General information about company | |
| Scrip Code* | 540147 |
| NSE Symbol* | NA |
| MSEI Symbol | |
| ISIN | INE700V01013 |
| Name of the listed entity | SHASHIJIT INFRAPROJECTS LIMITED |
| Date of start of financial year | 01-04-2022 |
| Date of end of financial year | 31-03-2023 |
| Date of Reporting to Exchange | 28-06-2023 |
| Whether any observations reported by the Secretarial Auditor | Yes |
| The listed entity has maintained proper records under the provisions of the above Regulations and circulars/ guidelines issued thereunder insofar as it appears from my/our examination of those records. | Yes |
| In previous, Any actions taken against the listed entity/its promoters/directors/its material subsidiaries either by SEBI or by stock exchanges (including under the Standard operating procedures issued by SEBI through various circulars). | No |
| Is there any observation made in the previous report | Yes |
| Name of the Certifying Firm | NITESH P. SHAH |
| Name of the practicing Company Secretary issuing the report | NITESH PARASMAL SHAH |
| Membership Type | ACS |
| ACS/FCS No. | 35681 |
| UDIN | A035681E000423772 |
| CP No. | 13222 |
| Place of PCS | Ahmedabad |
| PCS Report Date | 30-05-2023 |
Regulations | |||
| Sr No | Regulation | Applicability during the period under review (Yes/No) | Any Observation (Yes/No) |
| 1 | Securities and Exchange Board of India (Listing Obligations and Disclosure Requirements) Regulations, 2015 | Yes | No |
| 2 | Securities and Exchange Board of India (Issue of Capital and Disclosure Requirements) Regulations, 2018 | Yes | No |
| 3 | Securities and Exchange Board of India (Substantial Acquisition of Shares and Takeovers) Regulations, 2011 | Yes | No |
| 4 | Securities and Exchange Board of India (Buyback of Securities) Regulations, 2018 | No | No |
| 5 | Securities and Exchange Board of India (Share Based Employee Benefits) Regulations, 2014 | No | No |
| 6 | Securities and Exchange Board of India (Issue and Listing of Debt Securities) Regulations, 2008 | No | No |
| 7 | Securities and Exchange Board of India(Issue and Listing of Non-Convertible and Redeemable Preference Shares) Regulations,2013 | No | No |
| 8 | Securities and Exchange Board of India (Prohibition of Insider Trading) Regulations, 2015 | Yes | Yes |
| 9 | Specify any other regulation applicable to the Company | ||
| 1 | SECURITIES AND EXCHANGE BOARD OF INDIA (DEPOSITORIES AND PARTICIPANTS) REGULATIONS, 2018 | Yes | No |
Current Report | |||||||||||||
| Sr No | Compliance requirement (regulations/circulars/ guidelines including specific clauses) | Regulation Name/ SEBI Circular number | Regulation Number/ circular dated | Deviations | Action taken by | Name of Other Regulatory Body | Type of Action (Advisory/Clarification/Fine/Show Cause Notice/ Warning, etc.) | Details of other action taken | Details of violation | Fine Amount | Observations/remarks of the practising Company Secretary, if any | Management Response | Remarks |
| 1 | Regulation 3(5) of SEBI (Prohibition of Insider Trading) Regulations, 2015 | Securities and Exchange Board of India (Prohibition of Insider Trading) Regulations, 2015 | Regulation 3(5) of SEBI (Prohibition of Insider Trading) Regulations, 2015 | The Company had shared UPSI to Audit Committee and the Board of the Directors of the Company for the legitimate purpose in the months of May, 2022 but the entry was made in the Structured Digital Database in the month of August, 2022. | Other Regulatory Body | NA | Other | NA | Violation of Regulation 3(5) of the SEBI (prohibition of Insider Trading) Regulations, 2015 | As the Company did not make entry in the Structured Digital Database prior to Sharing of the USPI thus, the Company has made violation of Regulation 3(5) of the SEBI (prohibition of Insider Trading) Regulations, 2015 | The Management of the Company has responded that the Company had made entry in the Structured Digital Database prior to the sharing of information to the Audit Committee and the Board of Directors of the Company respectively but due to some technical issue unknown to us in the Structured Digital Database Software, the entry was not recorded and the Management of the Company was under bonafied belief that the entry has been made and recorded in the database. When the Company became aware of such violation, the Company made entry immediately in the database and made compliance of the regulation. Thus, the Company has complied with the provisions of Regulation 3(5) of the SEBI (prohibition of Insider Trading) Regulations, 2015. The management further responded that the Company has made all the entries of Sharing of UPSI in the Structured Digital Database during the year except the aforesaid two entries which were due to the reason beyond our control. It is further stated that there was no malafide intention of the Company and the Company has complied with the aforesaid regulation immediately on becoming aware of the violation. | The Required action has been taken by the Company to rectify the violation as aforesaid made by the Company | |
Previous Report | |||||||||||||||
| Sr No | Compliance requirement (regulations/circulars/ guidelines including specific clauses) | Regulation Name/ SEBI Circular number* | Regulation Number/ circular dated | Deviations | Actions taken by | Name of Other Regulatory Body | Type of Action (Advisory/Clarification/Fine/Show Cause Notice/ Warning, etc.) | Details of other action taken | Details of violation | Fine Amount | Observations of the practicing Company secretary in the previous reports | Observations made in the secretarial compliance report for the year ended.(the years are to be mentioned) | Comments of the practicing company secretary on the actions taken by the listed entity. | Management Response | Remarks |
| 1 | SEBI (Prohibition of Insider Trading) Regulations, 2015 | Securities and Exchange Board of India (Prohibition of Insider Trading) Regulations, 2015 | SEBI/HO/ISD/ISD/CIR/P/2020/168 dated 09th September, 2020 | The Listed Company has not updated the changes in the information of the designated persons with the designated depository on the same day. | Other Regulatory Body | NA | Other | NA | The Company had not updated the changes in the information of the designated persons with the designated depository on the same day. | During the Financial Year 2021-22, there had been a change in the Designated Persons as determined pursuant to the provisions of SEBI (Prohibition of Insider Trading) Regulations, 2015 but the Listed Company had not updated the same with the designated depository on the same day as required pursuant to Clause 4 of Annexure A of SEBI Circular No: SEBI/HO/ISD/ISD/CIR/P/2020/168 dated 09th September, 2020. | 2021-22 | NA | The Management has responded that the aforesaid violation was made due to oversight and without any malafide intention on the part of the Company. It is further stated that the Company has complied with the aforesaid violation immediately on becoming aware of it. | The Required action has been taken by the Company to rectify the violation as aforesaid made by the Company. | |
Affirmation | |||
| Sr No | Regulation | Compliance status (Yes/No/NA) | Observations /Remarks by PCS* |
| 1 | Secretarial Standards: The compliances of the listed entity are in accordance with the applicable Secretarial Standards (SS) issued by the Institute of Company Secretaries India (ICSI) | Yes | |
| 2 | Adoption and timely updation of the Policies | ||
| (a) | All applicable policies under SEBI Regulations are adopted with the approval of board of directors of the listed entities | Yes | |
| (b) | All the policies are in conformity with SEBI Regulations and has been reviewed & timely updated as per the regulations/circulars/guidelines issued by SEBI | Yes | |
| 3 | Maintenance and disclosures on Website | ||
| (a) | The Listed entity is maintaining a functional website | Yes | |
| (b) | Timely dissemination of the documents/ information under a separate section on the website | Yes | |
| (c) | Web-links provided in annual corporate governance reports under Regulation 27(2) are accurate and specific which re-directs to the relevant document(s)/ section of the website | Yes | |
| 4 | Disqualification of Director: None of the Director of the Company are disqualified under Section 164 of Companies Act, 2013 | Yes | |
| 5 | To examine details related to Subsidiaries of listed entities: (a) Identification of material subsidiary companies (b) Requirements with respect to disclosure of material as well as other subsidiaries | NA | Company does not have any Subsidiary |
| 6 | Preservation of Documents: The listed entity is preserving and maintaining records as prescribed under SEBI Regulations and disposal of records as per Policy of Preservation of Documents and Archival policy prescribed under SEBI LODR Regulations, 2015 | Yes | |
| 7 | Performance Evaluation: The listed entity has conducted performance evaluation of the Board, Independent Directors and the Committees at the start of every financial year as prescribed in SEBI Regulations | Yes | |
| 8 | Related Party Transactions | ||
| (a) | The listed entity has obtained prior approval of Audit Committee for all Related party transactions | Yes | |
| (b) | In case no prior approval obtained, the listed entity shall provide detailed reasons along with confirmation whether the transactions were subsequently approved/ratified/rejected by the Audit committee | Yes | |
| 9 | Disclosure of events or information: The listed entity has provided all the required disclosure(s) under Regulation 30 alongwith Schedule III of SEBI LODR Regulations, 2015 within the time limits prescribed thereunder. | Yes | |
| 10 | Prohibition of Insider Trading: The listed entity is in compliance with Regulation 3(5) & 3(6) SEBI (Prohibition of Insider Trading) Regulations, 2015 | No | As the Company did not make entry in the Structured Digital Database prior to Sharing of the USPI thus, the Company has made violation of Regulation 3(5) of the SEBI (prohibition of Insider Trading) Regulations, 2015 |
| 11 | Actions taken by SEBI or Stock Exchange(s), if any: No Actions taken against the listed entity/ its promoters/ directors/ subsidiaries either by SEBI or by Stock Exchanges (including under the Standard Operating Procedures issued by SEBI through various circulars) under SEBI Regulations and circulars/ guidelines issued thereunder | Yes | |