WRONG!!! I am well aware UCPA's "Holding Company" However, you are not aware on how the corporate organizational structure. Under 2013 Act a private limited company can issue shares only using the methods prescribed in the Act. Under the 1956 Act a private limited company could issue shares by passing a board resolution.
As per section 23 (The Act) of the companies act private company may issue securities by way rights issue, bonus issue or private placement.
They can offer security by invitation or to a select group of persons. The company may if authorized passed in a general meeting they can issues shares in any manner whatsoever including by way of a preferential offer, to any person whatsoever.
You might consider read some of their filings below. Private company do offer shares only not to the public. I providing you with a link below. If you digging deeper you will literally find your argument without exaggeration. Good luck with that.