlling Interest 97.25 94.60 65.45
Sub Total -Equity 16,906.23 15,148.73 11,811.43
Total Liabilities And Equity 30,256.51 29,876.11 21,186.89
Significant Accounting Policies and Notes on Financial Statements 1 to 57
As per our report attached For and on behalf of board of directors
For, Dhrumil A. Shah & Co. Upendra T. Shah
Chartered Accountants
FRN : 145163W Chairman
DIN: 00023057
Dhrumil Ashit Shah Tanmay U. Shah CS Preeti U Shah
Proprietor
Membership No. : 166079
Place : Ahmedabad Managing Director/CFO Company Secretary
Date:05/09/2025 DIN: 00023067 ICSI Mem. No. A17463
511Shah Investor's Home Umlted
CIN: U67120GJ1994PLC023Z57
Restated Consolidated Statement Of Profit & Loss For The Year Ended 31 March 2025
(-rln lakhs)
For the period For the period Far the period
Note
Partlculars ••• ended 31 March, ended 31 March, ended 31 March,
2025 2024 2023
Revenue From Operations 23
1. Interest Income l•I 2,503.63 1,578.60 1,141.73
ii. Dividend Income (bl 61.27 74.92 47.98
iii. Rental Income 1, I 10.08 8.94 6.00
Iv. Fees and commission Income (d) 6,759.19 5,843.20 3,932.46
v. Net galn/(loss) on fair value changes I• I 72.02 198.59 (191.44)
vl. Sale of products 1n 35.42 199.34
vll. Sale of services 1,1 21.20 40A8 17.13
viii. Other operating income (h) 2.21 15.10
(I) Total Revenue from operations 9,427.39 7,782.36 5,168.30
(II) Other Income 24 19.12 122.93 64.66
(Ill) Total Income 11+111 9,446.51 7,905.29 5,W.96
Expenses
i. Finance Costs 25 246.08 90.98 31.24
ii. Fees and commission expense 26 3,801.13 3,378.43 2,256.57
111. Impairment on flnancial Instruments 27 (0.87) (1.82) 22.23
iv. Purchases of Stock-In -trade 35.74
Changes in Inventories of finished goods, stock-in
v. -trade and work-in -progress 207.05
vi. Impairment on flnanclal Instruments
vii. Employee Benefits Expenses 28 1,151.50 1,092.19 957.05
viii. Depreciation, amortization and Impairment 29 164.14 144.24 132.02
ix. Others expenses 30 944.31 764.85 638.10
IIVI Total Expenses (IV) 6,306.29 S,504.61 4,244.26
(V) Profit/ (loss) before exceptional items and tax (Ill•
IV) 3,140.22 2,400.68 988.70
{VI) Exceptional items
{VII) Proftt/(loss) before tax (V -VI ) 3,140.22 2,400.68 988.70
(VIII) Tax Expense
(i) current Tax 31 831.30 591.20 257.87
(II) Deferred Tax 31 (28.36) 5.30 (0.92)
(Ill) (Excess)/Short provision for tax relatln1 to
31
prior years {4.28) (1.02) (8.72)
(IX) Profit/ (loss) for the period from continuing
operations(VII -VIII ) 2,341.56 1,805.ZO 740A7
IX) Proftt/lloss) for the period 2,341.56 1,80S.ZO 740.47
(XI) Share of profit from associate (net of taxes) 27.30
(XII) Profit after tax and share In profit of associate 2,341.56 ~805.20 767.77
(XIII) Other Comprehensive Income
(Al (1) Items that wlll not be reclassified to profit
or loss (534.16} 1,984.74 (517.56)
(ii) Income tax relating to items that will not
be reclasslfled to profit or loss 107.64 (295.10) 62.51
Subtotal IA) (426.52) 1,689.64 (455.05)
(B) (I) Items that wlll be reclasslfled to profit or loss 3.11
(11) Income tax relatln1 to Items that will be
reclassified to profit or loss {0.36}
Subtotal (B) 2.75
Other Comprehensive Income (A+ B) (426.52) 1,689.64 (452.30)
Total Comprehensive Income for the period
(XIV) (Xll+XIII) (Comprlslna: Profit (Loss) and other
Comprehensive Income for the period) 1,915.04 3,494.84 315.47
(XV) Net Profit attrlbuhl to :
Owners of parent 2,338.50 1,793.38 763.17
Non-Controlllng Interest 3.06 11.82 4.60
(XVI) Other Comprehensive lncome/(lou) attribute to:
Owners of parent (426.11) 1,672.31 (448.95)
Non-Controlling Interest (0.41) 17.33 {3.35)
(XVII) Total Comprehensive Income attribute to:
(XVll)=(XV)+IXVI)
(XVII) Owners of parent 1,912.39 3,465.69 314.22
(XVII) Non-Controlllng Interest 2.65 29.15 1.25
(XVIII) Eamlnp per equity share
Basic & DIiuted 32 14-84 11.38 4.84
Slsnlflcant Accounting Pallcles and Notes on Flnanclal Statements 1 to 57
As per our report attached For and on behalf of board of directors
For, Dhrumll A. Shah &Co. Upendra T. Shah
Chartered Accountants
FRN : 145163W O\alnnan
DIN: 00023057
Dhrumil Ashit Shah Tanmay u. Shah CS Preeti U Shah
Proprietor
Membership No. : 166079
Place : Ahmedabad Manaaina Director/CFO Company secretary
Date: 05/09/2025 DIN: 00023067 ICSI Mem. No. A17463
512Shah Investor's Home Limited
CIN: U67120GJ1994PLC023257
Consolidated cash Flow Statement for the ~ar ended March 312025
1
('I: in lakhs)
For the year ended For the year ended For the year ended on
Particulars
on 31 March 2025 on 31 March 2024 31 March 2023
A CASH FLOW FROM OPERATING ACTIVITE5
Profit Before Tax 3,140.22 2,400.68 988.70
Add/(less) : Adjustments
Depreciation /amortization 164.14 144.24 132.02
Finance cost 246.08 90.98 31.24
Dividend Income (61.27) (74.92) (47.98)
Impairment on financial instruments (0.87) (1.82) 22.23
Unrealized/realized (gain)/ loss on fair value changes (72.02) (198.59) (75.30)
Profit & Loss on sale of Fixed asset (1.46) 22.63 (17.33)
Operating profit before working capital changes 3,414.82 2,383.20 1,033.58
Adjustments for changes in working capital:
Decrease/increase in Other bank Balance (2,797.44) 2,899.84 (1,519.31)
Decrease/increase in trade and other receivables (907.12) 317.27 120.28
Decrease/increase in Loans given (578.06) 498.00 (617.11)
Decrease/increase in Other Financial Assets 15.33 25.58 1.60
Decrease/increase in Inventories 207.05
Decrease/increase in Other Non Financial Assets (21.04) (51.05) 70.33
Decrease/increase in Trade payables (1,237.90) 5,315.61 1,065.82
Decrease/increase in Other financial liabilities 2.64 8.67 (60.38)
Decrease/increase in Other Non financial liabilities (56.35) 63.06 (18.12)
Decrease/increase in Provisions (58.03) 106.03 (7.29)
Cash Generated from Operations
Direct Tax Paid ( Net of Refunds) (963.07) (546.79) (276.00)
Net cash used In / generated from Operating Activities (3,186.22) 11,019.42 0.45
B CASH FLOW FROM INVEmNG ACTIVITES
Purchase/ Proceeds from sale of Investment (943.14) (62.70) (1,348.07)
Purchase of Fixed Asset (241.40) (164.39) (689.10)
Dividend Income Received 61.27 74.92 48.34
Net cash from Investing Activities (1,123.27) (152.17) (1,988.83)
C CASH FLOW FROM FINANCING ACTIVITES
Proceeds/ Payment from Borrowings 217.29 (449.89) 799.80
Finance Cost (246.08) (90.98) (31.24)
Dividend Paid (157.56) (157.08) (78.77)
Net cash from Financing Activities (186.35) (697.95) 689.79
Net Increase/ ( Decrease ) in cash And cash Equivalents ( (4,495.84) 10,169.30 (1,298.59)
A+B+C)
Cash And Cash Equivalents -Opening Balance 13,006.98 2,837.68 4,136.27
Cash And Cash Equivalents -Closing Balance 8,511.14 13,006.98 2,837.68
Notes:
1 Cash and cash equivalents represents cash and bank balances as per Balance Sheet, intercorporate deposits placed for three
months or lower tenure.
2 Previous year's figures have been regrouped, wherever necessary. As per our report attached
As per our report attached For and on behalf of board of directors
For, Dhrumil A. Shah & Co. Upendra T. Shah
Chartered Accountants
FRN : 145163W Chairman
DIN: 00023057
Dhrumll Ashlt Shah Tanmay U. Shah cs Preetl u Shah
Proprietor
Membership No. : 166079
Place : Ahmedabad Managing Director/CFO Company Secretary
Date: 05/09/2025 DIN: 00023067 ICSI Mem. No. A17463
513Shah Investor's Home Umlted
CN: U67UOG.11994PLC023ZS7
llfflabld Consolldahld Statemant Of Chanps In Equity For The Yur Endlld March 31, 2025
A Equity Share C&pltal
f'ln lakhs)
For thll yaar anded 31 Man:h
Partlailan
2025 2024 2023
Balance at the be1lnnlng of the reporting period 1,575.40 1,575.40 1,575.40
°''" durin the "
Bllanct1 at th• 1111!:!!!!!y l!!rlod 1,575.40 1,575.40 1,575.40
B Other Equity
('l:lnlakllsl
Reserves and surplus
--
RIIIIIM!lfund
u/1 45-IC (11 Of Otho, Capital Non, . c . o. n. t. r. o. l llng
Partk:ulan, Seairttles Retained Comprehensive Redemption Total Other Equity
General Reserve Reserve Bank
Premium Eamlnp Income
Of
lndla Ac.t,. 1.9.3..4 .....
Balanct1 as at April 01, 2024 9,604.53 1,519.52 1,957.40 131.68 13,478.73
Praftt for the p■rlod 2,338.50 2,3 .3 .8 .. .5 .0 3.06
Transfer from Other comprehensive Income 1,128.38 1,121.3g
Transfer during the year 63.26
Dividend Distributed durtngthe year {157.54) (157.54)
Transfer to Statutory Reserve maintained under (63.26)
163.261
section 45-IC of RBI Act, 1934
Items ofth• OCI fortheytiar, net of tax
Adjustment during the year (426.11) 1426.11) IDA1l
Transfer to Retained Eamins {1,128.38) (1,121.381
Bllanct1 11 at Man:h 31, 20ZS 9,6.0..4..5.3. 4,765.60 326.B& 402.91 13L68 15,233.58 9. 7. .. Z. S
, .......
Balance as at April 01, 2023 148.U 341.69 131.68 10,170.58
.....
Praftt for th• p■rlod 1,793.38 1,793.38 11.82
Transfer from Other comprehensive Income 56.60
Transfer during the year 1,000.00 (1,000.00) 21.10 21.10
Dividend Distributed durtngthe year {157.54) 1157.54)
Transfer to Statutory Reserve maintained under (21.10)
121.101
section 45-IC of RBI Act, 1934
Items of th• OCI for the ytiar, net of tax
Adjustment during the year 1,672.31 1,672.:11 17.33
...... .....
Transfer to Retained Eamins (56.60) 156.601
Balanct1 as at March :n, 2024 9,604.53 1,519.52 1.,.9.5.7...4.0 13L68 19,478.73
.....
Balance as at April 01, 2022 7,804.53 480.47 215.00 131.68 9,935.19
Praftt for the p■rlod BOO.Oil 763.17 1,561.17 4.60
Transfer from other comprehensive Income 512.81 512.11 5.74
Transfer during the year (800.00) 29.50 1770.50)
Dividend Distributed durtngthe year {78.n) (71.771
Transfer to Statutory Reserve maintained under (29.50)
129.50)
section 45-IC of RBI Act, 1934
1tam1 of the oa for the yaar, net of tax
Adjustment during the year ........ ...... (448.95) (448,95) . (3. .. 35. )
Transfer to Retained Eamins (512.81) 1512.81) (5.74)
Balanct1 as at March 31, 2023 B48.18 34Ui9 13L68 10,170.58
Gl!lnenl RIIIIIMI
General reserve represents appropriation of surplus In the profit and loss account and Is available for distribution to shareholders as dividend.
Rltalnad Eamlnp
.... .......
Surp.lu..s. .in, profit or loss account (Retained Earnings) represents surplu5/aa:umulated profit of the company and Is available for distribution to shareholders as dividend •
Reserve fund ls created as per the terms of section 45-1q1) of the Reserve Bank of Ind la Act, 1934 as a statutory reserve as 20% of the profit after tax.
capital Redemption Reserve
The capital redemption reserve Is created to be utlllsed towards redemption of preference shares and It also Includes addition arlsln1 on account of buyback of shares. The reserve will be utlllsed
In accordance with provision of the Act.
Other c:omprehenslve lnc:ome
The Group has elected to recognize changes In the falrvalue of certain Investments In equity securttles In other comprehensive Income. These changes are accumulated within the Equity
Instruments through Other Comprehensive Income within equity. The company transfers amounts from this reserve to retained earnings when the relevant equity securities are dereco1nlzed.
514Shah Investor's Home Limited
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Material accounting Policies
lA. Corporate Information
Shah Investor's Home Limited ("SIHL" or 'the Holding Company') is a public limited company and incorporated
under the provisions of Companies Act. The Company domiciled in India and its registered office 810, X-Change
Plaza, DSCCSL (53E), Road SE, Block 53, Zone 5, Gift City, Gandhinagar, Gujarat-382355 and correspondence
office at SIHL House, Opp. Ambawadi Jain Temple, Nehrunagar Cross Road, Ahmedabad, Gujarat -380015.
Shah Investor's Home Limited, its subsidiaries are engaged in broking of equity, derivatives and mutual fund,
wealth management services, distribution of financial products, proprietary investments and other activities
in financial services.
These restated consolidated financial statements contain financial information of the Group and were
authorized for issue by the Board of Directors on September 5, 2025.
Information on the Group's structure provided in note 52.
18. Business Combination under Common Control
A common control business combination, involving entities or businesses in which all of the combining entities
or businesses are ultimately controlled by the same party or parties both before and after the business
combination and where the control is not transitory, is accounted for in accordance with Appendix C to Ind AS
103 1Business Combinations1
•
Business combinations involving entities or businesses under common control are accounted for using the
pooling of interest method as follows:
► The assets and liabilities of the combining entities are refiected at their carrying amounts.
► No adjustments are made to refiect fair values, or recognize new assets or liabilities. Adjustments are made
only to harmonize significant accounting policies.
► The financial information in the financial statements in respect of prior periods are restated as if the
business combination had occurred from the beginning of the preceding period in the financial statements.
► The identity of the reserves are preserved and appear in the financial statements of the transferee in the
same form in which they appeared in the financial statements of the transferor.
The difference, if any, between the amounts recorded as share capital issued plus any additional consideration
in the form of cash or other assets and the amount of share capital of the transferor is transferred to capital
reserve and is presented separately from other capital reserves with disclosure of its nature and purpose in
the notes.
lC. Business Combination under Acquisition method
The Group applies the acquisition method in accounting for business combinations for the businesses which
are not under common control. The cost of an acquisition is measured as the aggregate of the consideration
transferred measured at acquisition date fair value and the amount of any non-controlling interests in the
acquiree. For each business combination, the Group elects whether to measure the non-controlling interests
in the acquiree at fair value or at the proportionate share of the acquiree's identifiable net assets. Acquisition
related costs are expensed as incurred.
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At the acquisition date, the identifiable assets acquired and the liabilities assumed are recognised at their
acquisition date fair values. For this purpose, the liabilities assumed include contingent liabilities representing
present obligation and they are measured at their acquisition fair values irrespective of the fact that outflow
of resources embodying economic benefits is not probable. However, the following assets and liabilities
acquired in a business combination are measured at the basis indicated below:
A) Deferred tax assets or liabilities and the assets or liabilities related to employee benefit arrangements are
recognised and measured in accordance with Ind AS 12 'Income Tax' and Ind AS 19 'Employee Benefits'
respectively.
B) Potential tax effects of temporary differences and carry forwards of an acquiree that exist at the acquisition
date or arise as a result of the acquisition are accounted in accordance with Ind AS 12.
C) Reacquired rights are measured at a value determined on the basis of the remaining contractual term of
the related contract. Such valuation does not consider potential renewal of the reacquired right.
Any contingent consideration to be transferred by the acquirer is recognised at fair value at the acquisition
date. Contingent consideration classified as an asset or liability that is a financial instrument and within
the scope of Ind AS 109 'Financial Instruments', is measured at fair value with changes in fair value
recognised in profit or loss. If the contingent consideration is not within the scope of Ind AS 109, it is
measured in accordance with the appropriate Ind AS.
Contingent consideration that is classified as equity is not re-measured at subsequent reporting dates and
its subsequent settlement is accounted for within equity.
When the Group acquires a business, it assesses the financial assets and liabilities assumed for appropriate
classification and designation in accordance with the contractual terms, economic circumstances and
pertinent conditions as at the acquisition date.
If the business combination is achieved in stages, any previously held equity interest is re-measured at its
acquisition date fair value and any resulting gain or loss is recognised in profit or loss or OCI, as appropriate.
2A. Material accounting policies
The principal accounting policies applied in the preparation of these financial statements are set out below.
Accounting policies have been consistently applied except where a newly issued accounting standard is initially
adopted or a revision to the existing accounting standard requires a change in the accounting policy hitherto
in use.
2.1 Basis of preparation
(i) Compliance with Ind AS
The restated consolidated financial statements of the Group comply in all material aspects with
Indian Accounting Standards (Ind AS) notified under Section 133 of the Companies Act,2013 ("the
Act") read with Companies (Indian Accounting Standarads) Rules, 2015 as amended and other
relevant provisions of the Act.
The restated consolidated financial statements up to and including the year ended 31 March 2024
were prepared in accordance with the accounting standards notified under companies (Accounting
Standard) Rules,2006 (as amended) under the Act read with Rule 7 of the Companies (Accounts)
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Rules, 2014 (as amended), and other generally accepted accounting principles in India (collectively
referred to as "Indian GAAP" or "Previous GAAP")
These restated consolidated financial statements are the first financial statements of the Group
under Ind AS. Refer
55 for an explanation of how the transition from previous GAAP to Ind AS has affected Group's
financial position, financial performance and cash fiows.
The transition to Ind AS has been carried out in accordance with Ind AS 101 First Time Adoption of
Indian Accounting Standards. Accordingly, the impact of transition has been recorded in the
opening reserves as at 1 April 2022.
Accounting policies have been applied consistently over all the periods presented in these restated
consolidated financial statements, except where the Group has applied certain accounting policies
and exemptions upon transition to Ind AS.
(ii) Historical cost convention
The restated consolidated financial statements have been prepared on a historical cost basis,
except for the following:
► Financial instruments are measured at fair value through Profit and Loss or Other
Comprehensive Income,
► Defined benefit plans - plan assets measured at fair value; and
(iii) Preparation of restated consolidated financial statements
The Holding Company is covered in the definition of Non-Banking Financial Group as defined in
Companies (Indian Accounting Standards) (Amendment) Rules, 2016. As per the format prescribed
under Division Ill of Schedule Ill to the Companies Act, 2013 on 11 October 2018 (as amended),
the Holding Company presents the restated Balance Sheet, the restated Statement of Profit and
Loss and the restated Statement of Changes in Equity in the order of liquidity. A maturity analysis
of recovery or settlement of assets and liabilities within 12 months after the reporting date and
more than 12 months after the reporting date is presented in note 46.
(iv) Use of estimates and judgments
The preparation of restated consolidated financial statements in conformity with Ind AS requires
management to make estimates, judgments, and assumptions that affect the application of
accounting policies and the reported amounts of assets and liabilities (including contingent
liabilities) and disclosures as of the date of restated consolidated financial statements and the
reported amounts of revenue and expenses for the reporting period. Actual results could differ
from these estimates. Accounting estimates and underlying assumptions are reviewed on an
ongoing basis and could change from period to period. Appropriate changes in estimates are
recognized in the period in which the Company becomes aware of the changes in circumstances
surrounding the estimates. Any revisions to accounting estimates are recognized prospectively in
the period in which the estimate is revised and future periods.
(v) Determining whether an arrangement contains a lease
The Company evaluates if an arrangement qualifies to be a lease as per the requirements of Ind
AS 116. Identification of a lease requires significant judgment. The Company uses significant
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judgment in assessing the lease term (including anticipated renewals) and the applicable discount
rate. The Company determines the lease term as the non-cancellable period of a lease, together
with both periods covered by an option to extend the lease if the Company is reasonably certain
to exercise that option; and periods covered by an option to terminate the lease if the Company is
reasonably certain not to exercise that option.
2.2 Principles of consolidation and equity accounting
(i) Subsidiaries
The restated consolidated financial statement has comprised restated financial statements of the
Company and its subsidiaries. Subsidiaries are all the entities (including structured entities) over
which the Group has control. The Group controls an entity when the Group is exposed to, or has
rights to, variable returns from its involvement with the entity and has the ability to affect those
returns through its power to direct the relevant activities of the entity. Subsidiaries are fully
consolidated from the date on which control is transferred to the Group. They are deconsolidated
from the date that control ceases.
The acquisition method of accounting is used to account for business combinations by the Group.
The Group combines the financial statements of the Holding Company and its subsidiaries line by
line adding together like items of assets, liabilities, equity, income and expenses. lntercompany
transactions, balances and unrealized gains on transactions within the Group are eliminated.
Unrealized losses are also eliminated unless the transaction provides evidence of an impairment
of the transferred asset. Accounting policies of subsidiaries have been changed where necessary
to ensure consistency with the policies adopted by the Group.
Non-controlling interests in the results and equity of subsidiaries are shown separately in the
consolidated statement of profit or loss, consolidated statement of changes in equity and balance
sheet respectively. Statement of Profit and Loss including Other Comprehensive Income (OCI) is
attributable to the equity holders of the Holding Company and to the non-controlling interest basis
the respective ownership interest and such balance is attributed even if this results in controlling
interest is having a deficit balance.
(ii) Equity method
Under the equity method of accounting, the investments are initially recognized at cost and
adjusted thereafter to recognize the Group's share of the post-acquisition profits or losses of the
investee in profit or loss, and the Group's share of other comprehensive income of the investee in
other comprehensive income.
When the Group's share of losses in an equity-accounted investment equals or exceeds its interest
in the entity, including any other unsecured long-term receivables, the Group does not recognize
further losses, unless it has incurred obligations or made payments on behalf of the other entity.
Unrealized gains on transactions between the Group companies are eliminated to the extent of
the Group's interest in these entities. Unrealized losses are also eliminated unless the transaction
provides evidence of an impairment of the asset transferred. Accounting policies of equity
accounted investees have been changed where necessary to ensure consistency with the policies
adopted by the Group.
(iii) Changes in ownership interests
The Group treats transactions with non-controlling interests that do not result in a loss of control
as transactions with equity owners of the Group. A change in ownership interest results in an
adjustment between the carrying amounts of the controlling and non-controlling interests to
518Shah Investor's Home Limited
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refiect their relative interests in the subsidiary. Any difference between the amount of the
adjustment to non-controlling interests and any consideration paid or received is recognized
within equity.
When the Group ceases to consolidate or equity account for an investment because of a loss of
control or joint control, any retained interest in the entity is re-measured to its fair value with the
change in carrying amount recognized in profit or loss. This fair value becomes the initial carrying
-amount for the purposes of subsequently accounting for the retained interest as an associate or
financial asset. In addition, any amounts previously recognized in other comprehensive income in
respect of that entity are accounted for as if the Group had directly disposed of the related assets
or liabilities. This may mean that amounts previously expected credit recognized in other
comprehensive income are reclassified to profit or loss.
If the ownership interest in an associate is reduced but joint control or significant infiuence is
retained, only a proportionate share of the amounts previously recognized in other comprehensive
income are reclassified to profit or loss where appropriate.
2.3 Revenue Recognition
The Group recognizes revenue from contracts with customers based on a five-step model as set out in Ind
AS llS, Revenue from Contracts with Customers, to determine when to recognize revenue and at what
amount. Revenue is measured based on the consideration specified in the contract with a customer.
Revenue from contracts with customers is recognised when services are provided and it is highly probable
that a significant reversal of revenue is not expected to occur.
Revenue is measured at fair value of the consideration received or receivable. Revenue is recognised when
(or as) the Group satisfies a performance obligation by transferring a promised service (i.e. an asset) to a
customer. An asset is transferred when (or as) the customer obtains control of that asset.
When (or as) a performance obligation is satisfied, the Group recognizes as revenue the amount of the
transaction price (excluding estimates of variable consideration) that is allocated to that performance
obligation.
The Group applies the five-step approach for recognition of revenue:
► Identification of contract(s) with customers; A contract is defined as an agreement between
two or more parties that creates enforceable rights and obligations and sets out the criteria
for every contract that must be met.
► Identification of the separate performance obligations in the contract; A performance
obligation is a promise in a contract with a customer to transfer a good or service to the
customer.
► Determination of transaction price; The transaction price is the amount of consideration to
which the Company expects to be entitled in exchange for transferring promised goods or
services to a customer, excluding amounts collected on behalf of third parties.
► Allocation of transaction price to the separate performance obligations: For a contract that has
more than one performance obligation, the Company allocates the transaction price to each
performance obligation in an amount that depicts the amount of consideration to which the
Company expects to be entitled in exchange for satisfying each performance obligation.; and
► Recognition of revenue when (or as) each performance obligation is satisfied.
(i) Brokerage fee income
It is recognised on trade date basis in accordance with the terms of contract and is exclusive of goods and
service tax and securities transaction tax (STT) wherever applicable.
519Shah Investor's Home Limited
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(ii) Interest income
Interest income is recognized on accrual basis in restated statement of profit and loss for all financial
instruments measured at amortized cost.
(iii) Dividend income
Dividend income is recognized in the restated statement of profit and loss on the date that the Group's
right to receive payment is established, it is probable that the economic benefits associated with the
dividend will fiow to the entity and the amount of dividend can be reliably measured. This is generally
when the shareholders approve the dividend.
(iv) Net gain on fair value changes
The Company designates certain financial assets for subsequent measurement at fair value through profit
or loss (FVTPL) or fair value through other comprehensive income (FVOCI). The Company recognizes gains
on fair value change of financial assets measured at FVTPL and realized gains on de-recognition of financial
asset measured at FVTPL and FVOCI on net basis in profit or loss.
(v) Depository services income
Revenue from depository services on account of annual maintenance charges have been accounted over
the period of the performance obligation.
Revenue from depository services on account of transaction charges is recognized point in time when the
performance obligation is satisfied.
(vi) Delayed payment charges
Interest is earned on delayed payments from customers and is recognised on a time proportion basis taking
into account the amount outstanding from customers and the rates applicable.
2.4 Income Tax
The income tax expense or credit for the period is the tax payable on the current period's taxable income
based on the applicable income tax rate adjusted by changes in deferred tax assets and liabilities
attributable to temporary differences and to unused tax losses. Current and deferred tax is recognized in
restated statement of profit and loss, except to the extent that it relates to items recognized in other
comprehensive income or directly in equity. In this case, the tax is also recognized in other comprehensive
income or directly in equity, respectively
Current Tax
Current tax is measured at the amount of tax expected to be payable on the taxable income for the year
as determined in accordance with the provisions of the Income Tax Act, 1961. Current tax assets and
current tax liabilities are off set when there is a legally enforceable right to set off the recognized amounts
and there is an intention to settle the asset and the liability on a net basis.
Deferred Tax
Deferred tax is provided in full, using the liability method, on temporary differences arising between the
tax bases of assets and liabilities and their carrying amounts in the consolidated financial statements.
However, deferred tax liabilities are not recognized if they arise from the initial recognition of goodwill.
Deferred tax is also not accounted for, if it arises from initial recognition of an asset or liability in a
transaction other than a business combination that at the time of the transaction affects neither
520Shah Investor's Home Limited
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accounting profit nor taxable profit (tax loss). Deferred tax is determined using tax rates (and laws) that
have been enacted or substantially enacted by the end of the reporting period and are expected to apply
when the related deferred income tax asset is realized or the deferred income tax liability is settled.
Deferred tax assets are recognized for all deductible temporary differences and unused tax losses only if it
is probable that future taxable amounts will be available to utilize those temporary differences and losses.
Deferred tax liabilities are not recognized for temporary differences between the carrying amount and tax
bases of investments in subsidiaries and associates where the Company is able to control the timing of the
reversal of the temporary differences and it is probable that the differences will not reverse in the
foreseeable future.
Deferred tax assets and liabilities are offset when there is a legally enforceable right to offset current tax
assets and liabilities and when the deferred tax balances relate to the same taxation authority.
2.5 Leases
For any new contracts entered into on or after 1 April 2022, the Company considers whether a contract is,
or contains a lease. A lease is defined as 'a contract, or part of a contract, that conveys the right to use an
asset (the underlying asset) for a period of time in exchange for consideration'. The Company assess
whether it has the right to direct 'how and for what purpose' the asset is used throughout the period of
use.
Measurement and recognition of leases as a lessee
The Company has adopted Ind AS 116 "Leases" using the cumulative catch-up approach. Company has
recognised Right of Use assets as at 1 April 2022 for leases previously classified as operating leases and
measured at an amount equal to lease liability (adjusted for related prepayments/ accruals). The Company
has discounted lease payments using the incremental borrowing rate for measuring the lease liability.
The Company recognises right-of-use assets at the commencement date of the lease (i.e., the date the
underlying asset is available for use). Right-of-use assets are measured at cost, less any accumulated
depreciation and impairment losses, and adjusted for any re-measurement of lease liabilities.
The Company depreciates the right-of-use assets on a straight-line basis from the lease commencement
date to the earlier of the end of the useful life of the right-of-use asset or the end of the lease term. The
Company also assesses the right-of-use asset for impairment when such indicators exist.
Lease payments included in the measurement of the lease liability are made up of fixed payments
(including in substance fixed), variable payments based on an index or rate, amounts expected to be
payable under a residual value guarantee and payments arising from options reasonably certain to be
exercised.
Subsequent to initial measurement, the liability will be reduced for payments made and increased for
interest. It is re-measured to refiect any reassessment or modification, or if there are changes in in
substance fixed payments.
When the lease liability is re-measured, the corresponding adjustment is refiected in the right-of-use asset,
or profit and loss if the right-of-use asset is already reduced to zero.
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The Company has elected to account for short-term leases and leases of low-value assets using the
practical expedients. Instead of recognising a right-of-use asset and lease liability, the payments in relation
to these are recognised as an expense in profit or loss on a straight-line basis over the lease term.
When the Company revises its estimate of the term of any lease, it adjusts the carrying amount of the
lease liability to refiect the payments to make over the revised term, which are discounted using a revised
discount rate. The carrying value of lease liabilities is similarly revised when the variable element of future
lease payments dependent on a rate or index is revised, except the discount rate remains unchanged. In
both cases an equivalent adjustment is made to the carrying value of the right-of-use asset, with the
revised carrying amount being amortised over the remaining (revised) lease term. If the carrying amount
of the right-of-use asset is adjusted to zero, any further reduction is recognised in statement of profit and
loss.
For contracts that both convey a right to the Company to use an identified asset and require services to be
provided to the Company by the lessor, the Company has elected to account for the entire contract as a
lease, i.e. it does not allocate any amount of the contractual payments to, and account separately for, any
services provided by the supplier as part of the contract.
2.6 Cash and cash equivalents
For the purpose of presentation in the statement of cash fiows, cash and cash equivalents includes cash
on hand, deposits held at call with financial institutions, other short-term, highly liquid investments with
original maturities of three months or less that are readily convertible to known amounts of cash and which
are subject to an insignificant risk of changes in value. Outstanding bank overdrafts are not considered
integral part of the Company's cash management.
2.7 Financial instruments
Initial recognition and measurement:
Financial assets and financial liabilities are recognized when the entity becomes a party to the contractual
provisions of the instrument. Regular way purchases and sales of financial assets are recognized on trade
date, the date on which the Company commits to purchase or sell the asset.
At initial recognition, the Group except for trade receivables, measures the financial asset or financial
liability at its fair value plus or minus, in the case of a financial asset or financial liability not at fair value
through profit or loss, transaction costs that are directly attributable to the acquisition or issue of the
financial asset or financial liability, transaction costs that are incremental and directly attributable to the
acquisition or issue of the financial asset or financial liability, such as fees and commissions. Transaction
costs of financial assets and financial liabilities carried at fair value through profit or loss are expensed in
Statement of profit and loss. Immediately after initial recognition, an expected credit loss allowance (ECL)
is recognized for financial assets measured at amortized cost.
When the fair value of financial assets and liabilities differs from the transaction price on initial recognition,
the entity recognizes the difference as follows:
a) When the fair value is evidenced by a quoted price in an active market for an identical asset or liability
(i.e. a Level 1 input) or based on a valuation technique that uses only data from observable markets,
the difference is recognized as a gain or loss.
b) In all other cases, the difference is deferred and the timing of recognition of deferred day one profit or
loss is determined individually. It is either amortized over the life of the instrument, deferred until the
instrument's fair value can be determined using market observable inputs, or realized through
settlement.
522Shah Investor's Home Limited
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When the Group revises the estimates of future cash fiows, the carrying amount of the respective financial
assets or financial liability is adjusted to refiect the new estimate discounted using the original effective
interest rate. Any changes are recognized in Statement of profit and loss.
Fair value of financial instruments:
the Group's assets and liabilities are measured at fair value for financial reporting purpose. Fair value is the
price that would be received to sell an asset or paid to transfer a liability in an orderly transaction between
market participants at the measurement date regardless of whether that price is directly observable or
estimated using another valuation technique.
Fair value measurements under Ind AS are categorized into Level 1, 2, or 3 based on the degree to which
the inputs to the fair value measurement are observable and the significance of the inputs to the fair value
measurement in its entirety, which are described as follows:
► Level 1: quoted prices (unadjusted) in active markets for identical assets or liabilities that the
Company can access at measurement date
► Level 2: inputs other than quoted prices included in Level 1 that are observable for the asset
or liability, either directly or indirectly; and
► Level 3: inputs for the asset or liability that are not based on observable market data
(unobservable inputs) that the Company can access at measurement date.
Information about the valuation techniques and inputs used in determining the fair value of various assets
and liabilities are disclosed in note 43.
Financial assets
(i) Classification and subsequent measurement:
The Company has applied Ind AS 109 and classifies its financial assets in the following measurement
categories:
► Fair value through profit or loss (FVTPL)
► Fair value through other comprehensive income (FVOCI); or
► Amortised cost.
Classification and subsequent measurement of financial assets depends on:
► The Company's business model for managing the asset; and
► The cash fiow characteristics of the asset.
1. Financial assets carried at:
(A) Amortised cost
Financial assets at amortized cost are subsequently measured at amortized cost using effective
interest method. The amortized cost is reduced by impairment losses. Interest income, foreign
exchange gains and losses and impairment are recognized in profit or loss. Any gain and loss on
de-recognition are recognized in profit or loss.
(B) Fair value through other comprehensive income
Financial assets that are held within a business model whose objective is achieved by both, selling
financial assets and collecting contractual cash fiows that are solely payments of principal and
interest, are subsequently measured at fair value through other comprehensive income. Fair value
523Shah Investor's Home Limited
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movements are recognized in the other comprehensive income (OCI). Interest income measured
using the EIR method and impairment losses, if any are recognised in the Statement of Profit and
Loss. On derecognition, cumulative gain or loss previously recognised in OCI is reclassified from
the equity to 'other income' in the Statement of Profit and Loss.
(C) Fair value through profit or loss
A financial asset not classified as either amortised cost or FVOCI, is classified as FVTPL. Such
financial assets are measured at fair value with all changes in fair value, including interest income
and dividend income if any, recognised as 'other income' in the Statement of Profit and Loss.
2. Equity instruments
Equity instruments are instruments that meet the definition of equity from the issuer's
perspective; that is, instruments that do not contain a contractual obligation to pay and that
evidence a residual interest in the issuer's net assets.
All investments in equity instruments classified under financial assets are initially measured at fair
value, the Group may, on initial recognition, irrevocably elect to measure the same either at FVOCI
or FVTPL. The Group makes such election on an instrument-by-instrument basis. Fair value changes
on an equity instrument is recognised as revenue from operations in the Statement of Profit and
Loss unless the Group has elected to measure such instrument at FVOCI. Fair value changes
excluding dividends, on an equity instrument measured at FVOCI are recognized in OCI. Amounts
recognised in OCI are not subsequently reclassified to the Statement of Profit and Loss. Dividend
income on the investments in equity instruments are recognised as 'Revenue from operations' in
the statement of Profit and Loss.
3. Investments in mutual funds
Investments in mutual funds are measured at fair value through profit and loss (FVTPL).
4. Debt Instrument
Subsequent measurement of debt instruments depends on the Group's business model for
managing the asset and the cash fiow characteristics of the asset. There are three measurement
categories into which the Group has classified its debt instruments:
Amortised cost: Assets that are held for collection of contractual cash fiows and where the
contractual terms give rise on specified dates to cash fiows that represent solely payments of
principal and interest, are measured at amortised cost. A gain or loss on a debt investment
that is subsequently measured at amortised cost is recognised in profit or loss when the asset
is derecognized or impaired.
Fair value through other comprehensive income (FVTOCI): Assets that are held for collection
of contractual cash fiows and for selling the financial assets, where the assets' cash fiow
represent solely payments of principal and interest, are measured at fair value through other
comprehensive income (FVTOCI). Movements in the carrying amount are taken through OCI,
except for recognition of impairment gains or losses, interest revenue and foreign exchange
gains and losses which are recognised in profit & loss in the same manner as for financial
assets measured at amortised cost. The remaining fair value changes are recognised in OCI.
524Shah Investor's Home Limited
CIN:U67120GJ1994PLC023257
Fair value through profit or loss (FVTPL): Assets that do not meet the criteria for amortised
cost, are measured at fair value through profit or loss. A gain or loss on a debt investment that
is subsequently measured at fair value through profit or loss is recognised in profit or loss and
presented net in the statement of profit and loss within other income in the period in which
it arises. Interest income from these financial assets is included in other income.
(ii) Impairment
The Group recognizes impairment allowances using Expected Credit Losses ("ECL") method on all the
financial assets that are not measured at Fair value through profit or loss (FVTPL):
ECL are probability-weighted estimate of credit losses. They are measured as follows:
► Financials assets that are not credit impaired - as the present value of all cash shortfalls that
are possible within 12 months after the reporting date.
► Financials assets with significant increase in credit risk - as the present value of all cash
shortfalls that result from all possible default events over the expected life of the financial
assets.
► Financials assets that are credit impaired - as the difference between the gross carrying
amount and the present value of estimated cash fiows.
Financial assets are written off/fully provided for when there is no reasonable of recovering
financial assets in its entirety or a portion thereof.
However, financial assets that are written off could still be subject to enforcement activities under
the Group's recovery procedures, taking into account legal advice where appropriate. Any
recoveries made are recognised in the restated statement of Profit and Loss.
(iii) Derecognition
A financial asset is derecognised only when:
The Group has transferred the rights to receive cash fiows from the financial asset or retains the
contractual rights to receive the cash fiows of the financial asset, but assumes a contractual
obligation to pay the cash fiows to one or more recipients.
Where the Group has transferred an asset, the Group evaluates whether it has transferred
substantially all risks and rewards of ownership of the financial asset. In such cases, the financial
asset is derecognised. Where the entity has not transferred substantially all risks and rewards of
ownership of the financial asset, the financial asset is not derecognised.
Where the Group has neither transferred a financial asset nor retains substantially all risks and
rewards of ownership of the financial asset, the financial asset is derecognised if the Group has not
retained control of the financial asset. Where the Group retains control of the financial asset, the
asset is continued to be recognised to the extent of continuing involvement in the financial asset.
Transfer of loans through assignment transaction can be made only after continuing involvement in
loans i.e retaining a minimum specific percentage of loan but without retaining any substantial risk
and reward in the loan assigned. The assigned portion of loans is derecognized and gains/losses are
accounted for, only if the Company transfers substantially all risks and rewards specified in the
underlying assigned loan contracts. Gain/loss arising on such assignment transactions is recorded
upfront in the Statement of Profit and Loss and the corresponding loan is derecognized from the
Balance Sheet immediately. Further, if the transfer of loan qualifies for derecognition, entire interest
525Shah Investor's Home Limited
CIN:U67120GJ1994PLC023257
spread at its present value (discounted over the life of the asset) is recognized on the date of
derecognition itself as interest strip receivable (interest strip on assignment) and correspondingly
presented as gain/loss on de recognition of financial asset.
Financial liabilities
(i) Initial recognition and measurement
All financial liabilities are recognised when the Company becomes a party to the contractual provisions
of the financial instrument and are measured initially at fair value adjusted for transaction costs.
(ii) Subsequent measurement
Financial liabilities are subsequently measured at amortised cost using the EIR method. Financial
liabilities carried at fair value through profit or loss is measured at fair value with all changes in fair
value recognised in the Statement of Profit and Loss.
(iii) De recognition
A financial liability is derecognised when the obligation specified in the contract is discharged,
cancelled or expires.
2.8 Property, plant and equipment
Property, plant and equipment are stated at cost of acquisition less accumulated depreciation except in
the case of land which is stated at cost. Cost includes expenditure that is directly attributable to the
acquisition and installation of the assets.
Subsequent costs are included in the asset's carrying amount or recognized as a separate asset, as
appropriate, only when it is probable that future economic benefits associated with the item will fiow to
the Company and the cost of the item can be measured reliably. The carrying amount of any component
accounted for as a separate asset is derecognized when replaced. All other repairs and maintenance are
charged to Statement of profit and loss during the reporting period in which they are incurred.
Advances paid towards the acquisition of property, plant and equipment outstanding at each balance sheet
date is classified as capital advances under other non-financial assets and the cost of assets not put to use
before such date are disclosed under 'Capital work-in progress'.
Transition to Ind AS
On transition to lndAS, the Company has elected to continue with the carrying value of all of its property,
plant and equipment recognized as at April 01, 2022 measured as per the previous GAAP and use that
carrying value as the deemed cost of the property, plant and equipment.
Depreciation methods, estimated useful lives and residual value
Property, plant and equipment are stated at cost, less accumulated depreciation and impairment, if any.
The Company depreciates property, plant and equipment over their estimated useful lives on written down
value method. The estimated useful lives of assets are as follows:
Assets Category Useful Life
(a) Property, plants & equipment:
(i) Building 60 Years
(ii)Furniture and Fixture 10 Years
(iii)Vehicles (Two Wheelers) 10 Years
526Shah Investor's Home Limited
CIN:U67120GJ1994PLC023257
(iv)Vehicles (Four Wheelers) 8 Years
(v)Office Equipment 5 Years
(vi)Electrical Installations 10 Years
(b)Leasehold Property Amortized over the
lease period based on
straight line method
The useful lives for these assets is in compliance with the useful lives as indicated under Part C of Schedule
II of the Companies Act, 2013.
The useful lives, residual values of each part of tangible and the depreciation method are reviewed at the
end of each financial year. If any of these expectations differ from previous estimates, such change is
accounted for as a change in an accounting estimate.
De recognition:
The carrying amount of an item of property, plant and equipment is derecognized on disposal or when no
future economic benefits are expected from its use or disposal. Gains and losses on disposals are
determined by comparing proceeds with carrying amount and are recognized in the restated statement of
profit and loss when the asset is derecognized.
2.9 Intangible assets
Measurement at recognition:
Intangible assets are recognized where it is probable that the future economic benefit attributable to the
assets will fiow to the Company and its cost can be reliably measured. Intangible assets are stated at cost
of acquisition less accumulated amortization and impairment, if any.
Transition to Ind AS:
On transition to Ind AS, the Company has elected to continue with the carrying value of all of intangible
assets (including Goodwill) recognized as at April 01, 2022 measured as per the previous GAAP and use
that carrying value as the deemed cost of intangible assets. Goodwill has not been amortized after
transition to Ind AS since it has an indefinite useful life but tested for impairment at the year end.
Expenditure incurred on acquisition/development of intangible assets which are not put/ready to use at
the reporting date is disclosed under intangible assets under development. The Company amortizes
intangible assets on a straight-line basis over the four years commencing from the month in which the
asset is first put to use. The Company provides pro-rata amortization from the day the asset is put to use.
Assets Useful life
Computer Software 4 Years
The amortization period and the amortization method for an intangible asset with infinite useful life is
reviewed at the end of each financial year. If any of these expectations differ from previous estimates, such
change is accounted for as a change in an accounting estimate.
De recognition:
The carrying amount of an intangible asset is derecognized on disposal or when no future economic
benefits are expected from its use or disposal. Gains and losses on disposals are determined by comparing
proceeds with carrying amount and are recognized in the statement of profit and loss when the asset is
derecognized.
527Shah Investor's Home Limited
CIN:U67120GJ1994PLC023257
2.10 Impairment of non-financial assets
At each reportng date, the Group assesses whether there is any indication based on internal/external
factors, that an asset may be impaired. If any such indication exists, the Group estimates the recoverable
amount of the asset. The recoverable amount of asset is the higher of its fair value or value in use. Value
in use is based on the estimated future cash fiows, discounted to their present value using a pre-tax
discount rate that refiects the current market assessment of time value of money and the risks specific to
it. If such recoverable amount of the asset or the recoverable amount of the cash generating unit to which
the asset belongs is less than its carrying amount, the carrying amount is reduced to its recoverable
amount and the reduction is treated as an impairment loss and is recognised in the statement of profit and
loss. All assets (except goodwill) are subsequently reassessed for indications that an impairment loss
previously recognised may no longer exist. An Impairment loss is reversed if there has been a change in
estimates used to determine the recoverable amount. Such a reversal is made only to the extent that the
assets carrying amount would have been determined, net of depreciation or amortzation, had no
impairment loss been recognised.
2.11 Expected credit loss (ECL) model:
The Company applies the ECL model in accordance with Ind AS 109 for recognising impairment loss on
financial assets. The ECL allowance is based on the credit losses expected to arise from all possible default
events over the expected life of the financial asset ('lifetime ECL'), unless there has been no significant
increase in credit risk since origination, in which case, the allowance is based on the 12-month ECL. The
12-month ECL is a porton of the lifetime ECL which results from default events that are possible within 12
months after the reportng date.
ECL is calculated on a collective basis, considering the retail nature of the underlying portfolio of financial
assets.
The impairment methodology applied depends on whether there has been a significant increase in credit
risk. When determining whether the risk of default on a financial asset has increased significantly since
initial recognition, the Company considers reasonable and supportable information that is relevant and
available without undue cost or effort. This includes both quantitative and qualitative information and
analysis based on a provision matrix which takes into account the Company's historical credit loss
experience, current economic conditions, forward looking information and scenario analysis.
The expected credit loss is a product of exposure at default ('EAD'), probability of default ('PD') and loss
given default ('LGD'). The Company has devised an internal model to evaluate the PD and LGD based on
the parameters set out in Ind AS 109. Accordingly, the financial assets have been segmented into three
stages based on the risk profiles. The three stages refiect the general pattern of credit deterioration of a
financial asset. The company categorises financial assets at the reportng date into stages based on the
days past due
('DPD') status as under:
Stage 1: Trade receivable for which credit risk has not increased significantly and that are
also not credit impaired
Stage 2: Trade receivable for which credit risk has increased significantly but not credit
impaired
528Shah Investor's Home Limited
CIN:U67120GJ1994PLC023257
Stage 3: Trade receivable for which credit risk has increased significantly and are credit
impaired
LGD is an estimate of loss from a transaction given that a default occurs. PD is defined as the probability
of whether the borrowers will default on their obligations in the future. For assets which are in Stage 1, a
12-month PD is required. For Stage 2 assets a lifetime PD is required while Stage 3 assets are considered
to have a 100% PD. EAD represents the expected exposure in the event of a default and is the gross carrying
amount in case of the financial assets held by the Company.
The Company incorporates forward looking information into both assessments of whether the credit risk
of an instrument has increased significantly since its initial recognition and its measurement of ECL. Based
on the consideration of external actual and forecast information, the Company forms a 'base case' view of
the future direction of relevant economic variables. This process involves developing two or more
additional economic scenarios and considering the relative probabilities of each outcome. The base case
represents a most likely outcome while the other scenarios represent more optimistic and more pessimistic
outcomes.
The measurement of impairment losses across all categories of financial assets requires judgement, in
particular, the estimation of the amount and timing of future cash fiows and collateral values when
determining impairment losses and the assessment of a significant increase in credit risk. These estimates
are driven by a number of factors, changes in which can result in different levels of allowances. The
Company's ECL calculations are outputs of complex models with a number of underlying assumptions
regarding the choice of variable inputs and their interdependencies. The inputs and models used for
calculating ECLs may not always capture all characteristics of the market at the date of the financial
statements. The Company regularly reviews its models in the context of actual loss experience and makes
adjustments when such differences are significantly material.
The amount of ECL (or reversal) that is required to adjust the loss allowance at the reporting date to the
amount that is required to be recognised as an impairment gain or loss in profit or loss.
2.12 Provisions and contingencies:
Provisions are recognised when the Group has a present obligation (legal or constructive) as a result of a
past event, it is probable that an outflow of resources embodying economic benefits will be required to
settle the obligation and a reliable estimate can be made of the amount of the obligation. Provisions are
measured at the best estimate of the expenditure required to settle the present obligation at the reporting
date.
Provisions are determined by discounting the expected future cash fiows (representing the best estimate
of the expenditure required to settle the present obligation at the balance sheet date) at a pre-tax rate
that refiects current market assessments of the time value of money and the risks specific to the liability.
The unwinding of the discount is recognized as finance cost. Expected future operating losses are not
provided for.
Contingent liabilities are disclosed when there is a possible obligation arising from past events, the
existence of which will be confirmed only by the occurrence or non-occurrence of one or more uncertain
future events not wholly within the control of the Company or a present obligation that arises from past
events where it is either not probable that an outflow of resources will be required to settle the obligation
or a reliable estimate of the amount cannot be made. Contingent assets are not recognised in financial
statements since this may result in the recognition of income that may never be realised. However, when
529Shah Investor's Home Limited
CIN:U67120GJ1994PLC023257
the realisation of income is virtually certain, then the related asset is not a contingent asset and its
recognition is appropriate. Where an infiow of economic benefits is probable, the group discloses a brief
description of the nature of the contingent assets at the end of the reporting period, and, where
practicable, an estimate of their financial effect, measured using the principles set out for provisions in Ind
AS 37.
2.13 Employee benefits
(i) Short-term obligations
Short-term employee benefits are recognized as an expense at the undiscounted amount in the restated
Statement of Profit and Loss for the year in which the related services are rendered. The Group recognises
the costs of bonus payments when it has a present obligation to make such payments as a result of past
events and a reliable estimate of the obligation can be made.
(ii) Post-employment obligations
Defined contribution plan:
Contribution paid/payable to the recognised provident fund and Employee State Insurance Corporation,
which is a defined contribution scheme, is charged to the Statement of Profit and Loss in the period in
which they occur.
Defined benefits plan:
Gratuity is post-employment benefit and is in the nature of defined benefit plan. The liability recognised
in the Balance Sheet in respect of gratuity is the present value of defined benefit obligation at the Balance
Sheet date together with the adjustments for unrecognised actuarial gain or losses and the past service
costs. The defined benefit obligation is calculated at or near the Balance Sheet date by an independent
actuary using the projected unit credit method. Actuarial gains and losses comprise experience adjustment
and the effects of changes in actuarial assumptions are recognized in the period in which they occur,
directly in other comprehensive income in the period in which they occur and are not reclassified to the
Statement of Profit and Loss.
The Group has funded its Gratuity liability under group scheme with an Insurer. The retirement benefit
obligation recognised in the balance sheet represents the present value of the defined benefit obligations
reduced by the fair value of the scheme assets. Any asset resulting from this calculation is limited to the
present value of any economic benefits available in the form of refunds from the plans or reductions in
future contributions to the scheme.
2.14 Foreign currency translation
(i) Functional and presentation currency
Items included in restated consolidated financial statements of the Group are measured using the
currency of the primary economic environment in which the Group operates ('the functional
currency'). The restated consolidated financial statements are presented in Indian rupee (INR) in
lakhs rounded off to two decimal places except when otherwise stated as permitted by Schedule
Ill to the Companies Act, 2013, which is Group's functional and presentation currency.
(ii) Translation and balances
Foreign currency transactions are translated into the functional currency using the exchange rates
at the dates of the transactions. Foreign exchange gains and losses resulting from the settlement
530Shah Investor's Home Limited
CIN:U67120GJ1994PLC023257
of such transactions and from the translation of monetary assets and liabilities denominated in
foreign currencies at year end exchange rates are recognized in profit or loss.
(iii) Translation of subsidiaries
All income and expense items are converted at the average rate of exchange applicable for the
period. All assets and liabilities are translated at the closing rate as on the balance sheet date.
2.15 Dividend Distribution:
Provision is made for the amount of any dividend declared, being appropriately authorized and no longer
at the discretion of the entity, on or before the end of the reporting period but not distributed at the end
of the reporting period.
2.16 Earnings per share
a) Basic earnings per share
Basic earnings per share is calculated by dividing the net profit for the period (excluding other
comprehensive income) attributable to equity shareholders of the Group by the weighted average
number of equity shares outstanding during the financial year, adjusted for bonus element in equity
shares issued during the year.
b) Diluted earnings per share
Diluted earnings per share is computed by dividing the net profit for the period (excluding other
comprehensive income) attributable to equity shareholders by the weighted average number of shares
outstanding during the period as adjusted for the effects of all diluted potential equity shares except
where the results are anti-dilutive. Further, when a subsidiary issue the potential ordinary shares that
are convertible into the ordinary shares of the subsidiary, to parties other than the parent and if these
potential ordinary shares of the subsidiary have a dilutive effect on the basic earnings per share of the
reporting entity, they are included in the calculation of diluted earnings per share.
2.17 Borrowing Costs
Expenses related to borrowing cost are accounted using effective interest rate. Borrowing costs are interest
and other costs (including exchange differences relating to foreign currency borrowings to the extent that
they are regarded as an adjustment to interest costs) incurred in connection with the borrowing of funds.
Borrowing costs directly attributable to acquisition or construction of an asset which necessarily take a
substantial period of time to get ready for their intended use are capitalised as part of the cost of that
asset. Other borrowing costs are recognised as an expense in the period in which they are incurred.
2.18 Segment Reporting
An operating segment is a component of the Company that engages in business activities from which it
may earn revenues and incur expenses, whose operating results are regularly reviewed by the company's
Chief Operating Decision Maker ("CODM") to make decisions for which discrete financial information is
available. Based on the management approach as defined in Ind AS 108, the CODM evaluates the
Company's performance and allocates resources based on an analysis of various performance indicators
by business segments and geographic segments.
2.19 Rounding of amounts
All amounts disclosed in the financial statements and notes have been rounded off to the nearest lakhs as
per the requirements.
531Shah Investor's Home Limited
CIN:U67120GJ1994PLC023257
2.20 Events after reporting date
Where events occurring after the balance sheet date provide evidence of conditions that existed at the
end of the reporting period, the impact of such events is adjusted within the financial statements.
Otherwise, events after the balance sheet date of material size or nature are only disclosed.
3A. Key accounting estimates and judgements
The preparation of restated consolidated financial statements requires management to make judgments,
estimates and assumptions in the application of accounting policies that affect the reported amounts of assets,
liabilities, income and expenses. Actual results may differ from these estimates. Estimates and underlying
assumptions are reviewed on ongoing basis. Any changes to accounting estimates are recognized prospectively.
Information about critical judgments in applying accounting policies, as well as estimates and assumptions that
have the most significant effect on the amounts recognised in the restated financial statements are included
in the following notes:
(a) Provision and contingent liability:
On an ongoing basis, Group reviews pending cases, claims by third parties and other contingencies. For
contingent losses that are considered probable, an estimated loss is recorded as an accrual in financial
statements. Loss Contingencies that are considered possible are not provided for but disclosed as
Contingent liabilities in the financial statements. Contingencies the likelihood of which is remote are not
disclosed in the financial statements. Gain contingencies are not recognized until the contingency has been
resolved and amounts are received or receivable.
(b) Allowance for impairment of financial asset:
Judgements are required in assessing the recoverability of overdue and determining whether a provision
against those is required. Factors considered include the ageing of past dues, value of collateral and any
possible actions that can be taken to mitigate the risk of non-payment.
(c) Recognition of deferred tax assets:
Deferred tax assets are recognised for unused tax-loss carry forwards and unused tax credits to the extent
that realisation of the related tax benefit is probable. The assessment of the probability with regard to the
realisation of the tax benefit involves assumptions based on the history of the entity and budgeted data
for the future.
(d) Defined benefit plans:
The cost of defined benefit plans and the present value of the defined benefit obligations are based on
actuarial valuation using the projected unit credit method. An actuarial valuation involves making various
assumptions that may differ from actual developments in the future. These include the determination of
the discount rate, future salary increases and mortality rates. Due to the complexities involved in the
valuation and its long - term nature, a defined benefit obligation is highly sensitive to changes in these
assumptions. All assumptions are reviewed at each reporting date.
(e) Property, plant and equipment and Intangible Assets:
Management reviews the estimated useful lives and residual values of the assets annually in order to
determine the amount of depreciation to be recorded during any reporting period. The useful lives and
residual values as per schedule II of the Companies Act, 2013 or are based on the Group's historical
532Shah Investor's Home Limited
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experience with similar assets and taking into account anticipated technological changes, whichever is
more appropriate.
(f) Business Model assessment:
Classification and measurement of financial assets depends on the results of the business model test. The
Company determines the business model at a level that refiects how groups of financial assets are
managed together to achieve a particular business objective. This assessment includes judgement
refiecting all relevant evidence including how the performance of the assets is evaluated and their
performance measured, the risks that affect the performance of the assets and how these are managed
and how the managers of the assets are compensated. The Company considers the frequency, volume and
timing of sales in prior years, the reason for such sales, and its expectations about future sales activity.
However, information about sales activity is not considered in isolation, but as part of a holistic assessment
of how company's stated objective for managing the financial assets is achieved and how cash fiows are
realized. Therefore, the Company considers information about past sales in the context of the reasons for
those sales, and the conditions that existed at that time as compared to current conditions.
Monitoring is part of the Company's continuous assessment of whether the business model for which the
remaining financial assets are held continues to be appropriate and if it is not appropriate whether there
has been a change in business model and so a prospective change to the classification of those assets.
(i) De-recognition of financial instruments - In case of transfer of loans through securitisation and
direct assignment transactions, the transferred loans are de-recognised and gains/losses are
accounted for, only if the Company transfers substantially all risks and rewards specified in the
underlying assigned loan contract. In accordance with the Ind AS 109, on de-recognition of a
financial asset under assigned transactions, the difference between the carrying amount and the
consideration received are recognised in the restated statement of Profit and Loss.
4. Recent Accounting developments
Ministry of Corporate Affairs ("MCA") notifies new standards or amendments to the existing standards under
Companies (Indian Accounting Standards) Rules as issued from time to time. For the year ended March 31,
2025, MCA has not notified any new standards or amendments to the existing standards applicable to the
Company.
533Shah Investor's Home Limited
CIN: U67120GJ1994PLC023257.
Notes to the Restated Consolidated Financial Statement
5 Cash and Cash Equivalents ('t in lakhs)
As at 31 March, As at 31 March, As at 31 March,
Particulars
2025 2024 2023
Cash on Hand 3.16 3.94 2.74
Balances with Banks
In Current account* 707.98 2,237.07 1,288.94
Bank Deposit having maturity of less than 3 months•• 7,800.00 10,765.97 1,546.00
Total 8,511.14 13,006.98 2,837.68
• Balance with Banks Includes overdraft debit balance
6 Bank Balance other than above ('tin lakhs)
As at 31 March, As at 31 March, As at 31 March,
Particulars
2025 2024 2023
Bank Deposits with original maturity of more than 3 months
but less than 12 months** 4,483.25 3,636.99 3,923.40
Bank Deposits with original maturity of more than 12
months** 2,653.00 672.75 3,457.25
Earmarked balances with bank towards Unclaimed dividend 0.63 0.61 1.06
Interest Accrued on Fixed Deposits 205.42 234.51 63.00
Total 7,342.30 4,544.86 7,444.71
**Fixed deposits under lien with stock exchanges amounted to 13,089.25 lakhs (March 31, 2024: 13,378.71 lakhs, March
31,2023 : 7,312.65 lakhs) and kept as collateral security towards bank guarantees issued amounted to 1,638 lakhs
(March 31, 2024 : 1,488 lakhs, March 31,2023 : 1,375 lakhs) and kept as collateral security against credit facility
amounted to 209 lakhs (March 31, 2024 : 209 lakhs, March 31,2023 : 239 lakhs)
7 Receivables ('t in lakhs)
As at 31 March, As at 31 March, As at 31 March,
Particulars
2025 2024 2023
(I) Trade Receivables
Secured, considered good* 1,597.95 726.72 1,051.76
Unsecured, considered good 87.64 51.76 43.99
Trade Receivables which have significant increase in credit risk
Trade Receivables -Credit impaired
Total 1,685.59 778.48 1,095.75
Less: Allowances for impairment losses
Total 1,685.59 778.48 1,095.75
No trade or other receivable are due from directors or other officers of the company either severally or jointly with any
other person. Nor any trade or other receivable are due from firms or private companies respectively in which any
director is a partner, a director or a member.
*Secured against securities given as collateral by the customer.
For the year ended March 31, 2025 (~ in lakhs)
Less than 6
Particulars 6 Months -1 Year More than 1 Year Total
Months
(I) Undisputed Trade receivables-considered good 1,487.67 197.92 1,685.59
(ii) Undisputed Trade Receivables-considered doubtful
(iii) Disputed Trade Receivables considered good
(iv) Disputed Trade Receivables considered doubtful
For the year ended March 31, 2024 ('t in lakhs)
Less than 6
Panlculars 6 Months -1 Year More than 1 Year Total
Months
(I) Undisputed Trade receivables-considered good 772.09 6.39 778.48
(ii) Undisputed Trade Receivables-considered doubtful
(iii) Disputed Trade Receivables considered good
(iv) Disputed Trade Receivables considered doubtful
534Shah Investor's Home Limited
CIN: U67120GJ1994PLC023257.
Notes to the Restated Consolidated Financial Statement
For the year ended March 31, 2023 (" In lakhs)
Less than 6
Particulars 6 Months -1 Year More than 1 Year Total
Months
(I) Undisputed Trade receivables-considered good 1,066.24 29.51 1,095.75
(ii) Undisputed Trade Receivables-considered doubtful
(iii) Disputed Trade Receivables considered good
(iv} Disputed Trade Receivables considered doubtful
8 Loans (" in lakhs)
As at 31 March, As at 31 March, As at 31 March,
Particulars
2025 2024 2023
Loans
(A) Loans -At amortized cost
Loans repayable on demand 1,117.60 1,478.99 1,975.11
Loans to employees 0.84 1.26 6.21
Margin Trading facility 964.22
Total (A) -Gross 2,082.66 1,480.25 1,981.32
Less: Impairment Loss Allowance (185.36) (161.01) (164.08)
Total (A) -Net 1,897.30 1,319.24 1,817.24
(B) Secured/Unsecured
(i)Secured by Shares/ Securities 964.22
(ii) Unsecured 1,118.44 1,480.25 1,981.32
Total (B) -Gross 2,082.66 1,480.25 1,981.32
Less: Impairment Loss Allowance (185.36) (161.01) (164.08)
Total (B) -Net 1,897.30 1,319.24 1,817.24
(C) Loans In India
(i) Public Sector
(ii) Others [Refer (A) above] 2,082.66 1,480.25 1,981.32
Total (C) -Gross 2,082.66 1,480.25 1,981.32
Less: Impairment Loss Allowance (185.36) (161.01) (164.08)
Total (C) -Net 1,897.30 1,319.24 1,817.24
Stage wise break up loans:
(i) Low credit risk (Stage 1) 1,319.18 1,118.08 1,817.24
(ii) Significant increase in credit risk (Stage 2) 578.12 201.16
(iii) credit impaired (Stage 3]
Total 1,897.30 1,319.24 1,817.24
9 Investments (" In lakhs)
As at 31 March, As at 31 March, As at 31 March,
Particulars
2025 2024 2023
At Fair value through Other Comprehensive Income
In Equity instruments
Equity Shares (Quoted] 7,233.42 6,771.54 4,657.38
Unlisted Shares 239.26 239.53 96.52
Other Investment 0.19
Debenture/Bond 19.51 20.38 71.02
Preference Shares 39.69 37.11 34.68
At Fair value through Profit & Loss
Mutual Fund 220.17 177.93 138.85
Total 7,752.24 7,246.49 4,998.45
Less : Provision for diminution in Value of Investment (21.97) (22.84) (25.60)
Net Value of Investment 7,730.27 7,223.65 4,972.85
(i) Investment in India 7,730.27 7,223.65 4,972.85
(ii) Investment outside India
535Shah Investor's Home Limited
CIN:U67120GJ1994PLC023257
Notes to the Restated Consolidated Financial Statement
...~ 1'1•11-
Parllculan Fllc.Val1111 As at n .M..a.rd.i... z ozs As at 31 March.., 2024 As at 31 .M..a.rc.h.,. 2 023
"'"' "'"' "'"'
II) lnvaslment at fair valua throup athir
comprehensive Income (at FVOO)
(al Investment In Quoted Eql,llty Sheres
Angel One Ltd 10 19,731 456.42
Asian Paints Ltd 23,323 545.91 146 4.lE 101 2.79
Amal Ltd 13,549 269.6!l 13,223 176.78
Avenue Supermarts Ltd 10 34 LS< 1,363 46.39
Ba/aJ Auto Ltd 10 63 S.7E 39 1.51
Ba/al Finance Ltd 11,688 1,045.56 9,236 668.72 5,917 332.26
Bomay BurmahTradlns COlll Ltd zoo 3.53 200 3.13 200 1.62
Borosil Ltd 1,99,.40.0 666.20 1,16,.40.0 415.GE 1,09,.90.0 359.81
Borosil Scientific Ltd 87,300 106.67 87,300 3.9,.0,6 .,,
ae Automotive Indra Ltd 10 1,07,370 495.03
Continental Construction Ltd 10 0.12
coromandel lntematlonal Ltd 1 W,470 207.53 10,470 112.65 17,470 153•.o6o0
cvt,erscape Multr Media 10 1 1 o.oc 1
Dangee Dums Ltd 4,21,885 34.17 12,59,265 180.70
Data Swlthchgear Ltd 10 100 0.00 100 •0s0s1 100 0.01
Dravya Industrial Chemicals Ltd 10 5,500 0.00 5,500 5,500 •ss
Flnolex Industries Ltd 3,08,870 555.75 2,08,870 515.18 2,08,870 356.65
Gmm Praudler Ltd 13,775 139.66 17,825 220.27 .,
Happiest Minds Technologies Ltd 174 L2' 0.7.ill
Havells India Ltd 7,771 118.81 9,068 137.37 8,189 97.32
HdTechnologles Ltd 476 .7.,3,5 270 .2.,9,3
Hdfc Bank Ltd 8,474 122.72 10,949 176.25
Hindustan Alloys Ltd 1,,00 0.01 1,300 1,300
Hindustan Petroleum Corporation Ltd 10 1,-40,200 505.21
Hindustan Unilever Ltd 1,936 49.54
Hindusthan Engineering & Industries Ltd 10 15 0.00 15 o.oc 15 0.00
lndlan Energy Exchange Ltd "" 1.2C 519 0.66
lndlan Renewable Energy Development Agency Ltd 10 50050 81.98
lndraprastha Gas Ltd 9,200 39.65 ,,zoo 39.42
Info Edge !India) Ltd 2,596 186.43 2,974 166.33 4,475 166.82
lrcon International Ltd 1,28,000 200.29
"'"' 457 1.96 457 1.75
Jlo Flnandal services Ltd 10 11,676 26.56 11,676 41.31
Jubllant Foodworlcs Ltd 2 36,650 "'"'
Kansai Nerolac Paints Ltd 675 1.77 450 1.7.ill
Kotak Mahindra Bank Ltd 6,432 114.SE 10,892 188.81
La Opela Rg Ltd 1,384 <12 9,384 31.87
Lie Housing Finance Ltd 1,48,&20 908.14 1,43,220 470.76
Ltlmlndtree Ltd 1,302 "" 1,082 51.48
Mahindra aeAutomattve Ltd 10 . 1,07,370 376.44
MMa ap ril ce oC Lin td:u its 10 100 0.00 2,1 80 40
6
1.0 <.. .0 1. ,1
4
2,1 8.0 4.0
6
13.0 ... 60. 51
Mother:son Sumi Wiring India Ltd 716 0.37 716 716 ""
Nazara Technologles Ltd 4 101
Novateor Research Laboratories Ltd 10 1,50,000 53.84 1,50,000 63.72 1,74,000 32.19
Oil And Natural Gas Corporation Ltd 1,93,900 477.73 3,45,200 924.62 3,29,700 497.85
One 97 Communications Ltd 5,000 20.14 5,000 31.85
OptoClrcult 10 260 0.00 260 •oc 260 •oo
Pase Industries Ltd 10 ,o8o0o0 341.SS
Pentafour Products Ltd 10 0.04 4,000 0.4C 4,000 0.40
Patronet Lnc Ltd 10 34,800 91.65
Pl Industries Ltd 11,262 386.08 1,892 73.20 1,570 47.53
Pldlllte Industries Ltd 877 26M 877 20.64
Pyramid 5amlra Theatre Umlted 10 19,598 19,598 9,598
Reliance Industries Ltd 10 17,112 218.20 11,699 348.26 13,765 32.0.87
samvardhana Matherson International Ltd 768 0.9C 768 0.52
Sula Vineyards Ltd 41,800 112.59 .,
Syngene International Ltd 10 225 1.58 138
Tamllnadu Petroproducts Ltd 10
Tata consultancy services Ltd 1 " 1 ... 76 2.95 n 2.47
TeJas Networks Ltd 10 15,050 114.45
Tirupilti Ind Ltd 10 100 0.00 100 o.oc 100 0.01
Trans Freight COntainer:s Ltd 10 1,59.3 0.58 1,593 0.49 1,59.3 0.26
Tvs Motor company Ltd 1,000 21.51 1,000 10.77
Uno Minda Ltd 13,825 121.04 16,200 110.88 16,200 77..,9c3
VanasthallTextlle Industries Ltd 10 3,000 0.02 3,000 0.02 3,000
Vatsa corporation Ltd 10 10,900 0.11 10,900 1.09 10,900 1.09
Zydus Lifesciences Ltd 35,600 315.56 66,671 670.21 66,750 328.08
Total(a) 7-4' &,.771.54 4,657.38
(b)lnn&tment In Unquoted Equity Shara
Ficus Food Lab Private Umlted 10 1,90,000 18.31l 1,90,000 18.30 1,90,000 18.30
lnflnlum Mines And Mlneral!il Private Limited 10 1,10,000 13.91 1,10,000 12.11 1,10,000 17.27
National stock Exchange Of Indra Ltd 25,000 146.10 5,000 146.10
Sihl Commodities Limited 10 2,33,500 60.94 2,33,500 63.01 2,33,500 "'·"
Devmurti Owner Association 1,000 0.01 1,000 0.01 1,000 0.01
Total(b) Z39.Zti ""' 96.52
(c )Investment In Preference Sharell
Ficus Food Lab Private Umlted 10 12,50,000 39.69 12,50,000 37.11 12,50,000 3.4..6. 8
T~ Sracc Ltd 0.01 Preference 01012015 10 400 400 400 , ,
Total(c) "·" 37.11
536Shah Investor's Home Limited
CIN: U67120GJ1994PLC023257.
Notes to the Restated Consolidated Financial Statement
(d)lnvesunem: In Bond
Govemment Of India 31791364 Dayslbill D6.1123 Fv Rs
100 100 .... 50,000 47.89
Srei Equipment Finance Limited Sr-Vil 91.Da 16Mr23 ,
""1000 1000 19.51 '·""' 20.38 '·""' 23.13
Total(dl 19,51 "'" 71.112
(a I OU-lnvastmant
Arbor Park lfsc Up (Lip) ....0.. 19 ........
Totelle) , 0.1.,9
Toml00 7,D68.51i
(II) IIIWllilmant at falrvalu■ thruu1h Prolft and lms ...
IF1111'Ll
lclcl Prudentlal Mutual Fund B.se Liquid Etf ldcw 1000 10,000 100.00
Nippon India Mutual Fund Etf Uquld Bees 1000 46.37 0.46 44.02 41.74 ""
Nippon India Mutual Fund Etf Nifty Psu Bank Bees 1000 1,72,400 119.71
Nippon India Mutual Fund Etf Nifty SO Bem 62,100 153.47 62,100 117.90
Nippon India Mutual Fund Etf Nifty !lank Bees 5,000 24.02 5,000 20.53
Total(I) 220.17 177.93 ll8.85
Totallll+{III 7,752.24 7,246.49 4,998.45
Less : Provision for diminution in value of Investment (21.97) (22.84) (25.60)
Total lnvutmant 7,730.27 7,223.65 4,972.85
10 Other Financial Assets ("' in lakhs)
As at 31 March, As at 31 March, As at 31 March,
Particulars
2025 2024 2023
Rent, electricity and other deposits 32.86 29.86 33.56
Deposits with exchange 233.87 252.49 274.37
Dividend Receivable 0.29
Deposits with depository 0.45 0.45 0.45
Total 267.47 282.80 308.38
11 Current Tax Assets (Net) ("' in lakhs)
As at 31 March, As at 31 March, As at 31 March,
Particulars
2025 2024 2023
Advance Income tax and TDS (Net of 220.30 217.72 256.47
Provision)
Total 220.30 217.72 256.47
12(11) lnvesbnent Property l"ln a.ths)
Gross Block Daprecllllon and Amonlzallon Net Block Net Block
Name of Assets
Ason01-Apr-24 Addition Deduction As on 31-Mar-25 As on 01-Apr-24 for the year Deduction As on 31-Mar-25 As on 31-Mar-25 As on 31-Mar-24
BulldlllJI 123.45 123.45 32.68 4.42 37.10 86.35 90.77
Tot,I 12145 123.45 32.68 4.42 37.10 16.35 90,77
Gl'Cl!lllBlock Depredation and Amorllzatlan NIii Block NltBloc:k
Name of Assets
As on 01-Apr-23 Addition Deduction As on 31-Mar-24 As on 01-Apr-23 for tha year Daductlon As on 31-Mar-24 As on 31-Mar-24 M on 31-Mar-23
Bulldl111 123.45 123.45 28.04 4.65 32.68 90.77
T°"I 123.45 2lL04 4.65 32.61 '""
ll(b) Property, Plant and Eqllpment ........ I" In laths)
Gross Block Depredation and Amanlzatlon Net Block Nlll:Block
Name of Assets
As on Ol~r-24 Addition As on 31-Mar-25 As on 01-Apr-24 fortheJ!:!!: Deduction As on 31-Mar-25 As an 31-Mar-25 As on 31-Mar-24
Property, Plant and Equipment
Freehold Land 728.16 728.16 728.16 728.16
Building 1,330.81 16.14 1,346.95 358.36 47.58 405.94 941.01 972.45
EleCb'ic Installation 55.29 55.29 48.34 1.47 49.81 5.48 6.95
Fumiture & Fixtures 238.71 1.48 240.19 195.25 W.26 205.51 34.68 43A6
Office Equipment 221..8.1 36.35 258.16 171.33 26.75 198.08 60.08 SOA8
Vehlcles 370.16 122.42 13.26 479.32 1.9.9..0..0 66.58 12.32 253.26 226.06 171.16
Right to use ,. 1. 2,. 7 .15 ,.213257...Z1Z5 ,1 4.16 4.72 18.88 108.27 112.99
To<•I 17fi.39 13.Z& 157.3& '"" 1,131.41 Z,103.74 2,085.65
Previous Year 3,268.76 270.14 466.83 3,072.07 1,201.63 137.08 352.30 986.41 2,085.66 2,067.13
(ti} lntanafbla Allatl
comeuter5oftware 22.60 0.01 22.61 16.19 2.36 18.55 4.06 6A1
T. ..I 22.60 0.01 22.&1 16.19 :u& U.55 4.06 &.41
Previous Yei,r 115.14 1.04 93.57 22.60 103.74 2.52 90.07 16.19 6.41 11.40
537Shah Investor's Home Limited
CIN: U67120GJ1994PLC023257_
Notes to the Restated Consolidated Financial Statement
......... lnlakhs
Gross Block Depreciation and Amortization NIii Black Nit Block
Name of Auets AlonO~r-23 Addition Al on :11-Mar-24 AsonO~r-U forth■ D■ductlon As on :n-Mar-24 As an :U-Mar-24 As on :U-Mar-23
Ill Property, Plant and Equipment
Freehold Land 728.17 na.11 728.17 728.17
Bulldlng 1,180.18 150.63 1,330.81 311.02 47.34 358.36 972A5 964.57
Electric Installation 60.79 5.50 55.29 51.47 1.99 5.12 "'" 6.95 9.32
Furniture & Fixtures 273.93 2.53 37.75 238.71 217.99 13.12 35.86 195.25 43A6 55.94
Office Equipment 531.61 17.71 327.51 221.81 452.27 ,30,..0,9 311.04 171.33 50A9 79.35
Vehicles 271.53 99.27 0.65 370.15 159.'4 0.27 199.00 171.15 112.09
R.l.g.h tto use 127.15 127.15 9.'4 4.72 14.16 112.99 117.71
, , ,...,,
3,173.36 270.14 371A1 3,012.09 1,201.63 137.09 986.44 2,085.66 2,057.15
Previous Ynr 2,541.34 865.17 109.71 3,296.80 1,205.78 122.92 99.04 1,229.66 2,067.15 1,335.57
IHI Intangible Assets
,C. o.m. ,pu ter Software 115.14 1.04 93.57 22.60 103.74 .2..5.2. 90.07 16.19 6A1 11AO
115.14 .1.,0,4 93.57 Z2.60 103.74 90.07 16.19 6A1 llAO
Previous Year 109.02 115.14 94.66 9.08 103.74 llAO 14.36
(' In lakhs)
Gross Block Depredation and Amortization Net Block NetBlodl
Name of Assets As on 01-Apr-2Z Addition °""""" As on H•Mar-ll As on 01-Apr-2Z forth• Deduction As on 31-Mar-ZJ As on 31-Mar-23 As on 31-Mar-.ZZ
Ill Property, Plant and Equipment
Freehold Land 274.90 453.26 728.17 728.17 274.90
Bulldlng 1,063.74 253.16 13.28 1,303.62 303.28 43.23 7.46 339.0S 964.57 760A6
Electrlc lnstallatlon 60.54 0.25 60.79 48.80 2.67 51.47 9.32 11.74
Furniture & Fixtures 285.24 '·" 21.04 273.93 223.62 14.35 19.98 217.99 55.94 61.62
Office Equipment 524.15 51.15 43.69 531.61 463.88 29.87 41.48 452.27 79.35 60.28
Vehicles 205.62 97.62 31.70 271.53 161.48 28.08 30.12 159.44 112.09 4'l14
R.ig.h. t to use 127.15 127.15 4.72 4.72 '·"' 117.71 122.43
, ,
z,541.34 865.17 109.n 3,296.80 1,ZOS.78 122.92 99.04 1,2:29.66 Z.067.15 1,335.57
Previous Year Z.218.84 25.67 10.79 2,233.72 1,046.52 94.06 9.54 1,131.04 1,102.68 1,172.32
IHI lntanalble Assets .,,
,C. o.m. ,pu ter Softwere .1.09...0.2 ,. .. 115.14 .9.4..6.6. 9.08 1 .03 .. .7 .4 llAO "'"
115.14 9.08 103,74 11.40 14,36
Previous Year 105.24 3.77 109.02 86.74 7.91 14.36 18.50
12(c) Oipltal Work-ln-propess ('lnlakhsl
Parllculan 31Mar25 31-Mar-Z4 31-Mar-ll
Opening Balance 39.84 7.23 3.00
Add: Addition during the year 67.70 61.88 7.23
Ws: caeitalized durinl the l!ar 29.27 ,3..,0_0,
Closlng Bai.nee 107.54 39.84
Olpltal Work-ln-Pl'Olress Alel111 Schedule I" In lakhsl
... -
Amount In CWIPfora period of 31,-M lr,-2 5 Amount In CWIP for a period of 31-Mlr-Z4
Clpltal Work-ln-Pl'Oll'NI I.HI than 1 yur 1-2.Yean 2-3Yun Mo Yre et ah na n3 Less than 1 1-2.Y■an 2-3Yun Mo Yre n th na n 3 ""''
Projects in progress 67.70 32.61 7.23 107.54 32.61 7.23 39.84
...
Amount In CWIPfora parlod of 31,-M a,r- ll
Oipltel Wort-ln-Pnwess Morathan3
Les, than 1 year 1-2.Years 2-3Yei,n
Y■an
Projects In prosress 7.23 7.23
1Zldl lntaqlble assets under d-lopment I" In lakhs)
Panlculan 31-Mar-25 31-Mar-24 31-Mar-23
Opening Balance 13.94 1.50
Add: Addition during the year 12.44 1.50
l.e&s: Capitalized during the year
Clos~ Balance 13.94 13.94 1,50
lntaqlble assats under davalopmant apin1 SChedula ... ( .' .I .n lakhs)
lntarcfbla assets undar
Amount in CWIP for a period of 31 M,a rch, 2 025 Amount in CWIP for a period of 31 M,e n:h, 20 24
davelopmant Less than 1 yur 1-2.Yun z-n- Morethan3 l.es,s.t.h.a n 1 1-2.Yun 2-3Yun More than 3
Ynn Years
Projects in progress 12.44 1.50 13.94 12.44 1.50 13.94
Amount In CWIP for a period of 31 March 2023
lntanglbla assets undar
davelopment Lessthanlyur 1-2.Yun wv- Morethan3 Toal
Yun
Projects ln progress 1.50 1.50
538Shah Investor's Home Limited
CIN: U67120GJ1994PLC023257.
Notes to the Restated Consolidated Financial Statement
13 Other Non Financial Asset (' in lakhs)
As at 31 March, As at 31 March, As at 31 March,
Particulars
2025 2024 2023
Prepaid Expenses 73.27 53.06 48.97
Advance to Supplier 8.11 42.09 7.73
Capital Advances 93.75 93.47 245.29
Balance with Government authorities 40.43 21.16 5.84
Other Non Financial Asset 0.92 1.06
Other Advances 16.88 0.99 3.57
Total 232.44 211.69 312.46
14 Payables (" in lakhs)
As at 31 March, As at 31 March, As at 31 March,
Particulars
2025 2024 2023
Trade Payables*
(i)Total Outstanding dues of Micro and 3.11
small enterprises
(ii)Total Outstanding dues of creditors 12,411.80 13,655.46 8,339.73
other than Micro small and Medium
Enterprises
Other Payable
(i)Total Outstanding dues of Micro and
small enterprises
(ii)Total Outstanding dues of creditors 5.54 2.89 3.01
other than Micro small and Medium
Enterprises
Total 12,420.45 13,658.35 8,342.74
*Trade payables also includes balances due to parties other than clients which are insignificant in terms
of value
For the year ended 31 March 2025 (~ in lakhs)
Outstanding for following periods from due date of Payment
Particulars
Less than 1 year 1·2 year More than 3 year Total
(i)MSME 3.11 3.11
(ii) Others 12,417.34 12,417.34
(iii) Disputed dues-MSME
(iv) Disputed dues-Others
For the year ended 31 March 2024 (~ in lakhs)
Outstanding for following periods from due date of Payment
Particulars
Less than 1 year 1-Z year More than 3 year Total
(i)MSME
(ii) Others 13,658.35 13,658.35
(iii) Disputed dues-MSME
(iv) Disputed dues-Others
539Shah Investor's Home Limited
CIN: U67120GJ1994PLC023257.
Notes to the Restated Consolidated Financial Statement
For the year ended 31 March 2023 (~ in lakhs)
Outstanding for following periods from due date of Payment
Particulars
Less tltan 1 year 1-2 year More tltan 3 year Total
(i)MSME
(ii) Others 8,342.74 8,342.74
(iii) Disputed dues-MSME
(iv) Disputed dues-Others
15 Borrowings (Other than Debt Securities) (" in lakhs)
As at 31 March, As at 31 March, As at 31 March,
Particulars
2025 2024 2023
Vehicle Loans
a) From banks 84.20 49.95
Demand Loans
a) from banks 469.15 303.57 803.42
b) from other parties 17.46
Total 570.81 353.52 803.42
Borrowings in India 570.81 353.52 803.42
Borrowings outside India
Total 570.81 353.52 803.42
Secured* 570.81 353.52 803.42
Unsecured
Total 570.81 353.52 803.42
Rate of interest is ranging from 8.75% to 10.00% (as at 31 March, 2024: 8.75% to 9.70%), (as at 31
March, 2023: 8.75% to 9.70%) for above borrowings.
*The aforesaid vehicle loan from bank is secured by hypothecation of vehicle, repayable in 60 monthly
instalments. The aforesaid demand loans are secured against hypothecation of mortgage of
properties/investments/lien of fixed deposits/personal guarantee of directors.
16 Other Financial Liabilities (" in lakhs)
As at 31 March, As at 31 March, As at 31 March,
Particulars
2025 2024 2023
Unpaid dividend 0.63 0.61 1.06
Salary & Wages 10.58 8.07
Other payables 0.97 0.88 0.96
Deposits from others 1.59 1.59
Total 13.77 11.15 2.02
17 Current tax liabilities (Net) (" in lakhs)
As at 31 March, As at 31 March, As at 31 March,
Particulars
2025 2024 2023
Current Tax Provision (Net of Advance
Income tax and TDS) 35.05 15.77 7.16
Total 35.05 15.77 7.16
540Shah Investor's Home Limited
CIN:U67120GJ1994PLC023257
Notes to the Restated Consolidated Financial Statement
(" in lakhs)
As at 31 March, As at 31 March, As at 31 March,
Particulars
18 2025 2024 2023
DEFERRED TAX ASSETS:
Arising on account of timing difference
Fair Valuation of Equity Instruments 6.70 4.85 12.61
Preliminary Expense
Property, Plant and Equipment 1.19 0.55
Leave Encashment 0.33 0.30 0.01
Bonus 0.67 0.30
Gratuity 17.98 9.98 7.13
DEFERRED TAX LIABILITIES:
Arising on account of timing difference
Fair Valuation of Equity Instruments 103.33 376.69 84.64
Property, Plant and Equipment 1.72 1.70 6.33
Leave Encashment 0.14 0.03 0.04
Bonus 5.40 (0.00)
Gratuity (0.29) (0.00) 0.06
DEFERRED TAX ASSETS/ILIABILITIES) (78.70) (367.47) (71.02)
Movement In Deferred Tax Asset/(Llabllltles) I" in lakhs)
Recognized in
As at April Recognized As at March
Particulars Profit or
1,2024 inOCI 31, 2025
Loss
(a) Deferred Tax Assets
Fair Valuation of Equity Instruments (30.88) 2.92 34.66 6.70
Property, Plant and Equipment 0.00 (0.00) 0.00
Leave Encashment 0.30 (0.05) 0.25
Bonus (5.40) 5.40
Gratuity 9.98 2.55 5.46 17.99
(a) Deferred Tax Liabilities
Fair Valuation of Equity Instruments 340.96 (17.54) (220.09) 103.33
Property, Plant and Equipment 1.15 (0.62) 0.53
Leave Encashment 0.02 0.04 0.07
Bonus (0.67) 0.67
Gratuity (0.00) (0.09) (0.20) (0.29)
Deferred Tax Asset/(Liabilities) (Net) (367.47) 28.36 260.41 (78.70)
541Shah Investor's Home Limited
CIN: U67120GJ1994PLC023257.
Notes to the Restated Consolidated Financial Statement
Movement In Defen-ed Tax Asset/(Llabllltles) I" in lakhs)
Recognized in
As at April Recognized As at March
Particulars Profit or
1,2023 inOCI 31, 2024
Loss
(a) Deferred Tax Assets
Fair Valuation of Equity Instruments 4.60 (35.48) (30.88)
Property, Plant and Equipment (0.07) 0.07 0.00
Preliminary Expense
Leave Encashment (0.04) 0.33 0.31
Bonus 0.20 (5.60) (5.40)
Gratuity 7.14 2.27 0.58 9.99
[b) DEFERRED TAX LIABILITIES:
Fair Valuation of Equity Instruments 76.64 7.98 256.35 340.97
Property, Plant and Equipment 6.25 (5.11) 1.14
Leave Encashment (0.00) 0.03 0.03
Bonus (0.07) (0.60) (0.67)
Gratuity 0.03 0.07 (0.10) (0.00)
Deferred Tax Asset/(Uabllltles) (Net) (71.02) (5.30) (291.15) (367.47)
Movement in Defen-ed Tax Assetf (Liabilities) ('! In lakhs)
Recognized in
As at April Recognized As at March
Particulars Profit or
1,2022 inOCI 31, 2023
Loss
(a) Deferred Tax Assets
Fair Valuation of Equity Instruments 0.21 4.39 4.60
Property, Plant and Equipment 0.17 (0.24) (0.07)
Preliminary Expense 0.23 (0.23)
Leave Encashment 1.14 (1.16) (0.04)
Bonus 0.18 0.02 0.20
Gratuity 6.35 2.27 (1.48) 7.14
(b) DEFERRED TAX LIABILITIES:
Fair Valuation of Equity Instruments 190.26 0.32 (113.94) 76.64
Property, Plant and Equipment 6.57 (0.32) 6.25
Leave Encashment (0.02) 0.02 (0.00)
Bonus (0.02) (0.05) (0.07)
Gratui!I 0.10 (0.00) (0.07) 0.03
Deferred Tax Asset/(Uabilities) (Net) (188.61) 0.69 116.92 (71.02)
19 Provisions I" in lakhs)
As at 31 March, As at 31 March, As at 31 March,
Particulars
202S 2024 2023
Provisions for Gratuity 61.43 37.76 33.05
Provisions for other Employee Benefit 72.49 122.04 27.78
Provision for Other Expenses 32.84 40.23 30.24
Total 166.76 200.03 91.07
20 Other Non-Financial Liabilities (" in lakhs)
As at 31 March, As at 31 March, As at 31 March,
Particulars
202S 2024 2023
Statutory liabilities 64.68 121.09 58.03
Other Non- Financial Liabilities 0.06
Total 64.74 121.09 58.03
542Shah Investor's Home Limited
CIN: U67120GJ1994PLC023257.
Notes to the Restated Consolidated Financial Statement
21 Share Capital ('in lakhs)
Particulars As at 31 March, 2025 As at 31 March, 2024 As at 31 March, 2023
AUTHORIZED SHARE CAPITAL
3,00,00,000 Equity Shares of Rs.10/-each
(Previous Year 3,00,00,000 Equity Shares of Rs.10/-each) 3,000.00 3,000.00 3,000.00
Total 3,000.00 3,000.00 3,000.00
ISSUED. SUBSCRIBED & FULLY PAID UP CAPITAL
1,57,54,000 Equity Shares of Rs.10/-each fully paid up
(Previous Year 1,57,54,000 Equity Shares of Rs.10/-each fully paid up) 1,575.40 1,575.40 1,575.40
Total 1,575.40 1,575.40 1,575.40
:1!1.1 Tha lllCIIIICDlatlon aftha numbtlr of Eqwty Sh111'81 DUlstrilndl111 11111t 3151 March 202511 lllt out baklw : 1111 In l11kh1)
As ,t 31 Merell, 2025 As ,t H Mllrch, 2024 As ,t H Mllrch, 2023
Partla.il■n eN ao d. lo uh nh l. la !. sr . se . o.s . t o h f e R rws. i1 se0 lllln l■lch1 N ao d. !o uf s nh . ll.a m.re . as . . lo h f l! R rws. l s1 e0 lllln lalch1 No 1. Dof a s dhi lr ue ns lo lmf R s. "1nlalch1
otharwl&a stated
Shares 011tstandinr at the bea;innins of the year 1,57,54,000 1,575.40 1,57,54,000 1,575.40 1,57,54,000 1,575.40
Add: Share5 Issued during the year
Shares ootstandlng at the end of the year 1,57,54,000 1,575.40 1,57,54,000 1,575.40 1,57,54,000 1,575.40
21.2 Riat,ls, Pl'ffl111nca and l1lllrictlonl attachld to Equity Sh11111 :
The company has one clilSlii of equity shares havi111 a par value of Rs.10 each. Each shareholder is eligible for one wte per shall! held. The dividend proposed by the Board of Directors is subject to the approval of
the shareholders in the ensuinr Annual General Meetins. In the event of liquidation, the equity shareholders are eliSible to receive the remaininr assets of the company after distribution of all preferential amounts,
In proportion to their shareholding.
21.3 The delalls ot lhil111hold1rs holdng mON than "' lhara 1111 11t OUI below :
As at 31 Mllrch, 2025 As at ill Mllrch, Z024 As at ill Mllrch, ZOU
Nillma afthe llharehokl■rs
No.afSh■ra "afholdl1111 No.afSh■ra "af haldl1111 No.afSh■ra "af haldl1111
Pumlma Upendra Shah 34,50,000 21.90 36,00,000 22.85 38,00,000 24.12
Upendra T. Shah 30,00,000 19.04 31,50,000 19.99 39,50,000 25.07
Tanmay u. Shah 25,0S,000 15.90 25,0S,000 15.90 18,0S,000 11.46
Preetl Upendra Shah 14,15,000 '·" 14,15,000 8.98 13,15,000 8.35
21.4 Shareholdl111 af promoters and promoter group In the Company
Name of the shareholders As at 31 Man:h, zozs Al at 31 March, 2024 "ofc:hanae
No. of Shara K of holdln1 No. of Shares % of holdln,
Purnima Upendra Shah 34,50,000 21.90 36,00,000 22.85 (4.17)
Upendra T. Shah 30,00,000 19.04 31,50,000 19.99 (4.76)
Tanmay U. Shah 25,05,000 15.90 25,05,000 15.90
Preeti Upendra Shah 14,15,000 8.98 14,15,000 8.98
Truptl Utpal Shah 6,50,000 4.13 S,00,000 3.17 30.00
RaJesh Ramchand Punjabi 6,50,000 4.13 6,50,000 4.13
Ruch Ira Tan may Shah S,80,000 3.68 5,80,000 3.68
Utpal Praful Shah 5,30,000 3.36 3,80,000 2.41 39.47
Upendra Trikamlal Shah (Huf) 3,32,500 2.11 3,32,500 2.11
Shrutl RaJesh Punjabi 3,00,000 1.90 3,00,000 1.90
Sandhya RaJesh Punjabi 2,50,000 1.59 2,50,000 1.59
Kenisha Shah 2,41,200 1.53 2,41,200 1.53
Rehaan Utpal Shah 2,20,000 1AO Z.20,000 1.40
Aashna Utpal Shah 2,20,000 1AO 2,20,000 1.40
Sagar RaJesh Punjabi 1,71,700 1.09 1,68,700 1.07 1.78
Tanmay U. Shah (Huf) 1,00,600 0.64 1,00,600 0.64
Utpal Praful Shah(Huf) 36,400 0.23 32,400 0.21 12.35
Nlvedlta Vljay Vyas 1,650 0.01 "'" 0.01
Pritish Praful Sh;ah 1,650 0.01 1,650 0.01
Prafulbhal Shah 2,400 0.02 2,400 0.02
As at 31 Man:h, Z024 As at 31 March, 2023
Name of the shareholders '6ofc:hanp
No. of Sharas " of holdln1 No. of Shares '6 of holdlllf
Purnima Upendra Shah 36,00,000 22.85 38,00,000 24.12 (5.26}
Upendra T. Shah 31,50,000 19.99 39,50,000 25.07 (20.25)
Tanmay U. Shah 25,05,000 15.90 18,05,000 11.46 38.78
Preeti Upendra Shah 14,15,000 8.98 13,15,000 8.35 7.60
Truptl Utpal Shah 5,00,000 3.17 4,50,000 2.86 11.11
Rajesh Ramchand Punjabi 6,50,000 4.13 6,50,000 4.13
Ruchira Tan may Shah 5,80,000 3.68 4,80,000 3.05 20.83
Utpal Praful Shah 3,80,000 2A1 3,30,000 2.09 15.15
Upendra Trikamlal Shah (Huf) 3,32,500 2.11 3,32,500 2.11
Shrutl RaJesh Punjabi 3,00,000 1.90 3,00,000 1.90
Sandhya Rajesh Punjabi 2,50,000 1.59 2,50,000 1.59
Kenisha Shah 2,41,200 1.53 2,41,200 1.53
Rehaan Utpal Shah 2,20,000 1AO Z.20,000 1.40
Aashna Utpal Shah Z.20,000 lAO Z.20,000 1.40
Sagar Rajesh Punja bl 1,68,700 1.07 1,68,700 1.07
Tanmay U. Shah (Huf) 1,00,600 0.64 1,00,600 0.64
Utp;al Praful Sh;ah(Huf) 32,400 0.21 28,800 0.18 12.50
Nlvedlta Vljay Vyas 1,650 0.01 "'" 0.01
Prltish Praful Shah 1,,,o65o0 0.01 "'" 0.01
Prafulbhai Shah 0.02 2,400 0.02
543Shah Investor's Home Limited
CIN: U67120GJ1994PLC023257.
Notes to the Restated Consolidated Financial Statement
22 Other Equity (" in lakhs)
As at 31 March, As at 31 March, As at 31 March,
Particulars
202S 2024 2023
Other Reserves
capital Redemption Reserve 131.68 131.68 131.68
131.68 131.68 131.68
Others
Retained Earnings
Balance as per last Financial year 1,519.52 848.18 480.47
Add : Profit for the year 2,338.50 1,793.38 763.17
Transfer From Other Comprehensive Income 1,128.38 56.60 512.81
Less : Appropriations
Transfer to Statutory Reserve maintained under
section 45-IC of RBI Act, 1934 (63.26) (21.10) (29.50)
Transfer to General Reserve (1,000.00) (800.00)
Dividend on Equity Shares (157.54) (157.54) (78.77)
4,765.60 1,519.52 848.18
Other Comprehensive Income
Balance as per last Financial year 1,957.40 341.69 1,303.45
Adjustments during the year (426.11) 1,672.31 (448.95)
Transferred to Retained Earnings (1,128.38) (56.60) (512.81)
402.91 1,957.40 341.69
Statutory Reserve
Maintained under section 45-IC of RBI Act, 1934
Balance as per last Financial year 265.60 244.50 215.00
Add: Transfer during the year 63.26 21.10 29.50
328.86 265.60 244.50
General Reserve
Balance as per last Financial year 9,604.53 8,604.53 7,804.53
Add: Transfer during the year 1,000.00 800.00
9,604.53 9,604.53 8,604.53
Total 15,233.58 13,478.73 10,170.58
23 Revenue From Operations
(a) Interest Income ('I: in lakhs)
For the period For the period For the period
Particulars ended 31 March, ended 31 March, ended 31 March,
2025 2024 2023
On Financial Assets measured at Amortized Cost
Interest on Loans 147.64 143.06 243.17
Interest on Deposits with Banks 963.29 787.15 457.87
Interest on Margin Funding 105.79
Interest on Delayed payment 1,281.32 640.93 411.85
Interest on Bonds 21.70
Interest on Late Payment on AMC Charges 5.59 7.46 7.14
Total 2,503.63 1,578.60 1,141.73
544Shah Investor's Home Limited
CIN:U67120GJ1994PLC023257
Notes to the Restated Consolidated Financial Statement
(b) Dividend Income: (" in lakhs)
For the period For the period For the period
Particulars ended 31 March, ended 31 March, ended 31 March,
2025 2024 2023
Dividend income from Investment 61.27 74.92 47.98
Total 61.27 74.92 47.98
(c) Rental Income: (~ in lakhs)
For the period For the period For the period
Particulars ended 31 March, ended 31 March, ended 31 March,
2025 2024 2023
Rental income from operating leases 10.08 8.94 6.00
Total 10.08 8.94 6.00
(d) Fees and Commission Income (~ in lakhs)
For the period For the period For the period
Particulars ended 31 March, ended 31 March, ended 31 March,
2025 2024 2023
Brokerage and Fees Income
Brokerage Income 6,491.13 5,570.20 3,702.79
Depository Income 268.06 273.00 229.67
Total 6,759.19 5,843.20 3,932.46
(e) Net gain/ (loss) on fair value changes (" in lakhs)
For the period For the period For the period
Particulars ended 31 March, ended 31 March, ended 31 March,
2025 2024 2023
On financial instruments designated at fair value through
profit or loss
Profit/(Loss) on sale of derivatives held for trade 53.99 159.52 (266.44)
Profit/(loss) on securities held for trade (0.02) (0.00) 69.76
Profit/(loss) on Mutual Fund 18.05 39.07 5.24
Total 72.02 198.59 (191.44)
Fair Value changes:
Realized 215.14 159.52 (194.24)
Unrealized gain/(loss) (143.12) 39.07 2.80
Total 72.02 198.59 (191.44)
(f) Sale of products (~ in lakhs)
For the period For the period For the period
Particulars ended 31 March, ended 31 March, ended 31 March,
2025 2024 2023
Sale of Commodities
Gross Sale 36.48 205.32
Less: Gst Recovered 1.06 5.98
Net Sale 35.42 199.34
(g) Sale of Service (~ in lakhs)
For the period For the period For the period
Particulars ended 31 March, ended 31 March, ended 31 March,
2025 2024 2023
Consultancy Income 21.20 40.48 17.13
Total 21.20 40.48 17.13
545Shah Investor's Home Limited
CIN: U67120GJ1994PLC023257.
Notes to the Restated Consolidated Financial Statement
(h) Other operating income ('I: in lakhs)
For the period For the period For the period
Particulars ended 31 March, ended 31 March, ended 31 March,
2025 2024 2023
Profit From Bond Trading 0.10 12.03
Gain/(Loss)on Sale of Bond 2.11 3.07
Total 2.21 15.10
24 Other Income (" in lakhs)
For the period For the period For the period
Particulars ended 31 March, ended 31 March, ended 31 March,
2025 2024 2023
Interest in IT refund 0.50 106.05 0.62
Other Interest 0.34 3.38 6.41
Profit/(loss) on sale of fixed assets 1.46 (22.63) 17.33
Foreign Exchange Fluctuation 3.89 2.10 16.64
LES Incentive 2.21
Business Support and other miscellaneous income 12.93 31.73 23.66
Miscellaneous Income 0.09
Total 19.12 122.93 64.66
ZS Finance Costs ('I: In lakhs)
For the period For the period For the period
Particulars ended 31 March, ended 31 March, ended 31 March,
2025 2024 2023
On Financial liabilities measured at Amortized Cost
Interest on borrowings 246.08 90.98 31.24
Total 246.08 90.98 31.24
26 Fees and Commission Expense ('I: In lakhs)
For the period For the period For the period
Particulars ended 31 March, ended 31 March, ended 31 March,
2025 2024 2023
Brokerage sharing with intermediaries 3,463.18 3,078.94 1,964.08
Brokerage & Commission Expense 1.06 0.48 0.52
Depository Charges 53.29 53.84 40.95
Exchange Transaction Charges 283.60 245.17 251.02
Total 3,801.13 3,378.43 2,256.57
27 Impairment on financial instruments (5' In lakhs)
For the period For the period For the period
Particulars ended 31 March, ended 31 March, ended 31 March,
2025 2024 2023
On Financial liabilities measured at Amortized Cost -
Impairment on Investment (0.87) (2.75)
ECLon loans (0.00) (0.02) 0.02
Impairment on Loan 22.21
Bad debts written off 0.95
Total (0.87) (1.82) 22.23
546Shah Investor's Home Limited
CIN:U67120GJ1994PLC023257
Notes to the Restated Consolidated Financial Statement
28 Employee Benefits Expenses ('I: in lakhs)
For the period For the period For the period
Particulars ended 31 March, ended 31 March, ended 31 March,
2025 2024 2023
Salary, bonus, incentives and allowances 756.10 694.06 510.29
Staff welfare expenses 45.56 33.04 61.75
Director Remuneration 321.44 340.34 359.88
Contribution to provident and other funds 16.82 15.13 15.20
Gratuity and other long term benefits 11.58 9.62 9.93
Total 1,151.50 1,092.19 957.05
29 Depreciation and amortization expense ('I: in lakhs)
For the period For the period For the period
Particulars ended 31 March, ended 31 March, ended 31 March,
2025 2024 2023
Depreciation on Property, plant & equipment 161.78 141.72 122.94
Amortization on other intangible assets 2.36 2.52 9.08
Total 164.14 144.24 132.02
30 Other Expenses ('I: In lakhs)
For the period For the period For the period
Particulars ended 31 March, ended 31 March, ended 31 March,
2025 2024 2023
Legal and Professional charges 105.06 96.30 98.95
Rent 41.03 29.99 27.01
Rates & Taxes 15.04 29.36 23.24
Advertisements expenses 17.11 3.95 10.36
Audit fees 5.15 3.65 3.60
Travelling & Conveyance Expense 67.87 33.81 25.98
Communication expense 55.79 38.26 34.51
Office expense 1.99 0.96 1.37
Demat and other charges 0.00 0.00 0.00
Municipal Tax 0.21 0.21 0.18
Interest on delay in TDS 0.01 0.01
Selling and Distribution Expense 51.28 18.35 18.91
Repairs & Maintenance
Repairs to Building 21.86 14.55 15.20
Repairs to Office Equipment 25.59 16.27 8.83
Others 15.24 15.26 24.57
Office Management expense 111.28 125.44 55.00
SEBI Fees and Other Charges 7.07 4.41 4.48
Exchange Charges 95.42 56.39 21.31
Membership Fees 10.19 3.38 6.40
Margin Shortage Interest 0.44
Stationary & Printing 7.35 6.59 4.63
Software Expense 79.50 86.90 92.05
Donation 11.64 12.11
Expenditure on Corporate Social Responsibility 41.31 36.63 29.54
Miscellaneous Expense 51.87 25.66 32.27
Director Sitting fees 0.70 0.42 0.63
Internet and Mobile Charges 0.08 0.08 0.08
Insurance Expense 5.82 4.01 3.68
547Shah Investor's Home Limited
CIN: U67120GJ1994PLC023257.
Notes to the Restated Consolidated Financial Statement
Electricity Charges 29.84 27.92 26.24
Bank Charges 67.08 68.01 53.58
Consultancy Expense 1.49 5.97 9.39
Merchant Banker License Fees 6.11
Total 944.31 764.85 638.10
30.1 Payment to Auditor as: (" in lakhs)
For the period For the period For the period
Particulars ended 31 March, ended 31 March, ended 31 March,
2025 2024 2023
Statutory Audit Fees 3.23 2.63 1.78
Taxation Matters 0.78 0.78 0.78
Other services 1.14 0.24 1.04
Total 5.15 3.65 3.60
31 Tax Expenses (~ in lakhs)
For the period For the period For the period
Particulars ended 31 March, ended 31 March, ended 31 March,
2025 2024 2023
Current Tax 831.30 591.20 257.87
Deferred Tax (28.36) 5.30 (0.92)
(Excess)/Short provision for tax relating to prior years (4.28) (1.02) (8.72)
Total 798.66 595.48 248.23
32 Earnlnss Per Share (~ In lakhs)
Year ended 31 Year ended 31 Year ended 31
Particulars
March 2025 March2024 March 2023
Profit attributable to the Equity Shareholders
A 2,338.50 1,793.38 763.17
(Rs.)
Basic/ Weighted average number of Equity
B 1,57,54,000 1,57,54,000 1,57,54,000
Shares outstanding during the period
Basic/Diluted Earnings per Share A/B 14.84 11.38 4.84
33 Related Party Disclosures
List of Related Party
Sr. No. Name Relationship
Kn: Managerial Personnel:-
1 Upendra Trikamlal Shah Chairman and Whole-time Director
2 Purnima Upendra Shah Whole-time Director
3 Trupti Utpal Shah Whole-time Director
4 Tanmay Upendra Shah Managing Director and Chief Financial Officer
5 Preeti Upendra Shah Company Secretary and Director (Director upto 19 May, 2025)
6 Utpal Praful Shah Director (Upto 7 January, 2025)
7 Ruchira Tanmay Shah Director (Upto 19 May, 2025)
8 Amit Lalitkumar Doshi Independent Director
9 Darshan Bharatbhai Patel Additional Independent Director (From 28 January, 2025)
10 Bhushan Chelaram Punani Additional Independent Director (From 12 February, 2025)
11 Bhishmak Soni Independent Director (Upto 19 May, 2025)
12 Siddharth Bharat Shah Independent Director (Upto 1 July, 2022)
13 Rajesh Ramchand Punjabi Key Managerial Personnel
14 Jinal Shah Key Managerial Personnel
15 Shamik Chokshi Key Managerial Personnel (Upto 9 September, 2023)
548Shah Investor's Home Limited
CIN: U67120GJ1994PLC023257.
Notes to the Restated Consolidated Financial Statement
Sr. No. Name Relationship
Others
1 SIHL Fincap Limited Subsidiary Company
2 Sihl Strategic Advisors Private Limited Subsidiary Company
3 Sihl Consultancy Limited Subsidiary Company
4 Sihl Global lnvestments(IFSC) Private Limited Subsidiary Company
5 Sihl Commodities Limited Associate Company (Up to 25.02.2023) & Enterprise over which key managerial
personnel or close member of their family exercise control
6 lnfinium Mines & Minerals Private. Limited Associate Company (Up to 09.08.2023) & Enterprise over which key managerial
personnel or close member of their family exercise control
7 Ficus Food Lab Private Limited Enterprise over which key managerial personnel or close member of their family
exercise control
8 Sur Management Services Private Limited Enterprise over which key managerial personnel or close member of their family
exercise control
9 Arthika Quantomics Private Limited Enterprise over which key managerial personnel or close member of their family
exercise control
10 Arbor Park LLP Enterprise over which key managerial personnel or close member of their family
exercise control
11 Stock book LLP Enterprise over which key managerial personnel or close member of their family
exercise control
12 Plera Wellness Plus LLP Enterprise over which key managerial personnel or close member of their family
exercise control
13 Playqid Enterprise over which key managerial personnel or close member of their family
exercise control
14 Upendra Shah HUF Relative of KMP
15 Sunil Mehta Relative of KMP
16 Siddharth Mehta Relative of KMP
17 Lata Manubhai Shah Relative of KMP
18 Meena Deepakbhai Mehta Relative of KMP
19 Jayshree Sudhirbhai Shah Relative of KMP
20 Malavika Ketan Shah Relative of KMP
21 Tanmay Shah HUF Relative of KMP
22 Kenisha Shah Relative of KMP
23 Vijay Manubhai Vyas Relative of KMP
24 Nivedita Vyas Relative of KMP
25 Shashin Vyas Relative of KMP
26 Utpal Shah HUF Relative of KMP
27 Prafulbhai K Shah Relative of KMP
28 Pritish P. Shah Relative of KMP
29 Aashna Shah Relative of KMP
30 Rehaan Shah Relative of KMP
31 Pearl Shah Relative of KMP
32 Rohan Amit Doshi Relative of KMP
33 Rishita Rohan Doshi Relative of KMP
34 Amit Doshi HUF Relative of KMP
35 Sonal Amit Doshi Relative of KMP
36 Rahul Amit Doshi Relative of KMP
37 Devanshi Rahul Doshi Relative of KMP
38 Bharatbhai Mohanlal Shah Relative of KMP
39 Kalpana Bharatbhai Shah Relative of KMP
40 Sahil Bharat Shah Relative of KMP
41 Meena Siddharth Shah Relative of KMP
42 Rajesh Punjabi HUF Relative of KMP
43 Harish Ramchandra Punjabi Relative of KMP
44 Parmanand Ramchandra Punjabi Relative of KMP
45 Sagar Rajesh Punjabi Relative of KMP
46 Shruti Rajesh Punjabi Relative of KMP
47 Hitika Sagar Punjabi Relative of KMP
48 Arpita Jinal Shah Relative of KMP
49 Jinal Shah HUF Relative of KMP
so Hrishika Jinal Shah Relative of KMP
51 Kanisha Jinal Shah Relative of KMP
549Shah Investor's Home Limited
CIN: U67120GJ1994PLC023257.
Notes to the Restated Consolidated Financial Statement
52 Hirai Himanshu Patel Relative of KMP
53 Shamik Harivadan Chokshi HUF Relative of KMP
54 Kinjal Shamik Chokshi Relative of KMP
55 Naksh Shamik Chokshi Relative of KMP
56 Harivadan Manharlal Chokshi Relative of KMP
57 Jyotika Harivadan Chokshi Relative of KMP
58 Jishna Shamik Chokshi Relative of KMP
59 Kaushalya Madhyani Relative of KMP
60 Niti Prakash Gera Relative of KMP
61 Sangita Rajesh Tanna Relative of KMP
62 Sandhya Punjabi Relative of KMP
(A) Transactions with Related Parties
(" in lakhs)
For the year For the year For the year
ended ended ended
Sr. No. Nature of Transaction Name of Related Party
31st March, 31st March, 31st March,
2025 2024 2023
(ii In the books of Shah Investor's Home Limited
1 Loan Given Sihl Fincap Limited 1,171.73 14,817.45
2 Loan Repayment Sihl Fincap Limited 1,171.73 14,817.45
Shamik Chokshi 4.50 3.00
3 Loan Taken Sihl Fincap Limited 17,026.61 14,228.69 14,124.97
TanmayShah 10.00
Utpal Shah 300.00
4 Loan Repaid Sihl Fincap Limited 17,026.61 14,228.69 14,124.97
Tanmay Shah 10.00
Utpal Shah 300.00
5 Interest Income Sihl Fincap Limited 0.14 1.26
6 Interest Expense Sihl Fincap Limited 170.09 95.47 8.67
7 Consultancy Fees Stock Book LLP 10.00 15.00
8 Brokerage Paid Sur Management 12.75 26.16 19.41
Services Private Limited
Arthika Quantomics 23.67
Private Limites
9 Dividend Paid Directors 117.34 121.30 61.15
KMP 6.50 6.50 3.25
Relative of 25.10 21.09 10.04
KMP/Director
10 Rent deposit accepted/(repaid) Trupti Shah (2.00) (3.00)
Ruchira Shah (2.31)
TanmayShah (0.30)
550Shah Investor's Home Limited
CIN:U67120GJ1994PLC023257
Notes to the Restated Consolidated Financial Statement
11 Reimbursement Exps Arbor Park LLP 0.02 0.03
Ruchira Shah 0.04 1.18 2.77
TanmayShah 12.08 5.41 27.05
Trupti Shah 7.32 1.13
Preeti Shah 0.08 0.03 1.40
Rajesh Punjabi 0.24
Shamik Chokshi 0.65 1.06
UtpalShah 1.64
12 Managerial remuneration paid Upendra Shah 36.00 41.00 55.08
Purnima Shah 36.00 39.90 45.36
Preeti Shah 48.00 48.00 48.00
TanmayShah 60.00 60.00 60.00
Trupti Shah 48.00 48.00 48.00
UtpalShah 50.00 60.00 60.00
Rajesh Punjabi 60.00 60.00 60.00
Jinal Shah 13.92 16.66 12.48
Shamik Chokshi 5.92 9.72
13 Salary to Relative of KMP Arpita Jinal Shah 10.08 12.03 8.88
Sandhya Punjabi 27.00 27.00 27.00
14 Rent Income Arbro Park LLP 6.00
15 Rent Expense Ruchira Shah 0.57 2.28
TanmayShah 0.43 2.28
Trupti Shah 0.25 3.00 3.00
Upendra Shah 1.44 1.44 1.44
16 Sale of Investment Sihl Commodities 145.30
Limited
Sihl Consultancy Limited 47.89
Purnima Shah 15.26
Utpal Shah HUF 101.17
TanmayShah 49.67
17 Purchase of Property TanmayShah 65.81
Ruchira Shah 74.14
18 Brokerage Income Director 1.64 14.51 0.02
Independent Director 3.21 0.04 0.05
KMP 0.36 0.84 0.04
Subsidiary 0.40 10.64 2.17
Relatives of 28.73 28.72 15.48
Directos/KMPs
Other Related Parties 1.29 3.23 5.23
19 Donation & CSR Vimal Jyot Charitable 18.50 7.50 13.50
Trust
551Shah Investor's Home Limited
CIN:U67120GJ1994PLC023257
Notes to the Restated Consolidated Financial Statement
20 Director Sitting Fees Amit Doshi 0.28 0.28 0.28
Bhishmak Soni 0.28 0.14 0.28
Siddharth Shah 0.07
Darshan Patel 0.07
Bhushan Punani 0.07
21 Outstanding Balance
Deposit Trupti Shah 2.00 2.00
Ruchira Shah 1.20
TanmayShah 0.45 0.45 0.75
Loan Taken Shamik Chokshi 4.50
(II) In the books of SIHL Strategic Advisors Private Limited
Loan Given SIHL Fincap Limited 256.83 78.15 465.67
lnfinium Mines and 11.60 86.00
Minerals Private Limited
Ficus Food Lab Private 8.16
Limited
Loan Repayment SIHL Fincap Limited 256.83 78.15 465.67
lnfinium Mines and 74.02 23.58
Minerals Private Limited
Ficus Food Lab Private 8.16
Limited
Loan Taken SIHL Fincap Limited 301.08 6.62 42.79
Ficus Food Lab Private 0.02
Limited
Loan Repayment SIHL Fincap Limited 1.08 6.62 42.79
Ficus Food Lab Private 0.02
Limited
Interest Income SIHL Fincap Limited 3.13 0.60 2.83
Ficus Food Lab Private 0.16
Limited
Brokerage paid Shah Investor's Home 0.20 0.53 0.34
Limited
Director Remmuneration Ruchira Shah (Key 11.34
Managerial Persons)
Purchase of Investments Ficus Food Lab Private 144.00
Limited
Outstanding Balance
Loan Taken SIHL Fincap Limited 300.00
Ficus Food Lab Private 0.02
Limited
Loan Given lnfinium Mines and 74.02 86.00
Minerals Private Limited
552Shah Investor's Home Limited
CIN:U67120GJ1994PLC023257
Notes to the Restated Consolidated Financial Statement
Outstanding Balance in respect of Ficus Food Lab Private 144.00 144.00 144.00
investments in related parties Limited
(iii) In the books of SIHL Consultancy Limited
Loan Given lnfinium Mines and 0.20 344.21 86.31
Minerals Private Limited
SIHL Fincap Limited 1,199.91 1,033.70 374.09
Loan Repayment lnfinium Mines and 0.20 484.02 86.00
Minerals Private Limited
SIHL Fincap Limited 1,199.91 1,033.70 374.09
Loan Taken lnfinium Mines and 3.60 78.89
Minerals Private Limited
SIHL Fincap Limited 8.99 192.00
Loan Repaid lnfinium Mines and 3.60 78.89
Minerals Private Limited
SIHL Fincap Limited 8.99 192.00
Interest Income SIHL Fincap Limited 61.54 8.15 0.80
Brokerage Paid Shah Investor's Home 0.18 2.08 0.88
Limited
Consultancy Fees Arbor Park LLP 9.91 9.91 7.43
Purchase of Investment Shah Investor's Home 47.89
Limited
Outstanding Balance
Loan Taken
Loan Given lnfinium Mines and 139.81
Minerals Private Limited
(iv) In the books of SIHL Fincap Limited
Loan Given Preeti Shah 80.30 245.81
Shah Investor's Home 17,026.61 14,228.69 14,124.97
Limited
UtpalShah 12.02
SIHL Commodities 4.21 1.62 335.17
Limited
TanmayShah 54.42 3,296.38 10,518.29
lnfinium Mines and 50.00 0.15
Minerals Private Limited
Ficus Food Lab Pvt 606.47 215.71 96.26
Limited
SIHL Consultancy 8.99 192.00
Limited
553Shah Investor's Home Limited
CIN:U67120GJ1994PLC023257
Notes to the Restated Consolidated Financial Statement
SIHL Strategic Advisors 301.08 6.62 42.79
Pvt Limited
Stock Book LLP 8.91 4,703.69
Sur Managment Service 29.53 86.46 72.28
Private Limited
Loan Repayment Preeti Shah 205.30 120.81
Shah Investor's Home 17,026.61 14,228.69 14,124.97
Limited
UtpalShah 12.02
SIHL Commodities 4.21 42.16 294.62
Limited
TanmayShah 54.42 3,296.38 10,707.29
lnfinium Mines and 50.00 0.15
Minerals Private Limited
Ficus Food Lab Pvt 209.67 3.97 96.26
Limited
SIHL Consultancy 8.99 192.00
Limited
SIHL Strategic Advisors 1.08 6.62 42.79
Pvt Limited
Stock Book LLP 8.91 4,703.69
Sur Managment Service 29.53 138.46 20.28
Private Limited
Loan Taken Preeti Shah 264.56
Shah Investor's Home 1,171.73 14,817.45
Limited
Upendra T. Shah 8.10 26.59
SIHL Commodities 47.62 7.80 410.08
Limited
TanmayShah 3,686.91 3,610.69 1,537.03
lnfinium Mines and 25.53
Minerals Private Limited
SIHL Consultancy 1,199.91 1,033.70 374.09
Limited
SIHL Strategic Advisors 256.83 78.15 465.67
Pvt Limited
Stock Book LLP 0.97 1,037.01
Sur Managment Service 2,475.01 1,364.88 446.97
Private Limited
Loan Repaid Preeti Shah 264.56
Shah Investor's Home 1,171.73 14,817.45
Limited
Upendra T. Shah 8.10 26.59
SIHL Commodities 47.62 7.80 410.08
Limited
TanmayShah 3,686.91 3,610.69 1,537.03
lnfinium Mines and 25.53
Minerals Private Limited
554Shah Investor's Home Limited
CIN:U67120GJ1994PLC023257
Notes to the Restated Consolidated Financial Statement
SIHL Consultancy 1,199.91 1,033.70 374.09
Limited
SIHL Strategic Advisors 256.83 78.15 465.67
Pvt Limited
Stock Book LLP 0.97 1,037.01
Sur Managment Service 2,475.01 1,364.88 446.97
Private Limited
Reimbursement of expenses Ruchira Shah 2.23 1.98 1.23
SIHL Commodities 0.04 0.12
Limited
Director Remuneration Ruchira Shah 43.44 43.44 32.10
Interest Income Ficus Food Lab Pvt 42.90 3.97 0.26
Limited
Preeti Shah 1.03 9.76
Shah Investor's Home 170.09 95.47 8.67
Limited
SIHL Commodities 0.07 0.31
Limited
Stock Book LLP 0.01 12.41
TanmayShah 2.43 33.97
UtpalShah 0.02
Interest Expense Shah Investor's Home 0.14 1.26
Limited
SIHL Commodities 1.09 0.52
Limited
TanmayShah 4.21
SIHL Consultancy 61.54 8.15 0.80
Limited
SIHL Strategic Advisors 3.13 0.60 2.83
Pvt Limited
Sur Managment Service 12.62 8.60 2.25
Private Limited
Preeti Shah 0.55
Rent Expense Upendra T. Shah 3.60 3.60 3.60
Brokerage Paid Shah Investor's Home 0.02 8.04 0.94
Limited
Outstanding Balance
Loan Given Preeti Shah 125.00
SIHL Commodities 40.54
Limited
Ficus Food Lab Pvt 608.54 211.74
Limited
SIHL Strategic Advisors 300.00
Pvt Limited
Sur Managment Service 52.00
555
Private LimitedShah Investor's Home Limited
CIN: U67120GJ1994PLC023257.
Notes to the Restated Consolidated Financial Statement
34 Contingent Liability and Commitment (to the extent not provided for) (" in lakhs)
Particulars As at 31 March, 2025 As at 31 March, 2024 As at 31 March, 2023
Contingent liabilities:
Bank Guarantees given 6,000.00 6,000.00 6,300.00
Demand in respect of income tax matters for
which appeal is pending 419.94 419.94 419.94
Capital commitments:
There are no Capital commitment as at the year
end.
35 Investment Property (5' In lakhs)
Particulars As at 31 March, 2025 As at 31 March, 2024 As at 31 March, 2023
Amount recognized in Statement of Profit or
loss
Investment properties Rental Income 10.08 8.34
Direct operating expenses from property that
generated rental income
Depreciation 4.42 4.65
Profit from Investment Property 5.66 3.69
Fair Value of investment property is Rs. 250 lacs and such fair value is based on the approximate estimation by the
management.
36 Due to Micro, Small, & Medium Enterprise
The Group has sent letters to vendors to confirm whether they are covered under Micro, Small and Medium Enterprise
Development Act 2006 as well as they have filed required memorandum with prescribed authority. Based on and to the
extent of the information received by the Company from the suppliers regarding their status under the Micro, Small and
Medium Enterprises Development Act, 2006 (MSMED Act) the relevant particulars as at the year end are furnished
below:
I" in lakhs)
For the year ended For the year ended 31 For the year ended 31
Particulars
31 March,2025 March,2024 March,2023
The Principal amount remaining unpaid at the
year end 3.11
The Interest amount remaining unpaid at the
year end
The amount of interest paid by the buyer under
MSMED Act, 2006 along with the amounts of
the payment made to the supplier beyond the
appointed day during each accounting year
The amount of interest due and payable for the
year (where the principal has been paid but
interest under the MSMED Act, 2006 not paid)
The amount of interest accrued and remaining
unpaid at the year end
The amount of further interest due and payable
even in the succeeding year, until such date
when the interest dues as above are actually
paid to the small enterprise, for the purpose of
disallowance as a deductible expenditure under
section 23
The balance of MSMED parties as at the year
end 3.11
556Shah Investor's Home Limited
CIN: U67120GJ1994PLC023257.
Notes to the Restated Consolidated Financial Statement
37 REVENUE FROM CONTRACT WITH CUSTOMERS
The Group derives revenue primarily from the share broking business. Its other major revenue source is Interest income.
1. Disaggregate revenue Information
The table below presents disaggregate revenues from contracts with customers for the year ended 31 March 2025, 31
March 2024 and 31 March 2023. The Group believes that this disaggregation best depicts how the nature, amount,
timing and uncertainty of revenue and cash flows are affected by market and other economic factors.
Nature of SeNices
(a) Broking Income - Income from services rendered as a broker is recognized upon rendering of the services in
1
accordance with the terms of contract.
(b) Interest Income -Interest is earned on delayed payments from clients and amounts funded to them as well as loans
as well as term deposits with banks. Interest income is recognized on a time proportion basis taking into account the
amount outstanding from customers or on the financial instrument and the rate applicable
(c) Depository Income-Income from services rendered on behalf of depository is recognized upon rendering of the
services. in accordance with the terms of contract
2. Disaggregate revenue information
(" in lakhs)
For the year ended 31 For the year ended 31 For the year ended 31
Particulars
March, 2025 March, 2024 March, 2023
Operating income :
Brokerage Income 6,491.13 5,570.20 3,702.79
Interest Income 2,503.63 1,578.60 1,141.73
Depository Income 268.06 273.00 229.67
Nature, timing of satisfaction of the performance obligation and significant payment term:
(i) Income from services rendered as a broker is recognized upon rendering of the services.
(ii) Commissions from distribution of financial products are recognized upon allotment of the securities to the applicant
or as the case may be, on issue of the insurance policy to the applicant.
(iii) Interest is earned on delayed payments from clients and amounts funded to them as well as term deposits with
banks.
(iv) Interest income is recognized on a time proportion basis taking into account the amount outstanding from
customers or on the financial instrument and the rate applicable
(v) Income from services rendered on behalf of depository is recognized upon rendering of the services, in accordance
with the terms of contract.
The above services are point in time in nature, and no performance obligation remains once the transaction is executed
38 EMPLOYEE BENEFITS
A. The Company contributes to the following post-employment defined benefit plans
(I) Defined Contribution Plans
Contribution paid/payable to the recognized provident fund and Employee State Insurance Corporation, which is a
defined contribution scheme, is charged to the Statement of Profit and Loss in the period in which they occur.
557Shah Investor's Home Limited
CIN: U67120GJ1994PLC023257.
Notes to the Restated Consolidated Financial Statement
(ii) Defined Benefit Plan :
Gratuity is post-employment benefit and is in the nature of defined benefit plan. The liability recognized in the Balance
Sheet in respect of gratuity is the present value of defined benefit obligation at the Balance Sheet date together with the
adjustments for unrecognized actuarial gain or losses and the past service costs. The defined benefit obligation is
calculated at or near the Balance Sheet date by an independent actuary using the projected unit credit method.
Actuarial gains and losses comprise experience adjustment and the effects of changes in actuarial assumptions are
recognized in the period in which they occur, directly in other comprehensive income. They are included in retained
earnings in the statement of changes in equity and in the balance sheet.
(i) Breakup of amount recognized in profit and loss
(" in lakhs)
As at 31 March, 2025 As at 31 March, 2024 As at 31 March, 2023
Particulars
Interest on defined benefit obligation 2.67 2.39 2.38
Current service cost 8.86 7.82 9.02
Total expense recognized in the statement of
profit and loss 11.53 10.22 11.40
(ii) Break up of amount recognized in other
comprehensive Income
(oi: In lakhs)
Particulars As at 31 March, 2025 As at 31 March, 2024 As at 31 March, 2023
Remeasurements of the net defined benefit
liability/ (asset)
Actuarial gains/ (losses) 25.85 3.45 (5.94)
Return on plan assets (greater) / less than (1.11) (0.50) (0.26)
discount rate
Total expense recognized in the statement of 24.74 2.94 (6.19)
other comprehensive income
(iii) Breakup of the amount recognized in
balance sheet
(oi: In lakhs)
Particulars As at 31 March, 2025 As at 31 March, 2024 As at 31 March, 2023
Present value of the obligation as at the end of (191.90) (149.78) (136.63)
the year
Fair value of plan assets as at the end of the
year 128.77 112.66 104.46
Net (liability)/A sset recognized in balance (63.13) (37.12) (32.17)
sheet
(iv) Reconciliation of defined benefit obligation and plan asset
('IC in lakhs)
Particulars As at 31 March, 2025 As at 31 March, 2024 As at 31 March, 2023
Change in benefit obligations
Present value of the obligation as at the 149.78 136.63 129.33
beginning of the year
Current service cost 8.86 7.82 9.02
Interest cost 10.77 10.17 9.04
Actuarial (gain)/loss on obligations 25.85 3.45 (5.94)
Liability Transferred Out/Divestments 0.48 1.39
Benefits paid (3.36) (8.77) (6.21)
558Shah Investor's Home Limited
CIN: U67120GJ1994PLC023257.
Notes to the Restated Consolidated Financial Statement
Benefit obligations at the end (A) 191.90 149.78 136.63
Change in plan assets
Fair value of plan assets at the beginning of the 112.66 104.46 95.20
year
Interest income on plan assets 8.10 7.77 6.66
Contributions 10.26 8.70 8.55
Benefits paid (3.36) (8.77) (6.21)
Return on plan assets greater (lesser) than 1.11 0.50 0.26
discount rate
Fair value of plan assets at the end (Bl 128.77 112.66 104.46
Amount recognized in balance sheet [(surplus)
/ deficit] (A-B) 63.13 37.12 32.17
(v) Sensitivity of significant assumptions used
for DBO valuation
(" in lakhs)
For the Year ended 31 For the Year ended 31 For the Year ended 31
Particulars
March, 2025 March,2024 March, 2023
Effect on DBO due to 1% increase in discount (9.97) (7.00) (6.37)
rate
Effect on DBO due to 1% decrease in discount 11.46 8.01 7.26
rate
Effect on DBO due to 1% increase in salary 11.44 8.02 7.29
escalation rate
Effect on DBO due to 1% decrease in salary (9.50) (7.13) (6.51)
escalation rate
(vi) Assumptions to determine the defined benefit obligations
Particulars As at 31 March, 2025 As at 31 March, 2024 As at 31 March, 2023
Discount rate 6.78% 7.19% 7.44%
Salary escalation rate (p.a.) 6.00% 6.00% 6.00%
39 Leases
Following is the information pertaining to leases,
('I: In lakhs)
For the year ended For the year ended For the year ended
Particulars
March, 2025 March, 2024 March,2023
(a) Depreciation Charge for Right-of-Use Asset 4.72 4.72 4.72
(b) Interest Expense on Lease Liability
(c ) Expenses relating to short term leases
accounted in profit & loss 41.03 29.99 27.01
(d) Total cash Outflow for Leases for the period 41.03 29.99 27.01
(e )Additions to Right-to-Use Asset
(f) Carrying Amount of Right-to-Use Asset 108.27 112.99 117.71
559Shah Investor's Home Limited
CIN: U67120GJ1994PLC023257.
Notes to the Restated Consolidated Financial Statement
Maturity Analysis of Lease Liabilities (Undicounted Amounts):
Due As at March 31,2025 As at March 31,2024 As at March 31,2023
Not later than 1 year
Later than 1 year and not later than 5 years
Later than 5 Years
Total
40 The Company has entered into a lease agreement for the Thane branch for a period of 5 years, expiring on
4th October 2029. However, in light of the management's decision to discontinue operations and close the
branch in the near future, the lease has been reassessed for the purpose of Ind AS 116 - Leases.
While the contractual lease term is 5 years, management has concluded that the branch will be closed
before the lease term expires. Given the decision to terminate the operations early, the lease has been
classified as a short-term lease for the purpose of accounting under Ind AS 116.
This classification is based on management's current intention and the expected termination of the lease
within 12 months, making it eligible for the short-term lease as per Ind AS 116. Consequently, the lease
liability and the right-of-use (ROU) asset will not be recognized on the balance sheet.
41 Additional Regulatory Information as per Companies Act, 2013
1. The title deeds, comprising all the immovable properties are held in the name of company and no
immovable property is jointly held with others
2. The company has not revalued its Property, Plant and Equipment and Intangible Assets
3. No proceeding have been initiated or are pending against the company for holding any benami
property under the Benami Transactions (Prohibition) Act, 1988 (45 of 1988) and the rules made
thereunder.
4. The Company has not traded or invested in Crypto currency or Virtual Currency during the
financial year
5. The company is not declared willful defaulter by any bank or financial Institution or other lender.
6. The company has not entered into transactions with companies struck off under section 248 of
the Companies Act, 2013 or section 560 of Companies Act, 1956.
7. The company has not applied for any Scheme of Arrangements in terms of sections 230 to 237 of
the Companies Act, 2013
8. Utilization of Borrowed funds:
(a) No funds have been advanced or loaned or invested (either from borrowed funds or any
other sources or kind of funds) by the company to or in any other person(s) or entity(ies),
including foreign entities ("Intermediaries"), with the understanding, whether recorded in
writing or otherwise, that the Intermediary shall, whether, directly or indirectly lend or
invest in other persons or entities identified in any manner whatsoever by or on behalf of
the company ("Ultimate Beneficiaries") or provide any guarantee, security or the like on
behalf of the Ultimate Beneficiaries.
(b) No funds have been received by the company from any person(s) or entity(ies), including
foreign entities ("Funding Parties"), with the understanding, whether recorded in writing
or otherwise, that the company shall, whether, directly or indirectly, lend or invest in
other persons or entities identified in any manner whatsoever by or on behalf of the
Funding Party ("Ultimate Beneficiaries") or provide any guarantee, security or the like on
behalf of the Ultimate Beneficiaries."
9. The Company has not used the borrowings from banks and financial institutions for the purpose
other than for which it was taken.
10. The Company has no transactions relating to previously unrecorded income that have been
surrendered or disclosed as income during the year in the tax assessments under the Income Tax
Act, 1961. 560Shah Investor's Home Limited
CIN: U67120GJ1994PLC023257.
Notes to the Restated Consolidated Financial Statement
42 Disclosure relating to various ratios
Additional regulatory information required under clause (xvi) of Division Ill of Schedule Ill amendment,
disclosure of ratios, is not applicable to the Company as it is in broking business and not an NBFC
registered under Section 45-IA of Reserve Bank of India Act, 1934.
43 Fair Value Measurement
1. Accounting classification and fair values
The following table shows the carrying amount and fair values of financial assets and financial liabilities,
including their levels in the fair value hierarch
lnl11khl
,.,., ,.,.,
l'ilrtlculllln ClllrJYq111111111nt l'illr\lalua
31 March 2025 FY11'< FVOCI AmonJzed COit ''''" Level 2 Level 3
FNndalll!l!lftl
cash and cash equlvalents 8,511.14 8,511.14
Bank balance other than cash and cash
equhlalents above 7,342.30 7,342.30
Recetvables
{I) Trade receivables 1,685.59 1,685.59
(11) Other receivables
1,897.30 1,897.30
lnvestlTll!nts (Excluding subsidiaries) 220.17 7,SW.10 7,7'311.27 7,453.61 7,730.27
other flnanclal assets 267.47 267A7
Total fhlndal lllllllltli 220.17 7,510.10 19,703.80 27,434.07 7,453.61 276.66 7,730.27
Fnlndal li.blltles
Payables
(I) Trade payables
(ii) total outstandina dues of micro
enterprises and small enterprises 3.11 3.11
(111) total outstandlnc dues of creditors
other than micro enterprises and small
enterprises 12,411.80 12,411.80
Borrowinp (Other than debt securities) 570.81 570.81
Other flnandal llabllltles 13.77 ,a_n
Tatel fnandal llablntlm 12,999.49 12,999A9
lnlakhl
hrtlculan CarJYq IIIIICIUnt ,.,., ,.,., FalrValua
31 March ZOZ4 Ml'L FVOCI Amortiled cost ,• •, 11 '"''
Flnandal-
CBsh and cash equivalents 13,006.98 13,006.98
Bank balance other than cash and cash
equlllelents above 4,544.86 4,544..8.6.
Recelllables ,,.
{I) Trade receivables 778.48
{Ill Other receivables
"'"' 1,319.24 1,319.24
Investments (Exdudlns subsidiaries) 177.93 7,045.72 7,223.65 6,949A5 274.20 7,223.65
other flnandal assets 282.80 282.80
TDtal fnandal IIIIINlts 177.93 7,045.72 19,932.36 27,156.01 6,949A5 274.20 7,223.65
Flnandal llablltles
Payables
(1) Trade payables
{ii) total outstandin8 dues of micro
enterprfses and small enterprfses
{111) total outstandl111 dues of creditors
other than micro enterprises and small
enterprises 13,655.46 13,6S5A6
other Payable
{l)Total Outstandllll dues of Micro and small
enterprises
{ll)Total Outstandlns dues of creditors other
than Micro small and Medium Enterprises 2.89 '·"
Borrowlnp (Other than debt securities) 353.52 353.52
other flnandal llabllltles 11.15 11.15
TDtal fnandal llablltlm 14,023.03 14,023.03
.... lnlalchs
hrtlculan CarJYq1111111unt ,.,., ,. FalrValua
31 March 2023 FVOa Amonlled COS1 Level 2 Level 3
Flnandal llllllel::I
CBsh and cash equivalents 2,837.68 2,837.68
Bank balance other than cash and cash
equMlents above 7,444.71 7,444.71
Recelvables
{I) Trade receivables 1,(195.75 1,095.75
(11) Other receivables
"'"' 1,817.24 1,8.1.7..2..4
Investments (Exdudlns subsidiaries) 4,834.00 4,,97 2.85 4,796.22 4,972.85
other flnandal assets 308.38
TDtal fnandal lllllllltli '"'-" 4,834.00 13,503.76 18,476.61 4,796.22 176.63 4,972.85
Flnandal li.blltles
Payables
Trade payables
561Shah Investor's Home Limited
CIN: U67120GJ1994PLC023257_
Notes to the Restated Consolidated Financial Statement
(I) total outstanding dues of micro
enterprises and small enterprises
(11) total outstandl111 dues of creditors
atherthan micro enterprises and small
enterprises 8,339.73 8,339.73
Other Payable
(l)Total Outstandl111 dues of Micro and small
enterprises
IH)Total Outstanding dues of creditors other
than Micro small and Medium Enterprises 3.01 3.01
Borrowllljls (Other than debt securities) "'"' '"'-"
Other flnanclal llabllltles "" 2.02
Tatal lln■nclal Hablltla& 9,148.18 9,148.18
Level 1 : Category include financial assets and liabilities that are measured in whole or significantly
part by reference to published quotes in an active market.
Level 2: Category include financial assets and liabilities that are measured using a valuation
technique based on assumptions that are supported by prices from observable current
market transactions.
Level 3: Category include financial assets and liabilities that are measured using valuation
technique based on non-market observable inputs. This means that fair value are
determined in whole or in part using a valuation model based on assumptions that are
neither supported by prices from observable current market transactions in the same
instrument nor are they based on available market data.
2. Financial instruments not measured at fair value
Financial assets not measured at fair value includes cash and cash equivalents, trade receivables,
loans and other financial assets. These are financial assets whose carrying amounts approximate
fair value, due to their short-term nature.
Additionally, financial liabilities such as trade payables and other financial liabilities are not
measured at FVTPL, whose carrying amounts approximate fair value, because of their short-term
nature.
44 Financial risk management
The Group has operations in India. Whilst risk is inherent in the group's activities, it is managed through an
integrated risk management framework, including on-going identification, measurement and monitoring,
subject to risk limits and other controls. This process of risk management is critical to the Group's
continuing profitability and each individual within the Company is accountable for the risk exposures
relating to his or her responsibilities. The Group is exposed to credit risk, liquidity risk and market risk. It is
also subject to various operating and business risks.
A. Credit risk
Credit risk is the risk that the Company will incur a loss because its customers or counterparties
fail to discharge their contractual obligation. The Company manages and controls credit risk by
setting limits on the amount of risk it is willing to accept for individual counterparties, and by
monitoring exposures in relations to such limits.
The maximum exposure to credit risk for each class of financial instruments is the carrying
amount of that class of financial instruments presented in the financial statements. The
Company's major classes of financial assets are cash and cash equivalents, loans, investment in
mutual fund units, term deposits, trade receivables and security deposits.
Deposits with banks are considered to have negligible risk or nil risk, as they are maintained with
high rate banks/financial institutions as approved by the Board of directors.
562Shah Investor's Home Limited
CIN: U67120GJ1994PLC023257.
Notes to the Restated Consolidated Financial Statement
Investments primarily include investment in liquid mutual fund units that are marketable
securities of eligible financial institutions for a specified time period with high credit rating given
by domestic credit rating agencies.
The management has established accounts receivable policy under which customer accounts are
regularly monitored. The Company has a dedicated risk management team, which monitors the
positions, exposures and margins on a continuous basis.
Following provides exposure to credit risk for trade receivables and Loans. (" in lakhs)
Particulars As at 31 March, 2025 As at 31 March, 2024 As at 31 March, 2023
Trade Receivable (Net of impairment) 1,685.59 778.48 1,095.75
Loans (Net of impairment) 1,897.30 1,319.24 1,817.24
The financial instruments covered within the scope of ECL include financial assets measured at
amortized cost such as trade receivables and loans.
Trade Receivables :
The Company applies the Ind AS 109 Simplified approach for trade receivables which requires expected
lifetime losses to be recognized
Inputs considered in the ECL model
In assessing the impairment of financial assets under Expected Credit Loss (ECL) Model, the assets have
been segmented into three stages. The three stages reflect the general pattern of credit deterioration of a
financial instrument. The differences in accounting between stages, relate to the recognition of expected
credit losses.
Stage 1 : Trade receivable for which credit risk has not increased significantly and that are also not
credit impaired
Stage 2 : Trade receivable for which credit risk has increased significantly but not credit impaired
Stage 3 : Trade receivable for which credit risk has increased significantly and are credit impaired
Loans :
Loans includes Margin Trading Facility(MTF), Loans to staff and loans to subsidiaries for which staged
approach is taken into consideration for determination of ECL.
Stage 1.
All positions in the MTF loan book are considered as stage 1 asset for computation of expected credit loss.
For exposures where there has not been a significant increase in credit risk since initial recognition and
that is not credit impaired upon origination. Margin trading facility, Loans to subsidiaries and loans to staff
are considered in stage 1 for determination of ECL. Exposure to credit risk in stage 1 is computed
considering historical probability of default, market movements and macro-economic environment.
Margin trading facilities are secured by collaterals. As per policy of the Company, margin trading facilities
to the extent covered by collateral and servicing interest on a regular basis is not considered as
due/default. Accounts becoming due/default are fully written off as bad debt against respective
receivables and the amount of loss is recognized in the Statement of Profit and Loss. Subsequent
recoveries of amounts previously written off are credited to the Statement of Profit and Loss as bad debts
recovered.
Stage 2.
563Shah Investor's Home Limited
CIN: U67120GJ1994PLC023257.
Notes to the Restated Consolidated Financial Statement
Exposures under stage 2 include over dues up to 90 days pertaining to principal amount, interest and any
other charges on the MTF loan book which are unsecured. While arriving at chthe secured position of the
client, management would also consider balance in client's family accounts, securities in other segment
and collaterals in form other than the securities while considering the secured position of the client. At
each reporting date, the Company assesses whether there has been a significant increase in credit risk for
financial assets since initial recognition. In determining whether credit risk has increased significantly
since initial recognition, the Company uses days past due information and other qualitative factors to
assess deterioration in credit quality of a financial asset.
For credit exposures where there has been a significant increase in credit risk since initial recognition but
that are not credit impaired, a lifetime ECL is recognized.
Stage 3
Exposures under stage 3 include over dues past 90 days pertaining to principal amount, interest and any
other charges on MTF loan book which are unsecured.
Financial assets are assessed as credit impaired when one or more events that have a detrimental impact
on the estimated future cash flows of the asset have occurred. For financial assets that have become
credit impaired, a lifetime ECL is recognized.
B. Liquidity risk
Liquidity risk is the risk that the entity will encounter difficulty in meeting the obligations associated with
its financial liabilities that are settled by delivering cash or another financial asset. The entity's approach
to managing liquidity is to ensure, as far as possible, that it will have sufficient liquidity to meet its
liabilities when they are due, under both normal and stressed conditions, without incurring unacceptable
losses or risking damage to the entity's reputation.
Prudent liquidity risk management requires sufficient cash and marketable securities and availability of
funds through adequate committed credit facilities to meet obligations when due and to close out market
positions.
Ultimate responsibility for liquidity risk management rests with the board of directors, for the
management of the Company's short, medium and long-term funding and liquidity management
requirements. The Company manages liquidity risk by maintaining adequate reserves, banking facilities
and reserve borrowing facilities, by continuously monitoring forecast and actual cash flows, and by
matching the maturity profiles of financial assets and liabilities.
The table below provide details regarding the contractual maturities of significant financial liabilities as of
March 31,2025
(" in lakhs)
Particulars Carrying amount Less than 1 year 1-3 year
Trade Payable 12,420.45 12,420.45
Borrowings 570.81 529.84 40.97
Other financial Liabilities 13.77 13.77
The table below provide details regarding the contractual maturities of significant financial liabilities as of March 31,2024
(" In lakhs)
Particulars Carrying amount Less than 1 year 1-3 year
Trade Payable 13,658.35 13,658.35
Borrowings 353.52 353.52
Other financial Liabilities 11.15 11.15
564Shah Investor's Home Limited
CIN: U67120GJ1994PLC023257.
Notes to the Restated Consolidated Financial Statement
The table below provide details regarding the contractual maturities of significant financial liabilities as of March 31,2023
(" in lakhsl
Particulars Carrying amount Less than 1 year 1-3 year
Trade Payable 8,342.74 8,342.74
Borrowings 803.42 803.42
Other financial Liabilities 2.02 2.02
C. Market risk
Market Risk is the risk that the fair value or future cash flows of financial instruments will fluctuate due to
changes in market variables such as interest rates, foreign exchange rates, etc. The objective of market risk
management is to manage and control market risk exposures within acceptable parameters, while
maximizing the return.
(i) Currency risk
Currency Risk is the risk that the value of a financial instrument will fluctuate due to changes in foreign
exchange rates. The company's all transactions are denominated in Indian rupees only. Hence, the
Company is not significantly exposed to currency rate risk.
(ii) Interest rate risk
Interest Rate Risk is the risk that the fair value or future cash flow of a financial instrument will fluctuate
as result of changes in market interest rates. The Company's Loans are primarily in fixed interest rates.
Hence, the Company is not significantly exposed to interest rate risk.
(iii) Market price risks
The Company is exposed to market price risk, which arises from FVTPL investments. The management
monitors the proportion of these investments in its investment portfolio based on market indices.
Material investments within the portfolio are managed on an individual basis and all buy and sell
decisions
are approved by the appropriate authority
45 Capital Management
Risk management
The Group's objectives when managing capital are to safeguard their ability to continue as a going
concern, so that they can continue to provide returns for shareholders and benefits for other
stakeholders, and maintain an optimal capital structure to reduce the cost of capital.
The Group monitors its capital by using gearing ratio, which is net debt to total equity. Net debt includes
borrowings net of cash and bank balances and total equity comprises of Equity share capital, general
reserve and retained earnings. (" in lakhsl
Particulars As at 31 March, 2025 As at 31 March, 2024 As at 31 March, 2023
Gross Debt 570.81 353.52 803.42
Less : Cash and cash equivalents 8,511.14 13,006.98 2,837.68
Net debt(A) (7,940.33) (12,653.461 (2,034.26)
Total equity (Bl 16,906.23 15,148.73 11,811.43
Gearing ratio (A/Bl (0.471 (0.84) (0.171
46 Maturity analysis of assets and liabilities
The table below shows an analysis of assets and liabilities analyzed according to when they are expected
to be recovered or settled.
565Shah Investor's Home Limited
CIN:U67120GJ1994PLC023257
Notes to the Restated Consolidated Financial Statement
...
..... ('llnlakh1J
As R :U. Mlrdl, 2025 ,_, As at 31 March, ZOZ4 Al at 31
_
M■.,r,c,h,, 21123 ,_,
-- Pa11culars Wllhln 12 manthl Aftar12 IIIDlllhl Wllh~ 12..-lhs After12 malllhl ""' Whhln12
Fln1nd1I Aslets ........ ,..,., ...
C.,ih ;ind C.,sh Equlv.ilents 8,511.14 8,511.14 13,00.6..9.8. 2,837.68
Bank Balance other than (ii) above 4,666.00 2,676.30 7,342.29 3,m.02 m ... '·,"," "" '""" 3,491.34 7,444.71
Receivables 1,685.59 1,685.59 """ 1,095.75 ""'·"
Co= 1,897.30 1,897.30 1,319.24 1,319.24 1,817.24 1,.81.7..2 4
Olll tl hll e!s rt m Fle nn ;,l n:I
d ;,I illS5ets
,.,.,. ., .,
,
7, "73 '/J ·.2 "7 ,7 ,, _7 23 6/ 7J ,,.2 4,7
7 "'°"n
7, "22 '3 ·.6 "5 7,, 2. 2, 3. .6., 5 .,. .... 4,9 37 02 8. .8 35
8
,4 ., .39 ,07 82 .. 38 ,85
10,&73.75 8,:il.79.Z9 Z1,15l!i.01 '"""
,..,.,,,.
NDn-Flmndlll ■-
Praperty, Plant and llquipml!llt 2,103.74 2,103.74 2,085.66 2,11115.66 2,067.15
Capital work-In-progress ",',·.,". 107.54 "·" 39.84 7.23 '·"
Intangible usets under development "·" "·" 13.94 '·"' '·"'
Other Intangible asaet ,,..,
OC tu hr lr !Ie " n nt ota n> -< fia ns as ne cb i a(N l ae st s) l! l::s . 12. 32 80. ... 63. 80 , .. ".. ," . ,.2 2.,2 3,0 2,. .3 4,0 4. .,2,.1.7.. ....7, ..2, ,,,, ,.2 2. 11 . 1.1 .. 6.n , 9 67.17 245.29 ,. 32. 15. 26. ... 44,7 6
,..,,, ,.2 .,D ..Z ,,.9 ,1 . ,..' ." ,," .." , Z,JZl.17 ,,,.....,
T-IAINI 17,111.30 12,5192.73 311,112.03 251,724. 11,IIU.7!
U■bllltll!I
F Tl rn a1 dn ed 1 PI a U ya■ bbl lel slt la "-""·" ..., "-""·" "'".. '. ' 13,658.35 8,.3,4,. 2... 7.. 4, 8,342.74
"'""""" ""'"' ""·" "'"' 41.64 353.52 ""·"
Otherfinandal LiabilitiH 11.55 rn u..n. 2.19 11.15 '" '·"
,,,,,. ... ..., ,.,,.,. ..... ,...,..,,
13,979.19 1,147.12 "" 9,148.18
Nlllt-Flmnd■I U■bllllltl1 ,.,. ,.,.,
Defem!d m:llablHties (Net] 78.70 367A7 71.02 71.02
Current ta.: liabilities (Net) 15.n 15.n 7.16 '·"
Pruv:isio:ns 166.76 166.76 ""'" """" ""' 91.07
Other 110D.-IIDandal ll■bWtles ,,",'.". ,..,. ,." ..' ,". .1.21...0,9 ,.,., ,1.21..,0.9 ""' "·"
,.,.,, .... ,. ... ..".."..". """ ,." ,,' .· ,." .
Tami Uabllllm H,117.111 "'"'" """' ",ffl,0 """
47 Additional Disclosure pertaining to Subsidiaries as per division Ill of Companies Act, 2013
.....
('!lnlakhll)
.....
NetAssets p.e. Totel Assets-TOUI .. S. h. llr. e In Profit• (Loss) S .hi .r .e .In . o ther comprehensive Shere In Totel comprehensive
l.labllltles) Income
........
N■maafth■■ntlty ,.. .. ,
As "af Conlllllld■led 'Unl111h1 Conlllllklalai Profit/ "lnlakhl eanso11c1at■c1 oa "lnl■llhl CanllT llo llb di ■ tad "lnlallhl
Income
'"~"'
Shah lnvedor's Home Limited "'" 15,253.59 101.67 2,380.56 91.27 @89.30) 103.98 1,991.26
SUbTotallA) 90.22 15,253.59 101.67 2,380.56 91.27 (389.30) 103.98 1,991.26
SUblldlarles ..
S SI IH HL
L
cF oln nc sa up
l
tU anm ct yte Ld
i mited
1 4,0 .. .23 ,86 1, 77 25 3L .3 1S
1
{I0 1. .3 30 5)
)
(3(6 1. .9 7,5 0)
)
8 0. .3 935 (3 (5 3.. 96 71 }) ( (2 1. .2 82 6)
)
( (4 3,2 5. .. S 6. 76.)
)
SIHL strategic Advisors Private Limited """ 0.20 (0.65) rn 0.39
SIHL Global IFSC Private Limited j0.49j !83.161 !0,34j j8.04) j.O,A.2 ) !8,04j
s Nu ob
n
T -co ot mal
r
I oB lJ
l lng Interest
1 05 .. 50 80 2,5 ,'3 7,6 .,. >.,2
5,
.6 j 0l. .8 10 3) !4, ,2. ..0, ,6,
,
) o8. .6 w3 !3 (O6. A8 1! )) j.4.,1.2J tz! ,'! ·.. 8."7. !
SUbTotal(C) 0.S8 .. 0.13 0.10 (OA1)
Less-lntercompany Elimination and ,.,.
COnsolldatlon AdJustmenu 5.80 ,.,.
SUb Tot■I (DJ 5.80
Total(A+&+C-DJ 100.00 16,906.23 100.00 2,34L56 100.00 {426.52) 100.00 1,915.04
566Shah Investor's Home Limited
CIN: U67120GJ1994PLC023257.
Notes to the Restated Consolidated Financial Statement
48 Principles and assumptions used for consolidated financial statements and proforma adjustments
The Consolidated Financial Statements have been prepared by applying the principles laid in the Indian
Accounting Standard(lnd AS) - 110 "Consolidated Financial Statements" for the purposes of these
Consolidated Balance Sheet and Consolidated Statement of Profit and Loss, together referred to in as
'Consolidated Financial Statements'.
49 Operating Segment
The Group determines Operating Segments as components of an entity for which discrete financial
information is available that is evaluated regularly by the chief operating decision-maker (CODM), in
deciding how to allocate resources and assessing performance.
The Group's activities revolve around the distribution of Financial Products i.e. Mutual Funds, Bonds,
Insurance, Stock Broking and allied services, etc. Various financial products are aggregated into one
reportable segment being agency nature of the business under "Fees and Commission" in accordance
with aggregation criteria. Aggregation is done due to the similarities of the products and services provided
to the customer and similarities in the method used to provide services.
Considering the nature of the Group's business, as well as based on reviews by CODM to make decisions
about resource allocation and performance measurement, there is only one reportable segment in
accordance with the requirements of Ind AS - 108 -"Operating Segments", prescribed under Companies
(Indian Accounting Standards) Rules, 2015.
50 CORPORATE SOCIAL RESPONSIBILITY
('I in lakhs)
Year Ended 31 March, Year Ended 31 March, Year Ended 31 March,
Particulars 2025 2024 2023
(a) Total amount required to be spent during the
year 37.26 36.09 29.25
(b) Total amount of expenditure incurred during
the year 41.31 36.63 29.54
(c) Shortfall at the end of the year - -
(d) Total amount of previous years shortfall - -
(e) Reason for shortfall NA NA NA
(f) Nature of CSR activities Refer Note 1 Refer Note 1 Refer Note 1
(g) Details of related party transactions NA NA NA
{h) Where a provision is made with respect to a NA NA NA
liability incurred by entering into a contractual
obligation, the movements in the provision
during the year should be shown separately
Note 1: The Ministry of Corporate Affairs has notified Section 135 of the Companies Act, 2013 on
Corporate Social Responsibility with effect from 1 April 2014. As per the provisions of the said
section, the Company has undertaken the following CSR initiatives during the financial year 2024
-25. CSR initiatives majorly includes supporting under privileged in education, medical treatments,
etc. and various other charitable and noble aids.
567Shah Investor's Home Limited
CIN: U67120GJ1994PLC023257.
Notes to the Restated Consolidated Financial Statement
51 Taxation
(5' In lakhs)
For the year ended For the year ended For the year ended
Particulars March 31, 2025 March 31, 2024 March 31, 2023
Current Tax
Current tax on profit for the year 826.16 589.47 238.02
Tax on OCI 152.76 3.95 54.53
Total current tax expense 978.92 593.42 292.55
Deferred Tax
Decrease/ (Increase) in deferred tax assets (28.36) 5.30 (0.92)
Total deferred tax expenses/ benefit (28.36) 5.30 (0.92)
Total Income Tax Expenses 950.57 598.71 291.63
Effective Tax Rate Reconciliation
Applicable Tax Rate (%) 25.17 25.17 25.17
Profit before tax as per P&L 3,283.33 2,361.59 985.90
Add: Loss from Subsidiary Company 8.04 6.72 14.38
Profit before tax liable to tax 3,291.37 2,368.31 1,000.28
Profit on income at different rates 1,056.91 53.11 779.70
Tax on Special rate 15.07 0.40 5.05
Tax Expenses as per above rate 801.06 593.06 231.80
Tax Impact Due to:
Expenses (Allowed)/Disallowed 10.02 (3.98) 1.16
Tax on OCI 152.76 3.95 54.53
Total Current Tax 978.92 593.42 292.55
Deferred Tax (28.36) 5.30 (0.92)
Total Deferred Tax (28.36) 5.30 (0.92)
Total Tax Expenses Recognised 950.57 598.71 291.63
52 Note no The list of subsidiaries in the consolidated financial statement are as under :-
Shah Investor's Home Limited ('the Company' or 'the holding company') shareholding in the following companies as on
March 312025, March 31, 2024 and March 31, 2023 is as under:
Name of Entitles Country of Incorporation As at 31 March, ZOZS As at 31 March, 2024 As at 31 March, 2023
Name of the Subsidiary Companies
SIHL Fincap Limited India 100% 100% 100%
SIHL Consultancy Limited India 90.66% 90.66% 90.66%
SIHL Strategic Private Limited India 100% 100% 100%
SIHL Global IFSC Private Limited India 100% 100% 100%
568Shah Investor's Home Limited
CIN: U67120GJ1994PLC023257.
Notes to the Restated Consolidated Financial Statement
53 Events after Reporting Date
There were no significant events after the end of the reporting period which require any adjustment or
disclosure in the financial statements.
54 Previous year figures have been regrouped/reclassified wherever necessary.
55 First-time adoption of Ind-AS
Transition to Ind AS
As stated in Significant Accounting Policies these are the first financial statements prepared in accordance
with Ind AS. For the year ended 31st March, 2025 the Group had prepared its financial statements in
accordance with the Accounting Standards specified under Section 133 of the Companies Act, 2013 ("the
Act") read with rule 7 of the Companies (Accounts) Rules, 2014 and the other relevent provisions of the
Act.
The accounting policies set out in Significant Accounting Policies have been applied in preparing these
financial statements for the year ended 31st March, 2025 including the comparative information for the
year ended 31st March, 2024 amd 31st March 2023 and the openingmlnd AS balance sheet on the date of
transition i.e 1st April, 2022.
In preparing its Ind AS balance sheet as at 1st April, 2022 and in presenting the comparative information
for the year ended 31stMarch, 2024 and 31st March 2023 ,the Group has adjusted amounts reported
previously in financial statements prepared in accordance with IGAAP.
This note explains the principal adjustments made by the Group in restating its financial statements
prepared in accordance with IGAAP and how the transition from IGAAP to Ind AS has affected the Group's
financial position, financial performance and cash flows.
Set out below are the applicable Ind AS 101 optional Exemptions and Mandatory Exceptions applied in the
transition from IGAAP to Ind AS:
A. Exemptions and Exceptions availed
A.1. Ind AS optional exemptions
A.1.1 Deemed cost of property, plant and equipment and intangible assets
The Group has elected to continue with the carrying value of all its property, plant and equipment's and
intangible assets recognised as of 1st April, 2022 measured as per the previous GAAP and use that
carrying value as its deemed cost on transition date.
A.1.2 Business Combination
I. The Group has elected not to apply Ind AS 103 Business Combinations retrospectively to past
business combinations that occurred before the date of transition to Ind AS. Consequently, the
Group has kept the same classification for the past business combinations as in its IGAAP financial
Statements.
ii. The Group has tested the goodwill for impairment at the date of transition based on the
conditions as of the date of transition.
A.1.3 Cumulative Translation Differences on foreign operations
As per Ind AS 101, an entity may deem that the cumulative translation differences for all foreign operation
to be zero as at the date of transition by transferring any such cumulative difference to retained The
Group has elected to avail of this exemption.
A.1.4 Long Term Foreign Currency Monetary Items
The Group has opted for the exemption given in para D-13 AA of Ind AS 101 in respect of long term
569Shah Investor's Home Limited
CIN: U67120GJ1994PLC023257.
Notes to the Restated Consolidated Financial Statement
foreign currency monetary items. The exchange differences arising on reporting of long term foreign
currency items at rates different from those at which they were initially recorded during the period or
reported in previous financial statements, in so far as they relate to the accquisition of a depreciable capital
asset are added to or deducted from the cost of the asset and are depreciated over the balance life of the
asset.
A.2. Ind AS Mandatory exceptions
The Group has applied the following exceptions from full retrospective application of Ind AS which are
mandatorily required under Ind AS 101:
A.2.1 Estimates
As per Ind AS 101 , an entity's estimates in accordance with Ind AS at the date of transition to Ind AS
presented in the entity's first Ind AS financial statements as the case may be, should be consistent with
estimates made for the same date in accordance with the IGAAP unless there is objective evidence that
those estimates were in error. However, the estimates should be adjusted to reflect any differences in
accounting policies.
Derecognition of financial assets and financial liabilities
A.2.2 Classification and measurement of financial assets
Classifications and Measurement of Financial Assets Ind AS 101 requires an entity to assess classification
and measurement of financial assets on the basis of facts and circumstances that exists at the date of
transition to Ind AS. The Group has assessed classification and measurement of financial assets on the
basis of facts and circumstances that exist as on transition date.
A.2.3 Impairment of financial assets
The Group has applied impairment requirements of Ind AS 109 retrospectively; however, as permitted by
Ind AS 101, it has used reasonable and supportable information that is available without undue cost or
effort to determine the credit risk at the date that financial instruments were initially recognised in order
to compare it with the credit risk at the transition date.
A.2.4 Derecognition of financial assets and liabilities
As per Ind AS 101, an entity should apply the derecognition requirements in Ind AS 101, Financial
Instruments, prospectively for transactions occurring on or after the date of transition to Ind AS. However,
an entity may apply the derecognition requirements retrospectively from a date chosen by it if the
information needed to apply Ind AS 109 to financial assets and financial liabilities derecognized as a result
of past transactions was obtained at the time of initially accounting for those transactions. The Group has
elected to apply the derecognition principles of Ind AS 109 prospectively.
570Shah Investor's Home Limited
CIN: U67120GJ1994PLC023257.
Notes to the Restated Consolidated Financial Statement
55.1 (I) Reconclllatlon of total equity between previous GAAP and Ind AS:
(~ In lakhs)
Year Ended 31 Year Ended 31
Partlculars
March, 24 March, 23
Total Equity under previous GAAP 13,005.70 11,355.11
IND AS Adjustments:
Fair Valuation of Investments 2,565.83 623.03
Recognition of Gratuity Liability as per Acturial Valuation (1.43) (1.42)
Preliminary Expenses Adjustment (1.02)
Deferred tax Impact on IND AS Adjustments (354.97) (65.64)
Impact on loans (161.00) (164.06)
Impact of expected credit loss (0.01) (0.02)
Total IND AS Adjustments 2,048.43 390.87
Total Equity under Ind AS 15,054.13 11,745.98
(11) Reconciliation of profit as per Ind AS with profit reported under previous GAAP:
(~ In lakhs)
Year Ended 31 Year Ended 31
Partlculars
March, 24 March, 23
Net profr t as per the Previous GAAP 1,825.31 1,262.50
IND AS Adjustments:
Fair valuation of Investments (19.83) (563.18)
Preliminary Expenses Adjustment 1.02 1.02
Recognition of Gratuity Liability as per Acturial Valuation 2.91 (7.73)
Deferred tax impact on IND AS Adjustments (4.20) 47.88
Impact of expected credit loss (0.01) (0.02)
Other Adjustmnets 27.30
Total IND AS Adjustments (20.11) (494.73)
Net profit after tax (before OCI) as per Ind AS 1,805.20 767.77
Other comprehensive Income (net of tax) 1,689.64 (452.30)
Total Comprehensive Income under Ind AS 3,494.84 315.47
(iii) Reconciliation of cashflow
(~ In lakhs)
Particulars Net Cash flows from Net Cash flows Net Cash Net Increase In Cash
Operating Activities from Investing flows from and Cash Equivalents
Activities Financing
Activities
For F.y. 2022-23
As per Previous GAAP 1,592.58 (3,334.57) 51.54 (1,690.45)
Effect of transition to Ind AS(Refer Footnote) (1,592.13) 1,345.74 638.25 391.86
As per Ind AS 0.45 (1,988.83) 689.79 (1,298.59)
For F.y. 2023-24
As per Previous GAAP 6,673.02 4,050.60 (169.14) 10,554.48
Effect of transition to Ind AS(Refer Footnote) 4,346.41 (4,202.77) (528.81) (385.18)
As per Ind AS 11,019.42 (152.17) (697.95) 10,169.30
571Shah Investor's Home Limited
CIN: U67120GJ1994PLC023257.
Notes to the Restated Consolidated Financial Statement
(iv) Notes on reconciliations between previous GAAP and Ind AS:
(a) Expected credit allowance on Loan
Under Ind AS, impairement allowance has been determined based on forward-looking expected
credit loss (ECL) model which has lead to an increase in the amount of provision as on the date of
transition. The Company chose to calculate impairment allowance under simplified approch for
loans where the company does not separately track changes in credit risk.
(b) Investment other than Investment in Subsidiaries
Under previous GAAP, Investments were valued cost. Under Ind AS the investment in Equity
Shares & Mutual Funds are classified as financial asset measured at fair value through Other
comprehensive income and profit & loss respectively. Accordingly , the impact of difference in
carrying amount as per previous GAAP and fair value as on reporting date has been taken in
respective periods.
(c) Actuarial gains and losses
The impact is on account of measurement of employee benefits obligations as per Ind AS 19.
Under previous GAAP, acturial gains and losses were recognised in profit and loss. Under Ind AS,
the acturial gains and losses forming part of remeaurement of the net defined liability/asset, are
recognised in the Other Comprehensive Income (OCI) under Ind AS instead of Profit or loss.
(d) Deferred Tax
The previous GAAP requires deferred tax accounting tax accounting using the income statement
approach, which focuses on differences between taxable profits and accounting profits of the
period. Ind AS 12 requires entities to account for deferred taxes using balance sheet approach
which focuses on temporary differences between the carrying amout of an asset or liability in the
balance sheet and its tax base. Various transitional adjustments has resulted in recognition of
temporary differences.
(e) Effect of transition to Ind AS on Standalone Cash flow Statement
Net increase in cash and cash equivalents represents movemnet in cash credit facilities considered
as a component of cash and cash equivalents under Ind AS which as per previous GAAP, was
considered as financing activity. Other Ind AS Adjustments are either non cash adjustments or are
regroupng among the cash flows from operating, investing and financing activities and has no
impact on the net cash flow for the year ended 1st April, 2022 as compared with the previous
GAAP.
56. Approval of Financial Statements
The consolidated financial statements are approved for issue by the Board of Directors of parent Company
in their meeting held on September 5,2025.
572Shah Investor's Home Limited
CIN: U67120GJ1994PLC023257.
Notes to the Restated Consolidated Financial Statement
57 Statement of Adjustments to Audited Consolidated Financial Statements and Audited Special Purpose Ind AS Combined Financial
Statements
Reconclllatlon between audited equity and restated equity
(' In lakhs)
Sr. Particulars Note No. Asat Asat Asat
No March 31, March 31, 2024 March 31,
2025 2023
A. Total Equity as per Audited Consolidated Financial Statements and 16,808.98 15,054.13 11,745.98
Audited Special Purpose Ind AS Combined Financial Statements
B. Adjustments:
Material restatement adjustments
(i) Audit qualifications
(ii) Adjustments due to prior period items/other adjustment
(iii) Deferred tax impact on adjustments in {i) and (ii), as applicable
(iv} Change in accounting policies
C. Total Impact of adjustments (l+ll+lll+lv)
D. Total equity as per restated consolidated financial information (A+C) 16,808.98 15,054.13 11,745.98
Reconciliation between audited profit/(loss) and restated profit/ (loss) :
I" In lakhs)
Sr. Particulars Note No. Asat Asat Asat
No March 31, March 31, 2024March 31,
2025 2023
A. Profit/(Loss) after tax as per Audited Consolidated Financial 2,341.56 1,805.20 767.77
Statements and Audited Special Purpose Ind AS Combined
Financial Statements
B. Adjustments:
Materlal restatement adjustments
(i) Audit qualifications
(ii) Adjustments due to prior period items/other adjustment
(iii) Deferred tax impact on adjustments in (i) and (ii), as applica
ble
(iv) Change in accounting policies
C. Total Impact of adjustments (l+ll+lll+lv)
D. Restated profit/ (loss) after tax as per Restated Consolidated 2,341.56 1,805.20 767.77
Flnanclal Information (A+C)
573Shah Investor's Home Limited
CIN: U67120GJ1994PLC023257.
Notes to the Restated Consolidated Financial Statement
Note to adjustment :
(i) Audit qualifications -There are no audit qualifications in auditor's report for the financial years ended March
31, 2025, March 31, 2024 and March 31, 2023.
(ii) Material regrouping/reclassification - No material regrouping/reclassification have been made in the
Restated Consolidated Statement of Assets and Liabilities, Restated Consolidated Statement of Profit and
Loss and Restated Consolidated Statement of Cash Flows, wherever required, by reclassification of the
corresponding items of income, expenses, assets, liabilities and cash flows, in order to bring them in line with
the accounting policies and classification as per the Audited Consolidated Financial statements for the year
ended March 31, 2025 prepared in accordance with Schedule Ill (Division Ill) of the Act, as amended,
requirements of Ind AS 1- 'Presentation of financial statements' and other applicable Ind AS principles and
the requirements of the Securities and Exchange Board of India (Issue of Capital and Disclosure
Requirements) Regulations, 2018, as amended.
(iii) Material errors - There were no material errors in Audited Consolidated Financial Statements for the year
ended March 31, 2025, Audited Special Purpose Ind AS Combined Financial Statements for the financial years
ended March 31, 2024 and March 31, 2023 requiring any adjustments in Restated Consolidated Financial
Information.
As per our report attached For and on behalf of board of directors
For, Dhrumil A. Shah & Co. Upendra T. Shah
Chartered Accountants
FRN : 145163W Chairman
DIN:00023057
Dhrumil Ashit Shah Tanmay U. Shah CS Preeti U Shah
Proprietor
Membership No. : 166079
Place : Ahmedabad Managing Director/CFO Company Secretary
Date: 05/09/2025 DIN:00023067 ICSI Mem. No. A17463
574OTHER FINANCIAL INFORMATION
In accordance with the with Schedule VI, Part A (11)(I)(A)(ii)(b) of the SEBI ICDR Regulations, the audited
financial information of our Company for the financial years ended March 31, 2025, March 31, 2024 and March
31, 2023 (collectively, the “Audited Financial Information”) is available on our website at https://www.sihl.in/.
Our Company is providing a link to this website solely to comply with the requirements specified in the SEBI
ICDR Regulations. The Audited Financial Information do not and will not constitute, (i) a part of this Draft Red
Herring Prospectus; (ii) the Red Herring Prospectus or (iii) the Prospectus, a statement in lieu of a prospectus, an
offering circular, an offering memorandum, an advertisement, an issue or a solicitation of any issue or an issue
document or recommendation or solicitation to purchase or sell any securities under the Companies Act, the SEBI
ICDR Regulations, or any other applicable law in India or elsewhere. The Audited Financial Information should
not be considered as part of information that any investor should consider subscribing for or purchase any
securities of our Company and should not be relied upon or used as a basis for any investment decision. Due
caution is advised when accessing and placing reliance on any historic or other information available in the public
domain.
None of our Company or any of its advisors, nor BRLM nor any of their respective employees, directors, affiliates,
agents or representatives accept any liability whatsoever for any loss, direct or indirect, arising from any
information presented or contained in the Audited Financial Information, or the opinions expressed therein.
The accounting ratios of our Company as required under Clause 11 of Part A of Schedule VI of the SEBI ICDR
Regulations are given below:
Sr. For the year ended For the year ended For the year ended
Particulars
No. March 31, 2025 March 31, 2024 March 31, 2023
1 Basic and diluted Earnings per share (in ₹) 14.84 11.38 4.84
2 Return on Net Worth (RoNW) (in %) 13.91% 11.91% 6.50%
3 Net asset value per share (in ₹) 106.70 95.56 74.56
4 EBITDA (in ₹ lakhs) 3,531.31 2,512.97 1,114.59
Notes:
1. Basic EPS means net profit after tax attributable to owners of the Company, as restated / Weighted average no. of Equity Shares outstanding
during the year / period.
2. EPS has been calculated in accordance with the Indian Accounting Standard 33 – ‘Earning per share’ notified under the Companies (Indian
Accounting Standards) Rules, 2015. The above statement should be read with significant accounting policies and notes on Restated
Consolidated Financial Information.
3. RoNW is calculated as net profit after tax attributable to owners of the Company, as restated / Restated Closing net worth at the end of the
year/period. Net Worth means the aggregate value of the paid-up share capital and all reserves created out of the profits and securities
premium account and debit or credit balance of profit and loss account, after deducting the aggregate value of the accumulated losses,
deferred expenditure and miscellaneous expenditure not written off, as per the audited balance sheet, but does not include reserves created
out of revaluation of assets, write-back of depreciation and amalgamation.
4. Net Asset Value per share (NAV) is computed as Net Worth as per the Restated Financial Statements / Number of Equity Shares outstanding
as at the end of year/period, as adjusted for bonus issue of Equity Shares and sub-division of Equity Shares.
5. EBITDA is calculated as profit / (loss) before tax for the period / year including share in profit/ (loss) from associates/ joint ventures,
finance costs and depreciation and amortization expenses, excluding other Income.
Non-GAAP Measures
Certain measures included and presented in this Draft Red Herring Prospectus, for instance EBITDA, EBITDA
margin, interest coverage ratio, net debt to EBITDA ratio, return on capital employed and return on equity (Non-
GAAP Measures), are supplemental measures of our performance and liquidity that are not required by, or
presented in accordance with, Ind AS, IFRS or U.S. GAAP. Further, these Non-GAAP Measures, are not a
measurement of our financial performance or liquidity under Indian GAAP, IFRS or U.S. GAAP and should not
be considered as an alternative to net profit/loss, revenue from operations or any other performance measures
derived in accordance with Ind AS, IFRS or U.S. GAAP or as an alternative to cash flow from operations or as a
measure of our liquidity. We compute and disclose such Non-GAAP financial measures and such other statistical
information relating to our operations and financial performance as we consider such information to be useful
measures of our business and financial performance. In addition, Non-GAAP Measures used are not a standardised
term, hence a direct comparison of Non-GAAP Measures between companies may not be possible. Other
companies may calculate Non-GAAP Measures differently from us, limiting its usefulness as a comparative
measure. See “Risk Factor - Certain non-GAAP financial measures and certain other statistical information
relating to our operations and financial performance such as EBITDA, EBITDA margin, interest coverage ratio,
575net debt to EBITDA ratio, return on capital employed and return on equity have been included in this Draft Red
Herring Prospectus. These non-GAAP financial measures are not measures of operating performance or liquidity
defined by Ind AS and may not be comparable” on page 78.
Reconciliation of Non-GAAP Measures
Net Worth
₹ in lakhs, unless stated otherwise
For the year ended For the year ended For the year ended
Particulars
March 31, 2025 March 31, 2024 March 31, 2023
Equity Share Capital (A) 1,575.40 1,575.40 1,575.40
Other Equity (B) 15,233.58 13,478.73 10,170.58
Net Worth (A + B) 16,808.98 15,054.13 11,745.98
Return on Net worth
₹ in lakhs, unless stated otherwise
For the year ended For the year ended For the year ended
Particulars
March 31, 2025 March 31, 2024 March 31, 2023
Profit after Tax 2,338.50 1,793.38 763.17
Closing Net Worth 16,808.98 15,054.13 11,745.98
Return on Net Worth (RoNW) (%) 13.91% 11.91% 6.50%
Net asset value per Equity Share
For the year ended For the year ended For the year ended
Particulars
March 31, 2025 March 31, 2024 March 31, 2023
Closing Net Worth (₹ in lakhs) 16,808.98 15,054.13 11,745.98
Number of equity shares as at the end of the year, 1,57,54,000 1,57,54,000 1,57,54,000
adjusted for bonus issue of Equity Share and
subdivision of Equity Shares
Face Value per Equity Share (in ₹) 10.00 10.00 10.00
Net asset value per Equity Share (in ₹) 106.70 95.56 74.56
576RELATED PARTY TRANSACTIONS
For details of the related party transactions, as per the requirements under applicable Accounting Standards, i.e.,
Ind AS 24 ‘Related Party Disclosures’ for the periods ended Fiscals 2025, 2024 and 2023 and as reported in the
Restated Consolidated Financial Information, see “Financial Information – Note 48 – Related Party Disclosures”
beginning on page 614.
577MANAGEMENT’S DISCUSSION AND ANALYSIS OF FINANCIAL CONDITION AND RESULTS OF
OPERATIONS
You should read the following discussion of our financial condition and results of operations together with our
Restated Consolidated Financial Information which is included in this Draft Red Herring Prospectus. Our
Restated Consolidated Financial Information differ in certain material respects from IFRS, U.S. GAAP and GAAP
in other countries, and our assessment of the factors that may affect our prospects and performance in future
periods. Accordingly, the degree to which our Restated Consolidated Financial Information will provide
meaningful information to a prospective investor in countries other than India is entirely dependent on the
reader’s level of familiarity with Ind AS. Our financial year ends on March 31 of each year. Accordingly,
references to “Fiscal Year 2023”, “Fiscal Year 2024” and “Fiscal Year 2025”, are to the 12-month period ended
March 31 of the relevant year. This Draft Red Herring Prospectus includes the Restated Financial Information
of the Company that has been prepared under Ind AS notified under Section 133 of the Companies Act, 2013, and
in accordance with requirements of Section 26 of Part I of Chapter III of the Companies Act, Paragraph (A) of
Clause 11 (I) of Part A of Schedule VI of the SEBI ICDR Regulations and the Guidance Note on Reports in
Company Prospectuses (Revised 2019) issued by the Institute of Chartered Accountants of India as amended from
time to time.
Some of the information in the following discussion, including information with respect to our plans and
strategies, contain forward-looking statements that involve risks and uncertainties. You should read the section
“Forward-Looking Statements” on page 16 for a discussion of the risks and uncertainties related to those
statements. Our actual results may differ materially from those expressed in or implied by these forward-looking
statements as a result of various factors, including those described below and elsewhere in this Draft Red Herring
Prospectus. Also read “Risk Factors” and “Management’s Discussion and Analysis Of Financial Condition and
Results Of Operations – Significant Factors Affecting our Results of Operations and Financial Condition” on
pages 40 and 578, respectively, for a discussion of certain factors that may affect our business, financial condition
or results of operations.
Unless stated or the context requires otherwise, the financial information in this Draft Red Herring Prospectus is
derived from the Restated Consolidated Financial Information included in this Draft Red Herring Prospectus.
The financial information included in this section should be read in conjunction with our Restated Consolidated
Financial Information, the notes and annexures thereto and “Management’s Discussion and Analysis of
Financial Position and Results of Operations” on pages 503 and 578 respectively.
Unless stated otherwise, the industry and market data contained in this section is derived from the industry report
titled “Broking Industry in India” dated September 2025, which is exclusively prepared for the purposes of the
Issue and issued by CARE Analytics and Advisory Private Limited appointed by us pursuant to an engagement
letter dated April 16, 2025 and is exclusively commissioned and paid for by our Company (“CARE Report”). We
commissioned and paid for the CARE Report for the purposes of confirming our understanding of the industry
specifically for the purposes of the Issue, as no report is publicly available which provides a comprehensive
industry analysis, particularly for our Company’s products, that may be similar to the CARE Report. The CARE
Report is available on the website of our Company at https://www.sihl.in/. The data included herein includes
excerpts from the CARE Report and may have been re-ordered by us for the purposes of presentation. CARE
Analytics and Advisory Private Limited is not, and has not in the past, been engaged or interested in the formation,
or promotion, or management, of our Company. Further, it is an independent agency and neither our Company,
nor our Directors, Promoter, KMPs, SMPs, and Subsidiaries, nor the BRLM are a related party to CARE
Analytics and Advisory Private Limited as per the definition of “related party” under the Companies Act, 2013.
Prospective investors are advised not to unduly rely on the CARE Report. There are no parts, data or information
(which may be relevant for the proposed issue), that have been left out or changed in any manner. There are no
parts, data or information (which may be relevant for the proposed Issue), that has been left out or changed in
any manner. Also see, “Certain Conventions, Use of Financial Information and Market Data and Currency of
Presentation –Industry and Market Data” on page 13. Unless otherwise indicated, financial, operational, industry
and other related information derived from the CARE Report and included herein with respect to any particular
year refers to such information for the relevant calendar year.
Unless the context otherwise requires, in this section, references to “we”, “us”, or “our” refers to Shah Investor’s
Home Limited on a consolidated basis and references to “the Company” or “our Company” refers to Shah
Investor’s Home Limited on a standalone basis.
578Overview
For details in relation to our business overview, competitive strengths, business strategies and business operations,
please see “Our Business” beginning on page 438.
Significant Factors Affecting Our Results of Operations and Financial Condition
We believe that the following factors have significantly affected our results of operations and financial condition
during the periods under review, and may continue to affect our results of operations and financial condition in
the future:
General economic and financial services industry conditions in India
Our business and results of operations are affected by general economic conditions and trends in the financial
services industry in India.
Real GDP growth is projected at 6.5%, driven by strong rural demand, improving employment, and robust
business activity. The agriculture sector's bright prospects, healthy reservoir levels, and robust crop production
support this growth. Manufacturing is reviving, and services remain resilient, despite global uncertainties.
Investment activity is gaining traction, supported by healthy balance sheets and easing financial conditions.
However, risks from geopolitical tensions, global market volatility, and geo-economic fragmentation persist.
If general economic conditions in India deteriorate or are not in line with our expectations, or if there is an impact
on our business different from our expectations, our financial condition and results of operations may be materially
and adversely affected. In addition, if favourable trends in the financial services industry or digitalisation
slowdown or are reversed, our financial condition and results of operations may be materially and adversely
affected. Please see the section entitled “Risk Factors – Any downturn or disruption in the securities markets,
which are affected by general economic and market conditions in India and globally, may have a material
adverse effect on our business, financial condition, cash flows, results of operations and prospects” on page
79.
Indian equity capital markets
India's capital markets, including stock, bond, derivative markets, and mutual funds, have significantly
influenced the nation’s financial system and economic development. We operate in the financial services
industry in India where we conduct our business and generate substantially all of our revenues. We primarily
offer secondary market brokering services to retail customers that comprise of both, residents and non-
resident Indians. Our Company is also actively engaged in the business of providing services such as mutual
funds distributorship, margin funding, stock lending and borrowing. The Indian financial market has
experienced notable fluctuations in turnover across various exchanges in recent years. From FY20 to
FY25, the combined turnover for all exchanges has shown impressive growth, with a CAGR of
approximately 44.5% and Q-o-Q growth of 75.9% from Rs 116 trillion in Q1FY25 to Rs 203 trillion in
Q1FY26. This growth trend highlights the performance of key exchanges, including the BSE, NSE, Multi
Commodity Exchange (MCX), and National Commodity and Derivatives Exchange. In Jun’25, the MTF book
grew significantly, reaching Rs. 879 billion, a 23.7% increase over Mar’25, the MTF book grew at a CAGR of
87% from last trading day of Mar’20 to last trading day of Jun’25. This growth is driven by rising investor
awareness of MTF's benefits in boosting buying power and potential returns, along with a bullish stock
market. Interest income from MTF ranges between 15% to 35% of total revenue for leading players. (Source:
Care Report).
The Indian equity markets are affected by a variety of factors including growth in India’s GDP, taxation,
monetary and other policies of the Government of India, laws and regulations that affect trading, political
measures and regulatory developments, and general political stability, inflation, interest rate levels, change
in consumer spending and saving patterns such as a shift from one category of investment to another, currency
exchange rates and foreign investment including perceived unattractiveness of the Indian markets. Accordingly,
a downturn in the Indian securities markets, persistent or short term, could adversely impact trading and
investment patterns, result in decline in trading volumes and size, and, consequently, adversely impact our
business, prospectus, results of operation and financial condition.
Maintaining our customer relationships specifically in the state of Gujarat
579We have over the years established long-term relationships with our customers leading to recurrent business
engagements with them. In our brokerage and commission business and our advisory business (particularly equity
broking, wealth management, investment banking), revenues are largely influenced by the number of our retail,
institutional and corporate clients. Our ability to grow our share of clients' business is determined by us providing
advisory services, customised business solutions, quality research and efficient execution. We believe successfully
developing new customer relationships along with retaining existing customer relationships are critical for
growing our businesses and consequently for our results of operations. We believe our ability to offer customized
services to fit the needs of our customers across various business verticals allows us to deepen our relationships
with our customers and enables us to target a greater share of their requirements thereby leading to recurring
business.
The contribution of our western Indian operations in brokerage income as a percentage of total brokerage income
from operations of our Company for Fiscals 2025, 2024 and 2023, expressed in both absolute terms and as a
percentage of our total brokerage income.
Particulars Fiscal 2025 Fiscal 2024 Fiscal 2023
Amount (in ₹ As % of Amount (in As % of total Amount (in As % of total
lakhs) total ₹ lakhs) brokerage ₹ lakhs) brokerage
brokerage Income Income
Income
Gujarat 6,056.24 93.30 5,210.13 93.53 3,477.31 93.91
Maharashtra 283.44 4.37 234.30 4.21 164.75 4.45
Others 151.45 2.33 125.77 2.26 60.73 1.64
Total 6,491.13 100.00 5,570.20 100.00 3,702.79 100.00
Any decrease in revenues from western India, including due to increased competition or supply, or reduction in
demand, in markets in which we operate, may have an adverse effect on our business, cash flows, results of
operation and financial condition.
Competition
The Indian financial services industry is highly competitive. We face significant competition in all aspects of our
business. In particular, we compete with other Indian and foreign brokerage houses and asset managers, among
others, which operate in the markets in which we conduct our business. Over the last few quarters, brokers offering
digital platforms are able to garner a significant proportion of the market share both in terms of incremental clients
as well as trading volumes. Our competitors may have various competitive advantages over us such as greater
financial resources, wider brand recognition, broader knowledge resources, far-reaching partnerships, parentage
and access to existing client base. It is also possible for our competitors to quickly adopt our business practices,
scale up the services offered and set lower prices to compete with us. Mergers and acquisitions involving our
competitors may create entities with even greater competitive advantages.
Significant Accounting Policies
1A. Corporate Information
Shah Investor’s Home Limited (“SIHL” or ‘the Holding Company’) is a public limited company and incorporated
under the provisions of Companies Act. The Company domiciled in India and its registered office 810, X-Change
Plaza, DSCCSL(53E), Road 5E, Block 53, Zone 5, Gift City, Gandhinagar, Gujarat-382355 and correspondence
office at SIHL House, Opp. Ambawadi Jain Temple, Nehrunagar Cross Road, Ahmedabad, Gujarat - 380015.
Shah Investor’s Home Limited, its subsidiaries are engaged in broking of equity, derivatives and mutual fund,
wealth management services, distribution of financial products, proprietary investments and other activities in
financial services.
These restated consolidated financial statements contain financial information of the Group and were authorized
for issue by the Board of Directors on September 5, 2025.
Information on the Group’s structure provided in note 52.
5802A. Business Combination under Common Control
A common control business combination, involving entities or businesses in which all of the combining entities
or businesses are ultimately controlled by the same party or parties both before and after the business combination
and where the control is not transitory, is accounted for in accordance with Appendix C to Ind AS 103 'Business
Combinations'.
Business combinations involving entities or businesses under common control are accounted for using the pooling
of interest method as follows :
➢ The assets and liabilities of the combining entities are reflected at their carrying amounts.
➢ No adjustments are made to reflect fair values, or recognize new assets or liabilities. Adjustments are made
only to harmonize significant accounting policies.
➢ The financial information in the financial statements in respect of prior periods are restated as if the business
combination had occurred from the beginning of the preceding period in the financial statements.
➢ The identity of the reserves are preserved and appear in the financial statements of the transferee in the same
form in which they appeared in the financial statements of the transferor.
The difference, if any, between the amounts recorded as share capital issued plus any additional consideration in
the form of cash or other assets and the amount of share capital of the transferor is transferred to capital reserve
and is presented separately from other capital reserves with disclosure of its nature and purpose in the notes.
3A. Business Combination under Acquisition method
The Group applies the acquisition method in accounting for business combinations for the businesses which are
not under common control. The cost of an acquisition is measured as the aggregate of the consideration transferred
measured at acquisition date fair value and the amount of any non-controlling interests in the acquiree. For each
business combination, the Group elects whether to measure the non-controlling interests in the acquiree at fair
value or at the proportionate share of the acquiree’s identifiable net assets. Acquisition related costs are expensed
as incurred.
At the acquisition date, the identifiable assets acquired and the liabilities assumed are recognised at their
acquisition date fair values. For this purpose, the liabilities assumed include contingent liabilities representing
present obligation and they are measured at their acquisition fair values irrespective of the fact that outflow of
resources embodying economic benefits is not probable. However, the following assets and liabilities acquired in
a business combination are measured at the basis indicated below:
A) Deferred tax assets or liabilities and the assets or liabilities related to employee benefit arrangements are
recognised and measured in accordance with Ind AS 12 ‘Income Tax’ and Ind AS 19 ‘Employee Benefits’
respectively.
B) Potential tax effects of temporary differences and carry forwards of an acquiree that exist at the acquisition
date or arise as a result of the acquisition are accounted in accordance with Ind AS 12.
C) Reacquired rights are measured at a value determined on the basis of the remaining contractual term of the
related contract. Such valuation does not consider potential renewal of the reacquired right.
Any contingent consideration to be transferred by the acquirer is recognised at fair value at the acquisition date.
Contingent consideration classified as an asset or liability that is a financial instrument and within the scope of
Ind AS 109 ‘Financial Instruments’, is measured at fair value with changes in fair value recognised in profit or
loss. If the contingent consideration is not within the scope of Ind AS 109, it is measured in accordance with the
appropriate Ind AS.
Contingent consideration that is classified as equity is not re-measured at subsequent reporting dates and its
subsequent settlement is accounted for within equity.
When the Group acquires a business, it assesses the financial assets and liabilities assumed for appropriate
classification and designation in accordance with the contractual terms, economic circumstances and pertinent
conditions as at the acquisition date.
581If the business combination is achieved in stages, any previously held equity interest is re-measured at its
acquisition date fair value and any resulting gain or loss is recognised in profit or loss or OCI, as appropriate.
4A. Material accounting policies
The principal accounting policies applied in the preparation of these financial statements are set out below.
Accounting policies have been consistently applied except where a newly issued accounting standard is initially
adopted or a revision to the existing accounting standard requires a change in the accounting policy hitherto in
use.
4.1 Basis of preparation
(i) Compliance with Ind AS
The restated consolidated financial statements of the Group comply in all material aspects with Indian Accounting
Standards (Ind AS) notified under Section 133 of the Companies Act,2013 (“the Act”) read with Companies
(Indian Accounting Standarads) Rules, 2015 as amended and other relevant provisions of the Act.
The restated consolidated financial statements up to and including the year ended 31 March 2024 were prepared
in accordance with the accounting standards notified under companies (Accounting Standard) Rules,2006 (as
amended) under the Act read with Rule 7 of the Companies (Accounts) Rules, 2014 (as amended), and other
generally accepted accounting principles in India (collectively referred to as “Indian GAAP” or “Previous
GAAP”)
These restated consolidated financial statements are the first financial statements of the Group under Ind AS.
Refer 55 for an explanation of how the transition from previous GAAP to Ind AS has affected Group’s financial
position, financial performance and cash flows.
The transition to Ind AS has been carried out in accordance with Ind AS 101 First Time Adoption of Indian
Accounting Standards. Accordingly, the impact of transition has been recorded in the opening reserves as at 1
April 2022.
Accounting policies have been applied consistently over all the periods presented in these restated consolidated
financial statements, except where the Group has applied certain accounting policies and exemptions upon
transition to Ind AS.
(ii) Historical cost convention
The restated consolidated financial statements have been prepared on a historical cost basis, except for the
following:
➢ Financial instruments are measured at fair value through Profit and Loss or Other Comprehensive Income,
➢ Defined benefit plans – plan assets measured at fair value; and
(iii) Preparation of restated consolidated financial statements
The Holding Company is covered in the definition of Non-Banking Financial Group as defined in Companies
(Indian Accounting Standards) (Amendment) Rules, 2016. As per the format prescribed under Division III of
Schedule III to the Companies Act, 2013 on 11 October 2018 (as amended), the Holding Company presents the
restated Balance Sheet, the restated Statement of Profit and Loss and the restated Statement of Changes in Equity
in the order of liquidity. A maturity analysis of recovery or settlement of assets and liabilities within 12 months
after the reporting date and more than 12 months after the reporting date is presented in note 46.
(iv) Use of estimates and judgments
582The preparation of restated consolidated financial statements in conformity with Ind AS requires management to
make estimates, judgments, and assumptions that affect the application of accounting policies and the reported
amounts of assets and liabilities (including contingent liabilities) and disclosures as of the date of restated
consolidated financial statements and the reported amounts of revenue and expenses for the reporting period.
Actual results could differ from these estimates. Accounting estimates and underlying assumptions are reviewed
on an ongoing basis and could change from period to period. Appropriate changes in estimates are recognized in
the period in which the Company becomes aware of the changes in circumstances surrounding the estimates. Any
revisions to accounting estimates are recognized prospectively in the period in which the estimate is revised and
future periods.
(v) Determining whether an arrangement contains a lease
The Company evaluates if an arrangement qualifies to be a lease as per the requirements of Ind AS 116.
Identification of a lease requires significant judgment. The Company uses significant judgment in assessing the
lease term (including anticipated renewals) and the applicable discount rate. The Company determines the lease
term as the non-cancellable period of a lease, together with both periods covered by an option to extend the lease
if the Company is reasonably certain to exercise that option; and periods covered by an option to terminate the
lease if the Company is reasonably certain not to exercise that option.
4.2 Principles of consolidation and equity accounting
(i) Subsidiaries
The restated consolidated financial statement has comprised restated financial statements of the Company and its
subsidiaries. Subsidiaries are all the entities (including structured entities) over which the Group has control. The
Group controls an entity when the Group is exposed to, or has rights to, variable returns from its involvement with
the entity and has the ability to affect those returns through its power to direct the relevant activities of the entity.
Subsidiaries are fully consolidated from the date on which control is transferred to the Group. They are
deconsolidated from the date that control ceases.
The acquisition method of accounting is used to account for business combinations by the Group.
The Group combines the financial statements of the Holding Company and its subsidiaries line by line adding
together like items of assets, liabilities, equity, income and expenses. Intercompany transactions, balances and
unrealized gains on transactions within the Group are eliminated. Unrealized losses are also eliminated unless the
transaction provides evidence of an impairment of the transferred asset. Accounting policies of subsidiaries have
been changed where necessary to ensure consistency with the policies adopted by the Group.
Non-controlling interests in the results and equity of subsidiaries are shown separately in the consolidated
statement of profit or loss, consolidated statement of changes in equity and balance sheet respectively. Statement
of Profit and Loss including Other Comprehensive Income (OCI) is attributable to the equity holders of the
Holding Company and to the non-controlling interest basis the respective ownership interest and such balance is
attributed even if this results in controlling interest is having a deficit balance.
(ii) Equity method
Under the equity method of accounting, the investments are initially recognized at cost and adjusted thereafter to
recognize the Group’s share of the post-acquisition profits or losses of the investee in profit or loss, and the
Group’s share of other comprehensive income of the investee in other comprehensive income.
When the Group’s share of losses in an equity-accounted investment equals or exceeds its interest in the entity,
including any other unsecured long-term receivables, the Group does not recognize further losses, unless it has
incurred obligations or made payments on behalf of the other entity.
Unrealized gains on transactions between the Group companies are eliminated to the extent of the Group’s interest
in these entities. Unrealized losses are also eliminated unless the transaction provides evidence of an impairment
583of the asset transferred. Accounting policies of equity accounted investees have been changed where necessary to
ensure consistency with the policies adopted by the Group.
(iii) Changes in ownership interests
The Group treats transactions with non-controlling interests that do not result in a loss of control as transactions
with equity owners of the Group. A change in ownership interest results in an adjustment between the carrying
amounts of the controlling and non-controlling interests to reflect their relative interests in the subsidiary. Any
difference between the amount of the adjustment to non-controlling interests and any consideration paid or
received is recognized within equity.
When the Group ceases to consolidate or equity account for an investment because of a loss of control or joint
control, any retained interest in the entity is re-measured to its fair value with the change in carrying amount
recognized in profit or loss. This fair value becomes the initial carrying -amount for the purposes of subsequently
accounting for the retained interest as an associate or financial asset. In addition, any amounts previously
recognized in other comprehensive income in respect of that entity are accounted for as if the Group had directly
disposed of the related assets or liabilities. This may mean that amounts previously expected credit recognized in
other comprehensive income are reclassified to profit or loss.
If the ownership interest in an associate is reduced but joint control or significant influence is retained, only a
proportionate share of the amounts previously recognized in other comprehensive income are reclassified to profit
or loss where appropriate.
4.3 Revenue Recognition
The Group recognizes revenue from contracts with customers based on a five step model as set out in Ind AS 115,
Revenue from Contracts with Customers, to determine when to recognize revenue and at what amount. Revenue
is measured based on the consideration specified in the contract with a customer. Revenue from contracts with
customers is recognised when services are provided and it is highly probable that a significant reversal of revenue
is not expected to occur.
Revenue is measured at fair value of the consideration received or receivable. Revenue is recognised when (or
as) the Group satisfies a performance obligation by transferring a promised service (i.e. an asset) to a customer.
An asset is transferred when (or as) the customer obtains control of that asset.
When (or as) a performance obligation is satisfied, the Group recognizes as revenue the amount of the transaction
price (excluding estimates of variable consideration) that is allocated to that performance obligation.
The Group applies the five-step approach for recognition of revenue:
➢ Identification of contract(s) with customers; A contract is defined as an agreement between two or more
parties that creates enforceable rights and obligations and sets out the criteria for every contract that must be
met.
➢ Identification of the separate performance obligations in the contract; A performance obligation is a promise
in a contract with a customer to transfer a good or service to the customer.
➢ Determination of transaction price; The transaction price is the amount of consideration to which the
Company expects to be entitled in exchange for transferring promised goods or services to a customer,
excluding amounts collected on behalf of third parties.
➢ Allocation of transaction price to the separate performance obligations: For a contract that has more than one
performance obligation, the Company allocates the transaction price to each performance obligation in an
amount that depicts the amount of consideration to which the Company expects to be entitled in exchange for
satisfying each performance obligation.; and
➢ Recognition of revenue when (or as) each performance obligation is satisfied.
(i) Brokerage fee income
584It is recognised on trade date basis in accordance with the terms of contract and is exclusive of goods and service
tax and securities transaction tax (STT) wherever applicable.
(ii) Interest income
Interest income is recognized on accrual basis in restated statement of profit and loss for all financial instruments
measured at amortized cost.
(iii) Dividend income
Dividend income is recognized in the restated statement of profit and loss on the date that the Group's right to
receive payment is established, it is probable that the economic benefits associated with the dividend will flow to
the entity and the amount of dividend can be reliably measured. This is generally when the shareholders approve
the dividend.
(iv) Net gain on fair value changes
The Company designates certain financial assets for subsequent measurement at fair value through profit or loss
(FVTPL) or fair value through other comprehensive income (FVOCI). The Company recognizes gains on fair
value change of financial assets measured at FVTPL and realized gains on de-recognition of financial asset
measured at FVTPL and FVOCI on net basis in profit or loss.
(v) Depository services income
Revenue from depository services on account of annual maintenance charges have been accounted over the period
of the performance obligation.
Revenue from depository services on account of transaction charges is recognized point in time when the
performance obligation is satisfied.
(vi) Delayed payment charges
Interest is earned on delayed payments from customers and is recognised on a time proportion basis taking into
account the amount outstanding from customers and the rates applicable.
4.4 Income Tax
The income tax expense or credit for the period is the tax payable on the current period’s taxable income based
on the applicable income tax rate adjusted by changes in deferred tax assets and liabilities attributable to temporary
differences and to unused tax losses. Current and deferred tax is recognized in restated statement of profit and
loss, except to the extent that it relates to items recognized in other comprehensive income or directly in equity.
In this case, the tax is also recognized in other comprehensive income or directly in equity, respectively
Current Tax
Current tax is measured at the amount of tax expected to be payable on the taxable income for the year as
determined in accordance with the provisions of the Income Tax Act, 1961. Current tax assets and current tax
liabilities are off set when there is a legally enforceable right to set off the recognized amounts and there is an
intention to settle the asset and the liability on a net basis.
Deferred Tax
Deferred tax is provided in full, using the liability method, on temporary differences arising between the tax bases
of assets and liabilities and their carrying amounts in the consolidated financial statements. However, deferred tax
liabilities are not recognized if they arise from the initial recognition of goodwill. Deferred tax is also not
accounted for, if it arises from initial recognition of an asset or liability in a transaction other than a business
585combination that at the time of the transaction affects neither accounting profit nor taxable profit (tax loss).
Deferred tax is determined using tax rates (and laws) that have been enacted or substantially enacted by the end
of the reporting period and are expected to apply when the related deferred income tax asset is realized or the
deferred income tax liability is settled.
Deferred tax assets are recognized for all deductible temporary differences and unused tax losses only if it is
probable that future taxable amounts will be available to utilize those temporary differences and losses.
Deferred tax liabilities are not recognized for temporary differences between the carrying amount and tax bases
of investments in subsidiaries and associates where the Company is able to control the timing of the reversal of
the temporary differences and it is probable that the differences will not reverse in the foreseeable future.
Deferred tax assets and liabilities are offset when there is a legally enforceable right to offset current tax assets
and liabilities and when the deferred tax balances relate to the same taxation authority.
4.5 Leases
For any new contracts entered into on or after 1 April 2022, the Company considers whether a contract is, or
contains a lease. A lease is defined as ‘a contract, or part of a contract, that conveys the right to use an asset (the
underlying asset) for a period of time in exchange for consideration’. The Company assess whether it has the right
to direct ‘how and for what purpose’ the asset is used throughout the period of use.
Measurement and recognition of leases as a lessee
The Company has adopted Ind AS 116 “Leases” using the cumulative catch-up approach. Company has
recognised Right of Use assets as at 1 April 2022 for leases previously classified as operating leases and measured
at an amount equal to lease liability (adjusted for related prepayments/ accruals). The Company has discounted
lease payments using the incremental borrowing rate for measuring the lease liability.
The Company recognises right-of-use assets at the commencement date of the lease (i.e., the date the underlying
asset is available for use). Right-of-use assets are measured at cost, less any accumulated depreciation and
impairment losses, and adjusted for any re-measurement of lease liabilities.
The Company depreciates the right-of-use assets on a straight-line basis from the lease commencement date to
the earlier of the end of the useful life of the right-of-use asset or the end of the lease term. The Company also
assesses the right-of-use asset for impairment when such indicators exist.
Lease payments included in the measurement of the lease liability are made up of fixed payments (including in
substance fixed), variable payments based on an index or rate, amounts expected to be payable under a residual
value guarantee and payments arising from options reasonably certain to be exercised.
Subsequent to initial measurement, the liability will be reduced for payments made and increased for interest. It
is re-measured to reflect any reassessment or modification, or if there are changes in in substance fixed payments.
When the lease liability is re-measured, the corresponding adjustment is reflected in the right-of-use asset, or
profit and loss if the right-of-use asset is already reduced to zero.
The Company has elected to account for short-term leases and leases of low-value assets using the practical
expedients. Instead of recognising a right-of-use asset and lease liability, the payments in relation to these are
recognised as an expense in profit or loss on a straight-line basis over the lease term.
When the Company revises its estimate of the term of any lease, it adjusts the carrying amount of the lease liability
to reflect the payments to make over the revised term, which are discounted using a revised discount rate. The
carrying value of lease liabilities is similarly revised when the variable element of future lease payments dependent
on a rate or index is revised, except the discount rate remains unchanged. In both cases an equivalent adjustment
is made to the carrying value of the right-of-use asset, with the revised carrying amount being amortised over the
586remaining (revised) lease term. If the carrying amount of the right-of-use asset is adjusted to zero, any further
reduction is recognised in statement of profit and loss.
For contracts that both convey a right to the Company to use an identified asset and require services to be provided
to the Company by the lessor, the Company has elected to account for the entire contract as a lease, i.e. it does not
allocate any amount of the contractual payments to, and account separately for, any services provided by the
supplier as part of the contract.
4.6 Cash and cash equivalents
For the purpose of presentation in the statement of cash flows, cash and cash equivalents includes cash on hand,
deposits held at call with financial institutions, other short-term, highly liquid investments with original maturities
of three months or less that are readily convertible to known amounts of cash and which are subject to an
insignificant risk of changes in value. Outstanding bank overdrafts are not considered integral part of the
Company’s cash management.
4.7 Financial instruments
Initial recognition and measurement:
Financial assets and financial liabilities are recognized when the entity becomes a party to the contractual
provisions of the instrument. Regular way purchases and sales of financial assets are recognized on trade date, the
date on which the Company commits to purchase or sell the asset.
At initial recognition, the Group except for trade receivables, measures the financial asset or financial liability at
its fair value plus or minus, in the case of a financial asset or financial liability not at fair value through profit or
loss, transaction costs that are directly attributable to the acquisition or issue of the financial asset or financial
liability, transaction costs that are incremental and directly attributable to the acquisition or issue of the financial
asset or financial liability, such as fees and commissions. Transaction costs of financial assets and financial
liabilities carried at fair value through profit or loss are expensed in Statement of profit and loss. Immediately
after initial recognition, an expected credit loss allowance (ECL) is recognized for financial assets measured at
amortized cost.
When the fair value of financial assets and liabilities differs from the transaction price on initial recognition, the
entity recognizes the difference as follows:
a) When the fair value is evidenced by a quoted price in an active market for an identical asset or liability (i.e. a
Level 1 input) or based on a valuation technique that uses only data from observable markets, the difference
is recognized as a gain or loss.
b) In all other cases, the difference is deferred and the timing of recognition of deferred day one profit or loss is
determined individually. It is either amortized over the life of the instrument, deferred until the instrument’s
fair value can be determined using market observable inputs, or realized through settlement.
When the Group revises the estimates of future cash flows, the carrying amount of the respective financial assets
or financial liability is adjusted to reflect the new estimate discounted using the original effective interest rate.
Any changes are recognized in Statement of profit and loss.
Fair value of financial instruments:
the Group’s assets and liabilities are measured at fair value for financial reporting purpose. Fair value is the price
that would be received to sell an asset or paid to transfer a liability in an orderly transaction between market
participants at the measurement date regardless of whether that price is directly observable or estimated using
another valuation technique.
Fair value measurements under Ind AS are categorized into Level 1, 2, or 3 based on the degree to which the
inputs to the fair value measurement are observable and the significance of the inputs to the fair value
measurement in its entirety, which are described as follows:
587➢ Level 1: quoted prices (unadjusted) in active markets for identical assets or liabilities that the Company can
access at measurement date
➢ Level 2: inputs other than quoted prices included in Level 1 that are observable for the asset or liability, either
directly or indirectly; and
➢ Level 3: inputs for the asset or liability that are not based on observable market data (unobservable inputs)
that the Company can access at measurement date.
Information about the valuation techniques and inputs used in determining the fair value of various assets and
liabilities are disclosed in note 43.
Financial assets
(i) Classification and subsequent measurement:
The Company has applied Ind AS 109 and classifies its financial assets in the following measurement categories:
➢ Fair value through profit or loss (FVTPL)
➢ Fair value through other comprehensive income (FVOCI); or
➢ Amortised cost.
Classification and subsequent measurement of financial assets depends on:
➢ The Company’s business model for managing the asset; and
➢ The cash flow characteristics of the asset.
Financial assets carried at:
(A) Amortised cost
Financial assets at amortized cost are subsequently measured at amortized cost using effective interest method.
The amortized cost is reduced by impairment losses. Interest income, foreign exchange gains and losses and
impairment are recognized in profit or loss. Any gain and loss on de-recognition are recognized in profit or loss.
(B) Fair value through other comprehensive income
A financial asset not classified as either amortised cost or FVOCI, is classified as FVTPL. Such financial assets
are measured at fair value with all changes in fair value, including interest income and dividend income if any,
recognised as ‘other income’ in the Statement of Profit and Loss.
(C) Fair value through profit or loss
A financial asset not classified as either amortised cost or FVOCI, is classified as FVTPL. Such financial assets
are measured at fair value with all changes in fair value, including interest income and dividend income if any,
recognised as ‘other income’ in the Statement of Profit and Loss.
1. Equity instruments
Equity instruments are instruments that meet the definition of equity from the issuer’s perspective; that is,
instruments that do not contain a contractual obligation to pay and that evidence a residual interest in the issuer’s
net assets.
All investments in equity instruments classified under financial assets are initially measured at fair value, the
Group may, on initial recognition, irrevocably elect to measure the same either at FVOCI or FVTPL. The Group
makes such election on an instrument-by-instrument basis. Fair value changes on an equity instrument is
recognised as revenue from operations in the Statement of Profit and Loss unless the Group has elected to measure
such instrument at FVOCI. Fair value changes excluding dividends, on an equity instrument measured at FVOCI
588are recognized in OCI. Amounts recognised in OCI are not subsequently reclassified to the Statement of Profit
and Loss. Dividend income on the investments in equity instruments are recognised as ‘Revenue from operations’
in the statement of Profit and Loss.
2. Investments in mutual funds
Investments in mutual funds are measured at fair value through profit and loss (FVTPL).
3. Debt Instrument
Subsequent measurement of debt instruments depends on the Group’s business model for managing the asset and
the cash flow characteristics of the asset. There are three measurement categories into which the Group has
classified its debt instruments:
- Amortised cost: Assets that are held for collection of contractual cash flows and where the contractual terms
give rise on specified dates to cash flows that represent solely payments of principal and interest, are measured
at amortised cost. A gain or loss on a debt investment that is subsequently measured at amortised cost is
recognised in profit or loss when the asset is derecognized or impaired.
- Fair value through other comprehensive income (FVTOCI): Assets that are held for collection of
contractual cash flows and for selling the financial assets, where the assets’ cash flow represent solely
payments of principal and interest, are measured at fair value through other comprehensive income (FVTOCI).
Movements in the carrying amount are taken through OCI, except for recognition of impairment gains or
losses, interest revenue and foreign exchange gains and losses which are recognised in profit & loss in the
same manner as for financial assets measured at amortised cost. The remaining fair value changes are
recognised in OCI.
- Fair value through profit or loss (FVTPL): Assets that do not meet the criteria for amortised cost, are
measured at fair value through profit or loss. A gain or loss on a debt investment that is subsequently measured
at fair value through profit or loss is recognised in profit or loss and presented net in the statement of profit
and loss within other income in the period in which it arises. Interest income from these financial assets is
included in other income.
(ii) Impairment
The Group recognizes impairment allowances using Expected Credit Losses (“ECL”) method on all the financial
assets that are not measured at Fair value through profit or loss (FVTPL):
ECL are probability-weighted estimate of credit losses. They are measured as follows:
➢ Financials assets that are not credit impaired – as the present value of all cash shortfalls that are possible
within 12 months after the reporting date.
➢ Financials assets with significant increase in credit risk - as the present value of all cash shortfalls that result
from all possible default events over the expected life of the financial assets.
➢ Financials assets that are credit impaired – as the difference between the gross carrying amount and the
present value of estimated cash flows.
Financial assets are written off/fully provided for when there is no reasonable of recovering financial assets in its
entirety or a portion thereof.
However, financial assets that are written off could still be subject to enforcement activities under the Group’s
recovery procedures, taking into account legal advice where appropriate. Any recoveries made are recognised in
the restated statement of Profit and Loss.
(iii) Derecognition
589A financial asset is derecognised only when:
The Group has transferred the rights to receive cash flows from the financial asset or retains the contractual rights
to receive the cash flows of the financial asset, but assumes a contractual obligation to pay the cash flows to one
or more recipients.
Where the Group has transferred an asset, the Group evaluates whether it has transferred substantially all risks
and rewards of ownership of the financial asset. In such cases, the financial asset is derecognised. Where the entity
has not transferred substantially all risks and rewards of ownership of the financial asset, the financial asset is not
derecognised.
Where the Group has neither transferred a financial asset nor retains substantially all risks and rewards of
ownership of the financial asset, the financial asset is derecognised if the Group has not retained control of the
financial asset. Where the Group retains control of the financial asset, the asset is continued to be recognised to
the extent of continuing involvement in the financial asset.
Transfer of loans through assignment transaction can be made only after continuing involvement in loans i.e
retaining a minimum specific percentage of loan but without retaining any substantial risk and reward in the loan
assigned. The assigned portion of loans is derecognized and gains/losses are accounted for, only if the Company
transfers substantially all risks and rewards specified in the underlying assigned loan contracts. Gain/loss arising
on such assignment transactions is recorded upfront in the Statement of Profit and Loss and the corresponding
loan is derecognized from the Balance Sheet immediately. Further, if the transfer of loan qualifies for
derecognition, entire interest spread at its present value (discounted over the life of the asset) is recognized on the
date of derecognition itself as interest strip receivable (interest strip on assignment) and correspondingly presented
as gain/loss on derecognition of financial asset.
Financial liabilities
(i) Initial recognition and measurement
All financial liabilities are recognised when the Company becomes a party to the contractual provisions
of the financial instrument and are measured initially at fair value adjusted for transaction costs.
(ii) Subsequent measurement
Financial liabilities are subsequently measured at amortised cost using the EIR method. Financial
liabilities carried at fair value through profit or loss is measured at fair value with all changes in fair value
recognised in the Statement of Profit and Loss.
(iii) Derecognition
A financial liability is derecognised when the obligation specified in the contract is discharged, cancelled
or expires
4.8 Property, plant and equipment
Property, plant and equipment are stated at cost of acquisition less accumulated depreciation except in the case of
land which is stated at cost. Cost includes expenditure that is directly attributable to the acquisition and installation
of the assets.
Subsequent costs are included in the asset’s carrying amount or recognized as a separate asset, as appropriate,
only when it is probable that future economic benefits associated with the item will flow to the Company and the
cost of the item can be measured reliably. The carrying amount of any component accounted for as a separate
asset is derecognized when replaced. All other repairs and maintenance are charged to Statement of profit and loss
during the reporting period in which they are incurred.
590Advances paid towards the acquisition of property, plant and equipment outstanding at each balance sheet date is
classified as capital advances under other non-financial assets and the cost of assets not put to use before such
date are disclosed under ‘Capital work-in progress’.
Transition to IndAS
On transition to IndAS, the Company has elected to continue with the carrying value of all of its property, plant
and equipment recognized as at April 01, 2022 measured as per the previous GAAP and use that carrying value
as the deemed cost of the property, plant and equipment.
Depreciation methods, estimated useful lives and residual value
Property, plant and equipment are stated at cost, less accumulated depreciation and impairment, if any.
The Company depreciates property, plant and equipment over their estimated useful lives on written down value
method. The estimated useful lives of assets are as follows:
Assets Category Useful Life
(a) Property, plants & equipment:
(i) Building 60 Years
(ii)Furniture and Fixture 10 Years
(iii)Vehicles (Two Wheelers) 10 Years
(iv)Vehicles (Four Wheelers) 8 Years
(v)Office Equipment 5 Years
(vi)Electrical Installations 10 Years
(b)Leasehold Property Amortized over the lease period based on straight line
method
The useful lives for these assets is in compliance with the useful lives as indicated under Part C of Schedule II of
the Companies Act, 2013.
The useful lives, residual values of each part of tangible and the depreciation method are reviewed at the end of
each financial year. If any of these expectations differ from previous estimates, such change is accounted for as a
change in an accounting estimate.
Derecognition:
The carrying amount of an item of property, plant and equipment is derecognized on disposal or when no future
economic benefits are expected from its use or disposal. Gains and losses on disposals are determined by
comparing proceeds with carrying amount and are recognized in the restated statement of profit and loss when the
asset is derecognized.
4.9 Intangible assets
Measurement at recognition:
Intangible assets are recognized where it is probable that the future economic benefit attributable to the assets will
flow to the Company and its cost can be reliably measured. Intangible assets are stated at cost of acquisition less
accumulated amortization and impairment, if any.
Transition to Ind AS:
On transition to Ind AS, the Company has elected to continue with the carrying value of all of intangible assets
(including Goodwill) recognized as at April 01, 2022 measured as per the previous GAAP and use that carrying
591value as the deemed cost of intangible assets. Goodwill has not been amortized after transition to Ind AS since it
has an indefinite useful life but tested for impairment at the year end.
Expenditure incurred on acquisition/development of intangible assets which are not put/ready to use at the
reporting date is disclosed under intangible assets under development. The Company amortizes intangible assets
on a straight-line basis over the four years commencing from the month in which the asset is first put to use. The
Company provides pro-rata amortization from the day the asset is put to use.
Assets Useful life
Computer Software 4 Years
The amortization period and the amortization method for an intangible asset with infinite useful life is reviewed
at the end of each financial year. If any of these expectations differ from previous estimates, such change is
accounted for as a change in an accounting estimate.
Derecognition:
The carrying amount of an intangible asset is derecognized on disposal or when no future economic benefits are
expected from its use or disposal. Gains and losses on disposals are determined by comparing proceeds with
carrying amount and are recognized in the statement of profit and loss when the asset is derecognized.
4.10 Impairment of non-financial assets
At each reporting date, the Group assesses whether there is any indication based on internal/external factors, that
an asset may be impaired. If any such indication exists, the Group estimates the recoverable amount of the asset.
The recoverable amount of asset is the higher of its fair value or value in use. Value in use is based on the estimated
future cash flows, discounted to their present value using a pre-tax discount rate that reflects the current market
assessment of time value of money and the risks specific to it. If such recoverable amount of the asset or the
recoverable amount of the cash generating unit to which the asset belongs is less than its carrying amount, the
carrying amount is reduced to its recoverable amount and the reduction is treated as an impairment loss and is
recognised in the statement of profit and loss. All assets (except goodwill) are subsequently reassessed for
indications that an impairment loss previously recognised may no longer exist. An Impairment loss is reversed if
there has been a change in estimates used to determine the recoverable amount. Such a reversal is made only to
the extent that the assets carrying amount would have been determined, net of depreciation or amortization, had
no impairment loss been recognised.
4.11 Expected credit loss (ECL) model:
The Company applies the ECL model in accordance with Ind AS 109 for recognising impairment loss on financial
assets. The ECL allowance is based on the credit losses expected to arise from all possible default events over the
expected life of the financial asset ('lifetime ECL'), unless there has been no significant increase in credit risk
since origination, in which case, the allowance is based on the 12-month ECL. The 12-month ECL is a portion of
the lifetime ECL which results from default events that are possible within 12 months after the reporting date.
ECL is calculated on a collective basis, considering the retail nature of the underlying portfolio of financial assets.
The impairment methodology applied depends on whether there has been a significant increase in credit risk.
When determining whether the risk of default on a financial asset has increased significantly since initial
recognition, the Company considers reasonable and supportable information that is relevant and available without
undue cost or effort. This includes both quantitative and qualitative information and analysis based on a provision
matrix which takes into account the Company’s historical credit loss experience, current economic conditions,
forward looking information and scenario analysis.
592The expected credit loss is a product of exposure at default ('EAD'), probability of default ('PD') and loss given
default ('LGD'). The Company has devised an internal model to evaluate the PD and LGD based on the parameters
set out in Ind AS 109. Accordingly, the financial assets have been segmented into three stages based on the risk
profiles. The three stages reflect the general pattern of credit deterioration of a financial asset. The company
categorises financial assets at the reporting date into stages based on the days past due
('DPD') status as under:
- Stage 1: Trade receivable for which credit risk has not increased significantly and that are also not credit
impaired
- Stage 2: Trade receivable for which credit risk has increased significantly but not credit impaired
- Stage 3: Trade receivable for which credit risk has increased significantly and are credit impaired
LGD is an estimate of loss from a transaction given that a default occurs. PD is defined as the probability of
whether the borrowers will default on their obligations in the future. For assets which are in Stage 1, a 12-month
PD is required. For Stage 2 assets a lifetime PD is required while Stage 3 assets are considered to have a 100%
PD. EAD represents the expected exposure in the event of a default and is the gross carrying amount in case of
the financial assets held by the Company.
The Company incorporates forward looking information into both assessments of whether the credit risk of an
instrument has increased significantly since its initial recognition and its measurement of ECL. Based on the
consideration of external actual and forecast information, the Company forms a ‘base case’ view of the future
direction of relevant economic variables. This process involves developing two or more additional economic
scenarios and considering the relative probabilities of each outcome. The base case represents a most likely
outcome while the other scenarios represent more optimistic and more pessimistic outcomes.
The measurement of impairment losses across all categories of financial assets requires judgement, in particular,
the estimation of the amount and timing of future cash flows and collateral values when determining impairment
losses and the assessment of a significant increase in credit risk. These estimates are driven by a number of factors,
changes in which can result in different levels of allowances. The Company’s ECL calculations are outputs of
complex models with a number of underlying assumptions regarding the choice of variable inputs and their
interdependencies. The inputs and models used for calculating ECLs may not always capture all characteristics of
the market at the date of the financial statements. The Company regularly reviews its models in the context of
actual loss experience and makes adjustments when such differences are significantly material.
The amount of ECL (or reversal) that is required to adjust the loss allowance at the reporting date to the amount
that is required to be recognised as an impairment gain or loss in profit or loss.
4.12 Provisions and contingencies:
Provisions are recognised when the Group has a present obligation (legal or constructive) as a result of a past
event, it is probable that an outflow of resources embodying economic benefits will be required to settle the
obligation and a reliable estimate can be made of the amount of the obligation. Provisions are measured at the best
estimate of the expenditure required to settle the present obligation at the reporting date.
Provisions are determined by discounting the expected future cash flows (representing the best estimate of the
expenditure required to settle the present obligation at the balance sheet date) at a pre-tax rate that reflects current
market assessments of the time value of money and the risks specific to the liability. The unwinding of the discount
is recognized as finance cost. Expected future operating losses are not provided for.
Contingent liabilities are disclosed when there is a possible obligation arising from past events, the existence of
which will be confirmed only by the occurrence or non-occurrence of one or more uncertain future events not
wholly within the control of the Company or a present obligation that arises from past events where it is either not
593probable that an outflow of resources will be required to settle the obligation or a reliable estimate of the amount
cannot be made. Contingent assets are not recognised in financial statements since this may result in the
recognition of income that may never be realised. However, when the realisation of income is virtually certain,
then the related asset is not a contingent asset and its recognition is appropriate. Where an inflow of economic
benefits is probable, the group discloses a brief description of the nature of the contingent assets at the end of the
reporting period, and, where practicable, an estimate of their financial effect, measured using the principles set
out for provisions in Ind AS 37.
4.13 Employee benefits
(i) Short-term obligations
Short-term employee benefits are recognized as an expense at the undiscounted amount in the restated Statement
of Profit and Loss for the year in which the related services are rendered. The Group recognises the costs of bonus
payments when it has a present obligation to make such payments as a result of past events and a reliable estimate
of the obligation can be made.
(ii) Post-employment obligations
Defined contribution plan:
Contribution paid/payable to the recognised provident fund and Employee State Insurance Corporation, which is
a defined contribution scheme, is charged to the Statement of Profit and Loss in the period in which they occur.
Defined benefits plan:
Gratuity is post-employment benefit and is in the nature of defined benefit plan. The liability recognised in the
Balance Sheet in respect of gratuity is the present value of defined benefit obligation at the Balance Sheet date
together with the adjustments for unrecognised actuarial gain or losses and the past service costs. The defined
benefit obligation is calculated at or near the Balance Sheet date by an independent actuary using the projected
unit credit method. Actuarial gains and losses comprise experience adjustment and the effects of changes in
actuarial assumptions are recognized in the period in which they occur, directly in other comprehensive income
in the period in which they occur and are not reclassified to the Statement of Profit and Loss.
The Group has funded its Gratuity liability under group scheme with an Insurer. The retirement benefit obligation
recognised in the balance sheet represents the present value of the defined benefit obligations reduced by the fair
value of the scheme assets. Any asset resulting from this calculation is limited to the present value of any economic
benefits available in the form of refunds from the plans or reductions in future contributions to the scheme.
4.14 Foreign currency translation
(i) Functional and presentation currency
Items included in restated consolidated financial statements of the Group are measured using the currency of the
primary economic environment in which the Group operates (‘the functional currency’). The restated consolidated
financial statements are presented in Indian rupee (INR) in lakhs rounded off to two decimal places except when
otherwise stated as permitted by Schedule III to the Companies Act, 2013, which is Group’s functional and
presentation currency.
(ii) Translation and balances
Foreign currency transactions are translated into the functional currency using the exchange rates at the dates of
the transactions. Foreign exchange gains and losses resulting from the settlement of such transactions and from
the translation of monetary assets and liabilities denominated in foreign currencies at year end exchange rates are
recognized in profit or loss.
594(iii) Translation of subsidiaries
All income and expense items are converted at the average rate of exchange applicable for the period. All assets
and liabilities are translated at the closing rate as on the balance sheet date.
4.15 Dividend Distribution:
Provision is made for the amount of any dividend declared, being appropriately authorized and no longer at the
discretion of the entity, on or before the end of the reporting period but not distributed at the end of the reporting
period.
4.16 Earnings per share
a) Basic earnings per share
Basic earnings per share is calculated by dividing the net profit for the period (excluding other comprehensive
income) attributable to equity share holders of the Group by the weighted average number of equity shares
outstanding during the financial year, adjusted for bonus element in equity shares issued during the year.
b) Diluted earnings per share
Diluted earnings per share is computed by dividing the net profit for the period (excluding other comprehensive
income) attributable to equity shareholders by the weighted average number of shares outstanding during the
period as adjusted for the effects of all diluted potential equity shares except where the results are anti-dilutive.
Further, when a subsidiary issue the potential ordinary shares that are convertible into the ordinary shares of the
subsidiary, to parties other than the parent and if these potential ordinary shares of the subsidiary have a dilutive
effect on the basic earnings per share of the reporting entity, they are included in the calculation of diluted earnings
per share.
4.17 Borrowing Costs
Expenses related to borrowing cost are accounted using effective interest rate. Borrowing costs are interest and
other costs (including exchange differences relating to foreign currency borrowings to the extent that they are
regarded as an adjustment to interest costs) incurred in connection with the borrowing of funds. Borrowing costs
directly attributable to acquisition or construction of an asset which necessarily take a substantial period of time
to get ready for their intended use are capitalised as part of the cost of that asset. Other borrowing costs are
recognised as an expense in the period in which they are incurred.
4.18 Segment Reporting
An operating segment is a component of the Company that engages in business activities from which it may earn
revenues and incur expenses, whose operating results are regularly reviewed by the company’s Chief Operating
Decision Maker (“CODM”) to make decisions for which discrete financial information is available. Based on the
management approach as defined in Ind AS 108, the CODM evaluates the Company’s performance and allocates
resources based on an analysis of various performance indicators by business segments and geographic segments.
4.19 Rounding of amounts
All amounts disclosed in the financial statements and notes have been rounded off to the nearest lakhs as per the
requirements.
4.20 Events after reporting date
595Where events occurring after the balance sheet date provide evidence of conditions that existed at the end of the
reporting period, the impact of such events is adjusted within the financial statements. Otherwise, events after the
balance sheet date of material size or nature are only disclosed.
5A. Key accounting estimates and judgements
The preparation of restated consolidated financial statements requires management to make judgments, estimates
and assumptions in the application of accounting policies that affect the reported amounts of assets, liabilities,
income and expenses. Actual results may differ from these estimates. Estimates and underlying assumptions are
reviewed on ongoing basis. Any changes to accounting estimates are recognized prospectively.
Information about critical judgments in applying accounting policies, as well as estimates and assumptions that
have the most significant effect on the amounts recognised in the restated financial statements are included in the
following notes:
(a) Provision and contingent liability:
On an ongoing basis, Group reviews pending cases, claims by third parties and other contingencies. For contingent
losses that are considered probable, an estimated loss is recorded as an accrual in financial statements. Loss
Contingencies that are considered possible are not provided for but disclosed as Contingent liabilities in the
financial statements. Contingencies the likelihood of which is remote are not disclosed in the financial statements.
Gain contingencies are not recognized until the contingency has been resolved and amounts are received or
receivable.
(b) Allowance for impairment of financial asset:
Judgements are required in assessing the recoverability of overdue and determining whether a provision against
those is required. Factors considered include the ageing of past dues, value of collateral and any possible actions
that can be taken to mitigate the risk of non-payment.
(c) Recognition of deferred tax assets:
Deferred tax assets are recognised for unused tax-loss carry forwards and unused tax credits to the extent that
realisation of the related tax benefit is probable. The assessment of the probability with regard to the realisation
of the tax benefit involves assumptions based on the history of the entity and budgeted data for the future.
(d) Defined benefit plans:
The cost of defined benefit plans and the present value of the defined benefit obligations are based on actuarial
valuation using the projected unit credit method. An actuarial valuation involves making various assumptions that
may differ from actual developments in the future. These include the determination of the discount rate, future
salary increases and mortality rates. Due to the complexities involved in the valuation and its long - term nature,
a defined benefit obligation is highly sensitive to changes in these assumptions. All assumptions are reviewed at
each reporting date.
(e) Property, plant and equipment and Intangible Assets:
Management reviews the estimated useful lives and residual values of the assets annually in order to determine
the amount of depreciation to be recorded during any reporting period. The useful lives and residual values as per
schedule II of the Companies Act, 2013 or are based on the Group’s historical experience with similar assets and
taking into account anticipated technological changes, whichever is more appropriate.
596(f) Business Model assessment:
Classification and measurement of financial assets depends on the results of the business model test. The Company
determines the business model at a level that reflects how groups of financial assets are managed together to
achieve a particular business objective. This assessment includes judgement reflecting all relevant evidence
including how the performance of the assets is evaluated and their performance measured, the risks that affect the
performance of the assets and how these are managed and how the managers of the assets are compensated. The
Company considers the frequency, volume and timing of sales in prior years, the reason for such sales, and its
expectations about future sales activity. However, information about sales activity is not considered in isolation,
but as part of a holistic assessment of how company's stated objective for managing the financial assets is achieved
and how cash flows are realized. Therefore, the Company considers information about past sales in the context of
the reasons for those sales, and the conditions that existed at that time as compared to current conditions.
Monitoring is part of the Company’s continuous assessment of whether the business model for which the
remaining financial assets are held continues to be appropriate and if it is not appropriate whether there has been
a change in business model and so a prospective change to the classification of those assets.
(i) De-recognition of financial instruments - In case of transfer of loans through securitisation and direct
assignment transactions, the transferred loans are de-recognised and gains/losses are accounted for, only
if the Company transfers substantially all risks and rewards specified in the underlying assigned loan
contract. In accordance with the Ind AS 109, on de-recognition of a financial asset under assigned
transactions, the difference between the carrying amount and the consideration received are recognised
in the restated statement of Profit and Loss.
4. Recent Accounting developments
Ministry of Corporate Affairs (“MCA”) notifies new standards or amendments to the existing standards under
Companies (Indian Accounting Standards) Rules as issued from time to time. For the year ended March 31, 2025,
MCA has not notified any new standards or amendments to the existing standards applicable to the Company.
Financial assets that are held within a business model whose objective is achieved by both, selling financial assets
and collecting contractual cash flows that are solely payments of principal and interest, are subsequently measured
at fair value through other comprehensive income. Fair value movements are recognized in the other
comprehensive income (OCI). Interest income measured using the EIR method and impairment losses, if any are
recognised in the Statement of Profit and Loss. On derecognition, cumulative gain or loss previously recognised
in OCI is reclassified from the equity to ‘other income’ in the Statement of Profit and Loss.
Non-GAAP Measures
Certain non-GAAP measures such as Net Asset Value per share, EBITDA, Net Debt to Equity and, Net Fixed
Assets Turnover Ratio among others (“Non-GAAP Measures”) presented in this Draft Red Herring Prospectus,
are a supplemental measure of our performance and liquidity that are not required by, or presented in accordance
with, Ind AS, Indian GAAP, or IFRS. Further, these Non-GAAP Measures are not a measurement of our financial
performance or liquidity under Ind AS, Indian GAAP, or IFRS and should not be considered in isolation or
construed as an alternative to cash flows, profit / (loss) for the year / period or any other measure of financial
performance or as an indicator of our operating performance, liquidity, profitability or cash flows generated by
operating, investing or financing activities derived in accordance with Ind AS, Indian GAAP, or IFRS. In addition,
these Non-GAAP Measures are not a standardised term and, therefore, a direct comparison of similarly titled Non-
GAAP Measures between companies may not be possible. Other companies may calculate the Non-GAAP
Measures differently from us, limiting their usefulness as a comparative measure. Although the Non-GAAP
Measures are not a measure of performance calculated in accordance with applicable accounting standards, our
Company’s management believes that they are useful to an investor in evaluating us because these are widely
used measures to evaluate a company’s operating performance.
Also see “Risk Factors- Certain non-GAAP financial measures and certain other statistical information relating
to our operations and financial performance such as EBITDA, EBITDA margin, interest coverage ratio, net debt
597to EBITDA ratio, return on capital employed and return on equity have been included in this Draft Red Herring
Prospectus. These non-GAAP financial measures are not measures of operating performance or liquidity defined
by Ind AS and may not be comparable” on page 78.
Reconciliation of Net Asset Value per Equity Share
The table below reconciles the net asset value per Equity Share with respect to our Company derived from the
Restated Consolidated Financial Information.
(in lakhs, unless stated otherwise)
Particulars Year ended March 31,
2025 2024 2023
Net Worth of the Company (I) 16,808.98 15,054.13 11,745.98
Weighted average number of equity shares at the end of
157.54 157.54 157.54
the year (II)
Net asset value per equity share (III = I/II) (₹ per equity
106.70 95.56 74.56
share)
Reconciliation of EBITDA
The table below reconciles profit for the year to EBITDA with respect to our Company derived from the Restated
Consolidated Financial Information.
(₹ in lakhs, unless stated otherwise)
Particulars Year ended March 31,
2025 2024 2023
Restated Profit Before Tax for the year (I) 3,140.22 2,400.68 1,016.00
Adjustments:
Less: Other income (II) (19.12) (122.93) (64.66)
Add: Exceptional Items (III) - - -
Add: Finance costs (IV) 246.08 90.98 31.24
Add: Depreciation and amortization expenses (V) 164.14 144.24 132.02
Earnings Before Interest, Tax, Depreciation and 3,531.31 2,512.97 1,114.59
Amortization (EBITDA) (VIII = I - II + III + IV + V)
Reconciliation of total borrowings to Net Debt and Net Debt to Equity
(₹ in lakhs, unless stated otherwise)
Particulars Year ended March 31,
2025 2024 2023
Total Borrowings (Current + Non-Current) (I) 570.81 353.52 803.42
Adjustments:
Less: Cash and cash equivalents (II) 8,511.14 13,006.98 2,837.68
Less: Other Bank Balance (III) 7,342.30 4,544.86 7,444.71
Add: Fixed Deposit under Lien (IV)* 13,089.25 13,378.71 7,312.65
Net Debt (IV = I - II - III + IV) -2,193.38 -3,819.61 -2,166.33
Total Equity (V) 16,808.98 15,054.13 11,745.98
Net Debt to Equity (VI = IV/V) NA NA NA
*Fixed deposits held as lien with stock exchanges/clearing corporations are excluded from Cash & Bank Balances for the purpose of Net
Debt calculation.
Reconciliation of Revenue from Operations to Net Fixed Assets Turnover Ratio
(₹ in lakhs, unless stated otherwise)
Particulars Year ended March 31,
2025 2024 2023
Revenue from Operations (I) 9,427.39 7,782.36 5,168.30
Investment Property (II) 86.35 90.77 -
Property, plant and equipment (III) 1,995.47 1,972.67 1,949.44
Capital work-in-progress (IV) 107.54 39.84 7.23
Right to use assets (V) 108.27 112.99 117.71
Intangible assets under development (VI) 13.94 13.94 1.50
Intangible assets (VII) 58.13 60.48 65.47
Total Net Fixed Assets (VIII = II + III + IV + V + VI+ 2,369.71 2,290.70 2,141.35
598Particulars Year ended March 31,
2025 2024 2023
VII)
Net Fixed Assets Turnover Ratio (IX = I/ VIII) 3.98 3.40 2.41
KEY COMPONENTS OF OUR RESTATED CONSOLIDATED STATEMENT OF PROFIT AND LOSS
Set forth below are the key components of our statement of profit and loss from our restated statement of profit
and loss for Fiscal 2025, Fiscal 2024 and Fiscal 2023:
Total Income
Our total income comprises (i) Revenue from Operations; and (ii) Other Income.
Revenue from Operations
Revenue from Operations comprises (i) Interest Income; (ii) Dividend income; and (iii) Rental Income (iv) Fees
and Commission Income (v) Net gain/ (loss) on fair value changes (vi) Sale of Product (Commodities) (vii) Sale
of Service (Consultancy) and other operating income.
Other Income
Other income comprises (i) Interest Income, Profit / (loss) on sale of fixed assets, Foreign Exchange Fluctuations,
LES Incentive, Business Support Services and Miscellaneous Incomes.
Expenses
Our expenses comprise of Fees and Commission expenses, purchase of stock-in-trade, change in inventories of
commodities, Impairment on financial instruments, employee benefit expenses, finance costs, depreciation &
amortisation expenses, and other expenses.
Fees and Commission Expenses
Fees and Commission Expenses encompass following key components: (i) Brokerage & Commission Expenses;
and (ii) Depository Charges; (iii) Exchange Transaction Charges.
Purchase of stock-in-trade
Purchase of stock-in-trade consists of purchase of commodities for which gross delivery has been taken to settle
the transaction.
Changes in inventories of stock-in-trade
Changes in inventories of Stock-in-trade (Commodities) consists of a difference in inventories at the end of the
year and inventories at the beginning of the year.
Employee Benefits Expenses
Employee benefits expenses primarily comprise of salaries, bonus, incentives, director remuneration, contribution
to provident and other funds, staff welfare expenses, gratuity and other long term benefits.
Finance Costs
Finance cost primarily comprises of Interest cost on borrowings.
Details of our finance cost on consolidated basis for Fiscals 2025, 2024 and 2023 are set out below:
(in ₹ lakhs)
Particulars Fiscal 2025 Fiscal 2024 Fiscal 2023
Interest cost on borrowings 246.08 90.98 31.24
599Depreciation and Amortization Expenses
Depreciation and amortization expenses primarily comprises depreciation on property, plant and equipment,
depreciation on right of use assets and depreciation on intangible assets.
Other Expenses
Other expenses primarily comprise office expenses, legal and professional charges, software expense and bank
charges, stock exchange charges, telephone & communication expense, travelling & conveyance expense,
corporate social responsibility expenditure, electricity charges, rent, rates & taxes and miscellaneous expenses.
RESULTS OF OPERATIONS
The following table sets forth our selected financial data from our restated statement of profit and loss for Fiscal
2025, Fiscal 2024 and Fiscal 2023, the components of which are also expressed as a percentage of total income
for such years:
Fiscal 2025 Fiscal 2024 Fiscal 2023
As a % of As a % of
Particulars As a % of In ₹
In ₹ Lakhs Total In ₹ Lakhs Total
Total Income Lakhs
Income Income
Income
Revenue from Operations 9,427.39 99.80% 7,782.36 98.44% 5,168.30 98.76%
Other income 19.12 0.20% 122.93 1.56% 64.66 1.24%
Total income (A) 9,446.51 100.00% 7,905.29 100.00% 5,232.96 100.00%
Expenses
Fees and commission expense 3,801.13 40.24% 3,378.43 42.74% 2,256.57 43.12%
Purchases of stock-in-trade - - 35.74 0.45% - -
Changes in inventories of - - - - 207.05 3.96%
finished goods, work-in-
progress and stock-in-trade
Impairment on Financial (0.87) (0.01%) (1.82) (0.02%) 22.23 0.42%
Instruments
Employee benefits expenses 1,151.50 12.19% 1,092.19 13.82% 957.05 18.29%
Finance costs 246.08 2.61% 90.98 1.15% 31.24 0.60%
Depreciation and amortization 164.14 1.74% 144.24 1.82% 132.02 2.52%
expenses
Other expenses 944.31 10.00% 764.85 9.68% 638.10 12.19%
Total expenses (B) 6,306.29 66.76% 5,504.61 69.63% 4,244.26 81.11%
Profit before tax (C= A-B) 3,140.22 33.24% 2,400.68 30.37% 988.70 18.89%
Tax expense
- Current tax 831.30 8.80% 591.20 7.48% 257.87 4.93%
(28.36) (0.30%) 5.30 0.07% (0.92) (0.02%)
- Deferred tax
- Prior year tax adjustments (4.28) (0.05%) (1.02) (0.01%) (8.72) (0.17%)
Total tax expenses (D) 798.66 8.45% 595.48 7.53% 248.23 4.74%
Profit for the year (E= C-D) 2,341.56 24.79% 1,805.20 22.84% 740.47 14.15%
Share of profit from associate - - - - 27.30 0.52%
Profit after tax and share in
2,341.56 24.79% 1,805.20 22.84% 767.77 14.67%
profit in associate
Net Profit attribute to:
Owners of parent 2,338.50 24.76% 1,793.38 22.69% 763.17 14.58%
Non-Controlling Interest 3.06 0.03% 11.82 0.15% 4.60 0.09%
KEY BUSINESS HIGHLIGHTS
Our Revenue from Operations increased from ₹5,168.30 lakhs in Fiscal 2023 to ₹9,427.39 lakhs in Fiscal 2025.
Revenue split: Product category
600Our business is categorized into product families, namely, (i) Fees, Commission & Brokerage Income; (ii) Interest
Income (iii) Dividend income; and (iv) Rental Income (v) Net gain/ (loss) on fair value changes (vi) Sale of
Product (Commodities) (vii) Sale of Service (Consultancy) and Other Operations.
Fees and Commission Income
We derive the majority of our income from fees and commissions, which mainly include brokerage income and
depository income. Our Fees and Commission Income stood at ₹6,759.19 lakhs in Fiscal 2025, ₹5,843.20 lakhs
in Fiscal 2024, and ₹3,932.46 lakhs in Fiscal 2023. This steady growth has been driven by an increase in trading
volumes, higher client participation, and consistent growth in our depository services. Brokerage income remains
the largest contributor, accounting for the bulk of this revenue, while depository income provides a stable recurring
stream that supports our overall business operations.
Interest Income
We derive a portion of our Revenue from Operations from Interest Income, which primarily comprises interest
on loans, deposits with banks, margin funding, delayed payments, bonds, and late payment charges on AMC.
Revenue from Interest Income was ₹2,503.63 lakhs in Fiscal 2025, ₹1,578.60 lakhs in Fiscal 2024, and ₹1,141.73
lakhs in Fiscal 2023. The significant growth in Fiscal 2025 was primarily driven by higher income from interest
on delayed payments and deposits with banks, along with the introduction of interest from margin funding.
Dividend Income
We also generate a portion of our Revenue from Operations through Dividend Income arising from our
investments. Dividend Income stood at ₹61.27 lakhs in Fiscal 2025, ₹74.92 lakhs in Fiscal 2024, and ₹47.98 lakhs
in Fiscal 2023. The movement across the years reflects fluctuations in returns from our investment portfolio,
which are largely dependent on the performance and dividend distribution policies of the underlying companies
however, its not a part of our core broking business, Dividend Income provides an additional source of steady
returns and supports overall profitability.
Rental Income
We also generate some income by giving out a part of our premises on rent. Rental Income was ₹10.08 lakhs in
Fiscal 2025, ₹8.94 lakhs in Fiscal 2024, and ₹6.00 lakhs in Fiscal 2023. This shows a steady increase over the
years and provides us with an additional source of income, though it is not part of our core broking operations.
Net gain/ (loss) on fair value changes
We also generate income and incur loss from changes in the fair value of our trading and investment portfolio,
which includes Future & Option Derivatives, Equity Securities held for trading, and Mutual Fund Investments.
Net gain on fair value changes was ₹72.02 lakhs in Fiscal 2025, ₹198.59 lakhs in Fiscal 2024, compared to a net
loss of ₹191.44 lakhs in Fiscal 2023. These movements are mainly linked to realized and unrealized gains or
losses arising from market fluctuations. While such income is not part of our core broking operations, it reflects
the performance of our proprietary trading and treasury activities and can vary from year to year depending on
market conditions.
Sale of Product (Commodities)
We also generate income from the sale of commodities, though this is not a core part of our broking business. Net
sales from commodities were Nil in Fiscal 2025, ₹35.42 lakhs in Fiscal 2024, and ₹199.34 lakhs in Fiscal 2023.
The decline over the last two years reflects our strategic focus on core broking and financial services, with limited
reliance on commodity trading as a source of revenue.
Sale of Service (Consultancy)
We also generate income from consultancy services offered to clients through our subsidiary company, SIHL
Consultancy. The Consultancy Income was ₹21.20 lakhs in Fiscal 2025, ₹40.48 lakhs in Fiscal 2024, and ₹17.13
lakhs in Fiscal 2023. These earnings vary from year to year depending on the demand for advisory and related
services. While not a major part of our core broking operations, consultancy services provide us with an additional
601source of revenue and help strengthen our client relationships.
FISCAL 2025 COMPARED TO FISCAL 2024
Income
Total income increased by 19.50% from ₹7,905.29 lakhs in Fiscal 2024 to ₹9,446.51 lakhs in Fiscal 2025. This
was primarily attributable to an increase in Revenue from Operations and other income.
Revenue from Operations
In Fiscal 2025, our Revenue from Operations grew by 21.14%, rising from ₹7,782.36 lakhs in Fiscal 2024 to
₹9,427.39 lakhs in Fiscal 2025. This growth was mainly driven by Brokerage and fees income, which grew by
15.68% amounting to ₹5,843.20 lakhs in Fiscal 2024 to ₹6,759.19 lakhs in Fiscal 2025, reflecting higher client
activity and increased traded value which increased from ₹ 47,59,230.71 lakhs in fiscal 2024 to ₹ 59,44,704.02
lakhs. An increase in interest income, which rose by 58.60% to ₹ 2,503.63 lakhs in Fiscal 2025, was supported by
higher delayed payment charges, better returns on bank deposits, and the introduction of margin trading facility
during the year. Rental income also registered a steady growth of 12.75%, increasing to ₹10.08 lakhs in Fiscal
2025 from ₹ 8.94 lakhs in Fiscal 2024.
On the other hand, dividend income decreased by 18.22% to ₹61.27 lakhs in Fiscal 2025 as compared to ₹74.92
lakhs in Fiscal 2024, net gains on fair value changes contracted by 63.73% to ₹72.02 lakhs in Fiscal 2025 from ₹
198.59 lakhs in Fiscal 2024 due to lower derivative and mutual fund gains.
Further, sale of services which consists of consultancy income fell by 47.63% amounting to ₹21.20 lakhs in Fiscal
2025 to ₹40.48 lakhs in Fiscal 2024. In addition, there were no commodity sales or other operating income
recorded in Fiscal 2025 compared to income of ₹ 35.42 lakhs in Fiscal 2024.
Overall, in Fiscal 2025, our revenue profile became even more concentrated in our core brokerage segment which
alone contributed 71.70% of total revenues, highlighting the Company’s stronger focus on its main broking
business while reducing reliance on smaller, non-core income sources.
Other income
In Fiscal 2025, Other income stood at ₹19.12 lakhs, which saw a steep decline of 84.45% compared to ₹122.93
lakhs in Fiscal 2024 and shrinking its contribution to total income from 1.56% in Fiscal 2024 to 0.20% in Fiscal
2025 reaffirming the Company’s dependence on core operating revenues. This fall was primarily attributable to a
decline in interest on IT refunds arising out of favourable decision in an on-going litigation, which had contributed
₹106.05 lakhs in Fiscal 2024 as compared to ₹ 0.50 lakhs in Fiscal 2025. Similarly, other interest income reduced
to ₹0.34 lakhs to ₹3.38 lakhs, while income from business support services fell to ₹12.93 lakhs in fiscal 2025 from
₹31.73 lakhs in fiscal 2024. On the positive side, the Company reported a profit on sale of fixed assets of ₹1.46
lakhs in Fiscal 2025, reversing a loss of ₹22.63 lakhs in Fiscal 2024, and foreign exchange fluctuation gains arising
from our operations increased slightly to ₹3.89 lakhs from ₹2.10 lakhs in Fiscal 2024 while there was no incentive
income from liquidity enhancement scheme reported in Fiscal 2025 as compared to ₹2.21 lakhs in Fiscal 2024.
Expenses
Total expenses increased by 14.56% from ₹5,504.61 lakhs in Fiscal 2024 to ₹6,306.29 lakhs in Fiscal 2025
because of the reasons set out below.
Fees and commission expense
Fees and Commission Expense increased by 12.51%, from ₹3378.43 lakhs in Fiscal 2024 to ₹3801.13 lakhs in
Fiscal 2025. The increase was primarily driven by higher brokerage sharing with intermediaries, which rose from
₹3,078.94 lakhs in Fiscal 2024 to ₹3,463.18 lakhs in Fiscal 2025, attributable to increased trading volumes and
client activity. Exchange transaction charges also increased from ₹283.60 lakhs in Fiscal 2025 to ₹245.17 lakhs,
contributing to the overall rise in expenses. Other component such as depository charges remained relatively
stable.
Purchases of stock-in-trade
602Purchases of Commodities is Nil in Fiscal 2025 whereas in Fiscal 2024 its ₹35.74 lakhs.
Employee benefits expenses
Employee Benefit Expense has increased by 5.43% from 1,092.20 lakhs in Fiscal 2024 to ₹1,151.50 lakhs in
Fiscal 2025. Our company’s number of employees increased from 145 on March 31, 2024 to 171 on March 31,
2025, which increased the salary expense of the employees by 8.94% to ₹ 756.10 lakhs from ₹ 694.06 lakhs. On
the other hand due to decrease in Director Remuneration by 5.55% to ₹ 321.44 lakhs in Fiscal 2025 from ₹ 340.34
lakhs in Fiscal 2024. Contributions to provident and other funds, as well as gratuity and other long-term benefits,
saw minor increases.
Finance costs
Finance cost on borrowings increased significantly by 170.48% from ₹90.98 lakhs in Fiscal 2024 to ₹246.08 lakhs
in Fiscal 2025. In addition to the increase in borrowings from ₹353.51 lakhs as on March 31, 2024 to ₹570.80
lakhs as on March 31, 2025, this sharp rise is due to the finance cost reflecting a timing difference between the
average borrowings during the year and the closing balance as on the balance sheet date.
Depreciation and amortization expenses
Depreciation and amortization expenses increased by 13.80% from ₹144.24 lakhs in Fiscal 2024 to ₹164.14 lakhs
in Fiscal 2025, primarily due to higher depreciation on property, plant and equipment on account of net addition
in fixed assets by ₹163.13 lakhs during the year.
Other expenses
In Fiscal 2025, other expenses increased by 23.46% to ₹944.31 lakhs from ₹764.85 lakhs in Fiscal 2024, largely
driven by increased business and operational activities. Travelling and conveyance expenses doubled from ₹ 33.81
lakhs in fiscal 2024 to ₹ 67.87 lakhs in fiscal 2025, reflecting greater business development initiatives, while
communication expenses and selling & distribution costs also recorded increases. Selling & distribution costs
increased from ₹ 18.35 lakhs in fiscal 2024 to ₹ 51.28 lakhs in fiscal 2025. Exchange charges and miscellaneous
expenses witnessed significant growth in line with increased financial and administrative activities. Exchange
charges increased from ₹ 56.39 lakhs in fiscal 2024 to ₹ 95.42 lakhs. Legal and professional charges continued to
remain a major cost component, rising moderately, whereas office management expenses and software expenses
remained largely stable with marginal fluctuations. CSR expenditure also increased during the year.
Profit/ (loss) before tax
Our profit before tax increased by 30.81% from ₹2,400.68 lakhs in Fiscal 2024 to ₹3,140.22 lakhs in Fiscal 2025
for the reasons laid out above.
Income tax expense
Income tax expenses increased by 40.61% from ₹595.48 lakhs in Fiscal 2024 to ₹798.66 lakhs in Fiscal 2025,
primarily on account of higher current tax provisions. Current tax expense increased by 40.61%, from ₹591.20
lakhs in Fiscal 2024 to ₹831.30 lakhs in Fiscal 2025, mainly due to a rise in profit before tax during the year.
Profit/ (loss) for the year
Profit after tax increased by 29.71% from ₹1,805.20 lakhs in Fiscal 2024 to ₹2,341.56 lakhs in Fiscal 2025. The
PAT margin attributable to owners of the company improved from 23.04% of total revenue in Fiscal 2024 to
24.81% of total revenue in Fiscal 2025. This improvement was primarily driven by overall improvement in
Operating EBITDA margin.
FISCAL 2024 COMPARED TO FISCAL 2023
Income
Total income increased by 51.07% from ₹5,232.96 lakhs in Fiscal 2023 to ₹7,905.29 lakhs in Fiscal 2024 for the
reasons mentioned below.
603Revenue from Operations
In Fiscal 2024, our revenue from operations grew by 50.58%, increasing from ₹5,168.30 lakhs in Fiscal 2023 to
₹7,782.36 lakhs in Fiscal 2024. The growth was mainly supported by increased income in brokerage and fees
income, which rose by 48.59% to ₹5,843.20 lakhs in fiscal 2024 from ₹ 3,932.46 lakhs in fiscal 2023 reflecting
higher client activity and increased traded value which increased to ₹ 47,59,230.71 lakhs in fiscal 2024 from ₹
41,33,386.81 lakhs. Growth in interest income is by 38.26% from ₹1,141.73 lakhs in Fiscal 2023 to ₹1,578.60
lakhs in Fiscal 2024, driven by higher bank deposits and delayed payment charges. Dividend income increased
by 56.15% to ₹74.92 lakhs, while rental income improved by 49.00% to ₹8.94 lakhs.
A notable turnaround was seen in net gain on fair value changes, which moved from a loss of ₹191.44 lakhs in
Fiscal 2023 to a gain of ₹198.59 lakhs in Fiscal 2024, driven by improved performance in the derivatives segment.
On the other hand, commodity sales fell sharply by 82.23% amounting to ₹35.42 lakhs in fiscal 2024 from ₹199.34
lakhs in fiscal 2023, while consultancy income increased to ₹40.48 lakhs from ₹17.13 lakhs in Fiscal 2023. Other
operating income from the trading of listed bonds declined significantly from ₹15.10 lakhs to ₹ 2.21 lakhs.
Overall, in Fiscal 2024, the Company’s revenue mix was dominated by its core brokerage segments, which
contributed nearly 75.08% of total revenues.
Other income
Other income increased significantly by 90.12%, rising from ₹64.66 lakhs in Fiscal 2023 to ₹122.93 lakhs in
Fiscal 2024. The growth was primarily attributable to interest on IT refunds, which surged from ₹0.62 lakhs in
Fiscal 2023 to ₹106.05 lakhs in Fiscal 2024, due to a favourable outcome in an ongoing income tax litigation,
alongside a 34.11% increase in income from business support services and miscellaneous income from ₹23.66
lakhs to ₹31.73 lakhs. These gains were partly offset by adverse movements such as a loss on sale of fixed assets
of ₹ (22.63) lakhs in Fiscal 2024 as compared to a profit of ₹17.33 lakhs in Fiscal 2023, and a reduction in foreign
exchange fluctuation gains from ₹16.64 lakhs to ₹2.10 lakhs over the same period, attributable to the IFSC
operations. However, additional contributions came from the liquidity enhancement scheme (“LES”) incentive of
₹2.21 lakhs during Fiscal 2024, which were absent in the prior year. Overall, the increase in other income was
largely driven by the one-time IT refund and higher business support income, which outweighed losses on asset
sales and lower foreign exchange gains.
Expenses
Total expenses increased by 29.70% from ₹4,244.26 lakhs in Fiscal 2023 to ₹5,504.61 lakhs in Fiscal 2024 for
the reasons mentioned below.
Fees and commission expense
In Fiscal 2024, Fees and Commission Expense increased by 49.72%, from ₹2,256.57 lakhs in Fiscal 2023 to
₹3,378.43 lakhs. The sharp rise was primarily driven by higher brokerage sharing with intermediaries, which grew
from ₹ 1,964.08 lakhs in Fiscal 2023 to ₹ 3,078.94 lakhs in Fiscal 2024, reflecting growth in trading volumes and
brokerage income. Depository charges also rose moderately to ₹40.95 lakhs from ₹53.84 lakhs, while brokerage
& commission expense reduced from ₹0.52 lakhs in Fiscal 2025 to ₹0.48 lakhs. In contrast, exchange transaction
charges declined slightly from ₹251.02 lakhs in Fiscal 2023 to ₹245.17 lakhs in Fiscal 2024, slightly offsetting
the overall increase. Overall, the rise in Fees and Commission Expense was directly aligned with revenue growth,
indicating higher business activity while maintaining cost scalability.
Purchases of stock-in-trade
Purchases of stock-in-trade of commodities is Nil in Fiscal year 2023 as compared to ₹ 35.74 lakhs in Fiscal 2024.
Employee benefits expenses
Employee Benefit Expense has increased by 14.12% from ₹957.05 lakhs in Fiscal 2023 to ₹1,092.19 lakhs in
Fiscal 2024. Our company’s number of employees increased from 139 on March 31, 2023 to 145 on March 31,
2024, which increased the salary expense of the employees by 36.01% to ₹694.06 lakhs from ₹510.29 lakhs. On
the other hand there is a decrease in Director Remuneration by 5.43% to 340.34 lakhs from 359.88 lakhs.
604Contributions to provident and other funds, as well as gratuity and other long-term benefits, remained consistent.
Finance costs
Finance cost increased from ₹31.24 lakhs in Fiscal 2023 to ₹90.98 lakhs in Fiscal 2024. This was primarily
attributable to higher average borrowings during the year, even if the closing balance of borrowings as on March
31, 2024 does not capture the extent of borrowing levels throughout the year.
Depreciation and amortization expenses
Depreciation and amortization expenses increased by 9.26% from ₹132.02 lakhs in Fiscal 2023 to ₹144.24 lakhs
in fiscal 2024 primarily due to an increase in depreciation on Property, plant & equipment i.e. from ₹ 122.94 lakhs
in fiscal 2023 to ₹ 141.72 lakhs in fiscal 2024.
Other expenses
In fiscal 2024, the company’s other expenses increased by 19.86% to ₹764.85 lakhs from ₹638.10 lakhs in Fiscal
2023, mainly due to the increase in Office Management Expenses by ₹70.44 lakhs from ₹ 55 lakhs in fiscal 2023
to ₹ 125.44 lakhs in fiscal 2024 and Exchange charges which increased by ₹ 35.08 lakhs from ₹ 21.31 lakhs in
fiscal 2023 to ₹ 56.39 lakhs in fiscal 2024 indicating higher business activity. Overall, the expense pattern
demonstrates effective cost management while supporting business growth.
Profit/ (loss) before tax
Profit before tax increased by 142.81% from ₹988.70 lakhs in Fiscal 2023 to ₹2,400.66 lakhs in Fiscal 2024
primarily due to the reasons set out above.
Income tax expense
In Fiscal 2024, the company’s total tax expense increased by 139.89% to ₹ 595.48 lakhs from ₹ 248.23 lakhs in
Fiscal 2023, primarily due to a higher current tax liability, which rose from ₹ 257.87 lakhs to ₹ 591.20 lakhs,
reflecting improved profitability during the year.
Profit/(Loss) for the year
Profit for the year increased by 135.12% from ₹767.77 lakhs in Fiscal 2023 to ₹1,805.20 lakhs in Fiscal 2024, for
the reasons set out above. Majorly due to employee benefit expenses which increased in absolute term but
decreased as a percentage of total income from 18.29% of total income in fiscal 2023 to 13.82% of total income
in fiscal 2024 and other expenses which increased in absolute term but decreased as a percentage of total income
from 12.19% of total income in fiscal 2023 to 9.68% of total income in fiscal 2024. The PAT margin attributable
to owners of the company improved from 14.58% of total income in Fiscal 2023 to 22.69% of total income in
Fiscal 2024. This improvement was primarily driven by overall improvement in Operating EBITDA margin.
LIQUIDITY AND CAPITAL RESOURCES
Capital Requirements
Historically, our Company has been able to finance the growth of our business through the funds generated from
our operations, debt facilities from banks and equity. Our Company believes that, with the portion of the Issue
Proceeds which will be utilised for working capital, it will have sufficient capital to meet its anticipated capital
requirements for working capital requirements.
Cash Flow
Our anticipated cash flows are dependent on various factors that are beyond our control. The following table sets
forth certain information relating to our cash flows in Fiscal 2025, 2024 and 2023:
(in ₹ lakhs)
For the year ended For the year ended For the year ended
Particulars
March 31, 2025 March 31, 2024 March 31, 2023
Net cash generated from/ (used in) operating (3,186.22) 11,019.42 0.45
605For the year ended For the year ended For the year ended
Particulars
March 31, 2025 March 31, 2024 March 31, 2023
activities
Net cash generated from/(used in) investing
(1,123.27) (152.17) (1,988.83)
activities
Net cash generated from/ (used) in financing
(186.35) (697.95) 689.79
activities
Net increase/ (decrease) in cash and cash
(4,495.84) 10,169.30 (1,298.59)
equivalents
Cash Flows of Operating Activities
Fiscal 2025
In Fiscal 2025, net cash used in operating activities stood at ₹3,186.22 lakhs. The Company reported a profit
before tax of ₹3,140.22 lakhs, with operating profit before working capital changes amounting to ₹3,414.82 lakhs
after adjustments for depreciation and amortization of ₹164.14 lakhs, finance costs of ₹246.08 lakhs, dividend
income of ₹61.27 lakhs and unrealized fair value loss of ₹ 72.02 lakhs.
Moreover, decrease movements in working capital had a significant impact during the year, decrease was
primarily driven by other bank balances of ₹ 2,797.44 lakhs, trade and other receivables of ₹ 907.12 lakhs, loans
given of ₹578.06 lakhs and trade payables of ₹1,237.90 lakhs, along with changes in other non-financial assets,
liabilities and provisions. Net income tax paid for Fiscal 2025 was ₹963.07 lakhs.
Fiscal 2024
In Fiscal 2024, net cash generated from operating activities amounted to ₹11,019.42 lakhs. The Company reported
a profit before tax of ₹2,400.68 lakhs, with operating profit before working capital changes at ₹2,383.20 lakhs,
after incorporating adjustments such as depreciation and amortization of ₹144.24 lakhs, finance costs of ₹ 90.98
lakhs, dividend income of ₹74.92 lakhs, impairment on financial instruments of ₹1.82 lakhs, unrealized fair value
gains of ₹198.59 lakhs, and loss on sale of fixed assets of ₹22.63 lakhs.
Working capital changes during the year had a substantial positive impact, primarily driven by an increase in bank
balances of ₹2,899.84 lakhs, trade and other receivables of ₹317.27 lakhs and loans given of ₹ 498.00 lakhs, along
with a significant increase in trade payables of ₹5,315.61 lakhs. Additional movements included a decrease in
other non-financial assets of ₹ 51.05 lakhs, an increase in other financial liabilities of ₹ 8.67 lakhs, an increase in
other non-financial liabilities of ₹63.06 lakhs, and an increase in provisions of ₹106.03 lakhs, all of which further
supported the cash inflows during the year.
The Company also paid net income tax of ₹ 546.79 lakhs during the year.
Fiscal 2023
In Fiscal 2023, net cash generated from operating activities amounted to ₹0.45 lakhs. Our Company reported a
profit before tax of ₹988.70 lakhs, with operating profit before working capital changes at ₹1,033.58 lakhs, after
considering adjustments such as depreciation and amortization of ₹132.02 lakhs, finance costs of ₹31.24 lakhs,
dividend income of ₹ 47.98 lakhs, impairment on financial instruments of ₹22.23 lakhs, unrealized fair value
losses of ₹ 75.30 lakhs, and a gain on sale of fixed assets of ₹17.73 lakhs.
Working capital movements during the year had a mixed impact. Significant changes included a decrease in other
bank balances of ₹1,519.31 lakhs, a decrease in loans given of ₹617.11 lakhs, and an increase in inventories of ₹
207.05 lakhs, which negatively affected cash flows. On the other hand, positive contributions arose from an
increase in trade and other receivables of ₹120.28 lakhs, an increase in other non-financial assets of ₹70.33 lakhs,
and a substantial increase in trade payables of ₹1,065.82 lakhs. Additional changes comprised a decrease in other
financial liabilities of ₹ 60.38 lakhs, a decrease in other non-financial liabilities of ₹18.12 lakhs, and a reduction
in provisions of ₹ 7.29 lakhs.
The Company also paid net income tax of ₹276.00 lakhs during the year.
Cash Flow of Investing Activities
606Fiscal 2025
In Fiscal 2025, net cash used in investing activities stood at ₹ 1,123.27 lakhs. The major outflow was driven by
purchase of investments amounting to ₹943.14 lakhs and capital expenditure of ₹ 241.40 lakhs towards fixed
assets. These outflows were partially offset by dividend income of ₹61.27 lakhs received during the year. Overall,
the firm recorded a substantial cash outflow under investing activities, primarily reflecting its increased allocation
towards investments and asset acquisition.
Fiscal 2024
During Fiscal 2024, net cash used in investing activities was ₹152.17 lakhs. The outflows were mainly due to
purchase of fixed assets worth ₹164.39 lakhs and investment purchases of ₹ 62.70 lakhs. These were offset to
some extent by dividend income of ₹74.92 lakhs, which reduced the overall outflow. The lower level of investment
activity compared to the prior and subsequent year indicates a relatively stable year in terms of capital allocation.
Fiscal 2023
In Fiscal 2023, the firm reported a significant cash outflow of ₹ 1,988.83 lakhs under investing activities. This
was primarily attributable to a large investment outlay of ₹1,348.07 lakhs and fixed asset purchases of ₹689.10
lakhs. Dividend income of ₹48.34 lakhs provided only a limited offset. The magnitude of outflows in this year
highlights a phase of heavy investment activity, both in terms of financial investments and asset acquisition.
Cash Flow of Financing Activities
Fiscal 2025
During Fiscal 2025, the Company reported a net cash outflow of ₹186.35 lakhs from financing activities.
Comprising primarily proceeds from borrowing of ₹217.29 lakhs, payment of finance costs amounted to ₹246.08
lakhs and dividend pay-outs aggregated to ₹157.56 lakhs. The negative financing cash flow reflects higher finance
costs and shareholder pay-outs relative to borrowing inflows.
Fiscal 2024
In Fiscal 2024, financing activities resulted in a net cash outflow of ₹697.95 lakhs. The primary contributor to this
outflow was repayment of borrowings of ₹449.89 lakhs. This, coupled with dividend payments of ₹157.08 lakhs
and finance cost outgo of ₹ 90.98 lakhs, led to a sizeable net reduction in cash from financing. The year reflects
higher repayment.
Fiscal 2023
In Fiscal 2023 recorded a net cash inflow of ₹689.79 lakhs from financing activities. The inflow was largely driven
by fresh borrowings of ₹799.80 lakhs. Against this, outflows were limited to dividend payments of ₹78.77 lakhs
and finance costs of ₹31.24 lakhs. This indicates that financing requirements in Fiscal 2023 were primarily met
through borrowings, resulting in a net positive cash flow.
Financial Indebtedness
As of August 31, 2025, we had outstanding working capital facilities amounting to ₹ 9,458.62 lakhs. The details
of our indebtedness (on a consolidated basis) as on August 31, 2025 is provided below:
(in ₹ lakhs)
Amount outstanding
Sr. No. Nature of facility Sanctioned amount
as on August 31, 2025
Secured
Fund Based Borrowings
1. Intraday facility 2,000.00 -
2. Cash credit 1,000.00 -
3. Overdraft Against Property (Sub limit: Overdraft 3,000.00 1,239.52
Against Shares)
4. Overdraft Against Fixed Deposit 2500.00 73.24
607Amount outstanding
Sr. No. Nature of facility Sanctioned amount
as on August 31, 2025
5. Vehicle Loan 99.45 78.33
6. Loan Against Security 4,000.00 1,968.71
Sub total (A) 12,599.45 3,359.80
Non Fund Based Borrowings
7. Bank Guarantee 1,1500.00 6,000.00
Sub total (B) 1,1500.00 6,000.00
Total (C= A+B) 24,099.45 9,359.80
Unsecured
8. Inter Company Loan 98.82 98.82
Total (D) 98.82 98.82
Total (C+D) 24,198.27 9,458.62
Contingent liabilities
As of March 31, 2025, our contingent liabilities and guarantees identified under the Ind AS 37, on a consolidated
basis, were as follows:
(₹ in lakhs)
Contingent liabilities: As at March 31,2025
Bank Guarantees given 6,000.00
Demand in respect of income tax matters for which appeal is pending 419.94
Total 6419.94
There are no Capital commitments for the year ended March 31, 2025.
For details of our contingent liability and guarantees as at March 31, 2025 as per Ind AS 37, see “Restated
Financial Information – Note - 34: Notes to Restated Ind AS Consolidated Summary Statements – Contingent
Liability and Commitment” on page 503.
Off-balance sheet arrangements
There are no off-balance sheet arrangements that have or are reasonably likely to have a current or future effect
on our financial condition, revenues or expenses, results of operations, liquidity, capital expenditures or capital
resources that we believe are material to investors.
Qualifications and Emphasis of Matter
There have been no reservations or qualifications or adverse remarks of our Statutory Auditors in fiscals 2025,
2024 and 2023.
Related Party Transactions
We enter into various transactions with related parties in the ordinary course of business. These transactions
principally include rent payments, capital advances, repayment of advances given and remuneration paid to
Directors.
For details, see “Related Party Transactions” on page 577. Also, see “Risk Factors – We have in the past entered
into related party transactions and may continue to enter into such transactions under Ind AS 24, in the future,
and there can be no assurance that we could not have achieved more favourable terms had such transactions not
been entered into with related parties” on page 57.
Quantitative and Qualitative Disclosures About Market Risk
Our management monitors and manages key financial risk relating to our operations by analysing exposures by
degree and magnitude of risk. The risks include credit risk, liquidity risk and market risk. Our Board of Directors
has overall responsibility for the establishment and oversight of our risk management framework. Our risk
management policies are established to identify and analyse the risks faced by us, to set appropriate risk limits
608and controls and to monitor risks and adherence to limits. Risk management policies and systems are reviewed
regularly to reflect changes in market conditions and our activities.
Unusual or infrequent events or transactions
Except as described in this Draft Red Herring Prospectus, to our knowledge, there have been no unusual or
infrequent events or transactions that have in the past or may in the future affect our business operations or future
financial performance.
Extent to which material increases in net sales or revenue are due to increased sales volume, and increased
sales prices.
The reasons for the increase in revenue from operations and total income has been described above under ‘Fiscal
2025 compared with Fiscal 2024’and ‘Fiscal 2024 compared with Fiscal 2023’.
Significant economic changes that materially affect or are likely to affect income from continuing
operations
Our business has been subject, and we expect it to continue to be subject, to significant economic changes that
materially affect or are likely to affect income from continuing operations identified above in “Management’s
Discussion and Analysis Of Financial Condition and Results Of Operations - Significant Factors Affecting our
Results of Operations and Financial Condition” and the uncertainties described in the section “Risk Factors” on
pages 578 and 40 respectively.
Known trends or uncertainties
Other than as described in the section “Risk Factors” on page 40, to our knowledge, there are no known trends or
uncertainties that have or had or are expected to have a material adverse impact on revenues or income of our
Company from continuing operations.
Future relationship between cost and income
Other than as described in the sections “Risk Factors”, “Our Business” and “Management’s Discussion and
Analysis of Financial Position and Results of Operations” on pages 40, 438 and 578, respectively, to our
knowledge there are no known factors that may adversely affect our business prospects, results of operations and
financial condition.
Publicly announced new products or business segments /material increases in revenue due to increased
disbursements and introduction of new products
As on the date of this Draft Red Herring Prospectus, except as disclosed in “Our Business” on page 438, there are
no new products or business segments that have or are expected to have a material impact on our business
prospects, results of operations or financial condition.
Significant dependence on single or few customers
Given the nature of our business operations, we do not believe that our business is dependent on any single client
or a few clients.
Seasonality of business
Our business is not seasonal in nature.
Competitive conditions
We operate in a competitive environment. Please refer to the section “Industry Overview”, “Our Business”, and
“Risk Factors” on pages 382, 438 and 40 respectively, for further information on our industry and competition.
609Change in accounting policies
Except as described in this Draft Red Herring Prospectus, there have been no changes in our accounting policies
in the last three Fiscals.
Significant developments after March 31, 2025 that may affect our future results of operations
Except as set out in this Draft Red Herring Prospectus, to our knowledge, no circumstances have arisen since the
date of the last financial statements as disclosed in this Draft Red Herring Prospectus which materially or adversely
affect or are likely to affect, the trading or profitability of our Company, or the value of our assets or our ability
to pay our material liabilities within the next 12 months
610CAPITALISATION STATEMENT
The following table sets forth our Company’s capitalization as at March 31, 2025, as derived from our Restated
Consolidated Financial Information. This table should be read in conjunction with the sections titled
“Management’s Discussion and Analysis of Financial Condition and Results of Operations”, “Financial
Information – Restated Consolidated Financial Information” and “Risk Factors” on pages 578, 503 and 40,
respectively.
(in ₹ lakhs)
Particulars Pre-Issue as at March 31, 2025 (₹ in As adjusted for the Issue *
lakhs)
Total Borrowings
Current Borrowings (A) 504.40 [●]
Non-current Borrowings (including 66.41 [●]
current maturity on non-current
borrowings) (B)
Total Borrowings (C)=(A)+(B) 570.81 [●]
Total Equity
Equity Share Capital (D) 1,575.40 [●]
Other Equity (E) 15,233.58 [●]
Total Equity (F)=(D)+(E) 16,808.98 [●]
Total Borrowings/ Total Equity 0.03 [●]
(C)/(F)
Non-Current Borrowing/ Total 0.004 [●]
Equity (B)/(F)
The above terms carry the meaning as per Schedule III to the Companies Act, 2013 (as amended)
*Post Issue capitalization will be determined after finalization of Issue Price
611FINANCIAL INDEBTEDNESS
Our Company and our Subsidiaries avail loans and financing facilities in the ordinary course of their business for
meeting their working capital and business requirements. For details regarding the borrowing powers of our
Board, please see “Our Management - Borrowing Powers” on page 475.
We have obtained the necessary consents required under the relevant financing documentation for undertaking
activities in relation to the Issue, including inter alia effecting changes in our capital structure, shareholding
pattern, Board composition and constitutional documents.
As of August 31, 2025, our outstanding borrowings (on a consolidated basis) aggregated to ₹ 9,458.62 lakhs.
The details of the indebtedness of our Company (on a consolidated basis) as on August 31, 2025, are provided
below:
Sr. No. Nature of facility Sanctioned amount Amount outstanding
as on August 31, 2025
Secured
Fund Based Borrowings
1. Intraday facility 2,000.00 -
2. Cash credit 1,000.00 -
3. Overdraft Against Property (Sub limit: Overdraft 3,000.00 1,239.52
Against Shares)
4. Overdraft Against Fixed Deposit 2500.00 73.24
5. Vehicle Loan 99.45 78.33
6. Loan Against Security 4,000.00 1,968.71
Sub total (A) 12,599.45 3,359.80
Non Fund Based Borrowings
7. Bank Guarantee 1,1500.00 6,000.00
Sub total (B) 1,1500.00 6,000.00
Total (C= A+B) 24,099.45 9,359.80
Unsecured
8. Inter Company Loan 98.82 98.82
Total (D) 98.82 98.82
Total (C+D) 24,198.27 9,458.62
Key terms of our borrowings are disclosed below:
• Tenor: The tenor of the facilities availed by our Company are repayable on demand and typically ranges from
1 months to 12 months
• Interest rate: The applicable rate of interest for the facilities availed by our Company is typically linked to
benchmark rates, such as the repo rate or marginal cost of lending rate (MCLR), of a specified lender over a
specific period of time plus a specified spread per annum and are subject to mutual discussions between the
relevant lenders and our Company, as applicable. Typically, the rate of interest for our secured facilities
ranges 8.75% and 10.00%. The interest rate for the vehicle loan availed by our Company is 8.85% and 9.30%
per annum and the rate of interest rate for the unsecured facilities availed by our Company typically ranges
from 8.00% to 10.00% per annum.
• Security: In terms of our borrowings where security needs to be created, such security typically includes:
In terms of our borrowings where security needs to be created, such security typically includes:
• First and exclusive hypothecation charge by way of mortgage over commercial property;
• Fixed deposits lien marked in favour of HDFC Bank Limited;
• For cash credit, security by way of book debts – Charge on Debtors in books of Borrower, Hypothecation
in favour of HDFC Bank
612• Pledge of shares.
• Personal Guarantee of Upendra Trikamlal Shah, Purnima Upendra Shah, Trupti Utpal Shah, and Tanmay
Upendra Shah.
• Repayment: Most of our facilities are typically repayable in accordance with the repayment schedules in the
facility documents. Our unsecured facilities are repayable on maturity of the specified period of the facility
as provided in the relevant loan documentation.
• Prepayment: Certain loans availed by us have prepayment provisions which allows for prepayment of the
outstanding loan amount and sometimes carry a pre-payment penalty up to 2.00% on the outstanding amount
subject to terms and conditions stipulated under the loan documents.
• Penal interest: We are typically bound to pay additional interest to our lenders for defaults in the payment of
interest or other monies due and payable. This additional interest is charged as per the terms of our loan
agreements and typically range to 2.00% to 36.00% per annum, over and above the applicable interest rate
• Restrictive covenants: As per the terms of our borrowings, certain corporate actions for which our Company
requires prior written consent of the lenders include, including inter alia:
Change in control/ownership/management/directorship including:
1. Effecting any changes to the capital structure or in management set up of our Company;
2. Undertake any new project/schemes, implement and schemes of expansion or acquire fixed assets;
3. Reduction or change in promoter shareholding/change in promoter directorship resulting in change in
management control.
• Events of Default: As per the terms of our borrowings, the following, amongst others, constitute events of
default for the relevant loan agreement, including inter alia:
1. Default in repayment of loan facility;
2. Failure by the guarantors to comply with any provision of the financing documents;
3. If any material representation, warranty or statement or undertaking made by the Company is found to
be incorrect or untrue, in any respect, when made;
4. Initiation of insolvency or bankruptcy proceedings against the Company or the guarantors.
• Consequences of occurrence of events of default: In terms of our borrowings, the following, inter alia, are
the consequences of occurrence of events of default, whereby our lenders may:
1. Declare the facilities together with accrued interest, penalties, liquidated damages, penalties and all other
monies to be immediately due and payable by the Company;
2. Declare all undisbursed portion of the facilities stands cancelled;
3. Enforce all of the security and exercise all the rights specified in the security documents
This is an indicative list of the terms and conditions of the outstanding facilities and there may be additional terms
including those that may require the consent of the relevant lender, the breach of which may amount to an event
of default under various borrowing arrangements entered into by us, and the same may lead to consequences other
than those stated above. We have obtained the necessary consent required under the relevant loan documentation
for undertaking activities in relation to the Issue, including, inter alia, effecting a change in our shareholding
pattern, effecting a change in the composition of our Board.
For risks in relation to the financial and other covenants required to be complied with in relation to our borrowings,
see “Risk Factors – We have incurred indebtedness including in the form of loans from banks may incur
substantial additional indebtedness. Conditions and restrictions imposed on us pursuant to such indebtedness
could adversely affect our ability to obtain financing in the future” on page 71.
.
613SECTION VI – LEGAL AND OTHER INFORMATION
OUTSTANDING LITIGATION AND MATERIAL DEVELOPMENTS
Except as disclosed in this section, there are no outstanding (i) criminal proceedings (including any notices
received for such criminal proceedings and matters which are at first information report stage, even if no
cognizance has been taken by any court),including cases under Section 138 of the Negotiable Instruments Act,
1881.;(ii) all outstanding actions taken /penalties imposed by statutory and/or regulatory authorities (including
all penalties and notices); (iii) Disciplinary action including any penalty imposed and show cause notices issued
by SEBI or stock exchanges against the Promoters in the last five financial years including outstanding action
preceding the relevant issue documents and to be disclosed in the relevant issue document (iv) all outstanding
claims related to direct and indirect taxes in a consolidated manner, giving the number of cases and total amount;
In the event any tax matters involve an amount exceeding the threshold proposed in (i) below, in relation to the
Company, Promoters, or the Directors, individual disclosures of such tax matters will be included; and (iv) other
outstanding litigation involving the Relevant Parties as determined to be material pursuant to the Materiality
Policy in accordance with the SEBI ICDR Regulations in each case involving our Company, Promoters and
Directors (“Relevant Parties”).
Pursuant to the Materiality Policy adopted by our Board of Directors on September 05, 2025, for the purposes of
(iv) above, any pending litigation involving the Relevant Parties, has been considered ‘material’ and accordingly,
disclosed in this Draft Red Herring Prospectus where:
i. the claim/ dispute amount, to the extent quantifiable, exceeds the lower of (a) 2% of turnover as per the
Restated Consolidated Financial Information as at March 31, 2025; or (b) 2% of net worth based on the
Restated Consolidated Financial Information as at March 31, 2025, or (c) 5% of the average of absolute
value of profit or loss after tax, as per the Restated Consolidated Financial Information of our Company
for the last three Fiscals, whichever is lower; or
ii. where monetary liability is not quantifiable or does not exceed the threshold mentioned in point (i) above,
the outcome of any such pending proceedings may have a material bearing on the financial position,
business, operations, prospects or reputation of the Company; or
iii. the decision in such a proceeding is likely to affect the decision in similar proceedings, such that the
cumulative amount involved in such proceedings exceeds the threshold mentioned in point (i), even
though the amount involved in an individual proceeding does not exceed the threshold mentioned in point
(i).
2% of turnover, as per the Restated Consolidated Financial Information for Fiscal 2025 is ₹ 188.55 lakhs, 2% of
net worth, as per the Restated Consolidated Financial Information for Fiscal 2025 is ₹ 336.18 lakhs and 5% of
the average of absolute value of profit or loss after tax, as per the Restated Consolidated Financial Information
for the last three Fiscals is ₹ 81.91 lakhs. Accordingly, ₹ 81.91 lakhs has been considered as the materiality
threshold for the purpose of (i) above.
There are no findings/observations of any of the inspections by SEBI or any other regulator involving our
Company which are material, and which need to be disclosed or non-disclosure of which may have bearing on
the investment decision, other than the ones which have already disclosed in the issue document.
Further, any outstanding civil litigations/arbitration proceedings involving the Relevant Parties wherein the
monetary impact is not quantifiable or does not exceed the Threshold shall be considered ‘material’ and shall be
disclosed in the Issue Documents, if the outcome of such litigation could have a material adverse effect on the
business, performance, prospects, operations, financial position or reputation of the Company.
Pre-litigation notices received by any of the Relevant Parties from third parties (excluding such notices issued by
any statutory/ regulatory/ governmental/ tax authorities or notices threatening criminal action) shall, unless
otherwise decided by the Board, not to be considered as an outstanding litigation until such time that the Relevant
Parties are impleaded as parties in the proceedings before any judicial/ arbitral forum. Pre-litigation notices
received by the Relevant Parties from third parties (excluding those notices issued by governmental, statutory,
tax or regulatory authorities or notices threatening criminal action) shall, in any event, not be considered as
litigation until such time that Relevant Parties are impleaded as defendants/respondents in litigation/arbitration
proceedings initiated before any judicial/arbitral forum, court, tribunal or governmental authority, or is notified
by any governmental, statutory or regulatory authority of any such proceeding that may be commenced.
Further, pending litigations where the decision in one litigation is likely to affect the decision in similar litigations
which could either individually or collectively have a material adverse effect on the business, performance,
614prospects, operations, financial position or reputation of the Company, shall be disclosed in the Issue Documents,
even though the amount involved in an individual litigation may not exceed the Threshold.
Except as stated in this section, there are no outstanding material dues to creditors of our Company. Further in
terms of the Materiality Policy, a creditor shall be considered “material”, if the outstanding dues to such creditor
is equal to or in excess of 5% of the total consolidated trade payables of our Company, as on the date of the
Restated Consolidated Financial Information as disclosed in this Draft Red Herring Prospectus (“Material
Creditors”). Accordingly, as on March 31, 2025, any outstanding dues exceeding ₹ 621.02 lakhs have been
considered as material outstanding dues for the purposes of identification of material creditors and related
information in this section. For outstanding dues to any party which is a micro, small or medium
enterprise(“MSME”), the disclosure will be based on information available with the Company regarding the
status of the creditor as defined under Micro, Small and Medium Enterprises Development Act, 2006, as amended
read with the rules and notifications thereunder. It is clarified that the Company tracks the outstanding dues to
micro and small enterprises and disclosures have been made in this section accordingly.
Litigation involving our Company
Litigation against our Company
Criminal litigation
As on the date of this Draft Red Herring Prospectus, there are no criminal litigations instituted against our
Company.
Material civil litigation
As on the date of this Draft Red Herring Prospectus, there are no material civil litigations instituted against our
Company.
Actions taken by regulatory or statutory authorities
As on the date of this Draft Red Herring Prospectus, there are no actions taken by regulatory or statutory
authorities against our Company.
Litigation by our Company
Criminal litigation
As on the date of this Draft Red Herring Prospectus, there are no criminal litigations instituted by our Company.
Material civil litigation
As on the date of this Draft Red Herring Prospectus, there are no civil litigations instituted by our Company.
Findings/observations of any of the inspections by SEBI or any other regulator involving our Company which
are material, and which need to be disclosed or non-disclosure of which may have bearing on the investment
decision
Except as disclosed below, there are no findings/observations of any of the inspections by SEBI or any other
regulator involving our Company which are material, and which need to be disclosed or non-disclosure of which
may have bearing on the investment decision as on the date of this Draft Red Herring Prospectus;
1. Our Company being a registered Investment Adviser with SEBI, had received a show cause notice June 30,
2025 from SEBI under Regulation 30A of the SEBI (Intermediaries) Regulations, 2008 on failure to pay the
applicable renewal fees under Clause 3 of the SEBI (Investment Advisors) Regulations 2013. The Company
had vide their reply dated July 28, 2025, had confirmed that their registration as Investment Advisor may be
cancelled. Subsequently, SEBI vide its order dated September 10, 2025 had cancelled our registration as
Investment Advisor.
2. Our Company received a letter bearing reference no. SEBI/WRO/JS/PD/OW/P/2025/2463/1 dated January
23, 2025 (the “Letter”), from SEBI, highlighting certain observations/findings pursuant to the inspection of
our books of accounts, records, and other documents relating to the upstreaming and down streaming of client
funds conducted by SEBI and the Stock Exchanges on December 05 – 06, 2024, and January 02 – 03, 2025.
The Letter included the following observations (i) on verification of bank statements, out of 30 sample dates
reviewed, client funds were retained instead of being upstreamed to the clearing corporations on 18 dates, (ii)
funds were transferred from the settlement account to the upstreaming client nodal bank account (USCNBA)
and (iii) funds were transferred from the settlement account to the downstreaming client nodal bank account
615(DSCNBA), wherein the said transfers were not in compliance with SEBI circulars (collectively referred to
as the “Observations”). We submitted our detailed response to the said Observations on February 07, 2025,
and have not received any further communication from SEBI in this regard.
3. Our Company (“Applicant”) filed a suo-moto settlement application in terms of the SEBI (Settlement of
Administrative and Civil Proceedings) Regulations, 2014 which is repealed and replaced with SEBI
(Settlement Proceedings) Regulations, 2018 with effect from January 01, 2019 (hereinafter referred to as
‘Settlement Regulations’) proposing to settle, without admitting the findings of fact and conclusions of law,
through a settlement order, the non-compliance with Section 56, Section 67 and Section 73 of the Companies
Act, 1956 and the provisions of the SEBI(Disclosure and Investor Protection) Guidelines, 2009 (hereinafter
referred to as “DIP Guidelines”). The applicant in the application submitted that it had made preferential
allotment of its equity shares to 502 allottees on February 29, 2008. The said allotment was in violation of
Section 56, Section 67 and Section 73 of the Companies Act, 1956 and the DIP Guidelines. The applicant
submitted that it had provided an exit offer to all eligible shareholders and also submitted a certificate of
compliance with the requirement of the aforesaid SEBI Circular from an independent Chartered Accountant.
The applicant, vide letter dated March 02, 2019, proposed the revised settlement terms to settle the defaults
mentioned above. The High-Powered Advisory Committee (“HPAC”) in its meeting held on March 29, 2019
considered the settlement terms proposed and recommended the case for settlement upon payment of
`12,18,750/- (Rupees Twelve Lakh Eighteen Thousand Seven Hundred and Fifty only) by the applicant
towards settlement charges for the defaults. The Panel of Whole Time Members of SEBI accepted the said
recommendation of the HPAC on May 10, 2019, and the same was communicated to the applicant vide e-
mail dated May 15, 2019. Accordingly, the possible proceedings that may be initiated for the defaults, are
settled qua the applicant as per the above terms, by way of the order and SEBI shall not initiate any
enforcement action against the applicant for the said defaults.
Litigation involving our Subsidiaries
Litigations against our Subsidiaries
Criminal litigations
As on the date of this Draft Red Herring Prospectus, there are no criminal litigations instituted against our
Subsidiaries.
Actions Taken by Regulatory and Statutory Authorities
As on the date of this Draft Red Herring Prospectus, there are no actions taken by regulatory or statutory
authorities against our Subsidiaries.
Material Civil litigations
As on the date of this Draft Red Herring Prospectus, there are no material civil litigations instituted against our
Subsidiaries.
Litigations by our Subsidiaries
Criminal litigations
As on the date of this Draft Red Herring Prospectus, there are no criminal litigations instituted by our Subsidiaries.
Material Civil litigations
As on the date of this Draft Red Herring Prospectus, there are no material civil litigations instituted by our
Subsidiaries.
Litigation involving our Promoters
Against our Promoters
Criminal litigation
As on the date of this Draft Red Herring Prospectus, there are no criminal litigations instituted against our
Promoters.
616Material civil litigation
As on the date of this Draft Red Herring Prospectus, there are no civil litigations instituted against our Promoters.
Actions taken by regulatory or statutory authorities
As on the date of this Draft Red Herring Prospectus, there are no actions taken by any regulatory or statutory
authorities against our Promoters.
Disciplinary actions including penalty imposed by the SEBI or Stock Exchanges against our Promoters in the
last five Fiscals
As on the date of this Draft Red Herring Prospectus, there are no disciplinary actions including penalty imposed
by SEBI or Stock Exchanges against our Promoters in the last five Fiscals against our Promoters.
By our Promoters
Criminal litigation
As on the date of this Draft Red Herring Prospectus, there are no criminal litigations instituted by our Promoters.
Material civil litigation
As on the date of this Draft Red Herring Prospectus, there are no civil litigations instituted by our Promoters.
Actions taken by regulatory or statutory authorities
As on the date of this Draft Red Herring Prospectus, there are no actions taken by any regulatory or statutory
authorities against our Promoters.
Litigation involving our Directors
Against our Directors
Criminal litigation
As on the date of this Draft Red Herring Prospectus, there are no criminal litigations instituted against our
Directors.
Material civil litigation
As on the date of this Draft Red Herring Prospectus, there are no material civil litigations instituted against our
Directors.
Actions taken by regulatory or statutory authorities
As on the date of this Draft Red Herring Prospectus, there are no actions taken by any regulatory or statutory
authorities against our Directors.
By our Directors
Criminal litigation
As on the date of this Draft Red Herring Prospectus, there are no criminal litigations instituted by our Directors.
Material civil litigation
As on the date of this Draft Red Herring Prospectus, there are no criminal litigations instituted by our Directors.
Litigation Involving Our Key Managerial Personnel and Senior Management
Against our Key Managerial Personnel and Senior Management
Criminal Litigation
As on the date of this Draft Red Herring Prospectus, there are no criminal litigations against our against our KMP
or SMP.
Material Civil Litigation
As on the date of this Draft Red Herring Prospectus, there are no material civil litigations instituted against our
KMP or SMP.
Claims related to direct and indirect taxes
617Except as disclosed below, there are no claims related to direct and indirect taxes, involving our Company,
Promoters, Subsidiaries and Directors.
Nature of case Number of cases Amount involved (in ₹ lakhs)
Company
Direct Tax - -
Indirect Tax 5 415.26
Promoters
Direct Tax - -
Indirect Tax - -
Directors (excluding Promoters)
Direct Tax Nil Nil
Indirect Tax Nil Nil
Subsidiaries
Direct Tax - -
Indirect Tax 1 4.68
Litigation involving our Group Companies
As on the date of this Draft Red Herring Prospectus, there are no pending litigation proceedings involving our
Group Companies which will have a material impact on our Company.
Outstanding dues to Creditors
In terms of the Materiality Policy, creditors of our Company to whom an amount exceeding 5% of our total trade
payables as of March 31, 2025, based on the Restated Consolidated Financial Information of our Company was
outstanding, were considered ‘material’ creditors. Our total trade payables as of March 31, 2025, was ₹ 12,420.45
lakhs and accordingly, creditors to whom outstanding dues as of March 31, 2025, exceed ₹ 621.02 lakhs have
been considered as material creditors for the purposes of disclosure in this Draft Red Herring Prospectus. Details
of outstanding dues towards our material creditors are available on the website of our Company at www.sihl.in.
Based on the Materiality Policy, details of outstanding dues owed as of March 31, 2025, by our Company, on a
consolidated basis are set out below:
Types of Creditors* Number of creditors Amount outstanding
(in ₹ lakhs)
Micro, small and medium enterprises* 2 3.11
Other Creditors 22,358 12,417.34
Material Creditors - -
Total 22,360 12,420.45
Micro, small and medium enterprises* 2 3.11
* As defined under the Micro, Small and Medium Enterprises Development Act, 2006, as amended.
Material developments
Other than as stated in “Management’s Discussion and Analysis of Financial Position and Results Of Operations”
on page 578, there have not arisen, since the date of the Restated Consolidated Summary Financial Information
(i.e. March 31, 2025) disclosed in this Draft Red Herring Prospectus, any circumstances which may materially
and adversely affect, or are likely to affect, within the next 12 months, our operations, our profitability taken as a
whole or the value of our assets or our ability to pay our liabilities.
618GOVERNMENT AND OTHER APPROVALS
Our business requires various approvals, consents, licenses, registrations, and permits issued by relevant
governmental and regulatory authorities of the respective jurisdictions under various rules and regulations. We
have set out below an indicative list of all approvals, consents, licenses, registrations, and permits required by
our Company and our Material Subsidiary, as applicable, for the purposes of undertaking their respective
businesses and operations which are considered material and necessary for the purpose of undertaking business
activities, and operations our Company and our Material Subsidiary (“Material Approvals”). Except as
mentioned below no further Material Approvals are required for carrying on the present business activities and
operations of our Company and our Material Subsidiary to undertake the Issue. Additionally, unless otherwise
stated herein, these approvals, consents, licenses, registrations, and permits are valid as on the date of this Draft
Red Herring Prospectus. Certain Material Approvals may have lapsed or expired or may lapse in their ordinary
course of business , from time to time , and our Company and our Material Subsidiary have either already made
applications to the appropriate authorities for renewal of such Material Approvals or is in the process of making
such renewal applications in accordance with applicable law. We have also set out below (i) Material Approvals
or renewals applied for but not received; and (ii) Material Approvals expired and renewal yet to be applied for.
For further details in connection with the regulatory and legal framework within which we operate, see “Risk
Factors” and “Key Regulations and Policies in India” beginning on pages 40 and 457, respectively.
A. Approvals in relation to the Issue
For details of corporate and other approvals in relation to the Offer, see “Other Regulatory and Statutory
Disclosures – Authority for the Issue” on page 626.
B. Incorporation details of our Company and Material Subsidiary
a) Our Company
i. Certificate of incorporation dated October 12, 1994 issued by the Assistant Registrar of Companies, Gujarat
at Dadra & Nagar Haveli in the name of “Shah Investors Home Private Limited”.
ii. Certificate of incorporation consequent on change of name dated March 09, 1995 issued by the Assistant
Registrar of Companies, Gujarat at Dadra & Nagar Haveli upon conversion of our Company from a private
limited company into a public limited company in the name of “Shah Investors Home Limited”.
iii. Certificate of incorporation consequent on change of name dated October 13, 2000 issued by the Assistant
Registrar of Companies, Gujarat at Dadra & Nagar Haveli pursuant to change in the name of the Company
from “Shah Investors Home Limited” to “Shah Investor’s Home Limited”.
iv. The Corporate Identification Number of the Company is U67120GJ1994PLC023257
b) Our Material Subsidiary
i. Certificate of incorporation dated December 28, 2006 issued by the Registrar of Companies, Gujarat at
Dadra & Nagar Haveli in the name of “SIHL Fincap Limited”.
ii. Certificate for Commencement of Business dated January 12, 2007 issued by the Registrar of Companies,
Gujarat at Dadra & Nagar Haveli in the name of “SIHL Fincap Limited”.
iii. The Corporate Identification Number of the Company is U65923GJ2006PLC049661
C. Material approvals required in relation to our Company and Material Subsidiary
I. Tax related approvals obtained by our Company and Material Subsidiary
a) Our Company
i. The permanent account number of issued by the Income Tax Department, Government of India under the
Income Tax Act, 1961 is AAFCS4436C.
ii. The Tax Deduction and Collection Account Number of issued by the Income Tax Department under Income
Tax Act, 1961 is AHMS00832G
iii. The GST registration certificate issued to our Company by the following states for GST payments:
Sr. No. State GST IN
1. Gujarat 24AAFCS4436C1ZP
24AAFCS4436C2ZO*
619Sr. No. State GST IN
2. Maharashtra 24AAFCS4436C1ZJ
*Registration for Input Service Distributor
iv. The Company has availed the professional tax registrations issued under the relevant state laws where the
Company has its Registered Office, Corporate Office and the branch offices, to the extent applicable.
b) Our Material Subsidiary
i. The permanent account number of issued by the Income Tax Department, Government of India under the
Income Tax Act, 1961 is AAKCS4767R.
ii. The Tax Deduction and Collection Account Number of issued by the under the Income Tax Department
under Income Tax Act, 1961 is AHMS14333E.
iii. The Material Subsidiary has availed the professional tax registrations issued under the Gujarat State Tax on
Professions, Trades, Callings and Employment Act, 1976.
II. Labour/ employment related approvals obtained by our Company and our Material Subsidiary
a) Our Company
Sr. Reference/Registration/ Expiry Date /
Particulars Issuing Authority Date of Issue
No. License No. Period of Validity
1. Letter for Employees State 37000266180001099 July 22, 2010 -
implementation of Insurance
Employees State Corporation
Insurance Act,
1948 and
Registration of
Employees of the
Factories and
Establishments
2. Letter for Employees GJ/AHD/28008 September 28, -
Employees Provident Fund 1999 w.e.f April
Provident Funds Organization 01, 1999
and Miscellaneous
Provisions Act,
1952 and the
Schemes framed
thereunder
applicability there
of Allotment of
Code Number
b) Our Material Subsidiary
Sr. Reference/Registration/ Expiry Date /
Particulars Issuing Authority Date of Issue
No. License No. Period of Validity
1. Letter for Employees State 37001016090001017 March 21, 2012 -
implementation of Insurance
Employees State Corporation
Insurance Act,
1948 and
Registration of
Employees of the
Factories and
Establishments
III. Material approvals obtained in relation to the business and operations of our Company and
Material Subsidiary.
a) Our Company.
620Reference/Regist Expiry Date /
Issuing
Sr. No. Particulars ration/ License Date of Issue Period of
Authority
No. Validity
1. Certificate of Securities and INZ000167335 February 28, 2018 Valid till
Registration as Exchange Board suspended or
Stock Broker of India cancelled.
under Securities
and Exchange
Board of India
(Stock Brokers)
Regulations, 1992
(Single
Registration
Certificate)*
2. Certificate of Securities and IN – DP – 465 - July 21, 2020 Valid till
Registration as Exchange Board 2020 suspended or
Depository of India cancelled
Participant under
Securities and
Exchange Board
of India Act, 1992
read with the
Depositories Act,
1996
3. Approval of Multi Commodity MCX/MEM/MA/ June 09, 2025 Valid till
admission of Exchange of India PS/44484/25 suspended or
membership as a Limited (“MCX”) cancelled
Trading Member
(Stock Broker)
4. Approval of Multi Commodity MCXCCL/MEM/ August 11, 2025 Valid till
admission of Exchange 10038/44/2025 suspended or
membership as a Clearing cancelled
Self-Clearing Corporation
Member Limited
(“MCXCCL”)
5. Permission from Senior Manager, NSE/MEM_COM September 11, Valid till
National Stock National Stock P/MTF/470/116 2023 suspended or
Exchange of India Exchange of India cancelled
for Margin
Trading facilities
to client
6. Approval from National Stock - May 27, 2020 Valid till
NSE for SLBM Exchange of India suspended or
(“Securities cancelled
Lending and
Borrowing
Mechanism”)
7. AMFI Dy. Chief ARN - 39843 April 07, 2025 May 10, 2025 to
Registration as Executive, May 09, 2028
Mutual Fund Association of
Distributor Mutual Funds in
India
8. APMI registration Principal Officer, APRN06051 June 23, 2025 June 07, 2024 -
as a PMS Association of June 06, 2027
distributor Portfolio
Managers in India
*Notes:
1. The Company is registered with the NSE across multiple segments: as a Trading and Self-Clearing Member in the Capital Market, Debt
Market, and Commodity segments; as a Trading and Clearing Member in the Futures and Options segment; and as a Trading Member
in the Currency Futures segment.
2. The Company is registered with the BSE as a Self-Clearing Member in the Equity segment.
6213. The Company was registered with the Metropolitan Stock Exchange of India as a Trading and Clearing Member in the Equity Cash
and Derivatives segment and a Trading Member in the Currency Derivatives Segment. The Company has made an application to the
Metropolitan Stock Exchange of India dated July 24, 2019. The Registration of the Company is temporarily deactivated on the exchange.
4. The Company is registered as a depository participant with National Securities Depository Limited (“NSDL”) and Central Depository
Limited (“CDSL”). Our Company had made an application to CDSL dated June 14, 2023 for surrender of their registration. CDSL
vide their email dated July 31, 2023 deactivated our terminal and converted our registration to CDSL managed DP.
Our Company have also taken the necessary registrations under the Gujarat Shops and Establishments (Regulation
of Employment and Conditions of Service) Act, 2019 and Maharashtra Shops and Establishments (Regulation of
Employment and Conditions of Service) Act, 2017 for its Registered Office, Corporate Offices and Branch
Offices.
b) Our Material Subsidiary
Expiry Date /
Sr. Issuing Reference/Registration/
Particulars Date of Issue Period of
No. Authority License No.
Validity
1. Certificate of General Manager, No. N. 01. 00487 June 19, 2008 Valid till
registration Department of suspended or
granted by the Non – Banking cancelled.
RBI, to carry on Supervision,
the business of a Ahmedabad,
non-banking Regional Office
financial
institution without
accepting public
deposits
Our Material Subsidiary has taken the necessary registrations under the Gujarat Shops and Establishments
(Regulation of Employment and Conditions of Service) Act, 2019 its Registered Office.
IV. Material approvals or renewals for which applications are currently pending before relevant
authorities:
a) Our Company
Our Company through SIHL AIF Investment Trust have applied with SEBI for setting a Category III
Alternate Investment Fund by the name of “SIHL Dynamic Growth Fund” on July 23, 2025.
b) Our Material Subsidiary
Nil
V. Approvals in relation to our business which have expired, and renewal applications are yet to be filed
a) Our Company
Nil
b) Our Material Subsidiary
Nil
VI. Approvals required for our business but not yet applied for as on the date of this Draft Red Herring
Prospectus
a) Our Company
Nil
b) Our Material Subsidiary
Nil
VII. Our intellectual property
a) Our Company
Trademarks
As on the date of this Draft Red Herring Prospectus, our Company has the following registered trademarks;
622Sr. No. Description Class of trademark Registration No. Validity
under the Trade
Marks Act
1. Class 36 1596312 Upto August 30,
2027
2. Class 36 1596314 Upto August 30,
2027
Further, as on the date of this Draft Red Herring Prospectus, our Company has applied for the following
trademarks;
Sr. No. Description Class of trademark under Application Date of application
the Trade Marks Act number
1. Class 36 7239764 September 16, 2025
For risks associated with intellectual property, please see, “Risk Factors – We have applied for registrations of
certain intellectual property rights and any failure to enforce our rights could have an adverse effect on our
business prospects” on page 46.
b) Our Material Subsidiary
Nil
623GROUP COMPANIES
In terms of the SEBI ICDR Regulations and the applicable accounting standards, the term “group companies”, for
the purpose of identification and disclosure in the issue documents includes (i) such companies (other than
promoters and the subsidiaries) with which our Company has had related party transactions, in accordance with
Ind AS 24, during the period for which financial information is disclosed in this Draft Red Herring Prospectus, as
covered under applicable accounting standards, and (ii) any other companies considered material by the Board.
Accordingly, for (i) above, all such companies (other than our Subsidiaries) with which our Company had related
party transactions during the periods covered in the Restated Consolidated Financial Information included in the
issue documents, as covered under the applicable accounting standards (i.e., Ind AS 24), will be considered as
Group Companies of our Company in terms of the SEBI ICDR Regulations.
In addition, pursuant to the Materiality Policy, for the purposes of (ii) above, a company (other than our Promoters,
Subsidiary and companies categorized under (i) above) has been considered “material” and has been disclosed as
a ‘Group Company’ in this Draft Red Herring Prospectus if: such company is a member of the Promoter Group
Companies (other than the Promoters, in case the Promoters are companies) in terms of Regulation 2(1)(pp) of
the SEBI ICDR Regulations; and our Company has entered into one or more transactions with such company
during the last completed Fiscal, for which Restated Consolidated Financial Information are being included, which
individually or cumulatively in value exceeds 10% of the consolidated revenue from operations of our Company
for the last completed Fiscal or stub period, as applicable, as per the Restated Consolidated Financial Information.
Based on the parameters mentioned above, as on the date of this Draft Red Herring Prospectus, we have identified
the following as Group Companies, the details of which are set forth below:
S. Group Company Registered Address CIN/LLPIN
No.
1. SIHL Commodities Limited SIHL House, Opp. Ambawadi Jain U45201GJ1995PLC025825
Temple, Nehru Nagar Cross Road,
Ahmedabad - 380015, Gujarat,
India
2. Infinium Mines & Minerals LLP* SIHL House, Opp. Ambawadi Jain ACQ-9815
Temple, Nehru Nagar Cross Road,
Ahmedabad - 380015, Gujarat,
India
3. Ficus Food Lab Private Limited Plot No.228, Vadodara Jambusar U15490GJ2022PTC131251
Highway, Dabhasa, Vadodara -
391440, Padra, Gujarat, India
4. Sur Management Services Private Shop No- 16, T.F., Sandesh U74140GJ2010PTC059750
Limited Commercial Complex, Mirzapur
Court/ Old Madhupura Cinema,
Ahmedabad - 380001, Gujarat,
India
5. Arthika Quantomics Private Limited 22/525 Satyagrah Chhavni, U66120GJ2025PTC158460
Satellite, Jodhpur Char Rasta,
Ahmedabad - 380015, Gujarat,
India
*Pursuant to the form FiLLiP dated August 29, 2025, Infinium Mines & Minerals LLP had been converted into a limited liability partnership
having a LLP IN – ACQ-9815, from a private limited company, as on the date of this Draft Red Herring Prospectus.
Details of our Group Companies
In accordance with the SEBI ICDR Regulations, the financial information with respect to: (i) reserves (excluding
revaluation reserve); (ii) sales; (iii) profit after tax; (iv) earnings per share; (v) diluted earnings per share; and (vi)
net asset value, of the top Group Companies (determined on the basis of their market capitalization for listed
companies or annual turnover for unlisted companies as applicable), based on their respective audited financial
statements for the preceding three years, shall be hosted on the website of our Company, as indicated below:
S. Group Company Website
No.
1. SIHL Commodities Limited https://www.sihl.in/investor-relations/1
2. Infinium Mines & Minerals LLP* https://www.sihl.in/investor-relations/1
3. Ficus Food Lab Private Limited https://www.sihl.in/investor-relations/1
4. Sur Management Services Private Limited https://www.sihl.in/investor-relations/1
624S. Group Company Website
No.
5. Arthika Quantomics Private Limited https://www.sihl.in/investor-relations/1
*Pursuant to the form FiLLiP dated August 29, 2025, Infinium Mines & Minerals LLP had been converted into a limited liability partnership
having a LLP IN – ACQ-9815, from a private limited company, as on the date of this Draft Red Herring Prospectus.
Our Company has provided links to such websites solely to comply with the requirements specified under the
SEBI ICDR Regulations. Such financial information of the Group Companies provided on the websites given
above should does not constitute a part of this Draft Red Herring Prospectus and not be relied upon or used as a
basis for any investment decision. Neither our Company nor the BRLM or any of their respective directors,
employees, affiliates, associates, advisors, agents or representatives have verified the information available on the
websites indicated above. Anyone placing reliance on any other source of information would be doing so at their
own risk.
Nature and extent of interest of Group Companies
In the promotion of our Company
None of our Group Companies have any interest in the promotion of our Company.
In the properties acquired by our Company in the past three years before filing this Draft Red Herring
Prospectus or proposed to be acquired by our Company
None of our Group Companies are interested in the properties acquired by our Company in the three years
preceding the filing of this Draft Red Herring Prospectus or proposed to be acquired by our Company.
In transactions for acquisition of land, construction of building and supply of machinery, etc.
None of our Group Companies are interested in any transactions for acquisition of land, construction of building
or supply of machinery, etc. entered into by our Company.
Common pursuits among the Group Companies and our Company
None our Group Companies have common pursuits among the Group Companies and our Company except for
Sur Management Services Private Limited and Arthika Quantomics Private Limited which are in similar line of
business.
Related Business Transactions within our Group Companies and significance on the financial performance
of our Company
Except the transactions disclosed in “Related Party Transactions” and “Restated Consolidated Financial
Information –Notes to Restated Consolidated Financial Information –Related Party Transactions” on pages 577
and 503 respectively, there are no other related business transactions between our Company and our Group
Companies.
Litigation
There are no pending litigation proceedings involving our Group Companies which may have a material impact
on our Company.
Business interest of Group Companies
Except in the ordinary course of business and as stated in “Restated Consolidated Financial Information –Notes
to Restated Consolidated Financial Information –Note 33 –Related Party Transactions” and “History and Certain
Corporate Matters –Other Material Agreements” on page 503 and 463, respectively, none of our Group
Companies have any business interest in our Company.
Confirmations
None of our Group Companies have their securities listed on Stock Exchanges.
Further, none of our Group Companies has made any public or rights issue (as defined under the SEBI ICDR
Regulations) of securities in the three years preceding the date of this Draft Red Herring Prospectus.
There is no conflict of interest between the suppliers of raw materials and third-party service providers (which are
crucial for operations of the Company) and any of the Group Companies and its directors.
625OTHER REGULATORY AND STATUTORY DISCLOSURES
Authority for the Issue
Corporate Approvals
Our Board has approved the Issue pursuant to the resolution passed at its meeting held on August 26, 2025, and
our Shareholders have approved the Issue pursuant to a resolution dated August 28, 2025, in terms of Section
62(1)(c) of the Companies Act, 2013.
Our Board has pursuant to the resolution passed at its meeting held on September 29, 2025, approved this Draft
Red Herring Prospectus for filing with SEBI and the Stock Exchanges.
In-principle Listing Approvals
Our Company has received in-principle approvals from BSE and NSE for the listing of the Equity Shares pursuant
to their letters dated [●] and [●], respectively.
Regulatory approvals received in relation to the Issue
i. Our Company, through an email dated September 13, 2025, sought approval of BSE for the proposed Issue which will
result in change in our shareholding pattern (without change in control) of our Company, as a Trading cum Self Clearing
Member of BSE (Equity Segment) and Trading Member of BSE (Equity Derivatives Segment). Our Company has
received BSE’s response dated September 24, 2025, stating that no approval is required from membership department.
ii. Our Company, through an email dated September 13, 2025, sought approval of NSE for the proposed Issue which will
resulting in change in our shareholding pattern (without change in control) of our Company, as a stock-broker and
margin trading member on the cash segment with NSE. Our Company has not received any response as on the date of
this Draft Red Herring Prospectus.
iii. Our Company, through an email dated September 13, 2025, sought approval of MCX for the proposed Issue which will
resulting in change in our shareholding pattern (without change in control) of our Company, as a Trading cum Self
Clearing Member of MCX. Our Company has not received any response as on the date of this Draft Red Herring
Prospectus.
iv. Our Company, through an email dated September 18, 2025, sought approval of Metropolitan Stock Exchange of India
Limited for the proposed Issue which will result in change in our shareholding pattern (without change in control) of
our Company, as trading member with Metropolitan Stock Exchange of India Limited. Our Company has not received
any response as on the date of this Draft Red Herring Prospectus.
v. Our Company, through an email dated September 13, 2025, sought approval of NSDL for the proposed Issue which
will result in change in our shareholding pattern (without change in control) of our Company, as a Depository
Participant with NSDL. Our Company received NSDL’s response dated September 24, 2025, stating that NSDL does
not have objection to SIHL undertaking Initial Public Offer.
vi. Our Company, through an email dated September 18, 2025, sought approval of CDSL for the proposed Issue which
will result in change in our shareholding pattern (without change in control) of our Company, as a CDSL managed
depository participant. Our Company has not received any response as on the date of this Draft Red Herring Prospectus.
vii. Our Company, through an email dated September 17, 2025, sought approval of NSCCL for the proposed Issue which
will result in change in our shareholding pattern (without change in control) of our Company, as a Clearing Member.
Our Company has not received any response as on the date of this Draft Red Herring Prospectus.
viii. Our Company, through an email dated September 17, 2025, sought approval of MCXCCL for the proposed Issue which
will result in change in our shareholding pattern (without change in control) of our Company, as a Self-Clearing
Member. Our Company has not received any response as on the date of this Draft Red Herring Prospectus.
Prohibition by SEBI, RBI or other Governmental Authorities
Our Company, our Promoters, our Directors and the members of the Promoter Group are not prohibited from
accessing the capital market or debarred from buying, selling or dealing in securities under any order or direction
passed by SEBI or any securities market regulator in any other jurisdiction or any other authority/court.
None of the companies with which our Promoters and Directors are associated with as promoters, directors or
persons in control have been debarred from accessing capital markets under any order or direction passed by SEBI
or any other authorities.
Neither our Company nor our Directors or Promoters, members of our Promoter Group have been declared as a
‘willful defaulter’ or a ‘fraudulent borrower’, as defined under the SEBI ICDR Regulations.
626Our Promoters or Directors have not been declared as fugitive economic offenders under section 12 of the Fugitive
Economic Offenders Act, 2018.
Directors associated with the Securities Market
Except for our Executive Directors, none of our Directors are associated with securities market related business.
There are no outstanding actions initiated by SEBI in the last five years preceding the date of the Draft Red Herring
Prospectus against our Directors.
Confirmation under the Companies (Significant Beneficial Owners) Rules, 2018
Our Company, Promoters and members of the Promoter Group, severally and not jointly, confirm that they are in
compliance with the Companies (Significant Beneficial Owners) Rules, 2018, to the extent applicable to them, as
on the date of this Draft Red Herring Prospectus.
Eligibility for the Issue
Our Company is eligible for the Issue in accordance with the Regulation 6(1) of the SEBI ICDR Regulations, and
is in compliance with the conditions specified therein in the following manner:
• Our Company has net tangible assets of at least ₹300.00 lakhs, calculated on a restated and consolidated
basis, in each of the preceding three full financial years, i.e., as at and for Fiscal 2025, Fiscal 2024 and
Fiscal 2023, of which not more than 50% are held in monetary assets;
• Our Company has an average operating profit of at least ₹1500.00 lakhs, calculated on a restated and
consolidated basis, during the preceding three full financial years, i.e., Fiscal 2025, Fiscal 2024 and Fiscal
2023, with operating profit in each of these preceding three financial years;
• Our Company has a Net Worth of at least ₹100 lakhs, calculated on a restated and consolidated basis in
each of the preceding three full financial years, i.e., Fiscal 2025, Fiscal 2024 and Fiscal 2023; and
• Except as disclosed in this Draft Red Herring Prospectus, our Company has not changed its name in the
last one year.
Our Company’s net tangible assets, monetary assets, monetary assets as a percentage of the net tangible assets,
restated pre-tax operating profit and Net Worth derived from the Restated Consolidated Financial Information
included in this Draft Red Herring Prospectus as at, and for the Fiscal 2025, Fiscal 2024 and Fiscal 2023 are set
out below:
Derived from our Restated Consolidated Financial Information
(in ₹ lakhs)
Particulars Fiscal
2025 2024 2023
Net tangible assets, as restated (A)(1) 16,736.91 14,979.71 11,679.01
Operating profit, as restated (B)(2) 3367.18 2368.73 982.58
Average Operating profit, as restated 2,239.50
Net Worth, as restated (C)(3) 16,808.98 15,054.13 11,745.98
Monetary assets, as restated (D)(4) 917.19 2,476.13 1,355.74
Monetary assets as a percentage of the net tangible assets as 5.48 16.53 11.61
restated (E)= (D)/(A)(in %)
Source: Restated Consolidated Financial Information as included in “Financial Information” beginning on page 503.
Notes:
1. ‘Net tangible assets’ means the sum of all net assets of the Company, excluding intangible assets as defined in Indian Accounting
Standard (Ind AS) 38.
2. ‘Operating Profit’ has been calculated as profit before finance costs, other income, exceptional item and tax expenses including profit
from associates.
3. ‘Net worth’ means aggregate value of the paid-up share capital and other equity created out of the profits, securities premium account
and debit or credit balance of profit and loss account, after deducting the aggregate value of the accumulated losses, deferred
expenditure and miscellaneous expenditure not written off, derived from Restated Consolidated Financial Information, but does not
include reserves created out of revaluation of assets, write-back of depreciation and amalgamation.
4. ‘Monetary assets’ is the aggregate of cash on hand and balance with banks (including other bank balances and interest accrued
thereon) excluding (i) fixed deposits under lien with stock exchanges, these are clients’ fund hence cannot be utilized (ii) fixed deposits
against credit facilities of the Company (iii) fixed deposits for bank guarantees. These exclusions are made because these other balances
are not freely accessible and are subject to Company’s commitments. These are restricted or pledged for specific purposes, limiting
their immediate liquidity or use.
627Our Company has operating profits in each of Fiscal 2025, 2024 and 2023 in terms of our Restated Consolidated
Financial Information. Our average operating profit for Fiscals 2025, 2024 and 2023 is ₹ 2,239.50 lakhs. For
further details, please see, “Restated Consolidated Financial Information” beginning on page 503.
Further, our Company confirms that it is not ineligible to make the Issue in terms of Regulation 5 of the SEBI
ICDR Regulations, to the extent applicable. The details of our compliance with Regulation 5 of the SEBI ICDR
Regulations are as follows:
a. There are no convertible securities that are required to be converted on or before the filing of the Red
Herring Prospectus;
b. There are no outstanding warrants, options or rights to convert debentures, loans or other instruments
convertible into, or which would entitle any person any option to receive Equity Shares, as on the date of
this Draft Red Herring Prospectus.
Our Company confirms that it is in compliance with the conditions specified in Regulation 7(1) of the SEBI ICDR
Regulations, to the extent applicable, and will ensure compliance with the conditions specified in Regulation 7(2)
of the SEBI ICDR Regulations, to the extent applicable.
Further, in accordance with Regulation 49(1) of the SEBI ICDR Regulations, our Company shall ensure that the
number of Allottees under the issue shall be not less than 1,000 and should our Company fail to do so, the Bid
Amounts received by our Company shall be refunded to the Bidders, in accordance with the SEBI ICDR
Regulations and applicable law.
DISCLAIMER CLAUSE OF SEBI
IT IS TO BE DISTINCTLY UNDERSTOOD THAT SUBMISSION OF THIS DRAFT RED HERRING
PROSPECTUS TO SEBI SHOULD NOT, IN ANY WAY, BE DEEMED OR CONSTRUED THAT THE
SAME HAS BEEN CLEARED OR APPROVED BY SEBI. SEBI DOES NOT TAKE ANY
RESPONSIBILITY EITHER FOR THE FINANCIAL SOUNDNESS OF ANY SCHEME OR THE
PROJECT FOR WHICH THE ISSUE IS PROPOSED TO BE MADE OR FOR THE CORRECTNESS
OF THE STATEMENTS MADE OR OPINIONS EXPRESSED IN THIS DRAFT RED HERRING
PROSPECTUS. THE BRLM, BEELINE CPAITAL ADVISORS PRIVATE IMITED HAS CERTIFIED
THAT THE DISCLOSURES MADE IN THIS DRAFT RED HERRING PROSPECTUS ARE
GENERALLY ADEQUATE AND ARE IN CONFORMITY WITH THE SECURITIES AND
EXCHANGE BOARD OF INDIA (ISSUE OF CAPITAL AND DISCLOSURE REQUIREMENTS)
REGULATIONS, 2018, AS AMENDED. THIS REQUIREMENT IS TO FACILITATE INVESTORS TO
TAKE AN INFORMED DECISION FOR MAKING AN INVESTMENT IN THE PROPOSED ISSUE.
IT SHOULD ALSO BE CLEARLY UNDERSTOOD THAT WHILE THE COMPANY IS PRIMARILY
RESPONSIBLE FOR THE CORRECTNESS, ADEQUACY AND DISCLOSURE OF ALL RELEVANT
INFORMATION IN THIS DRAFT RED HERRING PROSPECTUS, THE BRLM ARE EXPECTED TO
EXERCISE DUE DILIGENCE TO ENSURE THAT THE COMPANY DISCHARGES ITS
RESPONSIBILITY ADEQUATELY IN THIS BEHALF AND TOWARDS THIS PURPOSE, THE BRLM
HAVE FURNISHED TO SEBI, A DUE DILIGENCE CERTIFICATE DATED SEPTEMBER 29, 2025 IN
THE FORMAT PRESCRIBED UNDER SCHEDULE V (A) OF THE SECURITIES AND EXCHANGE
BOARD OF INDIA (ISSUE OF CAPITAL AND DISCLOSURE REQUIREMENTS) REGULATIONS,
2018, AS AMENDED.
THE FILING OF THIS DRAFT RED HERRING PROSPECTUS DOES NOT, HOWEVER, ABSOLVE
THE COMPANY FROM ANY LIABILITIES UNDER THE COMPANIES ACT, 2013, AS AMENDED
OR FROM THE REQUIREMENT OF OBTAINING SUCH STATUTORY AND/OR OTHER
CLEARANCES AS MAY BE REQUIRED FOR THE PURPOSE OF THE ISSUE. SEBI FURTHER
RESERVES THE RIGHT TO TAKE UP, AT ANY POINT OF TIME, WITH THE BRLM, ANY
IRREGULARITIES OR LAPSES IN THIS DRAFT RED HERRING PROSPECTUS.
All legal requirements pertaining to this Issue will be complied with at the time of filing of the Red Herring
Prospectus and Prospectus with the RoC in terms of Companies Act.
Disclaimer from our Company, our Directors and the BRLM
Our Company, our Directors and the BRLM accept no responsibility for statements made otherwise than in this
Draft Red Herring Prospectus or in the advertisements or any other material issued by or at our instance and
anyone placing reliance on any other source of information, including our website, www.sihl.in, or any website
of any of the members of our Promoter Group or any affiliate of our Company, would be doing so at his or her
own risk.
628The BRLM accept no responsibility, save to the limited extent as provided in the Issue Agreement and the
Underwriting Agreement to be entered into between the Underwriters and our Company.
All information shall be made available by our Company and the BRLM to the Bidders and public at large and no
selective or additional information would be made available for a section of the investors in any manner
whatsoever, including at road show presentations, in research or sales reports, at Bidding Centers or elsewhere.
Neither our Company nor any member of the Syndicate shall be liable to the Bidders for any failure in uploading
the Bids, due to faults in any software or hardware system, or otherwise; the blocking of Bid Amount in the ASBA
Account on receipt of instructions from the Sponsor Bank on account of any errors, omissions or non-compliance
by various parties involved in, or any other fault, malfunctioning or breakdown in, or otherwise, in the UPI
Mechanism.
The BRLM and its respective associates and affiliates in their capacity as principals or agents, may engage in
transactions with, and perform services for, our Company, and their respective affiliates or associates or third
parties in the ordinary course of business and have engaged, or may in the future engage, in commercial banking
and investment banking transactions with our the Promoters , Company and its directors and officers, affiliates or
associates or third parties, for which they have received, and may in the future receive, compensation.
Bidders will be required to confirm, and will be deemed to have represented to our Company, the Underwriters
and their respective directors, officers, agents, affiliates and representatives that they are eligible under all
applicable laws, rules, regulations, guidelines and approvals to acquire the Equity Shares, and will not issue, sell,
pledge or transfer the Equity Shares to any person who is not eligible under applicable laws, rules, regulations,
guidelines and approvals to acquire the Equity Shares. Our Company and the Underwriters and their respective
directors, officers, agents, affiliates, employees and representatives accept no responsibility or liability for
advising any investor on whether such investor is eligible to acquire Equity Shares.
Disclaimer in respect of jurisdiction
Any dispute arising out of this Issue will be subject to the jurisdiction of appropriate court(s) at Ahmedabad, India
only.
This Issue is being made in India to persons resident in India (including individual Indian nationals resident in
India who are competent to contract under the Indian Contract Act, 1872, HUFs, companies, corporate bodies and
societies registered under the applicable laws in India and authorized to invest in equity shares, Indian Mutual
Funds registered with SEBI, Indian financial institutions, commercial banks, multilateral and bilateral
development financial institutions, state industrial development corporations, regional rural banks, co-operative
banks (subject to permission from the RBI), trusts under the applicable trust laws and who are authorized under
their respective constitutions to hold and invest in equity shares, public financial institutions as specified under
Section 2(72) of the Companies Act 2013, venture capital funds, National Investment Fund set up by the GoI,
provident funds and pension funds fulfilling the minimum corpus requirements under the SEBI ICDR Regulations,
permitted insurance companies and pension funds, insurance funds set up and managed by the army and navy and
insurance funds set up and managed by the Department of Post, (India), systematically important NBFCs,
permitted non-residents including Eligible NRIs, AIFs, FPIs registered with SEBI and QIBs. This Draft Red
Herring Prospectus does not, however, constitute an offer to sell or an invitation to subscribe to Equity Shares
offered hereby, in any jurisdiction to any person to whom it is unlawful to make an offer or invitation in such
jurisdiction. Any person into whose possession this Draft Red Herring Prospectus comes is required to inform
himself or herself about, and to observe, any such restrictions.
No action has been, or will be taken to permit a public offering in any jurisdiction where action would be required
for that purpose, except that the Draft Red Herring Prospectus has been filed with SEBI for its observations.
Accordingly, the Equity Shares represented hereby may not be offered or sold, directly or indirectly, and this Draft
Red Herring Prospectus may not be distributed, in any jurisdiction, except in accordance with the legal
requirements applicable in such jurisdiction. Neither the delivery of this Draft Red Herring Prospectus, nor any
offer or sale hereunder, shall, under any circumstances, create any implication that there has been no change in
our affairs from the date hereof or that the information contained herein is correct as of any time subsequent to
this date.
This Draft Red Herring Prospectus does not constitute offer to sell or an invitation to subscribe to or purchase the
Equity Shares in the Issue in any jurisdiction, other than in India to any person to whom it is unlawful to make an
offer or invitation in such jurisdiction. Any person into whose possession this Draft Red Herring Prospectus comes
is required to inform himself or herself about, and to observe, any such restrictions. Invitations to subscribe to or
purchase the Equity Shares in the Issue will be made only pursuant to the Red Herring Prospectus if the recipient
629is in India or the preliminary offering memorandum for the Issue, which comprises the Red Herring Prospectus
and the preliminary international wrap for the Issue, if the recipient is outside India.
No person outside India is eligible to Bid for Equity Shares in the Issue unless that person has received the
preliminary offering memorandum for the Issue, which contains the selling restrictions for the Issue outside India.
Eligibility and Transfer Restrictions
The Equity Shares offered in the Issue have not been and will not be registered under the U.S. Securities
Act or any state securities laws in the United States, and unless so registered, may not be offered or sold
within the United States, except pursuant to an exemption from, or in a transaction not subject to, the
registration requirements of the U.S. Securities Act and in accordance with any applicable U.S. state
securities laws. Accordingly, the Equity Shares are being offered and sold outside the United States in
‘offshore transactions’ in reliance on Regulation S under the U.S. Securities Act and the applicable laws of
the jurisdictions where such offers and sales are made.
The Equity Shares have not been and will not be registered, listed or otherwise qualified in any other
jurisdiction outside India and may not be offered or sold, and Bids may not be made by persons in any such
jurisdiction, except in compliance with the applicable laws of such jurisdiction.
Bidders are advised to ensure that any Bid from them does not exceed investment limits or the maximum
number of Equity Shares that can be held by them under applicable law. Further, each Bidder where
required must agree in the Allotment Advice that such Bidder will not sell or transfer any Equity Shares
or any economic interest therein, including any off-shore derivative instruments, such as participatory
notes, issued against the Equity Shares or any similar security, other than in accordance with applicable
laws.
Important Information for Investors – Eligibility and Transfer Restrictions
Until the expiry of 40 days after the commencement of the Issue, an offer or sale of the Equity Shares within
the United States by a dealer (whether or not it is participating in the Issue) may violate the registration
requirements of the U.S. Securities Act, unless made pursuant to available exemptions from the registration
requirements of the U.S. Securities Act and in accordance with applicable securities laws of any state or
other jurisdiction of the United States.
The Equity Shares have not been recommended by any U.S. federal or state securities commission or
regulatory authority. Furthermore, the foregoing authorities have not confirmed the accuracy or
determined the adequacy of this Draft Red Herring Prospectus or approved or disapproved the Equity
Shares. Any representation to the contrary is a criminal offence in the United States. In making an
investment decision, investors must rely on their own examination of our Company and the terms of the
Issue, including the merits and risks involved.
Disclaimer clause of BSE
As required, a copy of this Draft Red Herring Prospectus shall be submitted to BSE. The disclaimer clause as
intimated by BSE to us post scrutiny of this Draft Red Herring Prospectus shall be included in the Red Herring
Prospectus and the Prospectus prior to filing with the RoC.
Disclaimer clause of NSE
As required, a copy of this Draft Red Herring Prospectus shall be submitted to NSE. The disclaimer clause as
intimated by NSE to us post scrutiny of this Draft Red Herring Prospectus shall be included in the Red Herring
Prospectus and the Prospectus prior to filing with the RoC.
Listing
The Equity Shares issued through the Red Herring Prospectus and the Prospectus are proposed to be listed on the
Stock Exchanges. Application has been made to the Stock Exchanges for obtaining permission for listing and
trading of the Equity Shares being issue and sold in the Issue and [●] is the Designated Stock Exchange, with
which the Basis of Allotment will be finalized for the Issue.
If the permission to deal in and for an official quotation of the Equity Shares is not granted by the Stock Exchanges,
our Company shall forthwith repay, without interest, all monies received from the applicants in pursuance of this
Draft Red Herring Prospectus in accordance with applicable law. If such money is not repaid within the prescribed
time, then our Company and every officer in default shall be liable to repay the money, with interest, as prescribed
under applicable law.
630Our Company shall ensure that all steps for the completion of the necessary formalities for listing and
commencement of trading of Equity Shares at the Stock Exchanges are taken within three Working Days of the
Bid/Issue Closing Date. If our Company does not allot Equity Shares pursuant to the Issue within three Working
Days from the Bid/Issue Closing Date or within such timeline as prescribed by SEBI, it shall repay without interest
all monies received from Bidders, failing which interest shall be due to be paid to the Bidders at the rate of 15%
per annum for the delayed period.
Consents
Consents in writing of our Directors, our Company Secretary and Compliance Officer, our Chief Financial Officer,
Legal Counsel to our Company, Industry report provider, the Bankers to our Company, BRLM, Statutory Auditor,
the Registrar to the Issue have been obtained; and the consents in writing of the Syndicate Members, Escrow
Collection Banks, Public Issue Account Bank, Refund Bank, and Sponsor Bank to act in their respective
capacities, will be obtained. Further, such consents shall not be withdrawn up to the time of filing of the Red
Herring Prospectus with RoC.
Expert opinion
Our Company has received written consent dated September 29, 2025 from the Statutory Auditor, namely Ashit
N Shah & Co, Chartered Accountants, to include their name as required under Section 26(1) of the Companies
Act, 2013 read with SEBI ICDR Regulations, in this Draft Red Herring Prospectus, and as an “expert” as defined
under Section 2(38) of the Companies Act, 2013 and such consent has not been withdrawn as on the date of this
Draft Red Herring Prospectus. However, the term “expert” shall not be construed to mean an “expert” as defined
under the U.S. Securities Act.
Our Company has received written consent dated September 29, 2025 from Independent Chartered Accountants,
namely, Dhrumil A. Shah & Co., Chartered Accountants to include their names as required under section 26 (1)
of the Companies Act, 2013 read with SEBI ICDR Regulations, in in respect of their (a) examination report dated
September 05, 2025 on the Restated Consolidated Financial Information (b) The statement of possible special tax
benefits on direct taxes and indirect taxes each dated September 05, 2025, (c) certificates issued by them, , in this
DRHP, and as an “expert” as defined under section 2(38) of the Companies Act, 2013, and such consents has not
been withdrawn as on the date of this DRHP.
Our Company has received written consent dated September 29, 2025 from Mittal V Kothari & Associates,
Practising Company Secretaries, to include their name in this Draft Red Herring Prospectus and as an “expert” as
defined under Section 2(38) of the Companies Act, 2013, to the extent that and in their capacity as practising
company secretary, in relation to their certificate dated September 29, 2025. However, the term “expert” shall not
be construed to mean an “expert” as defined under the U.S. Securities Act.
Particulars regarding public or rights issues undertaken by our Company during the last five years
Except as disclosed in the section entitled “Capital Structure” on page 104, there have been no public issues or
rights issues undertaken by our Company during the five years immediately preceding the date of this Draft Red
Herring Prospectus.
Commission or brokerage on previous issues during the last five years
Since this is the initial public offering of the Equity Shares, no sum has been paid or has been payable as
commission or brokerage for subscribing to or procuring or agreeing to procure public subscription for any of our
Equity Shares in the five years preceding the date of this Draft Red Herring Prospectus.
Capital Issues in the preceding three years
Except as disclosed in the section entitled “Capital Structure” on page 104, our Company has not made any capital
issues during the three years immediately preceding the date of this Draft Red Herring Prospectus.
Performance vis-à-vis objects - Public/ rights issue of our Company
Except as disclosed in the section entitled “Capital Structure” on page 104 our Company has not undertaken any
public, including any rights issues to the public in the five years immediately preceding the date of this Draft Red
Herring Prospectus.
Performance vis- à-vis objects: Public/ rights issue of the listed Subsidiaries and listed Promoters
As on the date of this Draft Red Herring Prospectus our Company does not have a corporate listed promoter or a
listed subsidiary.
631Price information of past issued handled by the BRLM
1. Beeline Capital Advisors Private Limited
SME IPO:
Sr. No. Issue name Issue size Issue Listing date Opening price +/- % change in closing +/- % change in closing +/- % change in
(in ₹ crore) price (₹) on listing date price, [+/- % change in price, [+/- % change in closing
(in ₹) closing benchmark]- 30th closing benchmark]- 90th price, [+/- %
calendar days from listing calendar days from change in
listing closing
benchmark]- 180th
calendar days from
listing
1. +4.34% +1.85% +4.92%
Parmeshwar Metal Limited 24.74 182.00 January 09, 2025 345.80
(0.31%) (-4.37%) (+7.50%)
2. -19.07% -18.89% +9.70%
B.R.Goyal Infrastructure Limited 85.21 135.00 January 14, 2025 135.75
(-0.43%) (-1.75%) (+7.84%)
3. -20.89% +1.16% -10.67%
H.M. Electro Mech Limited 27.74 75.00 January 31, 2025 81.00
(-5.55%) (+3.24%) (+4.95%)
4. +19.55% +50.16% +77.82%
Solarium Green Energy Limited 105.04 190.00 February 13, 2025 202.00
(-3.03%) (+6.58) (+5.86%)
5. +15.70% +12.98%
Identixweb Limited 16.63 54.00 April 03, 2025 55.00 N.A.
(+5.51%) (+9.70%)
6. +17.54% +14.63%
Neptune Petrochemicals Limited 69.53 122 Jun 04, 2025 132.75 N.A.
(+3.19%) (+0.02%)
7. +157.34%
Cryogenic OGS Limited 17.77 47.00 July 10, 2025 89.30 N.A. N.A.
(-4.00%)
8. Monarch Surveyors And Engineering +12.62%
93.75 250.00 July 29, 2025 421.25 N.A. N.A.
Consultants Limited (-0.68%)
9. -22.27%
BLT Logistics Limited 9.72 75.00 August 11, 2025 90.95 N.A. N.A.
(+0.62%)
10. +11.41%
Connplex Cinemas Ltd 90.27 177.00 August 14, 2025 195.00 N.A. N.A.
(+1.96%)
11.
Jay Ambe Supermarkets Limited 18.45 78.00 September 17, 2025 79.00 N.A. N.A. N.A.
MAIN BOARD IPO:
632Sr. No. Issue name Designated Issue size Issue Listing date Opening price +/- % change in closing +/- % change in closing +/- % change in
Stock (in ₹ crore) price on listing date price, [+/- % change in price, [+/- % change in closing
Exchange (₹) (in ₹) closing benchmark]- 30th closing benchmark]- price, [+/- %
calendar days from 90th change in
listing calendar days from closing
listing benchmark]- 180th
calendar days from
listing
1. +72.74% +44.81% +74.14%
Mamata Machinery Limited BSE 179.35(1) 243.00 December 27, 2024 600.00
(-3.19%) (-1.79%) (+4.26%)
2. +1.82% +0.35%
Borana Weaves Limited BSE 144.89 216.00 May 27, 2025 243.00 N.A.
(+1.68%) (-0.30%)
3. -0.81
Shreeji Shipping Global Limited BSE 410.71 252.00 August 26, 2025 271.85 N.A. N.A.
(+1.39%)
4.
Amanta Healthcare Limited NSE 126.00 126.00 September 09, 2025 135.00 N.A. N.A. N.A.
(1) A discount of ₹12 per Equity Share was offered to Eligible Employees bidding in the Employee Reservation Portion of Mamta Machinery Limited IPO.
Source: Price Information www.bseindia.com and www.nseindia.com, Issue Information from respective Prospectus. In case of Main Board IPO, opening price information
as disclosed on the website of the Designated Stock Exchange, change in closing price over the issue/offer price as disclosed on Designated Stock Exchange, and for change
in closing price over the closing price as on the listing date, the CNX NIFTY or S&P BSE SENSEX is considered as the Benchmark Index as per the Designated Stock Exchange
disclosed by the respective Issuer at the time of the issue, as applicable.
Note:
1. The S&P BSE Sensex and NSE Nifty are considered as the Benchmark.
2. “Issue Price” is taken as “Base Price” for calculating % Change in Closing Price of the respective Issues on 30th / 90th/180th Calendar days from listing.
3. “Closing Benchmark” on the listing day of respective scripts is taken as “Base Benchmark” for calculating % Change in Closing Benchmark on 30th / 90th/180th Calendar
days from listing. Although it shall be noted that for comparing the scripts with Benchmark, the +/- % Change in Closing Benchmark has been calculated based on the
Closing Benchmark on the same day as that of calculated for respective script in the manner provided in Note No. 4 below.
4. In case 30th/ 90th/180th day is not a trading day, closing price on BSE/NSE of the previous trading day for the respective Scripts has been considered, however, if scripts
are not traded on that previous trading day then last trading price has been considered.
Summary statement of price information of past issues
Summary statement of price information of past issues (during the current Financial Year and two Financial Years preceding the current Financial Year) handled by Beeline
Capital Advisors Private Limited
SME IPO:
633No. of IPOs trading at No. of IPOs trading at No. of IPOs trading at premium
No. of IPOs trading at discount
premium – 30th calendar discount – 180th calendar – 180th calendar days from
Total Total Funds – 30th calendar days from listing
Financia days from listing days from listing listing
No. of Raised
l Year Less Less Less Less
IPO’s (in ₹ Crore) Over Between Over Between Over Between Over Between
than than than than
50% 25-50% 50% 25-50% 50% 25-50% 50% 25-50%
25% 25% 25% 25%
2025-26 7 319.78 - - 1 1 - 4 - - - - - -
2024-25 24 1,165.44 - - 4 14 - 6 - 5 3 10 2 4
2023-24 22 803.48 - - 2 13 4 3 - 2 2 15 1 2
MAIN BOARD IPO:
No. of IPOs trading at No. of IPOs trading at No. of IPOs trading at No. of IPOs trading at
Total
discount – 30th calendar days premium – 30th calendar days discount – 180th calendar days premium – 180th calendar days
Total Funds
Financial from listing from listing from listing from listing
No. of Raised
Year Less Less Less Less
IPO’s (in ₹ Over Between Over Between Over Between Over Between
than than than than
Crore) 50% 25-50% 50% 25-50% 50% 25-50% 50% 25-50%
25% 25% 25% 25%
2025-26 3 681.60 - - 1 - - 1 - - - - - -
2024-25 1 179.35 - - - 1 - - - - - 1 - -
2023-24 Nil
Notes:
1. Listing date is considered for calculation of total number of IPOs in the respective financial year.
2. In the event any day falls on a holiday, the price/index of the immediately preceding working day has been considered. If the stock was not traded on the said calendar
days from the date of listing, the share price is taken of the immediately preceding trading day.
3. Source: www.bseindia.com and www.nseindia.com
Track record of past issues handled by the BRLM
For details regarding the track record of the BRLM, as specified in Circular reference CIR/MIRSD/1/2012 dated January 10, 2012 issued by SEBI, please see the website of
the BRLM as set forth in the table below:
Sr. No. Name of the BRLM Website
1. Beeline Capital Advisors Private Limited https://beelinemb.com/
634Stock market data of the Equity Shares
As the Issue is the initial public offering of the Equity Shares, the Equity Shares are not listed on any stock
exchange as on the date of this Draft Red Herring Prospectus, and accordingly, no stock market data is available
for the Equity Shares.
Mechanism for redressal of Investor Grievances
The Registrar Agreement provides for retention of records with the Registrar to the Issue for a minimum period
of eight years from the last date of dispatch of the letters of allotment and demat credit to enable the investors to
approach the Registrar to the Issue for redressal of their grievances.
In terms of the SEBI ICDR Master Circular and the SEBI RTA Master Circular, and subject to applicable law,
any ASBA Bidder whose Bid has not been considered for Allotment, due to failure on the part of any SCSB, shall
have the option to seek redressal of the same by the concerned SCSB within three months of the date of listing of
the Equity Shares. SCSBs are required to resolve these complaints within 15 days, failing which the concerned
SCSB would have to pay interest at the rate of 15% per annum for any delay beyond this period of 15 days.
Further, the investors shall be compensated by the SCSBs in accordance with SEBI ICDR Master Circular and
the SEBI RTA Master Circular in the events of delayed unblock for cancelled/withdrawn/deleted applications,
blocking of multiple amounts for the same UPI application, blocking of more amount than the application amount,
delayed unblocking of amounts for non-allotted/partially-allotted applications, for the stipulated period. In the
event there is a delay in redressal of the investor grievance in relation to unblocking of amounts, the BRLM shall
compensate the investors at the rate higher of ₹100 per day or 15% per annum of the application amount, in
addition to the compensation paid by the respective SCSBs, for the period of such delay.
All Issue-related grievances may be addressed to the Registrar to the Issue with a copy to the relevant Designated
Intermediary to whom the Bid cum Application Form was submitted. The Bidder should give full details such as
name of the sole or First Bidder, Bid cum Application Form number, Bidder DP ID, Client ID, UPI ID, PAN, date
of the submission of Bid cum Application Form, address of the Bidder, number of the Equity Shares applied for
and the name and address of the Designated Intermediary where the Bid cum Application Form was submitted by
the Bidder.
Further, Bidders shall also enclose a copy of the Acknowledgment Slip or specify the application number duly
received from the Designated Intermediaries in addition to the documents/information mentioned hereinabove.
Our Company, the BRLM and the Registrar to the Issue accept no responsibility for errors, omissions, commission
or any acts of SCSBs or the Sponsor Banks including any defaults in complying with its obligations under
applicable SEBI ICDR Regulations.
The following compensation mechanism has become applicable for investor grievances in relation to Bids made
through the UPI Mechanism for public issues opening on or after May 1, 2021, for which the relevant SCSBs
shall be liable to compensate the investor:
Scenario Compensation amount Compensation period
Delayed unblock for cancelled / ₹ 100 per day or 15% per annum of the From the date on which the request for
withdrawn / deleted applications Bid Amount, whichever is higher cancellation / withdrawal / deletion is
placed on the bidding platform of the
Stock Exchanges till the date of actual
unblock.
Blocking of multiple amounts for the (i). Instantly revoke the blocked funds From the date on which multiple
same Bid made through the UPI other than the original application amounts were blocked till the date of
Mechanism amount; and actual unblock.
(ii) ₹100 per day or 15% per annum of
the total cumulative blocked amount
except the original Bid Amount,
whichever is higher.
Blocking more amount than the Bid 1. Instantly revoke the difference From the date on which the funds to the
Amount amount, i.e., the blocked amount less excess of the Bid Amount were
the Bid Amount; and blocked till the date of actual unblock
2. ₹100 per day or 15% per annum of
the difference amount, whichever is
higher
Delayed unblock for non – Allotted/ ₹100 per day or 15% per annum of the From the Working Day subsequent to
partially Allotted applications Bid Amount, whichever is higher the finalisation of the Basis of
Allotment till the date of actual
unblock
635Further, in the event there are any delays in resolving the investor grievance beyond the date of receipt of the
complaint from the investor, for each day delayed, the post- Issue BRLM shall also be liable to compensate the
investor at the rate of ₹100 per day or 15% per annum of the Bid Amount, whichever is higher. The compensation
shall be payable for the period ranging from the day on which the investor grievance is received till the date of
actual unblock.
Our Company has also appointed Hiral Bhawsar, Company Secretary of our Company, as the Compliance Officer
for the Issue. For details, see “General Information - Company Secretary and Compliance Officer” on page 97.
Investors can contact our Company Secretary and Compliance Officer or the Registrar to the Issue in case of any
pre- Issue or post- Issue related problems such as non-receipt of letters of Allotment, non-credit of Allotted Equity
Shares in the respective beneficiary account, non-receipt of refund intimations and non-receipt of funds by
electronic mode.
Anchor Investors are required to address all grievances in relation to the Issue to the BRLM giving full details
such as the name of the sole or First Bidder, Bid cum Application Form number, Bidders’ DP ID, Client ID, PAN,
date of the Bid cum Application Form, address of the Bidder, number of the Equity Shares applied for, Bid
Amount paid on submission of the Bid cum Application Form and the name and address of the Book Running
Lead Manager where the Bid cum Application Form was submitted by the Anchor Investor.
Our Company, the Book Running Lead Manager and the Registrar to the Issue accept no responsibility for errors,
omissions, commission or any acts of SCSBs including any defaults in complying with its obligations under
applicable SEBI ICDR Regulations.
Disposal of investor grievances by our Company
Our Company has applied for authentication on the Securities and Exchange Board of India Complaints Redress
System (“SCORES”) and is in compliance with the SEBI circulars in relation to redressal of investor grievances
through SCORES.
Our Company estimates that the average time required by our Company or the Registrar to the Issue or the relevant
Designated Intermediary for the redressal of routine investor grievances shall be 10 Working Days from the date
of receipt of the complaint. In case of non-routine complaints and complaints where external agencies are
involved, our Company will seek to redress these complaints as expeditiously as possible.
Our Company has not received any investor grievances during the three years preceding the date of this Draft Red
Herring Prospectus and there are no investor complaints pending as of the date of this Draft Red Herring
Prospectus.
Our Company has constituted a Stakeholders Relationship Committee to review and redress the shareholders and
investor grievances. For details, please see the section entitled “Our Management-Committees of our Board” on
page 475.
Our Company estimates that the average time required by our Company and/or the Registrar to the Issue for the
redressal of routine investor grievances shall be 15 Working Days from the date of receipt of the complaint. In
case of non-routine complaints and complaints where external agencies are involved, our Company will seek to
redress these complaints as expeditiously as possible.
Our Company estimates that the average time required by it or the Registrar to the Issue or the relevant Designated
Intermediary for the redressal of routine investor grievances shall be three days from the date of receipt of the
complaint. In case of non-routine complaints and complaints where external agencies are involved, our Company
will seek to redress these complaints as expeditiously as possible.
Disposal of investor grievances by listed Group Companies and Subsidiaries
As on the date of this Draft Red Herring Prospectus, our Company does not have any listed group companies and
subsidiary.
Exemption from complying with any provisions of securities laws, if any, granted by SEBI
As on the date of this Draft Red Herring Prospectus, our Company has not been granted by SEBI any exemption
from complying with any provisions of securities laws.
Other confirmations
No person connected with the Issue, including but not limited to our Company, the BRLM, the Syndicate
Members, the Promoters, our Directors or the members of the Promoter Group shall issue in any manner
636whatsoever any incentive, whether direct or indirect, in cash or kind or services or otherwise to any Bidder for
making a Bid, except for fees or commission for services rendered in relation to the Issue.
637SECTION VII – ISSUE RELATED INFORMATION
TERMS OF THE ISSUE
The Equity Shares being issued, and Allotted pursuant to the Issue shall be subject to the provisions of the
Companies Act, SEBI ICDR Regulations, SCRA, SCRR, the MoA, AoA, SEBI Listing Regulations, the terms of
this Draft Red Herring Prospectus, the Red Herring Prospectus, the Prospectus, the abridged prospectus, Bid cum
Application Form, the Revision Form, the CAN/Allotment Advice and other terms and conditions as may be
incorporated in Allotment Advices and other documents/certificates that may be executed in respect of the Issue.
The Equity Shares shall also be subject to laws as applicable, guidelines, rules, notifications and regulations
relating to the issue of capital and listing and trading of securities issued from time to time by SEBI, the
Government of India, the Stock Exchanges, the RBI, RoC and/or other authorities, as in force on the date of the
Issue and to the extent applicable or such other conditions as may be prescribed by the SEBI, the Government of
India, the Stock Exchanges, the RoC and/or any other authorities while granting its approval for the Issue.
The Issue
The Issue is through an issue by our Company. Expenses for the Issue shall be borne our Company in the manner
specified in “Objects of the Issue -Issue related expenses” on page 357.
Ranking of the Equity Shares
The Equity Shares being Allotted pursuant to the Issue shall be subject to the provisions of the Companies Act,
2013, our Memorandum of Association and our Articles of Association and shall rank pari passu in all respects
with the existing Equity Shares, including in respect of the right to receive dividend and voting. The Allottees,
upon Allotment of Equity Shares under the Issue, will be entitled to dividend and other corporate benefits, if any,
declared by our Company after the date of Allotment. For further details, see “Description of Equity Shares and
Terms of the Articles of Association” beginning on page 666.
Mode of Payment of Dividend
Our Company shall pay dividends, if declared, to the Shareholders in accordance with the provisions of the
Companies Act, 2013, the Memorandum and Articles of Association and provisions of the SEBI Listing
Regulations and any other guidelines or directions which may be issued by the Government in this regard.
Dividends, if any, declared by our Company after the date of Allotment, will be payable to the Bidders who have
been Allotted Equity Shares in the Issue, for the entire year, in accordance with applicable laws. For details, in
relation to dividends, see “Dividend Policy” and “Description of Equity Shares and Terms of Articles of
Association” beginning on pages 502 and 666, respectively.
Face Value, Issue Price, Price Band
The face value of each Equity Share is ₹ 10 and the Issue Price at the lower end of the Price Band is ₹ [●] per
Equity Share (“Floor Price”) and at the higher end of the Price Band is ₹ [●] per Equity Share (“Cap Price”).
The Anchor Investor Issue Price is ₹ [●] per Equity Share.
The Price Band and the minimum Bid Lot for the Issue will be decided by our Company in consultation with the
BRLM, as per applicable law and , which shall be advertised in all editions of [●] (a widely circulated English
national daily newspaper), [●] editions of [●] (a widely circulated Hindi national daily newspaper) and [●] editions
of [●] (a widely circulated Gujarati daily newspaper, Gujarati being the regional language of Gujarat, where our
Registered Office is located), each with wide circulation, at least two Working Days prior to the Bid/Issue Opening
Date and shall be made available to the Stock Exchanges for the purpose of uploading the same on their websites.
The Price Band, along with the relevant financial ratios calculated at the Floor Price and at the Cap Price, shall be
pre-filled in the Bid cum Application Forms available on the respective websites of the Stock Exchanges. The
Issue Price shall be determined by our Company (acting through the IPO Committee) in consultation with the
BRLM after the Bid/ Issue Closing Date, on the basis of assessment of market demand for the Equity Shares
issued and issue by way of Book Building Process.
At any given point of time, there shall be only one denomination for the Equity Shares.
Rights of the Equity Shareholders
Subject to applicable laws, rules, regulations and guidelines and the Articles of Association, our equity
Shareholders shall have the following rights:
• Right to receive dividends, if declared;
• Right to attend general meetings and exercise voting rights, unless prohibited by law;
638• Right to vote on a poll either in person or by proxy, or ‘e-voting’ in accordance with the provisions of the
Companies Act, 2013;
• Right to receive offers for rights shares and be allotted bonus shares, if announced;
• Right to receive any surplus on liquidation, subject to any statutory and other preferential claim being
satisfied;
• Right of free transferability, subject to applicable laws including any RBI rules and regulations and foreign
exchange regulations; and
• Such other rights, as may be available to a Shareholder of a listed public company under the Companies Act
2013, the terms of the SEBI Listing Regulations and the Memorandum and Articles of Association of our
Company.
For a detailed description of the main provisions of the Articles of Association of our Company relating to voting
rights, dividend, forfeiture and lien, transfer, transmission and/or consolidation/splitting, see “Description of
Equity Shares and Terms of Articles of Association” on page 666.
Allotment only in dematerialised form
Pursuant to Section 29 of the Companies Act, 2013 the Equity Shares shall be allotted only in dematerialized
form. Bidders will not have the option of Allotment of the Equity Shares in physical form. As per the SEBI ICDR
Regulations, the trading of the Equity Shares shall only be in dematerialised form on the Stock Exchanges.
In this context, our Company has entered into the following agreements with the respective Depositories and
Registrar to the Issue:
• Tripartite Agreement dated August 17, 2017, among CDSL, our Company and the Registrar to the Issue
• Tripartite Agreement dated March 21, 2012, among NSDL, our Company and the Registrar to the Issue
Market Lot and Trading Lot
Since trading of the Equity Shares on the Stock Exchanges shall only be in dematerialized/electronic form, the
tradable lot is one Equity Share. Allotment in this Issue will be only in dematerialized/electronic form in multiples
of one Equity Share subject to a minimum Allotment of [●] Equity Shares of face value of ₹ 10 each. For further
details, see “Issue Procedure” beginning on page 647.
Compliance with disclosure and accounting norms
Our Company shall comply with all applicable disclosure and accounting norms as specified by SEBI from time
to time.
Joint Holders
Subject to the provisions of the Articles of Association, where two or more persons are registered as the holders
of any Equity Shares, they shall be deemed to hold such Equity Shares as joint tenants with benefits of
survivorship.
Period of operation of subscription list
See “–Bid/Issue Period” on page 641.
Jurisdiction
The courts of Gujarat at Ahmedabad, India will have exclusive jurisdiction in relation to this Issue.
Nomination facility to Investors
In accordance with Section 72 of the Companies Act, 2013, read with the Companies (Share Capital and
Debentures) Rules, 2014, the sole Bidder, or the first Bidder along with other joint Bidders, may nominate any
one person in whom, in the event of the death of sole Bidder or in case of joint Bidders, death of all the Bidders,
as the case may be, the Equity Shares Allotted, if any, shall vest to the exclusion of all other persons, unless the
nomination is varied or cancelled in the prescribed manner. A person, being a nominee, entitled to the Equity
Shares by reason of the death of the original holder(s), shall be entitled to the same advantages to which such
person would be entitled if they were the registered holder of the Equity Share(s). Where the nominee is a minor,
the holder(s) may make a nomination to appoint, in the prescribed manner, any person to become entitled to Equity
Share(s) in the event of his or her death during the minority. A nomination shall stand rescinded upon a
sale/transfer/alienation of Equity Share(s) by the person nominating. A nomination may be cancelled or varied by
639nominating any other person in place of the present nominee by the holder of the Equity Shares who has made the
nomination by giving a notice of such cancellation. A buyer will be entitled to make a fresh nomination in the
manner prescribed. Fresh nomination can be made only on the prescribed form available on request at our
Registered Office or to the registrar and transfer agents of our Company.
Any person who becomes a nominee by virtue of the provisions of Section 72 of the Companies Act, 2013 shall
upon the production of such evidence as may be required by the Board, elect either:
a. to register himself or herself as the holder of the Equity Shares; or
b. to make such transfer of the Equity Shares, as the deceased holder could have made.
Further, the Board may at any time give notice requiring any nominee to choose either to be registered himself or
herself or to transfer the Equity Shares, and if the notice is not complied with within a period of 90 days, the Board
may thereafter withhold payment of all dividends, interests, bonuses or other monies payable in respect of the
Equity Shares, until the requirements of the notice have been complied with.
Since the Allotment of Equity Shares in the Issue will be made only in dematerialized mode, there is no need to
make a separate nomination with our Company. Nominations registered with respective Depository Participant of
the Bidder would prevail. If the Bidder wants to change the nomination, they are requested to inform their
respective Depository Participant.
Our Company shall comply with such disclosure and accounting norms as may be specified by SEBI from time
to time.
Bid/Issue Programme
BID/ISSUE OPENS ON [●](1)
BID/ISSUE CLOSES ON [●](2)#
1. Our Company in consultation with the BRLM, may consider participation by Anchor Investors in accordance
with SEBI ICDR Regulations. The Anchor Investor Bid/Issue Period shall be one Working Day prior to the
Bid/Issue Opening Date in accordance with the SEBI ICDR Regulations
2. Our Company in consultation with the BRLM, may consider closing the Bid/Issue Period for QIBs one working
day prior to the Bid/Issue Closing Date in accordance with the SEBI ICDR Regulations.
# UPI mandate end time and date shall be at 5:00pm on Bid/Issue Closing Date, i.e., on [●]
An indicative timeline in respect of the Issue is set out below:
Event Indicative Date
Bid/Issue opening date [●]
Bid/Issue closing date [●]
Finalisation of Basis of Allotment with the Designated Stock On or about [●]
Exchange
Initiation of refunds (if any, for Anchor On or about [●]
Investors)/unblocking of funds from ASBA Account*
Credit of Equity Shares to demat accounts of Allottees On or about [●]
Commencement of trading of the Equity Shares on the Stock On or about [●]
Exchanges
* In case of any delay in unblocking of amounts in the ASBA Accounts (including amounts blocked through the UPI Mechanism) exceeding
two Working Days from the Bid/ Issue Closing Date for cancelled / withdrawn / deleted ASBA Forms, the Bidder shall be compensated at a
uniform rate of ₹100 per day or 15% per annum of the of the Bid Amount, whichever is higher from the date on which the request for
cancellation/ withdrawal/ deletion is placed in the Stock Exchanges bidding platform until the date on which the amounts are unblocked; (ii)
any blocking of multiple amounts for the same ASBA Form (for amounts blocked through the UPI Mechanism), the Bidder shall be
compensated at a uniform rate ₹100 per day or 15% per annum of the total cumulative blocked amount except the original application amount,
whichever is higher from the date on which such multiple amounts were blocked till the date of actual unblock; (iii) any blocking of amounts
more than the Bid Amount, the Bidder shall be compensated at a uniform rate of ₹100 per day or 15% per annum of the difference in amount,
whichever is higher from the date on which such excess amounts were blocked till the date of actual unblock; (iv) any delay in unblocking of
non-allotted/ partially allotted Bids, exceeding two Working Days from the Bid/ Issue Closing Date, the Bidder shall be compensated at a
uniform rate of ₹100 per day or 15% per annum of the Bid Amount, whichever is higher for the entire duration of delay exceeding two Working
Days from the Bid/ Issue Closing Date by the SCSB responsible for causing such delay in unblocking. The BRLM shall, in their sole discretion,
identify and fix the liability on such intermediary or entity responsible for such delay in unblocking. The Bidder shall be compensated in the
manner specified in the
The above timetable, other than the Bid/Issue Closing Date, is indicative and does not constitute any
obligation or liability on our Company or the BRLM.
Whilst our Company shall ensure that all steps for the completion of the necessary formalities for the listing
and the commencement of trading of the Equity Shares on the Stock Exchanges are taken within the time
640prescribed under applicable law, the timetable may be extended due to various factors, such as extension
of the Bid/Issue Period by our Company in consultation with the BRLM, revision of the Price Band or any
delay in receiving the final listing and trading approval from the Stock Exchanges. The commencement of
trading of the Equity Shares will be entirely at the discretion of the Stock Exchanges within three Working
Days from the Bid/Issue Closing Date, as may be prescribed by the SEBI.
The Registrar to the Issue shall submit the details of cancelled/withdrawn/ deleted applications to the
SCSBs on a daily basis within 60 minutes of the Bid closure time from the Bid/Issue Opening Date till the
Bid/Issue Closing Date by obtaining the same the Stock Exchanges. The SCSBs shall unblock such
applications by the closing hours of the Working Day and submit the confirmation to the BRLM and the
Registrar to the issue on a daily basis in accordance with the SEBI RTA Master Circular.
SEBI is in the process of streamlining and reducing the post issue timeline for IPOs. Any circulars or
notifications from SEBI after the date of this Draft Red Herring Prospectus may result in changes to the
above-mentioned timelines. Further, the issue procedure is subject to change basis any revised SEBI
circulars to this effect.
In terms of the UPI Circulars, in relation to the Issue, the Book Running Lead Manager will be required to submit
reports of compliance with timelines and activities prescribed by SEBI in connection with the allotment and listing
procedure within three Working Days from the Bid/ Issue Closing Date, identifying non-adherence to timelines
and processes and an analysis of entities responsible for the delay and the reasons associated with it.
Any circular or notification from SEBI after the date of this Draft Red Herring Prospectus may result in changes
to the listing timelines. Further, the issue procedure is subject to change to any revised SEBI circulars to this
effect.
Submission of Bids (other than Bids from Anchor Investors):
Bid/Issue Period (except the Bid/Issue Closing Date)
Submission and Revision in Bids Only between 10.00 a.m. and 5.00 p.m. Indian Standard
Time (“IST”)
Bid/Issue Closing Date*
Submission and Revision in Bids Only between 10.00 a.m. and 3.00 p.m. IST
Submission of Electronic Applications (Online ASBA Only between 10.00 a.m. and up to 5.00 p.m. IST
through 3-in-1 accounts)–For Retail Individual Bidders
Submission of Electronic Applications (Bank ASBA through Only between 10.00 a.m. and up to 4.00 p.m. IST
Online channels like Internet Banking, Mobile Banking and
Syndicate UPI ASBA applications where Bid Amount is up
to ₹ 5.00 lakhs)
Submission of Electronic Applications (Syndicate Non- Only between 10.00 a.m. and up to 3.00 p.m. IST
Retail, Non-Individual Applications)
Submission of Physical Applications (Bank ASBA) Only between 10.00 a.m. and up to 1.00 p.m. IST
Submission of Physical Applications (Syndicate Non-Retail, Only between 10.00 a.m. and up to 12.00 p.m. IST
Non-Individual Applications of QIBs and NIIs where Bid
Amount is more than ₹ 5.00 lakhs)
Modification/ Revision/cancellation of Bids
Upward Revision of Bids by QIBs and Non-Institutional Only between 10.00 a.m. and up to 5.00 p.m. IST on Bid/
Investors categories# Issue Closing Date
Upward or downward Revision of Bids or cancellation of Only between 10.00 a.m. and up to 5.00 p.m. on Bid/ Issue
Bids by RIIs Closing Date
**UPI mandate end time and date shall be at 5:00 p.m. on Bid/ Issue Closing Date.
#QIBs and Non-Institutional Bidders can neither revise their bids downwards nor cancel/withdraw their bids.
On the Bid/ Issue Closing Date, Bids shall be uploaded until:
a) 4.00 p.m. IST in case of Bids by QIBs and Non-Institutional Bidders, and
b) 5.00 p.m. IST or such extended time as permitted by the Stock Exchanges, in case of Bids by RIBs
On Bid/Issue Closing Date, extension of time may be granted by Stock Exchanges only for uploading Bids
received by Retail Individual Bidders, after taking into account the total number of Bids received and as reported
by the BRLM to the Stock Exchanges.
The Registrar to the Issue shall submit the details of cancelled/withdrawn/deleted applications to the SCSB’s on
daily basis within 60 minutes of the Bid closure time from the Bid/ Issue Opening Date till the Bid/Issue Closing
Date by obtaining the same from the Stock Exchanges. The SCSB’s shall unblock such applications by the closing
641hours of the Working Day and submit a confirmation in respect thereof to the BRLM and the Registrar to the
Issue on a daily basis.
To avoid duplication, the facility of re-initiation provided to Syndicate Members shall preferably be allowed only
once per bid/batch and as deemed fit by the Stock Exchanges, after closure of the time for uploading Bids.
It is clarified that Bids not uploaded on the electronic bidding system or in respect of which the full Bid
Amount is not blocked by SCSBs or not blocked under the UPI Mechanism in the relevant ASBA Account,
as the case may be, would be rejected.
Due to limitation of time available for uploading the Bids on the Bid/Issue Closing Date, Bidders are advised to
submit their Bids one day prior to the Bid/Issue Closing Date. Any time mentioned in this Draft Red Herring
Prospectus is IST. Bidders are cautioned that, in the event a large number of Bids are received on the Bid/Issue
Closing Date, some Bids may not get uploaded due to lack of sufficient time. Such Bids that cannot be uploaded
on the electronic bidding system will not be considered for allocation under this Issue. Bids and any revision in
Bids will be accepted only during Working Days during the Bid / Issue Period.
Investors may please note that as per letter no. List/SMD/SM/2006 dated July 3, 2006 and letter no.
NSE/IPO/25101- 6 dated July 6, 2006 issued by BSE and NSE respectively, Bids and any revision in Bids shall
not be accepted on Saturdays and public holidays as declared by the Stock Exchanges. Bids and revisions by
ASBA Bidders shall be uploaded by the relevant Designated Intermediary in the electronic system to be provided
by the Stock Exchanges. Neither our Company, nor any member of the Syndicate is liable for any failure in
uploading or downloading the Bids due to faults in any software / hardware system or otherwise; or blocking of
application amount by SCSBs on receipt of instructions from the Sponsor Banks due to any errors, omissions, or
otherwise non-compliance by various parties involved in, or any other fault, malfunctioning or breakdown in the
UPI Mechanism.
Our Company in consultation with the BRLM, reserves the right to revise the Price Band during the Bid/Issue
Period. The revision in the Price Band shall not exceed 20% on either side, i.e. the Floor Price can move up or
down to the extent of 20% of the Floor Price and the Cap Price will be revised accordingly. Provided that Cap
Price shall remain minimum 105% of the Floor Price and shall not exceed 120% of the Floor Price
In case of revision in the Price Band, the Bid/Issue Period shall be extended for at least three additional
Working Days after such revision, subject to the Bid/Issue Period not exceeding 10 Working Days. In cases
of force majeure, banking strike or similar circumstances, our Company, in consultation with the BRLM,
for reasons to be recorded in writing, extend the Bid/Issue Period for a minimum of one Working Day,
subject to the Bid/ Issue Period not exceeding 10 Working Days. Any revision in Price Band, and the revised
Bid/Issue Period, if applicable, shall be widely disseminated by notification to the Stock Exchanges, by
issuing a press release and also by indicating the change on the terminals of the Syndicate Members and by
intimation to the Designated Intermediaries and the Sponsor Bank(s), as applicable. In case of revision of
Price Band, the Bid Lot shall remain the same.
None among our Company or any member of the Syndicate is liable for any failure in uploading the Bids due to
faults in any software/ hardware system or the blocking of Bid Amount in the ASBA Account on receipt of
instructions from the Sponsor Bank(s) on account of any errors, omissions or non-compliance by various parties
involved in, or any other fault, malfunctioning or breakdown in, or otherwise, in the UPI Mechanism.
In case of discrepancy in data entered in the electronic book vis-a-vis data contained in the Bid cum Application
Form for a particular Bidder, the details as per the Bid file received from the Stock Exchanges may be taken as
the final data for the purpose of Allotment.
Minimum Subscription
In the event our Company does not receive a subscription in the Issue as specified under Rule 19(2)(b) of the
SCRR, including devolvement of Underwriters, if any, or fails to obtain listing or trading permission from the
Stock Exchanges for the Equity Shares, our Company shall forthwith refund the entire subscription amount
received in accordance with applicable law including the SEBI ICDR Master Circular. If there is a delay beyond
four days after our Company becomes liable to pay the amount, our Company and our Directors, who are officers
in default, shall pay interest at the rate of 15% per annum.
Further our Company shall ensure that the number of prospective Allottees to whom the Equity Shares will be
allotted shall not be less than 1,000 in compliance with Regulation 49(1) of the SEBI ICDR Regulations, failing
which the entire application money shall be unblocked in the respective ASBA Accounts of the Bidders. In case
of delay, if any, in unblocking the ASBA Accounts within such timeline as prescribed under applicable laws, our
Company shall be liable to pay interest on the application money in accordance with applicable laws
642Arrangements for Disposal of Odd Lots
There are no arrangements for disposal of odd lots since our Equity Shares will be traded in dematerialised form
only and market lot for our Equity Shares will be one Equity Share.
New Financial Instruments
Our Company is not issuing any new financial instruments through this Issue.
Restrictions, if any on Transfer and Transmission of Equity Shares
Except for lock-in of the pre-issue capital of our Company, lock-in of the Promoters’ minimum contribution under
the SEBI ICDR Regulations and the Anchor Investor lock-in as provided in “Capital Structure” on page 104 and
except as provided under the Articles of Association, there are no restrictions on transfer of the Equity Shares.
Further, there are no restrictions on transmission of any shares of our Company and on their consolidation or
splitting, except as provided in the Articles of Association. For details, see “Description of Equity Shares and
Terms of Articles of Association” beginning on page 666.
Withdrawal of the Issue
Our Company, in consultation with the BRLM, reserve the right to not proceed with the Issue, in whole or part
thereof, to the extent of their respective portion of Issue Shares after the Bid/Issue Opening Date but before the
Allotment. In the event that our Company, in consultation with the BRLM, decide not to proceed with the Issue,
our Company shall issue a public notice in the newspapers in which the pre-Issue advertisements were published,
within two days of the Bid/Issue Closing Date or such other time as may be prescribed by the SEBI, providing
reasons for not proceeding with the Issue. In such event, the BRLM through the Registrar to the Issue shall notify
the SCSBs and the Sponsor Bank, to unblock the bank accounts of the ASBA Bidders within one Working Day
from the date of receipt of such notification and also inform the Bankers to the Issue to process refunds to the
Anchor Investors, as the case may be. Our Company shall also inform the same to the Stock Exchanges on which
the Equity Shares are proposed to be listed.
Notwithstanding the foregoing, the Issue is also subject to obtaining (i) the final listing and trading approvals of
the Stock Exchanges, which our Company shall apply for after Allotment, and (ii) the final RoC approval of the
Prospectus after it is filed with the RoC. If our Company, in consultation with the Book Running Lead Manager
withdraw the Issue after the Bid/Issue Closing Date and thereafter determines that it will proceed with a public
issuing of Equity Shares, our Company shall file a fresh draft red herring prospectus with the SEBI and Stock
Exchanges.
643ISSUE STRUCTURE
The Issue is being made through the Book Building Process. The Issue is of up to 54,00,000 Equity Shares of face
value of ₹ 10 each for cash at a price of ₹ [●] per Equity Share (including a premium of ₹ [●] per Equity Share)
aggregating up to ₹ [●] lakhs. The Issue will constitute [●] % of the post-issue paid-up Equity Share capital of our
Company.
The Issue shall constitute [●] of the post-Issue paid-up Equity Share capital of our Company.
The face value of the Equity Shares is ₹ 10 each.
In terms of Rule 19(2)(b) of the SCRR, the Issue is being made through the Book Building Process, in compliance
with Regulation 6(1) and Regulation 31 of the SEBI ICDR Regulations:
Particulars QIBs Non-Institutional Bidders Retail Individual Bidders
Number of Equity Shares Not more than [●] Equity Not less than [●] Equity Not less than [●] Equity
available for Shares of face value of ₹ 10 Shares of face value of ₹ 10 Shares of face value of ₹ 10
Allotment/allocation(2) each aggregating to ₹ [●] each aggregating to ₹ [●] each aggregating to ₹ [●]
available for allocation or available for allocation or
Issue less allocation to QIB Issue less allocation to QIB
Bidders and Retail Bidders and Non-
Individual Bidders Institutional Bidders
Percentage of Issue size Not more than 50% of the Not less than 15% of the Not less than 35% of the
available for Issue shall be available for Issue or the Issue less Issue or the Issue less
Allotment/allocation allocation to QIBs. allocation to QIBs and allocation to QIBs and Non-
Retail Individual Bidders Institutional Bidders will be
However, upto 5% of the will be available for available for allocation
Net QIB Portion (excluding allocation
the Anchor Investor
Portion) shall be available
for allocation
proportionately to Mutual
Funds only. Mutual Funds
participating in the Mutual
Fund Portion will also be
eligible for allocation in the
remaining balance QIB
Portion (excluding the
Anchor Investor Portion).
The unsubscribed portion in
the Mutual Fund Portion
will be available for
allocation to other QIBs
Basis of Proportionate as follows The allotment to each Non- Allotment to each Retail
Allotment/allocation if (excluding the Anchor Institutional Bidders shall Individual Bidder shall not
respective category is Investor Portion): not be less than the be less than the minimum
oversubscribed* (a) up to [●] Equity Shares minimum application size, Bid lot, subject to
of face value of ₹ 10 each subject to availability of availability of Equity Shares
shall be available for Equity Shares in the Non- in the Retail Portion and the
allocation on a Institutional Portion and the remaining available Equity
proportionate basis to remaining available Equity Shares if any, shall be
Mutual Funds only; and (b) Shares if any, shall be allotted on a proportionate
[●] Equity Shares of face Allotted on a proportionate basis. For details see, “Issue
value of ₹ 10 each shall be basis, in accordance with the Procedure” on page 647.
available for allocation on a conditions specified in the
proportionate basis to all SEBI ICDR Regulations
QIBs, including Mutual subject to:
Funds receiving allocation
as per (a) above. a. one third of the portion
Up to 60% of the QIB available to Non-
Portion (of up to [●] Equity Institutional Bidders
Shares of face value of ₹ 10 being [●] Equity Shares
each) may be allocated on a of face value of ₹ 10 each
discretionary basis to are reserved for Bidders
Anchor Investors of which Biddings more than ₹
one-third shall be available 2.00 lakhs and up to
for allocation to Mutual ₹10.00 lakhs;
Funds only, subject to valid
644Particulars QIBs Non-Institutional Bidders Retail Individual Bidders
Bid received from Mutual b. two third of the portion
Funds at or above the available to Non-
Anchor Investor Allocation Institutional Bidders
Price being [●] Equity Shares
are reserved for Bidders
Bidding more than ₹10
lakhs.
Provided that the
unsubscribed portion in
either of the categories
specified in (a) or (b)
above, may be allocated
to Bidders in the other
category.
Minimum Bid Such number of Equity Such number of Equity [●] Equity Shares of face
Shares and in multiples of Shares and in multiples of value of ₹ 10 each and in
[●] Equity Shares so that the [●] Equity Shares so that the multiples of [●] Equity
Bid Amount exceeds ₹2.00 Bid Amount exceeds ₹2.00 Shares of face value of ₹ 10
lakhs lakhs each
Maximum Bid Such number of Equity Such number of Equity Such number of Equity
Shares in multiples of [●] Shares in multiples of [●] Shares in multiples of [●]
Equity Shares of face value Equity Shares of face value Equity Shares of face value
of ₹ 10 each so that the Bid of ₹ 10 each so that the Bid of ₹ 10 each so that the Bid
does not exceed the size of does not exceed the size of Amount does not exceed
the Issue (excluding the the Issue (excluding the QIB ₹2.00 lakhs
Anchor portion), subject to Portion), subject to
applicable limits. applicable limits
Mode of Allotment Compulsorily in dematerialized form
Bid Lot [●] Equity Shares of face value of ₹ 10 each and in multiples of [●] Equity Shares of face
value of ₹ 10 each thereafter
Allotment Lot A minimum of [●] Equity Shares of face value of ₹ 10 each and in multiples of [●] Equity
Share thereafter
Trading Lot [●] One Equity Share
Who can apply(3)(4) Public financial institutions Resident Indian individuals, Resident Indian individuals,
as specified in Section 2(72) Eligible NRIs on a non- Eligible NRIs and HUFs (in
of the Companies Act 2013, repatriable basis, HUFs (in the name of Karta) applying
scheduled commercial the name of Karta), for Equity Shares such that
banks, mutual funds companies, corporate the Bid amount does not
registered with SEBI, FPIs bodies, scientific exceed ₹2.00 lakhs in value.
(other than individuals, institutions, societies, trusts
corporate bodies and family and FPIs who are
offices), VCFs, AIFs, state individuals, corporate
industrial development bodies and family offices
corporation, insurance which are recategorized as
company registered with category II FPIs and
IRDAI, provident fund with registered with SEBI
minimum corpus of
₹2500.00 lakhs, pension
fund with minimum corpus
of ₹2500.00 lakhs. National
Investment Fund set up by
the Government, insurance
funds set up and managed
by army, navy or air force of
the Union of India,
insurance funds set up and
managed by the Department
of Posts, India and
Systemically Important
NBFCs
Terms of Payment In case of Anchor Investors: Full Bid Amount shall be payable by the Anchor Investors at
the time of submission of their Bids (4)
In case of all other Bidders: Full Bid Amount shall be blocked in the bank account
645Particulars QIBs Non-Institutional Bidders Retail Individual Bidders
of the ASBA Bidder (other than Anchor Investors) or by the Sponsor Bank through the UPI
Mechanism (for RIBs using the UPI Mechanism) that is specified in the ASBA Form at the
time of submission of the ASBA Form.
Mode of Bidding Only through the ASBA Through ASBA process Through ASBA process
process (excluding the UPI only (including the UPI only (including the UPI
Mechanism) except for Mechanism for Bids up to ₹ Mechanism)
Anchor Investors 5 lakhs)
*Assuming full subscription in the Issue
1. Our Company, in consultation with the BRLM, may allocate up to 60% of the QIB Portion to Anchor
Investors on a discretionary basis in accordance with the SEBI ICDR Regulations. One-third of the Anchor
Investor Portion shall be reserved for domestic Mutual Funds, subject to valid Bids being received from
domestic Mutual Funds at or above the price Anchor Investor Allocation Price. In the event of under-
subscription or non-Allotment in the Anchor Investor Portion, the balance Equity Shares in the Anchor
Investor Portion shall be added to the Net QIB Portion. For details, see “Issue Procedure” on page 647 .
2. Subject to valid Bids being received at or above the Issue Price. This is an Issue in terms of Rule 19(2)(b) of
the SCRR in compliance with Regulation 6(1)) of the SEBI ICDR Regulations.
Subject to valid Bids being received at or above the Issue Price, under-subscription, if any, in the Non-
Institutional Portion or the Retail Portion would be allowed to be met with spill-over from other categories
or a combination of categories at the discretion of our Company in consultation with the BRLM and the
Designated Stock Exchange, on a proportionate basis. However, under-subscription, if any, in the QIB
Portion will not be allowed to be met with spill-over from other categories or a combination of categories.
3. In case of joint Bids, the Bid cum Application Form should contain only the name of the first Bidder whose
name should also appear as the first holder of the beneficiary account held in joint names. The signature of
only such first Bidder would be required in the Bid cum Application Form and such first Bidder would be
deemed to have signed on behalf of the joint holders. Our Company reserves the right to reject, in its absolute
discretion, all or any multiple Bids, except as otherwise permitted, in any or all categories.
4. Full Bid Amount shall be payable by the Anchor Investors at the time of submission of the Anchor Investor
Application Forms provided that any difference between the Anchor Investor Allocation Price and the
Anchor Investor Issue Price shall be payable by the Anchor Investor Pay-In Date as indicated in the CAN.
Bidders will be required to confirm and will be deemed to have represented to our Company, the
Underwriters, their respective directors, officers, agents, affiliates and representatives that they are eligible
under applicable law, rules, regulations, guidelines and approvals to acquire the Equity Shares.The Bids by
FPIs with certain structures as described under “Issue Procedure - Bids by FPIs” on page 652 and having
same PAN may be collated and identified as a single Bid in the Bidding process. The Equity Shares Allocated
and Allotted to such successful Bidders (with same PAN) may be proportionately distributed.
646ISSUE PROCEDURE
All Bidders should read the General Information Document for Investing in Public Offers prepared and issued in
accordance with the circular no. SEBI/HO/CFD/DIL1/CIR/P/2020/37 dated March 17, 2020 and the UPI
Circulars (the “General Information Document”), which highlights the key rules, processes and procedures
applicable to public issues in general in accordance with the provisions of the Companies Act, the SCRA, the
SCRR and the SEBI ICDR Regulations which is part of the abridged prospectus accompanying the Bid cum
Application Form. The General Information Document is also available on the websites of the Stock Exchanges
and the BRLM. Please refer to the relevant provisions of the General Information Document which are applicable
to the Issue, including in relation to the process for Bids through the UPI Mechanism.
Bidders may refer to the General Information Document for information in relation to (i) category of investors
eligible to participate in the Issue; (ii) maximum and minimum Bid size; (iii) price discovery and allocation; (iv)
payment instructions for ASBA Bidders; (v) issuance of CAN and Allotment in the Issue; (vi) general instructions
(limited to instructions for completing the Bid cum Application Form); (vii) submission of Bid cum Application
Form; (viii) other instructions (limited to joint bids in cases of individual, multiple bids and instances when an
application would be rejected on technical grounds); (ix) applicable provisions of the Companies Act, 2013
relating to punishment for fictitious applications; (x) mode of making refunds; (xi) Designated Date; (xii) disposal
of applications; and (xiii) interest in case of delay in Allotment or refund.
The SEBI vide its circular no. SEBI/HO/CFD/DIL2/CIR/P/2018/138 dated November 1, 2018 read with its
circular no. SEBI/HO/CFD/DIL2/CIR/P/2019/50 dated April 3, 2019, had introduced an alternate payment
mechanism using Unified Payments Interface (“UPI”) and consequent reduction in timelines for listing in a
phased manner. Further, SEBI vide its circular no. SEBI/HO/CFD/DIL2/CIR/P/2021/2480/1/M dated March 16,
2021 read with SEBI circular no. SEBI/HO/CFD/DIL2/P/CIR/2021/570 dated June 2, 2021, SEBI circular no.
SEBI/HO/CFD/DIL2/CIR/P/2022/51 dated April 20, 2022 (to the extent these have not been rescinded by the
SEBI ICDR Master Circular and the SEBI RTA Master Circular), had introduced certain additional measures for
streamlining the process of initial public offers and redressing investor grievances. The provisions of these
circulars are deemed to form part of this Draft Red Herring Prospectus. Furthermore, pursuant to ICDR Master
Circular, all individual bidders in initial public offerings whose application sizes are up to ₹500,000 shall use the
UPI Mechanism.
Pursuant to SEBI circular no. SEBI/HO/CFD/TPD1/CIR/P/2023/140 dated August 9, 2023, the time period for
listing of equity shares pursuant to a public issue has been reduced from six Working Days to three Working Days,
and as a result, the final reduced timeline of T+3 days has been made effective using the UPI Mechanism for
applications by UPI Bidders (“UPI Phase III”). The SEBI by way of a master circular no. SEBI/HO/CFD/PoD-
1/P/CIR/2024/0154 dated November 11, 2024, consolidated a chapter-wise framework for compliance with
various obligations under the SEBI ICDR Regulations. Accordingly, subject to any circulars, clarification or
notification issued by the SEBI from time to time, this Issue will be undertaken pursuant to the processes and
procedures prescribed under the SEBI ICDR Master Circular, subject to any circulars, clarifications or
notifications which may be issued by the SEBI.
The SEBI ICDR Master Circular has consolidated and rescinded the aforementioned circulars, to the extent they
relate to the SEBI ICDR Regulations. The SEBI ICDR Master Circular has prescribed certain additional measures
for streamlining the process of initial public offers and redressing investor grievances. The provisions of the SEBI
ICDR Master Circular are deemed to form part of this Draft Red Herring Prospectus.
Pursuant to ICDR Master Circular, applications made using the ASBA facility in initial public offerings shall be
processed by the Registrar along with the SCSBs only after application monies are blocked in the bank accounts
of investors (all categories). Accordingly, Stock Exchanges shall, for all categories of investors and other reserved
categories and also for all modes through which the applications are processed, accept the ASBA applications in
their electronic book building platform only with a mandatory confirmation on the application monies blocked.
In terms of Regulation 23(5) and Regulation 52 of SEBI ICDR Regulations, the timelines and processes mentioned
in the SEBI ICDR Master Circular shall continue to form part of the agreements being signed between the
intermediaries involved in the public issuance process and lead managers shall continue to coordinate with
intermediaries involved in the said process. In case of any delay in unblocking of amounts in the ASBA Accounts
(including amounts blocked through the UPI Mechanism) exceeding two Working Days from the Bid/ Issue
Closing Date, the Bidder shall be compensated at a uniform rate of ₹100 per day or 15% per annum of the
application amount for the entire duration of delay exceeding two Working Days from the Bid/ Issue Closing Date
by the intermediary responsible for causing such delay in unblocking.
647Our Company and the BRLM are not liable for any amendment, modification or change in the applicable law
which may occur after the date of this Draft Red Herring Prospectus. Bidders are advised to make their
independent investigations and ensure that their Bids are submitted in accordance with applicable laws and do
not exceed the investment limits or maximum number of the Equity Shares that can be held by them under
applicable law or as specified in this Draft Red Herring Prospectus, the Red Herring Prospectus and the
Prospectus.
Book Building Procedure
The Issue is being made through the Book Building Process, in terms of Rule 19(2)(b) of the SCRR, read with
Regulation 31 of the SEBI ICDR Regulations, in accordance with Regulation 6(1) of the SEBI ICDR Regulations
wherein not more than 50% of the Issue shall be available for allocation on a proportionate basis to QIBs, provided
that our Company in consultation with the BRLM may allocate up to 60% of the QIB Portion to Anchor Investors
on a discretionary basis in accordance with the SEBI ICDR Regulations, of which one-third shall be reserved for
domestic Mutual Funds, subject to valid Bids being received from domestic Mutual Funds at or above the Anchor
Investor Allocation Price. Further, in the event of under-subscription, or non-allocation in the Anchor Investor
Portion, the balance Equity Shares shall be added to the Net QIB Portion. Further, 5% of the Net QIB Portion
shall be available for allocation on a proportionate basis to Mutual Funds only and the remainder of the Net QIB
Portion shall be available for allocation on a proportionate basis to all QIB Bidders (other than Anchor Investors),
including Mutual Funds, subject to valid Bids being received at or above the Issue Price. Further, not less than
15% of the Issue shall be available for allocation on a proportionate basis to Non-Institutional Investors out of
which (a) one-third of such portion shall be reserved for applicants with application size of more than ₹2.00 lakhs
and up to ₹10.00 lakhs; and (b) two-third of such portion shall be reserved for applicants with application size of
more than ₹ 10.00 lakhs, provided that the unsubscribed portion in either of such sub-categories may be allocated
to applicants in the other sub-category of Non-Institutional Investors and not less than 35% of the Issue shall be
available for allocation to Retail Individual Bidders in accordance with the SEBI ICDR Regulations, subject to
valid Bids being received at or above the Issue Price.
The Equity Shares, on Allotment, shall be traded only in the dematerialised segment of the Stock Exchanges.
Investors must ensure that their PAN is linked with Aadhaar and are in compliance with the notification
by the Central Board of Direct Taxes dated February 13, 2020, read with press releases dated June 25,
2021, and September 17, 2021, March 30, 2022, and March 28, 2023.
Bidders should note that the Equity Shares will be Allotted to all successful Bidders only in dematerialised
form. The Bid cum Application Forms which do not have the details of the Bidders’ depository account,
including the DP ID and the Client ID and the PAN and UPI ID (for UPI Bidders Bidding through the UPI
Mechanism), shall be treated as incomplete and will be rejected. Bidders will not have the option of being
Allotted Equity Shares in physical form.
Phased implementation of Unified Payments Interface
SEBI has issued the UPI Circulars in relation to streamlining the process of public issue of inter alia, equity shares.
Pursuant to the UPI Circulars, the UPI Mechanism has been introduced in a phased manner as a payment
mechanism (in addition to mechanism of blocking funds in the account maintained with SCSBs under ASBA) for
applications by RIBs through Designated Intermediaries with the objective to reduce the time duration from public
issue closure to listing from six Working Days to up to three Working Days. The SEBI in its circular no.
SEBI/HO/CFD/TPD1/CIR/P/2023/140 dated August 9, 2023, has reduced the time period for listing of equity
shares pursuant to a public issue from six Working Days to three Working Days. This Issue will be undertaken
pursuant to the processes and procedures prescribed under UPI Phase III, subject to any circulars, clarifications
or notifications which may be issued by the SEBI.
Pursuant to UPI Circulars, SEBI has set out specific requirements for redressal of investor grievances for
applications that have been made through the UPI Mechanism. The requirements of the UPI Streamlining Circular
include, appointment of a nodal officer by the SCSB and submission of their details to SEBI, the requirement for
SCSBs to send SMS alerts for the blocking and unblocking of UPI mandates, the requirement for the Registrar to
submit details of cancelled, withdrawn or deleted applications, and the requirement for the bank accounts of
unsuccessful Bidders to be unblocked no later than one day from the date on which the Basis of Allotment is
finalized. Failure to unblock the accounts within the timeline would result in the SCSBs being penalized under
the relevant securities law. Additionally, if there is any delay in the redressal of investors’ complaints, the relevant
SCSB as well as the post– Issue BRLM will be required to compensate the concerned investor.
All SCSBs offering the facility of making applications in public issues shall also provide the facility to make
applications using UPI. Our Company will be required to appoint Sponsor Banks to act as conduits between the
648Stock Exchanges and NPCI in order to facilitate collection of requests and/ or payment instructions of the UPI
Bidders using the UPI.
Further, pursuant to SEBI Circular No: SEBI/HO/CFD/DIL2/CIR/P/2022/45 dated April 5, 2022, all individual
investors applying in public issues where the application amount is up to ₹500,000 shall use UPI and shall also
provide their UPI ID in the Bid cum Application Form submitted with any of the entities mentioned herein below:
a) a syndicate member;
b) a stock broker recognised with a registered stock exchange (and whose name is mentioned on the website of
the stock exchange as eligible for this activity);
c) a depository participant (whose name is mentioned on the website of the stock exchange as eligible for this
activity);
d) a registrar to an issue and share transfer agent (whose name is mentioned on the website of the stock exchange
as eligible for this activity)
For further details, refer to the “General Information Document” available on the websites of the Stock Exchanges
and the BRLM.
Bid cum Application Form
Copies of the Bid cum Application Form (other than for Anchor Investors) and the abridged prospectus will be
available with the Designated Intermediaries at the Bidding Centers, and our Registered Office. An electronic
copy of the Bid cum Application Form will also be available for download on the websites of NSE
(www.nseindia.com) and BSE (www.bseindia.com) at least one day prior to the Bid/Issue Opening Date.
Copies of the Anchor Investor Application Form will be available at the office of with the BRLM.
All Bidders (other than Anchor Investors) shall mandatorily participate in the Issue only through the ASBA
process.
UPI Bidders bidding using the UPI Mechanism must provide the valid UPI ID in the relevant space provided in
the Bid cum Application Form and the Bid cum Application Form that does not contain the UPI ID are liable to
be rejected.
Anchor Investors are not permitted to participate in the Issue through the ASBA process. The RIBs can
additionally Bid through the UPI Mechanism. RIBs bidding using the UPI Mechanism must provide the valid UPI
ID in the relevant space provided in the Bid cum Application Form and the Bid cum Application Form that does
not contain the UPI ID are liable to be rejected. Retail Individual Investors Bidding using the UPI Mechanism
may also apply through the SCSBs and mobile applications using the UPI handles as provided on the website of
SEBI ASBA Bidders (other than Retail Individual Investors using UPI Mechanism) must provide bank account
details and authorisation to block funds in their respective ASBA Accounts in the relevant space provided in the
ASBA Form and the ASBA Forms that do not contain such details are liable to be rejected or the UPI ID, as
applicable, in the relevant space provided in the ASBA Form.
ASBA Bidders shall ensure that the Bids are made on ASBA Forms bearing the stamp of the Designated
Intermediary, submitted at the Bidding Centers only (except in case of electronic ASBA Forms) and the ASBA
Forms not bearing such specified stamp are liable to be rejected. RIBs using UPI Mechanism, may submit their
ASBA Forms, including details of their UPI IDs, with the Syndicate, Sub-Syndicate members, Registered Brokers,
RTAs or CDPs. RIBs authorising an SCSB to block the Bid Amount in the ASBA Account. RIBs may also submit
their ASBA Forms with the SCSBs (except RIBs using the UPI Mechanism). ASBA bidders must ensure that the
ASBA Account has sufficient credit balance such that an amount equivalent to the full Bid Amount can be blocked
by the SCSB or the Sponsor Bank, as applicable at the time of submitting the Bid. In order to ensure timely
information to Bidders, SCSBs are required to send SMS alerts to investors intimating them about Bid Amounts
blocked/ unblocked.
The Sponsor Bank shall host a web portal for intermediaries (closed user group) from the date of Bid/Issue
Opening Date till the date of listing of the Equity Shares with details of statistics of mandate blocks/unblocks,
performance of apps and UPI handles, down-time/network latency (if any) across intermediaries and any such
processes having an impact/bearing on the Issue Bidding process. The prescribed colour of the Bid cum
Application Form for the various categories is as follows:
Category Colour of Bid cum Application Form*
Resident Indians, including resident QIBs, Non-Institutional
Bidders, Retail Individual Bidders and Eligible NRIs [●]
applying on a non-repatriation basis
649Category Colour of Bid cum Application Form*
Non-Residents including Eligible NRIs, their sub-accounts
(other than sub-accounts which are foreign corporates or
foreign individuals under the QIB Portion), FVCIs, FPIs and [●]
registered bilateral and multilateral development financial
institutions applying on a non-repatriation basis
Anchor Investors [●]
*Excluding electronic Bid cum Application Forms
Notes:
(1) Electronic Bid cum Application forms and the abridged prospectus will also be available for download on the website of NSE
(www.nseindia.com) and BSE (www.bseindia.com)
(2) Bid cum Application Forms for Anchor Investors shall be available at the offices of the BRLM
In case of ASBA forms, the relevant Designated Intermediaries shall upload the relevant bid details in the electronic
bidding system of the Stock Exchanges. For ASBA Forms (other than through UPI Mechanism) Designated
Intermediaries (other than SCSBs) shall submit/ deliver the ASBA Forms to the respective SCSB where the Bidder
has an ASBA bank account and shall not submit it to any non-SCSB bank or any Escrow Collection Bank.
For UPI Bidders using the UPI Mechanism, the Stock Exchanges shall share the Bid details (including UPI ID)
with the Sponsor Banks on a continuous basis to enable the Sponsor Banks to initiate the UPI Mandate Request
to UPI Bidders for blocking of funds. The Sponsor Banks shall initiate request for blocking of funds through NPCI
to UPI Bidders, who shall accept the UPI Mandate Request for blocking of funds on their respective mobile
applications associated with UPI ID linked bank account. The NPCI shall maintain an audit trail for every bid
entered in the Stock Exchanges bidding platform, and the liability to compensate UPI Bidders (using the UPI
Mechanism) in case of failed transactions shall be with the concerned entity (i.e., the Sponsor Banks, NPCI or the
Bankers to the Issue) at whose end the lifecycle of the transaction has come to a halt. The NPCI shall share the
audit trail of all disputed transactions/ investor complaints to the Sponsor 531 Banks and the bankers to an issue.
The BRLM shall also be required to obtain the audit trail from the Sponsor Banks and the Banker to the Issue for
analyzing the same and fixing liability. For ensuring timely information to investors, SCSBs shall send SMS alerts
as specified in the SEBI ICDR Master Circular.
Pursuant to NSE circular dated July 22, 2022 with reference no. 23/2022 and BSE circular dated July 22, 2022
with reference no. 20220722-30, has mandated that trading members, Syndicate Members, RTA and Depository
Participants shall submit Syndicate ASBA bids above ₹500,000 and NII and QIB bids above ₹200,000, through
SCSBs only.
For all pending UPI Mandate Requests, the Sponsor Banks shall initiate requests for blocking of funds in the
ASBA Accounts of relevant Bidders with a confirmation cut-off time of 5:00 p.m. on the Bid/ Issue Closing Date
(“Cut-Off Time”). Accordingly, UPI Bidders Bidding using through the UPI Mechanism should accept UPI
Mandate Requests for blocking off funds prior to the Cut-Off Time and all pending UPI Mandate Requests at the
Cut-Off Time shall lapse
The processing fees for applications made by UPI Bidders using the UPI Mechanism may be released to the
SCSBs only after such banks provide a written confirmation on compliance with the UPI Circulars.
The Sponsor Banks will undertake a reconciliation of Bid responses received from Stock Exchanges and sent to
NPCI and will also ensure that all the responses received from NPCI are sent to the Stock Exchanges platform
with detailed error code and description, if any. Further, the Sponsor Banks will undertake reconciliation of all
Bid requests and responses throughout their lifecycle on daily basis and share reports with the BRLM in the format
and within the timelines as specified under the UPI Circulars. Sponsor Banks and issuer banks shall download
UPI settlement files and raw data files from the NPCI portal after every settlement cycle and do a three way
reconciliation with UPI switch data, CBS data and UPI raw data. NPCI is to coordinate with issuer banks and
Sponsor Banks on a continuous basis.
The Sponsor Banks shall host a web portals for intermediaries (closed user group) from the date of Bid/ Issue
Opening Date until the date of listing of the Equity Shares with details of statistics of mandate blocks/unblocks,
performance of apps and UPI handles, down-time/network latency (if any) across intermediaries and any such
processes having an impact/bearing on the Issue Bidding process.
ELECTRONIC REGISTRATION OF BIDS
a) The Designated Intermediary may register the Bids using the on-line facilities of the Stock Exchanges. The
Designated Intermediaries can also set up facilities for off-line electronic registration of Bids, subject to the
condition that they may subsequently upload the off-line data file into the on-line facilities for Book Building
on a regular basis before the closure of the Issue.
650b) On the Bid/Issue Closing Date, the Designated Intermediaries may upload the Bids till such time as may be
permitted by the Stock Exchanges and as disclosed in this Draft Red Herring Prospectus.
c) The Designated Intermediaries shall modify select fields uploaded in the Stock Exchange Platform during
the Bid/Issue Period till 5.00 pm on the Bid/Issue Closing Date after which the Stock Exchange(s) send the
bid information to the Registrar to the Issue for further processing.
d) QIBs and Non-Institutional Bidders can neither revise their bids downwards nor cancel/withdraw their bids.
The Equity Shares issue in the Issue have not been and will not be registered under the U.S. Securities Act
or the securities laws of any state of the United States and may not be issue or sold in the United States
except pursuant to an exemption from, or in a transaction not subject to, the registration requirements of
the U.S. Securities Act and applicable state securities laws. The Equity Shares are being issue and sold only
outside the United States in reliance on Regulation S and the applicable laws of the jurisdictions where such
issues and sales occurs.
The Equity Shares have not been and will not be registered, listed or otherwise qualified in any other
jurisdiction outside India and may not be issue or sold, and Bids may not be made by persons in any such
jurisdiction, except in compliance with the applicable laws of such jurisdiction.
Participation by Promoters and members of the Promoter Group of the Company, the BRLM and the
Syndicate Members and the persons related to Promoter, Promoter Group, BRLM and the Syndicate
Members
The BRLM and the Syndicate Members shall not be allowed to purchase Equity Shares in this Issue in any manner,
except towards fulfilling their underwriting obligations. However, the associates and affiliates of the BRLM and
the Syndicate Members may Bid for Equity Shares in the Issue, either in the QIB Portion or in the Non-
Institutional Portion as may be applicable to such Bidders, where the allocation is on a proportionate basis and
such subscription may be on their own account or on behalf of their clients. All categories of investors, including
associates or affiliates of the BRLM and Syndicate Members, shall be treated equally for the purpose of allocation
to be made on a proportionate basis.
Neither (i) the BRLM or any associates of the BRLM (except Mutual Funds sponsored by entities which are
associates of the BRLM or insurance companies promoted by entities which are associate of BRLM or AIFs
sponsored by the entities which are associate of the BRLM or FPIs other than individuals, corporate bodies and
family offices sponsored by the entities which are associates of the BRLM, Pension funds sponsored by entities
which are associate of BRLM) nor (ii) any “person related to the Promoters/ Promoter Group” shall apply in the
Issue under the Anchor Investor Portion.
For the purposes of this section, a QIB who has any of the following rights shall be deemed to be a “person related
to the Promoters/ Promoter Group”: (a) rights under a shareholders’ agreement or voting agreement entered into
with the Promoters or Promoter Group; (b) veto rights; or (c) right to appoint any nominee director on our Board.
Further, an Anchor Investor shall be deemed to be an associate of the BRLM, if: (a) either of them controls,
directly or indirectly through its subsidiary or holding company, not less than 15% of the voting rights in the other;
or (b) either of them, directly or indirectly, by itself or in combination with other persons, exercises control over
the other; or (c) there is a common director, excluding a nominee director, amongst the Anchor Investor and the
BRLM.
The Promoters and members of the Promoter Group will not participate in the Issue.
Bids by Mutual Funds
With respect to Bids by Mutual Funds, a certified copy of their SEBI registration certificate must be lodged along
with the Bid cum Application Form. Failing this, our Company in consultation with the BRLM reserve the right
to reject any Bid without assigning any reason thereof.
Bids made by asset management companies or custodians of Mutual Funds shall specifically state names of the
concerned schemes for which such Bids are made. In case of a Mutual Fund, a separate Bid can be made in respect
of each scheme of the Mutual Fund registered with SEBI and such Bids in respect of more than one scheme of the
Mutual Fund will not be treated as multiple Bids provided that the Bids clearly indicate the scheme concerned for
which the Bid has been made.
No Mutual Fund scheme shall invest more than 10% of its NAV in equity shares or equity related instruments of
any single company provided that the limit of 10% shall not be applicable for investments in case of index funds
or sector or industry specific schemes. No Mutual Fund under all its schemes should own more than 10% of any
company’s paid-up share capital carrying voting rights.
651Bids by Eligible NRIs
Eligible NRIs may obtain copies of Bid cum Application Form from the Designated Intermediaries. Only Bids
accompanied by payment in Indian Rupees or freely convertible foreign exchange will be considered for
Allotment. Eligible NRIs bidding on a repatriation basis by using the Non-Resident forms should authorise their
SCSB to block their Non-Resident External (“NRE”) accounts (including UPI ID, if activated), or Foreign
Currency Non- Resident (“FCNR”) accounts, and Eligible NRI Bidders bidding on a non-repatriation basis by
using Resident Forms should authorize their respective SCSB to block their Non-Resident Ordinary (“NRO”)
accounts or accept the UPI mandate request (in case of UPI Bidders using the UPI Mechanism) for the full Bid
Amount, at the time of the submission of the Bid cum Application Form. NRIs applying in the Issue through the
UPI Mechanism are advised to enquire with the relevant bank, whether their account is UPI linked, prior to
submitting a Bid cum Application Form. Participation of Eligible NRIs in the Issue shall be subject to the FEMA
Rules.
In accordance with the FEMA Rules, the total holding by any individual NRI, on a repatriation basis, shall not
exceed 5% of the total paid-up equity capital on a fully diluted basis and the total holdings of all NRIs and OCIs
put together shall not exceed 10% of the total paid-up equity capital on a fully diluted basis. Provided that the
aggregate ceiling of 10% may be raised to 24% if a special resolution to that effect is passed by the members of
the Indian company in a general meeting.
Eligible NRIs will be permitted to apply in the Issue through Channel I or Channel II (as specified in the UPI
Circular). Further, subject to applicable law, Eligible NRIs may use Channel IV (as specified in the UPI Circular)
to apply in the Issue, provided the UPI facility is enabled for their NRE/ NRO accounts.
Eligible NRIs Bidding on non-repatriation basis are advised to use the Bid cum Application Form for residents
([●] in colour).
For details of investment by NRIs, see “Restrictions on Foreign Ownership of Indian Securities” on page 665.
Participation of Eligible NRIs shall be subject to the FEMA Non-debt Rules.
Bids by Hindu Undivided Families (“HUFs”)
Bids by Hindu Undivided Families or HUFs should be made in the individual name of the Karta. The
Bidder/Applicant should specify that the Bid is being made in the name of the HUF in the Bid cum Application
Form/Application Form as follows: “Name of sole or first Bidder/Applicant: XYZ Hindu Undivided Family
applying through XYZ, where XYZ is the name of the Karta”. Bids/Applications by HUFs will be considered at
par with Bids/Applications from individuals.
Bids by Foreign Portfolio Investors (“FPIs”)
In terms of the SEBI FPI Regulations, the issue of Equity Shares to a single FPI or an investor group (which
means the same multiple entities having common ownership directly or indirectly of more than 50% or common
control) must be below 10% of our post- Issue Equity Share capital. Further, in terms of the FEMA Non-debt
Instruments Rules, with effect from April 1, 2020, the aggregate FPI investment limit is the sectoral cap applicable
to an Indian company as prescribed in the FEMA Non-debt Instruments Rules with respect to its paid-up equity
capital on a fully diluted basis. The foreign investment limits for insurance companies was increased from 49%
to 74% of their paid-up equity share capital. Further, it was announced in the Union Budget for Fiscal 2025-2026,
that the foreign investment limits in the insurance sector will be raised from 74% to 100%. The enhanced foreign
investment limit of 100% has not been implemented as of the date of this Draft Red Herring Prospectus.
FPIs are permitted to participate in the Issue subject to compliance with conditions and restrictions which may be
specified by the Government from time to time. In case of Bids made by FPIs, a certified copy of the certificate
of registration issued under the SEBI FPI Regulations is required to be attached to the Bid cum Application Form,
failing which our Company reserves the right to reject any Bid without assigning any reason. FPIs who wish to
participate in the Issue are advised to use the Bid cum Application Form for Non-Residents ([●] in colour).
To ensure compliance with the above requirement, SEBI, pursuant to its circular dated July 13, 2018, has directed
that at the time of finalisation of the Basis of Allotment, the Registrar shall (i) use the PAN issued by the Income
Tax Department of India for checking compliance for a single FPI; and (ii) obtain validation from Depositories
for the FPIs who have invested in the Issue to ensure there is no breach of the investment limit, within the timelines
In terms of the FEMA, for calculating the aggregate holding of FPIs in a company, holding of all registered FPIs
shall be included.
The FEMA NDI Rules were enacted on October 17, 2019 in supersession of the Foreign Exchange Management
(Transfer or Issue of Security by a Person Resident Outside India) Regulations, 2017, except as respects things
652done or omitted to be done before such supersession. FPIs are permitted to participate in the Issue subject to
compliance with conditions and restrictions which may be specified by the Government from time to time.
Subject to compliance with all applicable Indian laws, rules, regulations, guidelines and approvals in terms of
Regulation 21 of the SEBI FPI Regulations, an FPI, may issue, subscribe to or otherwise deal in offshore derivative
instruments(as defined under the SEBI FPI Regulations as any instrument, by whatever name called, which is
issued overseas by a FPI against securities held by it in India, as its underlying) directly or indirectly, only in the
event (i) such offshore derivative instruments are issued only by persons registered as Category I FPIs; (ii) such
offshore derivative instruments are issued only to persons eligible for registration as Category I FPIs; (iii) such
offshore derivative instruments are issued after compliance with ‘know your client’ norms; and (iv) such other
conditions as may be specified by SEBI from time to time
An FPI issuing offshore derivate instruments is also required to ensure that any transfer of offshore derivative
instruments issued by, or on behalf of it subject to, inter alia, the following conditions:
(i) such offshore derivative instruments are transferred to persons subject to fulfilment of SEBI FPI
Regulations; and
(ii) prior consent of the FPI is obtained for such transfer, except when the persons to whom the offshore
derivative instruments are to be transferred are pre-approved by the FPI.
Bids by FPIs which utilise the multi-investment manager structure in accordance with the SEBI master circular
bearing reference number SEBI/HO/AFD-2/CIR/P/2022/175 dated December 19, 2022, submitted with the same
PAN but with different beneficiary account numbers, Client IDs and DP IDs shall not be treated as multiple Bids
(“MIM Bids”). FPIs bearing the same PAN may be treated as multiple Bids by a Bidder and may be rejected,
except for Bids from FPIs that utilise the multi investment manager structure in accordance with the Operational
FPI Guidelines (such structure referred to as “MIM Structure”). In order to ensure valid Bids, FPIs making MIM
Bids using the same PAN and with different beneficiary account numbers, Client IDs and DP IDs, are required to
submit a confirmation that their Bids are under the MIM Structure and indicate the name of their investment
managers in such confirmation which shall be submitted along with each of their Bid cum Application Forms. In
the absence of such confirmation from the relevant FPIs, such MIM Bids shall be rejected.
Further, in the following cases, the bids by FPIs will not be considered as multiple Bids: involving (i) the MIM
Structure and indicating the name of their respective investment managers in such confirmation; (ii) offshore
derivative instruments (“ODI”) which have obtained separate FPI registration for ODI and proprietary derivative
investments; (iii) sub funds or separate class of investors with segregated portfolio who obtain separate FPI
registration; (iv) FPI registrations granted at investment strategy level/sub fund level where a collective investment
scheme or fund has multiple investment strategies/sub-funds with identifiable differences and managed by a single
investment manager; (v) multiple branches in different jurisdictions of foreign bank registered as FPIs; (vi)
Government and Government related investors registered as Category 1 FPIs; and (vii) Entities registered as
Collective Investment Scheme having multiple share classes.
Please note that in terms of the General Information Document, the maximum Bid by any Bidder including QIB
Bidder should not exceed the investment limits prescribed for them under applicable laws. Further, MIM Bids by
an FPI Bidder utilising the MIM Structure shall be aggregated for determining the permissible maximum Bid.
Further, please note that as disclosed in this Draft Red Herring Prospectus read with the General Information
Document, Bid Cum Application Forms are liable to be rejected in the event that the Bid in the Bid cum
Application Form exceeds the Issue size and/or investment limit or maximum number of the Equity Shares that
can be held under applicable laws or regulations or maximum amount permissible under applicable laws or
regulations, or under the terms of the Red Herring Prospectus.
For example, an FPI must ensure that any Bid by a single FPI and/ or an investor group (which means the same
multiple entities having common ownership directly or indirectly of more than 50% or common control)
(collective, the “FPI Group”) shall be below 10% of the total paid-up Equity Share capital of our Company on a
fully diluted basis. Any Bids by FPIs and/ or the FPI Group (including but not limited to (a) FPIs Bidding through
the MIM Structure; or (b) FPIs with separate registrations for offshore derivative instruments and proprietary
derivative instruments) for 10% or more of our total paid-up post Issue Equity Share capital shall be liable to be
rejected.
Bids by SEBI registered VCFs, AIFs and FVCIs
The SEBI FVCI Regulations and the SEBI AIF Regulations, inter-alia, prescribe the respective investment
restrictions on the FVCIs, VCFs and AIFs registered with SEBI.
Accordingly, the holding in any company by any individual VCF or FVCIs (under Schedule I of the FEMA Non-
Debt Rules) registered with SEBI in one venture capital undertaking should not exceed 25% of the corpus of the
653VCF or FVCI. Further, VCFs and FVCIs can invest only up to 33.33% of the investible funds in various prescribed
instruments, including in public issue.
Category I and II AIFs cannot invest more than 25% of the investible funds in one investee company. A Category
III AIF cannot invest more than 10% of the investible funds in one investee company. A VCF registered as a
Category I AIF, as defined in the SEBI AIF Regulations, cannot invest more than one-third of its investible funds
by way of subscription to an initial public offering of a venture capital undertaking whose shares are proposed to
be listed. Additionally, post the repeal of the Securities and Exchange Board of India (Venture Capital Funds)
Regulations, 1996 (“SEBI VCF Regulations”), the VCFs which have not re-registered as an AIF under the SEBI
AIF Regulations shall continue to be regulated by the SEBI VCF Regulations until the existing fund or scheme
managed by the fund is wound up and such funds shall not launch any new scheme after the notification of the
SEBI AIF Regulations.
Further, the shareholding of VCFs, category I AIFs or category II AIFs and FVCIs holding equity shares of a
company prior to an initial public offering being undertaken by such company, shall be exempt from lock-in
requirements, provided that such equity shares shall be locked in for a period of at least one year from the date of
purchase by the venture capital fund or alternative investment fund or foreign venture capital investor.
There is no reservation for Eligible NRI Bidders, AIFs and FPIs. All Bidders will be treated on the same
basis with other categories for the purpose of allocation.
All non-resident investors should note that refunds (in case of Anchor Investors), dividends and other
distributions, if any, will be payable in Indian Rupees only and net of bank charges and commission.
Our Company or the BRLM will not be responsible for loss, if any, incurred by the Bidder on account of
conversion of foreign currency.
Bids by limited liability partnerships
In case of Bids made by limited liability partnerships registered under the Limited Liability Partnership Act, 2008,
a certified copy of certificate of registration issued under the Limited Liability Partnership Act, 2008, must be
attached to the Bid cum Application Form. Failing this, our Company in consultation with the BRLM reserves the
right to reject any Bid without assigning any reason thereof.
Bids by banking companies
In case of Bids made by banking companies registered with RBI, certified copies of: (i) the certificate of
registration issued by RBI, and (ii) the approval of such banking company’s investment committee are required
to be attached to the Bid cum Application Form, failing which our Company in consultation with the BRLM
reserve the right to reject any Bid without assigning any reason.
The investment limit for banking companies in non-financial services companies as per the Banking Regulation
Act, 1949, as amended, (the “Banking Regulation Act”), and the Master Directions – RBI (Financial Services
provided by Banks) Directions, 2016, as amended, is 10% of the paid-up share capital of the investee company,
not being its subsidiary engaged in non-financial services, or 10% of the bank’s own paid-up share capital and
reserves, whichever is lower. Further, the aggregate investment by a banking company in subsidiaries and other
entities engaged in financial services company cannot exceed 20% of the investee company’s paid up share capital
and reserves. However, a banking company would be permitted to invest in excess of 10% but not exceeding 30%
of the paid-up share capital of such investee company if (i) the investee company is engaged in non-financial
activities permitted for banks in terms of Section 6(1) of the Banking Regulation Act, or (ii) the additional
acquisition is through restructuring of debt/corporate debt restructuring/strategic debt restructuring, or to protect
the bank’s interest on investment made to a company. The bank is required to submit a time-bound action plan
for disposal of such shares within a specified period to the RBI. A banking company would require a prior approval
of the RBI to make (i) investment in excess of 30% of the paid-up share capital of the investee company, (ii)
investment in a subsidiary and a financial services company that is not a subsidiary (with certain exceptions
prescribed), and (iii) investment in a non-financial services company in excess of 10% of such investee company’s
paid-up share capital as stated in 5(a)(v)(c)(i) of the RBI (Financial Services provided by Banks) Directions, 2016,
as amended.
Bids by SCSBs
SCSBs participating in the Issue are required to comply with the terms of the SEBI ICDR Master Circular. Such
SCSBs are required to ensure that for making applications on their own account using ASBA, they should have a
separate account in their own name with any other SEBI registered SCSBs. Further, such account shall be used
solely for the purpose of making application in public issues and clear demarcated funds should be available in
such account for such applications.
654Bids by insurance companies
In case of Bids made by insurance companies registered with the IRDAI, a certified copy of certificate of
registration issued by IRDAI must be attached to the Bid cum Application Form. Failing this, our Company in
consultation with the BRLM reserve the right to reject any Bid without assigning any reason thereof.
The exposure norms for insurers, prescribed under the Insurance Regulatory and Development Authority of India
(Investment) Regulations, 2016, as amended, are broadly set forth below:
a) equity shares of a company: the lower of 10%* of the outstanding equity shares (face value) or 10% of the
respective fund in case of life insurer or 10% of investment assets in case of general insurer or reinsurer or
health insurer;
b) the entire group of the investee company: not more than 15% of the respective fund in case of a life insurer
or 15% of investment assets in case of a general insurer or reinsurer or health insurer or 15% of the
investment assets in all companies belonging to the group, whichever is lower; and
c) the industry sector in which the investee company operates: not more than 15% of the fund of a life insurer
or a general insurer or a reinsurer or health insurer or 15% of the investment asset, whichever is lower.
The maximum exposure limit, in the case of an investment in equity shares, cannot exceed the lower of an amount
of 10% of the investment assets of a life insurer or general insurer and the amount calculated under (a), (b) and
(c) above, as the case may be.
*The above limit of 10% shall stand substituted as 15% of outstanding equity shares (face value) for insurance
companies with investment assets of ₹ 2,50,000 crore or more or the above limit of 10% shall stand substituted
as 12% of outstanding equity shares (face value) for insurers with investment assets of ₹50,000 crore or more but
less than ₹ 2,50,000 crore.
Insurance companies participating in this Issue shall comply with all applicable regulations, guidelines and
circulars issued by IRDAI from time to time.
Bids by provident funds/pension funds
In case of Bids made by provident funds/pension funds, subject to applicable laws, with minimum corpus of ₹
2500.00 lakhs registered with the Pension Fund Regulatory and Development Authority established under Section
3(1) of the Pension Fund Regulatory and Development Authority Act, 2013, subject to applicable law, a certified
copy of a certificate from a chartered accountant certifying the corpus of the provident fund/pension fund must be
attached to the Bid cum Application Form. Failing this, our Company in consultation with the BRLM reserves the
right to reject any Bid, without assigning any reason thereof.
Bids under Power of Attorney
In case of Bids made pursuant to a power of attorney or by limited companies, corporate bodies, registered
societies, Eligible FPIs, Mutual Funds, insurance companies, insurance funds set up by the army, navy or air force
of the India, insurance funds set up by the Department of Posts, India or the National Investment Fund and
provident funds with a minimum corpus of ₹2500.00 lakhs (subject to applicable law) and pension funds with a
minimum corpus of ₹2500.00 lakhs, a certified copy of the power of attorney or the relevant resolution or
authority, as the case may be, along with a certified copy of the memorandum of association and articles of
association and/or bye laws must be lodged along with the Bid cum Application Form. Failing this, our Company
in consultation with the BRLM reserve the right to accept or reject any Bid in whole or in part, in either case,
without assigning any reason thereof.
Our Company in consultation with the BRLM in their absolute discretion, reserve the right to relax the above
condition of simultaneous lodging of the power of attorney along with the Bid cum Application Form subject to
the terms and conditions that our Company in consultation with the BRLM may deem fit.
Bids by Systemically Important Non-Banking Financial Companies
In case of Bids made by Systemically Important NBFCs registered with RBI, certified copies of: (i) the certificate
of registration issued by RBI, (ii) certified copy of its last audited financial statements on a standalone basis and
a net worth certificate from its statutory auditors, and (iii) such other approval as may be required by the
Systemically Important NBFCs, are required to be attached to the Bid cum Application Form. Failing this, our
Company in consultation with the BRLM, reserves the right to reject any Bid without assigning any reason thereof.
Systemically Important NBFCs participating in the Issue shall comply with all applicable regulations, guidelines
and circulars issued by RBI from time to time.
The investment limit for Systemically Important NBFCs shall be as prescribed by RBI from time to time.
655Bids by Anchor Investors
In accordance with the SEBI ICDR Regulations, in addition to details and conditions mentioned in this section,
the key terms for participation by Anchor Investors are provided below.
1) Anchor Investor Application Forms will be made available for the Anchor Investor Portion at the offices of
the Book Running Lead Manager.
2) The Bid must be for a minimum of such number of Equity Shares so that the Bid Amount exceeds ₹1000.00
lakhs. A Bid cannot be submitted for over 60% of the QIB Portion. In case of a Mutual Fund, separate Bids
by individual schemes of a Mutual Fund will be aggregated to determine the minimum application size of
₹1000.00 lakhs.
3) One-third of the Anchor Investor Portion will be reserved for allocation to domestic Mutual Funds subject to
valid Bids being received from domestic Mutual Funds at or above Anchor Investor Allocation Price.
4) Bidding for Anchor Investors will open one Working Day before the Bid/ Issue Opening Date and will be
completed on the same day.
5) Our Company in consultation with the Book Running Lead Manager will finalize allocation to the Anchor
Investors on a discretionary basis, provided that the minimum number of Allottees in the Anchor Investor
Portion will not be less than: (a) maximum of two Anchor Investors, where allocation under the Anchor
Investor Portion is up to ₹1000.00 lakhs; (b) minimum of two and maximum of 15 Anchor Investors, where
the allocation under the Anchor Investor Portion is more than ₹1000.00 lakhs but up to ₹ 25,000.00 lakhs,
subject to a minimum Allotment of ₹500.00 lakhs per Anchor Investor; and (c) in case of allocation above
₹25,000 lakhs under the Anchor Investor Portion, a minimum of five such investors and a maximum of 15
Anchor Investors for allocation up to ₹25,000 lakhs, and an additional 10 Anchor Investors for every additional
₹25,000 lakhs, subject to minimum Allotment of ₹500.00 lakhs per Anchor Investor.
6) Allocation to Anchor Investors will be completed on the Anchor Investor Bidding Date. The number of Equity
Shares allocated to Anchor Investors and the price at which the allocation is made, will be made available in
the public domain by the Book Running Lead Manager before the Bid/ Issue Opening Date, through intimation
to the Stock Exchanges.
7) Anchor Investors cannot withdraw or lower the size of their Bids at any stage after submission of the Bid.
8) If the Issue Price is greater than the Anchor Investor Allocation Price, the additional amount being the
difference between the Issue Price and the Anchor Investor Allocation Price will be payable by the Anchor
Investors on the Anchor Investor Pay-in Date specified in the CAN. If the Issue Price is lower than the Anchor
Investor Allocation Price, Allotment to successful Anchor Investors will be at the higher price, i.e., the Anchor
Investor Issue Price.
9) 50% of the Equity Shares Allotted to Anchor Investors in the Anchor Investor Portion shall be locked in for a
period of 90 days from the date of Allotment and the remaining 50% of the Equity Shares Allotted to Anchor
Investors will be locked in for a period of 30 days from the date of Allotment.
10) Neither the Book Running Lead Manager or any associate of the Book Running Lead Manager (other than
Mutual Funds sponsored by entities which are associates of the BRLM or AIFs sponsored by entities which
are associates of the BRLM or FPIs (other than individuals, corporate bodies and family offices) which are
associates of the BRLM or insurance companies promoted by entities which are associates of the BRLM or
pension funds sponsored by entities which are associates of the BRLM) shall apply in the Issue under the
Anchor Investors Portion. For details, see “Issue Procedure” on page 647. Further, no person related to the
Promoters or Promoter Group shall apply under the Anchor Investors category.
11) Bids made by QIBs under both the Anchor Investor Portion and the QIB Portion will not be considered
multiple Bids.
If the aggregate demand in this portion is greater than [●] Equity Shares of face value of ₹ 10 each at or above the
Issue Price, the allocation shall be made on a proportionate basis. For the method of proportionate basis of
Allotment, see “Issue Procedure” on page 647.
For the method of proportionate basis of Allotment, see “Issue Procedure” beginning on page 647.
In accordance with existing regulations issued by the RBI, OCBs cannot participate in this Issue.
The above information is given for the benefit of the Bidders. Our Company and the BRLM are not liable
for any amendments or modification or changes in applicable laws or regulations, which may occur after
the date of this Draft Red Herring Prospectus. Bidders are advised to make their independent investigations
656and ensure that any single Bid from them does not exceed the applicable investment limits or maximum
number of the Equity Shares that can be held by them under applicable law or regulation or as specified
in the Draft Red Herring Prospectus, Red Herring Prospectus and the Prospectus.
Information for Bidders
The relevant Designated Intermediary will enter a maximum of three Bids at different price levels opted in the
Bid cum Application Form and such options are not considered as multiple Bids. It is the Bidder’s responsibility
to obtain the acknowledgment slip from the relevant Designated Intermediary. The registration of the Bid by the
Designated Intermediary does not guarantee that the Equity Shares shall be allocated/Allotted. Such
Acknowledgement Slip will be non-negotiable and by itself will not create any obligation of any kind. When a
Bidder revises his or her Bid, he /she shall surrender the earlier Acknowledgement Slip and may request for a
revised acknowledgment slip from the relevant Designated Intermediary as proof of his or her having revised the
previous Bid.
In relation to electronic registration of Bids, the permission given by the Stock Exchanges to use their network
and software of the electronic bidding system should not in any way be deemed or construed to mean that the
compliance with various statutory and other requirements by our Company and/or the BRLM are cleared or
approved by the Stock Exchanges; nor does it in any manner warrant, certify or endorse the correctness or
completeness of compliance with the statutory and other requirements, nor does it take any responsibility for the
financial or other soundness of our Company, the management or any scheme or project of our Company; nor
does it in any manner warrant, certify or endorse the correctness or completeness of any of the contents of the
Draft Red Herring Prospectus or the Red Herring Prospectus; nor does it warrant that the Equity Shares will be
listed or will continue to be listed on the Stock Exchanges.
General Instructions
Do’s:
1. Check if you are eligible to apply as per the terms of the Red Herring Prospectus and under applicable law,
rules, regulations, guidelines and approvals. All Bidders (other than Anchor Investors) should submit their
Bids through the ASBA process only;
2. Ensure that you have Bid within the Price Band;
3. Do not Bid for a Bid Amount exceeding ₹2.00 lakhs (for Bids by RIIs);
4. Read all the instructions carefully and complete the Bid cum Application Form, as the case may be, in the
prescribed form;
5. Ensure that you (other than the Anchor Investors) have mentioned the correct details of ASBA Account (i.e.
bank account number or UPI ID, as applicable) in the Bid cum Application Form if you are not an UPI
Bidder bidding using the UPI Mechanism in the Bid cum Application Form and if you are an UPI Bidder
using the UPI Mechanism ensure that you have mentioned the correct UPI ID (with maximum length of 45
characters including the handle) in the Bid cum Application Form;
6. UPI Bidders using UPI Mechanism shall make Bids only through the SCSBs, mobile applications and UPI
handles shall ensure that the name of the bank appears in the list of SCSBs which are live on UPI, as
displayed on the SEBI website. UPI Bidders shall ensure that the name of the app and the UPI handle which
is used for making the application appears in Annexure ‘A’ to the SEBI circular no.
SEBI/HO/CFD/DIL2/COR/P/2019/85 dated July 26, 2019. An application made using incorrect UPI handle
or using a bank account of an SCSB or bank which is not mentioned on the SEBI website is liable to be
rejected;
7. Ensure that your Bid cum Application Form bearing the stamp of a Designated Intermediary is submitted to
the Designated Intermediary at the Bidding Centre (except in case of electronic Bids) within the prescribed
time. Bidders (other than Anchor Investors) shall submit the Bid cum Application Form in the manner set
out in the General Information Document;
8. Ensure that you have funds equal to the Bid Amount in the ASBA Account maintained with the SCSB,
before submitting the ASBA Form to any of the Designated Intermediaries;
9. If the first applicant is not the bank account holder, ensure that the Bid cum Application Form is signed by
the account holder. Ensure that you have mentioned the correct bank account number in the Bid cum
Application Form;
65710. Ensure that the signature of the first Bidder in case of joint Bids, is included in the Bid cum Application
Forms;
11. Ensure that you request for and receive a stamped acknowledgement counterfoil of the Bid cum Application
Form for all your Bid options from the concerned Designated Intermediary;
12. Ensure that the name(s) given in the Bid cum Application Form is/are exactly the same as the name(s) in
which the beneficiary account is held with the Depository Participant. In case of joint Bids, the Bid cum
Application Form should contain only the name of the first Bidder whose name should also appear as the
first holder of the beneficiary account held in joint names. Ensure that the signature of the First Bidder is
included in the Bid cum Application Forms;
13. UPI Bidders Bidding in the Issue to ensure that they shall use only their own ASBA Account or only their
own bank account linked UPI ID (only for UPI Bidders using the UPI Mechanism) to make an application
in the Issue and not ASBA Account or bank account linked UPI ID of any third party;
14. Ensure that you submit the revised Bids to the same Designated Intermediary, through whom the original
Bid was placed and obtain a revised acknowledgment;
15. Ensure that you have correctly signed the authorisation/undertaking box in the Bid cum Application Form,
or have otherwise provided an authorisation to the SCSB or Sponsor Bank, as applicable, via the electronic
mode, for blocking funds in the ASBA Account equivalent to the Bid Amount mentioned in the Bid cum
Application Form, as the case may be, at the time of submission of the Bid. In case of UPI Bidders submitting
their Bids and participating in the Issue through the UPI Mechanism, ensure that you authorise the UPI
Mandate Request raised by the Sponsor Bank for blocking of funds equivalent to Bid Amount and subsequent
debit of funds in case of Allotment;
16. Except for Bids (i) on behalf of the Central or State Governments and the officials appointed by the courts,
who, in terms of the SEBI circular no. MRD/DoP/Cir-20/2008 dated June 30, 2008, may be exempt from
specifying their PAN for transacting in the securities market, (ii) submitted by investors who are exempt
from the requirement of obtaining/specifying their PAN for transacting in the securities market, and (iii)
Bids by persons resident in the state of Sikkim, who, in terms of a SEBI circular dated July 20, 2006, may
be exempted from specifying their PAN for transacting in the securities market, all Bidders should mention
their PAN allotted under the IT Act. The exemption for the Central or the State Government and officials
appointed by the courts and for investors residing in the State of Sikkim is subject to (a) the Demographic
Details received from the respective depositories confirming the exemption granted to the beneficiary owner
by a suitable description in the PAN field and the beneficiary account remaining in “active status”; and (b)
in the case of residents of Sikkim, the address as per the Demographic Details evidencing the same. All other
applications in which PAN is not mentioned will be rejected;
17. Ensure that the Demographic Details are updated, true and correct in all respects;
18. Ensure that thumb impressions and signatures other than in the languages specified in the Eighth Schedule
to the Constitution of India are attested by a Magistrate or a Notary Public or a Special Executive Magistrate
under official seal;
19. Ensure that the category and the investor status is indicated in the Bid cum Application Form;
20. Ensure that in case of Bids under power of attorney or by limited companies, corporates, trust, etc., relevant
documents are submitted;
21. Ensure that Bids submitted by any person resident outside India is in compliance with applicable foreign and
Indian laws;
22. Since the Allotment will be in demat form only, ensure that the Bidder’s depository account is active, the
correct DP ID, Client ID, the PAN, UPI ID, if applicable, are mentioned in their Bid cum Application Form
and that the name of the Bidder, the DP ID, Client ID, the PAN and UPI ID, if applicable, entered into the
online IPO system of the Stock Exchanges by the relevant Designated Intermediary, as applicable, matches
with the name, DP ID, Client ID, PAN and UPI ID, if applicable, available in the Depository database;
23. Do not withdraw your Bid or lower the size of your Bid (in terms of quantity of the Equity Shares or the Bid
Amount) at any stage, if you are a QIB or a Non-Institutional Investor. Retail Individual Investors can revise
or withdraw their Bids until the Bid/Issue Closing Date;
24. RIBs who wish to revise their Bids using the UPI Mechanism, should submit the revised Bid with the
Designated Intermediaries, pursuant to which RIBs should ensure acceptance of the UPI Mandate Request
658received from the Sponsor Bank to authorise blocking of funds equivalent to the revised Bid Amount in the
RIB’s ASBA Account;
25. In case of QIBs and NII bidders, ensure that while Bidding through a Designated Intermediary, the ASBA
Form is submitted to a Designated Intermediary in a Bidding Centre and that the SCSB where the ASBA
Account, as specified in the ASBA Form, is maintained has named at least one branch at that location for
the Designated Intermediary to deposit ASBA Forms (a list of such branches is available on the website of
SEBI at http://www.sebi.gov.in);
26. Ensure that you have accepted the UPI Mandate Request received from the Sponsor Bank prior to 5:00 p.m.
of the Bid/ Issue Closing Date;
27. FPIs making MIM Bids using the same PAN, and different beneficiary account numbers, Client IDs and DP
IDs, are required to submit a confirmation that their Bids are under the MIM structure and indicate the name
of their investment manager in such confirmation which shall be submitted along with each of their Bid cum
Application Forms. In the absence of such confirmation from the relevant FPIs, such MIM Bids shall be
rejected;
28. UPI Bidders shall ensure that details of the Bid are reviewed and verified by opening the attachment in the
UPI Mandate Request and then proceed to authorize the UPI Mandate Request using his/her UPI PIN. Upon
the authorization of the mandate using his/her UPI PIN, an UPI Bidder may be deemed to have verified the
attachment containing the application details of the UPI Bidder in the UPI Mandate Request and have agreed
to block the entire Bid Amount and authorized the Sponsor Bank to block the Bid Amount mentioned in the
Bid Cum Application Form; and
29. Ensure that Anchor Investors submit their Bid cum Application Forms only to the BRLM.
30. Bids by Eligible NRIs for a Bid Amount of less than ₹2.00 lakhs would be considered under the Retail
Category for the purposes of allocation and Bids for a Bid Amount exceeding ₹2.00 lakhs would be
considered under the Non- Institutional Category for allocation in the Issue.
31. The ASBA bidders shall ensure that bids above ₹ 5,00,000 are uploaded only by the SCSBs.
32. Investors must ensure that their PAN is linked with Aadhaar and are in compliance with CBDT notification
dated February 13, 2020 and press release dated June 25, 2021, September 17, 2021, March 30, 2022 and
March 28, 2023.
The Bid cum Application Form is liable to be rejected if the above instructions, as applicable, are not
complied with. Application made using incorrect UPI handle or using a bank account of an SCSB or SCSBs
which is not mentioned in the Annexure ‘A’ to the SEBI circular no. SEBI/HO/CFD/DIL2/CIR/P/2019/85
dated July 26, 2019 is liable to be rejected.
Don’ts:
1. Do not Bid for lower than the minimum Bid size;
2. Do not Bid/revise Bid Amount to less than the Floor Price or higher than the Cap Price;
3. Do not Bid for a Bid Amount exceeding ₹2.00 lakhs (for Bids by Retail Individual Bidders);
4. Do not pay the Bid Amount in cheques, demand drafts or by cash, money order, postal order or by stock
invest;
5. Do not send Bid cum Application Forms by post; instead submit the same to the Designated Intermediary
only;
6. Do not Bid at Cut-off Price (for Bids by QIBs and Non-Institutional Bidders);
7. Do not instruct your respective banks to release the funds blocked in the ASBA Account under the ASBA
process;
8. Do not submit the Bid for an amount more than funds available in your ASBA account.
9. Do not submit Bids on plain paper or on incomplete or illegible Bid cum Application Forms or on Bid cum
Application Forms in a colour prescribed for another category of a Bidder;
10. In case of ASBA Bidders, do not submit more than one ASBA Forms per ASBA Account;
11. If you are a UPI Bidders and are using UPI mechanism, do not submit more than one ASBA Form for each
UPI ID;
65912. Anchor Investors should not Bid through the ASBA process;
13. Do not submit the ASBA Forms to any Designated Intermediary that is not authorised to collect the relevant
ASBA Forms or to our Company;
14. Do not Bid on a Bid cum Application Form that does not have the stamp of the relevant Designated
Intermediary;
15. Do not submit the General Index Register (GIR) number instead of the PAN;
16. Do not submit incorrect details of the DP ID, Client ID, PAN and UPI ID, if applicable, or provide details
for a beneficiary account which is suspended or for which details cannot be verified by the Registrar to the
Issue;
17. Do not submit a Bid in case you are not eligible to acquire Equity Shares under applicable law or your
relevant constitutional documents or otherwise;
18. Do not Bid if you are not competent to contract under the Indian Contract Act, 1872 (other than minors
having valid depository accounts as per Demographic Details provided by the depository);
19. Do not submit a Bid using UPI ID, if you are not a RIB;
20. Do not Bid on another ASBA Form or the Anchor Investor Application Form, as the case may be, after you
have submitted a Bid to any of the Designated Intermediaries;
21. Do not Bid for Equity Shares in excess of what is specified for each category;
22. Do not fill up the Bid cum Application Form such that the Equity Shares Bid for, exceeds the Issue size
and/or investment limit or maximum number of the Equity Shares that can be held under applicable laws or
regulations or maximum amount permissible under applicable laws or regulations, or under the terms of the
Red Herring Prospectus;
23. Do not withdraw your Bid or lower the size of your Bid (in terms of quantity of the Equity Shares or the Bid
Amount) at any stage, if you are a QIB or a Non-Institutional Bidder. Retail Individual Bidders can revise
or withdraw their Bids on or before the Bid/Issue Closing Date;
24. Do not submit Bids to a Designated Intermediary at a location other than the Bidding Centers;
25. If you are an RIB which is submitting the ASBA Form with any of the Designated Intermediaries and using
your UPI ID for the purpose of blocking of funds, do not use any third party bank account or third party
linked bank account UPI ID;
26. Do not link the UPI ID with a bank account maintained with a bank that is not UPI 2.0 certified by the NPCI
in case of Bids submitted by RIBs using the UPI Mechanism;
27. If you are a QIB, do not submit your Bid after 12:00 p.m. on the Bid/ Issue Closing Date (for Physical
Applications) and after 3 p.m. on the QIB Bid / Issue Closing Date (for online applications);
28. UPI Bidders Bidding through the UPI Mechanism using the incorrect UPI handle or using a bank account of
an SCSB or bank which is not mentioned in the list provided on the SEBI website is liable to be rejected;
and
29. Do not Bid if you are an OCB.
The Bid cum Application Form is liable to be rejected if the above instructions, as applicable, are not
complied with.
Further, in case of any pre - Issue or post – Issue related issues regarding share certificates/demat credit/refund
orders/unblocking etc., investors shall reach out to the Company Secretary and Compliance Officer. For details
of the Company Secretary and Compliance Officer, see “General Information” on page 96.
For helpline details of the Book Running Lead Manager pursuant to the SEBI ICDR Master Circular, see “General
Information” on page 96
Grounds for Technical Rejection
In addition to the grounds for rejection of Bids on technical grounds as provided in the GID, Bidders were
requested to note that Bids could be rejected on the following additional technical grounds:
1. Bids submitted without instruction to the SCSBs to block the entire Bid Amount;
6602. Bids which do not contain details of the Bid Amount and the bank account details in the ASBA Form;
3. Bids submitted on a plain paper;
4. Bids submitted by UPI Bidders using the UPI Mechanism through an SCSBs and/or using a mobile
application or UPI handle, not listed on the website of SEBI;
5. Bids under the UPI Mechanism submitted by UPI Bidders using third party bank accounts or using a third
party linked bank account UPI ID (subject to availability of information regarding third party account from
Sponsor Bank);
6. ASBA Form submitted to a Designated Intermediary does not bear the stamp of the Designated Intermediary;
7. Bids submitted without the signature of the first Bidder or sole Bidder;
8. The ASBA Form not being signed by the account holders, if the account holder is different from the Bidder;
9. ASBA Form by the RIBs by using third party bank accounts or using third party linked bank account UPI
IDs;
10. Bids by persons for whom PAN details have not been verified and whose beneficiary accounts are
“suspended for credit” in terms of SEBI circular CIR/MRD/DP/ 22 /2010 dated July 29, 2010;
11. GIR number furnished instead of PAN;
12. Bids by RIBs with Bid Amount of a value of more than ₹2.00 lakhs;
13. Bids by persons who are not eligible to acquire Equity Shares in terms of all applicable laws, rules,
regulations, guidelines and approvals;
14. Bids accompanied by stock invest, money order, postal order or cash; and
15. Bids uploaded by QIBs after 4.00 pm on the QIB Bid/ Issue Closing Date and by Non-Institutional Bidders
uploaded after 4.00 p.m. on the Bid/ Issue Closing Date, and Bids by RIBs uploaded after 5.00 p.m. on the
Bid/ Issue Closing Date, unless extended by the Stock Exchanges.
Further, in case of any pre-Issue or post Issue related issues regarding share certificates/demat credit/refund
orders/unblocking etc., investors shall reach out to the Company Secretary and Compliance Officer. For details
of our Company Secretary and Compliance Officer, see “General Information” on page 647.
Further, Bidders shall be entitled to compensation in the manner specified in the SEBI ICDR Master Circular and
the SEBI RTA Master Circular, as applicable to the RTAs in case of delays in resolving investor grievances in
relation to blocking/unblocking of funds.
Names of entities responsible for finalising the basis of allotment in a fair and proper manner
The authorised employees of the Designated Stock Exchange, along with the BRLM and the Registrar, shall
ensure that the Basis of Allotment is finalised in a fair and proper manner in accordance with the procedure
specified in SEBI ICDR Regulations.
Method of allotment as may be prescribed by SEBI from time to time
Our Company will not make any allotment in excess of the Equity Shares through the Red Herring Prospectus
and the Prospectus except in case of oversubscription for the purpose of rounding off to make allotment, in
consultation with the Designated Stock Exchange. Further, upon oversubscription, an allotment of not more than
one per cent of the Issue may be made for the purpose of making allotment in minimum lots.
The allotment of Equity Shares to applicants other than to the Retail Individual Bidders, Non Institutional Bidders
and Anchor Investors shall be on a proportionate basis within the respective investor categories and the number
of securities allotted shall be rounded off to the nearest integer, subject to minimum allotment being equal to the
minimum application size as determined and disclosed.
The allotment of Equity Shares to Retail Individual Bidders shall not be less than the minimum bid lot, subject to
the availability of shares in Retail Individual Bidders Portion, and the remaining available shares, if any, shall be
allotted on a proportionate basis. Not less than 15% of the Issue shall be available for allocation to Non-
Institutional Bidders. The Equity Shares available for allocation to Non-Institutional Bidders under the Non-
Institutional Portion, shall be subject to the following: (i) one-third of the portion available to Non-Institutional
Bidders shall be reserved for applicants with an application size of more than ₹ 2.00 lakhs and up to ₹10.00 lakhs,
and (ii) two-third of the portion available to Non-Institutional Bidders shall be reserved for applicants with an
application size of more than ₹10.00 lakhs , provided that the unsubscribed portion in either of the aforementioned
661sub-categories may be allocated to applicants in the other sub-category of Non-Institutional Bidders. The
allotment to Non-Institutional Bidder shall not be less than the minimum NII Application Size, subject to the
availability of Equity Shares in the Non-Institutional Portion, and the remaining Equity Shares.
Payment into Escrow Account(s) for Anchor Investors
Our Company, in consultation with the BRLM, in their absolute discretion, will decide the list of Anchor Investors
to whom the CAN will be sent, pursuant to which the details of the Equity Shares allocated to them in their
respective names will be notified to such Anchor Investors. For Anchor Investors, the payment instruments for
payment into the Escrow Account(s) should be drawn in favour of:
(a) In case of resident Anchor Investors: “[●]”
(b) In case of Non-Resident Anchor Investors: “[●]”
Anchor Investors should note that the escrow mechanism is not prescribed by SEBI and has been established as
an arrangement between our Company and the Syndicate, the Escrow Collection Bank and the Registrar to the
Issue to facilitate collections of Bid amounts from Anchor Investors.
Pre-Issue Advertisement
Subject to Section 30 of the Companies Act, 2013, our Company shall, after filing the Red Herring Prospectus
with the RoC, publish a pre- Issue advertisement, in the form prescribed by the SEBI ICDR Regulations, in: (i) ,
all editions of [●] (a widely circulated English national daily newspaper), [●] editions of [●] (a widely circulated
Hindi national daily newspaper) and [●] editions of [●] (a widely circulated Gujarati daily newspaper, Gujarati
being the regional language of Gujarat, where our Registered Office is located), each with wide circulation.
In the pre-Issue advertisement, we shall state the Bid/Issue Opening Date and the Bid/ Issue Closing Date. This
advertisement, subject to the provisions of Section 30 of the Companies Act, 2013, shall be in the format
prescribed in Part A of Schedule X of the SEBI ICDR Regulations.
The above information is given for the benefit of the Bidders/applicants. Our Company and the members of the
Syndicate are not liable for any amendments or modification or changes in applicable laws or regulations, which
may occur after the date of this Draft Red Herring Prospectus. Bidders/applicants are advised to make their
independent investigations and ensure that the number of Equity Shares Bid for do not exceed the prescribed
limits under applicable laws or regulations.
Signing of the Underwriting Agreement and the RoC Filing
a) Our Company and the Underwriters intend to enter into an Underwriting Agreement on or immediately after
the finalisation of the Issue Price but prior to the filing of Prospectus.
b) After signing the Underwriting Agreement, an updated Red Herring Prospectus will be filed with the RoC
in accordance with applicable law, which then would be termed as the ‘Prospectus’. The Prospectus will
contain details of the Issue Price, the Anchor Investor Issue Price, Issue size, and underwriting arrangements
and will be complete in all material respects.
Allotment Advertisement
Our Company, the Book Running Lead Manager and the Registrar shall publish an allotment advertisement before
commencement of trading, disclosing the date of commencement of trading in all editions of [●] an English
national daily newspaper, [●] and all editions of Hindi national daily newspaper and all editions of [●] Gujarati
regional daily newspaper (Gujarati being the regional language of Gujarat, where our Registered Office is located),
each with wide circulation.
The information set out above is given for the benefit of the Bidders. Our Company, and the Book Running
Lead Manager are not liable for any amendments or modification or changes in applicable laws or
regulations, which may occur after the date of this Draft Red Herring Prospectus. Bidders are advised to
make their independent investigations and ensure that the number of Equity Shares Bid for do not exceed
the prescribed limits under applicable laws or regulations.
Undertakings by our Company
Our Company undertakes the following:
• adequate arrangements shall be made to collect all Bid cum Application Forms submitted by Bidders and
Anchor Investor Application Form from Anchor Investors;
662• the complaints received in respect of the Issue shall be attended to by our Company expeditiously and
satisfactorily;
• all steps for completion of the necessary formalities for listing and commencement of trading at all the Stock
Exchanges where the Equity Shares are proposed to be listed shall be taken within three Working Days of
the Bid/Issue Closing Date or such other period as may be prescribed by the SEBI;
• if Allotment is not made within the prescribed time period under applicable law, the entire subscription
amount received will be refunded/unblocked within the time prescribed under applicable law. If there is
delay beyond the prescribed time, our Company shall pay interest prescribed under the Companies Act,
2013, the SEBI ICDR Regulations and applicable law for the delayed period;
• the funds required for making refunds to unsuccessful Bidders as per the mode(s) disclosed shall be made
available to the Registrar to the Issue by our Company;
• where refunds (to the extent applicable) are made through electronic transfer of funds, a suitable
communication shall be sent to the applicant within the time prescribed under applicable law, giving details
of the bank where refunds shall be credited along with amount and expected date of electronic credit of
refund;
• No further issue of the Equity Shares shall be made till the Equity Shares offered through the Red Herring
Prospectus are listed or until the Bid monies are unblocked in ASBA Account/refunded on account of non-
listing, under-subscription, etc
• Promoter’s contribution, if any, shall be brought in advance before the Bid/ Issue Opening Date and the
balance, if any, shall be brought in on a pro rata basis before calls are made on the Allottees.
• that if the Issue is withdrawn after the Bid/Issue Closing Date, our Company shall be required to file an Issue
Document with SEBI, in the event a decision is taken to proceed with the Issue subsequently.
• that our Company shall not have recourse to the Net Proceeds until the final approval for listing and trading
of the Equity Shares from all the Stock Exchanges where listing is sought has been received.
• It shall not issue any incentive, whether direct or indirect, in any manner, whether in cash or kind or services
or otherwise to the Bidder for making a Bid in the Issue, and shall not make any payment, direct or indirect,
in the nature of discounts, commission, allowance or otherwise to any person who makes a Bid in the Issue.
• No further issue of Equity Shares shall be made till the Equity Shares offered through the Red Herring
Prospectus are listed or until the Bid monies are unblocked in ASBA Account/refunded on account of non-
listing, under-subscription, etc.
The decisions with respect to the Price Band, the minimum Bid lot, revision of Price Band, and Issue Price, will
be taken by our Company in consultation with the BRLM, in accordance with applicable law.
Depository Arrangements
The Allotment of the Equity Shares in the Issue shall be only in a dematerialised form (i.e. not in the form of
physical certificates but be fungible and be represented by the statement issued through the electronic mode). In
this context, tripartite agreements had been signed among our Company, the respective Depositories and the
Registrar to the Issue:
• Tripartite Agreement dated August 17, 2017, among CDSL, our Company and the Registrar to the Issue
• Tripartite Agreement dated March 21, 2012, among NSDL, our Company and the Registrar to the Issue.
Impersonation
Attention of the applicants is specifically drawn to the provisions of sub-section (1) of Section 38 of the
Companies Act, which is reproduced below:
“Any person who—
a) makes or abets making of an application in a fictitious name to a company for acquiring, or subscribing for,
its securities; or
b) makes or abets making of multiple applications to a company in different names or in different combinations
of his name or surname for acquiring or subscribing for its securities; or
663c) otherwise induces directly or indirectly a company to allot, or register any transfer of, securities to him, or
to any other person in a fictitious name
d) shall be liable for action under Section 447.”
The liability prescribed under Section 447 of the Companies Act, for fraud involving an amount of at least ₹ 0.1
crore or 1% of the turnover of the company, whichever is lower, includes imprisonment for a term which shall
not be less than six-months extending up to 10 years and fine of an amount not less than the amount involved in
the fraud, extending up to three times such amount (provided that where the fraud involves public interest, such
term shall not be less than three years.) Further, where the fraud involves an amount less than ₹ 0.1 crore or one
per cent of the turnover of the company, whichever is lower, and does not involve public interest, any person
guilty of such fraud shall be punishable with imprisonment for a term which may extend to five years or with fine
which may extend to ₹0.5 crore or with both.
Utilisation of Issue Proceeds
• The Company specifically confirms and declares that all monies received out of the Issue shall be transferred
to a separate bank account other than the bank account referred to in sub-section 3 of Section 40 of the
Companies Act, 2013.
• Details of all monies utilized shall be disclosed and continue to be disclosed till the time any part of the issue
proceeds remains unutilised, under an appropriate head in the balance sheet of our Company indicating the
purpose for which such monies have been utilised; and
• Details of all unutilized monies, if any shall be disclosed under an appropriate separate head in the balance
sheet indicating the form in which such unutilized monies have been invested.
664RESTRICTIONS ON FOREIGN OWNERSHIP OF INDIAN SECURITIES
Foreign investment in Indian securities is regulated through the Industrial Policy, 1991 of the Government of India
and FEMA. While the Industrial Policy, 1991 prescribes the limits and the conditions subject to which foreign
investment can be made in different sectors of the Indian economy, FEMA regulates the precise manner in which
such investment may be made. Under the Industrial Policy, unless specifically restricted, foreign investment is
freely permitted in all sectors of the Indian economy up to any extent and without any prior approvals, but the
foreign investor is required to follow certain prescribed procedures for making such investment. The RBI and the
concerned ministries/departments are responsible for granting approval for foreign investment. The Government
has from time to time made policy pronouncements on foreign direct investment (“FDI”) through press notes and
press releases. The Department for Promotion of Industry and Internal Trade, Ministry of Commerce and Industry,
Government of India (earlier known as the Department of Industrial Policy and Promotion) (“DPIIT”), issued the
FDI Policy Circular of 2020 (“FDI Policy”) by way of circular bearing number DPIIT file number 5(2)/2020-FDI
Policy, which, with effect from October 15, 2020 consolidated, subsumed and superseded all previous press notes,
press releases and clarifications on FDI issued by the DPIIT that were in force and effect prior to October 15,
2020. FDI in companies engaged in sectors/ activities which are not listed in the FDI Policy is permitted up to
100% of the paid-up share capital of such company under the automatic route, subject to compliance with certain
prescribed conditions. The FDI Policy will be valid and remain in force until superseded in totality or in part
thereof.
In terms of Press Note 3 of 2020, dated April 17, 2020 (Press Note), issued by the DPIIT, the Consolidated FDI
Policy and the FEMA Non-Debt Instruments Rules has been amended to state that all investments under the
foreign direct investment route by entities of a country which shares land border with India or where the beneficial
owner of an investment into India is situated in or is a citizen of any such country will require prior approval of
the Government of India. Further, in the event of transfer of ownership of any existing or future foreign direct
investment in an entity in India, directly or indirectly, resulting in the beneficial ownership falling within the
aforesaid restriction/ purview, such subsequent change in the beneficial ownership will also require approval of
the Government of India. Pursuant to the Foreign Exchange Management (Non-debt Instruments) (Fourth
Amendment) Rules, 2020, a multilateral bank or fund, of which India is a member, shall not be treated as an entity
of a particular country nor shall any country be treated as the beneficial owner of the investments of such bank of
fund in India. Each Bidder should seek independent legal advice about its ability to participate in the Issue. In the
event such prior approval of the Government of India is required, and such approval has been obtained, the Bidder
shall intimate our Company and the Registrar to the Issue in writing about such approval along with a copy thereof
within the Issue Period
Transfer of shares between an Indian resident and a non-resident does not require the prior approval of the RBI,
provided that (i) the activities of the investee company are under the automatic route under the Consolidated FDI
Policy and transfer does not attract the provisions of the SEBI Takeover Regulations; (ii) the non-resident
shareholding is within the sectoral limits under the Consolidated FDI Policy; and (iii) the pricing is in accordance
with the guidelines prescribed by the SEBI/RBI.
For details of the aggregate limit for investments by NRIs and FPIs in our Company, see “Issue Procedure - Bids
by Eligible NRIs” and “Issue Procedure - Bids by FPIs” on page 652.
As per the existing policy of the Government of India, OCBs cannot participate in this Issue. For details, see
“Issue Procedure” on page 647.
The Equity Shares have not been and will not be registered under the U.S. Securities Act and may not be
issue or sold within the United States except pursuant to an exemption from, or in a transaction not subject
to, the registration requirements of the U.S. Securities Act and applicable U.S. state securities laws.
Accordingly, the Equity Shares are only being issue and sold outside the United States in offshore
transactions in reliance on Regulation S and the applicable laws of the jurisdiction where those issues and
sales occur.
The Equity Shares have not been and will not be registered, listed or otherwise qualified in any other
jurisdiction outside India and may not be issue or sold, and Bids may not be made by persons in any such
jurisdiction, except in compliance with the applicable laws of such jurisdiction.
The above information is given for the benefit of the Bidders. Our Company, our Promoters, our Director and the
BRLM are not liable for any amendments or modification or changes in applicable laws or regulations, which
may occur after the date of this Draft Red Herring Prospectus. Bidders are advised to make their independent
investigations and ensure that the number of Equity Shares Bid for do not exceed the applicable limits under laws
or regulations.
665SECTION VIII – DESCRIPTION OF EQUITY SHARES AND TERMS OF THE ARTICLES OF
ASSOCIATION
THE COMPANIES ACT, 2013
COMPANY LIMITED BY SHARES
ARTICLES OF ASSOCIATION
OF
SHAH INVESTOR’S HOME LIMITED
This set of Articles of Association has been approved pursuant to the provisions of Section 14 of the Companies
Act, 2013 and by a special resolution passed at the Annual General Meeting of Shah Investor’s Home Limited
(the “Company”) held on September 29, 2025. These Articles have been adopted as the Articles of Association of
the Company in substitution for and to the exclusion of all the existing Articles thereof.
No regulation contained in Table “F” in the First Schedule to Companies Act, 2013 shall apply to this Company
unless expressly made applicable in these Articles or by the said Act but the regulations for the Management of
the Company and for the observance of the Members thereof and their representatives shall be as set out in the
relevant provisions of the Companies Act, 2013 and subject to any exercise of the statutory powers of the
Company with reference to the repeal or alteration of or addition to its regulations by Special Resolution as
prescribed by the said Companies Act, 2013 be such as are contained in these Articles unless the same are
repugnant or contrary to the provisions of the Companies Act, 2013 or any amendment thereto.
1. (1) The regulations contained in table “F” of schedule I to the Companies Act, 2013 Table ‘F’ shall
shall apply only in so far as the same are not provided for or are not inconsistent apply
with these Articles.
(2) The regulations for the management of the Company and for the observance by Company to be
the members thereto and their representatives, shall, subject to any exercise of governed by these
the statutory powers of the Company with reference to the deletion or alteration Articles
of or addition to its regulations by resolution as prescribed or permitted by the
Companies Act, 2013, be such as are contained in these Articles.
Definitions and Interpretation
2. In these Articles —
(a) “Act” means the Companies Act, 2013 (including the relevant rules framed “Act”
thereunder) or any statutory modification or re-enactment thereof for the
time being in force and the term shall be deemed to refer to the applicable
section thereof which is relatable to the relevant Article in which the said
term appears in these Articles and any previous company law, so far as
may be applicable.
(b) “Applicable Laws” means all applicable statutes, laws, ordinances, rules “Applicable Laws”
and regulations, judgments, notifications circulars, orders, decrees,
byelaws, guidelines, or any decision, or determination, or any
interpretation, policy or administration, having the force of law, including
but not limited to, any authorization by any authority, in each case as in
effect from time to time
(c) “Articles” means these articles of association of the Company or as altered “Articles”
from time to time.
(d) “Auditors” means and includes those persons appointed as such for the “Auditors”
time being of the Company.
(e) “Board of Directors” or “Board”, means the collective body of the “Board of
Directors of the Company nominated and appointed from time to time in Directors” or
accordance with Articles 84 to 90, herein, as may be applicable. “Board”
(f) “Business Day” shall mean any day of the year, other than Saturdays and “Business Day”
Sundays and any other days on which banks are closed for business in the
city where the registered office of the Company is situated.
(g) “Company” means Shah Investor’s Home Limited. “Company”
(h) “Lien” means any mortgage, pledge, charge, assignment, hypothecation, “Lien”
security interest, title retention, preferential right, option (including call
commitment), trust arrangement, any voting rights, right of set-off,
counterclaim or banker’s lien, privilege or priority of any kind having the
effect of security, any designation of loss payees or beneficiaries or any
similar arrangement under or with respect to any insurance policy;
666(i) “Rules” means the applicable rules for the time being in force as “Rules”
prescribed under relevant sections of the Act.
(j) “Memorandum” means the memorandum of association of the Company “Memorandum”
or as altered from time to time.
Construction
In these Articles (unless the context requires otherwise):
(i) References to a party shall, where the context permits, include such party’s
respective successors, legal heirs and permitted assigns.
(ii) The descriptive headings of Articles are inserted solely for convenience of
reference and are not intended as complete or accurate descriptions of
content thereof and shall not be used to interpret the provisions of these
Articles and shall not affect the construction of these Articles.
(iii) References to articles and sub-articles are references to Articles and sub-
articles of and to these Articles unless otherwise stated and references to
these Articles include references to the articles and sub-articles herein.
(iv) Words importing the singular include the plural and vice versa, pronouns
importing a gender include each of the masculine, feminine and neuter
genders, and where a word or phrase is defined, other parts of speech and
grammatical forms of that word or phrase shall have the corresponding
meanings.
(v) Wherever the words “include,” “includes,” or “including” is used in these
Articles, such words shall be deemed to be followed by the words “without
limitation”.
(vi) The terms “hereof”, “herein”, “hereto”, “hereunder” or similar expressions
used in these Articles mean and refer to these Articles and not to any
Article of these Articles, unless expressly stated otherwise.
(vii) Unless otherwise specified, time periods within or following which any
payment is to be made or act is to be done shall be calculated by excluding
the day on which the period commences and including the day on which
the period ends and by extending the period to the next Business Day
following if the last day of such period is not a Business Day; and
whenever any payment is to be made or action to be taken under these
Articles is required to be made or taken on a day other than a Business
Day, such payment shall be made or action taken on the next Business Day
following.
(viii) A reference to a party being liable to another party, or to liability, includes,
but is not limited to, any liability in equity, contract or tort (including
negligence).
(ix) Reference to statutory provisions shall be construed as meaning and
including references also to any amendment or re-enactment for the time
being in force and to all statutory instruments or orders made pursuant to
such statutory provisions.
(x) References made to any provision of the Act shall be construed as meaning
and including the references to the rules and regulations made in relation
to the same by the MCA. The applicable provisions of the Companies Act,
1956 shall cease to have effect from the date on which the corresponding
provisions under the Companies Act, 2013 have been notified.
(xi) In the event any of the provisions of the Articles are contrary to the
provisions of the Act and the Rules, the provisions of the Act and Rules
will prevail.
Share capital and variation of rights
3. The authorized share capital of the Company shall be such amount and be Authorized share
divided into such shares as may from time to time, be provided in Clause V of capital
Memorandum, divided into such number, classes and descriptions of Shares and
into such denominations, as stated therein, with power to reclassify, subdivide,
consolidate and increase and with power from time to time, to issue any shares
of the original capital or any new capital and upon the sub-division of shares to
apportion the right to participate in profits, in any manner as between the shares
resulting from sub-division.
4. Subject to the provisions of the Act and these Articles, the shares in the capital Shares under
of the Company shall be under the control of the Board who may issue, allot or control of Board
otherwise dispose of the same or any of them to such persons, in such proportion
and on such terms and conditions and either at a premium or at par (subject to
the compliance with the provision of section 53 and 54 of the Act) and at such
time as they may from time to time think fit provided that the option or right to
call for shares shall not be given to any person or persons without the sanction
667of the Company in the general meeting. The Board shall cause to be filed the
returns as to allotment as may be prescribed from time to time.
Any application signed by or on behalf of an applicant for subscription for
Shares in the Company, followed by an allotment of any Shares therein, shall
be an acceptance of Shares within the meaning of these Articles, and every
person, who, thus or otherwise, accepts any Shares and whose name is entered
on the Registered shall, for the purpose of these Articles, be a member.
The money, if any, which the Board shall, on the allotment of any shares being
made by them, require or direct to be paid by way of deposit, call or otherwise,
in respect of any Shares allotted by them, shall immediately on the insertion of
the name of the allottee in the Register of Members as the name of the holder
of such Shares, become a debt due to and recoverable by the Company from the
allottee thereof, and shall be paid by him accordingly, in the manner prescribed
by the Board.
Every member or his heirs, executors or administrators, shall pay to the
Company the portion of the capital represented by his Share or Shares which
may, for the time being, remain unpaid thereon, in such amounts, at such time
or times, and in such manner as the Board shall, from time to time, in
accordance with the Regulations of the Company, require or fix for the payment
thereof.
5. Subject to the provisions of the Act, these Articles and with the sanction of the Board may allot
Company in the general meeting to give to any person or persons the option or shares otherwise
right to call for any shares either at par or premium during such time and for than for cash
such consideration as the Board think fit, the Board may issue, allot or otherwise
dispose shares in the capital of the Company on payment or part payment for
any property or assets of any kind whatsoever sold or transferred, goods or
machinery supplied or for services rendered to the Company in the conduct of
its business and any shares which may be so allotted may be issued as fully
paid-up or partly paid-up otherwise than for cash, and if so issued, shall be
deemed to be fully paid-up or partly paid-up shares, as the case may be,
provided that the option or right to call of shares shall not be given to any person
or persons without the sanction of the Company in the general meeting.
5A. The Company may issue the following kinds of shares in accordance with these Kinds of share
Articles, the Act, the Rules and other Applicable Laws: capital
(a) Equity Share capital:
(i) with voting rights; and / or
(ii) with differential rights as to dividend, voting or otherwise in
accordance with the Rules; and
(b) Preference share capital
6. (1) The Company shall keep or cause to be kept a Register and Index of Members, Issue of certificate
in accordance with the applicable Sections of the Act. The Company shall be
entitled to keep, in any State or Country outside India, a Branch Register of
Members, in respect of those residents in that State or Country.
Every person whose name is entered as a member in the register of members
shall be entitled to receive within two months after allotment or within one
month from the date of receipt by the Company of the application for the
registration of transfer or transmission, sub-division, consolidation or renewal
of shares or within such other period as the conditions of issue shall provide –
(a) one or more certificates in marketable lots for all his shares of each class
or denomination registered in his name without payment of any charges;
or
(b) several certificates, each for one or more of his shares, upon payment of
Rupees Twenty for each certificate or such charges as may be fixed by the
Board for each certificate after the first.
(2) In respect of any share or shares held jointly by several persons, the Company Issue of share
shall not be bound to issue more than one certificate, and delivery of a certificate certificate in case of
for a share to the person first named on the register of members shall be joint holding
sufficient delivery to all such holders.
668(3) Every certificate shall specify the shares to which it relates, distinctive numbers Option to receive
of shares in respect of which it is issued and the amount paid-up thereon and share certificate or
shall be in such form as the Board may prescribe and approve. hold shares with
depository
7. A person subscribing to shares offered by the Company shall have the option Option to receive
either to receive certificates for such shares or hold the shares in a share certificate or
dematerialized state with a depository, in which event the rights and obligations hold shares with
of the parties concerned and matters connected therewith or incidental thereof, depository
shall be governed by the provisions of the Depositories Act, 1996 as amended
from time to time, or any statutory modification thereto or re-enactment thereof.
Where a person opts to hold any share with the depository, the Company shall
intimate such depository the details of allotment of the share to enable the
depository to enter in its records the name of such person as the beneficial owner
of that share.
The Company shall also maintain a register and index of beneficial owners in
accordance with all applicable provisions of the Companies Act, 2013 and the
Depositories Act, 1996 with details of shares held in dematerialized form in any
medium as may be permitted by law including in any form of electronic
medium.
8. If any certificate be worn out, defaced, mutilated or torn or if there be no further Issue of new
space on the back for endorsement of transfer, then upon production and certificate in place
surrender thereof to the Company, a new certificate may be issued in lieu of one defaced, lost
thereof, and if any certificate is lost or destroyed then upon proof thereof to the or destroyed
satisfaction of the Company and on execution of such indemnity as the Board
deems adequate, a new certificate in lieu thereof shall be given. Every certificate
under this Article shall be issued on payment of fees not less than Rupees twenty
and as may be fixed by the Board for each certificate after the first. Such share
certificates shall also be issued in the event of consolidation or sub-division of
shares of the Company. Every such certificate shall be issued in the manner
prescribed under Section 46 of the Act and the rules framed thereunder.
Particulars of every share certificate issued shall be entered in the register of
members against the name of the person, to whom it has been issued, indicating
the date of issue. Provided that notwithstanding what is stated above, the Board
shall comply with such rules or regulations or requirements of any stock
exchange or the rules made under the Act or rules made under the Securities
Contracts (Regulation) Act,1956 or any other act, or rules applicable thereof in
this behalf.
Provided that notwithstanding what is stated above, the Board shall comply with
such rules or regulations or requirements of any stock exchange or the rules
made under the Act or rules made under the Securities Contracts (Regulation)
Act,1956 or any other act, or rules applicable thereof in this behalf.
8A. Except as required by Applicable Laws, no person shall be recognized by the Company not
Company as holding any share upon any trust, and the Company shall not be compelled to
bound by, or be compelled in any way to recognize (even when having notice recognize any
thereof) any equitable, contingent, future or partial interest in any share, or any equitable,
interest in any fractional part of a share, or (except only as by these Articles or contingent interest
by Applicable Laws) any other rights in respect of any share except an absolute
right to the entirety thereof in the registered holder.
8B. Subject to the applicable provisions of the Act and other Applicable Laws, any Terms of issue of
debentures, debenture-stock or other securities may be issued at a premium or debentures
otherwise and may be issued on condition that they shall be convertible into
shares of any denomination, and with any privileges and conditions as to
redemption, surrender, drawing, allotment of shares and attending (but not
voting) at a general meeting, appointment of nominee directors, etc. Debentures
with the right to conversion into or allotment of shares shall be issued only with
the consent of the Company in a general meeting by special resolution.
9. The provisions of the foregoing Articles relating to issue of certificates shall Provisions as to
mutatis mutandis apply to issue of certificates for any other securities including issue of certificates
debentures (except where the Act otherwise requires) of the Company. to apply mutatis
mutandis to
debentures, etc.
10. (1) The Company may exercise the powers of paying commissions conferred by Power to pay
the Act, to any person in connection with the subscription or procurement of commission in
subscription to its securities, provided that the rate per cent or the amount of the connection with
securities issued
669commission paid or agreed to be paid shall be disclosed in the manner required
by the Act and the Rules.
(2) The rate or amount of the commission shall not exceed the rate or amount Rate of commission
prescribed in the Rules. in accordance with
Rules
(3) The commission may be satisfied by the payment of cash or the allotment of Mode of payment of
fully or partly paid shares or partly in the one way and partly in the other. commission
11. (1) If at any time the share capital is divided into different classes of shares, the Variation of
rights attached to any class (unless otherwise provided by the terms of issue of members’ rights
the shares of that class) may, subject to the provisions of the Act, and whether
or not the Company is being wound up, be varied with the consent in writing,
of such number of the holders of the issued shares of that class, or with the
sanction of a resolution passed at a separate meeting of the holders of the shares
of that class, as prescribed by the Act.
(2) To every such separate meeting, the provisions of these Articles relating to Provisions as to
general meetings shall mutatis mutandis apply, but so that the necessary quorum general meetings to
shall be at least two persons holding at least one -third of the issued shares of apply mutatis
the class in question mutandis to each
Meeting
12. The rights conferred upon the holders of the shares of any class issued with Issue of further
preferred or other rights shall not, unless otherwise expressly provided by the shares not to affect
terms of issue of the shares of that class, be deemed to be varied by the creation rights of existing
or issue of further shares ranking pari passu therewith. members
13. Subject to section 55 and other provisions of the Act, the Board shall have the Power to issue
power to issue or re-issue preference shares of one or more classes which are redeemable
liable to be redeemed, or converted to equity shares, on such terms and preference shares
conditions and in such manner as determined by the Board in accordance with
the Act.
On the issue of Redeemable Preference Shares under the provisions of the
preceding Article, the following provisions shall take effect:-
(i) No such Shares shall be redeemed except out of the profits of the
Company which would otherwise be available for dividend or out of the
proceeds of a fresh issue of Shares made for the purpose of the redemption.
(ii) No such Shares shall be redeemed unless they are fully paid. The
period of redemption in case of preference shares shall not exceed the maximum
period for redemption provided under Section 55 of the Act;
(iii) The premium, if any, payable on redemption, must have been
provided for, out of the profits of the Company or the Share Premium Account
of the Company before, the Shares are redeemed; and
(iv) Where any such Shares are redeemed otherwise than out of the
proceeds of a fresh issue, there shall, out of profits which would otherwise have
been available for dividend, be transferred to a reserve fund to be called “Capital
Redemption Reserve Account”, a sum equal to the nominal amount of the
Shares redeemed and the provisions of the Act, relating to the reduction of the
Share Capital of the Company, shall, except as provided in Section 80 of the
Act, apply as if “Capital Redemption Reserve Account” were paid up Share
capital of the Company.
Whenever the capital, by reason of the issue of Preference Shares or otherwise,
is divided into different classes of shares, all or any of the rights and privileges
attached to each class may, subject to the applicable provisions of the Act, be
modified, commuted, affected or abrogated, or dealt with by an agreement
between the Company and any person purporting to contract on behalf of that
class, provided such agreement is ratified, in writing, by holders of at least
three-fourths in nominal value of the issued Shares of the class or is confirmed
by a special resolution passed at a separate general meeting of the holders of
Shares of that class and all the provisions hereinafter contained as to general
meetings, shall, mutatis mutandis, apply to every such meeting.
14. (1) Where at any time, the Company proposes to increase its subscribed capital by Further issue of
issue of further shares, either out of the unissued capital or the increased share share capital
capital, such shares shall be offered:
670to persons who, at the date of offer, are holders of Equity Shares of the
Company, in proportion as near as circumstances admit, to the share capital paid
up on those shares by sending a letter of offer on the following conditions : -
the aforesaid offer shall be made by a notice specifying the number of shares
offered and limiting a time prescribed under the Act from the date of the offer
within which the offer, if not accepted, will be deemed to have been declined
the aforementioned offer shall be deemed to include a right exercisable by the
person concerned to renounce the shares offered to him or any of them in favour
of any other person and the notice mentioned in sub-Article (i), above shall
contain a statement of this right; and
after the expiry of the time specified in the aforesaid notice or on receipt of
earlier intimation from the person to whom such notice is given that he declines
to accept the shares offered, the Board of Directors may dispose of them in such
manner which is not disadvantageous to the shareholders and the Company; or
to employees under any scheme of employees’ stock option, subject to a special
resolution passed by the Company and subject to the conditions as specified
under the Act and Rules thereunder; or
to any persons, if it is authorized by a special resolution passed by the Company
in a General Meeting, whether or not those persons include the persons referred
to in clause (a) or clause (b) above, either for cash or for consideration other
than cash, subject to applicable provisions of the Act and Rules thereunder.
The notice referred to in sub-clause (i) of sub-Article (a) shall be dispatched
through registered post or speed post or through electronic mode to all the
existing Members at least 3 (three) days before the opening of the issue.
The provisions contained in this Article shall be subject to the provisions of the
section 42 and section 62 of the Act, the rules thereunder and other applicable
provisions of the Act.
Notwithstanding anything contained in sub-clause (i) thereof, the further Shares
aforesaid may be offered to any persons, if it is authorised by a special
resolution, (whether or not those persons include the persons referred to in
clause (a) of sub-clause (i) hereof) in any manner either for cash or for a
consideration other than cash, if the price of such shares is determined by the
valuation report of a registered valuer subject to the compliance with the
applicable provisions of Chapter III and any other conditions as may be
prescribed in the Act and the rules made thereunder.
The notice referred to in above sub-clause hereof shall be dispatched through
registered post or speed post or through electronic mode to all the existing
shareholders at least 3 (three) days before the opening of the issue.
Nothing in sub-clause above hereof shall be deemed:
(a) To extend the time within the offer should be accepted; or
(b) To authorise any person to exercise the right of renunciation for a
second time, on the ground that the person in whose favour the remuneration
was first made has declined to take the Shares comprised in the renunciation.
(2) Nothing in this Article shall apply to the increase of the subscribed capital of
the Company caused by the exercise of an option as a term attached to the
debentures issued or loans raised by the Company to convert such debenture or
loans into shares in the Company.
Provided that the terms of issue of such debentures or loan containing such an
option have been approved before the issue of such debenture or the raising of
loan by a special resolution passed by the Company in general meeting.
Notwithstanding anything contained in [Article 14 (2)] hereof, where any
debentures have been issued, or loan has been obtained from any government
by the Company, and if that government considers it necessary in the public
interest so to do, it may, by order, direct that such debentures or loans or any
671part thereof shall be converted into shares in the Company on such terms and
conditions as appear to the government to be reasonable in the circumstances
of the case even if terms of the issue of such debentures or the raising of such
loans do not include a term for providing for an option for such conversion:
Provided that where the terms and conditions of such conversion are not
acceptable to the Company, it may, within sixty days from the date of
communication of such order, appeal to National Company Law Tribunal which
shall after hearing the Company and the government pass such order as it deems
fit. A further issue of shares may be made in any manner whatsoever as the
Board may determine including by way of preferential offer or private
placement, subject to and in accordance with the Act and the rules made
thereunder.
(3) A further issue of shares may be made in any manner whatsoever as the Board Mode of further
may determine including by way of preferential offer or private placement, issue of shares
subject to and in accordance with the Act and the Rules.
The provisions contained in this Article shall be subject to the provisions of the
section 42 and section 62 of the Act and other applicable provisions of the Act
and rules framed thereunder.
Subject to the provisions of the Act, the Company shall have the power to make Power to make
compromise or make arrangements with creditors and members, consolidate, compromise or
demerge, amalgamate or merge with other company or companies in arrangement
accordance with the provisions of the Act and any other applicable laws.
Lien
15. (1) The fully paid shares will be free from all Lien, however, the Company shall Company’s lien on
have a first and paramount Lien – shares
(a) on every share (not being a fully paid share) and upon the proceeds
of sale thereof for all monies (whether presently payable or not) called, or
payable at a fixed time, in respect of that share; and
(b) on all shares (not being fully paid shares) standing registered in the
name of a member, for all monies presently payable by him or his estate to the
Company:
Provided that the Board may at any time declare any share to be wholly or in
part exempt from the provisions of this Article.
Provided further that Company’s lien, if any, on such partly paid shares, shall
be restricted to money called or payable at a fixed price in respect of such
shares.
(2) The Company’s Lien, if any, on a share shall extend to all dividends or interest, Lien to extend to
as the case may be, payable and bonuses declared from time to time in respect dividends, etc.
of such shares for any money owing to the Company.
However, a member shall exercise any voting rights in respect of the shares in
regard to which the Company has exercised the right of Lien.
(3) Unless otherwise agreed by the Board, the registration of a transfer of shares Waiver of Lien in
shall operate as a waiver of the Company’s Lien. case of registration
16. The Company may sell, in such manner as the Board thinks fit, any shares on As to enforcing
which the Company has a Lien: Lien by sale
Provided that no sale shall be made—
(a) unless a sum in respect of which the Lien exists is presently payable;
or
(b) until the expiration of fourteen days after a notice in writing stating
and demanding payment of such part of the amount in respect of which the Lien
exists as is presently payable, has been given to the registered holder for the
time being of the share or to the person entitled thereto by reason of his death
or insolvency or otherwise.
17. (1) To give effect to any such sale, the Board may authorize some person to transfer Validity of sale
the shares sold to the purchaser thereof
(2) The purchaser shall be registered as the holder of the shares comprised in any Purchaser to be
such transfer. registered holder
672(3) The receipt of the Company for the consideration (if any) given for the share on Validity of
the sale thereof shall (subject, if necessary, to execution of an instrument of Company’s receipt
transfer or a transfer by relevant system, as the case may be) constitute a good
title to the share and the purchaser shall be registered as the holder of the share.
(4) The purchaser shall not be bound to see to the application of the purchase Purchaser not
money, nor shall his title to the shares be affected by any irregularity or affected
invalidity in the proceedings with reference to the sale
18. (1) The proceeds of the sale shall be received by the Company and applied in Application of
payment of such part of the amount in respect of which the Lien exists as is proceeds of sale
presently payable.
(2) The residue, if any, shall, subject to a like Lien for sums not presently payable Payment of
as existed upon the shares before the sale, be paid to the person entitled to the residual money
shares at the date of the sale.
19. The provisions of these Articles relating to Lien shall mutatis mutandis apply Provisions as to
to any other securities including debentures of the Company. Lien to apply
mutatis mutandis
to debentures, etc.
Calls on shares
20. (1) The Board may, from time to time, make calls upon the members in respect of Board may make
any monies unpaid on their shares (whether on account of the nominal value of Calls
the shares or by way of premium) and not by the conditions of allotment thereof
made payable at fixed times.
Provided that no call shall exceed one-fourth of the nominal value of the share
or be payable at less than one month from the date fixed for the payment of
the last preceding call.
(2) Each member shall, subject to receiving at least fourteen days’ notice specifying Notice of call
the time or times and place of payment, pay to the Company, at the time or
times and place so specified, the amount called on his shares.
(3) A call may be revoked or postponed at the discretion of the Board Revocation or
postponement of
call
21. A call shall be deemed to have been made at the time when the resolution of the Call to take effect
Board authorizing the call was passed and may be required to be paid by from date of
instalments. resolution
22. The joint holders of a share shall be jointly and severally liable to pay all calls Liability of joint
in respect thereof. holders of shares
23. (1) If a sum called in respect of a share is not paid before or on the day appointed When interest on
for payment thereof (the “due date”), the person from whom the sum is due call or instalment
shall pay interest thereon from the due date to the time of actual payment at payable
such rate as may be fixed by the Board.
(2) The Board shall be at liberty to waive payment of any such interest wholly or Board may waive
in part. interest
24. (1) Any sum which by the terms of issue of a share becomes payable on allotment Sums deemed to be
or at any fixed date, whether on account of the nominal value of the share or by calls
way of premium, shall, for the purposes of these Articles, be deemed to be a
call duly made and payable on the date on which by the terms of issue such sum
becomes payable.
(2) In case of non-payment of such sum, all the relevant provisions of these Articles Effect of
as to payment of interest and expenses, forfeiture or otherwise shall apply as if nonpayment of
such sum had become payable by virtue of a call duly made and notified. sums
(3) On the trial or hearing of any action or suit brought by the Company against Suit by company
any member or his representative for the recovery of any money claimed to be for recovery of
due to the Company in respect of his Shares, it shall be sufficient to prove that money against any
the name of the member, in respect of whose Shares the money is sought to be member
recovered, appears or is entered on the Register of Members as the holder, at or
subsequent to the date at which the money is sought to be recovered, is alleged
to have become due on the Shares in respect of which money is sought to be
recovered, and that the resolution making the call is duly recorded in the minute
book, and that notice, of which call, was duly given to the member or his
representatives and used in pursuance of these Articles, and it shall not be
necessary to prove the appointment of the Directors who made such call, and
not that a quorum of Directors was present at the meeting of the Board at which
any call was made, and nor that the meeting, at which any call was made, has
duly been convened or constituted nor any other matter whatsoever, but the
proof of the matters aforesaid shall be conclusive of the debt.
673(4) Neither the receipt by the Company of a portion of any money which shall, from Enforcing
time to time, be due from any member to the Company in respect of his Shares, forfeiture of shares
either by way of principal or interest, nor any indulgence granted by the by Company
Company in respect of the payment of any such money, shall preclude the
Company from thereafter proceeding to enforce a forfeiture of such Shares as
hereinafter provided.
25. The Board – Payment in
anticipation of calls
(a) may, if it thinks fit, subject to the provisions of the Act, receive from any may carry interest
member willing to advance the same, all or any part of the monies uncalled
and unpaid upon any shares held by him; and
(b) upon all or any of the monies so advanced, may (until the same would, but
for such advance, become presently payable) pay interest at such rate as
may be fixed by the Board. Nothing contained in this clause shall confer
on the member (a) any right to participate in profits or dividends or (b) any
voting rights in respect of the moneys so paid by him until the same would,
but for such payment, become presently payable by him.
The Directors may at any time repay the amount so advanced.
The provisions of these Articles relating to calls shall mutatis mutandis apply
to any other securities, including debentures, of the Company, to the extent
applicable.
26. If by the conditions of allotment of any shares, the whole or part of the amount Installments on
of issue price thereof shall be payable by installments, then every such shares to be duly
installment shall, when due, be paid to the Company by the person who, for the paid
time being and from time to time, is or shall be the registered holder of the share
or the legal representative of a deceased registered holder.
27. All calls shall be made on a uniform basis on all shares falling under the same Calls on shares of
class. same class to be on
uniform basis
Explanation: Shares of the same nominal value on which different amounts
have been paid-up shall not be deemed to fall under the same class.
28. The provisions of these Articles relating to calls shall mutatis mutandis apply Provisions as to
to any other securities including debentures of the Company. calls to apply
mutatis mutandis
to debentures, etc.
29. Dematerialization
Notwithstanding anything contained in the Articles, the Company shall be Dematerialization
entitled to dematerialise its shares, debentures and other securities and offer Of Securities
such shares, debentures and other securities in a dematerialised form pursuant
to the Depositories Act 1996.
Notwithstanding anything contained in the Articles, and subject to the
provisions of the law for the time being in force, the Company shall on a request
made by a beneficial owner, re-materialise the shares, which are in
dematerialised form.
Every Person subscribing to the shares offered by the Company shall have the
option to receive share certificates or to hold the shares with a Depository.
Where Person opts to hold any share with the Depository, the Company shall
intimate such Depository of details of allotment of the shares to enable the
Depository to enter in its records the name of such Person as the beneficial
owner of such shares. Such a Person who is the beneficial owner of the shares
can at any time opt out of a Depository, if permitted by the law, in respect of
any shares in the manner provided by the Depositories Act 1996 and the
Company shall in the manner and within the time prescribed, issue to the
beneficial owner the required certificate of shares. In the case of transfer of
shares or other marketable securities where the Company has not issued any
certificates and where such shares or securities are being held in an electronic
and fungible form, the provisions of the Depositories Act 1996 shall apply.
If a Person opts to hold his shares with a Depository, the Company shall intimate
such Depository the details of allotment of the shares, and on receipt of the
674information, the Depository shall enter in its record the name of the allottee as
the beneficial owner of the shares.
All shares held by a Depository shall be dematerialised and shall be in a fungible
form.
(a) Notwithstanding anything to the contrary contained in the Act or the
Articles, a Depository shall be deemed to be the registered owner for the
purposes of effecting any transfer of ownership of shares on behalf of the
beneficial owner.
(b) Save as otherwise provided in (a) above, the Depository as the
registered owner of the shares shall not have any voting rights or any other
rights in respect of shares held by it.
Every person holding shares of the Company and whose name is entered as the
beneficial owner in the records of the Depository shall be deemed to be the
owner of such shares and shall also be deemed to be a shareholder of the
Company. The beneficial owner of the shares shall be entitled to all the
liabilities in respect of his shares which are held by a Depository. The Company
shall be further entitled to maintain a register of members with the details of
members holding shares both in material and dematerialised form in any
medium as permitted by law including any form of electronic medium.
Notwithstanding anything in the Act or the Articles to the contrary, where
shares are held in a Depository, the records of the beneficial ownership may be
served by such Depository on the Company by means of electronic mode or by
delivery of disks, drives or any other mode as prescribed by law from time to
time.
Nothing contained in the Act or the Articles regarding the necessity to have
distinctive numbers for securities issued by the Company shall apply to
securities held with a Depository.
Transfer of shares
30. (1) A common form of transfer shall be used and the instrument of transfer of any Instrument of
share in the Company shall be in writing which shall be duly executed by or on transfer to be
behalf of both the transferor and transferee and shall be duly stamped and executed by
delivered to the Company within the prescribed period and all provisions of transferor and
section 56 of the Act and statutory modification thereof for the time being shall transferee
be duly complied with in respect of all transfer of shares and registration
thereof.
Every instrument of transfer shall be in writing and all provisions of the Act,
the rules and applicable laws shall be duly complied with. The instrument shall
also be duly stamped, under the relevant provisions of the Law, for the time
being, in force, and shall be signed by or on behalf of the transferor and the
transferee, and in the case of Share held by two or more holders or to be
transferred to the joint names of two or more transferees by all such joint holders
or by all such joint transferees, as the case may be.
(2) The Company shall keep the “Register of Transfers” and therein shall fairly and Register of transfer
distinctly enter particulars of every transfer or transmission of any Share.
The transferor shall be deemed to remain a holder of the share until the name of
the transferee is entered in the register of members in respect thereof.
31. The Board may, subject to the right of appeal conferred by the section 58 of the Board may refuse
Act decline to register – to register transfer
(a) the transfer of a share, not being a fully paid share, to a person of whom
they do not approve; or
(b) any transfer of shares on which the Company has a Lien.
The registration of a transfer shall not be refused on the ground of the transferor
being either alone or jointly with any other person or persons indebted to the
Company on any account whatsoever.
32. The Board may decline to recognize any instrument of transfer unless- Board may decline
to recognize
(a) the instrument of transfer is duly executed and is in the form as instrument of
prescribed in the Rules made under sub-section (1) of section 56 of the transfer
Act;
675(b) the instrument of transfer is accompanied by the certificate of the shares to
which it relates, and such other evidence as the Board may reasonably
require to show the right of the transferor to make the transfer; and
(c) the instrument of transfer is in respect of only one class of shares.
The registration of a transfer shall not be refused on the ground of the transferor
being either alone or jointly with any other person or persons indebted to the
Company on any account whatsoever.
33. On giving of previous notice of at least seven days or such lesser period in Transfer of shares
accordance with the Act and Rules made thereunder, the registration of transfers when suspended
may be suspended at such times and for such periods as the Board may from
time to time determine:
Provided that such registration shall not be suspended for more than thirty days
at any one time or for more than forty five days in the aggregate in any year.
33A Subject to the provisions of sections 58 and 59 of the Act, these Articles and Notice of refusal to
other applicable provisions of the Act or any other Applicable Laws for the time register transfer
being in force, the Board may refuse whether in pursuance of any power of the
Company under these Articles or any other Applicable Laws to register the
transfer of, or the transmission by operation of Applicable Laws of the right to,
any shares or interest of a member in or debentures of the Company. The
Company shall within one (1) month from the date on which the instrument of
transfer, or the intimation of such transmission, as the case may be, was
delivered to Company, or such other period as may be prescribed, send notice
of the refusal to the transferee and the transferor or to the person giving
intimation of such transmission, as the case may be, giving reasons for such
refusal. Provided that, subject to provisions of Article 32, the registration of a
transfer shall not be refused on the ground of the transferor being either alone
or jointly with any other person or persons indebted to the Company on any
account whatsoever. Transfer of shares/debentures in whatever lot shall not be
refused.
34. The provisions of these Articles relating to transfer of shares shall mutatis Provisions as to
mutandis apply to any other securities including debentures of the Company. transfer of shares to
apply mutatis
mutandis to
debentures, etc.
35. An application for the registration of a transfer of Shares in the Company may Application for
be made either by the transferor or the transferee. Where such application is registration of
made by a transferor and relates to partly paid Shares, the Company shall give transfer of shares
notice of the application to the transferee. The transferee may, within two weeks
from the date of the receipt of the notice and not later, object to the proposed
transfer. The notice to the transferee shall be deemed to have been duly given,
if dispatched by prepaid registered post to the transferee at the address given in
the instrument of transfer and shall be deemed to have been delivered at the
time when it would have been delivered in the ordinary course of post.
Transmission of shares
36. (1) On the death of a member, the survivor or survivors where the member was a Title to shares on
joint holder, and his nominee or nominees or legal representatives where he was death of a member
a sole holder, shall be the only persons recognized by the Company as having
any title to his interest in the shares.
(2) Nothing in clause (1) shall release the estate of a deceased joint holder from any Estate of deceased
liability in respect of any share which had been jointly held by him with other member liable
persons.
(3) Any person becoming entitled to a share in consequence of the death or Transmission
insolvency of a member may, upon such evidence being produced as may from Clause
time to time properly be required by the Board and subject as hereinafter
provided, elect, either –
(a) to be registered himself as holder of the share; or
676(b) to make such transfer of the share as the deceased or insolvent
member could have made.
(4) The Board shall, in either case, have the same right to decline or suspend Board’s right
registration as it would have had, if the deceased or insolvent member had unaffected
transferred the share before his death or insolvency.
37. (1) If the person so becoming entitled shall elect to be registered as holder of the Right to election of
share himself, he shall deliver or send to the Company a notice in writing signed holder of share
by him stating that he so elects.
(2) If the person aforesaid shall elect to transfer the share, he shall testify his Manner of
election by executing a transfer of the share. testifying election
(3) All the limitations, restrictions and provisions of these regulations relating to Limitations
the right to transfer and the registration of transfers of shares shall be applicable applicable to notice
to any such notice or transfer as aforesaid as if the death or insolvency of the
member had not occurred and the notice or transfer were a transfer signed by
that member.
38. A person becoming entitled to a share by reason of the death or insolvency of Claimant to be
the holder shall be entitled to the same dividends and other advantages to which entitled to same
he would be entitled if he were the registered holder of the share, except that he advantage
shall not, before being registered as a member in respect of the share, be entitled
in respect of it to exercise any right conferred by membership in relation to
meetings of the Company:
Provided that the Board may, at any time, give notice requiring any such person
to elect either to be registered himself or to transfer the share, and if the notice
is not complied with within ninety days, the Board may thereafter withhold
payment of all dividends, bonuses or other monies payable in respect of the
share, until the requirements of the notice have been complied with.
39. The provisions of these Articles relating to transmission by operation of law Provisions as to
shall mutatis mutandis apply to any other securities including debentures of the transmission to
Company apply mutatis
mutandis to
debentures, etc.
39A No fee shall be charged for registration of transfer, transmission, probate, No fee for transfer
succession certificate and letters of administration, certificate of death or or transmission
marriage, power of attorney or similar other document
Nomination by security holder
(i) Every holder of Securities in the Company may, at any time, Manner of
nominate, in the prescribed manner, a person to whom his Securities in the nomination by
Company, shall vest in the event of his death. security holder
(ii) Where the Securities in the Company are held by more than one
person jointly, the joint-holders may together nominate, in the prescribed
manner, a person to whom all the rights in the Securities in the Company shall
vest in the event of death of all joint holders.
(iii) Notwithstanding anything contained in these Articles or any other
law, for the time being, in force, or in any disposition, whether testamentary or
otherwise, in respect of such Securities in the Company, where a nomination
made in the prescribed manner purports to confer on any person the right to vest
the Securities in the Company, the nominee shall, on the death of the
Shareholders of the Company or, as the case may be, on the death of the joint
holders, become entitled to all the rights in the Securities of the Company or, as
the case may be, all the joint holders, in relation to such securities in the
Company, to the exclusion of all other persons, unless the nomination is varied
or cancelled in the prescribed manner.
(iv) In the case of fully paid up Securities in the Company, where the
nominee is a minor, it shall be lawful for the holder of the Securities, to make
the nomination to appoint in the prescribed manner any person, being a
guardian, to become entitled to Securities in the Company, in the event of his
death, during the minority.
(i) Any person who becomes a nominee by virtue of the provisions
of the preceding Article, upon the production of such evidence as may be
required by the Board and subject as hereinafter provided, elect, either –
677(a) to be registered himself as holder of the Share(s); or
(b) to make such transfer of the Share(s) as the deceased Shareholder
could have made.
(ii) If the person being a nominee, so becoming entitled, elects to be
registered as holder of the Share(s), himself, he shall deliver or send to the
Company a notice in writing signed by him stating that he so elects, and such
notice shall be accompanied with the death certificate of the deceased
shareholder.
(iii) All the limitations, restrictions and provisions of the Act relating
to the right to transfer and the registration of transfers of Securities shall be
applicable to any such notice or transfer as aforesaid as if the death of the
member had not occurred and the notice or transfer has been signed by that
Shareholder.
(iv) A person, being a nominee, becoming entitled to a Share by reason
of the death of the holder, shall be entitled to the same dividends and other
advantages which he would be entitled if he were the registered holder of the
Share except that he shall not, before being registered a member in respect of
his Share be entitled in respect of it to exercise any right conferred by
membership in relation to meetings of the Company:
Provided that the Board may, at any time, give notice requiring any such person
to elect either to be registered himself or to transfer the Share(s) and if the notice
is not complied with within ninety days, the Board may thereafter withhold
payment of all dividends, bonuses or other moneys payable in respect of the
Share(s) or until the requirements of the notice have been complied with.
Forfeiture of shares
40. If a member fails to pay any call, or instalment of a call or any money due in If call or instalment
respect of any share, on the day appointed for payment thereof, the Board may, not paid notice
at any time thereafter during such time as any part of the call or instalment must be given
remains unpaid or a judgement or decree in respect thereof remains unsatisfied
in whole or in part, serve a notice on him requiring payment of so much of the
call or instalment or other money as is unpaid, together with any interest which
may have accrued and all expenses that may have been incurred by the
Company by reason of non-payment.
41. The notice aforesaid shall: Form of Notice
(a) name a further day (not being earlier than the expiry of fourteen days from
the date of service of the notice) on or before which the payment required
by the notice is to be made; and
(b) state that, in the event of non-payment on or before the day so named, the
shares in respect of which the call was made shall be liable to be forfeited.
42. If the requirements of any such notice as aforesaid are not complied with, any In default of
share in respect of which the notice has been given may, at any time thereafter, payment of shares
before the payment required by the notice has been made, be forfeited by a to be forfeited
resolution of the Board to that effect. Subject to the provisions of the Act, such
forfeiture shall include all dividends declared or any other moneys payable in
respect of the forfeited Shares and not actually paid before the forfeiture.
43. When any share shall have been so forfeited, notice of the forfeiture shall be Entry of forfeiture
given to the defaulting member and an entry of the forfeiture with the date in register of
thereof, shall forthwith be made in the register of members. members
But no forfeiture shall be, in any manner, invalidated by any omission or
neglect to give such notice or to make any such entry as aforesaid.
44. The forfeiture of a share shall involve extinction at the time of forfeiture, of all Effect of forfeiture
interest in and all claims and demands against the Company, in respect of the
share and all other rights incidental to the share.
45. (1) A forfeited share shall be deemed to be the property of the Company and may Forfeited shares
be sold or re-allotted or otherwise disposed of either to the person who was may be sold, etc.
before such forfeiture the holder thereof or entitled thereto or to any other
person on such terms and in such manner as the Board thinks fit.
(2) At any time before a sale, re-allotment or disposal as aforesaid, the Board may Cancellation of
cancel the forfeiture on such terms as it thinks fit. forfeiture
46. (1) A person whose shares have been forfeited shall cease to be a member in respect Members still liable
of the forfeited shares, but shall, notwithstanding the forfeiture, remain liable to to pay money owing
678pay, and shall pay, to the Company all monies which, at the date of forfeiture, at the time of
were presently payable by him to the Company in respect of the shares. forfeiture
(2) The liability of such person shall cease if and when the Company shall have Cesser of liability
received payment in full of all such monies in respect of the shares.
47. (1) A duly verified declaration in writing that the declarant is a director, the Certificate of
manager or the secretary of the Company, and that a share in the Company has forfeiture
been duly forfeited on a date stated in the declaration, shall be conclusive
evidence of the facts therein stated as against all persons claiming to be entitled
to the share;
(2) The Company may receive the consideration, if any, given for the share on any Title of purchaser
sale, re-allotment or disposal thereof and may execute a transfer of the share in and transferee of
favour of the person to whom the share is sold or disposed of forfeited shares
(3) The transferee shall thereupon be registered as the holder of the share; and Transferee to be
registered as holder
(4) The transferee shall not be bound to see to the application of the purchase Transferee not
money, if any, nor shall his title to the share be affected by any irregularity or affected
invalidity in the proceedings in reference to the forfeiture, sale, re-allotment or
disposal of the share
48. Upon any sale after forfeiture or for enforcing a Lien in exercise of the powers Validity of sales
hereinabove given, the Board may, if necessary, appoint some person to execute
an instrument for transfer of the shares sold and cause the purchaser’s name to
be entered in the register of members in respect of the shares sold and after his
name has been entered in the register of members in respect of such shares the
validity of the sale shall not be impeached by any person.
49. Upon any sale, re-allotment or other disposal under the provisions of the Cancellation of
preceding Articles, the certificate(s), if any, originally issued in respect of the share certificate in
relative shares shall (unless the same shall on demand by the Company has been respect of forfeited
previously surrendered to it by the defaulting member) stand cancelled and shares
become null and void and be of no effect, and the Board shall be entitled to
issue a duplicate certificate(s) in respect of the said shares to the person(s)
entitled thereto.
50. The Board may, subject to the provisions of the Act, accept a surrender of any Surrender of share
share from or by any member desirous of surrendering them on such terms as certificates
they think fit.
51. The provisions of these Articles as to forfeiture shall apply in the case of non- Sums deemed to be
payment of any sum which, by the terms of issue of a share, becomes payable calls
at a fixed time, whether on account of the nominal value of the share or by way
of premium, as if the same had been payable by virtue of a call duly made and
notified.
52. The provisions of these Articles relating to forfeiture of shares shall mutatis Provisions as to
mutandis apply to any other securities including debentures of the Company. forfeiture of shares
to apply mutatis
mutandis to
debentures, etc.
Alteration of capital
53. Subject to the provisions of the Act, the Company may, by ordinary resolution Power to alter
- share capital
(a) increase the share capital by such sum, to be divided into shares of such
amount as it thinks expedient;
(b) consolidate and divide all or any of its share capital into shares of larger
amount than its existing shares:
Provided that any consolidation and division which results in changes in the
voting percentage of members shall require applicable approvals under
the Act;
(c) convert all or any of its fully paid-up shares into stock, and reconvert that
stock into fully paid-up shares of any denomination;
(d) sub-divide its existing shares or any of them into shares of smaller amount
than is fixed by the Memorandum;
(e) cancel any shares which, at the date of the passing of the resolution, have
not been taken or agreed to be taken by any person.
67954. Where shares are converted into stock: Right of
stockholders
(a) the holders of stock may transfer the same or any part thereof in the
same manner as, and subject to the same Articles under which, the shares from
which the stock arose might before the conversion have been transferred, or as
near thereto as circumstances admit:
Provided that the Board may, from time to time, fix the minimum amount of
stock transferable, so, however, that such minimum shall not exceed the
nominal amount of the shares from which the stock arose;
(b) the holders of stock shall, according to the amount of stock held by
them, have the same rights, privileges and advantages as regards dividends,
voting at meetings of the Company, and other matters, as if they held the shares
from which the stock arose; but no such privilege or advantage (except
participation in the dividends, voting and profits of the Company and in the
assets on winding up) shall be conferred by an amount of stock which would
not, if existing in shares, have conferred that privilege or advantage;
(c) such of these Articles of the Company as are applicable to paid-up
shares shall apply to stock and the words “share” and “shareholder”/ “member”
shall include “stock” and “stock-holder” respectively.
The Company, by resolution in general meeting, may convert any paid-up
Shares into stock, or may, at any time, reconvert any stock into paid up Shares
of any denomination.
The notice of such conversion of Shares into stock or reconversion of stock into
Shares shall be filed with the Registrar of Companies as provided in the Act.
54 A Share warrants- Issue of share
The Company may issue Share warrants in the manner provided by the said Act warrants and rights
and accordingly the Directors may, in their discretion, with respect to any fully of holder of share
paid up Share or stock, on application, in writing, signed by the person or all warrants
persons registered as holder or holders of the Share or stock, and authenticated
by such evidence, if any, as the Directors may, from time to time, require as to
the identity of the person or persons signing the application, and on receiving
the certificate, if any, of the Share or stock and the amount of the stamp duty on
the warrant and such fee as the Directors may, from time to time, prescribe,
issue, under the Seal of the Company, a warrant, duly stamped, stating that the
bearer of the warrant is entitled to the Shares or stock therein specified, and may
provide by coupons or otherwise for the payment of future dividends, or other
moneys, on the Shares or stock included in the warrant. On the issue of a Share
warrant the names of the persons then entered in the Register of Members as
the holder of the Shares or stock specified in the warrant shall be struck off the
Register of
Members and the following particulars shall be entered therein.
(i) fact of the issue of the warrant.
(ii) a statement of the Shares or stock included in the warrant
distinguishing each Share by its number, and
(iii) the date of the issue of the warrant.
A Share warrant shall entitle the bearer to the Shares or stock included in it,
and, notwithstanding anything contained in these articles, the Shares or stock
shall be transferred by the delivery of the Share-warrant, and the provisions of
the regulations of the Company with respect to transfer and transmission of
Shares shall not apply thereto.
The bearer of a Share-warrant shall, on surrender of the warrant to the Company
for cancellation, and on payment of such fees, as the Directors may, from time
to time, prescribe, be entitled, subject to the discretion of the Directors, to have
his name entered as a member in the Register of Members in respect of the
Shares or stock included in the warrant.
The bearer of a Share-warrant shall not be considered to be a member of the
Company and accordingly save as herein otherwise expressly provided, no
person shall, as the bearer of Share-warrant, sign a requisition for calling a
meeting of the Company, or attend or vote or exercise any other privileges of a
member at a meeting of the Company, or be entitled to receive any notice from
the Company of meetings or otherwise, or qualified in respect of the Shares or
stock specified in the warrant for being a director of the Company, or have or
exercise any other rights of a member of the Company. The Directors may, from
680time to time, make rules as to the terms on which, if they shall think fit, a new
Share warrant or coupon may be issued by way of renewal in case of
defacement, loss, or destruction.
55. The Company may, by special resolution as prescribed by the Act, reduce in Reduction of
any manner and in accordance with the provisions of the Act and the Rules, — capital
(a) its share capital; and/or
(b) any capital redemption reserve account; and/or
(c) any securities premium account; and/or
(d) any other reserve in the nature of share capital.
56. Where two or more persons are registered as joint holders (not more than three) Joint holders
of any share, they shall be deemed (so far as the Company is concerned) to hold
the same as joint tenants with benefits of survivorship, subject to the following
and other provisions contained in these Articles:
(a) The joint-holders of any share shall be liable severally as well as jointly Liability of Joint
for and in respect of all calls or instalments and other payments which holders
ought to be made in respect of such share.
(b) On the death of any one or more of such joint-holders, the survivor or Death of one or
survivors shall be the only person or persons recognized by the Company more joint-holders
as having any title to the share but the Board may require such evidence of
death as they may deem fit, and nothing herein contained shall be taken to
release the estate of a deceased joint-holder from any liability on shares
held by him jointly with any other person.
(c) Any one of such joint holders may give effectual receipts of any dividends, Receipt of one
interests or other moneys payable in respect of such share. Sufficient
(d) Only the person whose name stands first in the register of members as one Delivery of
of the joint-holders of any share shall be entitled to the delivery of certificate and
certificate, if any, relating to such share or to receive notice (which term giving of notice to
shall be deemed to include all relevant documents) and any notice served first named holder
on or sent to such person shall be deemed service on all the joint-holders.
(e) (i) Any one of two or more joint-holders may vote at any meeting either Vote of joint
personally or by attorney or by proxy in respect of such shares as if he were holders
solely entitled thereto and if more than one of such joint holders be present
at any meeting personally or by proxy or by attorney then that one of such
persons so present whose name stands first or higher (as the case may be)
on the register in respect of such shares shall alone be entitled to vote in
respect thereof.
(ii) Several executors or administrators of a deceased member in whose Executors or
(deceased member) sole name any share stands, shall for the purpose of this administrators as
clause be deemed joint-holders. joint holders
(f) The provisions of these Articles relating to joint holders of shares shall Provisions as to
mutatis mutandis apply to any other securities including debentures of the joint holders as to
Company registered in joint names. shares to apply
mutatis mutandis
to debentures, etc.
Capitalization of profits
57. (1) The Company by ordinary resolution in general meeting may, upon the Capitalization
recommendation of the Board, resolve —
(a) that it is desirable to capitalize any part of the amount for the time being
standing to the credit of any of the Company’s reserve accounts, or to the
credit of the profit and loss account, or otherwise available for distribution;
and
(b) that such sum be accordingly set free for distribution in the manner
specified in clause (2) below amongst the members who would have been
entitled thereto, if distributed by way of dividend and in the same
proportions.
(2) The sum aforesaid shall not be paid in cash but shall be applied, subject to the Sum how applied
provision contained in clause (3) below, either in or towards:
681(A) paying up any amounts for the time being unpaid on any shares held by
such members respectively;
(B) paying up in full, unissued shares or other securities of the Company to
be allotted and distributed, credited as fully paid-up, to and amongst such
members in the proportions aforesaid;
(C) partly in the way specified in sub-clause (A) and partly in that specified
in sub-clause (B).
(3) Subject to the provisions of the act, securities premium account , a capital Source of issue of
redemption reserve account or free reserves , for the purposes of this Article, be bonus issue
applied in the paying up of unissued shares to be issued to members of the
Company as fully paid bonus shares;
(4) The Board shall give effect to the resolution passed by the Company in Articles to be
pursuance of these Article. considered at the
time of passing of
Resolution
58. (1) Whenever such a resolution as aforesaid shall have been passed, the Board shall Powers of the
– Board for
capitalization
(a) make all appropriations and applications of the amounts resolved to be
capitalized thereby, and all allotments and issues of fully paid shares or
other securities, if any; and
(b) generally do all acts and things required to give effect thereto.
(2) The Board shall have power— Board’s power to
issue fractional
(a) to make such provisions, by the issue of fractional certificates/coupons certificate/ coupon
and may fix the value for distribution of any specific assets, and may etc.
determine that such cash payments shall be made to any members upon
the footing of the value so fixed or that fraction of value less than Rs.10/-
(Rupees Ten Only) may be disregarded in order to adjust the rights of all
parties, and may vest any such cash or specific assets in trustees upon
such trusts for the person entitled to the dividend or capitalised funds, as
may seem expedient to the Board. Where requisite, a proper contract shall
be delivered to the Registrar for registration in accordance with Section
75 of the Act and the Board may appoint any person to sign such contract,
on behalf of the persons entitled to the dividend or capitalised fund, and
such appointment shall be effective. or by payment in cash or otherwise
as it thinks fit, for the case of shares or other securities becoming
distributable in fractions; and
(b) to authorize any person to enter, on behalf of all the members entitled
thereto, into an agreement with the Company providing for the allotment
to them respectively, credited as fully paid-up, of any further shares or
other securities to which they may be entitled upon such capitalization, or
as the case may require, for the payment by the Company on their behalf,
by the application thereto of their respective proportions of profits
resolved to be capitalized, of the amount or any part of the amounts
remaining unpaid on their existing shares.
(3) Any agreement made under such authority shall be effective and binding on Agreement binding
such members. on members
(4) A general meeting may resolve that any surplus moneys arising from the Surplus money to
realisation of any capital assets of the Company, or any investments be distributed to
representing the same, or any other undistributed profits of the Company, not the members
subject to charge for income tax, be distributed among the members on the
footing that they receive the same as capital.
Buy-back of shares
59. Notwithstanding anything contained in these Articles but subject to all Buy-back of shares
applicable provisions of the Act or any other Applicable Laws for the time being
in force, the Company may purchase its own shares or other specified securities.
The Company may purchase its own Shares or other specified securities out of
free reserves, the securities premium account or the proceeds of issue of any
Share or specified securities.
682Subject to the provisions contained in sections 68 to 70 and all applicable
provisions of the Act and subject to such approvals, permissions, consents and
sanctions from the concerned authorities and departments, including the SEBI,
Registrar and the Reserve Bank of India, if any, the Company may, by passing
a special resolution at a general meeting, purchase its own Shares or other
specified securities from its existing Shareholders on a proportionate basis
and/or from the open market and/or from the lots smaller than market lots of the
securities (odd lots), and/or the securities issued to the employees of the
Company pursuant to a scheme of stock options or sweat Equity, from out of
its free reserves or out of the securities premium account of the Company or out
of the proceeds of any issue made by the Company specifically for the purpose,
on such terms, conditions and in such manner as may be prescribed by law from
time to time; provided that the aggregate of the securities so bought back shall
not exceed such number as may be prescribed under the Act or Rules made from
time to time.
General meetings
60. All general meetings other than annual general meeting shall be called Extraordinary
extraordinary general meeting. general meeting
61. The Board may, whenever it thinks fit, call an extraordinary general meeting. Powers of Board to
call extraordinary
general meeting
61A The Board may, whenever it thinks fit, call an Extra-ordinary General Meeting Calling of Extra-
and it shall do so upon a requisition, in writing, by any member or members ordinary General
holding, in aggregate not less than one-tenth or such other proportion or value, Meeting
as may be prescribed, from time to time, under the Act, of such of the paid-up
capital as at that date carries the right of voting in regard to the matter, in respect
of which the requisition has been made.
Any valid requisition so made by the members must state the object or objects
of the meeting proposed to be called, and must be signed by the requisitionists
and be deposited at the office, provided that such requisition may consist of
several documents, in like form, each of which has been signed by one or
more requisitionists.
Upon receipt of any such requisition, the Board shall forthwith call an Extra-
ordinary General Meeting and if they do not proceed within 21 (Twenty-one)
days or such other lessor period, as may be prescribed, from time to time, under
the Act, from the date of the requisition, being deposited at the office, to cause
a meeting to be called on a day not later than 45 (Forty-five) days or such other
lessor period, as may be prescribed, from time to time, under the Act, from the
date of deposit of the requisition, the requisitionists, or such of their number as
represent either a majority in value of the paid up Share capital held by all of
them or not less than one-tenth of such of the paid up Share Capital of the
Company as is referred to in Section 100(4) of the Act, whichever is less, may
themselves call the meeting, but, in either case, any meeting so called shall be
held within 3 (Three) months or such other period, as may be prescribed, from
time to time, under the Act, from the date of the delivery of the requisition as
aforesaid.
Any meeting called under the foregoing Articles by the requisitionists shall be
called in the same manner, as nearly as possible as that in which such meetings
are to be called by the Board.
Proceedings at general meetings
62. No business shall be transacted at any general meeting unless a quorum of Presence of
members is present at the time when the meeting proceeds to business. Quorum
63. No business shall be discussed or transacted at any general meeting except Business confined
election of Chairperson whilst the chair is vacant. to election of
Chairperson whilst
chair vacant
63 (A) Not more than 15 (Fifteen) months or such other period, as may be prescribed, Gap between two
from time to time, under the Act, shall lapse between the date of one Annual Annual General
General Meeting and that of the next. Nothing contained in the foregoing Meetings
provisions shall be taken as affecting the right conferred upon the Registrar
under the provisions of the Act to extend time within which any Annual General
Meeting may be held.
68363 (B) Every Annual General Meeting shall be called for a time during business hours Time for Annual
i.e., between 9 a.m. and 6 p.m., on a day that is not a National Holiday, and shall General Meeting
be held at the Office of the Company or at some other place within the city, in
which the Office of the Company is situated, as the Board may think fit and
determine and the notices calling the Meeting shall specify it as the Annual
General Meeting.
At least 21 (Twenty-one) days’ notice, of every general meeting, Annual or Dispatch of
Extra-ordinary, and by whomsoever called, specifying the day, date, place and documents before
hour of meeting, and the general nature of the business to be transacted there at, Annual General
shall be given in the manner hereinafter provided, to such persons as are under Meeting
these Articles entitled to receive notice from the Company, provided that in the
case of an General Meeting, with the consent of members holding not less than
95 per cent of such part of the paid up Share Capital of the Company as gives a
right to vote at the meeting, a meeting may be convened by a shorter notice. In
the case of an Annual General Meeting of the Shareholders of the Company, if
any business other than
(i) the consideration of the Accounts, Balance Sheet and Reports of
the Board and the Auditors thereon
(ii) the declaration of dividend,
(iii) appointment of directors in place of those retiring,
(iv) the appointment of, and fixing the remuneration of, the Auditors,
is to be transacted, and in the case of any other meeting, in respect of any item
of business, a statement setting out all material facts concerning each such item
of business, including, in particular, the nature and extent of the interest, if any,
therein of every director and manager, if any, where any such item of special
business relates to, or affects any other company, the extent of shareholding
interest in that other company or every director and manager, if any, of the
Company shall also be set out in the statement if the extent of such Share-
holding interest is not less than such percent, as may be prescribed, from time
to time, under the Act, of the paid-up Share Capital of that other Company.
Where any item of business consists of the according of approval of the
members to any document at the meeting, the time and place, where such
document can be inspected, shall be specified in the statement aforesaid.
The accidental omission to give any such notice as aforesaid to any of the
members, or the non-receipt thereof shall not invalidate any resolution passed
at any such meeting.
No general meeting, whether Annual or Extra-ordinary, shall be competent to
enter upon, discuss or transact any business which has not been mentioned in
the notice or notices upon which it was convened.
64. The quorum for a general meeting shall be as provided in the Act. Quorum for
general meeting
65. If at any meeting no director is willing to act as Chairperson or if no director is Members to elect a
present within fifteen minutes after the time appointed for holding the meeting, Chairperson
the members present shall, by poll or electronically, choose one of their
members to be Chairperson of the meeting.
66. On any business at any general meeting, in case of an equality of votes, whether Casting vote of
on a show of hands or electronically or on a poll, the Chairperson shall have a Chairperson at
second or casting vote. general meeting
67. (1) The Company shall cause minutes of the proceedings of every general meeting Minutes of
of any class of members or creditors and every resolution passed by postal ballot proceedings of
to be prepared and signed in such manner as may be prescribed by the Rules meetings and
and kept by making within thirty days of the conclusion of every such meeting resolutions passed
concerned or passing of resolution by postal ballot entries thereof in books kept by postal ballot
for that purpose with their pages consecutively numbered.
(2) There shall not be included in the minutes any matter which, in the opinion of Certain matters not
the Chairperson of the meeting – to be included in
(a) is, or could reasonably be regarded, as defamatory of any person; or Minutes
(b) is irrelevant or immaterial to the proceedings; or
684(c) is detrimental to the interests of the Company.
(3) The Chairperson shall exercise an absolute discretion in regard to the inclusion Discretion of
or non-inclusion of any matter in the minutes on the grounds specified in the Chairperson in
aforesaid clause. relation to Minutes
(4) The minutes of the meeting kept in accordance with the provisions of the Act Minutes to be
shall be evidence of the proceedings recorded therein. Evidence
68. (1) The books containing the minutes of the proceedings of any general meeting of Inspection of
the Company or a resolution passed by postal ballot shall: minute books of
general meeting
(a) be kept at the registered office of the Company; and
(b) be open to inspection of any member without charge, during business
hours on all working days.
(2) A body corporate, being a member, shall be deemed to be personally present, When body
if it is represented in accordance with and in the manner as may be prescribed corporate is
by, the applicable provisions of the Act. member of the
company
(3) Any member shall be entitled to be furnished, within the time prescribed by the Members may
Act, after he has made a request in writing in that behalf to the Company and obtain copy of
on payment of such fees as may be fixed by the Board, with a copy of any minutes
minutes referred to in clause (1) above.
Adjournment of meeting
69. (1) The Chairman, with the consent of the meeting, may adjourn any meeting, from Chairperson may
time to time, and from place to place, in the city or town, in which the office of adjourn the
the Company is situated meeting
(2) No business shall be transacted at any adjourned meeting other than the business Business at
left unfinished at the meeting from which the adjournment took place. adjourned meeting
(3) If, at the expiration of half an hour from the time appointed for holding a Adjournment in
meeting of the Company, a quorum shall not be present, then the meeting, if case quorum is not
convened by or upon the requisition of members, shall stand dissolved, but in present
any other case, it shall stand adjourned meeting also, a quorum is not present,
at the expiration of half an hour from the time appointed for holding the
meeting, the members present shall be a quorum, and may transact the business
for which the meeting was called adjourned to such time on the following day
or such other day and to such place, as the Board may determine, and, if no such
time and place be determined, to the same day in the next week, at the same
time and place in the city or town in which the office of the Company is, for the
time being, situate, as the Board may determine, and, if at such
(4) When a meeting is adjourned for thirty days or more, notice of the adjourned Notice of adjourned
meeting shall be given as in the case of an original meeting. meeting
(5) Save as aforesaid, and save as provided in the Act, it shall not be necessary to Notice of adjourned
give any notice of an adjournment or of the business to be transacted at an meeting not
adjourned meeting. required
Voting rights
70. Subject to any rights or restrictions for the time being attached to any class or Entitlement to vote
classes of shares - on show of hands
and on poll
(a) on a show of hands, every member present in person shall have one vote;
and
(b) on a poll, the voting rights of members shall be in proportion to his share
in the paid-up Equity Share capital of the company.
(c) every member, not disqualified by these articles shall be entitled to be
present, speak and vote at such meeting, and, on a show of hands, every
member, present in person
(d) Provided, however, if any preference Shareholder be present at any meeting
of the Company, subject to the provision of section 47, he shall have a right to
vote only on resolutions, placed before the meeting, which directly affect the
rights attached to his Preference Shares.
71. A member may exercise his vote at a meeting by electronic means in accordance Voting through
with the Act and shall vote only once. electronic means
(The Company shall also provide e-voting facility to the Shareholders of the
Company in terms of the provisions of the Companies (Management and
685Administration) Rules, 2014, the SEBI Listing Regulations or any other Law,
if applicable to the Company
72. (1) In the case of joint holders, the vote of the senior who tenders a vote, whether Vote of joint
in person or by proxy, shall be accepted to the exclusion of the votes of the other holders, proxy
joint holders.
The proxy so appointed shall not have any right to speak at the meeting.
Several executors or administrators of a deceased member in whose name
Shares stand shall, for the purpose of these Articles, be deemed joint holders
thereof.
(2) For this purpose, seniority shall be determined by the order in which the names Seniority of names
stand in the register of members.
Such person shall alone be entitled to speak and to vote in respect of such
Shares, but the other of the joint holders shall be entitled to be present at the
meeting.
73. A member of unsound mind, or in respect of whom an order has been made by How members non
any court having jurisdiction in lunacy, may vote, whether on a show of hands compos mentis and
or on a poll, by his committee or other legal guardian, and any such committee minor may vote
or guardian may, on a poll, vote by proxy. If any member be a minor, the vote
in respect of his share or shares shall be by his guardian or any one of his
guardians.
74. Any business other than that upon which a poll has been demanded may be Voting by poll
proceeded with, pending the taking of the poll.
At any general meeting, a resolution put to the vote of the meeting shall be
decided on a show of hands, unless a poll is demanded, before or on the
declaration of the result of the show of hands, by any member or members
present in person or by proxy and holding Shares in the Company, which confer
a power to vote on the resolution not being less than one-tenth or such other
proportion as may statutorily be prescribed, from time to time, under the Act,
of the total voting power, in respect of the resolution or on which an aggregate
sum of not less than Rs. 500,000/- or such other sum as may statutorily be
prescribed, from time to time, under the Act, has been paid up, and unless a poll
is demanded, a declaration by the Chairman that a resolution has, on a show of
hands, been carried unanimously or by a particular majority, or has been lost
and an entry to that effect in the minutes book of the Company shall be
conclusive evidence of the fact, without proof of the number or proportion of
the votes recorded in favour of or against that resolution.
If a poll is demanded as aforesaid, the same shall subject to the clause herein
with respect to the election of chairman and question of adjournment of meeting
hereunder, be taken at such place as may be decided by the Board, at such time
not later than 48 (Forty-eight) hours from the time when the demand was made
and place in the city or town in which the office of the Company is, for the time
being, situated, and, either by open voting or by ballot, as the Chairman shall
direct, and either at once or after an interval or adjournment, or otherwise, and
the result of the poll shall be deemed to be resolution of the meeting at which
the poll was demanded. The demand for a poll may be withdrawn at any time
by the persons, who made the demand.
Where a poll is to be taken, the Chairman of the meeting shall appoint one or,
at his discretion, two scrutinisers, who may or may not be members of the
Company to scrutinise the votes given on the poll and to report thereon to him,
subject to that one of the scrutinisers so appointed shall always be a member,
not being an officer or employee of the Company, present at the meeting,
provided that such a member is available and willing to be appointed. The
Chairman shall have power, at any time, before the result of the poll is declared,
to remove a scrutiniser from office and fill the vacancy so caused in the office
of a scrutiniser arising from such removal or from any other cause.
Any poll duly demanded on the election of a Chairman of a meeting or on any
question of adjournment of the meeting shall be taken forthwith at the same
meeting.
The demand for a poll, except on questions of the election of the Chairman and
of an adjournment thereof, shall not prevent the continuance of a meeting for
the transaction of any business other than the question on which the poll has
been demanded.
686On a poll taken at a meeting of the Company, a member entitled to more than
one vote, or his proxy or other person entitled to vote for him, as the case may
be, need not, if he votes, use all his votes or cast in the same way all the votes,
he uses
No objections shall be made to the validity of any vote, except at any meeting
or poll at which such vote shall be tendered, and every vote, whether given
personally or by proxy, or not disallowed at such meeting or on a poll, shall be
deemed as valid for all purposes of such meeting or a poll whatsoever.
75. No member shall be entitled to vote at any general meeting unless all calls or Restriction on
other sums presently payable by him in respect of shares in the Company have voting rights
been paid or in regard to which the Company has exercised any right of Lien.
76. A member is not prohibited from exercising his voting on the ground that he Restriction on
has not held his share or other interest in the Company for any specified period exercise of voting
preceding the date on which the vote is taken, or on any other ground not being rights in other cases
a ground set out in the preceding Article. to be void
77. Any member whose name is entered in the register of members of the Company Equal rights of
shall enjoy the same rights and be subject to the same liabilities as all other members
members of the same class.
Proxy
78. (1) Any member entitled to attend and vote at a general meeting may do so either Member may vote
personally or through his constituted attorney or through another person as a in person or
proxy on his behalf, for that meeting. otherwise
A member, present by proxy, shall be entitled to vote only on a poll.
(2) The instrument appointing a proxy and the power-of attorney or other authority, Proxies when to be
if any, under which it is signed or a notarized copy of that power or authority, deposited
shall be deposited at the registered office of the Company not less than 48 hours
before the time for holding the meeting or adjourned meeting at which the
person named in the instrument proposes to vote, and in default the instrument
of proxy shall not be treated as valid.
No instrument appointing a proxy shall be a valid after the expiration of 12
(Twelve) months or such other period as may be prescribed under the Laws, for
the time being, in force, or if there shall be no law, then as may be decided by
the Directors, from the date of its execution.
79. An instrument of Proxy may state the appointment of a proxy either for the Form of proxy
purpose of a particular meeting specified in the instrument and any adjournment
thereof or it may appoint for the purpose of every meeting of the Company or
of every meeting to be held before a date specified in the instrument and every
adjournment of any such meeting. An instrument appointing a proxy shall be in
the form as prescribed in the Rules.
Every Instrument of proxy, whether for a specified meeting or otherwise, shall,
as nearly as circumstances thereto will admit, be in any of the forms as may be
prescribed from time to time
80. A vote given in accordance with the terms of an instrument of proxy shall be Proxy to be valid
valid, notwithstanding the previous death or insanity of the principal or the notwithstanding
revocation of the proxy or of the authority under which the proxy was executed, death of the
or the transfer of the shares in respect of which the proxy is given: principal
Provided that no intimation in writing of such death, insanity, revocation or
transfer shall have been received by the Company at its office before the
commencement of the meeting or adjourned meeting at which the proxy is used.
80 (A) Every proxy, whether a member or not, shall be appointed, in writing, under the Manner of
hand of the appointer or his attorney, or if such appointer is a body corporate appointment of
under the common seal of such corporate, or be signed by an officer or officers proxy
or any attorney duly authorised by it or them, and, for a member of unsound
mind or in respect of whom an order has been made by a court having
jurisdiction in lunacy, any committee or guardian may appoint such proxy.
Board of Directors
81. Unless otherwise determined by the Company in general meeting, the number Board of Directors
of directors shall not be less than 3 (three) and shall not be more than fifteen
(fifteen), provided that the Company may appoint more than fifteen directors
after passing a special resolution. The Company shall have at the minimum such
number of independent Directors on the Board of the Company, as may be
required in terms of the provisions of applicable law. In addition, not less than
two-thirds of the total number of Directors shall be persons whose period of
687office is liable to determination by retirement of Directors by rotation. The
Company shall also comply with the provisions of the Companies
(Appointment and Qualification of Directors) Rules, 2014 and the provisions of
the SEBI Listing Regulations.
The Company shall have such number of Independent Directors on the Board
or Committees of the Board of the Company, as may be required in terms of the
provisions of Section 149 of the Act and the Companies (Appointment and
Qualification of Directors) Rules, 2014, SEBI Listing Regulations or any other
Law, as may be applicable. Further, the appointment of such Independent
Directors shall be in terms of the aforesaid provisions of Law and subject to the
requirements prescribed under the SEBI Listing Regulations.
81A The Directors shall not be required to hold any qualification shares in the Qualification
Company. shares
82. (1) The Board of Directors shall appoint the Chairperson of the Company. Chairperson and
Managing Director
The same individual may, at the same time, be appointed as the Chairperson as
well as the Managing Director of the Company.
(2) At every Annual General Meeting of the Company, one-third of such of the Directors liable to
Directors, for the time being, as are liable to retire by rotation or if their number retire by rotation
is not three or a multiple of three, the number nearest to one-third shall retire
from Office. The Independent, Nominee, Special and Debenture Directors
Managing Directors, if any, shall not be subject to retirement under this clause
and shall not be taken into account in determining the rotation of retirement or
the number of directors to retire, subject to Section 152 and other applicable
provisions, if any, of the Act.
If the Managing Director ceases to hold the office of director, he shall ipso-
facto and forthwith ceases to hold the office of Managing Director.
Subject to Section 152 of the Act, the directors, liable to retire by rotation, at
every annual general meeting, shall be those, who have been longest in Office
since their last appointment, but as between the persons, who became Directors
on the same day, and those who are liable to retire by rotation, shall, in default
of and subject to any agreement among themselves, be determined by lot.
A retiring director shall be eligible for re-election and shall act as a director
throughout the meeting at which he retires.
Subject to Section 152 of the Act, the Company, at the general meeting at which
a director retires in manner aforesaid, may fill up the vacated Office by electing
a person thereto.
If the place of retiring director is not so filled up and further the meeting has
not expressly resolved not to fill the vacancy, the meeting shall stand adjourned
till the same day in the next week, at the same time and place or if that day is a
public holiday, till the next succeeding day, which is not a public holiday, at the
same time and place.
If at the adjourned meeting also, the place of the retiring director is not filled up
and that meeting also has not expressly resolved not to fill the vacancy, the
retiring director shall be deemed to have been re-appointed at the adjourned
meetings, unless:-
(a) at that meeting or at the previous meeting, resolution for the re-
appointment of such director has been put to the meeting and lost;
(b) the retiring director has, by a notice, in writing, addressed to the
Company or its Board, expressed his unwillingness to be so re-appointed;
(c) he is not qualified, or is disqualified, for appointment.
(d) a resolution, whether special or ordinary, is required for the
appointment or reappointment by virtue of any provisions of the Act; or
(e) Section 162 of the Act is applicable to the case.
83. (1) The remuneration of the directors shall, in so far as it consists of a monthly Remuneration of
payment, be deemed to accrue from day-to-day. Directors
(2) The remuneration payable to the directors, including manager, if any, shall be Remuneration to
determined in accordance with and subject to the provisions of the Act by an require members’
ordinary resolution passed by the Company in general meeting. consent
688(3) In addition to the remuneration payable to them in pursuance of the Act, the Travelling and
directors may be paid all travelling, hotel and other expenses properly incurred other expenses
by them—
(a) in attending and returning from meetings of the Board of Directors or
any committee thereof or general meetings of the Company; or
(b) in connection with the business of the Company.
(c) and if any director be called upon to go or reside out of the ordinary place
of his residence for the Company’s business, he shall be entitled to be repaid
and reimbursed of any travelling or other expenses incurred in connection with
business of the Company. The Board may also permit the use of the Company’s
car or other vehicle, telephone(s) or any such other facility, by the director, only
for the business of the Company.
(4) Subject to the provisions of these Articles and the provisions of the Act, the Sitting Fees
Board may, decide to pay a Director out of funds of the Company by way of
sitting fees, within the ceiling prescribed under the Act, a sum to be determined
by the Board for each meeting of the Board or any committee or sub-committee
thereof attended by him in addition to his traveling, boarding and lodging and
other expenses incurred
Appointment and Remuneration of Directors
84. Subject to the provisions of section 196, 197 and read with schedule V of the Appointment
Companies Act, 2013 and other provisions of the Act, the Rules, Law including
the provisions of the SEBI Listing Regulations, and these Articles, the Board of
Directors, may from time to time, appoint one or more of the Directors to be
Managing Director or Managing Directors or other whole-time Director(s) of
the Company, for a term not exceeding five years at a time and may, from time
to time, (subject to the provisions of any contract between him or them and the
Company) remove or dismiss him or them from office and appoint another or
others in his or their place or places and the remuneration of Managing or
Whole-Time Director(s) by way of salary and commission or paid remuneration
either by way of a monthly payment or at a specified percentage of the net
profits of the Company or partly by one way and partly by the other, or in any
other manner, as may be, from time to time, permitted under the Act or as may
be thought fit and proper by the Board or, if prescribed under the Act, by the
Company in general meeting. The Board shall have the power to pay
remuneration to such director for his services rendered.
Subject to the superintendence, directions and control of the Board, the
Managing Director or Managing Directors shall exercise the powers, except to
the extent mentioned in the matters, in respect of which resolutions are required
to be passed only at the meeting of the Board, under Section 179 of the Act and
the rules made thereunder
85. Subject to the provisions of the Act, the Board shall appoint Independent Independent
Directors, who shall have appropriate experience and qualifications to hold a Director
position of this nature on the Board.
86. (1) Subject to the provisions of section 196, 197 and 188 read with Schedule V to Remuneration
the Act, the Directors shall be paid such further remuneration, whether in the
form of monthly payment or by a percentage of profit or otherwise, as the
Company in General meeting may, from time to time, determine and such
further remuneration shall be divided among the Directors in such proportion
and in such manner as the Board may, from time to time, determine and in
default of such determination shall be divided among the Directors equally or
if so determined paid on a monthly basis.
(2) Subject to the provisions of these Articles, and the provisions of the Act, if any Payment for Extra
Director, being willing, shall be called upon to perform extra service or to make Service
any special exertions in going or residing away from the place of his normal
residence for any of the purposes of the Company or has given any special
attendance for any business of the Company, the Company may remunerate the
Director so doing either by a fixed sum or otherwise as may be determined by
the Director
87. All cheques, promissory notes, drafts, hundis, bills of exchange and other Execution of
negotiable instruments, and all receipts for monies paid to the Company, shall negotiable
be signed, drawn, accepted, endorsed, or otherwise executed, as the case may instruments
be, by such person and in such manner as the Board shall from time to time by
resolution determine.
68988. (1) Subject to the provisions of the Act, the Board shall have power at any time, Appointment of
and from time to time, to appoint a person as an additional director, provided additional directors
the number of the directors and additional directors together shall not at any
time exceed the maximum strength fixed for the Board by the Articles.
(2) Such person shall hold office only up to the date of the next annual general Duration of office
meeting of the Company but shall be eligible for appointment by the Company of additional
as a director at that meeting subject to the provisions of the Act. director
89. (1) The Board may appoint an alternate director to act for a director (hereinafter in Appointment of
this Article called “the Original Director”) during his absence for a period of alternate director
not less than three months from India. No person shall be appointed as an
alternate director for an independent director unless he is qualified to be
appointed as an independent director under the provisions of the Act.
(2) An alternate director shall not hold office for a period longer than that Duration of office
permissible to the Original Director in whose place he has been appointed and of alternate
shall vacate the office if and when the Original Director returns to India director
(3) If the term of office of the Original Director is determined before he returns to Re-appointment
India the automatic reappointment of retiring directors in default of another provisions
appointment shall apply to the Original Director and not to the alternate applicable to
director. Original Director
90. (1) If the office of any director appointed by the Company in general meeting is Appointment of
vacated before his term of office expires in the normal course, the resulting director to fill a
casual vacancy may, be filled by the Board of Directors at a meeting of the casual vacancy
Board.
(2) The director so appointed shall hold office only up to the date upto which the Duration of office
director in whose place he is appointed would have held office if it had not been of Director
vacated. appointed to fill
casual vacancy
(3) The office of director shall be vacated, pursuant to the provisions of section 164 Manner of vacation
and section 167 of the Companies Act, 2013. Further, the Director may resign of office of director
his office by giving notice to the Company pursuant to section 168 of the
Companies Act, 2013
Subject to the provisions of Section 149 of the Act, the Company may, by
special resolution, from time to time, increase or reduce the number of directors,
and may alter their qualifications and the Company may, subject to the
provisions of Section 169 of the Act, remove any director before the expiration
of his period of Office and appoint another qualified person in his stead. The
person so appointed shall hold Office during such time as the director, in whose
place he is appointed, would have held, had he not been removed.
(4) If it is provided by the Trust Deed, securing or otherwise, in connection with Debenture Director
any issue of Debentures of the Company, that any person or persons shall have
power to nominate a director of the Company, then in the case of any and every
such issue of Debentures, the person or persons having such power may
exercise such power, from time to time, and appoint a director accordingly. Any
director so appointed is hereinafter referred to as “the Debenture Director”. A
Debenture Director may be removed from Office, at any time, by the person or
persons in whom, for the time being, is vested the power, under which he was
appointed, and another director may be appointed in his place. A Debenture
Director shall not be required to hold any qualification Share(s) in the
Company.
690(5) (i) No person, not being a retiring director, shall be eligible for Right of Persons
appointment to the office of director at any general meeting unless he or some Other than retiring
member, intending to propose him, has, not less than 14 (Fourteen) days or such Directors to Stand
other period, as may be prescribed, from time to time, under the Act, before the for Directorship
meeting, left at the Office of the Company, a notice, in writing, under his hand,
signifying his candidature for the Office of director or an intention of such
member to propose him as a candidate for that office, along with a deposit of
Rupees One lakh or such other amount as may be prescribed, from time to time,
under the Act, which shall be refunded to such person or, as the case may be, to
such member, if the person succeeds in getting elected as a director or gets more
than twenty-five per cent of total valid votes cast either on show of hands or on
poll on such resolution.
(ii) Every person, other than a director retiring by rotation or otherwise
or a person who has left at the Office of the Company a notice under Section
160 of the Act signifying his candidature for the Office of a director, proposed
as a candidate for the Office of a director shall sign and file with the Company,
the consent, in writing, to act as a director, if appointed.
(iii) A person, other than a director re-appointed after retirement by
rotation immediately on the expiry of his term of Office, or an Additional or
Alternate Director, or a person filling a casual vacancy in the Office of a director
under Section 161 of the Act, appointed as a director or reappointed as a director
immediately on the expiry of his term of Office, shall not act as a director of the
Company, unless he has, within thirty days of his appointment, signed and filed
with the Registrar his consent, in writing, to act as such director.
(6) The Company shall keep at its Office a Register containing the particulars of its
directors and key managerial personnel and their shareholding as mentioned in Register of
Section 170 of the Act, and shall otherwise comply with the provisions of the Directors and key
said Section in all respects. Managerial
Personnel and their
Every director and Key Managerial Personnel within a period of thirty days of Shareholding
his appointment, or relinquishment of his office, as the case may be, disclose to
the company the particulars specified in sub-section (1) of section 184 relating
to his concern or interest in any company or companies or bodies corporate
(including shareholding interest), firms or other association which are required
to be included in the register under that section 189 of the Companies Act, 2013.
(7) (iii) Subject to the provisions of the Act, a director, who is neither in the Remuneration of
Whole-time employment nor a Managing Director, may be paid remuneration director who is
either; neither in the
Whole-time
(a) by way of monthly, quarterly or annual payment with the approval of employment nor a
the Central Government; or Managing Director
(b) by way of commission, if the Company, by a special resolution,
authorises such payment.
(iv) The fee payable to a director, excluding a Managing or Whole time
Director, if any, for attending a meeting of the Board or Committee thereof shall
be such sum, as the Board may, from time to time, determine, but within and
subject to the limit prescribed by the Central Government pursuant to the
provisions, for the time being, under the Act.
Powers of Board
91. (1) The management of the business of the Company shall be vested in the Board General powers of
and the Board may exercise all such powers, and do all such acts and things, as the Company
the Company is by the Memorandum or otherwise authorized to exercise and vested in Board
do, and, not hereby or by the statute or otherwise directed or required to be
exercised or done by the Company in general meeting but subject nevertheless
to the provisions of the Act and other Applicable Laws and of the Memorandum
and these Articles and to any regulations, not being inconsistent with the
Memorandum and these Articles or the Act, from time to time made by the
Company in general meeting provided that no such regulation shall invalidate
any prior act of the Board which would have been valid if such regulation had
not been made.
(2) Without prejudice to the general powers as well as those under the Act, and so Powers of the
as not in any way to limit or restrict those powers, and without prejudice to the Board
other powers conferred by these Articles or otherwise, it is hereby declared that
the Directors shall have, inter alia, the following powers, that is to say, power -
691(i) to pay the costs, charges and expenses, preliminary and incidental to
the promotion, formation, establishment and registration of the Company;
(ii) to pay and charge, to the account of the Company, any commission
or interest lawfully payable thereon under the provision of the Act;
(iii) subject to the provisions of the Act, to purchase or otherwise acquire
for the Company any property, rights or privileges, which the Company is
authorised to acquire, at or for such price or consideration and generally on such
terms and conditions as they may think fit and being in the interests of the
Company, and in any such purchase or other acquisition to accept such title or
to obtain such right as the directors may believe or may be advised to be
reasonably satisfactory;
(iv) at their discretion and subject to the provisions of the Act, to pay for
any property, right or privileges acquired by or services rendered to the
Company, either wholly or partially, in cash or in Shares, Bonds, Debentures,
mortgages, or other securities of the Company, and any such Shares may be
issued either as fully paid up, with such amount credited as paid up thereon, as
may be agreed upon, and any such bonds, Debentures, mortgages or other
securities may either be specifically charged upon all or any part of the
properties of the Company and its uncalled capital or not so charged;
(v) to secure the fulfilment of any contracts or engagement entered into
by the Company or, in the interests or for the purposes of this Company, by,
with or against any other Company, firm or person, by mortgage or charge of
all or any of the properties of the Company and its uncalled capital, for the time
being, or in such manner and to such extent as they may think fit;
(vi) to accept from any member, as far as may be permissible by law, a
surrender of his Shares or any part thereof, whether under buy-back or
otherwise, on such terms and conditions as shall be agreed mutually, and as may
be permitted, from time to time, under the Act or any other Law or the
Regulations, for the time being, in force,
(vii) to appoint any person to accept and hold in trust, for the Company,
any property belonging to the Company, in which it is interested, or for any
other purposes, and execute and do all such deeds and things as may be required
in relation to any trust, and to provide for the remuneration of such trustee or
trustees;
(viii) to institute, conduct, defend, compound or abandon any legal
proceedings by or against the Company or its Officers, or otherwise concerning
the affairs of the Company, and also to compound and allow time for payment
or satisfaction of any debts, due and of any differences to arbitration and
observe and perform any awards made thereon;
(ix) to act on behalf of the Company in all matters relating to bankruptcy
and insolvents;
(x) to make and give receipts, releases and other discharges for moneys
payable to the Company and for the claims and demands of the Company;
(xi) subject to the applicable provisions of the Act, to invest and deal with
any moneys of the Company not immediately required for the purposes thereof
upon such security, not being Shares of this Company, or without security and
in such manner, as they may think fit, and from time to time, to vary or realise
such investments, save as provided in Section 49 of the Act, all investments
shall be made and held in the Company’s own name;
(xii) to execute, in the name and on behalf of the Company, in favour of
any director or other person, who may incur or be about to incur any personal
liability whether as principal or surety, for the benefit or purposes of the
Company, such mortgages of the Company’s property, present and future, as
they may think fit, and any such mortgage may contain a power of sale and such
other powers, provisions, covenants and agreements as shall be agreed upon;
692(xiii) to determine from time to time, who shall be entitled to sign, on behalf
of the Company, bills, invoices, notes, receipts, acceptances, endorsements,
cheques, dividend warrants, releases, contracts and or any other document or
documents and to give the necessary authority for such purpose, and further to
operate the banking or any other kinds of accounts, maintained in the name of
and for the business of the Company;
(xiv) to distribute, by way of bonus, incentive or otherwise, amongst the
employees of the Company, a Share or Shares in the profits of the Company,
and to give to any staff, officer or others employed by the Company a
commission on the profits of any particular business or transaction, and to
charge any such bonus, incentive or commission paid by the Company as a part
of the operational expenditure of the Company;
(xv) to provide for the welfare of directors or ex-directors, Shareholders,
for the time being, or employees or ex-employees of the Company and their
wives, widows and families or the dependents or connections of such persons,
by building or contributing to the building of houses or dwellings, or grants of
moneys, whether as a gift or otherwise, pension, gratuities, allowances, bonus,
loyalty bonuses or other payments, also whether by way of monetary payments
or otherwise, or by creating and from time to time, subscribing or contributing
to provident and other association, institutions, funds or trusts and by providing
or subscribing or contributing towards places of worship, instructions and
recreation, hospitals and dispensaries, medical and other attendance and other
assistance, as the Board shall think fit, and to subscribe or contribute or
otherwise to assist or to guarantee money to charitable, benevolent, religious,
scientific, national or other institutions or objects, which shall have any moral
or other claim to support or aid by the Company, either by reason of locality or
place of operations, or of public and general utility or otherwise;
(xvi) before recommending any dividend, to set aside out of the profits of
the Company such sums, as the Board may think proper, for depreciation or to
a Depreciation Fund, or to an Insurance Fund, a Reserve Fund, Capital
Redemption Fund, Dividend Equalisation Fund, Sinking Fund or any Special
Fund to meet contingencies or to repay debentures or debenture-stock, or for
special dividends or for equalising dividends or for repairing, improving,
extending and maintaining any of the property of the Company and for such
other purposes, including the purposes referred to in the preceding clause, as
the Board may, in their absolute discretion, think conducive to the interests of
the Company and, subject to the provisions of the Act, to invest the several sums
so set aside or so much thereof, as required to be invested, upon such
investments, other than shares of the Company, as they may think fit, and from
time to time, to deal with and vary such investments and dispose of and apply
and expend all or any part thereof for the benefit of the Company, in such
manner and for such purposes, as the Board, in their absolute discretion, think
conducive to the interests of the Company, notwithstanding, that the matter, to
which the Board apply or upon which they expend the same, or any part thereof,
may be matters to or upon which the capital moneys of the Company might
rightly be applied or expended, and to divide the Reserve Fund into such special
funds, as the Board may think fit, with full power to transfer the whole or any
portion of a Reserve Fund or divisions of a Reserve Fund and with full powers
to employ the assets constituting all or any of the above funds, including the
Depreciation Fund, in the business of the Company or in the purchase of or
repayment of debentures or debenture stock and without being bound to keep
the same separate from the other assets and without being bound to pay interest
on the same with power however to the Board at their discretion to pay or allow
to the credit of such funds interest at such rate as the Board may think proper,
subject to the provisions of the applicable laws, for the time being, in force.
(xvii) to appoint and at their discretion, remove or suspend such general
managers, secretaries, assistants, supervisors, clerks, agents and servants or
other employees, in or for permanent, temporary or special services, as they
may, from time to time, think fit, and to determine their powers and duties and
to fix their salaries, emoluments or remuneration of such amount, as they may
think fit.
693(xviii) to comply with the requirements of any local laws, Rules or
Regulations, which, in their opinion, it shall, in the interests of the Company,
be necessary or expedient to comply with.
(xix) at any time, and from time to time, by power of attorney, under the
Seal of the Company, to appoint any person or persons to be the attorney or
attorneys of the Company, for such purposes and with such powers, authorities
and discretions, not exceeding those vested in or exercisable by the Board under
these presents and excluding the powers to make calls and excluding also except
in their limits authorised by the Board the power to make loans and borrow
moneys, and for such period and subject to such conditions as the Board may,
from time to time, think fit, and any such appointment may, if the Board thinks
fit, be made in favour of the members or in favour of any Company, or the
Share-holders, directors, nominees, or managers of any Company or firm or
otherwise in favour of any fluctuating body of persons whether nominated
directly or indirectly by the Board and any such Power of Attorney may contain
such powers for the protection of convenience of person dealing with such
Attorneys, as the Board may think fit, and may contain powers enabling any
such delegates all or any of the powers, authorities and discretions, for the time
being, vested in them;
(xx) Subject to the provisions of the Act, for or in relation to any of the
matters, aforesaid or otherwise, for the purposes of the Company, to enter into
all such negotiations and contracts and rescind and vary all such contracts, and
execute and do all such contracts, and execute and do all such acts, deeds and
things in the name and on behalf of the Company, as they may consider
expedient;
(xxi) from time to time, make, vary and repeal bylaws for the regulation of
the business of the Company, its Officers and Servants.
Proceedings of the Board
92. (1) The Board of Directors may meet for the conduct of business, adjourn and When meeting to be
otherwise regulate its meetings, as it thinks fit. convened
Provided, that the Board of Directors shall hold meetings at least once in every
three months and at least four times every calendar year in such a manner that
not more than one hundred and twenty days (120) days shall intervene between
two consecutive meetings of the Board.
(2) The Chairperson or any one Director with the previous consent of the Who may summon
Chairperson may, or the company secretary on the direction of the Chairperson Board meeting
shall, at any time, summon a meeting of the Board.
(3) The quorum for a Board meeting shall be as provided in the Act. Quorum for Board
meetings
Provided that where, at any time, the number of interested directors exceeds or
is equal to two-thirds of the total strength the number of the remaining directors,
that is to say, the number of directors who are not interested, present at the
meeting, being not less than two, shall be the quorum, during such time.
If a meeting of the Board could not be held for want of quorum, then the meeting
shall automatically stand adjourned for 30 minutes in the same day and at same
place.
A meeting of the Board, at which a quorum is present, shall be competent to
exercise all or any of the authorities, powers and discretions, which, by or under
the Act or the Articles of the Company, are, for the time being, vested in or
exercisable by the Board generally.
(4) The participation of directors in a meeting of the Board may be either in person Participation at
or through video conferencing or audio visual means or teleconferencing, which Board meetings
are capable of recording and recognising the participation of the directors and
of recording and storing the proceedings of such meetings along with date and
time subject to the rules as may be prescribed.
(5) At least 7 (seven) Days’ written notice shall be given in writing to every Notice of Board
Director by hand delivery or by speed-post or by registered post or by facsimile meetings
or by email or by any other electronic means, either (i) in writing, or (ii) by fax,
e-mail or other approved electronic communication, receipt of which shall be
confirmed in writing as soon as is reasonably practicable, to each Director,
setting out the agenda for the meeting in reasonable detail and attaching the
694relevant papers to be discussed at the meeting and all available data and
information relating to matters to be discussed at the meeting except as
otherwise agreed in writing by all the Directors.
Subject to the provisions of section 173(3) meeting may be called at shorter
notice.
93. (1) Subject to the restrictive provisions of any agreement or understanding as Questions at Board
entered into by the Company with any other person(s) such as the collaborators, meeting how
financial institutions, etc. and save as otherwise expressly provided in the Act, decided
questions arising at any meeting of the Board shall be decided by a majority of
votes.
(2) In case of an equality of votes, the Chairperson of the Board, if any, shall have Casting vote of
a second or casting vote. Chairperson at
Board meeting
94. The continuing directors may act notwithstanding any vacancy in the Board; Directors not to act
but, if and so long as their number is reduced below the quorum fixed by the when number falls
Act for a meeting of the Board, the continuing directors or director may act for below minimum
the purpose of increasing the number of directors to that fixed for the quorum,
or of summoning a general meeting of the Company, but for no other purpose.
95. (1) The Chairperson of the Company shall be the Chairperson at meetings of the Who to preside at
Board. In his absence, the Board may elect a Chairperson of its meetings and meetings of the
determine the period for which he is to hold office. Board
(2) If no such Chairperson is elected, or if at any meeting the Chairperson is not Directors to elect a
present within fifteen minutes after the time appointed for holding the meeting, Chairperson
the directors present may choose one of their number to be Chairperson of the
meeting
96. (1) The Board may, subject to the provisions of the Act, delegate any of its powers Delegation of
to Committees consisting of such member or members of its body as it thinks powers
fit.
(2) Any Committee so formed shall, in the exercise of the powers so delegated, Committee to
conform to any regulations that may be imposed on it by the Board. All acts conform to Board
done by any such committee of the Board, in conformity with such regulations, regulations
and in fulfilment of the purposes of their appointment but not otherwise, shall
have the like force and effect as if were done by the Board.
(3) The participation of directors in a meeting of the Committee may be either in Participation at
person or through video conferencing or audio visual means or Committee
teleconferencing, as may be prescribed by the Rules or permitted under meetings
Applicable Laws.
97. (1) A Committee may elect a Chairperson of its meetings unless the Board, while Chairperson of
constituting a Committee, has appointed a Chairperson of such Committee. Committee
(2) If no such Chairperson is elected, or if at any meeting the Chairperson is not Who to preside at
present within fifteen minutes after the time appointed for holding the meeting, meetings of
the members present may choose one of their members to be Chairperson of the Committee
meeting.
98. (1) A Committee may meet and adjourn as it thinks fit. Committee to meet
(2) Questions arising at any meeting of a Committee shall be determined by a Questions at
majority of votes of the members present. Committee meeting
how decided
(3) In case of an equality of votes, the Chairperson of the Committee shall have a Casting vote of
second or casting vote. Chairperson at
Committee meeting
99. The meetings and proceedings of any meeting of such Committee of the Board, Acts of Board or
consisting of two or more members, shall be governed by the provisions Committee valid
contained herein for regulating the meetings and proceedings of the meetings notwithstanding
of the directors, so far as the same are applicable thereto and are not superseded defect of
by any regulations made by the Directors under these Articles appointment
All acts done in any meeting of the Board or of a Committee thereof or by any
person acting as a director, shall, notwithstanding that it may be afterwards
discovered that there was some defect in the appointment of any one or more of
such directors or of any person acting as aforesaid, or that they or any of them
were disqualified or that his or their appointment had terminated, be as valid as
if every such director or such person had been duly appointed and was qualified
to be a director.
100. Save as otherwise expressly provided in the Act, a resolution in writing, signed Passing of
and has been circulated in draft, together with the necessary papers, if any, to resolution by
all the directors or to all the members of the Committee, then in India, not being Circulation
less in number than the quorum fixed for a meeting of the Board or Committee,
695as the case may be, and to all the directors or to all the members of the
Committee, at their usual addresses in India and has been approved, in writing,
by such of the directors or members of the Committee as are then in India, or
by a majority of such of them, as are entitled to vote on the resolution. whether
manually or by secure electronic mode, shall be valid and effective as if it had
been passed at a meeting of the Board or Committee, duly convened and held.
101. (1) Subject to the provisions of the Act, - Chief Executive
Officer, Manager,
A chief executive officer, manager, company secretary and chief financial Company
officer may be appointed by the Board for such term, at such remuneration and Secretary or Chief
upon such conditions as it may think fit; and any chief executive officer, Financial Officer
manager, company secretary and chief financial officer so appointed may be etc.
removed by means of a resolution of the Board; the Board may appoint one or
more chief executive officers for its multiple businesses.
(2) A director may be appointed as chief executive officer, manager, company Director may be
secretary or chief financial officer. chief executive
officer, etc.
(3) The Company shall not appoint or employ, at the same time, more than one of
the following categories of managerial personnel, namely
(i) Managing Director, and
(ii) Manager
(4) A provision of the Act or these regulations requiring or authorising a thing to Authorisation of
be done by or to a director and chief executive officer, manager, company act done in respect
secretary, chief financial officer shall not be satisfied by its being done by or to of any director,
the same person acting both as director and as, or in place of, chief executive chief executive
officer, manager, company secretary, chief financial officer. officer, manager,
company secretary,
chief financial
officer
Registers
102. The Company shall keep and maintain at its registered office all statutory Statutory registers
registers namely, register of charges, register of members, register of debenture
holders, register of any other security holders, the register and index of
beneficial owners and annual return, register of loans, guarantees, security and
acquisitions, register of investments not held in its own name and register of
contracts and arrangements for such duration as the Board may, unless
otherwise prescribed, decide, and in such manner and containing such
particulars as prescribed by the Act and the Rules.
The registers and copies of annual return shall be open for inspection during
business hours on all working days, at the registered office of the Company by
the persons entitled thereto on payment, where required, of such fees as may be
fixed by the Board but not exceeding the limits prescribed by the Rules.
103. (1) The Company may exercise the powers conferred on it by the Act with regard Foreign register
to the keeping of a foreign register; and the Board may (subject to the provisions
of the Act) make and vary such regulations as it may think fit respecting the
keeping of any such register.
(2) The foreign register shall be open for inspection and may be closed, and extracts
may be taken therefrom and copies thereof may be required, in the same
manner, mutatis mutandis, as is applicable to the register of members.
The Seal
104. (1) The Board shall provide for the safe custody of the seal. The seal, its custody
and use Affixation
(2) The Seal shall be under the safe custody of Company Secretary or such other of seal
officer(s) as may be authorized by the Board.
(3) The seal of the Company shall not be affixed to any instrument except by
the authority of a resolution of the Board or of a Committee of the Board
authorized by it in that behalf, and except in the presence of one director and
such director shall sign every instrument to which the seal of the Company is
so affixed.
Dividends and Reserve
105. The Company in general meeting may declare dividends, but no dividend shall Company in
exceed the amount recommended by the Board but the Company in general general meeting
meeting may declare a lesser dividend. may declare
dividends
696106. Subject to the provisions of the Act, the Board may from time to time pay to the Interim dividends
members such interim dividends of such amount on such class of shares and at
such times as it may think fit and as in their judgement, the position of the
Company justifies.
107. (1) The Board may, before recommending any dividend, set aside out of the profits Dividends only to
of the Company such sums as it thinks fit as a reserve or reserves which shall, be paid out of
at the discretion of the Board, be applied for any purpose to which the profits profits
of the Company may be properly applied, including provision for meeting
contingencies or for equalizing dividends; and pending such application, may,
at the like discretion, either be employed in the business of the Company or be
invested in such investments (other than shares of the Company) as the Board
may, from time to time, think fit.
Subject to the applicable provisions of the Act, no dividend shall be declared or
paid otherwise than out of profits of the financial year arrived at after providing
for depreciation in accordance with the provisions of the Act or out of the profits
of the Company for any previous financial year or years arrived at after
providing for depreciation in accordance with these provisions and remaining
undistributed or out of both provided that :-
(i) if the Company has not provided for any previous financial year or
years it shall, before declaring or paying a dividend for any financial year,
provide for such depreciation out of the profits of the financial year or out of
the profits of any other previous financial year or years;
(ii) if the Company has incurred any loss in any previous financial year
or years the amount of loss or an amount which is equal to the amount provided
for depreciation for that year or those years whichever is less, shall be set off
against the profits of the Company for the year for which the dividend is
proposed to be declared or paid as against the profits of the Company for any
financial year or years arrived at in both cases after providing for depreciation
in accordance with the provisions of schedule II of the Act.
(2) The Board may also carry forward any profits which it may consider necessary Carry forward of
not to divide, without setting them aside as a reserve. Profits
108. (1) Subject to the rights of persons, if any, entitled to shares with special rights as Division of profits
to dividends, all dividends shall be declared and paid according to the amounts
paid or credited as paid on the shares in respect whereof the dividend is paid,
but if and so long as nothing is paid upon any of the shares in the Company,
dividends may be declared and paid according to the amounts of the shares.
(2) No amount paid or credited as paid on a share in advance of calls shall be treated Payments in
for the purposes of this Article as paid on the share. Amount paid-up in advance advance
of calls on any share may carry interest but shall not entitle the holder of the
share to participate in respect thereof, in a dividend subsequently declared.
(3) All dividends shall be apportioned and paid proportionately to the amounts paid Dividends to be
or credited as paid on the shares during any portion or portions of the period in apportioned
respect of which the dividend is paid; but if any share is issued on terms
providing that it shall rank for dividend as from a particular date such share
shall rank for dividend accordingly.
109. (1) The Board may deduct from any dividend payable to any member all sums of No member to
money, if any, presently payable by him to the Company, either alone or jointly receive dividend
with any other person or persons, on account of calls or otherwise in relation to whilst indebted to
the shares of the Company. the Company and
Company’s right to
reimbursement
therefrom
(2) The Board may retain dividends payable upon shares in respect of which any Retention of
person is, under the Transmission Clause hereinbefore contained, entitled to dividends
become a member or where any person under these articles is entitled to transfer
until such person shall become a member in respect of such Shares, or shall duly
transfer the same and until such transfer of Shares has been registered by the
Company..
110. (1) Any dividend, interest, bonus or other monies payable in cash in respect of Dividend how
shares may be paid by electronic mode or by cheque or warrant sent through the remitted
post directed to the registered address of the holder or, in the case of joint
holders, to the registered address of that one of the joint holders who is first
named on the register of members, or to such person and to such address as the
holder or joint holders may in writing direct but the joint holders of a Share
697shall be severally as well as jointly liable for the payment of all instalments of
calls due in respect of such Share and for all incidents otherwise.
(2) Every such cheque or warrant or pay- slip sent through the post to the registered Instrument of
address of the member or person entitled, or, in the case of joint holders, to that Payment
one of them first named in the Register in respect of the joint holdings. It shall
be made payable to the order of the person to whom it is sent. The Company
shall not be liable or responsible for any cheque or warrant or pay-slip lost in
transmission or for any dividend lost to the member or person entitled thereto
due to or by the forged endorsement of any cheque or warrant or the fraudulent
recovery of the dividend by any other means.
(3) Payment in any way whatsoever shall be made at the risk of the person entitled Discharge to
to the money paid or to be paid. The Company will not be responsible for a Company
payment which is lost or delayed. The Company will be deemed to having made
a payment and received a good discharge for it if a payment using any of the
foregoing permissible means is made.
111. Any one of two or more joint holders of a share may give effective receipts for Receipt of one
any dividends, bonuses or other monies payable in respect of such share. holder sufficient
112. No dividend shall bear interest against the Company. No interest on
dividends
113. The waiver in whole or in part of any dividend on any share by any document Waiver of
shall be effective only if such document is signed by the member (or the person dividends
entitled to the share in consequence of the death or bankruptcy of the holder)
and delivered to the Company and if or to the extent that the same is accepted
as such or acted upon by the Board.
114. Any general meeting declaring a dividend may, on the recommendation of the Setting off dividend
Directors, make a call on the members of such amount as the meeting decides, against calls
but so that the call on each member shall not exceed the dividend payable to
him and so that the call be made payable at the same time as the dividend and
the dividend may, if so arranged between the Company and the members, be
set off against the calls.
115. Subject to the applicable provisions, if any, of the Act, a transfer of Shares shall When transfer of
not pass the right to any dividend declared thereon and made effective from the share shall not pass
date prior to the registration of the transfer. dividend right
Unpaid or unclaimed dividend
116. (1) Where the Company has declared a dividend but which has not been paid or Transfer of
claimed within thirty (30) days from the date of declaration, the Company shall, unclaimed dividend
within seven (7) days from the date of expiry of the said period of thirty (30)
days, transfer the total amount of dividend which remains unpaid or unclaimed,
to a special account to be opened by the Company in that behalf in any
scheduled bank to be called “the Unpaid Dividend Account of Shah Investor’s
Home Limited ” subject to the applicable provisions of the Act and the Rules
made thereunder.
The Company shall within a period of ninety days of making any transfer of an
amount to the Unpaid Dividend Account, prepare a statement containing the
names, their last known addresses and the unpaid dividend to be paid to each
person and place it on the website of the Company and also on any other website
approved by the Central Government, for this purpose. No unclaimed or unpaid
dividend shall be forfeited by the Board before the claim becomes barred by
law.
(2) Any money transferred to the unpaid dividend account of the Company which Transfer to IEPF
remains unpaid or unclaimed for a period of seven (7) years from the date of Account
such transfer, shall be transferred by the Company to the Investor Education
and Protection Fund established under section 125 of the Act. Any person
claiming to be entitled to an amount may apply to the authority constituted by
the Central Government for the payment of the money claimed.
(3) No unclaimed or unpaid dividend shall be forfeited by the Board until the claim Forfeiture of
becomes barred by Applicable Laws. unclaimed dividend
Accounts
117. (1) The books of account and books and papers of the Company, or any of them, Inspection by
shall be open to the inspection of directors in accordance with the applicable Directors
provisions of the Act and the Rules with respect to :-
(i) all sums of money received and expended by the Company and the
matters in respect of which the receipt and expenditure take place;
(ii) all sales and purchases of goods by the Company;
698(iii) the assets and liabilities of the Company;
(iv) such particulars, if applicable to this Company, relating to utilisation
of material and/or labour or to other items of cost, as may be prescribed by the
Central Government.
Where the Board decides to keep all or any of the books of account at any place,
other than the Office of the Company, the Company shall, within 7 (Seven)
days, or such other period, as may be fixed, from time to time, by the Act, of
the decision, file with the Registrar, a notice, in writing, giving the full address
of that other place.
The Company shall preserve, in good order, the books of account, relating to
the period of not less than 8 (Eight) years or such other period, as may be
prescribed, from time to time, under the Act, preceding the current year,
together with the vouchers relevant to any entry in such books.
Where the Company has a branch office, whether in or outside India, the
Company shall be deemed to have complied with this Article, if proper books
of account, relating to the transaction effected at the branch office, are kept at
the branch office, and the proper summarised returns, made up to day at
intervals of not more than 3 (Three) months or such other period, as may be
prescribed, from time to time, by the Act, are sent by the branch office to the
Company at its Office or other place in India, at which the books of account of
the Company are kept as aforesaid.
The books of account shall give a true and fair view of the state of affairs of the
Company or branch office, as the case may be, and explain the transactions
represented by it. The books of account and other books and papers shall be
open to inspection by any director, during business hours, on a working day,
after a prior notice, in writing, is given to the Accounts or Finance department
of the Company.
(2) No member (not being a director) shall have any right of inspecting any books Restriction on
of account or books and papers or document of the Company except as inspection by
conferred by Applicable Laws or authorized by the Board. members
(3) The Directors shall, from time to time, in accordance with sections 129 and 134 Annual Reports,
of the Act, cause to be prepared and to be laid before the Company in Annual Financial
General Meeting of the Shareholders of the Company, such Balance Sheets, Statements to be
Profit and Loss Accounts, if any, and the Reports as are required by those laid in Annual
Sections of the Act. General Meeting
and sent to
A copy of every such Profit & Loss Accounts and Balance Sheets, including members, trustees.
the Directors’ Report, the Auditors’ Report and every other document(s) Appointment of
required by law to be annexed or attached to the Balance Sheet, shall at least 21 various auditors
(Twenty-one) days, before the meeting, at which the same are to be laid before
the members, be sent to the members of the Company, to every trustee for the
holders of any Debentures issued by the Company, whether such member or
trustee is or is not entitled to have notices of general meetings of the Company
sent to him, and to all persons other than such member or trustees being persons
so entitled.
The Auditors, whether statutory, branch or internal, shall be appointed and their
rights and duties shall be regulated in accordance with the provisions of the Act
and the Rules made thereunder.
Borrowing Powers
699118. Subject to the provisions of the Act, the Board may from time to time, at their Power of the Board
discretion raise or borrow or secure the payment of any sum or sums of money to borrow monies
for and on behalf of the Company. Any such money may be raised or the
payment or repayment thereof may be secured in such manner and upon such
terms and conditions in all respect as the Board may think fit by promissory
notes or by opening loan or current accounts or by receiving deposits and
advances at interest with or without security or otherwise and in particular by
the issue of bonds, perpetual or redeemable debentures of the Company charged
upon all or any part of the property of the Company (both present and future)
including its uncalled capital for the time being or by mortgaging or charging
or pledging any lands, buildings, machinery, plant, goods or other property and
securities of the Company or by other means as the Board deems expedient.
The Board of Directors shall not except with the consent of the Company by
way of a special resolution, borrow moneys where the moneys to be borrowed
together with the moneys already borrowed by the Company (apart from
temporary loans obtained from the Company’s bankers in the ordinary course
of business) exceeds the aggregate of paid up capital of the Company and its
free reserves.
Subject to the Act and the provisions of these Articles, any bonds, debentures,
debenture-stock or other securities issued or to be issued by the Company shall
be under the control of the Board, who may issue them upon such terms and
conditions and in such manner and for such consideration as the Board shall
consider to be for the benefit of the Company.
Winding up
119. Subject to the applicable provisions of the Act and the Rules made thereunder Winding up of
and the Insolvency and Bankruptcy Code, 2016 (to the extent applicable).– Company
(a) If the Company shall be wound up, the liquidator may, with the sanction of a
special resolution of the Company and any other sanction required by the Act,
divide amongst the members, in specie or kind, the whole or any part of the
assets of the Company, whether they shall consist of property of the same kind
or not.
(b) For the purpose aforesaid, the liquidator may set such value as he deems fair
upon any property to be divided as aforesaid and may determine how such
division shall be carried out as between the members or different classes of
members.
(c) The liquidator may, with the like sanction, vest the whole or any part of such
assets in trustees upon such trusts for the benefit of the contributories if he
considers necessary, but so that no member shall be compelled to accept any
shares or other securities whereon there is any liability.
Indemnity and Insurance
120. (a) Subject to the provisions of the Act, every director, managing director, whole- Directors and
time director, manager, company secretary and other officer of the Company officers right to
shall be indemnified by the Company out of the funds of the Company from indemnity
and against all suits, proceedings, cost, charges, losses, damage and expenses
which they or any of them shall or may incur or sustain by reason of any act
done or committed in or about the execution of their duty in their respective
office except such suits, proceedings, cost, charges, losses, damage and
expenses, if any that they shall incur or sustain, by or through their own wilful
neglect or default respectively. And it shall include the payment of all costs,
losses and expenses (including travelling expense) which such director,
manager, company secretary and officer may incur or become liable for by
reason of any contract entered into or act or deed done by him in his capacity
as such director, manager, company secretary or officer or in any way in the
discharge of his duties in such capacity including expenses.
(b) Subject as aforesaid, every director, managing director, manager, company Director, Managing
secretary or other officer of the Company shall be indemnified against any director, Manager,
liability incurred by him in defending any proceedings, whether civil or criminal Company
in which judgement is given in his favour or in which he is acquitted or Secretary or other
discharged or in connection with any application under applicable provisions of officer of the
the Act in which relief is given to him by the Court. Company shall be
indemnified
700(c) The Company may take and maintain any insurance as the Board may think fit Insurance
on behalf of its present and/or former directors and key managerial personnel
for indemnifying all or any of them against any liability for any acts in relation
to the Company for which they may be liable but have acted honestly and
reasonably.
Secrecy
121. (i) Every director, manager, auditor, treasurer, trustee, member of a Directors,
committee, officer, servant, agent, accountant or other person employed in the manager, auditor,
business of the Company shall, if so required by the Directors, before entering members, etc to
upon his duties, sign a declaration pledging himself to observe strict secrecy maintain secrecy
respecting all transactions and affairs of the Company with the customers and
the state of the accounts with the individuals and in matters relating thereto, and
shall, by such declaration, pledge himself not to reveal any of the matters which
may come to his knowledge in the discharge of his duties except when required
so to do by the Directors or by Law or by the person to whom such matters
relate and except so far as may be necessary in order to comply with any of the
provisions contained in these Articles or the Memorandum of Association of
the Company and the provisions of the Act.
(ii) Subject to the provisions of the Act, no member shall be entitled to
visit or inspect any works of the Company, without the permission of the
Directors, or to require inspection of any books of accounts or documents of the
Company or discovery of or any information respecting any details of the
Company’s trading or business or any matter which is or may be in the nature
of a trade secret, mystery of trade, secret or patented process or any other matter,
which may relate to the conduct of the business of the Company and, which in
the opinion of the Directors, it would be inexpedient in the interests of the
Company to disclose.
General Power
122. Wherever in the Act, it has been provided that the Company shall have any General power
right, privilege or authority or that the Company could carry out any transaction
only if the Company is so authorized by its Articles, then and in that case this
Article authorizes and empowers the Company to have such rights, privileges
or authorities and to carry out such transactions as have been permitted by the
Act, without there being any specific Article in that behalf herein provided.
At any point of time from the date of adoption of these Articles, if the Articles
are or become contrary to the provisions of the SEBI Listing Regulations, the
provisions of the SEBI Listing Regulations shall prevail over the Articles to
such extent and the Company shall discharge all its obligations as prescribed
under the SEBI Listing Regulations, from time to time.
701SECTION IX – OTHER INFORMATION
MATERIAL CONTRACTS AND DOCUMENTS FOR INSPECTION
The copies of the following documents and contracts which have been entered or are to be entered into by our
Company (not being contracts entered into in the ordinary course of business carried on by our Company) which
are or may be deemed material, will be attached to the copy of the Red Herring Prospectus which will be delivered
to the RoC for filing and are also available at the following weblink www.sihl.in. Copies of the abovementioned
contracts and also the documents for inspection referred to hereunder, may be inspected at our Registered Office
between 10:00 a.m. to 05:00 p.m. on all Working Days from the date of the Red Herring Prospectus until the Bid
/ Issue Closing Date (except for such agreements executed after the Bid / Issue Closing Date).
A. Material Contracts for the Issue
1. Issue Agreement dated September 29, 2025, entered amongst our Company and the Book Running
Lead Manager.
2. Registrar Agreement dated September 29, 2025, entered amongst our Company and the Registrar to
the Issue.
3. Cash Escrow and Sponsor Bank Agreement dated [●], entered amongst our Company, the Registrar to
the Issue, the Book Running Lead Manager, the Syndicate Members, the Escrow Collection bank,
Sponsor Bank, Public Issue Account bank and the Banker(s) to the Issue.
4. Syndicate Agreement dated [●], entered amongst our Company, the Book Running Lead Manager, the
Syndicate Members, and the Registrar to the Issue.
5. Underwriting Agreement dated [●], entered amongst our Company and the Underwriters.
6. Monitoring Agency Agreement dated [●] entered amongst our Company and the Monitoring Agency.
B. Material Documents
1. Certified copies of updated MoA and AoA, updated from time to time.
2. Certificate of incorporation dated October 12, 1994, issued to our Company by the Assistant Registrar
of Companies, Gujarat at Dadra & Nagar Haveli, in the name of Shah Investors Home Private Limited.
3. Certificate of incorporation, pursuant to conversion from private to public limited, dated March 09,
1995, issued to our Company by the Assistant Registrar of Companies, Gujarat at Dadra & Nagar
Haveli, in the name of Shah Home Investor Limited.
4. Fresh Certificate of incorporation, pursuant to change of name, dated October 13, 2000, issued to our
Company by the Assistant Registrar of Companies, Gujarat at Dadra & Nagar Haveli, in the name of
Shah Investor’s Home Limited.
5. Resolutions of the Board of Directors and Shareholders dated August 26, 2025 and August 28, 2025,
respectively in relation to the Issue and other related matters.
6. Resolution passed by the Board of Directors dated October 15, 1994, for appointing Upendra Trikamlal
Shah as the Chairman of the Company.
7. Resolution passed by the Board of Directors and the Shareholders dated August 10, 2023 and
September 09, 2023, respectively for appointing Tanmay Upendra Shah as the Managing Director of
the Company.
8. Resolution passed by the Board of Directors and Shareholders dated August 10, 2023 and September
09, 2023, respectively for appointing Upendra Trikamlal Shah as the Wholetime Director of the
Company.
9. Resolution passed by the Board of Directors and Shareholders dated August 29, 2024, and September
30, 2024 respectively for appointing Purnima Upendra Shah as the Wholetime Director of the
Company.
10. Resolution passed by the Board of Directors and Shareholders dated August 10, 2023 and September
09, 2023, respectively for appointing Trupti Utpal Shah as the Wholetime Director of the Company
11. Resolution of the Board of Directors dated September 29, 2025 approving the DRHP.
12. Resolution of the Board of Directors dated September 29, 2025 approving the objects of the Issue.
70213. Resolution approving the KPI passed by the Audit Committee dated September 29, 2025.
14. Certificate dated September 29, 2025, from Independent Chartered Accountant, namely, Dhrumil A.
Shah & Co.,verifying the Key Performance Indicators (KPIs)
15. Certificate dated September 29, 2025, from Independent Chartered Accountant, namely, Dhrumil A.
Shah & Co.,verifying the working capital requirements of our Company.
16. Consent dated September 29, 2025 from our Statutory Auditors, namely, Ashit N Shah & Co.,
Chartered Accountants to include their names as required under section 26 (1) of the Companies Act,
2013 read with SEBI ICDR Regulations, in this DRHP, and as an “expert” as defined under section
2(38) of the Companies Act, 2013 and such consents has not been withdrawn as on the date of this
DRHP.
17. Consent dated September 29, 2025 from Independent Chartered Accountant, namely, Dhrumil A. Shah
& Co., Chartered Accountants to include their names as required under section 26 (1) of the Companies
Act, 2013 read with SEBI ICDR Regulations, in in respect of their (a) examination report dated
September 05, 2025 on the Restated Consolidated Financial Information (b) The statement of possible
special tax benefits on direct taxes and indirect taxes each dated September 29, 2025, (c) certificates
issued by them, , in this DRHP, and as an “expert” as defined under section 2(38) of the Companies
Act, 2013, and such consents has not been withdrawn as on the date of this DRHP.
18. Consents of our Directors, our Chief Financial Officer, our Company Secretary and Compliance
Officer, Legal Counsel to our Company, Bankers to our Company, Banker(s) to the Issue, the BRLM,
Syndicate Members, and the Registrar to the Issue, Monitoring Agency, Escrow Collection Bank(s),
Public Issue Account Bank(s), Refund Bank(s) and Sponsor Bank(s).
19. Consent letter dated September 29, 2025 from Mittal V Kothari & Associates, Practising Company
Secretaries, to include their name in this Draft Red Herring Prospectus and as an “expert” as defined
under Section 2(38) of the Companies Act, 2013, to the extent that and in their capacity as practising
company secretary, in relation to their certificate dated September 29, 2025.
20. Consent letter dated September 29, 2025, from CARE Analytics & Advisory Private Limited with
respect to Industry Report titled “Broking Industry in India”.
21. Industry Report titled “Broking Industry in India” dated September, 2025, prepared and issued by
CARE Analytics & Advisory Private Limited and commissioned for an agreed fee, exclusively for the
purpose of this Issue.
22. Copies of annual reports of our Company for the preceding three Fiscals i.e., Fiscals 2025, 2024 and
2023.
23. Due Diligence Certificate dated September 29, 2025 addressed to SEBI from the BRLM.
24. In principle listing approvals dated [●] and [●] issued by BSE and NSE, respectively.
25. Tripartite agreement dated August 17, 2017, amongst our Company, CDSL and the Registrar to the
Issue.
26. Tripartite agreement dated March 21, 2012, amongst our Company, NSDL and the Registrar to the
Issue.
27. SEBI final observation letter dated [●].
Any of the contracts or documents mentioned in this Draft Red Herring Prospectus may be amended or modified
at any time if so required in the interest of our Company or if required by the other parties, without notice to the
Shareholders subject to compliance of the provisions contained in the Companies Act and other relevant statutes.
703DECLARATION
I hereby certify and declare that all relevant provisions of the Companies Act, 2013 and the guidelines, regulations
or rules issued by the Government of India or the guidelines, or regulations issued by the Securities and Exchange
Board of India (“SEBI”), established under Section 3 of the SEBI Act, as the case may be, have been complied
with and no statement made in this Draft Red Herring Prospectus is contrary to the provisions of the Companies
Act, 2013, the Securities and Contracts (Regulation) Act, 1956, as amended, the Securities and Contracts
(Regulation) Rules, 1957, as amended, the Securities and Exchange Board of India Act, 1992, as amended, or
rules made or guidelines or regulations issued there under, as the case may be. I further certify that all statements
in this Draft Red Herring Prospectus are true and correct.
SIGNED BY
Sd/-
Upendra Trikamlal Shah
(Chairman and Whole Time Director)
Place: Ahmedabad
Date: September 29, 2025
704DECLARATION
I hereby certify and declare that all relevant provisions of the Companies Act, 2013 and the guidelines, regulations
or rules issued by the Government of India or the guidelines, or regulations issued by the Securities and Exchange
Board of India (“SEBI”), established under Section 3 of the SEBI Act, as the case may be, have been complied
with and no statement made in this Draft Red Herring Prospectus is contrary to the provisions of the Companies
Act, 2013, the Securities and Contracts (Regulation) Act, 1956, as amended, the Securities and Contracts
(Regulation) Rules, 1957, as amended, the Securities and Exchange Board of India Act, 1992, as amended, or
rules made or guidelines or regulations issued there under, as the case may be. I further certify that all statements
in this Draft Red Herring Prospectus are true and correct.
SIGNED BY
Sd/-
Purnima Upendra Shah
(Whole Time Director)
Place: Ahmedabad
Date: September 29, 2025
705DECLARATION
I hereby certify and declare that all relevant provisions of the Companies Act, 2013 and the guidelines, regulations
or rules issued by the Government of India or the guidelines, or regulations issued by the Securities and Exchange
Board of India (“SEBI”), established under Section 3 of the SEBI Act, as the case may be, have been complied
with and no statement made in this Draft Red Herring Prospectus is contrary to the provisions of the Companies
Act, 2013, the Securities and Contracts (Regulation) Act, 1956, as amended, the Securities and Contracts
(Regulation) Rules, 1957, as amended, the Securities and Exchange Board of India Act, 1992, as amended, or
rules made or guidelines or regulations issued there under, as the case may be. I further certify that all statements
in this Draft Red Herring Prospectus are true and correct.
SIGNED BY
Sd/-
Tanmay Upendra Shah
(Managing Director and Chief Financial Officer)
Place: Ahmedabad
Date: September 29, 2025
706DECLARATION
I hereby certify and declare that all relevant provisions of the Companies Act, 2013 and the guidelines, regulations
or rules issued by the Government of India or the guidelines, or regulations issued by the Securities and Exchange
Board of India (“SEBI”), established under Section 3 of the SEBI Act, as the case may be, have been complied
with and no statement made in this Draft Red Herring Prospectus is contrary to the provisions of the Companies
Act, 2013, the Securities and Contracts (Regulation) Act, 1956, as amended, the Securities and Contracts
(Regulation) Rules, 1957, as amended, the Securities and Exchange Board of India Act, 1992, as amended, or
rules made or guidelines or regulations issued there under, as the case may be. I further certify that all statements
in this Draft Red Herring Prospectus are true and correct.
SIGNED BY
Sd/-
Trupti Upendra Shah
(Whole Time Director)
Place: Ahmedabad
Date: September 29, 2025
707DECLARATION
I hereby certify and declare that all relevant provisions of the Companies Act, 2013 and the guidelines, regulations
or rules issued by the Government of India or the guidelines, or regulations issued by the Securities and Exchange
Board of India (“SEBI”), established under Section 3 of the SEBI Act, as the case may be, have been complied
with and no statement made in this Draft Red Herring Prospectus is contrary to the provisions of the Companies
Act, 2013, the Securities and Contracts (Regulation) Act, 1956, as amended, the Securities and Contracts
(Regulation) Rules, 1957, as amended, the Securities and Exchange Board of India Act, 1992, as amended, or
rules made or guidelines or regulations issued there under, as the case may be. I further certify that all statements
in this Draft Red Herring Prospectus are true and correct.
SIGNED BY
Sd/-
Amit Lalitkumar Doshi
(Independent Director)
Place: Ahmedabad
Date: September 29, 2025
708DECLARATION
I hereby certify and declare that all relevant provisions of the Companies Act, 2013 and the guidelines, regulations
or rules issued by the Government of India or the guidelines, or regulations issued by the Securities and Exchange
Board of India (“SEBI”), established under Section 3 of the Securities and Exchange Board of India Act, 1992,
as amended, as the case may be, have been complied with and no statement made in this Draft Red Herring
Prospectus is contrary to the provisions of the Companies Act, 2013, the Securities and Contracts (Regulation)
Act, 1956, as amended, the Securities and Contracts (Regulation) Rules, 1957, as amended, the Securities and
Exchange Board of India Act, 1992, as amended, or rules made or guidelines or regulations issued there under, as
the case may be. I further certify that all statements in this Draft Red Herring Prospectus are true and correct.
SIGNED BY
Sd/-
Bhushan Chelram Punani
Independent Director
Place: Ahmedabad
Date: September 29, 2025
709DECLARATION
I hereby certify and declare that all relevant provisions of the Companies Act, 2013 and the guidelines, regulations
or rules issued by the Government of India or the guidelines, or regulations issued by the Securities and Exchange
Board of India (“SEBI”), established under Section 3 of the Securities and Exchange Board of India Act, 1992,
as amended, as the case may be, have been complied with and no statement made in this Draft Red Herring
Prospectus is contrary to the provisions of the Companies Act, 2013, the Securities and Contracts (Regulation)
Act, 1956, as amended, the Securities and Contracts (Regulation) Rules, 1957, as amended, the Securities and
Exchange Board of India Act, 1992, as amended, or rules made or guidelines or regulations issued there under, as
the case may be. I further certify that all statements in this Draft Red Herring Prospectus are true and correct.
SIGNED BY
Sd/-
Darshan Bharatbhai Patel
(Independent Director)
Place: Ahmedabad
Date: September 29, 2025
710DECLARATION
I hereby certify and declare that all relevant provisions of the Companies Act, 2013 and the guidelines, regulations
or rules issued by the Government of India or the guidelines, or regulations issued by the Securities and Exchange
Board of India (“SEBI”), established under Section 3 of the Securities and Exchange Board of India Act, 1992,
as amended, as the case may be, have been complied with and no statement made in this Draft Red Herring
Prospectus is contrary to the provisions of the Companies Act, 2013, the Securities and Contracts (Regulation)
Act, 1956, as amended, the Securities and Contracts (Regulation) Rules, 1957, as amended, the Securities and
Exchange Board of India Act, 1992, as amended, or rules made or guidelines or regulations issued there under, as
the case may be. I further certify that all statements in this Draft Red Herring Prospectus are true and correct.
SIGNED BY
Sd/-
Abhinav Mahesh Kapadia
(Independent Director)
Place: Ahmedabad
Date: September 29, 2025
711