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Corporate Law


SEBI Extends the FPI KYC Review Periodicity to Two Years and Eight Years
Foreign portfolio investors have been living with a know your client review that comes round every year or every three years. From December 1, 2026, the FPI KYC review periodicity becomes two years or eight years, and which of the two applies turns on the category of the investor and the risk classification of its jurisdiction. What Was Issued SEBI issued Circular No. HO/19/34/14(10)2026-AFD-POD3/I/24814/2026 on October 30, 2026, titled Rationalisation of Periodicity of KYC R

Kaustav Chowdhury
5 min read


MCA Annual Filing Extension for FY 2025-26: New Dates for AOC-4 and MGT-7
The Ministry of Corporate Affairs has moved the dates for this year's annual filings. The MCA annual filing extension gives companies until the end of December for the financial statements and the end of January for the annual return. It relaxes the additional fee and it relaxes nothing else. What Was Issued General Circular No. 05/2026 was issued on October 24, 2026, under File No. Policy-17/111/2022-CL-V-MCA. The stated reason is representations from stakeholders asking for

Kaustav Chowdhury
6 min read


SEBI Makes Call Recording Optional for Research Analysts' Institutional Clients From November 8
The Securities and Exchange Board of India has relaxed one of the record keeping obligations that research analysts have found hardest to operate. From November 8, 2026, call recording optional for research analysts is the position for interactions with institutional investor clients, and the relaxation is narrower than the headline suggests. What Was Issued SEBI issued circular HO/38/11/(9)2026-MIRSD-POD/I/24272/2026 on October 23, 2026. It revises the Master Circular for Re

Kaustav Chowdhury
5 min read


How to Decide Whether a Cyber Incident Must Be Disclosed Under Regulation 30 of the LODR
When personal data belonging to a listed company's customers turns up where it should not be, the first legal question is usually not a data protection question. It is whether the event has to be told to the stock exchanges, and how soon. Regulation 30 of the LODR answers that, and the answer turns on two things the company has to settle before the clock starts. Step 1: Start With the Duty, Not With the Policy Regulation 30 of the SEBI (Listing Obligations and Disclosure Requ

Kaustav Chowdhury
5 min read


SBI Discloses a Cyberattack to the Stock Exchanges After Customer Records Surface on the Dark Web
On October 21, 2026 the State Bank of India told the stock exchanges that it had been the subject of a cyberattack. That SBI discloses a cyberattack to the market at all is a function of the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015, and the filing repays close reading, because the obligation it discharges is a securities law obligation and not a data protection one. What the Bank Disclosed According to the disclosure as reported, the bank was a

Kaustav Chowdhury
5 min read


Removal of Difficulties Order Corrects the DPDP Act on Children's Consent and Significant Data Fiduciary Audits
Background and Facts The Central Government has exercised its power to remove difficulties under the Digital Personal Data Protection Act, 2023. The Removal of Difficulties Order, made through the Ministry of Electronics and Information Technology and dated October 5, 2026, corrects two pieces of text in the Act: a missing preposition in the children's consent provision, and the description of the periodic audit a Significant Data Fiduciary must undertake. The Order comes int

Kaustav Chowdhury
6 min read


How to Defend an Input Tax Credit Reversal Where Your Supplier Did Not Deposit the Tax
A notice proposing an input tax credit reversal because a supplier did not pay the tax over is answerable, but only on the documents. This guide sets out how to build that answer, in the order the steps arise, beginning with the question that decides which defence is available at all. Step 1: Work Out What the Notice Actually Alleges Three allegations travel under the same heading and they are not answered the same way. The first is simple non-payment by the supplier. The sec

Kaustav Chowdhury
5 min read


Punjab and Haryana High Court Lays Down Guidelines Against Mechanical Reversal of Input Tax Credit
Background and Facts A buyer who paid its supplier in full, took delivery and claimed credit can still lose that credit because the supplier never paid the tax over. The Punjab and Haryana High Court has held that this cannot be done by reflex. Deciding a batch of 424 writ petitions, the Court upheld the provision that makes credit conditional on the tax having been paid to the Government, but ruled that the mechanical reversal of input tax credit is not open to the authoriti

Kaustav Chowdhury
5 min read


How to Challenge a SARFAESI Enforcement Measure Before the Debts Recovery Tribunal
A borrower who wants to challenge a SARFAESI enforcement measure has one application, one forum and one short period in which to file. This guide sets out how to bring that application, in the order the steps arise, beginning with the distinction that decides whether the application is competent at all. Step 1: Identify Which Application You Are Making Two different applications go to the Debts Recovery Tribunal and they are not interchangeable. A secured creditor recovering

Kaustav Chowdhury
6 min read


SEBI Requires Investor Awareness Messages on Broker Websites and Trading Apps From November 1
Background and Facts A disclosure obligation that attaches to a landing page is a different compliance problem from one that attaches to a document. SEBI has directed stock brokers to display investor awareness messages on their websites and on their trading applications, by a circular dated October 1, 2026 issued as part of an initiative the regulator calls Project Jagrook. Display is voluntary from October 5 to October 31, 2026 and mandatory from November 1, 2026. The circu

Kaustav Chowdhury
5 min read


Supreme Court Holds a SARFAESI Measure Taken in Good Faith Cannot Be Unwound by a Civil Suit
Background and Facts A borrower who believes a secured creditor has gone too far has a forum, and it is not the civil court. The Supreme Court has held that a SARFAESI measure taken in good faith cannot be assailed, that a civil court has no jurisdiction over a matter the Debts Recovery Tribunal is empowered to determine, and that a claim for damages cannot be built until the Tribunal has first found the measure to be outside the Act. The appeal was brought by an asset recons

Kaustav Chowdhury
6 min read


How to Apply for Recall of an Admission Order Under the Insolvency and Bankruptcy Code
An application for recall of an admission order is not an appeal and is not a review, and the three are refused for different reasons. This guide sets out how to apply for recall of an order admitting a company into the corporate insolvency resolution process, in the order the steps arise, beginning with the choice of route that decides everything after it. Step 1: Choose Between Recall, Review and Appeal Before Drafting The National Company Law Tribunal has no power to revie

Kaustav Chowdhury
6 min read


Supreme Court Holds an Insolvency Admission Obtained by Fraud May Be Recalled at Any Time
Background and Facts An order admitting a company into insolvency is difficult to undo, and the Code contains no express power to undo it. The Supreme Court has held that an insolvency admission obtained by fraud or collusion may be recalled by the National Company Law Tribunal at any point of time, and that a person who invokes the Code is under a public law duty not to deceive or mislead the tribunal. The judgment in Greenopolis Welfare Confederation v. Rakesh Kumar Gupta w

Kaustav Chowdhury
6 min read


Bombay High Court Orders Deletion of Identified Content but Refuses Blanket Monitoring of Future Posts
Background and Facts An order against a platform is easy to obtain in form and hard to obtain in substance, because the width of the direction decides whether it can be obeyed at all. The Bombay High Court has directed the deletion of specifically identified material published in breach of an existing injunction, and has refused the wider relief sought alongside it, declining blanket monitoring of future posts and the suspension or deletion of the accounts the material came f

Kaustav Chowdhury
6 min read


How to Enforce Rights in Recorded Lecture and Course Content in India
A recorded lecture carries at least two rights that can be enforced separately, and most claims over pirated course content plead only one of them. This guide sets out how to enforce rights in recorded lecture and course content, in the order the steps arise, beginning with the performer's right that belongs to the speaker personally and is frequently overlooked. Step 1: Separate the Rights Before Drafting Anything Three things may sit in a single recorded lecture. There is c

Kaustav Chowdhury
6 min read
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