The section 42 and relevant rules of the private placement states that an offer or invitation to subscribe securities under private placement shall not be made to persons more than two hundred in the aggregate in a financial year. The limit of 200 is applicable class-wise or for aggregate of all classes during the financial year??
In our case, the company is an NBFC already issued debentures on private placement basis and now planning to issue CCPS (Compulsory convertible Preference Shares) on private placement basis. Whether both the persons (CCPS and Debentures) will be considered for the limit of 200?
Thanks in advance.

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Thanks and Regards,
Nonit Kumar
Professional Consultant
|Mehta & Mehta Company Secretaries |
Plot No-187, Pocket-17, Sector 24, Rohini,
Delhi 110085
Mob.: +91 8956280026| 9953486498
Head Office: Worli Mumbai
B: +91 (22) 6611 9696 |
Website: http://www.mehta-mehtaadvisory.com|
Our Branch office locations: Mumbai | Navi Mumbai | Pune | Cochin | Kolkata | Vapi | Hyderabad | Delhi | Kolhapur | Bengaluru | Jaipur | Raipur | Ahmedabad | Bhubaneswar
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