Suraj Limited Secretarial Compliance Report for FY26 Notes Three Deviations
Suraj Limited has received its secretarial compliance report for the financial year ended March 31, 2026, prepared by Hardik Jetani & Associates. The report identifies three deviations from SEBI (LODR) Regulations, 2015, including non-submission of PDF format secretarial compliance report to BSE Limited, non-compliance with standalone cash flow submission to NSE, and delayed related party transactions disclosure. The company incurred fines totaling Rs 1,42,160 including GST for these violations. Management attributed the issues to procedural oversights and technical errors. The report confirms compliance with other regulatory requirements including secretarial standards, policy adoption, website disclosures, and prohibition of insider trading regulations.

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Suraj Limited has received its secretarial compliance report for the financial year ended March 31, 2026, prepared by Hardik Jetani & Associates, Practicing Company Secretaries. The report, prepared pursuant to Regulation 24A of the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015, identifies three deviations from compliance requirements during the review period.
The report examined compliance with various SEBI regulations including the SEBI (LODR) Regulations, 2015, SEBI (Issue of Capital and Disclosure Requirements) Regulations, 2018, SEBI (Substantial Acquisition of Shares and Takeovers) Regulations, 2011, and SEBI (Prohibition of Insider Trading) Regulations, 2015, among others.
Compliance Deviations Identified
The practicing company secretary noted three specific deviations during the review period:
| Sr. No. | Compliance Requirement | Deviation | Stock Exchange | Fine Amount |
|---|---|---|---|---|
| 1 | Regulation 24A (2) - Secretarial compliance report submission | PDF of secretarial compliance report not submitted | BSE Limited | Rs. 61160 including GST |
| 2 | Regulation 33 - Filing of Financial Results | Non-compliance with submission of Standalone cash flow for the year ended March 2025 | National Stock Exchange of India Limited | Rs. 81000/- including GST |
| 3 | Regulation 23(9) - Related Party Transactions disclosure | Delayed submission of RPT disclosure for the half year ended March 31, 2025 | National Stock Exchange of India Limited | - |
Management Response and Observations
Regarding the first deviation, the company stated that it had duly complied with the requirement within the prescribed timeline by filing the Annual Secretarial Compliance Report (ASCR) in XBRL format on May 23, 2025. However, due to an unintentional and inadvertent oversight, the PDF version could not be uploaded on the BSE portal, which was described as purely procedural in nature.
For the standalone cash flow statement omission, management attributed the issue to a technical error during the scanning process, stating the omission was unintentional and procedural without any intent to withhold material information.
The delayed RPT disclosure was attributed to circumstances beyond the company's control, including the first-time implementation of the Integrated Filing – Financials in XBRL system and slow internet connectivity issues that prolonged the submission process.
Overall Compliance Status
Despite these deviations, the report confirmed that Suraj Limited has complied with provisions of applicable regulations and circulars in other areas. The company maintains compliance with Secretarial Standards issued by ICSI, has adopted and updated all applicable policies under SEBI regulations, and maintains a functional website with timely dissemination of required documents.
The report also confirmed that none of the directors are disqualified under Section 164 of Companies Act, 2013, and the company is in compliance with prohibition of insider trading regulations. The listed entity does not have any material subsidiary, and there were no instances of resignation of statutory auditors during the review period.
Historical Stock Returns for Suraj
| 1 Day | 5 Days | 1 Month | 6 Months | 1 Year | 5 Years |
|---|---|---|---|---|---|
| -1.30% | -2.94% | -9.47% | -15.75% | -40.35% | -24.83% |
Will Suraj Limited implement new internal controls or compliance monitoring systems to prevent similar procedural oversights in future filings?
How might these regulatory deviations impact Suraj Limited's corporate governance rating or institutional investor confidence going forward?
Could the technical issues cited by Suraj Limited indicate broader IT infrastructure weaknesses that may affect future regulatory compliance?


































