Due to outbreak of war between two countries, the stock prices of a listed IT company falls drastically. The management after due deliberations, decided to offer buy-back of its equity shares amounting to ₹ 200 crore. Ho

As per Regulation 9 of the SEBI (Buy-Back of Securities) Regulations, 2018, the company shall, within two working days of the public announcement, as and by way of security for performance of its obligations under the regulations, deposit in an escrow account such sum as specified. The amount in the escrow account shall be deposited in the following manner: if the consideration payable does not exceed Rupees 100 crore; 25 per cent of the consideration payable; if the consideration payable exceeds Rupees 100 crore; 25 per cent upto Rupees 100 crore and 10 per cent thereafter. In view of the SEBI (Buy-Back of Securities) Regulations, 2018, the company contention that money will be available only at the time of final payment for buy-back offer, will not be in accordance with the requirements under the SEBI (Buy-Back of Securities) Regulations, 2018. In the escrow account money should be deposited within two working days of the public announcement.