Limited disclosure default for PDF filing led to reduced penalty after timely XBRL filing and prompt cure of the defect.

Penalty for non-filing of the cash flow statement in PDF format under SEBI listing disclosure rules was treated as a limited default because the statement had already been uploaded in XBRL form within time and the deficiency was cured within five days after notice from the stock exchange. On those facts, the Tribunal confined the penalty to the period of default at a reduced daily rate and reduced it to Rs. 25,000, allowing the appeal in part.

---

---

Issues: Whether the penalty imposed for non-filing of the cash flow statement in PDF format under Regulation 33(3)(g) of the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015 was liable to be reduced in view of prior filing in XBRL form and prompt compliance after notice.

Analysis: The cash flow statement had been uploaded in XBRL form within time, and the omission related only to non-uploading in PDF format. The record showed that the lapse was pointed out by the stock exchange and the deficiency was cured within five days. The Tribunal treated the failure as a limited default and held that, in the facts of the case, the penalty ought to be confined to the period of default at a reduced daily rate.

Conclusion: The penalty was reduced to Rs. 25,000/- and the appeal was allowed in part.

---