DEPUTY GENERAL MANAGER ALTERNATIVE INVESTMENT FUND AND FOREIGN PORTFOLIO INVESTOR DEPARTMENT DIVISION OF POLI… — THE SECURITIES AND EXCHANGE BOARD OF INDIA ACT, 1992

DEPUTY GENERAL MANAGER ALTERNATIVE INVESTMENT FUND AND FOREIGN PORTFOLIO INVESTOR DEPARTMENT DIVISION OF POLICY AND DEVELOPMENT AFD/PoD/OW/2025/18380 July 09 , 2025 Shri. K. Rajagopal Sundaram Alternate Assets Limited , Sundaram Towers, 1 st and 2nd floor 46, Whites Road, Royapettah, Chennai, 600014 Dear Sir , Sub: Request for Informal Guidance by way of interpretive letter under the provisions of Securities and Exchange Board of India (Informal Guidance) Scheme, 2003 in connection with the provisions of Securities and Exchange Board of India (Alternative Investment Funds) Regulations, 2012 ("AIF Regulations") Ref: Your letter dated April 23, 2025 In the context of your letter under reference, you have, inter alia, stated that Sundaram Alternate Assets Limited ('the Applicant') is a SEBI registered Portfolio Manager bearing registration no. INP000006271 and also the Investment Manager for Sundaram Alternative Investment Trust, a Category III Alternative Investment Fund ("AIF") having registration no. IN/AIF3/16 -17/0291 and Sundaram Category II AIF having registration no. IN/AIF2/1718/0340 , and have sought an interpretive letter under the Securities and Exchange Board of India (Informal Guidance) Scheme , 2003 ("Informal Guidance Scheme") from SEBI in respect of the following query – Please clarify whether during the extended period, the close-ended Alternative Investment Fund is permitted only to liquidate its existing portfolio investments or allowed to make investments in portfolio companies . 2. Our Comments: The submissions made in your letter have been considered and without necessarily agreeing with your analysis, our views on the issues raised in your letter are as under: 2.1. In terms of Regulation 13(5) of AIF Regulations, extension of the tenure of the close