Rajesh, the promoter of the company had acquired 10000 equity shares of the company on 5th April, 2025, for a market price of ₹ 555/- and disposed off 5000 equity shares on 25th April, 2025 at a price of ₹ 605/-. He furt

Provision related to continual disclosure and timeline under the SEBI (Prohibition of Insider Trading) Regulations, 2015 Pursuant to Regulation 7(2) of the SEBI (Prohibition of Insider Trading) Regulations, 2015 Every promoter, member of promoter group, designated person and director of every company shall disclose to the company the number of such securities acquired or disposed of within two trading days of such transaction if the value of the securities traded, whether in one transaction or a series of transactions over any calendar quarter, aggregates to a traded value in excess of ten lakh rupees or such other value as may be specified; Every company shall notify the particulars of such trading to the stock exchange on which the securities are listed within two trading days of receipt of the disclosure or from becoming aware of such information. (Transaction type include buy/sales/pledge/revoke/Invoke) It is also clarified for the avoidance of doubts that the disclosure of the incremental transactions after any disclosure under this sub-regulation, shall be made when the transactions effected after the prior disclosure cross the threshold specified in Regulation 7 (2) (a). The above disclosures shall be made in such form and such manner as specified by SEBI from time to time. Further SEBI vide its circular dated September 9, 2020 has prescribed Automation of Continual Disclosures under Regulation 7(2) of SEBI (Prohibition of Insider Trading) Regulations, 2015 - System driven disclosures and discontinuation of disclosures by listed entities after phase-wise implementation of circular. Acquisition of share by Rajesh, the promoter of the company is as under: Acquisition date 5th April, 2025: 10000 * ₹555 = ₹55,50,000 Disposal Date 25th April 2025: 5000 * ₹605 = ₹30,25,000 Acquisition date 10th May, 2025: 15000 * ₹585 = ₹87,75,000 In the instant case, since the aggregate traded value of the securities has exceeded to ₹10 Lakh Rupees in each of the case, Rajesh is required to make disclosure within 2 trading days from each of the transaction date. The company is required to disclose within two trading days of receipt of the disclosure or from becoming aware of such information. Further, each of the transactions are contra-trade to each other i.e. opposite transaction within a period of six months, hence this will also be construed as violation of the provisions of the SEBI (Prohibition of Insider Trading) Regulations, 2015.