ANSAL PROPERTIES AND INFRASTRUCTURE LIMITED

Section 194 of Companies Act, 2013

Prohibition on forward dealings in securities of Company by Director or Key
Managerial Personnel (New Section)
Section Provisions of Sections Checklist



194(1)







































No director of a company or any of
its key managerial personnel shall
buy in the company, or in its
holding, subsidiary or associate
company


















YES NO
There will be a contravention of the
provisions of Section 194 of the
Companies Act, 2013, if ATLEAST
ONE of any of the Sub Points within
Section -A AND ATLEAST ONE of
any of the Sub-points within Section-
B AND ATLEAST ONE of any of the
Sub-points within Section-C is YES

Section- A

Whether any of the rights as specified
in Section-C has been bought by:-

Managing Director/
CEO/Manager of the
Company

Or

Its Company Secretary

Or

Its Whole Time
Director (WTD)

Or

Its CFO

Or

Any other officer
prescribed as KMP
(Key Managerial Personnel)

(Although in Sub-section 1 the word
Director is used, we shall construe it
to mean Whole Time Director
pursuant to the explanation of the
Section)
ANSAL PROPERTIES AND INFRASTRUCTURE LIMITED






























































(a) a right to call for delivery or a
right to make delivery at a
specified price and within a
specified time, of a specified
number of relevant shares or
a specified amount of relevant
debentures; or






YES NO

Section B

Whether the relevant shares or
debentures, in relation to which the
right as mentioned in Section C are
bought in:

Company

OR

its Holding
Company

OR

its Subsidiary
Company

OR

its Associate
Company

Section- C
Whether :

1) the right to call for
delivery of specified
no. of relevant shares
bought at :-


a) at a specified
price; and
b) within a specified
time

2) the right to make
delivery of specified
number of relevant
shares bought at :-

a) at a specified
price; and
b) within a specified
time

ANSAL PROPERTIES AND INFRASTRUCTURE LIMITED
























































(b) a right, as he may elect, to call
for delivery, or to make
delivery at a specified price
and within a specified time, of
a specified number of relevant
shares or a specified amount
of relevant debentures.


Explanation:- Relevant Shares
and Relevant Debentures
means shares and debentures of
the Company in which the
concerned person is a Whole-Time
Director or other Key Managerial
Personnel or Shares and
Debentures of its holding and
Subsidiary Companies.


YES NO

3) the right to call for
delivery of specified
amount of relevant
Debentures bought at
:-

a) at a specified
price; and
b) within a specified
time

4) whether the right to
make delivery of
specified amount of
relevant Debentures
has been bought at :-

a) at a specified
price; and
b) within a specified
time


5) the right may be
exercised to call for
delivery of specified
number of relevant
shares bought at :-

a) at a specified
price; and
b) within a specified
time


6) the right may be
exercised to make
delivery of specified
number of relevant
shares bought at :-

a) at a specified
price; and
b) within a specified
time


ANSAL PROPERTIES AND INFRASTRUCTURE LIMITED






























194(2)
































If a director or any key managerial
personnel of the company
contravenes the provisions of sub-
section (1), such director or key
managerial personnel of the
company shall be punishable with
imprisonment for a term which
may extend to two years or with
fine which shall not be less than
one lakh rupees but which may
extend to five lakh rupees, or with
both.




YES NO

7) the right may be
exercised to call for
delivery of specified
amount of relevant
debentures bought at
:-

a) at a specified
price; and
b) within a specified
time

8) whether the right
may be exercised to
make delivery of
specified amount of
relevant debentures
bought at :

a) at a specified
price; and
b) within a specified
time



If there is any contravention by the
Whole Time Director(WTD)/KMP, Such
WTD/KMP will be punishable with:-

(i) Imprisonment for a term
of upto 2 years

OR

(ii) Fine between Rs. 100,000 and
500,000

OR

(iii) With (i) and (ii) both



ANSAL PROPERTIES AND INFRASTRUCTURE LIMITED

Date : 26
th
February, 2014



194(3)








Where a director or other key
managerial personnel acquires any
securities in contravention of sub-
section (1), he shall, subject to the
provisions contained in sub-section
(2), be liable to surrender the
same to the company and the
company shall not register the
securities so acquired in his name
in the register, and if they are in
dematerialized form, it shall inform
the depository not to record such
acquisition and such securities, in
both the cases, shall continue to
remain in the names of the
transferors.




In case the WTD/KMP acquires any
Securities in contravention of Sub-
Section (1), the said WTD/KMP shall
surrender the said securities to the
Company, and the Company shall not
register the transfer of the said
Securities and further inform the
Depository not to record the transfer
of the Securities, in case the securities
are held in the Demat Form.

The effect will be such as if the
securities were never purchased by
the WTD/KMP and the securities shall
remain in the names of Transferor(s).