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Inter se transfer under SAST Code...

This query is : Resolved 

Can any help me on followings:

In one Company listed on BSE, promoter group holds 74.35% shares, now one person of this promoter group want to transfer 3% shares to another person in promoter group in that case:

1). exemption from SAST Regulation will available U/R 3(1)(e) automatically or have to apply sebi for approval?

2).the proposed transfer is of only 3% shares, and transferor is holding 1.5% shares individually making post transfer holding of only 4.5%, however he along with person acting in concert (PAC) was already holding more than 15% shares even before proposed transfer, now wheather it is necessary to file Report U/R 3(4) with SEBI?

Answer to your query is

1. Exemption is available authomatically & no need to apply for sebi approval.

2. No need to file any report under regulation 3(4).

However, according to my opinion, it is advisable to intimate the stock exchanges where the shares of the company are listed the following information for safeguarding the interest of the company.

Name of the Transferor & Transferee
(Specifically mentioning that the transferor & transferee is in promoter group)

No. & % of the shares transferred.

Kindly note that the above disclosure is to be done just as a matter to safeguard the Companys interest beore sebi & stock exchanges & not under any SEBI regulation.

Thanks a lot.... this has a great relife to us...

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