ELITE PHARMACEUTICALS INC /NV/ (ELTP) – Company response
2026-03-18 · Re: · Accession 0001493152-26-011126 · Agreed to revise
Responds to staff letter of 2026-03-04.
ASC 606: Revenue RecognitionSegment Reporting (ASC 280)Risk Factors
2026-03-04 · Elite Pharmaceuticals, Inc. Form 10-K for the Fiscal Year Ended March 31, 2025 Filed June 30, 2025 · Comment 1 · Revenue Recognition, page F-8 Agreed to revise
Staff comment: We note your disaggregation of revenue disclosure provided on page F-9 as well as the information provided in your February 20, 2024 response letter, specifically your response to comment four. You state that you disaggregate your revenue based on type of good or service (e.g., manufacturing and license fees) and regulatory pathway (e.g., ANDA vs NDA). Please address the following: • Given that you have paused further development of NDAs and do not appear to have engaged in business activities in this segment since 2021, explain to us how disaggregation by regulatory pathway provides a meaningful level of disaggregation of your revenues. • In your February 20, 2024 response to prior comment… letter →
Company response: letter, specifically your response to comment four. You state that you disaggregate your revenue based on type of good or service (e.g., manufacturing and license fees) and regulatory pathway (e.g., ANDA vs NDA). Please address the following: ● Given that you have paused further development of NDAs and do not appear to have engaged in business activities in this segment since 2021, explain to us how disaggregation by regulatory pathway provides a meaningful level of disaggregation of your revenues. U.S. Securities and Exchange Commission ● In your February 20, 2024 response to prior comment four, you stated that when determining the level of revenue disaggregation, you considered the… response letter →
2026-03-04 · Elite Pharmaceuticals, Inc. Form 10-K for the Fiscal Year Ended March 31, 2025 Filed June 30, 2025 · Comment 2 · Note 14. Segment Results, page F-23 Agreed to revise
Staff comment: You disclose that Consolidated Loss from Operations is the measure of segment profit or loss that is regularly reviewed by your CODM and that this measure is reported in your Consolidated Statements of Operations. Your disclosure on page F-24, however, of Operating Income by Segment does not tie to your Consolidated Statements of Operations. With a view towards future disclosure, clarify for us your measure of segment profit or loss and provide us with the components of such measure and illustrate how it ties to your Consolidated Statements of Operations. Please also ensure that all of the information required by ASC 280-10-50-22 is disclosed in your future filings. letter →
Company response: The Company acknowledges the Staff’s comment and clarifies that the Chief Operating Decision Maker (“CODM”) regularly reviews Consolidated Income from Operations as the measure of segment profit or loss, which is reported in the Company’s Consolidated Statements of Operations. The Company notes that the presentation of Operating Income by Segment in Note 14 did not clearly reconcile to the Consolidated Statements of Operations. The Company will include Income (Loss) from Operations as a line item within the segment results table to facilitate reconciliation in future filings as follows: For the Years Ended March 31, 2025 2024 Operating income by segment $ 32,121,818 $ 19,473,752 Corporate… response letter →
2026-03-04 · Elite Pharmaceuticals, Inc. Form 10-K for the Fiscal Year Ended March 31, 2025 Filed June 30, 2025 · Comment 3 · the information required by ASC 280-10-50-22 is disclosed in your future filings. Agreed to revise
Staff comment: As a related matter, with a view towards future disclosure, provide us with the information required by ASC 280-10-50-26A through 50-26C as it relates to significant segment expenses and other segment items. letter →
Company response: The Company acknowledges the Staff’s comment and confirms there are no significant segment expenses or other segment items that are separately provided to the CODM beyond research and development and general and administrative expenses. The CODM does not receive segment-level information related to depreciation, amortization, capital expenditures, or other non-cash items, and therefore such items are excluded. Going forward, the Company will enhance its segment disclosures to explicitly address the requirements of ASC 280-10-50-26A through 50-26C, including clarifying that significant segment expenses are presented in the Consolidated Statements of Operations and that no additional… response letter →
Full letter on EDGAR → · Filing index · All ELITE PHARMACEUTICALS INC /NV/ (ELTP) correspondence
ASC 606: Revenue Recognition – what to check: Confirm each performance obligation, timing (point vs. over time) and significant judgments are disaggregated and explained, not boilerplate ASC 606 language.
Segment Reporting (ASC 280) – what to check: Check ASU 2023-07 significant segment expense disclosure, CODM identification, and that MD&A segment discussion matches the ASC 280 note.
Risk Factors – what to check: Replace hypothetical risks with ones that have materialized and update for current events.
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