Progression Ltd. is a listed Company with a paid up capital of ₹200 Crore divided into 20 crore shares of ₹10 each. R, S, T and U are the promoters of the said company holding 2 crore, 5.40 crore, 0.80 crore and 2.20 cro

In the instant case R, S, T and U being promoters are to be considered as Persons Acting in Concert as per the definition in Securities and Exchange Board of India (Substantial Acquisition of Shares and Takeovers) Regulations, 2011. In terms of Regulation 29(1) of the said Regulations any person together with persons acting in concert crosses 5% of shares or voting rights needs to disclose to the Target Company and concerned Stock Exchanges within 2 working days in the prescribed format and in a similar way, Sub-regulation (2) requires such persons holding more than 5% acquires or sells more than 2% require compliance of the same. As per given case R, S T & U are holding 10%, 27%, 4% and 11% shares respectively. In all the 3 situations, disclosures in the prescribed formats need to be made to the company and concerned stock exchanges as per Regulation 29(2) although transfers involve mere 1.5%, 1.1% & 1% respectively.