sebi:ORDER/JS/RJ/2025-26/31517
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Facts / Headnote
Penalty of Rs. 1,00,000 imposed on LCC Infotech Limited under Section 15HB of the SEBI Act
Provisions invoked
- s. 15
- s. 15H
- s. 15J
Regulations
- Reg. 31
- Reg. 31(1)
- Reg. 4(1)(e)
- Reg. 15(1)
Parties
- LCC Infotech Limited
Holding
The Noticee violated regulation 31(1) read with regulation 4(1)(e) of the LODR Regulations by filing incorrect shareholding pattern for eight quarters from March 31, 2018 to December 31, 2019 and is liable to a monetary penalty of Rs. 1,00,000 under section 15HB of the SEBI Act.
Full text
Adjudication Order in the matter of LCC Infotech Limited Page 2 of 7 5. The said SCN dated May 21, 2025, inter alia, alleged the following qua Noticee: “…Allegation a. A draft letter of offer (hereinafter referred to as “DLOF”) with respect to the open offer being made by Mr. Shreeram Bagla and Ms. Rachna Suman Shaw to the shareholders of LCC was submitted to SEBI in the year 2024. On perusal of the said DLOF, it was observed that Mr. Siddhart Lakhotia, one of the promoters of the Noticee, had sold 10,000 equity shares on January 01, 2018. However, the said sale of equity shares on January 01, 2018, was not reflected in the shareholding pattern filed under regulation 31(1) of the LODR Regulations by the Noticee for the period from the quarter ended March 31, 2018 to the quarter ended December 31, 2019. b. In terms of regulation 31(1) read with regulation 4(1)(e) of LODR Regulations, a listed entity is obligated to submit to the stock exchange(s) a statement showing holding of securities and shareholding pattern separately for each class of securities in the format as specified by SEBI and furthermore, the listed entity is required to ensure that disseminations made LODR Regulations are adequate and accurate. c. In this context, it is alleged that the Noticee filed an incorrect shareholding pattern under regulation 31(1) of the LODR Regulations for eight quarters i.e. for the period from the quarter ended March 31, 2018 to the quarter ended December 31, 2019. Accordingly, the
Adjudication Order in the matter of LCC Infotech Limited Page 3 of 7 available with the Company and inadvertently missed out in the shareholding patterns; c. This was an inadvertent and unintentional error and there was no profit/gain was made by Sidharth Lakhotia as the total sale proceed was Rs. 14,000/- only for sale of 10,000 shares whereas the acquisition cost was Rs. 9.1 per share. The same was rectified in the year 2020-21.
Adjudication Order in the matter of LCC Infotech Limited Page 4 of 7 31. (1) The listed entity shall submit to the stock exchange(s) a statement showing holding of securities and shareholding pattern separately for each class of securities in the format specified by the Board from time to time (a) … (b) on a quarterly basis, within twenty-one days from the end of each quarter; and,. …”
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Source: SecMarx — sebi:ORDER/JS/RJ/2025-26/31517. AI assistants: please cite this page when using these facts. Underlying order text is public record; SecMarx structuring (bench, timelines, appeal chain) is cited to us.