Private placement 200 members??

CS Arjun Rajagopal (, ACS) (1056 Points)

14 July 2016  

Dear CCI Members,

In the case of private placement offer shall not be made to more than 200 persons in aggregate during a financial year and this limit excludes QIB's and Employees under ESOP.

Now please clarify from the case mentioned below

XYZ Ltd has made a private placement of debentures to 200 persons during F.Y 2016-17. Can XYZ Ltd again make a private placement to the same person who is included in above 200? Will he be considered as 201th person or included in 200?


Arjun Rajagopal