Exemption order under Regulation 11 of SEBI (SAST) Regulations, 2011 in the matter of Paushak Ltd.

WTM/GM/CFD/04/2018–2019 SECURITIES AND EXCHANGE BOARD OF INDIA ORDER UNDER SECTION 11(1)AND SECTION 11(2)(h)OF THE SEBIACT READ WITH REGULATION 11(5)OF THE SECURITIES AND EXCHANGE BOARD OF INDIA (SUBSTANTIAL ACQUISITION OF SHARES AND TAKEOVERS)REGULATIONS,2011. IN THE MATTER OF PROPOSED ACQUISITION OF SHARES AND VOTING RIGHTS IN – TARGET COMPANY PAUSHAK LIMITED ACQUIRER LAKSH TRUST

BACKGROUND –

1.1 Paushak Limited (“Target Company”) was incorporated on May 6, 1972, under the Companies Act, 1956as Darshak Limited. The aforesaid name was subsequently changed to Paushak Limited w.e.f. September 19, 2005. The Registered Office of the Target Company is at Alembic Road, Vadodara, Gujarat–390003. The shares of the Target Company are listed on BSE Limited (“BSE”) and the National Stock Exchange of India Limited(“NSE”).

1.2 An Application dated August 9, 2017 (“Application”) seeking exemption from the applicability of inter alia Regulations 3and 5 of the Securities and Exchange Board of India (Substantial Acquisition of Shares and Takeovers) Regulations, 2011 (“Takeover Regulations”) in the matter of proposed acquisition of shares and voting rights in the Target Company, was received by SEBI from Mr. Chirayu Amin and Mrs. Malika Amin, Trustees of Laksh Trust (“Acquirer Trust”).

1.3 Regulations 3and 5 of the Takeover Regulations state – “Substantial acquisition of shares or voting rights. 3.(1) No acquirer shall acquire shares or voting rights in a target company which taken together with shares or voting rights, if any, held by him and by persons acting in concert with him in such target company, entitle them to exercise twenty-five per cent or more of the voting rights in such target company unless the acquirer makes a public announcement of an open offer for acquiring shares of such target company in accordance with these regulations. (2). No acquirer, who together with persons acting in concert with him, has acquired and holds in accordance with these regulations shares or voting rights in a target company entitling them to exercise twenty-five per cent or more of the voting rights in the target company but less than the maximum permissible non-public shareholding, shall acquire within any Order in the matter of PaushakLimited financial year additional shares or voting rights in such target company entitling them to exercise more than five per cent of the voting rights, unless the acquirer makes a public announcement of an openoffer for acquiring shares of such target company in accordance with these regulations: Provided that such acquirer shall not be entitled to acquire or enter into any agreement to acquire shares or voting rights exceeding such number of shares as would take the aggregate shareholding pursuant to the acquisition above the maximum permissible non-public shareholding.

Explanation — For purposes of determining the quantum of acquisition of additional voting rights under this sub-regulation,— (i) Gross acquisitionsalone shall be taken into account regardless of any intermittent fall in shareholding or voting rights whether owing to disposal of shares held or dilution of voting rights owing to fresh issue of shares by the target company. (ii) In the case of acquisition of shares by way of issue of new shares by the target company or where the target company has made an issue of new shares in any given financial year, the difference between the pre-allotment and the post-allotment percentage voting rights shall be regardedas the quantum of additional acquisition. (3) For the purposes of sub-regulation (1) and sub-regulation (2), acquisition of shares by any person, such that the individual shareholding of such person acquiring shares exceeds the stipulated thresholds, shall also be attracting the obligation to make an open offer for acquiring shares of the target company irrespective of whether there is a change in the aggregate shareholding with persons acting in concert.

Indirect acquisition of shares or control. 5.(1) For the purposes of regulation 3 and regulation 4, acquisition of shares or voting rights in, or control over, any company or other entity, that would enable any person and persons acting in concert with him to exercise or direct the exercise of such percentage of voting rights in, or control over, a target company, the acquisition of which would otherwise attract the obligation to make a public announcement of an open offer for acquiring shares under these regulations, shall be considered as an indirect acquisition of shares or voting rights in, or control over the target company…”

1.4 In the aforementioned Applicationand subsequent submissions, the following was inter alia stated – i. The Acquirer Trust does not hold any shares in the Target Company. ii. As on the date of application, the Promoter and Promoter Group hold 66.91% of the equity shares and voting rights in the Target Company.

Order in the matter of PaushakLimited iii. The pre–acquisition shareholding in the Target Company as on June 30, 2017 along with the proposed post–acquisition shareholding in the Target Company, are provided below:

TABLE A–SHAREHOLDING IN THE TARGET COMPANY (SOURCE:APPLICATION) SR. NAME PRE –ACQUISITION POST –ACQUISITION NO. NO.OF % NO.OF % SHARES SHAREHOLDING SHARES SHAREHOLDING A. PROMOTER/PROMOTER GROUP 1. MALIKA CHIRAYU AMIN (‘TRANSFEROR’) 39,273 1.22 39,273 1.22 2. NIRAYU PVT.LTD. 1,71,535 5.35 1,71,535 5.35 3. SIERRA INVESTMENTS PVT. LTD. 8,15,375 25.42 8,15,375 25.42 4. WHITEFIELD CHEMTECH PVT. LTD. 77,700 2.42 77,700 2.42 5. SHRENO LIMITED 2,37,369 7.40 2,37,369 7.40 6. LAKSH TRUST (‘ACQUIRER TRUST’) 0 0.00 0 0.00 7. CHIRAYU RAMANBHAI AMIN 93,682 2.92 93,682 2.92 8. PRANAV CHIRAYU AMIN 29,599 0.92 29,599 0.92 9. SHAUNAK CHIRAYU AMIN 26,999 0.84 26,999 0.84 10. UDIT CHIRAYU AMIN 26,997 0.84 26,997 0.84 11. ALEMBIC LIMITED 6,10,615 19.04 6,10,615 19.04 12. YERABEN RAMANBHAI AMIN 3,455 0.11 3,455 0.11 13. JYOTI SURESH PATEL 300 0.01 300 0.01 14. NINOCHAKA AKOTHARI 278 0.01 278 0.01 15. SHREYA RUPENDRA MUKHARJI 3,513 0.11 3,513 0.11 16. UJJWAL VIDYALAYA 5,447 0.17 5,447 0.17 17. AROGYAVARDHINI SOCIETY 3,365 0.10 3,365 0.10 18. VIDYANIDHI TRUST 123 0.00 123 0.00 19. VIRSAD FAMILY TRUST 200 0.01 200 0.01 20. LABURNUM FAMILY TRUST 200 0.01 200 0.01 TOTAL 21,46,025 66.91 21,46,025 66.91 B. PUBLIC SHAREHOLDING 10,61,089 33.09 10,61,089 33.09 C. TOTAL (A+B) 32,07,114 100.00 32,07,114 100.00

Order in the matter of PaushakLimited iv. The proposed acquisition of shares by the Acquirer Trust will occur simultaneously as under – a. Mrs. Malika Chirayu Amin is one of the Promoter Group shareholders directly holding 1.22% shareholding in the Target Company. b. Mrs. Malika Chirayu Amin is also holding shares in Nirayu Private Limited, Whitefield Chemtech Private Limited, Sierra Investments Private Limited and Shreno Limited (collectively referred as ‘Promoter Holding Companies’). c. The Acquirer Trust proposes to acquire equity shares in the aforementioned 4 Promoter Holding Companiesfrom Mrs. Malika Chirayu Aminas under–

TABLE B–SHAREHOLDING IN THE PROMOTER HOLDING COMPANY BEING ACQUIRED BY THE ACQUIRER TRUST (SOURCE:APPLICATION) PROMOTER HOLDING COMPANY (PHC) %OF SHARES NO.OF SHARES HELD BY OF PHCBEING RESPECTIVE NAME OF TRANSFERRED %OF SHARES OF PROMOTER TRANSFEROR NAME OF PHC SUCH PHCBEING HOLDING TRANSFERRED COMPANY IN THE TARGET COMPANY NIRAYU PVT.LIMITED 1,29,215 70.39 5.35 MALIKA SIERRA INVESTMENTS PVT.LIMITED 4,88,447 16.67 25.42 CHIRAYU AMIN WHITEFIELD CHEMTECH PVT.LIMITED 4,09,549 32.26 2.42 SHRENO LIMITED 50,454 1.12 7.40

Order in the matter of PaushakLimited v. The Settlor, Trustees and Beneficiaries of Acquirer Trust are as under –

ACQUIRER TRUST SETTLOR TRUSTEES BENEFICIARIES* RELATIONSHIP* Malika 1. Chirayu Ramanbhai 1. Pranav Chirayu The first two Trustees, viz. Chirayu Chirayu Amin Amin Ramanbhai Amin and Malika Chirayu Amin 2. Malika Chirayu Amin 2. Shaunak Chirayu Amin are spouse. Remaining three 3. Pranav Chirayu Amin Amin trustees who are also the beneficiaries are 4. Shaunak Chirayu Amin 3. Udit Chirayu Amin sons of the first two trustees. 5. Udit Chirayu Amin *Amended as per the Addendum to the Trust Deed dated November 10, 2017, which was informed to SEBI vide letter dated November 15, 2017.

vi. The Board of Directors of the Target Company (as provided in the Application) is as follows –

NAME DESIGNATION 1. CHIRAYU AMIN PROMOTER NON-EXECUTIVE (CHAIRMAN) 2. UDIT AMIN PROMOTER NON-EXECUTIVE 3. ABHIJIT JOSHI WHOLE-TIME DIRECTOR 4. SHAMITA AMIN INDEPENDENT DIRECTOR 5. AMIT GARODIA INDEPENDENT DIRECTOR 6. V.H.GANDHI INDEPENDENT DIRECTOR 7. ATUL PATEL INDEPENDENT DIRECTOR vii. Grounds for seeking exemption – a. The Acquirer Trust should fall under ‘Promoter Group’ of the Target Company as its trustees and beneficiaries are promoters and members of the promoter family of the target company. Thus, the proposed acquisition would not result in any increase/ decrease in the holding of the promoters or promoter group. b. The proposed acquisition of shares by the Acquirer Trust from the transferor would not result in change in control and management of the target company. Mr. Chirayu Amin, Mrs. Malika Amin, Mr. Pranav Amin, Mr. Shaunak Amin and Mr. Udit Amin (Trustees of Acquirer Trust) through whom control would be exercised over the assets of the Acquirer Trust, are also the members belonging to promoter and promoter group of the target company in their personal capacity. c. The proposed acquisition is further to an internal reorganization within the Promoter Family and is intended to streamline succession and promote welfare of Promoter Family. The proposed acquisition would be a non-commercial transaction which would not affect or prejudice the interests of the public shareholders of the Target Company in any manner. d. There will be no effective change in the exercise of voting power or in the control/ management of the target company. The change in the identity of persons exercising voting rights over the Target Company would only Order in the matter of PaushakLimited be between persons, who in their personal capacities, are persons belonging to promoter and promoter group of the Target Company and are the relatives of the person transferring the shares.

1.5 Vide a letter dated November 15, 2017, Mr. Chirayu Amin and Mrs. Malika Amin in their capacity as Trustees on behalf of the Acquirer Trust furnished the Addendum to Trust Deed dated November 10, 2017, which suitably incorporated the following conditions:

a. Clause 3.6:‘Family Members’ means the following – i. Mr. Chirayu Ramanbhai Amin, ii. Mrs. Malika Chirayu Amin, iii. Mr. Pranav Chirayu Amin, iv. Mr. Shaunak Chirayu Amin, v. Mr. Udit Chirayu Amin, vi. Spouse of the persons referred to in sub clause (iii), (iv) & (v) above, vii. Lineal Descendants of the persons referred to in sub clause (iii), (iv) & (v) above, b. Clause 3.17:‘Initial Beneficiaries’ shall mean each of the following persons: viii. Mr. Pranav Chirayu Amin, ix. Mr. Shaunak Chirayu Amin, x. Mr. Udit Chirayu Amin c. Clause 13.3: Notwithstanding anything to the contrary contained in other provisions of this deed, no person other than a Family Member as defined in Clause 3.6 shall be eligible to be added as Beneficiary of the Trust.

d. Clause 13.8: In the event any person or class of persons are added to or removed as Beneficiary or Beneficiaries of the Trust, the Trustees shall disclose the same to the concerned Stock Exchange on which the shares of the Company held by the Trust (as a part of Trust Fund), directly or indirectly, are listed and a copy of such disclosure shall be furnished to SEBI.

e. Clause 8.4: In case of dissolution of the Trust as mentioned in Clause 12 of the Deed, the Trust Fund will be distributed only tothe Beneficiaries of the Trust.

f. Clause 14.1: The Beneficiaries shall not create any encumbrance on their interest in the Trust, either directly or indirectly, nor otherwise use such interest in the Trust as collateral for any purpose which could result in an involuntary transfer of such beneficiary’s interest in favour of any person other than a beneficiary.

Order in the matter of PaushakLimited g. Clause 6.8:The liabilities and obligations of the Settlor under SEBI Act, 1992 and regulations framed thereunder shall not change or get diluted.

h. Clause 16.9: Notwithstanding anything to the contrary, no person other than a Family Member as defined in Clause 3.6 shall be eligible to be appointed as the Trustee of the Trust.

i. Clause 16.10: In the event, a new person is appointed as a Trustee of thesaid Trust, the existing Trustees shall disclose such appointment to the concerned Stock Exchange on which the shares of the Company held by the Trust (as a part of Trust Fund), directly or indirectly, are listed and a copy of such disclosure shall be endorsed to SEBI.

j. Clause 17.11: In the event, any Trustee is removed/ retired from the said Trust, the remaining Trustees shall disclose such removal/ retirement to the concerned Stock Exchange on which the shares of the Company held by the Trust (as a partof Trust Fund), directly or indirectly, are listed and a copy of such disclosure shall be furnished to SEBI.

k. Clause 21.2:As far as the provisions of the SEBI Act, 1992 and the regulations framed thereunder are concerned, the ownership or control of shares of a Company (governed by SEBI Act or Regulations framed thereunder) or voting rights thereof held in the Trust, as a part of Trust Fund, will be treated as vesting not only with the Trustees but also with the Beneficiaries.

l. Clause 29: The Trustees shall be only entitled to engage and/ or delegate any of their powers to persons viz. investment manager, attorney, lawyer, accountant, chartered accountants, consultants, advisors, etc. in their professional capacity and the powers vested with the Trustees shall not be delegated to any person for any reason whatsoever.

m. Clause 46.9: The Trustees shall annually, within 7 days from the close of the financial year, provide a statement to the listed company whose shares are directly or indirectly held by it (as a part of Trust Fund), confirming that the Trust is in compliance with the exemption order(s) passed by SEBI and shall require such company to disclose the same prominently as a note to the shareholding pattern filed by the company, pursuant to Regulation 31 of SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015, with the Stock Exchanges for the quarter ending 31stMarch.

n. Clause 46.10: The Trustees shall obtain a certificate annually from a Chartered Accountant as regards the complianceprovided in clause 46.9 and furnish the certificate to the concerned Stock Exchange and to SEBI.

Order in the matter of PaushakLimited o. Clause 52: Notwithstanding anything contained hereinabove, no clause of this Trust Deed shall mean to create any limitation of liability of the Trustees or Beneficiaries in relation to the provisions of SEBI Act, 1992 and the regulations framed thereunder. Further, it is also clarified that each of the Trustees are jointly and severally liable for, and absolutely and unconditionally guarantee to the Beneficiaries, the performance of all obligations under the said Trust Deed.

1.6 It was also submitted on behalf of the Acquirer Trust (vide the letter dated November 15, 2017) that a Scheme of Arrangement proposing the amalgamation of Sierra Investments Private Limited and Whitefield Chemtech Private Limited with Nirayu Private Limited is being considered before the Hon’ble National Company Law Tribunal, Ahmedabad Bench. Pursuant to the approval of the said Scheme of Amalgamation and as a consideration for amalgamation, all the shareholders holding shares of the respective Transferor Companies on the record date, shall be allotted shares in the Transferee Company (i.e. Nirayu Private Limited). Further, all the assets and liabilities, including the shares in the Target Companies held by the Transferor Companies (Sierra Investments Private Limited and Whitefield Chemtech Private Limited) shall stand transferred to Nirayu Private Limited. Accordingly, the shares of Sierra Investments Private Limited and Whitefield Chemtech Private Limited, proposed to be acquired by the Acquirer Trust, shall stand replaced by shares of Nirayu Private Limited as may be issued pursuant to the above referred Scheme of Arrangement. However, the same shall not have any effect on the percentage of shareholding proposed to be indirectly acquired by the Acquirer Trust in the Target Company.

1.7 TheApplication along with the further submissions were forwarded to the Takeover Panel in terms of the provisoto Regulation 11(5) of the Takeover Regulationsand deliberated by the Takeover Panel in its meeting held on December 16, 2017. After deliberations, the Takeover Panel made the following observations – “In case of Paushak Limited…the Panel noted that the applicant trust is the same in the three target companies and that the submissions are in line with the broad guidelines adopted by the Panel. Accordingly, upon deliberation in the matter, the Panel recommended grant of exemption to the proposed transactions in the respective target companies.”

Order in the matter of PaushakLimited

Findings–

2.1 I have considered the Application submitted by the Acquirer Trust along with their additional submissions; the recommendations of the Takeover Panel and other material available on record.

2.2 From the preceding paragraphs, it is noted that –

A. The Application submitted is in respect of the proposed acquisition of shares and voting rights in the Target Companyi.e. Paushak Limited.

B. The aforesaid acquisition is proposed to be made by Laksh Trust i.e. the Proposed Acquirer, in the following manner – i. As on the date of application, the Promoters and Promoter Group hold 66.91% of the equity shares and voting rights in the Target Company. Mrs. Malika Chirayu Amin is one of the Promoter Group shareholders directly holding 1.22% shareholding in the Target Company. Mrs. Malika Chirayu Amin is also holding shares in the Promoter Holding Companies, viz. Nirayu Private Limited, Sierra Investments Private Limited, Whitefield Chemtech Private Limitedand Shreno Limited.

Order in the matter of PaushakLimited ii. Malika Chirayu Amin proposes to transfer her shareholding in the following Promoter Group entities to the Acquirer Trust, as under –

TABLE C–SHAREHOLDING IN THE PROMOTER HOLDING COMPANY BEING ACQUIRED BY THE ACQUIRER TRUST (SOURCE:APPLICATIONAND SUBSEQUENT SUBMISSIONS) PROMOTER TARGET COMPANY HOLDING COMPANY PRE – POST – POST –ACQUISITION ACQUISITION ACQUISITION NO. OF % OF NO. OF % OF NO. OF % OF SHARES SHARES SHARES SHARES SHARES IN SHARES IN THE THE TARGET TARGET COMPANY COMPANY INDIRECTLY INDIRECTLY ACQUIRED ACQUIRED BY BY ACQUIRER ACQUIRER TRUST TRUST THROUGH THROUGH PROMOTER PROMOTER HOLDING HOLDING COMPANY COMPANY NIRAYU PRIVATE Malika Chirayu Amin (‘Transferor’) 1,72,287 93.86 43,072 23.47 LIMITED 1,71,535 5.35 – – 1,29,215 70.39 Laksh Trust (‘Acquirer Trust’) SIERRA Malika Chirayu Amin (‘Transferor’) 6,51,262 22.23 1,62,815 5.56 INVESTMENTS PVT. – – 4,88,447 16.67 8,15,375 25.42 LIMITED Laksh Trust (‘Acquirer Trust’) WHITEFIELD Malika Chirayu Amin (‘Transferor’) 5,46,065 43.01 1,36,516 10.75 CHEMTECH PVT. – – 4,09,549 32.26 77,700 2.42 LIMITED Laksh Trust (‘Acquirer Trust’) SHRENO LIMITED Malika Chirayu Amin (‘Transferor’) 2,38,734 5.30 1,88,280 4.18 – – 50,454 1.12 2,37,369 7.40 Laksh Trust (‘Acquirer Trust’)

iii. Transfer of 1,29,215 (70.39%)equity shares of Nirayu Private Limitedto the Acquirer Trust. iv. Transfer of 4,88,447 (16.67%)equity shares of Sierra Investments Pvt. Limited to the Acquirer Trust. v. Transfer of 4,09,549 (32.26%) equity shares of Whitefield Chemtech Pvt. Limited to the Acquirer Trust. vi. Transfer of 50,454 (1.12%)equity shares of Shreno Limitedto the Acquirer Trust.

C. As per the shareholding pattern of the abovementioned four Promoter Group Companies, there are significant cross–holdings across these companies. Further, pursuant to the proposed acquisitions, the Acquirer Trust would hold shares of the Promoter Group Companies, which in turn hold shares in the Target Company. Order in the matter of PaushakLimited

D. A Scheme of Arrangement involving the amalgamation of Sierra Investments Private Limited and Whitefield Chemtech Private Limited with Nirayu Private Limited is proposed. However, the same shall not affect the shareholding proposed to be indirectly acquired by the Acquirer Trust in the Target Company.

E. The proposed acquisition is further to an internal reorganization within the Promoter Family and is intended to streamline succession and promote welfare of Promoter Family.

F. There will be no change in control of the Target Company pursuant to the proposed acquisition.

G. The pre–acquisition and post–acquisition shareholding of the Promoters in the Target Company will remain the same.

H. There will also be no change in the public shareholding of the Target Company.

I. The Target Company shall continue to be in compliance with the minimum public shareholding requirements under the Securities Contracts Regulation Rules, 1957 (“SCRR”) and the SEBI (Listing Obligations and Disclosure Requirements)Regulations, 2015.

J. The Proposed Acquirer/Acquirer Trust has executed and submitted a copy of the Addendum to the Trust Deed dated November 10, 2017 vide letter dated November 15, 2017.

K. The Takeover Panel has also recommended grant of exemption to the Proposed Acquirer.

2.3 Considering the aforementioned, I am of the view that exemption as sought for in the Application (read with further correspondence/submissions/ clarifications) be granted to the Proposed Acquirer, subject to certain conditions as ordered herein below.

Order in the matter of PaushakLimited

Order –

3.1 I, in exercise of the powers conferred upon me under Section 19 read with Section 11(1) and Section 11(2)(h) of the Securities and Exchange Board of India Act, 1992 (“SEBI Act”) and Regulation 11(5) of the Takeover Regulations, hereby grant exemption to the Proposed Acquirer, viz. Laksh Trust, from complying with the requirements of Regulation 3 and 5 of the Takeover Regulations with respect to the proposed acquisition/exercise of voting rights in respect of the Target Company, viz. Paushak Limited, by way of proposed transactions as mentioned in the Application.

3.2 The exemption so granted is subject to the following conditions:

i. The proposed acquisition shall be in accordance with the relevant provisions of the Companies Act, 2013 and other applicable laws. ii. On completion of the proposed acquisition, the Proposed Acquirer shall file a report with SEBI within a period of 21 days from the date of such acquisition, as provided in the Takeover Regulations. iii. The statements/ averments made or facts and figures mentioned in the Application and other submissions by the Proposed Acquirer are true and correct. iv. The provisions of the SEBI Act and the Regulations framed thereunder will apply on the basis that the ownership or control of shares or voting rights vests not only directly on the Trustees but also indirectly on the beneficiaries of the Proposed Acquirer. v. There shall be no limitation of liability of the Trustees/beneficiaries in relation to the provisions of the SEBI Act and all Regulations framed thereunder. vi. The Proposed Acquirer shall honour its undertakings and shall also ensure compliance with the statements, disclosures and undertakings made in the Application and in the subsequent correspondence. vii. The Proposed Acquirer shall confirm, on an annual basis, that it is in compliance with the Exemption Order passed by SEBI. The said confirmation shall be furnished to the Target Company, which shall disclose prominently as a note to the shareholding pattern filed for the quarter ending March 31 each year, under Regulation 31 of the SEBI (Listing Obligations and Disclosure Requirements)Regulations, 2015. viii. The Proposed Acquirer shall get the compliance status certified from an independent auditor annually and furnish the same to the Stock Exchanges with a copy endorsed to SEBI for its records.

Order in the matter of PaushakLimited ix. The liabilities and obligations of the transferor under the SEBI Act and Regulations framed thereunder will not change or get diluted due to transfers to the Proposed Acquirer. x. The Proposed Acquirer shall also ensure that the covenants in the Trust Deeds are not contrary to the above conditions and undertaking provided by the transferors. In such case, the Trust Deeds shall be suitably modified and expeditiously reported to SEBI.

3.3 The exemption granted above is limited to the requirements of making open offer under the Takeover Regulations and shall not be construed as exemption from the disclosure requirements under Chapter V of the aforesaid Regulations; compliance with the SEBI (Prohibition of Insider Trading) Regulations, 2015; Listing Agreement/SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015 or anyother applicable Acts, Rules and Regulations.

3.4 The Application dated August 9, 2017, filed by Mr. Chirayu Amin and Mrs. Malika Amin, Trustees of Laksh Trust, is accordingly disposed of.

Place: Mumbai G. MAHALINGAM Date: April 6, 2018 WHOLE TIME MEMBER SECURITIES AND EXCHANGE BOARD OF INDIA

Order in the matter of PaushakLimited