Key Quantitative Figures
- Trade in question: 1,600 equity shares executed on August 21, 2026
- Previous purchase: 4,800 equity shares purchased directly from open secondary market on August 14, 2026 at ₹16.68 per share
- Total purchase value: ₹80,064 (4,800 shares × ₹16.68)
- Total paid-up capital: 89,51,970 shares
- Promoter locked-in minimum contribution: 18,79,359 Equity Shares (100% intact)
- Traded volume percentage: 0.0536% buy / 0.0357% sell against total paid-up capital
Dates of Action
- August 14, 2026: Promoter purchased 4,800 shares from secondary market
- August 21, 2026: 1,600 shares traded with Market Maker (JSK Securities and Services Private Limited)
- August 25, 2026: BSE SME clarification letter received
- August 26, 2026: This reply letter submitted
Parties Involved
- Promoter: Mr. Vishal Goel (DIN: 0108470, Whole time Director)
- Market Maker: JSK Securities and Services Private Limited
- Regulator: BSE SME Exchange Compliance & Surveillance Department
Compliance Status
- SEBI (ICDR) Regulations, 2018 (Promoter Lock-in Status): FULLY COMPLIED - 18,79,359 locked-in shares remain 100% intact
- SEBI (PIT) Regulations, 2015 (Regulation 7(2)): COMPLIED - Aggregate traded value of ₹80,064 below statutory threshold of ₹10 Lakhs per quarter
- SEBI (SAST) Regulations, 2011 (Regulations 29(2) & 3(2)): COMPLIED - Traded volume significantly below 2% disclosure limit and within 5% creeping acquisition limit
Purpose and Rationale
The 1,600 shares traded with the Market Maker were executed out of freely tradeable secondary market shares purchased on August 14, 2026. The non-obtainment of prior written permission was an inadvertent administrative oversight without any malafide intent.
Financial Impact
No material financial impact disclosed. All transactions were within regulatory thresholds and involved only non-locked-in secondary market shares.
Capital Structure Impact
Zero impact on capital structure. The promoter's locked-in minimum contribution of 18,79,359 shares remains completely intact and unencumbered.
Supporting Documentation
- Annexure 1: Secondary Purchase Contract Note dated Aug 14, 2026
- Annexure 2: Secondary Sale Trade Execution Statement dated Aug 21, 2026
- Annexure 3: Demat Holding Statement (BENPOS) dated 21-08-2026 confirming 18,79,359 shares intact under Lock-in
Request for Action
The company humbly requests the Exchange to take their response on record and condone this unintentional administrative lapse, given that all underlying shares were non-locked-in secondary market shares and all statutory threshold limits were fully respected.