The Board of Directors of Kalpataru Limited , at its meeting held on Tuesday, May 12, 2026, approved amendments to the Code of Practices and Procedures for Fair Disclosure of Unpublished Price Sensitive Information (the 'Fair Disclosure Policy'). The amendment was made pursuant to Regulation 8 read with Schedule A of the Securities and Exchange Board of India (Prohibition of Insider Trading) Regulations, 2015 ('PIT Regulations'). The amended policy has been intimated to the stock exchanges and is also available on the company's official website at https://www.kalpataru.com/investor-corner .

Policy Revision Details

The Fair Disclosure Policy was originally adopted on August 02, 2024, and the amendments approved on May 12, 2026 constitute its first revision. The key details of the policy revision are summarised below:

Key Principles of the Fair Disclosure Policy

The amended policy sets out the following core principles governing the disclosure of Unpublished Price Sensitive Information (UPSI):

• Timely and adequate public disclosure of all credible and concrete UPSI as soon as such information comes into being
• Uniform and universal dissemination of UPSI to avoid selective disclosure
• Prompt dissemination of UPSI that gets disclosed selectively, inadvertently or otherwise
• Appropriate, fair, and prompt response to queries on news reports and requests for verification of market rumours by regulatory authorities
• Ensuring that information shared with analysts and research personnel is not UPSI
• Publishing transcripts or records of proceedings of meetings with analysts and other investor relations conferences on the official website
• Handling UPSI on a need-to-know basis

Oversight and Disclosure Coordination

Under the revised policy, the Board of Directors is required to designate a senior officer as the Chief Investor Relations Officer (CIRO), who will report to the Chief Financial Officer or Managing Director. The CIRO is responsible for ensuring timely, adequate, uniform, and universal dissemination of UPSI to stock exchanges, analysts, shareholders, and media. Disclosure or dissemination of UPSI is to be approved in advance by the CIRO, who may consult the Managing Director, Executive Director(s), or the Chief Financial Officer in cases of doubt.

In instances where UPSI is accidentally disclosed without prior approval, the person responsible is required to immediately inform the CIRO, who will then promptly disseminate the information to make it generally available.

Legitimate Purpose Framework

The policy includes a dedicated framework for determining Legitimate Purposes under which UPSI may be shared. Sharing of UPSI is permitted in the ordinary course of business with partners, collaborators, lenders, customers, suppliers, merchant bankers, legal advisors, auditors, insolvency professionals, or other advisors or consultants, provided such sharing is not undertaken to evade or circumvent regulatory prohibitions. Any person receiving UPSI pursuant to a legitimate purpose is classified as an insider and is required to maintain confidentiality in compliance with SEBI PIT Regulations.

Structured Digital Database

The policy mandates that the Board of Directors ensure the maintenance of a Structured Digital Database containing the nature of UPSI, the names of persons who have shared the information, and the names of persons with whom the information has been shared, along with their Permanent Account Number (PAN) or any other identifier authorised by law. The database must be maintained internally with adequate controls, including time stamping and audit trails to ensure non-tamperability. Information not originating from within the organisation must be entered into the database not later than 2 calendar days from receipt. The Compliance Officer is responsible for maintaining the database and providing notice to relevant persons or entities to maintain confidentiality of UPSI.

Kalpataru Limited has disclosed, under Regulation 30 of the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015, that its wholly owned subsidiary, Ananta Landmarks Private Limited (ALPL), has received a GST appellate order dated May 8, 2026, from the Joint Commissioner of State Tax, Mumbai – App-F-0008. The order imposes a net GST demand of Rs. 4,00,85,389 (Rupees Four Crores Eighty-Five Thousand Three Hundred and Eighty-Nine only) for the period April 2021 to March 2022, inclusive of interest and penalty.

Background and Prior Disclosures

This development follows a series of earlier disclosures made by Kalpataru Limited regarding GST-related orders received by ALPL. The table below summarises the prior demands communicated to the stock exchanges:

In the current matter, ALPL had originally received an order dated December 30, 2025, passed by the Deputy Commissioner of State Tax (MUM-AUD-E-0405), Mumbai, imposing a total GST demand of Rs. 5,48,78,704 (Rupees Five Crores Forty-Eight Lakhs Seventy-Eight Thousand Seven Hundred and Four Only) for FY 2021-22, inclusive of interest and penalty under the IGST Act, 2017, the Central Goods and Services Tax Act, 2017, and the State Goods and Services Tax Act, 2017.

Appeal and Revised Order

ALPL filed an appeal on February 20, 2026 against the original order. The GST Appellate Authority has now partially allowed the appeal, reducing the demand to Rs. 4,00,85,389, under Section 107 of the CGST Act, 2017, and Section 20 of the IGST Act read with Section 107 of the CGST Act, 2017. The order was received by ALPL on May 8, 2026 at 2:29 p.m.

The key details of the appellate order are summarised below:

Nature of Alleged Contraventions

The order pertains to the following alleged violations:

• RCM Liability on services provided by Municipal Corporation
• Excess claim of Input Tax Credit (ITC) in GSTR-3B on account of various reasons
• Differential tax liability on corporate guarantee

Financial Impact and Next Steps

Kalpataru Limited has stated that this order does not have a material financial impact on the company. ALPL intends to file a further appeal against the order before the appropriate GST Appellate Tribunal. Based on the opinion of its legal advisors, ALPL is of the view that it has a strong case in the matter.

The disclosure was made in accordance with SEBI Master Circular HO/49/14/14(7)2025-CFD-POD2/I/3762/2026 dated January 30, 2026, read with Regulation 30 of the SEBI Listing Regulations. The information has also been simultaneously disseminated on the company's website.