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IPO of Shares through

Book Building
- By Mahavir Lunawat

Corporate Secretarial Study Circle,

Sewree, July 4, 2007


Basics & Key Concepts

Regulatory Framework
Process, Parties & Documents
Green Shoe Option
RPL IPO A Glimpse of the Success Story

Basics & Key Concepts

Different Types of Issues :

Basics & Key Concepts

Book Building :
Public Offer of securities through book
building mechanism is designed to
ascertain demand for the securities at
various price levels within a price-band to
facilitate discovery of the Issue Price.
Auction of securities !

Basics & Key Concepts

Book Building Benefits :

Discovery of Realistic Price

Determination of price at a date close to the date of opening of public offer

Proper Allocation : Main benefit from book building is to determine the

realistic price for shares and demand level from syndicate members in order
to adjust pricing and allocation decision.

Ascertainment of level of subscription : one need not wait till the issue is
closed to know whether the minimum level of subscription is achieved.

Overall Improvement over Fixed-Price IPOs : Unlike in the fixed-price

IPOs, securities, if routed through book building, can be issued at a realistic
price that is fixed according to demand, and

Other Advantages : Book building also has other advantages like fast
completion of issue process, faster collection of payment, etc.

Basics & Key Concepts

Red Herring Prospectus : Prospectus without issue
price and size of the issue.
Price Band : The investors are informed of the price
band for bidding (floor price and cap price). The cap
price should not be more than 20% of the floor price.
Price band can be revised by +/- 20% of floor
The investors can bid at any price in multiples of Re.1
within the price band.
Margin Amount : The money collected along with the
application is referred to as margin amount. QIBs have to
pay 10% margin only.

Basics & Key Concepts

Minimum Lot Size :
Amount payable at the floor price and cap price to be in the range
of Rs. 5000 to Rs. 7000.
Bids should be for the minimum lot size or multiples there of.

Bidding Centers :
Bidding centers are essentially broking outfits associated with the
Book Running Lead Managers / Syndicate Members.
They have on-line connectivity to either or both BSE and NSE.
Investors desirous of participating in the bidding process should
submit their bid cum application forms to any of the designated
bidding centers / collection centres.

Basics & Key Concepts

Revision of Bids :
Book building process provides for revision of the options both
in respect of the quantum of shares and / or the bid price to all
categories of investors.
The investors can revise their bids any number of times before the
closure of the issue.
For every revision they are required to go to the same bidding
center where the original bid earlier revision was registered along
with the transaction registration slip issued by the bidding center.
The investors are required to use the revision bid form.
If there is an upward revision (in terms of shares and / or price) the
investors are required to pay the differential amount along with the
revised bid. In case of revising the bid lower the registrars will take
care of the refund at the time of processing.

Basics & Key Concepts

Cut-off Price : Retail individual bidders can bid at cut off
price, in which case, they need not indicate the specific price
and yet become eligible to be considered for allotment
irrespective of the issue price finally decided through the price
discovery process. They must pay the margin amount calculated
at the ceiling price.
Escrow Account : Margin money deposited. Upon
determination of final price, the money is transferred to public
issue a/c to the extent of shares to be issued. Balance is
Basis of Allotment : The allotment is made on proportionate
basis. The number of shares allotted is in minimum lot
prescribed and thereafter in multiples of 1 share. Where the
shares available for allotment to any category is less than the
minimum lot, the successful investors in that category are
identified on the basis of drawal of lots.

IPO - Regulatory Framework

SEBI (DIP) Guidelines, 2000
Securities Contracts (Regulation) Act, 1956 and Rules,
Listing Agreement and Stock Exchanges Regulations
Companies Act, 1956
Companies (Issue of Share Certificates) Rules, 1960
Depositories Act, 1996
Stamp Act
Foreign Exchange Management Act, 1999 and
Regulations made thereunder

DIP - Eligibility

Net tangible assets of at least Rs. 3 crore in each of the preceding 3 full years, of
which not more than 50% is held in monetary assets: If more than 50% of the net
tangible assets are held in monetary assets, firm commitments to deploy such
excess monetary assets in its business/project;
Track record of distributable profits u/s 205 of Companies Act at least for 3 out of
preceding 5 years;
Pre issue NWof not less than Rs. 1 crore in each of the preceding 3 full years;
In case of change of name within the last one year, atleast 50% of the revenue for
the preceding 1 full year is earned from the activity suggested by the new name;
aggregate of he proposed issue and all previous issues in the same financial year
does not exceed 5 times its pre issue net worth as per last audited accounts.
(i) Issue is made through book-building, with atleast 50% of the net offer to
public being allotted to QIBs, or The project has at least 15% participation by
FIs / Scheduled Commercial Banks, of which at least 10% comes from the
Appraiser(s) + atleast 10% of the issue size to be allotted to QIBs, otherwise the
issue will fail;
(ii) The minimum post-issue face value capital shall be Rs. 10 crore, or
compulsory market-making for at least 2 years from the date of listing.

DIP Other Conditions

Companies barred not to issue shares
No Partly Paid-up Shares : Partly paid up shares to be
made fully paid or forfeited in the manner specified, before
the public offering.
Additional conditions for Unlisted Companies :
Prospective allottees to be not less than 1000.
No outstanding convertible securities or other right
which would entitle the existing promoters or
shareholders any option to receive equity shares after
public offer.
IPO Grading (Effective April 30, 2007)
Grading to be obtained from at least 1 rating agency
All the grades obtained to be disclcosed in the offer documents
Expenses to be incurred by the company.

DIP Other Imp Provisions

Filing of Offer Document
Draft offer doc to be filed with SEBI at least 30 days
prior to filing of Prospectus with ROC
SEBI may specify changes / issue observations within
30 days (additional 15 days from further clarifications)

Filing on Book-built Issue

DRHP is filed with SEBI
After taking into account SEBI observations, RHP is
filed with ROC, at least 3 days before the bid opens
Post book-building process and finalisation of price,
Prospects is filed with SEBI.

DIP Promoters Contribution

Promoters Contribution
Not less than 20% of the post issue capital
Promoters to bring in full contribution (up to
Rs. 100 crore) at least 1 day prior to the
opening of the Issue.
Contribution in excess of Rs.100 crore, to be
brought in advance of the calls made on public
Definition of Promoter Clause 6.8.3(m)
Explanation increased relevance

DIP Promoters Contribution

Shares ineligible for computation of 20%
Shares acquired in the preceding 3 years, if
Acquired for consideration other than cash / assets revaluation
Resulting from bonus out of revaluation reserve

Shares acquired during preceding 1 year, at a price lower than

the issue price. Exceptions (1) if the promoter brings the
differential money (2) inter-se transfer, if the transferor had
acquired shares more than 1 year before / at a price not less
than the issue price.
Pledged securities held by promoters
Securities in respect of which no specific written consent

Public issue by a company listed for at least 3 years &
has a track record of dividend payment for at least 3
immediate preceding yrs.
Company having no identifiable promoter
Rights issue

DIP Lock-in
Minimum Promoters Contribution of 20% - for 3
Years Excess Promoters Contribution For 1 Year.
(From the date of allotment or Commencement of
Commercial Production, whichever is later)
Pre-Issue Share Capital For 1 year (From the date of
allotment in the public issue)
Transfers during the lock-in period permitted, subject to
Pledge - only with banks / FIs as collateral against
loans, if the pledge forms one of the terms of the loan
Lock in to be reduced by the period during which
shares are lent under green shoe stabilising mechanism

DIP Bidding related

Bidding Period : Opening / Closing Dates : Bid to be open for atleast

3 working days and not more than 7 working days, which may be
extended to 10 working days, in case the price band is revised.
Revision of price Band : Any revision in the price band to be widely
disseminated by informing the stock exchanges, issuing press release
and indicating on the website / terminals of the syndicate members.
Placing :
Individual as well as QIBs to place their bids only through the designated
RII may bid at cut off price instead of writing the specific bid prices in the
bid forms.
Bidding is permitted only if an electronically linked transparent facility is

Revision : Investors shall have the right to revise their bids provided that
QIBs shall not be allowed to withdraw their bids after closure of bidding.

DIP Other Imp Provisions

Denomination of Shares : In case of IPO by unlisted
If the issue price is Rs. 500/- or more the face value can be less
than Rs. 10/- per share but in no case be less than Re. 1/-.
If the issue price is less than Rs. 500/- face value has to be Rs. 10/per share.
At any given time there can be only one denomination for the
shares of the company.
Denomination to be in conformity with the Memorandum and
Articles of Association.

Time limit for allotment and interest for delay: As far as

possible allotment of securities offered to public shall be made
within 15 days of the closure of public issue. The company
would need to pay interest @15% pa, if the allotment letters /
refund orders are not despatched within the aforesaid period.

DIP Other Imp Provisions

Time limit for making calls (or forfeiture) : The securities
issued to be made fully paid (or may be forfeited) within a
period of 12 months from the date of allotment. If the issue size
is above Rs.500 crores and use of issue proceeds is being
monitored by a monitoring agency it shall not be necessary to
call the entire subscription money within 12 months.
Despatch of Refund Orders / Certificates : In case where
electronic credit is not possible, refund orders of value over
Rs.1,500/- and share / debenture certificates to be sent by
registered Post only
Disclosure of further issue of capital : Any further issue
(bonus/rights/pref.allotment etc.) to be made between filing of
offer doc to SEBI till listing of shares/refund of money, to be
disclosed in the draft offer doc.

DIP Issue Allocation

Issue Allocation

SCRR Minimum Offer to Public

Rule 19(2)(b) of the SC(R)R, makes it mandatory to offer at least

25% of the shares to public. However, if the following conditions
are satisfied, then 10% only needs to be offered to public

Minimum 20 lakh securities (excluding reservations, firm allotment

and promoters contribution) are offered to public;
Minimum size of offer to public is at least Rs. 100 crore; and
The issue is being made only through book building method with
allocation of 60% of the issue size to the qualified institutional buyers
(QIBs) as specified by SEBI.

Any subscription by the Central Government, a state government,

development or investment agency of a state government or a
financial institution, as specifically mentioned, do not form part of
minimum public shareholding (10% or 25% as the case may be).
Infrastructure Companies are Exempt from this requirement.

Stock Exchanges Regulations

Stock Exchanges have stipulated minimum threshold for the purpose of listing
of IPOs, which is as under :
Minimum issue size - Rs. 10 crores
Minimum post-issue paid up capital - Rs. 20 crores
Minimum market capitalization Rs. 25 crores

Post-issue paid up capital should be not less than Rs. 10 crores.
Capitalisation i.e. Issue price multiplied by post issue number of shares should
not be less than Rs. 25 crores
3 year track record
Project / activity plan must be approved by FI.
Other Stock Exchanges not having screen based trading Minimum paid-up
capital of Rs. 3 crores.
OTCEI : Minimum paid-up capital of Rs. 30 lakh and the minimum offer to the
public should be 25% of the issued capital or Rs. 20 lakh worth of shares in face
value, whichever is higher.

Listing Agreement Clause 24

Pre-issue Formalities :

To obtain in-principle approval for listing of the new securities

To make true, fair and adequate disclosure in the offer documents
To get the offer documents vetted by SEBI
To submit to the SE a) copy of the acknowledgment card so vetted
by SEBI and b) compliance certificate from merchant banker
reporting positive compliance of guidelines on disclosure and
investor protection.
In the event of non-submission of the above documents or
withdrawal of the acknowledgement card by SEBI at any time
before grant of permission for listing, the securities shall not be
eligible for listing and the company shall become liable to refund
the subscription monies immediately.

Listing Agreement Clause 42

Issuer to deposit with DSE 1% of the amount of
securities offered.
50% of the above security deposit should be in
cash. This is limited to Rs. 3 crores.
The balance can be provided by way of a bank
Security deposit is refunded to the issuer after it
obtains no-objection certificate from SEBI.

Companies Act

Section 2 (26) definition of prospectus- any document described or

issued as a prospectus and includes any notice, circular or
advertisement or other document inviting deposits from the public or
inviting offers from the public for the subscription or purchase of any
shares in, or debentures of a body corporate
Section 60
Prospectus needs to be delivered to ROC for registration before it is
issued to public.
Prospectus needs to be issued within 90 days from regisdtration.

Section 60B - information memorandum- red herring prospectus to

be filed with ROC at least three days prior to opening of offer
Section 61 - terms and conditions mentioned in prospectus cannot be
varied unless the approval of the shareholders in general meeting is

Companies Act
Section 62- civil liability for mis-statements in the
prospectus (damages)
Section 63- criminal liability for mis-statements in the
prospectus (Up to 2 yrs &/or Rs.50,000/-).
Section 65- penalty for fraudulently inducing persons to
invest money (Up to 5 yrs &/or Rs.1,00,000/-)
Section 68B- Issue of securities in demat mode, if the Issue
size exceeds Rs.10 cr.
Section 69- If minimum subscription not received within
120 days from the date of the first issue of prospectus, the
monies to be refunded to applicants without interest. If
monies refunded after 130 days from the date of the first
issue of prospectus, then interest shall be payable at 6%
per annum
Section 75 : Filing of return of allotment within 30 days of
Section 113 read with Rules thereunder : issue of shares
Section 628 : Penalty for false statement (Up to 2 yrs &
fine Not compoundable)

OCBs are de-recognised as a class of investors
FIIs investment limits
Single FII : Up to 10% of the post-issue capital
Aggregate : Up to 24% of the post issue capital; can be
increased up to sectoral limit, with the approval of
Board of Directors followed by shareholders approval
by a special resolution
Single sub-account : Up to 10% of the post-issue
capital; 5% in case the sub-account is a foreign
corporate or an individual

Reporting to RBI within 30 days

Overseas Securities Law

Overseas securities law to be checked, as NRIs/FIIs
residing abroad invest in an IPO

Section 5 of Securities Act, 1933 No offer may be

made public unless a registration statement has been
filed with SEC or the offer is exempt.
Placement of securities only to qualified institutional
buyers under Rule 144A is exempt from registration

Rule 144A : permits financial institutions with more

than $100 mn. invested in securities to trade
unregistered privately placed securities among
themselves freely without re-sale conditions
Appropriate disclosures should be made in the offer
document (international wrap), website and other
notices/circulars etc. disseminated to public

Process, Parties & Documents

Application Form


Bidding Center


Registration of bids

Electronic Data Capture

Stamping / Franking
and Dispatch

Allotment Letters/
Refund Orders /


Data Analysis
Printing of Refund Orders

Preparation of Basis
Generation and Creation of Allotment as per basis,

Key Players

Book Running Lead Managers
Syndicate Members
Bidding Centers
Escrow Bankers
Legal Advisors (Indian as well as overseas)
Printers and Advertisement Agencies
Compliance Officer

With the support of


The stock exchanges

The Depositories
The Postal System

Categories of Investors

Qualified Institutional Investors (QIBs)

Non Institutional Investors (HNIs)
Retail Individual Investors

Additionally there can be reservations for


Employees / Directors of the issuer / promoter companies

Existing shareholders of the issuer / promoter companies

Role of the Bidding Centers

Accept bid-cum-application forms from
investors along with cheque/ demand draft
Register bids (for all options) through online / off-line terminals
Generate transaction registration slips
(TRS) for each of the options
Lodge bid-cum-applications with an escrow

Role of the Escrow Bankers

Receive / collect bid-cum-application forms from the bidding
Sort them according to the category (employees, shareholders,
NRIs, Public)
Affix unique running bank serial numbers for each of the
application and the accompanying payment instruments
Prepare bank schedules giving details of bank serial number,
application number, name of the investor, amount collected,
cheque number, paying bank and branch name
Schedules are to be serially numbered and totalled
Send cheques/drafts in clearing
Account for cheque returns

Role of the Escrow Bankers

Send provisional collection certificates on or before the 3rd
day from the date of closure.
Reconcile and send final certificates (category-wise) in
respect of all the branches
Prepare and forward cheque return statements
Transfer funds to Public Issue / Offer and refund order
Honour refund orders after matching the same with master
Make available periodic reconciliation of the refund

Role of the Registrars to the Issue

Receive / collect bid-cum-application forms from the escrow
collection branches along with the schedule on a daily basis
Prepare 3 day report for submission o SEBI
Enter details of applications received lot-wise (Lot Register)
Prepare bunches of uniform no. of applications
Capture the data from the applications
Print check list and verify the data entered with applications
Update corrections and verify correction check lists
Send beneficiary account details to the depositories for
Obtain demographic details of valid beneficiary accounts

Role of the Registrars to the Issue

Match application details (names of the applicants) with the
depository details
Print mismatches and manually identify cases where discretion
is taken
Enter cheque return details and mark them in as such in the data
Reconcile amount collected as per application with the schedule
Seek clarifications from the bankers in respect of mismatches
Do a branch wise reconciliation of the amount received as per
data captured at their end and as per bank final certificate
Reconcile amount collected as per application with the schedule;
Seek clarifications from the bankers in respect of mismatches
Identify applications to be rejected on technical grounds
Verify the identified applications physically

Grounds of technical rejections

PAN No. Not Provided in Applications for Rs.
50,000 or more
HNIs / QIBs applying at cut-off
Applications not bid but banked
Applications bid but not banked
DP ID / Client ID not provided
Multiple bids
Bids by minors
Bids outside the price band

Role of the Registrars to the Issue

Confirm rejections after due scrutiny
Reconcile the data captured with the Book file received through
the BRLMs
Identify and generate summary of matched and unmatched
Inform BRLMs and the Issuer of the number, nature of the
technical rejections & obtain their decision
Prepare proceedings of the interaction with the BRLMs and the
Issuer on various matters
Prepare category-wise basis of allotment including proposed
ratio for various categories (in the event of over-subscription)
Submit the same to the designated stock exchange for their
approval and obtain the approval of the stock exchange
including lucky numbers for various categories where ratio has
been proposed

Role of the Registrars to the Issue

Generate bank-wise controls of the amount collected, amount to be

transferred to public issue/offer account and refund account
Give written instructions jointly with the lead managers to the bankers
Print can-cum-refund orders and arrange for despatch of the same
within 2 working days of the approval of the basis by the designated
stock exchange
Upload files for execution of the corporate action for credits to
successful allottees and for lock-in of pre issue capital
Submit despatch certificate to Stock Exchanges
Submit confirmation of electronic credits from the depositories for the
Provide documents/ reports required for listing of the securities issued
through the public issue and assist in obtaining listing and trading
Collect FIRC from the Escrow bankers
Prepare and make available the FC-GPR to be submitted to RBI by the
Prepare 78-day report (final 3 day report) to be submitted to SEBI

Key Documents
Offer Document
Draft Red Herring Prospectus
Red Herring Prospectus


MOU with BRLMs

MOU with RTI and STA
Escrow Agreement
Syndicate Agreement
Agreement with Post Monitoring Agency

Comfort Letters from Auditors & Due Diligence

Certificates from BRLMs

Major Timelines
Closure of Bidding Period

Days after closure


3 day Monitoring Report (Within 3 days from DD;

DD- 3 working days from bid closure)


Scrutiny and approval of Basis by Stock Exchange


Despatch of refunds and uploading of credits and

filing Listing Application (Within 2 working days
from Basis approval or 15 days from bid-closure)


Completion of necessary formalities for listing &

commencement of trading (Within 7 working days
of basis approval)


Post Issue Advertisement (Within 10 working days

from date of filing of listing application)


Final 3 day monitoring report (Within 3 days from

DD; DD- 3 working days from listing or 78 days
from closing of issue, whichever is earlier)


Approval of Basis of Allotment by the Designated Stock
Issue, Allotment and credit of Shares
Applications for listing and trading alongwith all
supporting documents
Listing and Trading Permission
Commencement of Trading
After due date for Balance Amount Payable, Application
for listing & trading of balance shares
In-principle approval for credit of balance shares
Credit of balance shares
Final Listing & Trading approval
Demat accounts frozen till trading commences

Green Shoe Option

For stabilising the post-listing pricing

Shareholders approval for allotment of further shares
to SA
One BRLM to be appointed as SA
Max shares that can be over-allotted 15% of the issue
Disclosures of specified details in offer document
Stabilisation mechanism available for 30 days after
trading starts
Shares to be transferred to lender(s) not later than 2
working days after the stabilising period subject to the
remaining lock-in
SA to file daily and final report to SEs/SEBI

Green Shoe Option contd.

Working mechanism
Shares up to 15% of issue size allotted as part of IPO
Money received on over-allotment is deposited in GSObank a/c
Promoters / pre-issue shareholders holding more than
5% shares may lend their shares (credited to GSO
demat a/c)
SA purchases shares from market, if the market price
falls below the issue price
Shares are transferred to lender(s); balance shares, if
any, are issued to lender(s)
Balance in the GSO bank a/c is transferred to IEPF of

Green Shoe Option contd

Issue of 200 L shares, green shoe issue of 30 L
Promoter x lent 30 L shares our of his total
shareholding of 300 L shares
Issue price is Rs. 100.
Money received on 30L shares, ie. Rs.30 crore
is transferred to GSO Bank A/c

Green Shoe Option contd

Scenario I (No purchases made by SA)
Transfer of Rs. 30 crore from GSR bank A/c to the companys Bank
Allotment of additional 30 L shares to X
Post-issue capital 530 shares

Scenario II (Total purchase made by SA, 30 L shares @ average

price of Rs.90/-)
30 L shares to be transferred to X
Balance Rs. 3 crore to be transferred to IEPF of DSE
Post-issue capital 500 shares

Scenario III (partial purchase made by SA, 10 L shares @ average

price of Rs.90/-)
10L shares to be transferred to X
Rs. 20 crore to be transferred from GSO Bank A/c to the companys
Bank A/c
Allotment of additional 20L shares to X
Balance Rs. 1 crore to be transferred to IEPF of DSE
Post-issue capital 520 shares


I P O A Glimpse of

the Success Story

RPL IPO Overview

Bidding Period : April 13 to 20

Price Band Rs. 57/- to 62/Shares offered to public 45 Crore
Shares to be issued in demat form
Payment Methods I and II; method I for
retail only with Rs.16/- payable with
application. Due date May 24, 2006
Issue Price Rs. 60/-; listed above Rs.100/-.

RPL IPO Some Numbers

10 Escrow Bankers
136 Bank Branches
73 Bidding Centres
2 Refund Bankers
371 Syndicate & Sub-Syndicate Members
2720 Bidding Terminals
Registrar : Karvy
Stock Exchanges : BSE and NSE; BSE being DSE

RPL IPO Issue Structure

RPL Capital Composition
Pre IPO Capital

Post IPO Shareholding Pattern


270 Cr.

Pre IPO Investors

45 Cr.



315 Cr.


RILs contribution
Issue to Public
Total Issue
Total Post Issue

90 Cr.
45 Cr.
(A) + (B)

135 Cr.
450 Cr.





Pre IPO Investors






RPL IPO Functions Involved


RPL IPO Milestone Activities




Board approves further issue of capital


Members approve further issue of capital at their

Extraordinary General Meeting


Draft Red Herring Prospectus was filed with SEBI/ROC


Applications made to BSE & NSE for in-principle



SEBI Observations on DRHP


Filing of RHP with ROC


ROC Acknowledgement


RPL IPO Milestone Activities




Issue opened on
Issue closed on


Based on the demand of shares and bid

price, the issue price was determined


10 Prospectus incorporating the issue price

filed with ROC
11 Basis of allotment finalised in consultation
with BSE
12 Allotment of shares


13 Listing application made to BSE & NSE



RPL IPO Milestone Activities





Equity shares were credited in the

NSDL/CDSL system
Commencement of Trading on BSE & NSE 11.05.2006


Completion of despatch of refund orders

Return of allotment filed with ROC
Due Date for Balance Amount Payable
In-principle approval from SEs for listing of
the balance shares


Corporate Action for the balance fully paid- 08/09.06.06

up shares
Listing & Trading approval for the balance 12/13.06.06



RPL IPO Performance

(In Times)

Sl No














Retail Individual








Before Technical rejections

RPL IPO Performance

(Amount wise Only public )








RPL IPO Technical Rejections

PAN Not provided (except NRIs)

Payment Method I by HNIs
HNI at cut-off
Applications not bid but banked
Applications bid but not banked
Client ID / DP ID Not provided
Mistakes in Client ID / DP ID Escrow
Possible fictitious / benami (More than 20 common
addresses) Treatment
One or more Direct Form with one or more Normal form








14,78,60,432 3,03,26,792


Post IPO Matters

Refunds not gone through

Shares in Pool Account
Postal return undeliverables
Wrong credit / dual credit
Improper Reconciliation
Continuous Monitoring - MIS

RPL IPO Special Features

Pre-IPO Placement
Co-promoter After RHP filing
Control Mechanism
Control Room at Maker IV
Coordinators Network throughout

Instructions Manuals
The e-way : IPO Tracker Internally designed Portal & Karisma
IPO Insurance of Rs. 20 Crore
Qualitative Documentation, crisp Bid Cum Application Form
Completion of mammoth processing activities within a record period
of 7 working days
Issue Pricing lower than the book-built price
Concurrent Audit

Thank You !