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    <title>2015 (6) TMI 792 - SECURITIES APPELLATE TRIBUNAL MUMBAI</title>
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    <description>Transfer of shares into a person&#039;s demat account was treated as an acquisition that triggered disclosure obligations once the holding crossed the prescribed threshold under the takeover and insider trading regime. The fact that the transfer was said to be inadvertent, or that no consideration passed, did not change the legal character of the acquisition, and failure to disclose therefore constituted a violation. Penalty for non-compliance was upheld because actual investor loss is not a prerequisite, the retention of the shares remained unexplained, and the adjudicating authority had already considered mitigating circumstances while imposing a nominal sanction.</description>
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      <description>Transfer of shares into a person&#039;s demat account was treated as an acquisition that triggered disclosure obligations once the holding crossed the prescribed threshold under the takeover and insider trading regime. The fact that the transfer was said to be inadvertent, or that no consideration passed, did not change the legal character of the acquisition, and failure to disclose therefore constituted a violation. Penalty for non-compliance was upheld because actual investor loss is not a prerequisite, the retention of the shares remained unexplained, and the adjudicating authority had already considered mitigating circumstances while imposing a nominal sanction.</description>
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