Sameeksha India Flexicap Equity Fund

What Is the Sameeksha India Flexicap Equity Fund?

The Sameeksha India Flexicap Equity Fund is a GIFT City Category III AIF designed to provide eligible non-resident Indians (NRIs) and foreign investors with professionally managed exposure to Indian equities through an IFSC-based fund structure.

The fund is registered with the International Financial Services Centres Authority (IFSCA) and is structured at the IFSC as an offshore AIF. According to the fund presentation, it invests primarily in securities listed on Indian stock exchanges or IFSC stock exchanges, with the ability to participate in opportunities such as about-to-IPO equities where permitted.

For investments in Indian-listed securities, the fund can invest directly through the Foreign Portfolio Investment (FPI) route or indirectly through the India Equity Fund (Domestic AIF), depending on the investment opportunity and applicable regulations.

This makes the strategy particularly relevant for investors looking for an India-focused GIFT City fund rather than a conventional global-equity allocation.

For investors evaluating the broader GIFT City ecosystem, ALTPORT's GIFT City funds section provides additional context on IFSC investment opportunities. The fund can also be evaluated alongside other Category III alternative investment funds.

Sameeksha India Flexicap Equity Fund Snapshot

Important: Minimum subscription, fees, dealing frequency, redemption notice periods and other commercial terms should be confirmed against the latest PPM, contribution agreement and applicable fund documents before investing.

Sameeksha India Flexicap Equity Fund Investment Strategy

The core investment proposition is straightforward: identify attractive Indian businesses across market capitalisations and invest when the expected return adequately compensates for the risk.

The fund follows a flexicap approach rather than restricting itself to a particular market-cap segment. This allows the portfolio to move across large-cap, mid-cap and small-cap Indian companies depending on where the investment team identifies attractive risk-adjusted opportunities.

The investment philosophy is described as “Growth at Right Value.” The objective is not to buy growth at any price, but to identify businesses with:

• Sustainable growth potential
• Strong business models
• Competitive advantages
• Quality management
• Sound corporate governance
• Attractive return on invested capital
• Strong cash-flow generation
• Valuations that provide an appropriate return relative to risk

The strategy is also designed around a 2+ year investment horizon, with meaningful upside potential required before capital is committed.

The presentation indicates that the fund can maintain substantial cash when attractive opportunities are unavailable. This reflects an absolute-return orientation, rather than a requirement to remain fully invested simply to track a benchmark.

How Sameeksha Selects Indian Equity Opportunities

The investment process combines technology-enabled screening with detailed fundamental research.

The research platform automatically maintains historical financial information for 1,800+ companies, creating a broad starting universe. Idea generation can incorporate market trends, government policy, screeners, management interactions, broker research, investor conferences, channel checks and technology-assisted qualitative screening.

Potential investments then move through multiple research stages.

Level 1: Initial Evaluation

The initial evaluation considers factors such as:

• Market-implied valuation
• ROIC
• Cash-flow trends
• Accounting quality
• Capital allocation history
• Growth characteristics
• Financial and forensic checks

A 50-point checklist forms part of the first-stage assessment.

Level 2: Deep Dive

Companies that pass the initial evaluation undergo a more detailed review using a 75-point checklist, including:

• DCF and excess-ROE models
• Detailed company reports
• Industry forecasts
• Competitive analysis
• Porter's Five Forces
• Management interactions
• Site visits
• Channel checks
• Peer comparison

The final investment note is reviewed by the research team and Investment Committee before CIO approval.

This process creates a structured pathway from idea generation → screening → deep research → investment committee review → portfolio holding.

Portfolio Construction Across Large, Mid and Small-Cap Companies

The Sameeksha India Flexicap Equity Fund does not follow a rigid large-cap, mid-cap or small-cap allocation model.

Instead, market-cap exposure can change as the investment team identifies opportunities and evaluates liquidity, valuation, expected return and downside risk.

This flexibility is important because the fund's investment process is focused on business quality and expected returns, rather than maintaining a predetermined market-cap allocation.

At the same time, the portfolio is not designed simply to maximise exposure to smaller companies. Position sizing is explicitly linked to liquidity.

The fund presentation describes portfolio-level liquidity gates and position-level build-time limits. For example, position sizes are constrained based on the number of trading days required to build a position, while the investment team seeks to avoid excessive market impact.

The broader philosophy is therefore:

The more difficult a security is to trade, the greater the return required to justify owning it.

This creates an additional layer of risk management around the fund's flexicap approach.

About Sameeksha Investment Managers LLP

The Sameeksha India Flexicap Equity Fund is an offshore India-focused investment vehicle structured as a GIFT City / IFSC Category III AIF, with Sameeksha Investment Managers LLP acting as the investment manager.

The fund is part of the broader Sameeksha investment platform, whose investment approach has been developed around fundamental research, disciplined portfolio construction and a focus on generating risk-adjusted returns. The broader platform traces its origins to Bhavin Shah, who started Sameeksha Capital in 2015 to manage his personal savings through a professional investment setup.

The domestic Sameeksha platform includes its portfolio management activities, including the Sameeksha Capital business. However, Sameeksha Investment Managers LLP should not be confused with Sameeksha Capital Private Limited: for this GIFT City fund, the IFSC investment-management entity is Sameeksha Investment Managers LLP.

The investment philosophy is research-intensive and process-driven, combining quantitative analysis, detailed company research, valuation discipline and portfolio-level risk controls.

Indian Listed Equities, IPO Opportunities and IFSC Securities

The fund's investment universe is primarily centred on Indian equities.

The fund presentation states that the strategy can invest in equities listed on Indian stock exchanges and IFSC stock exchanges, as well as eligible about-to-IPO equities across sectors and market-cap categories.

An important feature of the Category III AIF structure is the ability to participate in IPO opportunities where the fund qualifies as an institutional investor.

The presentation specifically identifies IPO subscription as an investment option and notes that the fund can participate in Initial Public Offers where eligible.

The strategy may therefore look beyond currently listed stocks to selected opportunities approaching the public markets. Such investments remain subject to the fund's investment mandate, applicable regulations, due diligence and risk controls.

Investors should not interpret this as a promise that the fund will participate in every IPO or pre-IPO opportunity.

Use of Derivatives, Cash and Short-Term Securities

Derivatives are not presented as the primary investment strategy.

Instead, the fund may use selected derivative positions as a satellite strategy to enhance returns, manage risk or reduce portfolio volatility where appropriate.

The presentation states that gross exposure through equity and derivatives is intended not to exceed 2× the NAV of the fund.

This is distinct from positioning the fund as a leveraged trading strategy. Derivatives form part of the portfolio toolkit and remain subject to the fund's risk-management framework.

The fund may also hold cash and short-term instruments when required for liquidity, portfolio management or tactical positioning. The broader strategy can include government securities and Treasury bills where permitted under the fund's mandate.

The investment team has also demonstrated a willingness to increase cash when attractive risk-adjusted opportunities are unavailable.

How the GIFT City Structure Works for NRIs and Overseas Investors

One of the distinguishing features of the Sameeksha India Flexicap Equity Fund GIFT City structure is that it allows eligible non-resident investors to access an India-focused strategy through an IFSC-based fund.

The fund presentation describes a structure in which NRIs and foreign investors invest into the offshore AIF, with the fund deploying capital into Indian investment opportunities.

For Indian securities, the fund can use the FPI route, subject to applicable regulatory requirements. The fund structure therefore creates a bridge between overseas capital and Indian listed-equity opportunities.

The fund operates with a foreign-currency-oriented structure, with the presentation showing USD-based fund flows and USD-denominated performance reporting.

This can be particularly relevant for investors seeking:

• Indian equity exposure
• A professionally managed India-focused portfolio
• Access through GIFT City/IFSC
• A Category III AIF structure
• An investment vehicle designed for eligible non-resident investors

NRIs evaluating alternatives can also explore ALTPORT's NRI investment opportunities and dedicated information on AIF investments for NRIs.

Tax treatment should always be evaluated based on the investor's residential status, jurisdiction, applicable Indian regulations, fund structure and current tax rules. GIFT City should not automatically be interpreted as “tax-free.”

Sameeksha India Flexicap Equity Fund Performance

The fund presentation reports offshore AIF performance in USD terms, with data shown from inception on 14 March 2024 through 31 August 2026.

The presentation also reports a 7.4% YTD relative return for 2026 through August.

Importantly, these figures are specifically identified as India Equity Fund (Offshore AIF) performance and should not be confused with the performance of Sameeksha's domestic PMS or domestic AIF products.

The presentation states that the performance information is based on data provided by the fund accountants and is not audited by SEBI. Past performance should not be interpreted as a guarantee of future results.

Sameeksha India Flexicap Equity Fund Minimum Investment, Fees and Redemption Terms

The fund presentation currently available for this strategy states:

• Minimum investment: US$150,000
• Accredited investor minimum: US$75,000
• Monthly NAV reporting
• Redemption requests can be submitted to the fund, with proceeds generated following the sale/liquidation of investments.

The presentation also describes an investor-aligned, gains-linked fee structure, under which a Special Profit Allocation and additional returns-linked component are linked to fund profitability rather than relying exclusively on conventional fixed-fee economics.

It also states an expense figure of 0.15% at AUM of US$18 million borne by the fund, with 0.5% borne by HME, as presented in the fund material.

Because commercial terms can change and the presentation itself may not constitute the latest contractual documentation, investors should confirm the current minimum subscription, fee schedule, performance-linked charges, redemption notice, dealing frequency, lock-in and other terms from the latest PPM and contribution agreement.

To request the latest available documents, investors can request the latest fund documents.

Who Can Consider the Sameeksha India Flexicap Equity Fund?

The fund may be relevant for eligible:

• NRIs
• Overseas investors
• Foreign investors
• Family offices
• Global investors seeking India exposure
• Other investors who satisfy the applicable IFSC/AIF eligibility requirements

It may be particularly relevant for investors who want a professionally managed Indian-equity portfolio through GIFT City, rather than building a direct portfolio of Indian stocks themselves.

Eligibility, KYC, source-of-funds requirements, FATCA/CRS documentation and other regulatory requirements must be completed before investment.

Key Risks of the Sameeksha India Flexicap Equity Fund

Investing in a Category III AIF involves significant risk, and capital is not guaranteed.

Equity-market risk

The fund primarily invests in equities, so portfolio value can decline materially during market corrections.

Small- and mid-cap risk

Flexicap investing can create meaningful exposure to smaller companies, which may have lower liquidity and higher price volatility.

Concentration risk

A research-driven, high-conviction portfolio may hold a relatively limited number of securities. Poor performance in an individual investment can therefore have a material portfolio impact.

Liquidity risk

Some smaller or less actively traded securities may take longer to buy or sell. The fund's position-sizing and liquidity framework is designed to manage this risk but cannot eliminate it.

Currency risk

The fund is structured around foreign-currency investment and reports performance in USD. Returns for an investor may therefore differ depending on the relationship between the investment currency and the investor's home currency.

Derivatives risk

Derivative positions can increase complexity and may create losses if markets move adversely. Their use is subject to the fund's mandate and risk controls.

Regulatory and tax risk

IFSC, Indian securities, FPI, AIF and taxation rules can change. Investors should obtain appropriate professional advice regarding their individual circumstances.

Redemption and liquidity risk

An investor may not always be able to redeem capital immediately at the desired price or time. The applicable PPM and contribution agreement govern redemption conditions.

Meet the Investment Team

The broader Sameeksha investment platform was founded by Bhavin Shah, who has built the investment philosophy around fundamental research, valuation discipline and process-driven portfolio management.

The presentation highlights a research-led organisation supported by a sizeable research team and an Investment Committee, with proprietary technology used across research, portfolio monitoring, order management and risk controls.

For the GIFT City fund specifically, the formal investment-management role is attributed to Sameeksha Investment Managers LLP. Individual titles and responsibilities should be verified against the latest IFSC fund documentation before being represented as the formally designated fund manager.

Sameeksha India Flexicap Equity Fund vs Other Sameeksha Strategies

The GIFT City fund should not be confused with Sameeksha's domestic PMS or domestic AIF products.

For example, investors comparing structures can review the Sameeksha India Equity Fund PMS, while those evaluating an alternative domestic AIF can explore the Sameeksha Capital Investment Fund.

The key difference is that the Sameeksha India Flexicap Equity Fund is an IFSC/GIFT City Category III AIF designed around India-focused equity investing for eligible non-resident investors.

Investors comparing investment structures can also read ALTPORT's guide to PMS vs AIF vs mutual funds.

How to Invest in Sameeksha India Flexicap Equity Fund through ALTPORT

Investing through ALTPORT can begin with an eligibility and suitability review for the GIFT City Category III AIF.

The broad process involves:

1. Investor eligibility assessment
2. KYC and identity verification
3. FATCA/CRS and applicable regulatory documentation
4. Review of the latest PPM and contribution agreement
5. Subscription documentation
6. Required bank remittance in the applicable currency
7. Completion of fund onboarding and allocation

Investors should review the current offering documents carefully before making any investment decision.