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    <title>2016 (8) TMI 918 - SECURITIES APPELLATE TRIBUNAL MUMBAI</title>
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    <description>Large, concluded supply contracts that formed a substantial part of a listed company&#039;s order book were treated as price sensitive information requiring immediate disclosure under a disclosure-based regime. The tribunal found no reliable basis to defer disclosure until advance payment, amendments, or third-party confirmation, because the contracts became binding on signing and market-relevant information had to be disclosed continuously. Delayed disclosure therefore violated insider trading disclosure obligations. The penalty on the company and its directors under the SEBI Act was upheld because the breach was not isolated, mitigating factors had been considered, and the sanction remained well below the statutory maximum. The challenged order was sustained and both appeals failed.</description>
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      <description>Large, concluded supply contracts that formed a substantial part of a listed company&#039;s order book were treated as price sensitive information requiring immediate disclosure under a disclosure-based regime. The tribunal found no reliable basis to defer disclosure until advance payment, amendments, or third-party confirmation, because the contracts became binding on signing and market-relevant information had to be disclosed continuously. Delayed disclosure therefore violated insider trading disclosure obligations. The penalty on the company and its directors under the SEBI Act was upheld because the breach was not isolated, mitigating factors had been considered, and the sanction remained well below the statutory maximum. The challenged order was sustained and both appeals failed.</description>
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