360 ONE WAM Limited Files Revised Promoter Encumbrance Disclosure for Kush and Kyra Bhagat
360 ONE WAM Limited filed a revised disclosure with BSE Limited on April 30, 2026, correcting encumbrance details for promoter group members Kush Bhagat and Kyra Bhagat. The revision changed their 'Promoter Holding Already Encumbered' status to 'nil' as suggested by the exchange. Both individuals hold 13,50,000 shares each (0.33% stake) subject to restrictions under a retention and profit-sharing agreement with APAC Company XV Limited dated October 31, 2022. The filing ensures compliance with SEBI regulations on substantial acquisition of shares and takeovers.

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360 one wam Limited has submitted a revised regulatory disclosure to BSE Limited, addressing discrepancies in earlier filings related to promoter group members. The company filed the corrected disclosure on April 30, 2026, following clarifications sought by the stock exchange regarding encumbrance details for specific promoter entities.
Disclosure Revision Details
The revision specifically addresses the encumbrance status for Mr. Kush Bhagat and Ms. Kyra Bhagat, both members of the promoter group. Based on suggestions from BSE Limited, the company has corrected the 'Promoter Holding Already Encumbered' status to 'nil' for both individuals in the revised disclosure.
| Parameter | Kush Bhagat | Kyra Bhagat |
|---|---|---|
| Total Shareholding | 13,50,000 shares (0.33%) | 13,50,000 shares (0.33%) |
| Previously Encumbered Holdings | Nil | Nil |
| Current Encumbrance Status | Subject to restrictions | Subject to restrictions |
| Encumbrance Entity | APAC Company XV Limited | APAC Company XV Limited |
Regulatory Background
The disclosure relates to compliance requirements under Regulation 31(1) and 31(2) of SEBI (Substantial Acquisition of Shares and Takeovers) Regulations, 2011. The encumbrance conditions stem from a retention and profit-sharing agreement (RPSA) dated October 31, 2022, between APAC Company XV Limited, the KB Group, and Mr. Yatin Shah.
Share Transfer and Restrictions
On March 11, 2026, Ms. Shilpa Bhagat executed an off-market inter se transfer of 27,00,000 equity shares through gift transactions. The transfer allocated 13,50,000 shares each to Mr. Kush Bhagat and Ms. Kyra Bhagat, establishing their current shareholding positions.
Key Restrictions Under RPSA
The agreement imposes specific limitations on the KB Group's share transactions:
- Prohibition on transfer or encumbrance creation without prior written consent from APAC
- Encumbrance limits of 40% during the first 12 months and 30% thereafter
- Free transfer allowance of up to 10% of restricted holdings annually
Compliance Documentation
Company Secretary Rohit Bhase signed the revised disclosure, ensuring proper regulatory compliance. The filing includes comprehensive details of all promoter and promoter group members' shareholdings and encumbrance status as of the reporting date of March 13, 2026.
The revised disclosure maintains transparency in promoter shareholding patterns while addressing the stock exchange's specific concerns regarding encumbrance reporting accuracy.
Historical Stock Returns for 360 One WAM
| 1 Day | 5 Days | 1 Month | 6 Months | 1 Year | 5 Years |
|---|---|---|---|---|---|
| +3.08% | +1.35% | +12.31% | -4.74% | +8.16% | +278.41% |
How might the encumbrance restrictions under the RPSA agreement impact 360 One WAM's ability to attract new strategic investors or execute future fundraising plans?
What potential implications could arise when the RPSA agreement's encumbrance limits change from 40% to 30% after the initial 12-month period?
Will APAC Company XV Limited's control over share transfers affect the promoter group's decision-making autonomy in future corporate governance matters?


































