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The Board found Noticees violated Regulation 13(b) of IA Regulations and Clause 1 of Code of Conduct for Investment Advisers by conducting unregistered investment advisory activities through six partnership firms while failing to disclose these activities during SEBI registration applications. The Designated Authority established that Noticees suppressed material facts and continued unauthorized advisory services even after obtaining individual registrations. Although DA recommended three-year restraint from new assignments, the Board noted Noticees were already debarred from securities market for two years and penalized Rs. 18,00,000 under separate proceedings. Considering existing sanctions, the Board exercised powers under Section 19 SEBI Act 1992 read with Regulation 27(5) to impose proportionate six-month restraint from accepting new assignments or contracts, finding three-year restriction disproportionate to meet justice requirements.
The Board found Noticees violated Regulation 13(b) of IA Regulations and Clause 1 of Code of Conduct for Investment Advisers by conducting unregistered investment advisory activities through six partnership firms while failing to disclose these activities during SEBI registration applications. The Designated Authority established that Noticees suppressed material facts and continued unauthorized advisory services even after obtaining individual registrations. Although DA recommended three-year restraint from new assignments, the Board noted Noticees were already debarred from securities market for two years and penalized Rs. 18,00,000 under separate proceedings. Considering existing sanctions, the Board exercised powers under Section 19 SEBI Act 1992 read with Regulation 27(5) to impose proportionate six-month restraint from accepting new assignments or contracts, finding three-year restriction disproportionate to meet justice requirements.
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