What is the mechanism for obtaining UBO information by a company, having legal person(s) as its members, from ultimate beneficial owners?

Following procedure is to be followed to ensure compliance with the requirements to obtain and maintain ultimate beneficial ownership information.
1) In respect of members of a company, say Company X, who are natural persons and hold not less than 10% ownership or controlling rights in it, no information would be required to be entered in the register of UBO because their particulars would already being maintained and recorded in the register of members of Company X under section 119 of the Act read with regulation 19 of the Regulations.
2) Company X will circulate the letter requiring ultimate beneficial ownership information from those members who:
(i) are legal persons, i.e. other than natural persons or individuals, and

(ii) have not less than 10% ownership or controlling stake in Company X;

3) A Company Y which is a member of Company X and in receipt of the above letter from Company X will then;

(i) in respect of its members who are natural persons and hold not less than 10% ownership or controlling interest, extract information from its register of members required under section 119 of the Companies Act, 2017 read with regulation 19 of the Companies (General Provisions & Forms) Regulations, 2018, for provision to Company X. It may be noted that the sets of information required vide clause 4 of circular no. 16 and that vide regulation 19 of the Regulations are almost identical;
(ii) in respect of its members who are legal persons and hold not less than 10% ownership or controlling interest, circularize the requirement as requested by Company X;

4) If there is another company or legal person in the ownership chain which is a member of Company Y, as per sr. no. 3(ii) above, the aforesaid process as mentioned in sr. no. 3(i) above will be repeated, until the natural person or individual exercising ultimate ownership or control and lying at the end of the ownership chain is reached;

5) Company Y will provide the information available with it in its register of members in respect of members who are natural persons as at sr. no. 3(i), and that received from members who are legal persons as at sr. no. 3(ii) and 4 above, to Company X;
6) Company X will enter the particulars of those natural persons who are members of Company Y and of any other legal person up the ownership chain, and have ultimate shareholding or controlling interests of not less than 10% in Company X through Company Y, in the register of ultimate beneficial ownership as specified in terms of Circular no. 16 of 2018;
To illustrate, assume that Company X has Company Y as its member with 50% shareholding in it, and Company Y has two individuals as members i.e. Mr. A and Mr. B with 90% and 10% shareholding respectively in Company Y. In this case, the indirect or ultimate beneficial ownership of Mr. A in Company X would be 45% (50%x90%) and that of Mr. B in Company X would be 5%(50%x10%). Accordingly, particulars of Mr. A would be required to be maintained by Company X.
For the purpose of compliance with Circulars no. 16 and 20 of 2018, Company X would enter the particulars of Mr. A in its register of ultimate beneficial ownership only. The ultimate or indirect shareholding of 5% possessed by Mr. B in Company X being less than the requisite ultimate shareholding of 10% would not be reflected on the said register.