Private placement 200 members??

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?

Regards,

Arjun Rajagopal