SEBI has compiled all 39 informal guidance letters issued under the PIT Regulations from October 2015 to September 2026. Read together, they show a pattern. On the hardest questions, SEBI often sends the answer back to the company's own Code of Conduct and its Compliance Officer. 𝗪𝗵𝗮𝘁 𝘁𝗵𝗲 𝗥𝗲𝗰𝗲𝗻𝘁 𝗟𝗲𝘁𝘁𝗲𝗿𝘀 𝗦𝗮𝘆: 1️⃣ 𝗣𝗹𝗲𝗱𝗴𝗲 𝗶𝘀 𝘁𝗿𝗮𝗱𝗶𝗻𝗴. Creating or releasing a pledge is "dealing", so it is a trade. Revocation within six months does not trigger