Background: SEBI vide its order dated 22 November 2018 had imposed a penalty of Rs. 65 lakh on the Company for the alleged violation of the provisions of Regulations 4(1), 5A and 19(7) of the Buy Back Regulations, 1998 pertaining to the buy-back of shares held by notified parties, in the year 2003. Further, the Company had deposited the penalty amount under protest to SEBI and simultaneously, an appeal was filed before SAT against the order passed by SEBI