Issuu

The Delisting Playbook Rules, Routes and Regulatory Hurdles CS RACHIT SHARMA Sr. Manager, Research and Advisory, Taxmann

Contents 1.

Introduction

Key definitions every Practitioner should have at hand

Scope, applicability and the threshold conditions

Voluntary Delisting: Two distinct routes

The Exit opportunity mechanism (Chapter IV)

Compulsory Delisting (Chapter V)

Special Provisions for Particular Categories of Companies (Chapter VI)

Relisting, Relaxations and Other Residual Provisions (Chapter VII and VIII)

A Practitioner’s Checklist

10.

Conclusion

1. Introduction Delisting is, in essence, the reverse of an IPO. A company that once invited the public to become its shareholders now seeks to buy them out and remove its shares permanently from the trading platform of the stock exchange1. Delisting is deceptively simple to describe and remarkably difficult to execute. The law gives public shareholders considerable leverage, and this leverage, exercised through the reverse book building mechanism, has made or broken many well-funded delisting attempts. The SEBI (Delisting of Equity Shares) Regulations, 2021 replaced the 2009 Regulations and have themselves been amended twice since: first by the 2024 amendment, which introduced a fixed price alternative, a framework for investment holding companies and a revised floor-price methodology, and again by the 2025 amendment, which added a dedicated regime for public sector undertakings. This write-up walks through the Regulations, as amended up to September 2025, in the sequence a practitioner would actually encounter them: definitions and scope, the threshold conditions, the two routes of voluntary delisting, the mechanics of the exit opportunity, compulsory delisting, the special dispensations of Chapter VI, and the residual provisions on relisting and regulatory relaxation. Illustrations and real market episodes are used along the way, because the numbers in this regulation only make real sense once they are watched playing out on a stock exchange screen.

2. Key definitions every Practitioner should have at hand Regulation 2 is unusually dense for a definitions clause, because several expressions used throughout the Regulations borrow their meaning from the Takeover Regulations or the Issue of Capital and Disclosure Requirements Regulations rather than being defined afresh. The terms that matter most in day-to-day practice are summarised below.

Term

Meaning in Brief

Source

Acquirer

A person who decides to make a delisting offer along with persons acting in concert, or who is the promoter/part of the promoter group along with persons acting in concert

Reg. 2(1)(b)

Frequently traded shares

Shares meeting the trading-frequency test under the Takeover Regulations

Reg. 2(1)(n)

Floor price

The minimum price the acquirer may offer while proposing voluntary delisting, computed under Regulation 19A

Reg. 2(1)(m)

Indicative price

A price higher than the floor price that the acquirer may voluntarily offer upfront

Reg. 2(1)(o)

Discovered price

The price arrived at through the reverse book building process under Schedule II

Reg. 2(1)(l)

Fixed delisting price

The upfront price offered by the acquirer under the fixed price process

Reg. 2(1)(la)

Regulation 2(1)(j) of the SEBI (Delisting of Equity Shares) Regulations, 2021 defines ‘delisting’ as the permanent removal of equity shares of a company from the trading platform of a recognised stock exchange, either voluntarily or compulsorily.

The Delisting Playbook Rules, Routes and Regulatory Hurdles

Term

Meaning in Brief

Source

Delisting period

The period from the date of initial public announcement to the date of payment of consideration, or the date of return of shares if the offer fails

Reg. 2(1)(k)

Investment Holding Company

A company holding investments in listed or unlisted companies, or other assets besides such investments

Reg. 2(1)(ra)

Persons acting in concert / promoter / promoter group / control

Borrowed, without modification, from the Takeover Regulations and the ICDR Regulations

Reg. 2(1)(u), (v), (w), (e)

3. Scope, applicability and the threshold conditions 3.1 Voluntary and Compulsory Delisting The Regulations recognise two distinct routes. The term ‘Voluntary delisting’ is initiated by the company or an acquirer, on an application made under Chapter III of the Regulations2. The term ‘Compulsory delisting’, by contrast, is a punitive removal ordered by a recognised stock exchange under Chapter V, typically for chronic non-compliance3. The two routes could not be more different in spirit: one is a commercial decision taken by a promoter or acquirer who wants full ownership; the other is a consequence visited upon a company, its promoters and its directors for failing the market.

3.2 Scope and Carve-Outs The Regulations apply to the delisting of equity shares, including shares with superior voting rights, from all or any of the recognised stock exchanges on which they are listed4. Three categories of companies fall outside this framework altogether: (a) companies listed and traded on the innovators growth platform without having made a public issue; (b) companies delisted pursuant to a resolution plan approved under section 31 of the Insolvency and Bankruptcy Code, 2016, provided the public shareholders are given an exit opportunity at a price not less than what promoters or other shareholders receive, with the exit justification disclosed to the stock exchange within one day of approval of the plan; and (c) delistings that occur by operation of law, such as winding-up proceedings or withdrawal of recognition granted to a stock exchange. (Regulation 3(2) and Regulation 38 of the Delisting Regulations.)

3.3 Conditions precedent to any delisting Regulation 4 sets out the gatekeeping conditions5. These are typically the first four questions a promoter walking in with a delisting proposal should be asked, because getting any one of them wrong can derail the timeline by months: 2 3 4 5

Regulation 2(1)(bb) of the Delisting Regulations. Regulation 2(1)(g) read with Chapter V of the Delisting Regulations. Regulation 3(1) of the Delisting Regulations. Regulation 4 of the Delisting Regulations.

The Delisting Playbook Rules, Routes and Regulatory Hurdles

(a) Has the class of equity shares been listed for at least three years? (b) Are there any outstanding instruments convertible into the same class of shares? If yes, they must be dealt with before an application can even be made. (c) Has a buyback (including one pursuant to consolidation or division of all or part of the equity capital) been completed at least six months ago? (d) Has a preferential allotment been completed at least six months ago? (This condition does not apply where a new acquirer has stepped in under Regulation 5A of the Takeover Regulations, or a new promoter has been reclassified under the Listing Regulations.) Regulation 4 also carries three anti-abuse safeguards that are easy to overlook. First, an acquirer who sold the equity shares of the company in the six months preceding the initial public announcement is barred from proposing a delisting6. Second, none of the conditions relating to listing history or the convertible-instrument bar shall apply to a delisting falling under Regulation 5 (delisting from some of the recognised stock exchanges only)7. Third, and most fundamentally, no acquirer shall directly or indirectly use company funds to finance the exit opportunity, and no acquirer shall employ any device, scheme to defraud any shareholder or other person or engage in any transaction or practice that operates as a fraud or deceit upon any shareholder or other person or engage in any fraudulent, deceptive or manipulative practice in connection with the delisting8. This last safeguard is the provision SEBI reaches for whenever a delisting is later found to have been engineered through concert-party accumulation or price manipulation.

4. Voluntary Delisting: Two distinct routes Chapter III of the Regulations offers two routes for voluntary delisting, and the choice between them depends entirely on whether the shares will continue to trade on any exchange with nationwide terminals after the exercise.

4.1 Route A: Delisting from Some Exchanges, No Exit Opportunity Where a company wants to come off a regional or smaller exchange while remaining listed on an exchange with nationwide trading terminals (in practice, the BSE or the NSE), it does not need to provide an exit opportunity to public shareholders9. The company obtains board approval, applies to the relevant exchange, issues a public notice in at least one English, Hindi, and one vernacular newspaper stating the reasons for delisting and confirming continued listing elsewhere, and discloses the delisting in its next annual report10. The exchange must dispose of the application within thirty working days of a complete application11. This is the housekeeping route, used mostly to shed listings on defunct regional exchanges, and it rarely detains a practitioner for long.

6 7 8 9 10 11

Regulation 4(2) of the Delisting Regulations. Regulation 4(3) of the Delisting Regulations. Regulation 4(4) and 4(5) of the Delisting Regulations. Regulation 5 of the Delisting Regulations. Regulation 6(1) and 6(2) of the Delisting Regulations. Regulation 6(3) of the Delisting Regulations.

The Delisting Playbook Rules, Routes and Regulatory Hurdles

4.2 Route B: Delisting from All Exchanges, Exit Opportunity Required This is the route that occupies most of a delisting practitioner’s working life. Where a company wishes to delist from every recognised stock exchange with nationwide trading terminals, it must first provide an exit opportunity to all public shareholders, following the elaborate procedure in Part B of Chapter III read with Chapter IV 12. The stages below are best read together with the detailed treatment of Chapter IV that follows in the Delisting Regulations.

4.2.1 Initial Public Announcement and Appointment of the Manager On the date the acquirer decides to delist voluntarily, it makes an initial public announcement to all exchanges on which the shares are listed, and the exchanges must disseminate it to the public forthwith13. A copy of the initial public announcement must reach the company’s registered office within one working day14, and the announcement must disclose the reasons for delisting, along with an undertaking of compliance with Regulation 4(2) and 4(5), without omitting relevant information or containing any misleading information. Before making this announcement, the acquirer must appoint a SEBI-registered merchant banker as Manager to the Offer, who cannot be an associate of the acquirer, and route every subsequent step through that Manager15.

4.2.2 Board Approval and the Peer Review Company Secretary’s Due Diligence The company’s Board must approve the delisting proposal within twenty-one days of the date of the initial public announcement16. Before doing so, the Board appoints a Peer Review Company Secretary and hands over two years of trading and off-market transaction data relating to the acquirer, its related entities, and the top twenty-five shareholders, along with any further information the Company Secretary considers necessary17. The Company Secretary shall carry out the due diligence and submit a report to the Board of Directors certifying whether that trading history complies with applicable securities laws, including the anti-fraud safeguard in Regulation 4(5)18. Only on the strength of that report can the Board certify that the company and the acquirer are compliant with securities laws and that the delisting is in shareholders’ interest19. The Board must disclose both the due-diligence report and the audit report under Regulation 12(2) to the exchanges alongside its decision20. This is not a paper exercise: it is SEBI’s principal tool for catching pre-announcement accumulation of shares by the acquirer or its associates.

4.2.3 Shareholder Approval and In-Principle Approval Shareholder approval must follow as a special resolution, passed by postal ballot or e-voting, within forty-five days of the Board’s approval21, with full disclosure of material 12 13 14 15 16 17 18 19 20 21

Regulation 7 of the Delisting Regulations. Regulation 8(1) of the Delisting Regulations. Regulation 8(2) of the Delisting Regulations. Regulation 9 of the Delisting Regulations. Regulation 10(1) of the Delisting Regulations. Regulation 10(2) of the Delisting Regulations. Regulation 10(3) of the Delisting Regulations. Regulation 10(4) of the Delisting Regulations. Regulation 10(5) and 10(6) of the Delisting Regulations. Regulation 11(1) and 11(2) of the Delisting Regulations. The Delisting Playbook Rules, Routes and Regulatory Hurdles

facts in the explanatory statement22. Critically, the resolution is acted upon only if the votes cast in favour by public shareholders are at least twice the votes cast against by public shareholders. This test filters out delistings driven purely by promoter voting power23. Within fifteen working days of the date of passing of the special resolution (or of any other statutory approval, whichever is later), the company applies to the relevant exchange for in-principle approval, accompanied by a six-month audit report as required under the SEBI (Depositories and Participants) Regulations, 201824. The exchange must dispose of a complete application seeking in-principle approval for delisting within fifteen working days of receipt of a complete application. Further, the exchange cannot unfairly withhold approval. However, it may satisfy itself on matters such as investor-grievance resolution, payment of listing fees, pending litigation and compliance with the Listing Regulations or any other relevant matter as it may deem fit25. Stage

Timeline

Regulatory Anchor

Initial public announcement

On the date the delisting decision is taken

Reg. 8

Appointment of Manager to the Offer

Before the initial public announcement

Reg. 9

Board approval, on Peer Review CS due diligence

Within 21 days of the initial announcement

Reg. 10

Shareholders’ special resolution

Within 45 days of Board approval

Reg. 11

In-principle approval of exchange

Application within 15 working days of the resolution; disposed of within 15 working days

Reg. 12

Escrow — 25% deposit

Within 7 working days of shareholder approval

Reg. 14(1)

Escrow — balance 75% deposit

Before the detailed public announcement

Reg. 14(3)

Detailed public announcement

Within 1 working day from the date of receipt of in-principle approval

Reg. 15

Letter of offer dispatched

Within 2 working days of the detailed public announcement

Reg. 16

Bidding/tendering period

Opens within 7 working days of the detailed announcement; open for 5 working days

Reg. 17

Outcome announcement

Within 2 working days of closure of the bidding period

Reg. 17(4)

Payment of consideration

Immediately (secondary market) or within 5 working days of the outcome announcement

Reg. 24

Final application to exchange

Within 5 working days from the date of making payment to public shareholders

Reg. 25

22 23 24 25

Regulation 11(3) of the Delisting Regulations. Regulation 11(4) of the Delisting Regulations. Regulation 12(1) and 12(2) of the Delisting Regulations. Regulation 12(3) and 12(4) of the Delisting Regulations.

The Delisting Playbook Rules, Routes and Regulatory Hurdles

Case Study | Hexaware Technologies — a rare success story (2020) Baring Private Equity Asia, through its holding vehicle HT Global IT Solutions Holdings, held roughly 62% of Hexaware Technologies and launched a voluntary delisting offer in June 2020. The floor price was fixed at around Rs.265 per share. Over a five-day reverse book building window in September 2020, public shareholders tendered enough shares to take the acquirer’s post-offer holding past 90%, and the discovered price settled at Rs. 475 per share, a premium of nearly 80% over the floor price. Baring accepted the discovered price, and Hexaware became one of the very few large, fully sponsor-backed take-private transactions to succeed in India, as reported contemporaneously by Business Standard and law-firm deal write-ups. The lesson for practitioners is that a realistic floor price, sustained institutional support and a promoter genuinely prepared to pay a fair premium are what separate a successful delisting from a failed one. Case Study | UTV Software Communications — a promoter-driven buyout (201112) Walt Disney already held just over 50% of UTV Software Communications when, in July 2011, it offered to buy out its public shareholders (roughly 29.96% of the company) via the delisting’s reverse book building process, at a ceiling price of Rs.1,000 per share, valuing that public offer at roughly Rs.1,208 crore. The promoter group’s own shares were consolidated separately, outside the statutory exit-opportunity mechanism, which under the Regulations extends only to public shareholders. The bidding window closed on 20 January 2012 with the discovered price rising to Rs.1,100 per share to cross the 90% threshold, and UTV’s shares were suspended from trading on the BSE and the NSE in March 2012, not January 2012. This transaction is a useful counterpoint to Vedanta: it shows that a delisting launched from a majority position, with a price shareholders regarded as fair, can move through the reverse book building process without the drama that accompanies a delisting launched from a bare 50-plus-per-cent base against an actively traded, widely held stock.

5. The Exit opportunity mechanism (Chapter IV) Chapter IV is the engine room of the Regulations. It governs every voluntary delisting that requires an exit opportunity, and a practitioner who does not have its escrow, pricing, tendering and disclosure mechanics down cold will struggle to run a delisting on time.

5.1 The Escrow Account Within seven working days of obtaining shareholder approval, the acquirer must open an interest-bearing escrow account with a Scheduled Commercial Bank and deposit 25% of the total estimated consideration, calculated based on the number of equity shares outstanding with the public shareholders multiplied by the floor price or the indicative price (whichever is higher) for the reverse book building process, or the fixed delisting price in case delisting is proposed through the fixed price process26. 26 Regulation 14(1) of the Delisting Regulations, as substituted by the 2024 Amendment Regulations w.e.f. 25 September 2024.

The Delisting Playbook Rules, Routes and Regulatory Hurdles

The acquirer, the Manager to the Offer and the bank must enter into a tripartite agreement authorising the Manager to operate the account27. Before making the detailed public announcement, the acquirer must deposit in the escrow account the remaining 75% of the total consideration amount28, and must immediately top up any shortfall discovered once the final price is known29. The escrow account must consist of either the cash deposited with a Scheduled Commercial Bank, a bank guarantee in favour of the Manager to the Offer, or a combination of both30. Where the escrow account consists of cash, the Manager is authorised to make electronic transfers or issue banker’s cheques for permitted purposes, and to release any surplus to the acquirer once consideration has been fully paid31. Where the escrow account consists of a bank guarantee, the bank guarantee must remain valid until payments are made for all shares tendered32. If the offer fails, 99% of the escrowed amount is released to the acquirer within one working day of the public announcement, with the remaining 1% held back until the shares are returned to shareholders or the lien on them is revoked33.

5.2 Detailed Public Announcement, Letter of Offer and Schedule I Disclosures Within one working day of receiving in-principle approval, the acquirer must publish a detailed public announcement in at least one English, Hindi, and vernacular newspaper in the region where the recognised stock exchange is located. The detailed public announcement must contain all material information including the information specified in Schedule I and must not contain any false or misleading statement. The announcement must specify a date, i.e. being a day not later than one working day from the date of the announcement, which shall be the ‘specified date’ for determining the names of shareholders to whom the letter of offer must be sent. The detailed public announcement must be dated and signed on behalf of the Board (by the Manager or Secretary and at least two directors, one of whom must be the managing director where there is one)34. Schedule I prescribes the minimum contents of the detailed public announcement, which in summary must cover: the floor price, offer price and their basis; the escrow details; the object of the proposed delisting and the proposed timetable; three years of stock market data and six months of monthly price and volume data; the present and expected postdelisting shareholding pattern; a statement on material deviation in utilisation of issue proceeds over the preceding five years; and Board certifications of compliance with the securities laws35. The letter of offer must be dispatched within two working days of the date of the detailed public announcement36. 27 28 29 30 31 32 33 34 35 36

Regulation 14(2) of the Delisting Regulations. Regulation 14(3) of the Delisting Regulations. Regulation 14(4) of the Delisting Regulations. Regulation 14(5) of the Delisting Regulations. Regulation 14(6) of the Delisting Regulations. Regulation 14(7) of the Delisting Regulations Regulation 14(8) and 14(9) of the Delisting Regulations. Regulation 15 of the Delisting Regulations. Schedule I of the Delisting Regulations, read with Regulation 15(2). Regulation 16 of the Delisting Regulations.

The Delisting Playbook Rules, Routes and Regulatory Hurdles

The letter of offer must be sent to all public shareholders holding equity shares of the class sought to be delisted, whose names appear on the register of the company or depository as on the date specified in the detailed public announcement. A copy of the letter of offer must also be made available on the websites of the company and the manager to the offer for the benefit of all public shareholders. The letter of offer must be accompanied by a form for the use of public shareholders to either create a lien or tender physical shares, as the case may be. Further, a shareholder may participate in the offer for delisting of equity shares and make bids even without receiving the form or physical letter of offer, using the tendering mechanism specified by SEBI37.

5.3 Fixing the Floor Price The floor price is the statutory minimum below which the delisting cannot proceed, and it is the highest of five parameters set out in Regulation 19A: the volume-weighted average acquisition price over the preceding 52 weeks, the highest price paid in the preceding 26 weeks, an independently determined adjusted book value (not applicable to public sector undertakings), the 60-day volume-weighted market price for frequently traded shares, or an independent valuer’s assessment for infrequently traded shares38. The reference date for this computation is the date of the initial public announcement, or the next trading day if the announcement was made after market hours or on a nontrading day39. This is a mechanical, formula-driven floor: the acquirer cannot simply propose a low number and hope shareholders accept it.

Illustration | Working out the adjusted book value Assume a company’s balance sheet shows total assets (other than jewellery, art, shares/securities and immovable property) of Rs.800 crore, immovable property with a stamp-duty value of Rs.150 crore, quoted investments worth Rs.50 crore at market value, and total liabilities of Rs.600 crore, excluding paid-up equity capital, undeclared dividend reserves, reserves and surplus, provisions for ascertained liabilities and contingent liabilities other than arrears of cumulative preference dividends. Adjusted book value = A + B + C + D − L = Rs.800 crore + Nil + Rs.50 crore + Rs.150 crore − Rs.600 crore = Rs.400 crore. If the company has 40 crore shares outstanding, the adjusted book value works out to Rs.10 per share. This figure is only one of the five parameters in Regulation 19A; the floor price is the highest of the five.

37 Regulation 16(7) of the Delisting Regulations. 38 Regulation 19A(1) of the Delisting Regulations, inserted by the 2024 Amendment Regulations w.e.f. 25 September 2024. 39 Regulation 19A(2) of the Delisting Regulations.

The Delisting Playbook Rules, Routes and Regulatory Hurdles

5.4 Reverse Book Building, the Discovered Price and Who May Participate Public shareholders holding the class of shares sought to be delisted are entitled to participate in the reverse book building (or fixed price) process in the manner specified in Schedule II40; Holders of depository receipts and their custodians may not participate unless they first convert into the underlying equity shares41. Bids are placed through an electronically linked transparent facility operated across at least the four metropolitan bidding centres (Mumbai, Delhi, Kolkata, Chennai) plus any city specified by the exchange42, and may be revised upwards, but never downwards, until one day before the bidding period closes43. The discovered price is the price at which the acquirer’s post-offer shareholding, taken together with the shares validly tendered (excluding shares held by overseas depository custodians, employee benefit trusts, and specified inactive shareholders), first reaches 90% of the total issued shares of that class44. This 90% threshold, and not the highest bid received, is what determines the price, and it is precisely this feature that has produced some of the steepest premiums, and some of the most spectacular failures, in Indian delisting history. Illustration | How the discovered price is found Suppose a company has 1,00,00,000 public shares outstanding and the acquirer needs 60,00,000 of them to cross the 90% mark. The floor price is Rs.100. Shareholders tender as follows: 15,00,000 shares at Rs.100, 20,00,000 shares at Rs.110, 15,00,000 shares at Rs.120, and 12,00,000 shares at Rs.135. Cumulative tender at Rs.100 = 15,00,000. At Rs.110 = 35,00,000. At Rs.120 = 50,00,000. At Rs.135 = 62,00,000, which is the first point at which the cumulative tender crosses the 60,00,000 threshold. The discovered price is therefore Rs.135, and the acquirer must pay every accepted shareholder Rs.135 per share, not the price each of them individually bid, provided the acquirer accepts that price rather than rejecting it or making a counter-offer.

40 Regulation 19(1) of the Delisting Regulations. 41 Regulation 19(3) of the Delisting Regulations. 42 Schedule II, paragraphs 1 and 3 of the Delisting Regulations. 43 Schedule II, paragraph 5 of the Delisting Regulations. 44 Schedule II, paragraph 13 of the Delisting Regulations, read with Regulation 21.

The Delisting Playbook Rules, Routes and Regulatory Hurdles

Case Study | Vedanta Limited — a Rs.1 lakh crore-plus delisting that failed (2020) In May 2020, Vedanta Resources, through its promoter group, launched a bid to delist Vedanta Limited at a floor price of Rs.87.25 per share, needing to acquire about 134 crore shares from the public to cross 90%. The reverse book building window ran from 5 to 9 October 2020. By the close of bidding, only around 125.5 crore shares were confirmed, roughly 8.6 crore short of the threshold, after roughly 12 crore tendered shares could not be confirmed in time, and the offer was declared to have failed under Regulation 19(1) as it then stood. The stock fell sharply once the failure was announced, and the episode subsequently drew scrutiny from SEBI over unconfirmed bids and price volatility, as widely reported by Business Standard and other financial dailies at the time. Practitioners still cite Vedanta as the textbook illustration of how the 90% threshold, combined with a large free float and an actively traded stock, can defeat even a wellresourced promoter group if the floor price is not calibrated close to where institutional shareholders are willing to exit.

5.5 The Fixed Price Alternative (Introduced in 2024) Over time, reverse book building has acquired a reputation for volatility and occasional manipulation, with discovered prices sometimes running many multiples above the floor price. To address this, the 2024 amendment introduced a fixed price process as an alternative for frequently traded shares45. Under this route, the acquirer fixes the delisting price upfront at not less than 15% above the Regulation 19A floor price46, and is eligible only if the shares are frequently traded47. The acquirer must accept the equity shares tendered or offered in the delisting offer once its post-offer shareholding, together with tendered shares, reaches 90% at the fixed delisting price48. There is no price discovery and, correspondingly, no scope for the shareholder-driven premium escalation that characterised episodes like Hexaware. In exchange, shareholders lose the upside that reverse book building can generate, so the choice of route is itself a negotiating decision the CS advising the acquirer must think through carefully. Feature

Reverse Book Building

Fixed Price Process

Price discovery

Determined by shareholder bids, subject to the 90% test

Fixed upfront by the acquirer

Minimum premium

None prescribed; floor price is the base

At least 15% above the Regulation 19A floor price

Eligibility

Available to all companies

Only companies with frequently traded shares

Counter-offer available

Yes, at 75%/50% thresholds

No; offer is binding once tendered

Price risk for acquirer

Uncapped upside for shareholders; can run well above floor

Capped and known from day one

45 Regulation 20A of the Delisting Regulations, inserted by the 2024 Amendment Regulations w.e.f. 25 September 2024. 46 Regulation 20A(1) of the Delisting Regulations. 47 Regulation 20A(2) of the Delisting Regulations. 48 Regulation 20A(3) of the Delisting Regulations.

The Delisting Playbook Rules, Routes and Regulatory Hurdles

Feature

Reverse Book Building

Fixed Price Process

Typical use case

Widely held, liquid stocks where price discovery is credible

Cases where cost certainty outweighs the benefit of an auction

5.6 Minimum Acceptance, and Accepting, Rejecting or Countering the Price An offer succeeds only if the acquirer’s post-offer shareholding, together with shares accepted as eligible bids at the discovered price (or the fixed price, or the counter-offer price), reaches 90% of the total issued shares of that class, excluding shares held by overseas depository custodians, employee benefit trusts under the SEBI (Share Based Employee Benefits) Regulations, 2014, and specified categories of inactive shareholders certified by the Peer Review Company Secretary49. The acquirer shall be bound to accept the equity shares tendered or offered in the delisting offer if the discovered price determined through the reverse book-building process equals the floor price or any indicative price it offered.50 The acquirer is equally bound to accept at its own indicative price where the reverse book-building price is higher than the floor price but lower than that indicative price. If the discovered price exceeds an indicative price the acquirer offered, the acquirer may reject it. If it does so under a reverse book-building process, it may instead make a counteroffer, provided its post-offer holding together with tendered shares is at least 75%, and at least 50% of the public shareholding has been tendered51. The counter-offer may be made within 2 working days of the closure of the bidding period, and thereafter, the acquirer must ensure compliance with the provisions of these regulations in accordance with the timeline provided in Schedule IV. The counter-offer price cannot be lower than the higher of the volume-weighted average of the shares tendered/offered in the reverse book-building process or the acquirer’s own indicative price52. The entire counter-offer cycle, from announcement to payment, must run within the timelines prescribed in Schedule IV, summarised below. Activity

Timeline

Public announcement of counter-offer by acquirer via stock exchange mechanism

Within 2 working days from the date of closure of the RBB bidding process

Newspaper publication of counter-offer announcement

Within 4 working days from the closure of the RBB bidding process

Option to withdraw shares tendered in RBB

Within 10 working days from the counter-offer public announcement

Dispatch of ‘letter of offer for counter-offer’

Within 4 working days from the closure of the RBB bidding process

Opening of counter-offer bidding process

Not later than 7 working days from the date of public announcement

Closing of counter-offer bidding process

Not later than 5 working days from the opening of the counter-offer bidding process

49 50 51 52

Regulation 21 of the Delisting Regulations. Regulation 22(1) and 22(2) of the Delisting Regulations. Regulation 22(3) and 22(4) of the Delisting Regulations, as amended in 2024. Regulation 22(5) of the Delisting Regulations.

The Delisting Playbook Rules, Routes and Regulatory Hurdles

Activity

Timeline

Public Announcement of success/failure of counter-offer in the same newspaper in which detailed public announcement was made

Not later than 5 working days from closing of the counter-offer bidding process

Payment of consideration

Not later than 10 working days from closing of counter-offer, or via secondary market settlement mechanism

Release of equity shares

On the date of making public announcement of the success or failure of the counter-offer

5.7 Failure of the Offer and the Cooling-Off Period An offer is deemed to have failed if the minimum 90% threshold is not met, or if the acquirer rejects the discovered price arrived at through reverse book building53. On failure, tendered shares are released back to shareholders on prescribed trigger dates, the acquirer bears all expenses of the failed offer, and the acquirer is barred from making another delisting offer for six months from the relevant failure date54, a restriction that does not apply where the offer was made by a new promoter following reclassification, or by a new acquirer under Regulation 5A of the Takeover Regulations55. This six-month cooling-off period is a genuine constraint in practice: a promoter cannot simply relaunch a failed delisting the following week at a marginally higher price.

5.8 Payment, and the One-Year Tail for Remaining Shareholders On success, shareholders whose bids were accepted are paid the discovered price (or, for a fixed price process, the fixed delisting price under Regulation 20A), generally through the secondary market settlement mechanism where the price equals the floor or indicative price, or within five working days of the outcome announcement where the price is higher56, with interest at 10% per annum payable for delayed payment, subject to a SEBI waiver for delays not attributable to the acquirer57. Within five working days of paying public shareholders, the acquirer makes the final application to the relevant recognised stock exchange, which must dispose of the application within fifteen working days of receipt. Once the stock exchange approves the delisting application, the company’s equity shares are permanently delisted from the stock exchange. A feature that often surprises first-time promoters is that delisting does not close the door for good: shareholders who missed the bidding window retain a right, for a minimum of one year after delisting, to tender their shares to the acquirer at the same exit price, and the acquirer is obliged to accept, with payment made out of the balance escrow58. The Manager to the Offer must publish quarterly newspaper advertisements and send follow-up communications reminding these shareholders of the window, and file quarterly progress reports with the stock exchanges disclosing the number of remaining public shareholders at the beginning and end of the quarter and those who availed the exit opportunity during the quarter59. 53 54 55 56 57 58 59

Regulation 23(1) of the Delisting Regulations. Regulation 23(2) of the Delisting Regulations. Regulation 23(3) of the Delisting Regulations. Regulation 24(1) of the Delisting Regulations. Regulation 24(2) of the Delisting Regulations. Regulation 26 of the Delisting Regulations. Regulation 27(1) of the Delisting Regulations.

The Delisting Playbook Rules, Routes and Regulatory Hurdles

For the CS running the post-delisting compliance calendar, this one-year tail is easy to forget once the headline transaction has closed, and equally easy to get pulled up for if it is overlooked.

5.9 Obligations of the Company, the Manager and the Acquirer On receipt of the detailed public announcement, the company’s Board must constitute a committee of independent directors to provide written, reasoned recommendations on the delisting offer and disclose the voting pattern at the meeting where the recommendation was discussed. The company must publish these recommendations, along with the details of the voting pattern, at least two working days before the bidding period begins60. The Manager to the Offer must, before making the detailed public announcement, ensure that the acquirer can implement the offer and has firm, verifiable funding arrangements in place, and must ensure that all the contents of the initial public communications are complete, true, fair, adequate in all material aspects and based on reliable sources and are in compliance with the requirements under these regulations and other applicable securities laws.61 The manager to the offer must ensure that market intermediaries engaged for delisting of equity shares are registered with the Board, and the manager must exercise due diligence, care, and professional judgement to ensure compliance with these regulations.62 The manager to the offer must not, directly or indirectly through its associates, deal in the company’s shares on its own account from the date of its appointment until the offer concludes63. The acquirer bears parallel obligations: firm financial arrangements before the initial announcement, true and fair disclosures throughout, joint and several liability with persons acting in concert, an undertaking to keep buying from remaining shareholders for a year post-delisting, and a prohibition on selling any shares of the company during the delisting period64. Finally, once shares are delisted from every exchange with nationwide trading terminals, the company must cancel all the outstanding depository receipts issued overseas and convert them into the underlying equity shares within one year of delisting65.

6. Compulsory Delisting (Chapter V) Compulsory delisting is not something any promoter chooses; it is a sanction imposed by a recognised stock exchange, on grounds prescribed in the rules made under the Securities Contracts (Regulation) Act, 1956, after the company has been given a reasonable opportunity of being heard66. A panel comprising two directors of the exchange (one a public representative), an investorassociation representative, a Ministry of Corporate Affairs or Registrar of Companies representative, and the exchange’s Executive Director or Secretary takes the decision67. 60 61 62 63 64 65 66 67

Regulation 28 of the Delisting Regulations. Regulation 29(1) and 29(2) of the Delisting Regulations. Regulation 29(3) and 29(4) of the Delisting Regulations Regulation 29(5) of the Delisting Regulations. Regulation 30 of the Delisting Regulations. Regulation 31 of the Delisting Regulations. Regulation 32(1) of the Delisting Regulations. Regulation 32(2) of the Delisting Regulations.

The Delisting Playbook Rules, Routes and Regulatory Hurdles

Before passing an order, the recognised stock exchange must give notice in at least one English national newspaper, one Hindi national newspaper and one vernacular newspaper of the region where the recognised stock exchange is located. Any person aggrieved by the proposed delisting may serve a fifteen-working-day public notice period on the recognised stock exchange, and the notice must also be displayed on its trading systems and website. Once an order is passed, the exchange must publish it, disclose the fair value and the names of promoters who will be liable to provide the exit opportunity, notify other exchanges, and upload the order on its website68. Schedule III lays down guidelines the exchange must follow, including tracing the promoters diligently, weighing the extent of non-compliance and the number of affected shareholders, verifying compliance status with the Registrar of Companies, maintaining a public list of companies proposed for compulsory delisting, and pursuing prosecution or winding-up petitions where warranted69. The consequences are severe and deliberately so. The exchange must appoint an independent valuer from its own panel of expert valuers to fix a fair value for the delisted shares, using the same parameters used to compute the floor price70, and the promoters must acquire the public shareholders’ shares at that value within three months. However, shareholders retain the option to hold on to their shares instead, with 10% per annum interest payable on any delayed payment71. The company, its whole-time directors, the persons responsible for ensuring compliance with the securities laws, its promoters and any company promoted by them are barred from directly or indirectly accessing the securities market, seeking listing of any equity shares or acting as an intermediary in the securities markets for ten years from the date of such delisting72. Where the fair value is positive, promoter shareholdings are frozen against transfer, corporate benefits like dividends, rights and bonus issues are suspended for all promoterheld shares, and the promoters and responsible officers are barred from holding directorships in any listed company until the exit opportunity is completed and certified by the exchange73. In practice, the mere threat of compulsory delisting, once an exchange’s notice under Regulation 32(3) lands on a promoter’s desk, tends to concentrate minds far more effectively than any voluntary compliance reminder ever could.

7. Special Provisions for Particular Categories of Companies (Chapter VI) Chapter VI recognises that a single, one-size-fits-all reverse book building process is disproportionate for certain categories of companies, and it carves out five distinct dispensations. 68 69 70 71 72 73

Regulation 32(5) of the Delisting Regulations. Schedule III of the Delisting Regulations, read with Regulation 32(4). Regulation 33(1), 33(2) and 33(3) of the Delisting Regulations. Regulation 33(4) and 33(5) of the Delisting Regulations. Regulation 34(1) of the Delisting Regulations. Regulation 34(2) of the Delisting Regulations.

The Delisting Playbook Rules, Routes and Regulatory Hurdles

7.1 Small Companies A company with paid-up capital not exceeding Rs.10 crore and net worth not exceeding Rs.25 crore as on the last date of the preceding financial year, whose shares are thinly traded (less than 10% of total shares traded on each exchange in the preceding twelve months), and which has not been suspended for non-compliance in the preceding year, may delist without following the full Chapter IV machinery74. Instead, the acquirer appoints a Manager to the Offer, fixes an exit price after consultation (which must not be lower than the floor price prescribed under the Takeover Regulations), and writes individually to every public shareholder, disclosing the price and its justification. The acquirer may proceed only if shareholders holding 90% or more of the public shareholding give their written consent within 75 working days of the first communication, with payment following within a further 15 working days75. Interest at 10% per annum applies to delayed payments, again subject to a waiver for delay not attributable to the acquirer76, and the exchange may delist once it is satisfied that the applicable requirements have been complied with. 77. This route suits closely held, thinly traded small companies where a full-blown reverse book building exercise would be a disproportionate expense for everyone involved.

7.2 Companies on the Innovators Growth Platform A company whose equity shares are listed and traded on the innovators growth platform pursuant to a public issue may delist with the approval of the Board and through a special resolution, which may be acted upon only if a majority of public shareholders vote in favour). The delisting requires a floor price computed under the Takeover Regulations together with a justified delisting premium, and may be completed once the acquirer’s post-offer holding reaches 75% with at least 50% of public shareholders as on the date of the Board meeting tendering their shares and having those shares accepted, followed by approval from the exchange l78,. This represents a materially lower threshold than the 90% test applicable to mainboard companies.

7.3 Subsidiary Delisting via a Court-Approved Scheme Where a listed subsidiary in the same line of business as its listed holding company is folded into that holding company through a court- or tribunal-approved scheme of arrangement, the ordinary delisting machinery does not apply at all79. Instead, the holding company issues its own shares instead of cancelling the subsidiary’s shares. Once the delisting becomes effective, the subsidiary becomes a wholly owned subsidiary of the listed holding company80. This route is, subject to conditions including compliance with Listing Regulations provisions on related-party and material transactions, e-voting thresholds mirroring those for ordinary voluntary delisting (2:1 for the subsidiary, simple majority for the holding company), a minimum three-year listing and subsidiary history for both companies, a bar on adverse SEBI orders in the preceding three years, a bar on further restructuring for three years, a three-year bar on relisting the delisted subsidiary, and a share-swap valuation not less than the 60-day volume-weighted average price81. 74 75 76 77 78 79 80 81

Regulation 35(1) of the Delisting Regulations. Regulation 35(2) and 35(3) of the Delisting Regulations. Regulation 35(4) of the Delisting Regulations. Regulation 35(5) of the Delisting Regulations. Regulation 36(2) of the Delisting Regulations. Regulation 37(1) of the Delisting Regulations. Regulation 37(2)(a) and (b) of the Delisting Regulations. Regulation 37(2)(c) to (j) of the Delisting Regulations.

The Delisting Playbook Rules, Routes and Regulatory Hurdles

This route is as much a corporate-restructuring tool as a delisting tool, and is typically used when a group wants to simplify a multi-listed structure without a cash exit.

7.4 Investment Holding Companies A dedicated framework, inserted in 2024, allows a listed investment holding company to delist pursuant to a scheme of arrangement by transferring its underlying shareholdings in other listed companies directly to its own public shareholders, in proportion to their holding (net of pro-rata liabilities), and paying cash for unlisted investments and other assets, with public shareholding subsequently extinguished through a selective capital reduction under section 66 of the Companies Act, 201382. This route is available only where at least 75% of the company’s fair value comprises direct investments in listed equity shares, with that fair value being certified by a joint report of two independent registered valuers using 60-day volume-weighted prices for frequently traded holdings and fair valuation for the rest83. It further requires compliance with Listing Regulations, a 2:1 public-vote e-voting test, disclosure of the entitlement ratio and consideration basis, confirmation of that ratio by a chartered accountant or merchant banker, a minimum three-year listing history, a clean regulatory record for three years, and a three-year bar on relisting84. Further, compliance with any requirement specified by any financial sector regulator governing the investment holding company is an additional overlay85.

7.5 Public Sector Undertakings The most recent addition, effective September 2025, allows a public sector undertaking (other than banks, NBFCs and insurers) to delist through the fixed price process alone, where the aggregate holding of the acquirer along with other public sector undertakings already equals or exceeds 90% of the total issued shares of that class. Delisting is approved by special resolution through postal ballot or e-voting. The delisting price is set at least 15% above a floor price that is determined as the highest of the (i) volume-weighted average acquisition price over the preceding 52 weeks, (ii) the highest acquisition price paid in the preceding 26 weeks, or (iii) the price determined under a joint valuation report obtained from two independent registered valuers, taking into account valuation parameters such as book value, adjusted book value, comparable trading multiples and the income approach. Unlike the general Regulation 19A floor price, the PSU floor price has no 60-day tradedmarket-price component86. A specific mechanism is also prescribed for unclaimed consideration where a delisted PSU is subsequently struck off within a defined window: the unclaimed amount is parked with the designated stock exchange for seven years, then transferred to the Investor Education and Protection Fund (or SEBI’s Investor Protection and Education Fund if that is not possible), with the investor retaining a claim route through the exchange even after transfer87.

82 83 84 85 86

Regulation 38A(1) and 38A(2) of the Delisting Regulations, inserted by the 2024 Amendment Regulations. Regulation 38A(3)(i) of the Delisting Regulations. Regulation 38A(3)(ii) to (ix) of the Delisting Regulations. Regulation 38A(4) of the Delisting Regulations. Regulation 38B(2) of the Delisting Regulations, inserted by the 2025 Amendment Regulations w.e.f. 3 September 2025. 87 Regulation 38B(3) of the Delisting Regulations.

The Delisting Playbook Rules, Routes and Regulatory Hurdles

8. Relisting, Relaxations and Other Residual Provisions (Chapter VII and VIII) 8.1 Relisting of Delisted Shares A company delisted under Chapter III (voluntary delisting) or Chapter VI (the special provisions for small companies, the innovators growth platform, subsidiary schemes, investment holding companies or public sector undertakings) cannot apply for fresh listing for three years, and a company compulsorily delisted cannot do so for ten years88. This bar does not apply where the delisting followed an approved insolvency resolution plan, or occurred from the innovators growth platform, or occurred under the smallcompany route89. Any subsequent listing application is treated as a fresh listing, subject to the ordinary law governing listing of equity shares of unlisted companies, with mandatory disclosure in the offer document of the reasons for the earlier delisting90.

8.2 SEBI’s Power to Clarify, Relax and Direct SEBI retains a general power to issue clarifications and guidelines to remove difficulties in interpreting the Regulations91, and a targeted power to relax strict enforcement of any procedural requirement, or a disclosure requirement not relevant to a particular industry, or non-compliance caused by factors beyond an acquirer’s control, on a self-attested application accompanied by a non-refundable fee of Rs.1 lakh92. A separate regulatory-sandbox power allows SEBI to exempt persons for up to twelve months to test new products, processes, services or business models in a live environment of a regulatory sandbox in the securities markets. Finally, SEBI may issue directions in the interest of investors and the securities market for any violation of the Regulations93, a residual enforcement power that sits alongside, and does not displace, the specific consequences already built into Chapters III, IV and V.

9. A Practitioner’s Checklist The following sequence, organised across the life of a Chapter III/IV delisting, has proved the most reliable way to keep a mandate on schedule and out of regulatory difficulty.

9.1 Before the Initial Public Announcement (a) Confirm the Regulation 4 gatekeeping conditions before any internal announcement is even contemplated, particularly the three-year listing history and the six-month buyback/preferential-allotment cooling-off periods.

88 89 90 91 92 93

Regulation 40(1) of the Delisting Regulations. Regulation 40(2) of the Delisting Regulations. Regulation 40(4) of the Delisting Regulations. Regulation 41 of the Delisting Regulations. Regulation 42(1) to 42(3) of the Delisting Regulations. Regulation 43 of the Delisting Regulations.

The Delisting Playbook Rules, Routes and Regulatory Hurdles

(b) Check that the acquirer, and every person acting in concert with it, has not sold shares of the company in the preceding six months. (c) Choose the route deliberately: reverse book building where the promoter is prepared to pay a market-discovered premium and wants the flexibility of a counter-offer, or the fixed price process where certainty of cost matters more than optionality and the shares are frequently traded. (d) Line up the Manager to the Offer and confirm it is not an associate of the acquirer, since this appointment must precede the initial public announcement.

9.2 During Execution (a) Brief the Peer Review Company Secretary early; the Regulation 10 due-diligence report on dealings by the acquirer and the top twenty-five shareholders cannot be rushed, and Board approval is time-boxed to 21 days from the initial announcement. (b) Build the escrow funding plan around the 25%/75% split under Regulation 14, and stress-test it against a discovered price meaningfully above the floor price. (c) Cross-check the Schedule I disclosure checklist against the draft detailed public announcement before it goes to press; omissions here are a common source of exchange queries. (d) Track the Regulation 21 exclusion categories (custodian-held depository-receipt shares, employee-benefit-trust shares, inactive shareholders) carefully when computing whether the 90% threshold has actually been crossed.

9.3 After Completion (a) Calendar the one-year Regulation 26 tail-period obligations at the same time as the main transaction timetable, not as an afterthought once the exit has closed. (b) Set up the Regulation 27 quarterly advertisement, shareholder-communication and stock-exchange reporting cycle immediately on delisting, rather than waiting for the first quarter to lapse. (c) Where depository receipts are outstanding, track the one-year Regulation 31 cancellation deadline separately from the remaining-shareholder tail period. (d) Where public sector, subsidiary or investment-holding-company routes are in play, map the transaction against Chapter VI at the outset, since these routes have thresholds and mechanics that diverge materially from the default Chapter IV process, and generally cannot be switched into midway through an ongoing Chapter IV delisting.

The Delisting Playbook Rules, Routes and Regulatory Hurdles

10. Conclusion Delisting law in India has evolved considerably since the SEBI (Delisting of Securities) Guidelines of 2003, and the 2021 Regulations, as amended in 2024 and again in 2025, reflect a regulator that is still recalibrating the balance between an easy exit for promoters and genuine price protection for minority shareholders. The introduction of the fixed price process, the investment-holding-company framework and the public sector undertaking dispensation all point in the same direction: more routes, each tailored to a particular commercial reality, rather than a single rigid process forced upon every company. For the practising Company Secretary, the discipline that matters most is not memorising every sub-regulation, but knowing, at the outset of any mandate, which of these routes the facts actually fit, and building the transaction timetable around the escrow, disclosure and shareholder-approval milestones that the chosen route demands. Get that sequencing right, and delisting is a manageable, if lengthy, corporate exercise. Get it wrong, and the company risks becoming the next Vedanta rather than the next Hexaware.

The Delisting Playbook Rules, Routes and Regulatory Hurdles

About Us

Our Journey Founded

1972

Evolution

From a small family business to a leading technology-oriented Publishing/Product company

Expansion

Launch of Taxmann Advisory for personalized consulting solutions

Our Vision

Aim

Growth

Future

Achieve perfection, skill, and accuracy in all endeavour

Evolution into a company with strong independent divisions: Research & Editorial, Production, Sales & Marketing, and Technology

Continuously providing practical solutions through Taxmann Advisory

Our Strength Core Editorial and Research Division

Team Over 200 motivated legal professionals (Lawyers, Chartered Accountants, Company Secretaries)

Expertise Monitoring and processing developments in judicial, administrative, and legislative fields with unparalleled skill and accuracy

Impact Helping businesses navigate complex tax and regulatory requirements with ease

Taxmann Today Legacy

Innovation

Commitment

Over 60 years of domain knowledge and trust

Technology-driven solutions for modern challenges

Ensuring perfection, skill, and accuracy in every solution provided

Our Core Domain Areas Income Tax Corporate Tax Advisory Trusts & NGO Consultancy TDS Advisory Global Mobility Services Personal Taxation Training Due Diligence

Goods & Services Tax Transaction Advisory Business Restructuring Classification & Rate Advisory Due Diligence Training Trade Facilitation Measures

Foreign Exchange Management Laws

UAE Corporate Tax

Due Dilligence Advisory Services Assistance in compounding of offences Transactions Services Investment outside India

Corporate Tax Advisory Corporate Structuring VAT Advisory Residential Status

Your Partners for Frictionless Advice Tax Advisory High-quality advice for all your Income-tax, GST, FEMA, and UAE Corporate Tax queries From a distinguished panel of experts

Tax Research Support Get real-time research support

Tax Restructuring and Implementation Support

By a team of trained researchers

Structure your business and processes in a tax-efficient way

To upscale the quality of your advice

Implement the SOPs for tax compliances

And save your manpower cost

Automate your ERPs to handle tax compliances

A Glimpse of the People Behind Taxmann

Naveen Wadhwa

Vinod K. Singhania

V.S. Datey

Research and Advisory [Corporate and Personal Tax]

Expert on Panel | Research and Advisory (Direct Tax)

Expert on Panel | Research and Advisory [Indirect Tax]

Chartered Accountant (All India 24th Rank)

Over 35 years of experience in tax laws

Holds 30+ years of experience

14+ years of experience in Income tax and International Tax

PhD in Corporate Economics and Legislation

Engaged in consulting and training professionals on Indirect Taxation

Expertise across real estate, technology, publication, education, hospitality, and manufacturing sectors

Author and resource person in 800+ seminars

A regular speaker at various industry forums, associations and industry workshops Author of various books on Indirect Taxation used by professionals and Department officials

Contributor to renowned media outlets on tax issues

S.S. Gupta

Expert on Panel | Research and Advisory [Indirect Tax] Chartered Accountant and Cost & Works Accountant 34+ Years of Experience in Indirect Taxation Bestowed with numerous prestigious scholarships and prizes Author of the book GST – How to Meet Your Obligations', which is widely referred to by Trade and Industry

Manoj Fogla

Nirav Shah

Expert on Panel | Research and Advisory [Charitable Trusts and NGOs]

Expert on Panel | Research and Advisory [UAE Corporate Tax]

Over three decades of practising experience on tax, legal and regulatory aspects of NPOs and Charitable Institutions

25+ years of experience and practicing in the UAE

Law practitioner, a fellow member of the Institute of Chartered Accountants of India and also holds a Master's degree in Philosophy

Has previously worked with the KPMG

PhD from Utkal University, Doctoral Research on Social Accountability Standards for NPOs Author of several best-selling books for professionals, including the recent one titled 'Trust and NGO's Ready Reckoner' by Taxmann Drafted publications for The Institute of Chartered Accountants of India, New Delhi, such as FAQs on GST for NPOs & FAQs on FCRA for NPOs. Has been a faculty and resource person at various national and international forums

Chartered Accountant (All India 36th Rank)

Contact Us Taxmann Delhi 59/32, New Rohtak Road New Delhi – 110005 | India Phone | 011 45562222 Email | sales@taxmann.com Taxmann Mumbai 35, Bodke Building, Ground Floor, M.G. Road, Mulund (West), Opp. Mulund Railway Station Mumbai – 400080 | Maharashtra | India Phone | +91 93222 47686 Email | sales.mumbai@taxmann.com Taxmann Pune Office No. 14, First Floor, Prestige Point, 283 Shukrwar Peth, Bajirao Road, Opp. Chinchechi Talim, Pune – 411002 | Maharashtra | India Phone | +91 98224 11811 Email | sales.pune@taxmann.com Taxmann Ahmedabad 7, Abhinav Arcade, Ground Floor, Pritam Nagar Paldi Ahmedabad – 380007 | Gujarat | India Phone: +91 99099 84900 Email: sales.ahmedabad@taxmann.com Taxmann Hyderabad 4-1-369 Indralok Commercial Complex Shop No. 15/1 – Ground Floor, Reddy Hostel Lane Abids Hyderabad – 500001 | Telangana | India Phone | +91 93910 41461 Email | sales.hyderabad@taxmann.com Taxmann Chennai No. 26, 2, Rajan St, Rama Kamath Puram, T. Nagar Chennai – 600017 | Tamil Nadu | India Phone | +91 89390 09948 Email | sales.chennai@taxmann.com

www.taxmann.com

Taxmann's Analysis | The Delisting Playbook: Rules, Routes & Hurdles