the designated person is in possession of an UPSI which was not existing at the time of formulation/submission of trading plan, would these trades be in violation of SEBI (PIT) Regulations?

 If an insider/designated person trades on the basis of earlier UPSI, which is still not generally
available, then it will be in violation of SEBI (PIT) Regulations. However, if at the time of
formulation of trading plan, there was no UPSI or later on a new UPSI was generated, then
the trading can be carried out as per the trading plan, even if the new UPSI has not been made
generally available