In an informal guidance to Apollo Tricoat Tubes Ltd., the SEBI by way of an interpretative letter under SEBI (informal guidance) scheme, 2003 has clarified that even an ex-promoter/ inactive promoter is required to comply with the trading-window closure rule under Prohibition of insider trading norms.
from taxmann.com News https://www.taxmann.com/topstories/222330000000019557/‘trading-window-closure’-rule-applies-equally-to-activein-active-promoters-sebi-clarifies.aspx
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