A promptly cured, bona fide omission of limited-review pages does not warrant a fine.

Calcom Vision Limited, whose shares are listed on BSE, filed its unaudited financial results for the quarter ended 31 December 2024 on 14 February 2025, before the stated due date of 16 February 2025.

The filing omitted two continuation pages of the limited review reports containing the Chartered Accountant’s full signature and UDIN.

After BSE raised a query on 18 February 2025, the company cured the omission that day.

BSE imposed a fine of ₹35,400 for non-compliance with Regulation 33 of the SEBI (LODR) Regulations and rejected the company’s waiver request.

The company appealed under Section 23L of the SCRA.

Whether the omission of two pages containing the Chartered Accountant’s signature and UDIN amounted to non-compliance warranting the fine under Regulation 33 of the SEBI (LODR) Regulations

Whether, in the circumstances, BSE’s fine and rejection of the waiver request should be set aside

Section 23L of the Securities Contracts (Regulation) Act, 1956 provides the appellate basis for challenging the impugned BSE communication/order.

Regulation 33 of the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015 requires listed entities to submit the prescribed financial results and accompanying review report within the specified period.

The Tribunal also applied a pragmatic approach to the facts, recognising that bona fide inadvertence and prompt rectification may justify setting aside a fine where the financial results are undisputed and there is no allegation that the Chartered Accountant disowned the reports.

The company had filed its results before the due date, and the omission was limited to two continuation pages of the limited review reports, rather than the financial results themselves.

The first pages bore the firm’s seal and the partner’s initials; the omitted pages contained the partner’s full signature and UDIN.

The Tribunal noted that the company supplied the missing pages on the same day BSE raised its query, that the financial results were undisputed, and that the Chartered Accountant had not disowned the reports.

On those facts, it accepted the explanation of bona fide inadvertence and considered a pragmatic approach appropriate.

It directed that the amount be refunded forthwith if already deposited; pending interlocutory applications were disposed of, with no order as to costs.