THE TAKEOVER CODE – UNDERSTANDING

TENDER OFFERS

SUBMITTED TO:

DR. Y. PAPA RAO

(FACULTY OF CORPORATE REGULATION)

SUBMITTED BY:

EKTA KUMARI
ROLL NO. - 63

SEMESTER - VIII

SECTION - C

B.A. LL.B. (HONS.)

SUBMITTED ON:

08.04.2019

HIDAYATULLAH NATIONAL LAW UNIVERSITY,

ATAL NAGAR, 492002

ACKNOWLEDGEMENT

I feel highly elated to work on the project - THE TAKEOVER CODE – UNDERSTANDING
TENDER OFFERS. The practical realisation of the project has obligated the assistance of many
persons. Firstly, I express my deepest gratitude towards Dr. Y. Papa Rao, Faculty of Corporate
Regulation, to provide me with the opportunity to work on this project. His able guidance and
supervision in terms of his lectures were of extreme help in understanding and carrying out the
nuances of this project.

I would also like to thank the University and the Vice Chancellor for providing extensive
database resources in the library and for the internet facilities provided by the University.

Some typography or printing errors might have crept in, which are deeply regretted. I would be
grateful to receive comments and suggestions to further improve this project.

Ekta Kumari

Roll. No. 63

Semester VIII

Section C

2
DECLARATION OF ORIGINALITY

I, Ekta Kumari, have undergone research of the project work titled ― THE TAKEOVER CODE
– UNDERSTANDING TENDER OFFERS, as a student of Corporate Regulation. I hereby
declare that this Research Project has been prepared by the student for academic purpose only,
and is the outcome of the investigation done by me and also prepared by myself under the
supervision of Dr. Y. Papa Rao, Faculty of Corporate Regulation, Hidayatullah National Law
University, Raipur. The views expressed in the report are personal to the student and do not
reflect the views of any authority or any other person, and do not bind the statute in any manner.

I also declare that this Research Paper or any part, thereof has not been or is not being submitted
elsewhere for the award of any degree or Diploma. This report is the intellectual property of the
on the part of student research work, and the same or any part thereof may not be used in any
manner whatsoever in writing.

Ekta Kumari

Roll. No. 63

Semester VIII

Section C

3
CERTIFICATE

This is to certify that Ms. Ekta Kumari, Roll Number - 63 , student of Semester VIII, Section C
of B.A.LL.B. (Hons.), Hidayatullah National Law University, Raipur (Chhattisgarh) has
undergone research of the project work titled ― THE TAKEOVER CODE –
UNDERSTANDING TENDER OFFERS, in the subject of Corporate Regulation. Her
performance in research work is up to the level.

………………………… ……………………………

Place: Atal Nagar

Date: 08.04.2019

Dr. Y. Papa Rao

(Faculty- Corporate Regulation)

Hidayatullah National Law University, Raipur

4
TABLE OF CONTENTS

TABLE OF CONTENTS

Acknowledgements ....................................................................................................................2

Introduction ................................................................................................................................6

Research Methodology ...............................................................................................................7

Objectives, Scope and Applicability of the Takeover Regulations.............................................9

Types of Tender Offer...............................................................................................................10

Mandatory Tender Offers………………………………………………………………....10

Voluntary Offers…………………………………………………………………………..13

Competing Offers…………………………………………………………….……………13

Conditional Tender Offers………………………………………………………………...14

Conditions of Withdrawal........................................................................................................16

Minority Squeeze and Delisting ..............................................................................................19

Conclusion ...............................................................................................................................21

References…………………………………………………………………………………….22

5
CHAPTER I: INTRODUCTION

The regulation of takeovers of listed companies in India is set out in the Securities
Exchange Board of India (Substantial Acquisition of Shares and Takeovers) Regulations
2011 (the “Takeover Regulations”). The applicable minimum level of public shareholding
required to be maintained by a listed company is determined in accordance with the Equity
Listing Agreement (which is executed by the listed company with every stock exchange on
which its equity shares are listed) read with the Securities Contracts (Regulation) Rules,
1957 (the “SCRR”). The delisting of listed securities is governed by the SCRR and the
Securities and Exchange Board of India (Delisting of Equity Shares) Regulations, 2009 (the
“Delisting Regulations”). Pursuant to a successful delisting, the acquisition of shares through a
compulsory squeeze out process is set out in Section 236 of the Companies Act, 2013 (which is
pending notification).

The SCRR, Takeover Regulations, and Delisting Regulations are primarily administered by the
Securities and Exchange Board of India (the “SEBI”), which is the regulator of the
Indian securities markets and has been established as a statutory authority under the
Securities and Exchange Board of India Act, 1992. Compliances under the Equity
Listing Agreement are monitored and administered by the relevant stock exchanges under the
supervision of SEBI.

The Takeover Regulations came into effect on October 22, 2011, repealing and
replacing the Securities and Exchange Board of India (Substantial Acquisitions of Shares
and Takeovers) Regulations, 1997 (“1997 Takeover Regulations”).

6
RESEARCH METHODOLOGY

OBJECTIVES

1. To study the objectives, scope and applicability of the takeover regulations.

2. To study the various types of tender offers.
3. To find out the offer size and offer price requirement of various types of tender offers.
4. To study the conditions of withdrawal of tender offers.
5. To study minority squeezing and delisting.

7
NATURE OF STUDY

The nature of the study in this project is doctrinal and is primarily descriptive and analytical.

SOURCE OF DATA

Both primary sources such as Statutes and case-laws as well as secondary sources such as
books and articles have been used for this research paper.

NAME OF THE LIBRARY

The researcher has referred books and collected data from the library at Hidayatullah
National Law University, Raipur in order to complete this research paper.

CHAPTERISATION

This project has been divided into 4 chapters.

Chapter 1 is the Introduction part of the paper.

Chapter 2 deals with the Objectives, Scope and Applicability of the Takeover Regulations.

Chapter 3 deals with Types of Tender Offers.

Chapter 4 enumerates the Conditions of Withdrawal of Tender Offers.

Chapter 5 deals with Minority Squeezing and Delisting.

8
 CHAPTER 2: OBJECTIVES, SCOPE & APPLICABILITY
OF THE TAKEOVER REGULATIONS

The Takeover Regulations are premised on the principles of fairness, equity and
transparency, and are based on the following fundamental objectives:

1. To provide a transparent legal framework for facilitating takeover activities;

2. To protect the interests of shareholders in securities and the securities market, taking
into account that the acquirer and the other shareholders need a fair, equitable and
transparent framework to protect their interests;
3. To balance the various, and at times, conflicting objectives and interests of
various stakeholders in the context of substantial acquisition of shares in, and
takeovers of, listed companies;
4. To provide each shareholder an opportunity to exit its investment in the target
company when a substantial acquisition of shares in, or takeover of, a target company
takes place, on terms that are not inferior to the terms on which substantial
shareholders exit their investments;
5. To provide acquirers with a transparent legal framework to acquire shares in, or control
of, the target company and to make an MTO;
6. To ensure that the affairs of the target company are conducted in the ordinary
course when a target company is the subject matter of an MTO;
7. To ensure that fair and accurate disclosure of all material information is made by
persons responsible for making them to various stakeholders to enable them to
take informed decisions;
8. To regulate and provide for fair and effective competition among acquirers
desirous of taking over the same target company; and
9. To ensure that only those acquirers who are capable of actually fulfilling their
obligations under the Takeover Regulations make MTOs.

The Takeover Regulations govern any direct or indirect acquisition of shares or voting rights in
a target company, or direct or indirect acquisition of control over a target company.

9
 Any acquisition of securities which entitle the holder to exercise voting rights in the target
company (including shares underlying depository receipts, which receipts carry an entitlement
to exercise voting rights) are covered by the provisions of the Takeover Regulations.
Broadly, a „target company‟ is a company whose shares are listed on a stock exchange
which has been granted recognition under the Securities Contracts (Regulation) Act, 1956.
There are, at present, 21 recognized stock exchanges in India.

The Takeover Regulations contemplate various types of tender offers, for which it
prescribes distinct (but sometimes overlapping) regimes. The Takeover Regulations also
set out some exempted transactions, which do not attract mandatory tender offer
obligations, and the conditions under which such exemptions would apply.

In addition, the Takeover Regulations prescribe certain reporting and disclosure requirements for
holders of equity shares or voting rights in a target company, which are either event-based
or periodic in nature.

CHAPTER 3: TYPES OF TENDER OFFERS

Takeover Regulations primarily deal with three types of tender offers:

A. Mandatory Tender Offer

The Takeover Regulations prescribe certain circumstances where an acquirer is obligated

to make a Mandatory Tender Offer to the shareholders of the target company to acquire at
least26% of the shares of the target company. These triggers are described below:

Initial Trigger

Any acquirer acquiring shares or voting rights, which taken together with shares or voting rights
already held by such acquirer along with persons acting in concert with him, entitles
them to exercise 25% or more of the voting rights in the target company, is required to
make a Mandatory Tender Offer.

10
Consolidation Trigger

Any acquirer who, together with persons acting in concert with him, holds 25% or more of the
shares or voting rights but less than the maximum permissible non-public shareholding limit in a
target company ,is required to make a Mandatory Tender Offer on the gross acquisition,
in a single financial year, of more than 5% of the shares or voting rights of such target company.

The limit of 5% is calculated by aggregating gross acquisitions, i.e., without taking into account
any intermediate dilution in shareholding or voting rights.

Control Trigger

Irrespective of the extent of shares or voting rights held in the target company, any acquirer who
acquires, directly or indirectly, control over a target company is required to make a Mandatory
Tender Offer.

Any acquisition of control over an unlisted company which in turn controls a listed company in
India would be considered an indirect acquisition of control, and would trigger a Mandatory
Tender Offer.

„Control‟ under the Takeover Regulations is widely defined and includes the right to appoint a
majority of the directors of the target company, or to control the management or policy decisions
of the target company, whether individually or with persons acting in concert, directly or
indirectly, including by virtue of shareholding or management rights or shareholders‟ agreements
or in any other manner. „Control‟ includes both de facto and de jure control. Since the test for
control is not defined by an objective shareholding threshold, acquisition of control is determined
on a caseby- case basis by assessing whether the acquirer can exercise control over the
management or policy decisions of the target company, whether through the exercise of
contractual rights or otherwise.

Unlike the 1997 Takeover Regulations, the Takeover Regulations, 2011 do not distinguish
between varying degrees of control. Therefore, any cessation of control by a person in

11
joint control with an acquirer will not be considered an acquisition of control by the acquirer, and
will not trigger a Mandatory Tender Offer.

Trigger on Indirect Acquisitions

The Takeover Regulations also provide clear and specific guidance that indirect acquisitions of
voting rights and/or control in a target company will also trigger a Mandatory Tender Offer. An
indirect acquisition occurs when the acquirer acquires the ability to exercise or direct the exercise
of such percentage of voting rights in, or control over, the target company that would trigger the
initial, consolidation or control triggers described above.

E.g., the acquisition of 25% of the shares or voting rights in a holding company which holds 40%
of the shares or voting rights in a target company together with a minority representation on the
board of directors of the holding company would not constitute an indirect acquisition. However,
the acquisition of 70% of the shares or voting rights of the holding company simpliciter, or the
acquisition of 30% of the shares or voting rights along with „control‟ rights in a holding company
which holds 26% of a target company would trigger Mandatory Tender Offer obligations.

Where the acquisition of the target company in India is only an incidental element of an
international transaction, some leeway in relation to the tender offer process has been provided to
the acquirer. In such situations, the acquirer can formally launch the Mandatory Tender Offer
after the international transaction has been consummated and is eligible to price protection
in relation to the price payable under such Mandatory Tender Offer (subject to a 10%
interest payment requirement). The Takeover Regulations stipulate an objective test for
what would constitute a „genuine‟ indirect acquisition, i.e., where the acquisition of the
target company is incidental to the international acquisition and the target company not a
predominant part of the business being acquired. Therefore, this relaxation in the Mandatory
Tender Offer process is available where the proportionate net asset value/sales
turnover/market capitalization of the Indian target company does not exceed 80% of the entity
or business being acquired under the primary (international) acquisition.

Where the Indian target company is a predominant part of the entity or business being
acquired, based on the 80% test described above, the transaction will be treated as a „direct

12
 acquisition‟ for the purposes of making a Mandatory Tender Offer under the Takeover
Regulations.

B. Voluntary Offers

The Takeover Regulations provide a distinct regime for acquirers to make Voluntary Offers 1 to
public shareholders. A Voluntary Offer may be made by an existing shareholder or an acquirer
who holds no shares in the target company.

The launch of a Voluntary Offer is subject to the fulfilment of certain conditions. Therefore, if
any acquirer or persons acting in concert with such acquirer has acquired any shares or voting
rights of the target company without attracting a Mandatory Tender Offer in the preceding
52 weeks, then such acquirer will not be permitted to launch a Voluntary Offer. In
addition, an acquirer who has launched a Voluntary Offer is not permitted to acquire any
shares of the target company during the offer period other than under such tender offer.

An acquirer who has launched a Voluntary Offer is also not permitted to acquire shares of the
target company for a period of 6 months after the completion of the Voluntary Offer,
except under another Voluntary Offer. This does not prohibit the acquirer from launching a
competing offer under the Takeover Regulations.

C. Competing Offers

A competing offer2 is required to be made within 15 business days of the original tender offer.
A competing offer may be made by any person (i.e., whether it be an existing
shareholder or otherwise) without being subject to the restrictions applicable to Voluntary
Offers.

There is a prohibition on a competing acquirer making an offer or entering into an agreement

that could trigger a Mandatory Tender Offer at any time after the expiry of the said 15 business
days and until completion of the original offer. Therefore, time is of the essence.

1
SEBI (Substantial Acquisition of Shares and Takeovers) Regulations, 2011, Regulation 6.
2
SEBI (Substantial Acquisition of Shares and Takeovers) Regulations, 2011, Regulation 20.

13
 Once a competing offer has been launched, the two competing offers are treated on par and the
target company would have to extend equal levels of information and support to each
competing acquirer. A target company cannot favour one acquirer over the other(s) or
appoint such acquirer‟s nominees on the board of directors of the target company, pending
completion of the competing offers.

A competing offer can be conditional upon a minimum level of acceptance only if the original
tender offer is also conditional. The „losing‟ competing acquirer is not permitted to sell
the shares acquired by him under the competing offer to the winner of the competing bid.
Therefore, any person making a competing offer will continue to be a shareholder in the
target company, even if his competing offer has failed.

D. Conditional Tender Offers

Where a tender offer is conditional upon a minimum level of acceptances, the acquirer is
not bound to accept any shares tendered in such offer if the stipulated minimum level
of acceptance is not achieved. If the stipulated minimum level of acceptance is not achieved,
the acquirer is also not permitted to acquire any shares, voting rights or control under the
definitive agreements which triggered the Mandatory Tender Offer in the first place.3

OFFER SIZE, OFFER PRICE

A Mandatory Tender Offer is required to be made for at least 26% of the total shares of the
target company, taking into account any potential increase in the total share capital during
the offer period.4

A Voluntary Offer, launched by an acquirer holding between 25% and the maximum
permissible non-public shareholding in the target company, has to be made for at least
10% of the total shares of the target company, and shall not exceed such number of shares as
would, together with the shares already held by the voluntary acquirer, breach the maximum
permissible level of non- public shareholding. The SEBI has also clarified that a Voluntary
Offer launched by an acquirer holding less than 25% of the share capital of the target company

3
SEBI (Substantial Acquisition of Shares and Takeovers) Regulations, 2011, Regulation 19.
4
SEBI (Substantial Acquisition of Shares and Takeovers) Regulations, 2011, Regulation 7(1).

14
 has to be made for atleast 26% of the total shares of the target company and may be made
for the entire share capital of the target company.5

A competing offer has to be made for at least such number of shares as would be equal to the

shareholding of the original acquirer and PACs with him, the number of shares proposed to be
acquired under the original offer and under any agreements which may have triggered
the original offer, net the competing acquirer‟s existing shareholding.

The Takeover Regulations embody the „best price rule‟ in determining the consideration
payable to shareholders under a tender offer. In this respect, the Takeover Regulations treat
companies whose shares are frequently traded and infrequently traded differently, and
specify different parameters for tender offers triggered by direct and indirect acquisitions.

Broadly, the minimum offer price for a Mandatory Tender Offer triggered by a direct
acquisition nor for a Voluntary Offer would have to be the highest of the following6:

 the negotiated price;

 the volume weighted average price paid or payable by the acquirer/ PACs
during the 52 weeks immediately preceding the date of the tender offer;
 the highest price paid by the acquirer/ PACs for any acquisition during the
26 weeks immediately preceding the date of the tender offer;
 if the shares are frequently traded, the volume weighted average market
price during the 60 trading days immediately preceding the date of the tender
offer;
 if the shares are infrequently traded, the fair price determined on the basis of
parameters which are customary for the valuation of shares of a company, such as
book value and comparable trading multiples.

In case of an indirect acquisition which satisfies the 80% test described above, the acquirer
is permitted to peg the Mandatory Tender Offer price to the above parameters prevailing on
the date that the primary (international) acquisition is announced or contracted, as opposed

5
SEBI (Substantial Acquisition of Shares and Takeovers) Regulations, 2011, Regulation 7(2).
6
SEBI (Substantial Acquisition of Shares and Takeovers) Regulations, 2011, Regulation 8(2).

15
to the date on which the Indian tender offer actually commences. However, such an indirect
acquirer will be required to pay 10% interest for the period intervening the date on which
the primary acquisition is announced or contracted and the date on which the detailed public
announcement for the underlying Indian target company is made (if more than 5 working days).

Indirect acquisitions also mandate a „price attribution‟ where the proportionate net asset
value/sales turnover/ market capitalization of the Indian target company represents more
than15% of the total value of the entity or business being acquired.

The Takeover Regulations prohibit acquirers from making payments on the side to promoters or
selling shareholders in the form of non-compete fees, control premium or
otherwise. Specifically, all such incidental, contemporaneous or collateral payments are
required to be factored into the offer price in determining the consideration payable to
shareholders under the tender offer.The best price rule also covers all acquisitions that are made
subsequent to the tender offer, and a price differential would have to be topped up if the
acquirer makes the acquisition in the following 26 weeks (except under a delisting offer or, in
case of market purchases, on the normal segment of the stock exchange.

CHAPTER 4: CONDITIONS FOR WITHDRAWAL

The Takeover Regulations permit an acquirer to withdraw a tender offer in

7
certain circumstances, including the following :

 if any statutory approvals required for the tender offer or for effecting the
acquisition triggering the tender offer have been finally refused; and
 the acquirer, being a natural person, has died;
 if any condition stipulated in the agreement for acquisition attracting the
obligation to make the tender offer is not met for reasons outside the reasonable
control of the acquirer, and such agreement is rescinded.

7
SEBI (Substantial Acquisition of Shares and Takeovers) Regulations, 2011, Regulation 23.

16
SEBI has permitted conditions such as completion of conditions precedent to the transaction
within a specified long stop date and material adverse change leading to the
rescission of the agreement as valid grounds for withdrawal. However, if a
Mandatory Tender Offer is triggered by a preferential allotment of equity shares of the
target company to the acquirer, the acquirer is not permitted to withdraw the tender offer
on this ground even if the preferential allotment is not successful. Such circumstances as in the
opinion of the Board, merit withdrawal.

The withdrawal of a tender offer on the aforementioned grounds is subject to specific

disclosures having been made in the tender offer documents. The Takeover Regulations also
provide SEBI the discretion to permit an acquirer to withdraw a tender offer. In such
cases, the acquirer is required to approach SEBI, which will then pass a reasoned order
permitting the withdrawal.

EXEMPTIONS

The Takeover Regulations prescribe a rational and tiered approach to exemptions

from Mandatory Tender Offer obligations. Some transactions are exempt from the initial
as well as consolidation triggers, whereas others are only exempt from the
consolidation trigger. Transactions which are exempt from the initial and consolidation
trigger include8:

1. acquisitions pursuant to an inter se transfer of shares amongst qualifying

persons, including immediate relatives;
 persons named as promoters of the target company in the shareholding
disclosures filed under the Equity Listing Agreement for not less than three
years prior to the proposed acquisition. SEBI has ruled that this
exemption is not available to promoters of companies which have been
listed for less than three years;
 a company, its subsidiaries, its holding company, and other subsidiaries of such
holding company; and

8
SEBI (Substantial Acquisition of Shares and Takeovers) Regulations, 2011, Regulation 10.

17
  persons acting in concert with each other for not less than three years
prior to the proposed acquisition, and disclosed as such in filings made
under the Equity Listing Agreement;

2. acquisitions in the ordinary course by:

 a SEBI-registered underwriter by way of allotment pursuant to an
underwriting agreement in terms of the Securities and Exchange Board of India
(Issue of Capital and Disclosures Requirements) Regulations, 2009 (the “ICDR
Regulations”);
 a SEBI-registered stock broker on behalf of its client in exercise of lien over the
shares purchased on behalf of the client under the bye-laws of the relevant stock
exchange;
 a scheduled commercial bank (as classified by the Reserve Bank of India), acting as
an escrow agent;
 invocation of pledge by scheduled commercial banks or public financial institutions
(as classified by the Reserve Bank of India) as a pledgee;

3. acquisitions under a scheme of amalgamation, merger or demerger pursuant to an order

of a court or other competent authority under any law or regulation, Indian or
foreign, subject to fulfilment of specified conditions;

4. acquisitions pursuant to a delisting in accordance with the Delisting Regulations; and

5. bailout takeovers of sick industrial companies undertaken pursuant to a

scheme formulated by an operating agency under the Sick Industrial Companies
(Special Provisions) Act, 1985.

Any acquisition of shares, up to his entitlement, by a shareholder under a rights issue,

any increase in voting rights pursuant to a buy-back, and acquisition of shares in a target
company in exchange for shares of another target company tendered under a tender offer under
the Takeover Regulations are examples of acquisitions which are exempt from the consolidation
trigger.

18
 CHAPTER 5: MINORITY SQUEEZE OUT AND DELISTING

Where the shares accepted in the tender offer by the acquirer results in the acquirer‟s aggregate
shareholding exceeding the maximum permissible non-public shareholding threshold,
the acquirer is required to dilute its shareholding in accordance with the provisions of the
SCRR to ensure that the public shareholding in the target company is maintained at the
stipulated threshold.

The Takeover Regulations do not permit an acquirer whose shareholding has breached
the maximum permissible non-public shareholding threshold pursuant to a tender offer to
initiate a delisting of the target company for a period of twelve months from the completion of
the tender offer. Therefore, any delisting of a target company will have to be undertaken
through a two-step process, and the framework of the Takeover Regulations does not
contemplate an automatic „going private‟ regime. A squeeze-out of minority shareholders is
governed by the provisions of the Companies Act, 2013 and the Delisting Regulations.

In terms of the Delisting Regulations, a voluntary delisting can be initiated only by a promoter
(i.e., controlling shareholder). Therefore, a minority shareholder or a person who is not in
control of the target company cannot presently launch a delisting offer. Delisting is initiated
through a delisting offer, for which the procedure is prescribed in the Delisting Regulations.

The Delisting Regulations stipulate that a delisting offer will be successful only if the
shares accepted reach the higher of:

 ninety per cent. of the total issued shares of the class of shares proposed to be delisted,
excluding the shares which are held by a custodian and against which depository
receipts have been issued overseas; or
 the aggregate percentage of the promoters shareholding (along with persons
acting in concert with him) prior to the delisting offer and fifty per cent. of the size of
the delisting offer.

19
It may be noted that persons acting in concert with the promoter are not permitted to tender their
shares in a delisting offer.

If the delisting offer is successful and the higher of the two parameters described above are met,
the target company will be delisted. Where the target company is delisted, any remaining public
shareholders holding shares in the target company are entitled to tender their shares to
the promoter within a minimum period of one year from the date of delisting. In such
cases, the promoter is required to accept the shares tendered at the same final price at
which the shares were delisted.

20
 CONCLUSION

The regulation of takeovers of listed companies in India is set out in the Securities
Exchange Board of India (Substantial Acquisition of Shares and Takeovers) Regulations
2011. The applicable minimum level of public shareholding required to be maintained by a listed
company is determined in accordance with the Equity Listing Agreement (which is executed by
the listed company with every stock exchange on which its equity shares are listed) read with
the Securities Contracts (Regulation) Rules, 1957.

The Takeover Code of 2011 is a timely and progressive regulation that would facilitate
investments and attract investors. Even though SEBI has not implemented all the suggestions of
the Achuthan Committee, it has still taken into consideration some of the major issues that had
been plaguing the industry till now. It has tried to maintain a balance between the concerns of the
investors as well as that of the promoters. It has got both pro and cons like all other
laws. Takeover code 2011 will prevent malfunctioning while takeovers and acquisitions but can
harm interest of promoters at same time. Several companies are complaining that the new rules
are not to their advantage and are putting more burden on them.

21
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Securities and Exchange Board of India (Substantial Acquisition of Shares and Takeovers)
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th
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