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of Private placement of securities - Allotment of Unsecured Fully Convertible Debentures (FCDs) in excess of 500 members - section 71(5) - However the restriction of 500 persons is done away if a trustee was appointed by the Company. In the instant case, it is an admitted fact that a trustee was appointed. Thus there was no restriction to the number of shareholders to whom the debentures would be issued. - AT
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