Details of the Designated Person
- Name: Mithil Gandhi
- PAN: AMCPG2906P
- Designation: General Manager - Sales
- Functional Role: Sales
- Promoter/Promoter Group: No
Details of Violation
The violation involves contra trade as defined under SEBI PIT Regulations.
- Sale Transaction: On June 19, 2026, Mithil Gandhi sold 3,999 shares at ₹3,110 per share, for a total value of ₹1,24,36,890.
- Purchase Transactions: Subsequently, he purchased 599 shares on August 3, 2026 at ₹2,676 per share (value ₹16,02,924) and 400 shares on August 4, 2026 at ₹2,676 per share (value ₹10,70,400).
- Total Purchase: 999 shares within six months of the sale transaction.
- Violation: These purchase transactions qualify as contra trades and were executed without obtaining pre-clearance from the Compliance Officer, as required under the company's code.
Action Taken by the Company
- Issued a written warning to Mr. Mithil Gandhi not to repeat such actions and to ensure strict compliance with the Code of Conduct and SEBI PIT Regulations.
- Directed Mr. Gandhi to disgorge the profits from the trade amounting to ₹4,33,566 (Four Lakh Thirty Three Thousand Five Hundred and Sixty Six Rupees only) to the SEBI Investor Protection and Education Fund (IPEF).
Reasons for Action
The company issued warning letters considering that the transactions were carried out inadvertently by the Designated Person, without any intention to violate the SEBI (PIT) Regulations. The disgorgement is required as per SEBI PIT Regulations for profits earned in violation of the Insider Trading Regulations.
Disgorgement Details
- Mode of Transfer: Online
- Transferor: Mithil Gandhi
- Bank Details: HDFC Bank, Kandivali (East) Branch, Account Number 12651140000115
- UTR/Transaction Reference Number: 261026290606378
- Transaction Date: October 26, 2026
- Transaction Amount: ₹4,33,566
Previous Instances
No previous instances of violations since the last financial year.