Happy to share that Katalyst Advisors has obtained yet another one of its kind SEBI approval, this time for Mr. Achal Bakeri, Founder Promoter, Chairman and Managing Director of Symphony Limited, who will gift approximately 3,43,000 equity shares, about 0.5% of the Company’s equity capital and roughly INR 20 crore at current prices, from his personal holding. The gift will be made over four years, and, unusually, to the next of kin of employees, ex-employees, housekeeping staff and family office staff, as a gesture to recognise the silent but vital role of the employees’ families of Symphony.
This follows the approval we had obtained in March 2025 for Mr. Sanjay Shah, promoter of Prudent Corporate Advisory Services Limited, who gifted 1,75,000 shares worth about INR 34 crore to some 650 employees, including his household help.
Why does a promoter gift need SEBI’s approval? Because Regulation 31A(6) of the LODR Regulations provides that on a gift by a promoter, the recipient is immediately classified as a promoter or promoter group member. Applied to an act of personal generosity, that would make an employee, ex-employee, or a household help, or their family members (in the present case) part of the promoter group of a listed company. Therefore, the answer lies in Regulation 102, under which SEBI may relax the strict enforcement of any requirement where it causes undue hardship, pursuant to which a gift can be undertaken, and the donees remain public shareholders.
On accounting, Ind AS 102 treats a shareholder transfer to service providers as a share-based payment unless it is clearly for another purpose. That presumption is displaced here. There is no vesting, no retention condition and no linkage to service, and more particularly, in the present case, the shares go to the families rather than to the employees.
On tax, the value is taxable in the recipient’s hands as income from other sources at fair market value, subject to the gift threshold.
Attached is the press release, where our role has been acknowledged.