Samtel (India) Ltd. — Regulatory Filings 2021

Jun 16, 2021

SAMTEL INDIA LIMITED Administrative Office: 1212, 12th Floor,, 43 Chiranjiv Tower, Nehru Place, New Delhi - 110019 PHONES: 011-40555700, FAX:011-41555006 www.samtel-india.com CIN No.: L31909RJ1981PLC012073

Courier/Regd. Post

June 16, 2021

The Executive Director / Secretary, B S E Ltd., Deptt. of Corporate Services, Phiroze Jeejeebhoy Towers, Dalal Street, Fort, Mumbai – 400 001.

Reg.: Submission of Compliance Report for the financial year ended 31[st] March, 2021 under Clause 24(A) of the SEBI (Listing Obligations & Disclosure Requirement) 2015 as amended from time to time.

Dear Sir,

In compliance to Clause 24(A) of the SEBI (Listing Obligations & Disclosure Requirement) 2015 as amended from time to time, we are enclosing herewith Compliance report dated 15[th] June, 2021 issued by Mr. Jatin Gupta of M/s Jatin Gupta & Associates, New Delhi, for the year ended March 31[st] 2021.

Hope you will find the above in order. Kindly acknowledge its receipt.

Thanking you

Yours faithfully For Samtel India Ltd.

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Satish K Kaura Mg. Director

Encl. As above

Regd. Office: Village Naya Nohra, Kota Baran Road, Kota (Rajasthan)

JATIN GUPTA & ASSOCIATES COMPANY SECRETARIES

Office : TR-1, Top Floor, Plot No. 3, Anupam Plaza, LSC, MayurVihar Phase I, Delhi 110 091 (Above Yes Bank Limited) Ph- +91-11-2275 6338 : E-Mail : jatinfcs@gmail.com

Secretarial compliance report of Samtel India Limited for the year ended 31[st] March, 2021

I, Jatin Gupta of M/s Jatin Gupta & Associates, Company Secretaries, Delhi have examined:

• (a) documents and records made available to us and explanation provided by Samtel India Limited (“the listed entity”) ;

• (b) the filings/ submissions made by the listed entity to the stock exchanges ;

• (c) website of the listed entity ;

• (d) any other document/ filing, as may be relevant, which has been relied upon to make this certification, for the year ended 31[st] March, 2021 (“Review Period”) in respect of compliance with the provisions of :

• (a) the Securities and Exchange Board of India Act, 1992 (“SEBI Act”) and the Regulations, circulars, guidelines issued thereunder; and

• (b) the Securities Contracts (Regulation) Act, 1956 (“SCRA”), rules made thereunder and the Regulations, circulars, guidelines issued thereunder by the Securities and Exchange Board of India (“SEBI”);

The specific Regulations, whose provisions and the circulars/guidelines issued thereunder, have been examined, include :-

• (a) Securities and Exchange Board of India (Listing Obligations and Disclosure Requirements) Regulations, 2015;

• (b) Securities and Exchange Board of India (Issue of Capital and Disclosure Requirements) Regulations, 2018;

• (c) Securities and Exchange Board of India (Substantial Acquisition of Shares and Takeovers) Regulations, 2011;

• (d) ~~Securities and Exchange Board of India (Buyback of Securities) Regulations, 2018;~~

• (e) ~~Securities and Exchange Board of India (Share Based Employee Benefits) Regulations, 2014;~~

• (f) ~~Securities and Exchange Board of India (Issue and Listing of Debt Securities) Regulations, 2008;~~

• (g) ~~Securities and Exchange Board of India(Issue and Listing of Non Convertible and Redeemable Preference Shares) Regulations,2013;~~

JATIN Digitally signed by JATIN GUPTA GUPTA Date: 2021.06.15 16:40:25 +05'30'

JATIN GUPTA & ASSOCIATES COMPANY SECRETARIES

Office : TR-1, Top Floor, Plot No. 3, Anupam Plaza, LSC, MayurVihar Phase I, Delhi 110 091 (Above Yes Bank Limited)

Ph- +91-11-2275 6338 : E-Mail : jatinfcs@gmail.com

• (h) Securities and Exchange Board of India (Prohibition of Insider Trading) Regulations, 2015;

• (i) And (other regulations as applicable) and circulars/guidelines issued thereunder;

and based on the above examination, I hereby report that, during the Review Period:

• (a) The listed entity has complied with the provisions of the above Regulations and circulars/guidelines issued thereunder, except in respect of matters specified below:-

Sr.No	Compliance Requirement (Regulations/ circulars / guidelines including specific clause)	Deviations	Observations/ Remarks of the Practicing Company Secretary
1	Payment of Annual Listing Fee to the Stock Exchange (BSE) where the equity shares of the company is listed	Company is not regular in payment of Listing Fess.	As informed by management and their representatives, In the absence of adequate business activities the company is going through liquidity crunch. Thus, due to non-availability of funds, company has failed to pay the Listing Fees. The arrear / delay in paymentpersist.
2	Report under Regulation 55 A of SEBI (Depository and participants) Rules, 1996.	Company has not filed report for the Qtr. Ended 31st Dec.2019, 31st March, 2020 and 30th June, 2020 30th Sept., 2020, 31st Dec., 2020 and 31st March, 2021.	As informed by management and their representatives, the non submission of report was due to non receipt of BO Data from CDSL. Application for change of RTA was pending with CDSL since 2017-18, whereas the

JATIN Digitally signed by JATIN GUPTA GUPTA Date: 2021.06.15 16:40:44 +05'30'

JATIN GUPTA & ASSOCIATES COMPANY SECRETARIES

Office : TR-1, Top Floor, Plot No. 3, Anupam Plaza, LSC, MayurVihar Phase I, Delhi 110 091 (Above Yes Bank Limited) Ph- +91-11-2275 6338 : E-Mail : jatinfcs@gmail.com

application for
change of RTA was
already accepted by
NSDL. However,
instead of approving
the change of RTA,
CDSL has blocked the
BO Data. Hence, non
compliance.
It’s a long pending
issue which is
unresolved, hence
we are unable to
comment upon
same, since Company
does not have
requisite data.

• (b) The entity has maintained records under the provisions of the above Regulations and circulars/guidelines issued thereunder insofar as it appears from my examination of those records, amidst ongoing pandemic, since physical visits were curtailed to a minimal level.

• (c) The following are the details of actions taken against the listed entity/its promoters/ directors/ ~~material subsidiaries~~ either by SEBI or by Stock Exchanges (including under the Standard Operating Procedures issued by SEBI through various circulars) under the aforesaid Acts/Regulations and circulars/guidelines issued thereunder:

JATIN Digitally signed by JATIN GUPTA Date: 2021.06.15 GUPTA 16:40:55 +05'30'

JATIN GUPTA & ASSOCIATES COMPANY SECRETARIES

Office : TR-1, Top Floor, Plot No. 3, Anupam Plaza, LSC, MayurVihar Phase I, Delhi 110 091 (Above Yes Bank Limited) Ph- +91-11-2275 6338 : E-Mail : jatinfcs@gmail.com

Sr. No.	Action taken by	Details of violation	Details of action taken E.g. fines, warning letter, debarment, etc.	Observations / remarks of the Practicing Company Secretary, **any. **
1.	NSDL/BSE	non payment of listing fee	depository participants that the demat accounts of the promoters and promoter Group have been frozen by NSDL due to non compliances as reported by BSE with regard to non payment of listing fee by the company.	the default is admitted and self explanatory. The freezing of account by NSDL pertains to promoters in their individual capacity, hence company has nothing to do with same. Though company also continue to be a defaulter company for non payment of listingfee

(d) The listed entity has taken the following actions to comply with the observations made in previous reports : nil

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Digitally signed JATIN by JATIN GUPTA Date: GUPTA 2021.06.15 16:41:08 +05'30'

JATIN GUPTA & ASSOCIATES COMPANY SECRETARIES

Office : TR-1, Top Floor, Plot No. 3, Anupam Plaza, LSC, MayurVihar Phase I, Delhi 110 091 (Above Yes Bank Limited) Ph- +91-11-2275 6338 : E-Mail : jatinfcs@gmail.com

(Note) :

1. Provide the list of all the observations in the report for the previous year along with the actions taken by the listed entity on those observations :

2. Add the list of all observations in the reports pertaining to the periods prior to the previous year in case the entity has not taken sufficient steps to address the concerns raised / observations :

E.g. In the report for the year ended 31[st ] March, 2021, the PCS shall provide a list of:

• all the observations in the report for the year ended 31[st ] Mar, 2021 along with the actions taken by the listed entity on those observations.

• the observations in the reports pertaining to the year ended 31[st] Mar,2021 and earlier, in case the entity has not taken sufficient steps to address the concerns raised/ observations in those reports. )

JATIN GUPTA

Digitally signed by JATIN GUPTA Date: 2021.06.15 16:41:20 +05'30'

Place: Delhi Signature: Date: 15.06.2021

Name of the Practicing Company Secretary : Jatin Gupta

FCS No.: 5651 C P No.: 5236 UDIN : F005651C000467541