
Volume #17 | IssueNo. 308/2025 | January 2025

All in one, One in all!
Let us follow the path of “Amor Fati”( Meaning: Love of fate), by preparing to accept life as a package –😃😌😂🧐 – with resilience.
I received this as a New year wish from a very learned, dear friend of mine. Little did I know that my Mahakumbhmela experience would be exactly this – to accept the experience as a whole, as a package and not pick and choose. With a feeling of gratitude and blessedness, I am happy to share my learnings that can be applied universally to Life as a whole :
- Expect the unexpected – That’s the best way to be prepared for an event involving millions. If you think Sangam is just 15 minutes away, don’t be surprised if it takes you 3 hours. Sheer number of people and vehicles on the way, sudden barricades, one-ways, no-entries make it completely unpredictable. This is not to criticise the administration which according to me (what I saw) was doing its best given the huge surge.
- Go with the flow – Don’t get fixated or frustrated when things don’t turn out the way you want. Change will be the order of the day despite all planning. Take it as it comes. Enjoy every moment. See and experience whatever you can. There is an universe out there and you can never fully cover the spectacular hectares !
- Decide on the spot – In the corporate world there is Plan B or even C but in the Kumbhmela like event, just as in Life, there is no Plan B. Despite all the reading, following the videos, discussing with others and days of planning, a new unforeseen situation is likely to arise. Don’t question. Just accept and take on the spot decisions. There is no right or wrong. You are meant to go through it with resilience.
- Follow the leader – It helps if the travelling group just chooses a leader and allows him to decide. Consensus may not work all the time, given the unpredictable nature of the event. Quick decisions in the larger interest will be the need of the hour. Break-away groups will add to the chaos.
- Celebrate Inclusiveness and Diversity – This was evident all over. People of multiple faiths, varied beliefs, different customs and practices, costumes (sometimes none at all !), backgrounds, lifestyles and status – all coming together in awe and devotion, in search of spirituality and experience. Cutting across generations, nations, culture, language and food habits. Mahakumbh had something to offer to everyone that came. From the holy dip to spiritual discourses, blessings from the Gurus, meetings with sadhus to cultural extravaganza, it was a treat to the senses as a whole.
- Appearances belie – Never judge a book by its cover. It turned out that Shambunathji who drove us around in Prayagraj owned a few cars, was an ex-army man and earning solely to maintain an ashram that provides food and shelter to the needy. At 89, he stood straight as a ramrod, was unbelievably fit, alert, chirpy and full of life. He had deep knowledge in philosophy, religion and spirituality that he shared generously all along, which made us reflective and surrender to a higher force, amidst the chaotic environment.
Many more but it is best for each one of us to discover. Undoubtedly it was of an unimaginable scale with fantastic levels of planning and execution, subjected to high degree of expectations and scrutiny. Surely once in a lifetime celestial event. No one who visited the 2025 Mahakumbh would be around to share his experience in the next one which is to occur only 144 years later. Powerful. The world’s largest congregation of people for 44 days in one place, spreading the message of “ALL IN ONE, ONE IN ALL” !
Resonating with the Kumbh scale, the first issue of 2025 (308th Samhita) is also mega in many ways – glimpses of the Union Budget, 2025, impactful regulatory changes by RBI through multiple notifications, SEBI and IBBI updates AND introduction of new topics like ESG and IFSC. Pick what you want to read but there is an interconnectedness when viewed holistically through the economic lens.
For any previous issues of Samhita and the readers’ feedback, please visit http://www.sharadasc.com/resource-center/.
Budget Highlights FY-2025-26
Staying true to the theme of the current budget “Sabka Vikas”, our FM provided a much needed reprieve to the growing middle class by way of much awaited tax cuts through the Budget FY 2025-26. There are several other proposals that are bound to give the required fillip to the economy.
Refer the link below to read the highlights of the Budget.
MCA Update
MCA vide notification dated December 31, 2024 amended the Companies (Accounts) Rules, 2014 to extend the timeline for filing Form CSR 2 for the preceding FY 2023-2024. The timeline has been extended from December 31, 2024 to March 31, 2025.
RBI Updates
The investment in Debt Instruments by Non-Resident Investors is regulated through FEMA (Debt Instruments) Regulations, 2019 read with FEMA (Permissible Capital Accounts Transactions) Regulations, 2000 and FEMA (Borrowing and Lending) Regulations, 2018 and various circulars issued by RBI.
Vide notification dated January 07, 2025, the RBI has issued Master Direction on Non-resident Investment in Debt Instruments, which provides a comprehensive framework for foreign investments in debt instruments in India, contouring eligible investors, investment channels, and applicable guidelines for investments by Foreign Portfolio Investors, Non-Resident Indians, and Overseas Citizens of India. Please refer the link below for highlights of the said amendments.
(Open Highlights of RBI Amendments)
(Open RBI Notification dt January 07, 2025)
The FEMA (Deposit) Regulations, 2016 contain regulations relating to Deposits between Person Resident In India (PRII) and Person Resident Outside India (PROI). The term Deposit has been defined under these regulations to include deposit of money with a bank, company, proprietary concern, partnership firm, corporate body, trust or any other person. Further, the Schedules to the Regulations prescribe different types of bank accounts which can be opened, permissible debits and credits to such accounts, repatriation of funds etc, thereby providing guidelines for foreign exchange transactions between PRII and PROI.
RBI vide Notification dated January 14, 2025 has amended the Regulations and highlights of the same are as follows:
- Transfer between Repatriable Rupee Accounts: Transfer of funds between repatriable accounts is now permitted for all bona fide transactions. Earlier debits from repatriable rupee accounts such as NRE account could be made for specific purposes covered in the Regulations. With this amendment, debit can even be towards transfer to another repatriable rupee account such as the SNRR Account
- Opening of Special Non-Resident Rupee (SNRR) Accounts outside India: SNRR account can now be opened by Person outside India (having business interest in India) with an authorized dealer in India or its branch outside India for the purposes of entering into permissible current and capital account transactions with a Person Resident in India.
Prior to the amendment, the SNRR account could be opened only with branches of AD Bank in India and the transactions which could be undertaken using the SNRR account was limited to bonafide transactions in rupees. A list of transactions in INR was also specified in the regulations. Pursuant to the amendment, the scope has been broadened with permitted usage for :
a) putting through permissible current and capital account transactions with a person resident in India and
b) putting through any transaction with a person resident outside India.
FAQs have also been released by RBI on ‘Accounts in India by non-residents’ and ‘SNRR Accounts’.
These amendments are a move towards encouraging the use of Rupee in cross border transactions.
Pursuant to the above amendment, IFSCA vide notification dated January 29, 2025 has notified units in IFSC that SNRR account can now be used for all business-related transactions of the IFSC unit outside IFSC. Hitherto it could be used only for certain business related transactions outside IFSC such as administrative expenses in INR outside IFSC, INR amount from sale of scrap, government incentives in INR, etc. The IFSCA has also directed banking units in IFSC to facilitate internet banking facilities for SNRR accounts of the IFSC Units.
(Open RBI Notification dt January 14, 2025)
(Open FAQs on Accounts in India by Non-Residents)
(Open FAQs on SNRR Accounts)
(Open IFSCA Circular dt January 29, 2025)
RBI vide Notification dated January 14, 2025 has amended the Foreign Exchange Management (Mode of Payment and Reporting of Non-Debt Instruments) Regulations, 2019. Pursuant to this, investment in Equity Instruments and Convertible note can be made not only through inward remittances through banking channels but by using funds held in repatriable foreign currency or rupee accounts as referred to under FEMA (Deposit) Regulations, 2016. Earlier the Regulations permitted such investments only through inward remittance from abroad through banking channels or out of funds held in NRE, FCNR or Escrow Accounts.
Further, an explanation has been added in the Regulations to clarify that ‘Banking Channels’ include Rupee Vostro Accounts and Special Rupee Vostro Accounts as permitted under the Foreign Exchange Management (Deposit) Regulations, 2016.
The following Schedules and Regulation have been amended in light of the above:
- Schedule I- Purchase or sale of equity instruments of an Indian company by a person resident outside India
- Schedule II- Foreign Portfolio Investors
- Schedule VI – Limited Liability Partnerships
- Schedule VII – Foreign Venture Capital Investors
- Schedule VIII – Investment Vehicles
- Schedule X – Indian Depository Receipts
- Regulation 3.2- Issue of Convertible Notes by an Indian start-up company
RBI vide Notification dated January 14, 2025 has amended the Foreign Exchange Management (Foreign Currency Accounts by a person resident in India) Regulations, 2015 to include the following provisions after existing Regulation 5(C):
- Exporters can now open and maintain Foreign Currency Accounts outside India, for realizing full export value and advance remittance received by the exporter towards export of goods or services.
- Funds in this account may be utilised for:
- Paying for imports into India or
- Repatriation into India within the next month from the date of receipt of the funds, adjusting for forward commitments. This is subject to fulfilment of realization and repatriation requirements under FEMA (Export of Goods and Services) Regulations, 2015.
This has been considered as a move to strengthen the value of Rupee, aiding Exporters.
SEBI Updates
Vide notification dated December 12, 2024, SEBI had notified major amendments to SEBI LODR. In furtherance to the same, SEBI has issued a circular on December 31, 2024 to give effect to certain recommendations of the Expert Committee and carry out consequential changes to the provisions of SEBI Master Circular dated November 11, 2024, on compliance with the LODR Regulations. Highlights of the same are as follows:
- Integrated filing- this has been introduced for Governance and Financial related periodic filings. The same is applicable for filings to be done for quarter ended December 31, 2024 and thereafter.
- Secretarial Auditor
– Disqualifications for appointment or continuation of a Secretarial Auditor of the listed entity has been prescribed.
– Services that a Secretarial Auditor cannot render to the listed entity have been specified. Internal audit, design and implementation of compliance management system, management services etc have been prescribed under services that shall not be rendered. - Guidelines for disclosure of Employee Benefit Scheme related documents has been prescribed which includes uploading of scheme document in website, mandatory disclosure of minimum information, Board approval for redacting information from the document and justification for the same.
- Single Filing System: Single filing of statement on redressal of investor grievances, corporate governance report, reconciliation of share capital audit report and disclosure of voting results has already been implemented by BSE & NSE. Details of other filings to be brought under the system shall be communicated by Stock Exchanges.
- System driven disclosure of certain filings: Stock Exchanges shall specify the process, procedure and timelines for system driven disclosure w.r.t. shareholding pattern under Regulation 31(1)(b) & new ratings or revision in the ratings under Regulation 30(6) r/w sub-para 3 of para A of part A of schedule III of LODR.
- Changes to the Master Circular which covers:
– The formats for corporate governance report, financial results, statement of deviation, RPT etc. deleted in view of new Integrated Filing
– Fines introduced for non-compliance with the timelines specified for reclassification of promoter / promoter group entity as public
– Changes to the provisions relating to Group Governance.
– Annexure 18A w.r.t. timelines for disclosure of material events /information substituted by Annexure 5 of this circular.
Vide circular dated January 10, 2025, SEBI has delegated the power to waive or reduce the interest levied in respect of cases where recovery proceedings initiated for failure to pay penalty, to the following Competent Authority:
- Panel of Executive Directors of SEBI, where the amount of interest sought to be waived or reduced is less than Rs. 2 crores;
- Panel of Whole-time Members, in other cases.
The procedure for application for waiver or reduction of interest has been prescribed in the Circular.
SEBI vide circular dated January 17, 2025 has relaxed the timeline for review of ESG rating pursuant to publication of BRSR as part of ease of doing business measures.
ESG Rating Providers (ERPs) are independent rating agencies registered with SEBI. ERPs provide unbiased ratings to entities based on environmental, social and governance (ESG) parameters. Few ESG Rating providers registered with SEBI are:
- CARE ESG RATINGS LIMITED
- CRISIL ESG RATINGS & ANALYTICS LIMITED
- ICRA ESG RATINGS LIMITED
To promote ease of doing business, SEBI has relaxed the timeline for reviewing ESG ratings following the publication of the BRSR. The revised guideline stipulates that ERPs must review ESG ratings immediately upon the occurrence or announcement of any material developments, but no later than 10 days from the event. However, the review of ESG ratings following the publication of the BRSR by the rated entity must be carried out immediately, and in no case later than 45 days from the BRSR publication.
Earlier the publication of BRSR was considered as a Material Development which had to be reviewed by the ERPs within 10 days.
SEBI vide Circular dated December 30, 2024 has allowed subscription to the issue of non-convertible securities during trading window closure period in terms of PIT Regulations. This is in addition to conversion of warrants or debentures, rights issue, further public issue, preferential allotment or tendering of shares in a buy-back offer, open offer, delisting offer etc. which are allowed for trading during such period as per existing regulations.
IFSC Update
Vide circular dated December 02, 2024, International Financial Services Centre Authority (IFSCA) had mandated Regulated Entities to align their Complaint Handling and Grievance Redressal w.e.f January 15, 2025. Pursuant to the representation from Regulated Entities citing operational challenges related to the implementation of the said circular, IFSCA has extended the timeline for implementation of the circular to 1st April 2025.
IBBI Updates
The IBBI has issued a circular dated January 09, 2025 further extending the deadline from December 31, 2024 to March 31, 2025 for filing various forms related to voluntary liquidation processes under the IBC Code, 2016. Initially set by Circular No. IBBI/LIQ/74/2024 on June 28, 2024, it introduced an online platform to submit various forms to IBBI instead of through email communication. These forms pertain to details of Corporate Debtor, Meetings of Contributories, dissolution application etc.
Vide circular dated October 29, 2024, the IBBI had introduced a centralized electronic listing and auction platform for the sale of assets under the liquidation process. IBBI has collaborated with the Indian Banks’ Association (IBA) to facilitate the auction of assets through the eBKray platform which is in existence since last 5 years.
Based on the positive response received for the platform, IBBI vide circular dated January 10, 2025 has mandated the use of eBKray Auction Platform for Liquidation Processes w.e.f April 01, 2025. It is further directed that listing of unsold assets in all ongoing liquidation cases shall be completed by March 31, 2025.
Information Utilities act as a Repository for all financial information received by it from financial or operational creditors or debtors. It is one of the key pillars of the insolvency and bankruptcy resolution ecosystem.
Vide notification dated January 29, 2025, the IBBI has amended the Guidelines for Technical Standards for the Performance of core services and other services under the Insolvency and Bankruptcy Board of India (Information Utilities) Regulations, 2017. Highlights of the same are as follows:
- An Information Utility (IU) shall make use of PAN for verification of identity of user during registration process or any other Officially Valid Documents (“OVD”) for which the verification facility is enabled to the IU by the relevant authority who issues such ID.
- IU shall obtain a Sub – Authentication User Agency (AUA) license from UIDAI to make use of facility of demographic authentication of user from UIDAI database.
- Before filing an application to initiate CIRP under section 7 or 9 of the Code, as the case may be, the submitter shall file the information of default with the IU, and the IU shall process the information for the purpose of issuing a Record of Default in accordance with Regulation 21.
- Enables filing of supporting documents to Form C (Information relating to Debt) at any time instead of earlier requirement to submit them along with Form C provided it meets certain conditions w.r.t security, file format, digital signing etc.
- Guidelines for IU to mark the status of authentication of submitted debt information party wise and for each record, both in cases where default has been reported and where default has not been reported.
- Mandate to preserve details of recipient e-mail address, body of the mail, delivery status, time stamp and any other details, of all the authentication invitation e-mails, generated by the system as per Regulation 21 in the database.
IBBI vide notification dated January 28, 2025 has amended the following provisions under the IBBI (Model Bye-Laws and Governing Board of Insolvency Professional Agencies) Regulations, 2016:
- An application for issue or renewal of an authorisation for assignment under clause 12 of Para VI of Schedule to Regulations can be made at any time before the date of expiry of the authorisation, but not earlier than 90 days before the date of expiry of the authorisation as against existing timeline of 45 days.
- The authorisation shall be deemed to have been issued or renewed, as the case may be, by the Agency if the authorisation for assignment is not issued, renewed or rejected by the Agency within 90 days of the date of receipt of application as against 15 days’ timeline.
Vide notification dated January 28, 2025 the IBBI has amended the Insolvency and Bankruptcy Board of India (Liquidation Process) Regulations, 2016. Highlights of the same are as follows:
- Liquidators are now required to submit final report along with Form H even for cases where a scheme of compromise or arrangement under Section 230 of the Companies Act, 2013 is approved. Earlier such report was required to be submitted where the entity was sold as a going concern.
- The reference to ‘Public Accounts of India’ for Opening of Corporate Liquidation Account has been omitted. This is line with practical scenarios where opening of such account with a scheduled bank has proven to be efficient in expeditious claim processing and overall fund management.
- Regulation 47B has been inserted to introduce filing of electronic forms by Insolvency Professional with specified timelines. Late filing would attract additional fee of Rs. 500 per Form for each calendar month of delay after the date notified for filing.
- Amendments introduced to Schedule I (Mode of Sale) to streamline the process for auction of assets:
- Facilitates wider participation in auction process by changing the timeline from 14 days to about 30 days
- Liquidator is now required to provide the prospective bidder, access of the assets under auction to facilitate their inspection and due diligence
- All prospective bidders must submit necessary documents, including a declaration of eligibility under Section 29A in specified formats
- The liquidator is required to verify the eligibility of the highest bidder (H1) within 3 days of the auction and consult the Stakeholder Consultation Committee (SCC) on the auction results. If H1 is ineligible, next highest bidder (H2) may be considered subject to consultation of SCC.
BBI vide notification dated January 28, 2025 has amended the Insolvency and Bankruptcy Board of India (Voluntary Liquidation Process) Regulations, 2017. The amendments are similar to the ones introduced under Liquidation Process Regulations summarised above. Highlights are as follows:
- The reference to ‘Public Accounts of India’ for Opening of Corporate Liquidation Account has been omitted. This is line with practical scenarios where opening of such account with scheduled bank has proven to be efficient in expeditious claim processing and overall fund management.
- Regulation 41A introduced for electronic filing of forms by the liquidator with specified timelines as below. Late filing whether by way of correction, updation or otherwise will attract fee of Rs. 500 per form for each calendar month of delay after the specified timeline.
Form No. | Period Covered and Scope | Timeline |
VL 1 | This includes details of the corporate person, details of the voluntary liquidation process, etc. | On or before the 10th day of the second month after the public announcement. |
VL 2 | Details of the meetings of contributories with the reasons for delay in the process, details of replacement of liquidator (if any), etc. | On or before the 10th day of the subsequent month, after the meeting of contributories |
VL 3 | Details of dissolution application, details of unclaimed proceeds, details of realisation and distribution made to stakeholders, details of pending litigations, detection of fraud | On or before the 10th day of the subsequent month, after submission of the dissolution application of the corporate person or withdrawal/suspension application for the voluntary liquidation process, to the Adjudicating Authority. |
VL 4 | Details of order for dissolution: This includes details of the distribution of proceeds, receipts and payments, etc. | On or before the 14th day of passing of the order for dissolution of the corporate person, or withdrawal / suspension of the voluntary liquidation process. |
- Format for providing ‘Details of Stakeholders entitled to Unclaimed Dividends or Undistributed Proceed’ in Form G (Deposit of Unclaimed Dividends and/or Undistributed Proceeds) has been substituted.
ESG Updates
The International Auditing and Assurance Standards Board (IAASB) and the International Ethics Standards Board for Accountants (IESBA) have jointly introduced new sustainability-related standards (The ISSA 5000 and IESSA) to enhance trust and transparency in sustainability reporting and assurance.
While the ISSA 5000 provides a principle-based framework for conducting credible sustainability assurance, IESSA lays down foundation for ethical mindset and trust. These two standards have a framework neutral approach, enabling their application to sustainability information prepared under any appropriate reporting framework.
The common goals of IAASB and IESBA behind collaboration for effective implementation of the said standards include supporting informed stakeholder decisions with independently assured data and mitigating risks of fraud, including greenwashing, and non-compliance with laws and regulations.
These standards are effective from December 15, 2026 with early adoption encouraged.
The Mahakumbh in Prayagraj is integrating environmental protection with culture and spirituality. Vide Press Release dt January 07, 2025 informs about initiatives such as the launch of Swachhata Rath Yatra involving government agencies, public representatives, and local citizens in promoting cleanliness and public participation.
On January 31, the city hosted the Green Mahakumbh, a national event under the Gyan Mahakumbh series, organized by Shiksha Sanskriti Utthan Nyas. The event featured discussions on nature, environment, water, and cleanliness, with experts sharing insights on preserving ecological balance and raising awareness among visitors.
The Miyawaki technique, developed by Japanese botanist Akira Miyawaki in the 1970s, is a method for creating dense, fast-growing forests in limited spaces. By planting native species close together, this technique accelerates growth, improves soil quality, enhances biodiversity, and absorbs more carbon than traditional forests.
The Prayagraj Municipal Corporation is creating dense urban forests using the Miyawaki Technique to improve the city’s environment. Over the past two years, they have planted trees on more than 55,800 square meters across 10 locations. Key projects include 1.2 lakh trees of 63 species in the Naini industrial area and 27,000 trees in Baswar, transforming a former garbage dump. These forests reduce pollution, improve air quality, prevent soil erosion, and boost biodiversity. Experts highlight that Miyawaki forests can lower temperatures by 4-7°C, improve soil fertility, and provide habitats for wildlife. The project includes a diverse mix of fruit-bearing, medicinal, ornamental, and native species like mango, neem, peepal, hibiscus, and bamboo.
The Bharat Cleantech Manufacturing Platform was launched at the Bharat Climate Forum 2025 in New Delhi to boost India’s cleantech sectors, including solar, wind, hydrogen, and battery storage. It was stated that Product Linked Incentives (PLIs) should only serve as a starting point and emphasis should be on self-sustainability in the clean energy sectors. The platform aims to foster innovation, collaboration, financing, and resource-sharing among Indian firms, making India a global leader in sustainability.
Feburary 2025

Quote of the day
"Times flies but memories last"
Disclaimer: The contents of this Newsletter are only a summary and has not dealt with any issue in detail. Any action taken or proposed to be taken must be in consultation with professionals and not merely based on the articles / news updates. S. C. Sharada & Associates disclaims all liability on action taken without professional advice.