Dayanand Munjal Investments Private Limited has disclosed its shareholding in Shivam Autotech Limited , confirming that no shares were encumbered during the financial year ended March 31, 2026. The entity held 9,14,17,272 equity shares as on March 31, 2026, representing a significant stake in the company. This declaration ensures shareholders are aware of the status of the promoter's holdings regarding any pledges or liens.

The disclosure was submitted to The BSE Limited and The National Stock Exchange Limited in compliance with Regulation 31(4) of the SEBI (Substantial Acquisition of Shares and Takeovers) Regulations, 2011. This regulation requires substantial shareholders to inform the exchanges if they have created any encumbrance on their shares during the financial year. The confirmation of zero encumbrance indicates that the entire holding is free from such charges.

Shareholding Details

The filing provides specific details regarding the holding period and the status of the shares. The confirmation covers the entire duration of the financial year ended March 31, 2026.

The letter was signed by Yogesh Chander Munjal, Director of Dayanand Munjal Investments Private Limited. A copy of the disclosure was also marked to the Audit Committee of Shivam Autotech Limited for their records.

Shivam Autotech Limited reported several compliance deviations under SEBI regulations for the financial year ended March 31, 2026, including fines for delayed disclosures and procedural lapses related to debt issuances. A secretarial compliance report by Yogesh K & Associates highlighted specific instances of non-compliance involving related party transactions and the utilization of debenture proceeds. The company has addressed certain issues, such as obtaining requisite stock exchange approvals, while other observations regarding fund deployment remain.

The report detailed that the company issued Optionally Convertible Debentures (OCDs) worth ₹75 crore in Tranche-1 and ₹45 crore in Tranche-2 during the review period. As per a monitoring agency report dated May 15, 2026, a total amount of ₹105.15 crore was utilized in Q4FY26 towards the repayment of Non-Convertible Debentures (NCDs) and reimbursement to the allottee, AASCO. The agency noted that while ₹115 crore was earmarked for repayment, the company had already made partial repayments from its own funds before the OCD issue. Subsequently, ₹37.15 crore was used for reimbursement, an action not disclosed as an object in the offer document and lacking specific Board approval. The statutory auditor provided a certificate confirming the transaction on May 13, 2026.

Further observations indicated underutilisation of funds. An amount of ₹0.01 crore from the issue proceeds was utilized for bank charges, whereas the implementation schedule required the deployment of ₹5 crore towards long-term working capital within fifteen days of receipt of funds. By March 31, 2026, the company had not fully utilized this amount, resulting in an underutilisation of ₹4.99 crore. This deployment also lacked specific Board approval.

The company faced regulatory actions for previous non-compliances. The National Stock Exchange (NSE) and Bombay Stock Exchange (BSE) imposed fines of ₹5,000 each for a one-day delay in intimating related party transactions for the half-year ended March 31, 2024. Additionally, fines of ₹59,000 were imposed by both exchanges for failing to obtain in-principle approval for OCDs issued via private placement. The company rectified this by ratifying the issuance through a postal ballot and subsequently securing the necessary approvals from NSE and BSE.

NSE also issued an advisory letter regarding the non-compliance of the proviso to Regulation 167(2) of the SEBI (Issue of Capital and Disclosure Requirements) Regulations, 2018. The exchange observed that 250 unlisted secured OCDs were not kept under lock-in as required. The company acknowledged the matter and stated it had implemented measures to prevent recurrence.

Compliance Status

The report confirmed that Shivam Autotech complied with most regulatory requirements, including Secretarial Standards, policy updates, and website disclosures. It confirmed no disqualification of directors and that the company does not have any subsidiaries. Performance evaluations of the Board and committees were conducted, and the company maintained compliance with insider trading regulations.