Date & Title

26th December, 2025 - Request for informal guidance by way of "Interpretive letter" under the Securities and Exchange Board of India (Informal Guidance) Scheme, 2025

Extracted Data Points

  • Applicant: Maithan Alloys Limited, a listed entity whose equity shares are listed on The Calcutta Stock Exchange Limited, National Stock Exchange of India Limited, and BSE Limited under permitted category
  • Corporate Identity: CIN L27101WB1985PLC039503, incorporated on 19th September, 1985 under Companies Act, 1956
  • Business: Manufacturing of Ferro Alloys products for iron and steel sector and Real Estate Business activities
  • Production Units:
  • Unit-I: P.O. Kalyaneshwari 713 369, Paschim Bardhaman (West Bengal)
  • Unit-II: E.P.I.P., Byrnihat, Dist. Ri-bhoi-793101 (Meghalaya)
  • Unit-III: Plot No. 42-43, APSEZ, P.O. Atchutapuram, Dist. Visakhapatnam 531011 (A.P.)
  • Guidance Purpose: Interpretation of expression "related to promoters or directors" under Regulation 16(1)(b)(iii) of SEBI (LODR) Regulations, 2015
  • Specific Query: Whether cousin of a Member of Promoter Group and Director of Subsidiary companies qualifies as "related" for independent director appointment
  • Proposed Appointee: Cousin of Mr. Siddhartha Shankar Agarwalla (promoter group member and subsidiary director)
  • Appointee Qualifications:
  • Doctorate degree
  • Fellow programmer from IIM Kolkata
  • P.G.D.M. from IIM-Kozhikode
  • Assistant Professor at Praxis Business School
  • Head of Corporate Branding Team
  • Author of published papers on consumer behavior and religiosity
  • Family Relationship: The proposed director is daughter of Mr. Siddhartha Shankar Agarwalla's Father's Sister
  • Promoter Structure:
  • Promoter: Mr. Subhas Chandra Agarwalla (Chairman and Managing Director)
  • Promoter Group Employees receiving remuneration:
  • Mr. Subhas Chandra Agarwalla, Chairman and MD
  • Mr. Subodh Agarwalla, Whole-time Director and CEO
  • Mr. Sudhanshu Agarwalla, President and CFO
  • Mr. Siddhartha Shankar Agarwalla, Vice President
  • Shareholding: Mr. Siddhartha Shankar Agarwalla's shareholding aggregated under "Promoter Group" per SEBI (ICDR) Regulations, 2018
  • Subsidiary Roles: Mr. Siddhartha Shankar Agarwalla serves as Director in two subsidiaries of the company
  • Regulatory Requirement: Need to appoint independent directors under Regulation 17 of SEBI (LODR) Regulations, 2015 due to tenure conclusion of existing independent director
  • Fee Payment:
  • Application fee: ₹50,000
  • GST @18%: ₹9,000
  • Total: ₹59,000
  • Payment date: 22nd December, 2025
  • Payment method: NEFT
  • Transaction number: AXSK253560010071
  • Bank: CITIBANK
  • Virtual Account Code: BDSKCEF7RHN15XQWXN
  • IFSC: CITI0100000
  • GST Number: 19AABCM7758B2ZC
  • Purpose: Application fee for seeking Informal Guidance under SEBI (Informal Guidance) Scheme, 2025
  • Contact Person: Mr. Rajesh K. Shah (Mobile: 98306-00838), email: rajesh@maithanalloys.com
  • Confidentiality: Requested under Paragraph 15 of the Scheme
  • Regulatory Provisions Cited:
  • Regulation 16(1)(b)(iii) of SEBI (LODR) Regulations, 2015
  • Regulation 2(1)(zd) of SEBI (LODR) Regulations, 2015 (definition of "relative")
  • Regulation 2(1)(w) of SEBI (LODR) Regulations, 2015 (definition of "promoter" and "promoter group")
  • Companies Act, 2013 provisions
  • SEBI (ICDR) Regulations, 2018
  • Company's Interpretation: Believes the word "related" is limited to relatives as defined under Regulation 2(1)(zd) of SEBI (LODR) Regulations, 2015, and that the cousin does not fall under this definition
  • File Reference: HO/27/12/16(2)2025-LAD1-V2 (Computer No. 10687)