SEBI on Thursday the, 31st day of December, 2015 issued circular on dealing with cases prior to April 01, 2014, it has been decided that offers of securities – shares and debentures – by companies to more than 49 persons were deemed to be public offers.

The detailed circular is appended at the below mentioned link: SEBI Circular No. CIR-CFD-DIL-31-8-2015 dated 31.12.15