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Any insider who,
a) either on his own behalf or on behalf of any other person, deals in securities of Harshudyan on the basis of any UPSI; or
b) communicates any UPSI to any person, with or without his request for such information except as required in the ordinary course of business or under any law; or
c) counsels, or procures for any other person to deal in any securities of Harshudyan on the basis of UPSI shall be liable to a penalty in terms of SEBI Act.