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<h1>Company's 'Record Date' for Share Transfers Lacks Legal Validity, Consider Section 108(1A) Implications.</h1> The circular addresses the issue of a company fixing a 'record date' for share transfers without officially closing the register of members. It clarifies that this practice lacks legal validity. If the intention behind setting a 'record date' is to disregard or delay share transfer proposals received between the record date and the annual general meeting where dividends are declared, it effectively equates to closing the register from the record date. The implications of section 108(1A) must be considered in this context.