General information about company |
| Scrip Code* | 543497 |
| NSE Symbol* | NOTLISTED |
| MSEI Symbol | NOTLISTED |
| ISIN | INE0KQ001017 |
| Name of the listed entity | BHATIA COLOUR CHEM LIMITED |
| Date of start of financial year | 01-04-2025 |
| Date of end of financial year | 31-03-2026 |
| Date of Reporting to Exchange | 06-05-2026 |
| Whether any observations reported by the Secretarial Auditor | Yes |
| The listed entity has maintained proper records under the provisions of the above Regulations and circulars/ guidelines issued thereunder insofar as it appears from my/our examination of those records. | Yes |
| In previous, Any actions taken against the listed entity/its promoters/directors/its material subsidiaries either by SEBI or by stock exchanges (including under the Standard operating procedures issued by SEBI through various circulars). | No |
| Is there any observation made in the previous report | Yes |
| Name of the Certifying Firm | Ranjit Binod Kejriwal |
| Name of the practicing Company Secretary issuing the report | Ranjit Binod Kejriwal |
| Membership Type | FCS |
| ACS/FCS No. | 6116 |
| UDIN | F006116H000279873 |
| CP No. | 5985 |
| Place of PCS | Surat |
| PCS Report Date | 05-05-2026 |
Regulations |
| Sr No | Regulation | Applicability during the period under review (Yes/No) | Any Observation (Yes/No) |
| 1 | Securities and Exchange Board of India (Listing Obligations and Disclosure Requirements) Regulations, 2015 | Yes | Yes |
| 2 | Securities and Exchange Board of India (Issue of Capital and Disclosure Requirements) Regulations, 2018 | Yes | No |
| 3 | Securities and Exchange Board of India (Substantial Acquisition of Shares and Takeovers) Regulations, 2011 | Yes | No |
| 4 | Securities and Exchange Board of India (Buyback of Securities) Regulations, 2018 | No | No |
| 5 | Securities and Exchange Board of India (Share Based Employee Benefits and Sweat Equity) Regulations, 2021 | No | No |
| 6 | Securities and Exchange Board of India (Issue and Listing of Non-Convertible Securities) Regulations, 2021 | No | No |
| 7 | Securities and Exchange Board of India (Prohibition of Insider Trading) Regulations, 2015 | Yes | No |
Current Report |
| Sr No | Compliance requirement (regulations/circulars/ guidelines including specific clauses) | Regulation Name/ SEBI Circular number | Regulation Number/ circular dated | Deviations | Action taken by | Name of Other Regulatory Body | Type of Action (Advisory/Clarification/Fine/Show Cause Notice/ Warning, etc.) | Details of other action taken | Details of violation | Fine Amount | Observations/remarks of the practising Company Secretary, if any | Management Response | Remarks |
| 1 | Regulation 30 of SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015 | Securities and Exchange Board of India (Listing Obligations and Disclosure Requirements) Regulations, 2015 | Regulation 30 of SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015 | Initial disclosure contained a typographical error, which was subsequently corrected by filing a revised outcome | Other Regulatory Body | No regulatory Body has taken any action. | Other | No regulatory Body has taken any action. | The Company had submitted the outcome of the Board Meeting held on May 12, 2025; however, due to a typographical error, certain details in the disclosure were incorrect. The Company subsequently revised and re-submitted the outcome on May 13, 2025 with corrected information. | | The company had erroneously mentioned the pre-preferential holding of one of the allottees, where no pre-preferential shares were held. | The Company submits that the error in the initial disclosure was purely typographical and inadvertent in nature. Upon identification, the Company promptly revised the outcome of the Board Meeting with correct details. | The lapse is procedural in nature and has been rectified promptly. The Company should ensure adequate verification mechanisms to avoid such errors in future disclosures. |
| 2 | Regulation 31 of SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015 | Securities and Exchange Board of India (Listing Obligations and Disclosure Requirements) Regulations, 2015 | Regulation 31 of SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015 | Delay in submission of shareholding pattern beyond the prescribed timeline. | Other Regulatory Body | No regulatory Body has taken any action. | Other | No regulatory Body has taken any action. | The Company had allotted 15,07,199 equity shares on May 12, 2025, resulting in a change exceeding 2% of the total paid-up share capital. As per the applicable provisions, the Company was required to file the updated shareholding pattern within 10 days of such change. However, the same was filed on May 22, 2025, after the expiry of the prescribed timeline. | | The Company has not complied with the timeline prescribed under Regulation 31(1)(c) of SEBI (LODR) Regulations, 2015 for submission of shareholding pattern. | The Company has taken necessary steps to strengthen its compliance mechanism and ensures that such delay will not recur. | This is a delay-based non-compliance. The Company should ensure strict adherence to prescribed timelines under SEBI (LODR) Regulations, 2015 to avoid recurrence. |
| 3 | SEBI Circular No. SEBI/HO/CFD/CMD/CIR/P/2020/242 dated December 09, 2020 | Securities and Exchange Board of India (Listing Obligations and Disclosure Requirements) Regulations, 2015 | SEBI Circular No. SEBI/HO/CFD/CMD/CIR/P/2020/242 dated December 09, 2020 | Non updation of e-voting details of Annual General Meeting (AGM) on CDSL portal | Other Regulatory Body | No regulatory Body has taken any action. | Other | No regulatory Body has taken any action. | Non-updation of e-voting details of Annual General Meeting on the CDSL portal. | | The Company did not update the e-voting details pertaining to its Annual General Meeting on the CDSL portal as required under the applicable e-voting framework. | The Company has taken necessary steps to strengthen its compliance mechanism and ensures that such instance will not recur. | This is a procedural non-compliance. The Company should ensure strict adherence to e-voting requirements and proper coordination with the e-voting service provider to avoid recurrence. |
Previous Report |
| Sr No | Compliance requirement (regulations/circulars/ guidelines including specific clauses) | Regulation Name/ SEBI Circular number* | Regulation Number/ circular dated | Deviations | Actions taken by | Name of Other Regulatory Body | Type of Action (Advisory/Clarification/Fine/Show Cause Notice/ Warning, etc.) | Details of other action taken | Details of violation | Fine Amount | Observations of the practicing Company secretary in the previous reports | Observations made in the secretarial compliance report for the year ended.(the years are to be mentioned) | Comments of the practicing company secretary on the actions taken by the listed entity. | Remedial actions, if any, taken by the listed entity | Management Response | Remarks |
| 1 | Regulation 34 of SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015 | Securities and Exchange Board of India (Listing Obligations and Disclosure Requirements) Regulations, 2015 | Regulation 34 of SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015 | Submission of Revised Annual Report for Financial Year 2023-24. | Other Regulatory Body | No regulatory Body has taken any action. | Other | No regulatory Body has taken any action. | Due to typographical error, the Company has filed the Revised Annual Report for Financial Year 2023-24. | | Certain inadvertent typographical error was noticed in the Annual Report of the Company for Financial Year 2023-24. Therefore, the Company has filed the Revised Annual Report for the Financial year 2023-24 on August 21, 2024. | For the year ended March 31, 2025 | The company has rectified the error in the revised filing of Annual Report. | Rectification of error by revised filing. | Upon notice, the company rectified the inadvertent error and filed Revised Annual Report for Financial Year 2023-24 on August 21, 2024. | |
Affirmation |
| Sr No | Regulation | Compliance status (Yes/No/NA) | Observations /Remarks by PCS* |
| 1 | Secretarial Standards:
The compliances of the listed entity are in accordance with the applicable Secretarial Standards (SS) issued by the Institute of Company Secretaries India (ICSI) | Yes | |
| 2 | Adoption and timely updation of the Policies |
| (a) | All applicable policies under SEBI Regulations are adopted
with the approval of board of directors of the listed entities | Yes | |
| (b) | All the policies are in conformity with SEBI Regulations and
has been reviewed & timely updated as per the
regulations/circulars/guidelines issued by SEBI | Yes | |
| 3 | Maintenance and disclosures on Website |
| (a) | The Listed entity is maintaining a functional website | Yes | |
| (b) | Timely dissemination of the documents/ information under
a separate section on the website | No | It was observed that the Company had not disseminated certain documents on its website as required under applicable provisions. On being intimated by BSE Limited, the Company has since completed the uploading of such documents and has initiated measures to strengthen its compliance processes. |
| (c) | Web-links provided in annual corporate governance reports
under Regulation 27(2) are accurate and specific which re-directs to the relevant document(s)/ section of the website | NA | The company is SME listed company, hence, Regulation 27(2) is exempted. |
| 4 | Disqualification of Director:
None of the Director of the Company are disqualified under
Section 164 of Companies Act, 2013 | Yes | |
| 5 | Details related to Subsidiaries of listed entities:
(a) Identification of material subsidiary companies
(b) Requirements with respect to disclosure of material as well as other subsidiaries | NA | The Company doesn�t have any Subsidiary Company. |
| 6 | Preservation of Documents:
The listed entity is preserving and maintaining records as prescribed under SEBI Regulations and disposal of records as per Policy of Preservation of Documents and Archival policy prescribed under SEBI LODR Regulations | Yes | |
| 7 | Performance Evaluation:
The listed entity has conducted performance evaluation of the
Board, Independent Directors and the Committees at the start
of every financial year as prescribed in SEBI Regulations | Yes | |
| 8 | Related Party Transactions |
| (a) | The listed entity has obtained prior approval of Audit
Committee for all Related party transactions | Yes | |
| (b) | In case no prior approval obtained, the listed entity shall
provide detailed reasons along with confirmation whether
the transactions were subsequently
approved/ratified/rejected by the Audit committee | NA | All related party transaction were done with prior approval of audit committee. |
| 9 | Disclosure of events or information:
The listed entity has provided all the required disclosure(s) under Regulation 30 along with Schedule III of SEBI LODR Regulations within the time limits prescribed thereunder | Yes | |
| 10 | Prohibition of Insider Trading:
The listed entity is in compliance with Regulation 3(5) & 3(6)
SEBI (Prohibition of Insider Trading) Regulations, 2015 | Yes | The SDD software installed by the company was corrupted due to some technical issue. So, the company has to install a new version of SDD software. Due to lack of proper back up, the company has made entries again in new SDD software to record the same, with current time stamp. |
| 11 | Actions taken by SEBI or Stock Exchange(s), if any:
No Actions taken against the listed entity/ its promoters/directors/ subsidiaries either by SEBI or by Stock Exchanges (including under the Standard Operating Procedures issued by SEBI through various circulars) under SEBI Regulations and circulars/ guidelines issued thereunder (or)
The actions taken against the listed entity/ its promoters/ directors/ subsidiaries either by SEBI or by Stock Exchanges are specified in the last column | Yes | |
| 12 | Resignation of statutory auditors from the listed entity or its material subsidiaries:
In case of resignation of statutory auditor from the listed entity or any of its material subsidiaries during the financial year, the listed entity and / or its material subsidiary(is) has / have complied with paragraph 6.1 and 6.2 of section V-D of chapter V of the Master Circular on compliance with the provisions of the LODR Regulations by listed entities | NA | As there is no resignation of Auditor, these clauses are not applicable |