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The AT dismissed the appeals and upheld the regulatory order finding fraudulent issuance of GDRs to create a false impression of USD 24.25 million foreign subscription. The tribunal concluded the first appellant and the company materially altered and acquiesced to a pledge agreement with a foreign bank, evidencing control over funds and subsequent interest remittal, notwithstanding absence of genuine receipt of subscription monies. The AT affirmed restraint from securities market access for three years and imposition of monetary penalties for contraventions of statutory provisions and PFUTP regulations, holding the appellants' contentions on board authorisation and alleged bona fides to be unavailing and the impugned order free of legal infirmity.