SEBI/HO/IMD/IMD -RAC -3/P/CIR/2025/125

2 · 1.The 'Disclosure Document' has been divided into two sections viz. static and dynamic. The format of 'Disclosure Document' along with template is given in Annexure -I.

2 · 2.PMS to ensure that each parameter of 'Disclosure Document' begins on a fresh page. Only the page(s) containing change(s) in any parameter would need to be certified by independent Chartered Accountant and Principal Officer of the PMS. The same shall also be highlighted in the communication to clients.

2 · 3.The updated Disclosure Document Page(s) in which changes are carried out shall be simultaneously communicated to the clients, updated on the website of portfolio manager and filed with the Board within 7 working days from the date of change.

2 · 4.All other requirements, terms and conditions as enshrined in the SEBI (Portfolio Managers) Regulations, 2020 shall remain unchanged including the contents of the 'Disclosure Document' which have been specified in Regulation 22 (4) of SEBI (Portfolio Managers) Regulations, 2020 and their certification from an Independent Chartered Accountant as specified under Regulation 22 (5) of SEBI (Portfolio Managers) Regulations . 2020.

1 · Disclaimer Clause

2 · Definitions

3 · Description

4 · Penalties, pending litigation or proceedings, findings of inspection or investigation for which action may have been taken or initiated by any regulatory authority.

5 · Services Offered

6 · Risk factors

7 · Nature of expenses

8 · Taxation

111A · of the IT Act provides that short-term capital gains arising on sale of listed equity shares of a company or units of equity oriented fund or units of a business trust are chargeable to income tax at a concessional rate of 15% plus applicable surcharge and cess, provided such transactions are entered on a recognized stock exchange and are chargeable to Securities Transaction Tax (STT). This tax rate has been increased from 15% to 20% with effect from 23 July 2024. However, the above shall not be applicable to transaction undertaken on a recognized stock exchange located in any International Financial Services Centre and where the consideration for such transaction is paid or payable in foreign currency. Further, Section 48 provides that no deduction shall be allowed in respect of STT paid for the purpose of computing Capital Gains.

9 · Accounting policies

10 · Investors services

11 · Details of the diversification policy of the portfolio manager

12 · Client Representation

13 · Financial Performance

14 · Performance of Portfolio Manager

15 · Audit Observations

16 · Details of investments in the securities of related parties of the portfolio manager