Comment on the following: Negotiated deals, private arrangement and spot transaction methods of buy back of shares are allowed under SEBI (Buy Back of Securities) Regulation, 1998.

Regulation 4(vi) of SEBI (Buy-back of Securities) Regulations, 2018 does not permit buy-back through negotiated deals (of and on stock exchange), private arrangement and spot transactions. According to Regulation 4(iv) of the SEBI (Buy-back of Securities) Regulation, 2018, a company may buy-back its own shares or other specified securities by any one of the following methods: from the existing shareholders or other specified securities holders on a proportionate basis through the tender offer; from the open market through: book-building process stock exchange from odd-lot holders. No offer of buy-back for 15% or more of paid-up capital and free reserves, shall be made from the open market. Alternate Answer [based upon SEBI (Buy-back of Securities) Regulations, 1998] Regulation 4(2) of erstwhile SEBI (Buy-back of Securities) Regulations, 1998 does not permit buy-back through negotiated deals (of and on stock exchange), private arrangement and spot transactions. According to Regulation 4(1) of the SEBI (Buy-back of Securities) Regulation, 1998, a company may buy-back its own shares or other specified securities by any one of the following methods: from the existing shareholders or other specified securities holders on a proportionate basis through the tender offer; from the open market through: book-building process stock exchange from odd-lot holders. No offer of buy-back for 15% or more of paid-up capital and free reserves, shall be made from the open market.