This document is a regulatory filing submitted to the Securities and Exchange Board of India (SEBI) by Sandeep Gupta, a promoter of Asian Hotels (West) Limited. It serves as a report under Regulation 10(7) of the SEBI (Substantial Acquisition of Shares and Takeovers) Regulations, 2011, concerning an acquisition of shares that was exempt from open offer requirements.

Nature of the Event

The filing reports an acquisition of shares by way of an inter-se transfer among promoters/promoter group members. Specifically, Sandeep Gupta acquired 200,000 equity shares from Vinita Gupta via a gift. The transaction date was September 30, 2026. There was no acquisition price, as the transfer was a gift.

Key Quantitative Figures and Shareholding Changes

  • Shares Acquired: 200,000
  • Acquirer (Sandeep Gupta) Holding Change: Increased from 1,901,974 shares (16.32%) to 2,101,974 shares (18.04%).
  • Seller (Vinita Gupta) Holding Change: Decreased from 200,000 shares (1.72%) to 0 shares.
  • Total Fees Paid to SEBI: ₹177,000 (comprising ₹150,000 fees + ₹27,000 GST).
  • UTR Number: HSBCN52026100694161691
  • Date of Fee Payment: October 6, 2026

Parties Involved

  • Acquirer: Sandeep Gupta
  • Seller: Vinita Gupta
  • Target Company: Asian Hotels (West) Limited
  • Stock Exchanges: National Stock Exchange of India Limited (NSE) and BSE Limited (BSE)
  • Persons Acting in Concert (PACs) listed: Gunjan Jain, Madhu Jain, Renu Arun Aggarwal, Chaman Lal Gupta And Sons HUF. Their shareholdings remained unchanged by this transaction.

Regulatory References and Compliance Dates

The acquisition was structured to rely on the exemption provided in Regulation 10(1)(a)(i) of the Takeover Regulations for transfers between immediate relatives.

  • Regulation 10(5) Report to Stock Exchanges: Filed on September 22, 2026 (at least 4 working days before the acquisition).
  • Regulation 10(6) Report to Stock Exchanges: Filed on October 3, 2026 (within 4 working days after the acquisition).
  • Regulation 10(7) Report to SEBI: Filed on October 6, 2026 (within 21 working days of the acquisition).
  • Relationship between Acquirer and Seller: Mother-Son, confirmed as 'immediate relatives' as per Regulation 2(1).

Attached Declarations

The filing includes yearly declarations made under Regulation 31(4) for the financial years ending March 31, 2024, 2025, and 2026. These declarations, signed by Sandeep Gupta on behalf of the promoters, state that their shareholdings in Asian Hotels (West) Limited were not encumbered during those periods. The declarations also note the death of promoter Sushil Kumar Gupta on October 29, 2021, and that his demat accounts were frozen pending transmission. The 2026 declaration adds that the company received notices from NSE and BSE on March 25, 2026, revoking the suspension of trading, with trading set to resume in a restricted zone from April 2, 2026.

Financial Impact

The acquisition was a non-cash gift transaction. The only monetary outflow disclosed is the regulatory fee of ₹177,000 paid to SEBI. There is no dilution or change to the company's capital structure beyond the change in ownership percentages among the promoter group.