Under Section 42, the maximum number of persons to whom a private-placement offer can be made in a financial year (excluding QIBs and ESOP employees) is:

1. Section 42(2) caps the offerees at 200 in a financial year per kind of security. 2. QIBs and employees receiving ESOPs are excluded from this 200 limit. 3. Hence (D). _Source: ICAI BoS CA Inter Paper 2 — Prospectus and Allotment_