Key Quantitative Figures
- Sunil Ramdayal Attal: 1,000 equity shares (0.00% holding)
- Megha Jhawar: 8,000 equity shares (0.01% holding)
Dates of Action
- Request dates: October 6, 2026 (from both individuals)
- Receipt date by company: October 12, 2026
- Disclosure date to exchanges: October 12, 2026
Parties Involved
- Promoter Group Members: Sunil Ramdayal Attal and Megha Jhawar
- Regulatory References: SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015, Regulation 31A
Regulatory Framework
The reclassification requests are made under Regulation 31A of the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015 (as amended).
Approval Requirements
The requests shall be subject to consideration/approval of:
- Board of Directors of the Company
- Stock Exchanges (BSE Limited and National Stock Exchange of India Ltd.)
- Other applicable conditions specified under Regulation 31A of SEBI Listing Regulations
Rationale for Reclassification (from individual requests)
Both individuals stated they were classified as promoter group members merely because they received equity shares on gift basis from existing promoter/promoter group members. They confirmed:
- Not engaged in management decisions
- Do not exercise control over company affairs
- Do not have any special rights through formal or informal arrangements
- Not represented on the Board of Directors
- Not acting as Key Managerial Personnel
- Not wilful defaulters per RBI guidelines
- Not fugitive economic offenders
Undertakings Provided
Both individuals undertook to:
- Not hold more than 10% of total voting rights along with 'persons related'
- Continue compliance with conditions (i), (ii), and (iii) of Regulation 31A(3)(b) at all times post-reclassification
- Comply with conditions (iv) and (v) of Regulation 31A(3)(b) for at least three years post-reclassification
- Not be in violation of SEBI circular no. SEBI/HO/MRD/DSA/CIR/P/2017/92 dated August 01, 2017
- Not be in violation of Regulation 34 of SEBI (Delisting of Equity Shares) Regulations, 2021
Financial Impact
Minimal direct impact due to very small shareholding percentages (0.00% and 0.01%). No financial quantification provided in the disclosure.
Capital Structure Impact
No change to overall capital structure. Potential minor adjustment in promoter group vs public shareholding categorization if approved.
#Tags: #AdvancedEnzyme #SEBIRegulation31A #ShareholdingReclassification #RegulatoryCompliance #OwnershipStructure