Significant Beneficial Owner Case on LinkedIn India and Group CEOs

Written by Nihal Srivastava, Krystal7 Consultants. Last updated 23 October 2026.

On 22 May 2024 the Registrar of Companies (ROC), as adjudicating officer, penalised LinkedIn Technology Information Private Limited and its directors under sections 89 and 90 of the Companies Act, 2013. Reports of the order say it treated Microsoft's CEO Satya Nadella and LinkedIn's CEO Ryan Roslansky as significant beneficial owners (SBOs). The Regional Director, Northern Region dismissed the appeal on 27 Feb 2026. The Delhi High Court stayed both orders on 15 May 2026.

This case note sets out the facts as they stood on 8 Mar 2026, the law, the ROC's reported reasoning and our view. The MCA website did not serve us the ROC or Regional Director orders. The record here comes from the Delhi High Court orders of 15 May 2026 and 6 Oct 2026. It ends with governance steps for Indian subsidiaries and what has happened since.

Is a foreign parent's global CEO a significant beneficial owner of the Indian subsidiary?

On shareholding, almost never. A salaried CEO of a widely held group rarely holds a majority stake in any company in the chain. Reports of the LinkedIn order say the ROC reached the CEOs through the control limb instead: significant influence or control over the Indian company. By 8 Mar 2026 the Regional Director had dismissed the appeal.

So on the publish date of this note the regulator's answer, as reported, was yes, and no court had ruled on it. The test reported is rule 2(1)(h)(iv) of the Companies (Significant Beneficial Owners) Rules, 2018 (SBO Rules). It covers an individual who "has right to exercise, or actually exercises, significant influence or control" other than through direct holdings alone. No percentage applies.

Many Indian subsidiaries of widely held multinationals file no BEN-2, because no individual holds a majority stake at the top. The LinkedIn orders, as reported, say that answer is incomplete until the company also tests who controls it in fact.

What did the ROC and the Regional Director decide in the LinkedIn case?

The ROC, sitting as adjudicating officer under section 454, imposed a penalty for violation of sections 89 and 90 on 22 May 2024. The Regional Director, Northern Region dismissed the appeal by the company and its directors on 27 Feb 2026. The Delhi High Court order of 15 May 2026 records both orders and their dates.

Item	Detail
Company	LinkedIn Technology Information Private Limited (LinkedIn India)
First order	Order of the Adjudicating Officer and ROC dated 22 May 2024
Provisions	Sections 89 and 90 of the Companies Act, 2013
Persons penalised	The company and its directors, who are the petitioners in the High Court (paragraphs 1 and 6 of the order of 15 May 2026); reports also name Satya Nadella and Ryan Roslansky
Appeal	Under section 454(5) to the Regional Director, Northern Region
Appeal order	Dismissed on 27 Feb 2026
Status on 8 Mar 2026	ROC order in force after the appeal failed
Later challenge	W.P.(C) 6677/2026 in the Delhi High Court, stay granted on 15 May 2026

Paragraph 7 of the High Court's order of 15 May 2026 records the appeal and its dismissal on 27 Feb 2026. It gives no reasons for the dismissal, and the Regional Director's order text was not available to us. Check that order itself before you rely on any account of the Regional Director's reasoning.

What were the facts?

LinkedIn India is an Indian subsidiary within the Microsoft group. Microsoft Corporation, a widely held US listed company, owns LinkedIn Corporation and sits at the top of the chain. No individual holds a majority stake in Microsoft Corporation. On the shareholding tests in the SBO Rules, that structure points to no SBO.

Reports of the ROC order say it looked past the shareholding to the board, the reporting lines and the bank mandates. We could not check those findings against the order. The petitioners told the High Court that the declarations under sections 89 and 90 were "originally filed on 29th January 2024". Paragraph 3 of the order of 15 May 2026 records this. That date came before the ROC order.

The ROC also relied on a filing that Microsoft's CEO made with the US Securities and Exchange Commission (SEC). Paragraph 5 of the High Court order records this, and the filing is Annexure P-12 to the petition. The petitioners argued that US disclosure rules differ from the SBO obligations under Indian law.

Which law applies to a significant beneficial owner?

Section 90 of the Companies Act, 2013 and the SBO Rules apply. Section 90(1) requires every individual who holds a beneficial interest of 25 percent "or such other percentage as may be prescribed" to declare it. The same duty applies to an individual with the right to exercise, or the actual exercise of, significant influence or control.

The company then has four duties under section 90:

1. Keep a register of SBOs under section 90(2), in Form BEN-3.
2. File a return with the ROC under section 90(4), in Form BEN-2.
3. Take the steps prescribed under section 90(4A) to find out whether any individual is an SBO.
4. Send notices under section 90(5) to any person it believes is, or knows of, an SBO, in Form BEN-4.

A person who receives a notice must reply within 30 days of its date under section 90(6). If no reply comes or the reply is not satisfactory, section 90(7) gives the company 15 days after that period to apply to the Tribunal.

Section 89 runs alongside. It covers a share registered in one person's name but held beneficially by another, such as a nominee share. A section 89 declaration goes on MGT-4 and MGT-5, and the company files MGT-6 within 30 days of receiving it under section 89(6). The ROC's penalty order covered violations of both sections.

Our BEN-2 guide for subsidiaries of foreign groups covers the forms and tracing rules in full. This note focuses on the control limb.

How do the objective and subjective tests differ?

Rule 2(1)(h) of the SBO Rules sets four tests. The first three are objective: they turn on a 10 percent holding of shares, votes or distributions, held indirectly or together with direct holdings. The fourth is subjective: it turns on significant influence or control, with no threshold.

Feature	Objective tests, rule 2(1)(h)(i) to (iii)	Subjective test, rule 2(1)(h)(iv)
What it measures	Shares, voting rights or distributions	Significant influence or control
Threshold	At least 10% held indirectly, or indirectly with direct holdings	None
How indirect holding works	Majority stake in the member or in its ultimate holding company	Any manner other than direct holdings alone
Evidence	Registers of members and group charts	Board papers, delegations, bank mandates, agreements, conduct
Typical result for a widely held listed group	No SBO	Depends on facts; reports say the LinkedIn ROC named the CEOs
Risk of disagreement with the ROC	Low	High

"Significant influence" in rule 2(1)(i) of the SBO Rules is the power to take part in the reporting company's financial and operating policy decisions. It can be direct or indirect, and it stops short of control or joint control. "Control" takes its meaning from section 2(27). It includes the right to appoint most directors. It also includes control of management or policy decisions "in any other manner".

The majority stake rule decides the objective tests. Explanation III(i) to rule 2(1)(h) deals with a member that is a body corporate. An individual holds its stake indirectly only through a majority stake in that member or in its ultimate holding company. A CEO with a fraction of 1 percent of a listed parent holds nothing indirectly. Only the subjective test can reach that person.

Why does the Act say 25 percent when the Rules say 10 percent?

Section 90(1) sets 25 percent "or such other percentage as may be prescribed". The SBO Rules prescribe at least 10 percent for shares, votes and distributions. The Act itself allows a lower figure by rule, so the 10 percent threshold rests on that delegation. Bank KYC uses a different line again: more than 10 percent of shares, capital or profits.

Some practitioners question whether the Rules can go below the Act's 25 percent. In our view that debate does not touch the LinkedIn case. The CEOs failed every percentage test, so the threshold was never the issue. The control limb in the Act has no percentage at all, and the Rules copy that.

How did the ROC reason?

We could not read the ROC order, so we cannot set out its grounds or their paragraph numbers. The High Court order of 15 May 2026 records one ground: the ROC relied on a US SEC filing by the CEO of Microsoft Corporation (paragraph 5). Commentary on the order describes more grounds, which we have not checked.

As reported, the ROC looked at who sits on the Indian board, to whom those directors report, and who runs the money. It then traced the reporting lines up to the two CEOs. The table below treats those points as group facts a regulator may rely on, with the answer to each. Only the last row is on the High Court record.

Group fact	What a regulator may read into it	The counter argument
Indian directors are employees of the parent group, unpaid by the Indian company	They act as nominees, reporting up to the group CEO	Section 166 makes every director owe duties to the Indian company, whoever employs them
The group CEO leads the business worldwide, including India	The CEO exercises influence over the Indian company's policy	A CEO acts for the parent board and its shareholders, not on his own account
Board resolutions place banking and treasury authority with parent treasury staff	Financial control sits with parent personnel	A parent's treasury policy is a group control, not a natural person's control
The parent's bylaws give its CEO general charge of the business	The CEO's authority runs down to every subsidiary	Bylaws describe a role in the parent, not a right in the Indian company
The CEO's filing with the US SEC, which the ROC relied on	Evidence of influence over group companies	US disclosure tests differ from section 90, as the petitioners argued

The High Court order also records the petitioners' complaint that the ROC "roped in all petitioners in the order imposing penalty" (paragraph 6). They said there was "no occasion" for them to make a declaration under sections 89 and 90. We could not read the ROC order. So we cannot state its findings on officers in default or on BEN-4 notices under rule 2A(2).

What did LinkedIn argue?

The petitioners' case, as the High Court recorded it on 15 May 2026, had four parts.

1. They filed the declarations under sections 89 and 90 on 29 Jan 2024 (paragraph 3).
2. The ROC went "beyond the scope and purview" of sections 89 and 90 (paragraph 4).
3. The ROC relied on a US SEC filing by Microsoft's CEO, and US disclosure rules differ from SBO duties in India (paragraph 5).
4. The ROC named every petitioner in the penalty order, although there was "no occasion" for them to declare under sections 89 and 90 (paragraph 6).

The High Court order does not record what the company argued before the ROC, and we could not read the ROC order. The outcome is on record: the ROC imposed the penalty, and the Regional Director dismissed the appeal on 27 Feb 2026 (paragraph 7).

What penalties did the ROC impose, and under which sections?

The High Court order of 15 May 2026 records a penalty for violation of sections 89 and 90, but no amounts. The ROC order text was not available to us, so we do not state the penalty on each person or the total. Press reports give totals that we could not check against the order. The table shows the statutory ceilings that bind any such order.

Default	Who pays	Penalty	Maximum	Section
Failure to declare as an SBO (BEN-1)	The individual	INR 50,000, plus INR 1,000 for each day after the first	INR 2,00,000	90(10)
Failure to keep the register, file BEN-2 or take the section 90(4A) steps	The company	INR 1,00,000, plus INR 500 for each day after the first	INR 5,00,000	90(11)
Same default	Each officer in default	INR 25,000, plus INR 200 for each day after the first	INR 1,00,000	90(11)
Contravention with no specific penalty, such as a missed section 90(5) notice	Company; officer in default	INR 10,000, plus INR 1,000 for each day after the first	INR 2,00,000 (company); INR 50,000 (officer)	450
Failure to declare a beneficial interest in shares	The person	INR 50,000, plus INR 200 for each day after the first	INR 5,00,000	89(5)
Failure to file MGT-6	Company; officer in default	INR 1,000 a day	INR 5,00,000 (company); INR 2,00,000 (officer)	89(7)

On these caps, a company's exposure for one run of section 90 defaults is INR 5,00,000 under section 90(11). A missed section 90(5) notice adds up to INR 2,00,000 under section 450. An individual who never gives BEN-1 faces at most INR 2,00,000 under section 90(10). Section 90(12) adds action under section 447 for wilfully false information, but nothing in the High Court orders suggests the ROC used it.

Under section 454, an aggrieved person appeals to the Regional Director within 60 days of receiving the order. Section 454(8) makes it an offence not to comply with an order within 90 days. A company faces a fine of INR 25,000 to INR 5,00,000. An officer faces up to six months, a fine of INR 25,000 to INR 1,00,000, or both.

Our view

If the ROC order says what reports describe, we think it reached the wrong answer on the two CEOs. Our reasons are rooted in the text of section 90. We also think the group facts reported in the case would worry any regulator, and Indian subsidiaries should fix those facts now.

First, section 90 looks for the individual who stands behind the corporate chain. Section 90(1) speaks of an individual acting "alone or together, or through one or more persons or trust". A salaried CEO of a widely held company does not act on his own account. He exercises the parent board's authority, which answers to dispersed shareholders. The control the ROC found belongs to Microsoft Corporation as a company.

Second, the SBO Rules have no fallback that names a senior manager when ownership tests name nobody. Bank KYC rules do have one. Paragraph 5(1)(iv) of the RBI's Know Your Customer Directions, 2025 covers the case where the tests identify no natural person. The beneficial owner then "is the relevant natural person who holds the position of senior managing official". The ROC's reading brings that fallback into the Companies Act by interpretation. If the Ministry wanted it, it knew how to write it.

Third, the reading has no natural stopping point. If reporting lines make the group CEO an SBO, the group CFO and regional president may follow. Every change of group CEO would then need fresh BEN-1 and BEN-2 filings in every Indian subsidiary.

Fourth, Explanation I to rule 2(1)(h) speaks to an individual who holds no right or entitlement indirectly under sub clauses (i), (ii) or (iii). It says that person "shall not be considered to be a significant beneficial owner". Read literally, it excludes a person whose only link is control. We would not rest a case on that literal reading alone, because it would shrink sub clause (iv) sharply. It still supports the petitioners.

Fifth, the penalty on every director is the weakest part of the order. Section 90(11) reaches only an "officer who is in default". Section 2(60) limits that class. A non executive director falls in it mainly where the director knew of the contravention through board proceedings and did not object. The same applies where the contravention happened with the director's consent or connivance. A penalty on every director that rests only on their knowing the holding structure would not meet that test.

The ROC's side is not empty. Rule 2(1)(h)(iv) covers a person who "actually exercises" control, and section 2(27) includes control "in any other manner". Suppose foreign employees fill the Indian board, take no Indian pay and sign resolutions that defer to a parent's treasurer. A regulator can then fairly ask who decides. In our view the answer is still the parent company, not its CEO. But if the reported facts are right, the company's own arrangements gave the ROC its opening.

Until a court rules, we advise subsidiaries to assume their ROC may follow LinkedIn, and to build the record that answers it.

What should an Indian subsidiary do now?

Run the SBO test as a documented board exercise. The file should show that the Indian board tested and minuted who owns and controls the company. Then fix the governance facts that a regulator may treat as signs of personal control.

Area	Risk signal a regulator may look at	What we advise
Board composition	Parent employees with no role in India	Add a director with an operating role in India, besides the resident director
Delegation of powers	Banking authority with parent staff	Delegate section 179(3) money powers only to a committee, the managing director, the manager or a principal officer, within limits
Group policies	Resolutions deferring to a parent officer	Adopt group policies as the Indian board's own decision, with a right to depart
Minutes	Little deliberation in India	Record discussion and reasons under section 118 for budgets, related party deals and bank mandates
SBO analysis and BEN-4	No SBO identified and no rule 2A steps on record	Minute a yearly analysis of both tests; send BEN-4 to each corporate member of 10% or more
BEN-1, BEN-2 and BEN-3	Declarations questioned	File BEN-2 within 30 days of each BEN-1; keep the register open to members under section 90(3)
Financial statements	How the holding company was described	Name the immediate and ultimate holding companies correctly in the notes and in MGT-7

Review the related party approvals under section 188 at the same meeting, because they show who decides money flows. The same record helps on tax, since minutes that show decisions abroad can feed a permanent establishment argument against the parent. Our note on board meetings with non resident directors by video conference covers how to hold and minute those meetings.

What has happened since 8 Mar 2026?

The Delhi High Court stayed both orders on 15 May 2026. LinkedIn India and its directors filed W.P.(C) 6677/2026 with CM APPL. 32878/2026 for a stay. Justice Anish Dayal issued notice, and counsel for the respondents accepted it and was given eight weeks to file a reply. The Court recorded that the respondents' counsel had no instructions. It stayed "the operation of impugned orders till the next date of hearing".

Date	Step in W.P.(C) 6677/2026	What the order says
15 May 2026	Notice and stay	Notice issued; reply in eight weeks; both orders stayed till the next date of hearing; listed 6 Oct 2026
6 Oct 2026	Listed hearing	Not taken up because of a Full Court Reference to bid farewell to the Chief Justice; listed on 15 Mar 2027
15 Mar 2027	Next listing	Not yet known

The order of 6 Oct 2026 does not mention the stay, and it does not record whether the respondents have filed their reply. The stay of 15 May 2026 ran "till the next date of hearing", and the Court did not hear the matter on 6 Oct 2026. Check whether the stay continues on the case status page of the Delhi High Court website, using CNR DLHC010220472026, or ask the petitioners' counsel.

The order of 15 May 2026 opens its stay direction with "Having appreciated the submissions advanced on behalf of petitioners". It records no finding on the merits. Some reports describe the Court as finding that the ROC "may have exceeded" its mandate. The order on the High Court website does not say that.

What changed in 2026

Section 90 and the SBO Rules did not change in 2026 as far as we found. The changes were in the LinkedIn proceedings and in the beneficial ownership tests that run beside section 90.

Area	Old position	New position	Date	Instrument
LinkedIn appeal	ROC order of 22 May 2024 under appeal	Appeal dismissed	27 Feb 2026	Regional Director, Northern Region order
LinkedIn writ	Regional Director's order in force	Both orders stayed till the next hearing	15 May 2026	Delhi High Court, W.P.(C) 6677/2026
FDI from land border countries	Any beneficial owner from such a country meant the government route	PML Rules definition; non controlling ownership up to 10% on the automatic route	Cabinet approval 10 Mar 2026	PIB release of 10 Mar 2026; check the NDI Rules on rbi.org.in for the amending notification
Company law reform	Not applicable	Corporate Laws (Amendment) Bill, 2026 introduced and sent to a Joint Committee, which reported on 3 Aug 2026; not law on 23 Oct 2026 as far as we found	23 Mar 2026	Bill No. 85 of 2026

The land border change uses the beneficial ownership test in the Prevention of Money Laundering Rules, not section 90. Our note on Press Note 3 and land border FDI covers it.

Worked example

Arbor Software India Private Limited (Arbor India) is wholly owned by Arbor Holdings BV of the Netherlands. A nominee holds one share. Arbor Inc, listed in New York and widely held, owns Arbor Holdings. No individual holds more than 5 percent of Arbor Inc. Arbor India has three directors: two are Arbor Inc employees in the US, and one is a whole time director in Pune.

On the objective tests, Arbor India has no SBO. No individual holds a majority stake in Arbor Holdings or in Arbor Inc. On a LinkedIn style reading of the subjective test, the ROC could name Arbor Inc's CEO and its Asia Pacific president. Here is the exposure if the ROC took that view, treated all three directors as officers in default, and every default ran past its cap.

Person	Section and working	Exposure (INR)
Arbor India	90(11): 1,00,000 + 500 x 800 days	5,00,000
Arbor India	450: 10,000 + 1,000 x 190 days	2,00,000
Each of 3 directors as officers in default	90(11): 25,000 + 200 x 375 days = 1,00,000; 450: 10,000 + 1,000 x 40 days = 50,000	1,50,000 each, so 4,50,000
Arbor Inc CEO	90(10): 50,000 + 1,000 x 150 days	2,00,000
Asia Pacific president	90(10): 50,000 + 1,000 x 150 days	2,00,000
Total	5,00,000 + 2,00,000 + 4,50,000 + 2,00,000 + 2,00,000	15,50,000

The caps arrive quickly. An individual's penalty under section 90(10) reaches INR 2,00,000 after 150 days beyond the first. The officer cap under section 450 arrives after 40 days. We do not run these caps on LinkedIn's own facts, because the ROC order text was not available to us.

The bigger cost for a listed group is a penalty order naming its CEO. The fix is cheaper. Arbor India's board meets on 16 Mar 2026, minutes its analysis and sends BEN-4 to Arbor Holdings on 17 Mar 2026. The reply is due within 30 days of the notice, by 16 Apr 2026. If no satisfactory reply arrives, section 90(7) requires an application to the NCLT within 15 days after that, by 1 May 2026.

Common mistakes

1. Stopping at the shareholding tests. A widely held parent often yields no SBO on shares. Fix: test significant influence and control as well, and minute the result.
2. Filing nothing and keeping no evidence. No BEN-1 means no BEN-2, but section 90(4A) still requires steps. Fix: send BEN-4 to each corporate member of 10 percent or more and keep the replies.
3. Naming the group CEO by reflex. A BEN-2 that names someone who is not an SBO is also a wrong filing. Section 90(12) punishes wilfully false information. Fix: decide on reasoned board minutes, not on fear.
4. Boards that only sign. Directors who never deliberate in India invite a finding that someone abroad decides. Fix: record real discussion of budgets, bank mandates and related party deals.
5. Delegating money powers to parent staff. Resolutions that hand banking authority to people outside the Indian company read as outside control. Fix: delegate within section 179(3) and set limits in the resolution.
6. Assuming non executive directors are safe. The LinkedIn petitioners, the company and its directors, told the High Court that the ROC named all of them in the penalty order. Fix: give each director a short SBO briefing and record objections where a director has them.

Checklist

1. List every member holding 10 percent or more from the register of members.
2. Obtain a signed group chart up to the ultimate holding company, with shares, votes and dividend rights.
3. Test each member and its ultimate holding company for an individual majority stake.
4. Map who appoints the Indian directors, who signs the bank mandates and who approves the budget.
5. Decide on significant influence and control for each individual named in that map.
6. Send BEN-4 to each corporate member of 10 percent or more under rule 2A(2).
7. Minute the board's SBO analysis and the reasons for the result.
8. Collect BEN-1 from each SBO, file BEN-2 within 30 days of receipt and update the BEN-3 register.
9. Review delegations under section 179(3) so that money powers sit with Indian officers or a board committee.
10. Repeat the exercise once a year and after any change in the group above India.

Our company compliance service runs this review for foreign owned subsidiaries; send your group chart and we will tell you who must declare.

Frequently Asked Questions

Who was held to be a significant beneficial owner in the LinkedIn case?+

Reports of the ROC order of 22 May 2024 say it treated Microsoft's CEO Satya Nadella and LinkedIn's CEO Ryan Roslansky as SBOs of LinkedIn Technology Information Private Limited. They describe the ROC using the significant influence or control test in rule 2(1)(h)(iv) of the SBO Rules. The Delhi High Court order of 15 May 2026 records only the ROC's reliance on a US SEC filing by Microsoft's CEO.

Is the LinkedIn ROC order binding on other companies?+

No. An adjudication order under section 454 binds only the parties to it. Other ROCs can still follow its reasoning, and the Regional Director dismissed the appeal against it on 27 Feb 2026. Until the Delhi High Court decides W.P.(C) 6677/2026, treat the order as a sign of how ROCs may read section 90.

Does a listed foreign parent exempt an Indian subsidiary from section 90?+

No. Rule 8 of the SBO Rules switches the rules off only for shares held by the IEPF authority, an Indian holding reporting company, governments and their entities, and vehicles regulated by SEBI, RBI, IRDAI or PFRDA. A listed foreign parent often yields no SBO on shareholding, but the subsidiary must still take the section 90(4A) steps and test control.

Can an individual with no shares be a significant beneficial owner?+

Yes. Rule 2(1)(h)(iv) of the SBO Rules covers an individual who has the right to exercise, or actually exercises, significant influence or control other than through direct holdings alone. No percentage applies to that limb, which is the route the ROC is reported to have used for the two CEOs.

What is the penalty for not giving a BEN-1 declaration?+

Section 90(10) of the Companies Act, 2013 fines the individual INR 50,000 and INR 1,000 for each day after the first, up to INR 2,00,000. The company and its officers face separate penalties under section 90(11) for not filing BEN-2 or not taking the steps in section 90(4A).

Can non executive directors be penalised for SBO defaults?+

Only if they are officers in default. Section 2(60) covers a director who knew of the contravention through board proceedings and did not object, or who consented to it. It also covers directors the board specifies, and all directors where the company has no key managerial personnel and none is specified. The LinkedIn petitioners argued that the ROC named every director without that link.

How long does a company have to appeal an ROC penalty order?+

Section 454(6) of the Companies Act, 2013 allows 60 days from receipt of the order to appeal to the Regional Director. The Regional Director may confirm, modify or set aside the order. Not complying with a final order within 90 days is an offence under section 454(8).

Did the Delhi High Court stay the LinkedIn penalty?+

Yes. On 15 May 2026 the Delhi High Court stayed the ROC order of 22 May 2024 and the Regional Director's order of 27 Feb 2026 till the next hearing in W.P.(C) 6677/2026. On 6 Oct 2026 the matter was not taken up and was listed for 15 Mar 2027. That order does not mention the stay.

Should a subsidiary name the group CEO in BEN-2 to be safe?+

Not by reflex. BEN-2 follows a BEN-1 from a person who is an SBO, and a wrong declaration has its own risk under section 90(12). We advise a minuted analysis of both tests, BEN-4 notices to corporate members, and governance changes that keep decisions with the Indian board.

Sources

• Delhi High Court, order in W.P.(C) 6677/2026 and CM APPL. 32878/2026, LinkedIn Technology Information Private Limited and others v Union of India and others, 15 May 2026, https://delhihighcourt.nic.in/app/downloadOrderbByDate/W.P.(C)/6677/2026/15-05-2026
• Delhi High Court, order in W.P.(C) 6677/2026, 6 Oct 2026, https://delhihighcourt.nic.in/app/downloadOrderbByDate/W.P.(C)/6677/2026/06-10-2026
• Registrar of Companies, adjudication order under sections 89 and 90 in the matter of LinkedIn Technology Information Private Limited, 22 May 2024 (link as found; the MCA website did not serve it to us, so we have not read it), https://www.mca.gov.in/bin/dms/getdocument?mds=san%252BPg76sI9tkgd5lcHzZg%253D%253D&type=open
• Income Tax Department, Companies Act, 2013 section 90 (register of significant beneficial owners), read 23 Oct 2026, https://www.incometaxindia.gov.in/w/section-90-93
• Income Tax Department, Companies Act, 2013 section 89 (declaration in respect of beneficial interest), read 23 Oct 2026, https://www.incometaxindia.gov.in/w/section-89-92
• Income Tax Department, Companies Act, 2013 section 2 (clauses 27, 59, 60 and 87), read 23 Oct 2026, https://www.incometaxindia.gov.in/w/section-2-148
• Income Tax Department, Companies Act, 2013 section 450 (punishment where no specific penalty), read 23 Oct 2026, https://www.incometaxindia.gov.in/w/section-450-2
• Income Tax Department, Companies Act, 2013 section 454 (adjudication of penalties), read 23 Oct 2026, https://www.incometaxindia.gov.in/w/section-454-2
• Ministry of Corporate Affairs, Companies (Significant Beneficial Owners) Rules, 2018 (G.S.R. 561(E), 13 Jun 2018) and Amendment Rules, 2019 (G.S.R. 100(E), 8 Feb 2019), https://www.mca.gov.in/content/mca/global/en/acts-rules/ebooks/notifications.html
• ICAI Navi Mumbai Branch, text of rules 2, 4 and 8 of the Companies (Significant Beneficial Owners) Rules, 2018 as amended, read 24 Oct 2026, https://navimumbai.icai.org/detail/31509.aspx
• Reserve Bank of India, Reserve Bank of India (Payments Banks, Know Your Customer) Directions, 2025, paragraph 5(1)(iv), 28 Nov 2025 (updated as on 1 Oct 2026), https://www.rbi.org.in/Scripts/NotificationUser.aspx?Id=13090&Mode=0
• Press Information Bureau, Cabinet approves changes in guidelines on investments from countries sharing land border with India, 10 Mar 2026, https://www.pib.gov.in/PressReleasePage.aspx?PRID=2237806
• PRS Legislative Research, The Corporate Laws (Amendment) Bill, 2026 (Bill No. 85 of 2026), introduced in Lok Sabha 23 Mar 2026, Joint Committee report 3 Aug 2026, https://prsindia.org/billtrack/the-corporate-laws-amendment-bill-2026