Gratex Industries Limited has received approval from BSE Limited for the waiver of a fine amounting to Rs. 23,600 that was levied for non-submission of the statement of investor complaints under Regulation 13(3) of SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015 for the quarter ended March 31, 2025. The waiver was communicated by BSE on April 29, 2026, following the company's representation to the Internal Regulatory Oversight and Review Group.

Background of the Penalty

The company had initially filed its Integrated Filing (Governance) Report for the quarter ended March 31, 2025 on April 16, 2025. In this filing, the company selected 'No' for the clause regarding the applicability of Annexure 1 (Part B) of the SEBI Circular dated December 31, 2024 related to Investor Grievance Redressal Report. This selection was based on a misinterpretation of the clause, though the company had correctly noted in the notes tab that no complaints were received during the quarter.

Waiver Approval Process

Following an exchange query, Gratex Industries submitted a revised Integrated Filing (Governance) Report on May 21, 2025, which included the Investor Grievance Redressal Report as Annexure I Part B as per SEBI requirements, reporting NIL investor grievances. The company had applied for the waiver on May 21, 2025, explaining the circumstances.

BSE Decision and Advisory

The Internal Regulatory Oversight and Review Group noted that the company had submitted the Integrated (Governance) Report on April 16, 2025, before the due date, and had correctly mentioned that no complaints were received during the quarter in the notes tab. Based on these facts, the group decided to accede to the company's waiver request. BSE has advised Gratex Industries to be careful in future to avoid recurrence of such lapses and ensure exercise of due diligence and accuracy while submitting disclosures to the Stock Exchange.

The company had paid a waiver processing fee of Rs. 11,800 (including GST) on May 28, 2025, and has sought guidance from BSE regarding potential refund of this amount following the waiver approval.

Gratex Industries Limited has formally disclosed to the Bombay Stock Exchange that it does not qualify as a Large Corporate under the Securities and Exchange Board of India (SEBI) regulatory framework. The disclosure was made pursuant to SEBI Circular No. SEBI/HO/DDHS/CIR/P/2018/144 dated November 26, 2018, which establishes criteria for Large Corporate classification.

Regulatory Compliance Disclosure

The company submitted its initial disclosure confirming non-applicability as a Large Corporate, with Managing Director Karan Baldevkrishan Sharma signing the communication on April 13, 2026. The disclosure specifically references the applicability criteria mentioned in clause 2.2 of the SEBI circular, confirming that Gratex Industries Limited does not meet the threshold requirements.

Financial Position Details

As part of the mandatory disclosure format, the company provided key financial and operational details in a structured annexure:

The company's outstanding borrowings of Rs. 0.17 crore as of March 31, 2026, represent a significantly low debt level that places it well below the Large Corporate threshold criteria.

Regulatory Framework Context

The disclosure references two key SEBI circulars that govern Large Corporate identification and compliance requirements. The primary circular SEBI/HO/DDHS/CIR/P/2018/144 dated November 26, 2018, established the initial framework, while subsequent circular SEBI/HO/DDHS/P/CIR/2021/613 dated August 10, 2021, provided updated applicability criteria.

Under the regulatory framework, entities identified as Large Corporates face mandatory borrowing requirements through debt securities. Beginning from FY 2022, any shortfall in mandatory borrowing through debt securities attracts a fine of 0.2% of the shortfall amount, levied by stock exchanges at the end of each two-year block period.

Corporate Governance Structure

The disclosure documentation was prepared and signed by key members of the company's leadership team. Company Secretary and Compliance Officer Neha Arora and Chief Financial Officer Mona Pratap Menon provided supporting signatures on April 8, 2026, demonstrating proper corporate governance protocols in regulatory compliance matters.

The company has designated BSE Limited as the stock exchange where any potential fines would be paid in case of future shortfall in mandatory borrowing requirements, should its status change in subsequent financial years.