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<h1>Companies Can Avoid Penalties on Pre-2014 Securities by Offering Refunds with Interest; Chartered Accountant Certification Required.</h1> The circular outlines procedures for handling cases before April 1, 2014, where companies offered or allotted securities to more than 49 but up to 200 investors in a financial year. Previously, such offers were considered public offers, requiring compliance with the Companies Act, 1956, and SEBI guidelines. To avoid penalties, companies can allow investors to surrender securities for a refund with 15% annual interest. Refunds must be processed through banking channels, and companies can deduct previously paid amounts. A Chartered Accountant must certify compliance, and stock exchanges must inform listed entities and publish the circular on their websites.