TaxTMI 
TaxTMI 
2016 (3) TMI 1321
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....o December 31, 2015. On further scrutiny it was observed that earlier , during January 17, 2013 to June 04, 2013, the price of the scrip had increased from Rs. 11/- to Rs. 36.25/ in 36 trading days and average trading volume during this period was merely 280 shares per day with average number of trade as low as 3 per day. For the purposes of preliminary examination of facts and circumstances prevailing during these periods these periods were taken in three patches i.e., (a) January 17, 2013 to June 04, 2013 (Patch -1) , (b) July 22, 2013 to November 05, 2014 (Patch-2) and (c) November 07, 2014 to December 31, 2015 (Patch -3). The price movement vis-a-vis traded volume in the scrip during this period is illustrated below: 2. During preliminary examination several acts and omissions, in connection with dealing in shares of Kailash Auto having a bearing on the securities market, including layering of funds, circulation of funds and securities, amongst inter -connected parties for acquisition and divestment of securities of connected unlisted private companies and corporate actions including capital reduction, issuance of bonus shares, private placement and merger of such ....
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....s acquired by Careful Projects Advisory Ltd. (hereinafter referred to as "CPAL") and Panchshul Marketing Ltd. (hereinafter referred to as "PML") who had together acquired shares amounting to 69.81% of the total paid-up share capital of the company from Padma Impex Ltd., the erstwhile promoter of Kailash Auto through a share purchase agreement dated May 02, 2012. Consequently, the board of directors of Kailash Auto had approved CPAL and PML as promoters of Kailash Auto. (b). On November 22, 2012, the board of directors of Kailash Auto had agreed for reduction of share capital of Kailash Auto and merger of CPAL and PML with Kailash Auto. The scheme of reduction of share capital of Kailash Auto and amalgamation of CPAL and PML with it were approved by the Hon'ble High Court of Allahabad and the Hon'ble High Court Bombay vide separate orders dated May 9, 2013 and May 10, 2013, respectively. The swap ratio for the amalgamation was approved as follows: (i) The paid up value per share of the transferee company (Kailash Auto) would be of Rs. 1/- each, fully paid up post reduction of capital. (ii) The paid up value per share in the transferor companies (CPAL and....
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....03/2011 Shivratri Merchants Pvt. Ltd. 83,300 31/03/2011 Solty Dealtrade Pvt. Ltd. 1,58,300 31/03/2011 Speedwell Enclave Consultancy Pvt. Ltd. 1,73,300 31/03/2011 Timeless Suppliers Pvt. Ltd. 1,48,300 Total 33,01,550 (f). During the Financial Year 2011-12, CPAL had a paid up share capital of Rs. 285,686,800/- consisting of 285,686,800 shares of Rs. 1/- each. CPAL had increased its authorised share capital from Rs. 3,450,000/- to Rs. 290,000,000/- and then its shares were split from Rs. 10/- each to Rs. 1/- each, thereby converting 340,155 equity shares of Rs. 10/- each into 3,401,550 equity shares of Rs. 1/- each. (g). Thereafter, during the same financial year, CPAL had issued 187,085,250 equity shares of Rs. 1/- each as bonus shares in the ratio of 55 shares for 1 share and further issued 95,200,000 equity shares of Rs. 1/- each through private placement. The list of the persons who received bonus shares, and persons who were allotted shares in this private placement amongst others (hereinafter referred to as the "recipients of CPAL shares") is given in the following Table: Table 2- List of recipients of CPAL Shar....
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.... 30,800 31/03/2011 Mahadhan Vincom Pvt. Ltd. 31,250 31/03/2011 Pushpdant Tradelink Pvt. Ltd. 13,500 31/03/2011 Pushpdhara Dealer Pvt. Ltd. 46,000 31/03/2011 Pushpmala Vinimay Pvt. Ltd. 12,700 31/03/2011 Ranpriya Tradevin Pvt. Ltd. 40,500 31/03/2011 Safeline Developers Advisory Pvt. Ltd. 8,500 31/03/2011 Saptrishi Agencies Pvt. Ltd. 9,400 31/03/2011 Speedwell Enclave Consultancy Pvt. Ltd. 5,600 31/03/2011 Superdeal Vincom Pvt. Ltd. 7,800 31/03/2011 Timeless Suppliers Pvt. Ltd. 20,000 Total 3,36,900 (j). During the Financial Year 2011-12, PML had a paid up share capital of Rs. 300,224,000/- consisting of 30,02,24,000 shares of Rs. 1/- each. PML had increased its authorised share capital from Rs. 1,00,00,000/- to Rs. 31,00,00,000/-. and then its shares were split from Rs. 10/- each to Rs. 1/- each, thereby converting 3,46,900equity shares of Rs. 10/- each into 34,69,000 equity shares of Rs. 1/- each. (k). Thereafter, during Financial Year 2011-12, PML had issued 225,485,000 equity shares of Rs. 1/- each as bonus shares in the ratio of 65 shares for 1 share a....
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..... 4. Saptrishi Agencies Pvt. Ltd. 5. Superdeal Vincom Pvt. Ltd. 2. Dhankuber Dealcomm Pvt. Ltd. 3. Manikaran Dealtrade Pvt. Ltd. 52, Weston Street, 4th Floor, Kolkata- 700012 6. Fairlink Realtors Consultants Pvt. Ltd. 7. Intecity Complex Consultants Pvt. Ltd 8. Safeline Developers Advisory Pvt. Ltd. 4. Needful Projects Advisory Pvt. Ltd. 5. Solty Dealtrade Pvt. Ltd. 8, Netaji Subhash Road, Kolkata-700001 9. Mahadhan Vincom Pvt. Ltd. 10. Pushpmala Vinimay Pvt. Ltd. 6. Panchshul Marketing Pvt. Ltd. 7. Shivratri Merchants Pvt. Ltd. 8. Pushapmala Vinimay Pvt. Ltd. 310, C.R. Avenue, Kolkata-700006 11. Pushpdant Tradelink Pvt. Ltd. 9. Gannayak Sales Pvt. Ltd. 9/12, Lal Bazar Street, 3rd Floor, Kolkata -700001 12. Pushpdhara Dealer Pvt. Ltd. 13. Speedwell Enclave Consultancy Pvt. Ltd. 14. Timeless Suppliers Pvt. Ltd. 10. Speedwell Enclave Consultancy Pvt. Ltd. 11. Timeless Suppliers Pvt. Ltd. 26, W.C. Banerjee Street, Near Girish Park, Kolkata-700006 Table - 6 Common directors of primary allottees of CPAL and PML Common Directors primary allottees of PML primary allottees of CPAL Hanish Toshniwal Confident Van....
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....ow: Table 8 - Key financial figures of Kailash Year FY13-14 ( Rs. in crore) FY12-13 ( Rs. in crore) FY11-12 ( Rs. in crore) FY10-11 ( Rs. in crore) Operating Income 20.41* 0.34 0.13 0.35 Operating & Administration Expenses 18.88* 0.3 0.1 0.12 Employee Expense 0.05 0.02 0.05 0.1 Adjusted Net Profit 0.84 0.01 -0.21 -0.17 Price Earning (P/E) 4,065.00 0 0 0 EPS 0.01 0 -0.51 0 Price to Book Value ( P/BV) 41.06 22.14 0 0 Price/Cash EPS (P/CEPS) 2,841.14 1,27,400.70 0 0 EV/EBIDTA 0 0 0 0 Source: Capitaline and BSE *Operating income reported during April 2013 to March 2014 is 20.41 crores. Company has clarified to BSE that this value of 20.41 crores is sales value of securities sold in the market during the FY 13-14. Also the operating administrative expense reported 18.88 crores is the buy value of securities bought from the market during the FY 13-14. (r). Considering the operating performance and net profit of CPAL and PML in the year of incorporation 2010-11 and Financial Yea....
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....vt. Ltd. to PML and CPAL, within a short span of time, the price of the scrip increased significantly which continued till July 22, 2013 when new category share (after amalgamation) of Kailash Auto was listed and permitted for trading on BSE. (w). The above findings indicate that CPAL and PML were incorporated with a dubious plan and premeditated arrangement and artifice to increase number of shares therein through sham and non-genuine transactions with regard to issuance of their shares which resulted in fetching exorbitant and unrealistic consideration in the scheme of amalgamation. 6. In order to analyse the price volume pattern, the trading in the scrip of Kailash Auto was analysed in the aforesaid three patches with a focus on the following:- (a). trading frequency; (b). trading volume generated; (c). contribution to price rise. 7. During the analysis it was noticed that certain entities related/connected to Kailash Auto were found to be the net buyers to the beneficiaries and thereby created artificial demand for the supply of shares from beneficiaries. From the Know Your Client (KYC) details, their bank statements, off-market transactions ....
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.... trades during this period. It was also noticed that these entities by putting 1 or 2 trades per day with negligible/very less quantity of buy order contributed significantly to the price rise. From last traded price ("LTP") analysis, it was observed that price of the scrip increased from Rs. 11 to Rs. 36.25 mainly through first trades on 27 instances. Out of these 27 instances, Shyam Kanheyalal Vyas and Bharat Bagri (HUF) established new high price on 13 instances. Out of total price rise of Rs. 25.75/-, the contribution of these two entities in establishing new high price was Rs. 14.57/- which constitutes 56.58% of the total new high price. It was noted that the counterparty client to the trades of these two entities (in most of the cases) were PML, Overall Vincom Pvt. Ltd. (forming part of recipients of PML shares) and Bholebaba Suppliers Pvt. Ltd. (an entity from Kailash Auto Group I). The scrip was an illiquid one at that point of time and there was negligible trading therein at that time. Considering this fact and that the connected entities of Kailash Auto were counter parties to the trades of these two entities it was prima facie observed that these two entities alongwith P....
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....ng for such shares was 1 or more years) at an average price of Rs. 35/- which was artificially increased on the platform of the stock exchange and in the process made huge profit of approximately 3400% on their investment in a period of 12 months or more. The profit/gain earned by beneficiaries during Patch-2 is detailed in the following Table:- Table 11 - Profit made by the beneficiaries Beneficiaries breakup (in terms of unit sold) No. of beneficiaries Total quantity sold Total sell quantity (%) Estimate amount of money converted/ profit made 10 lakh and more 39 7,93,15,052 17.03 2,69,67,11,768 6 lakh and more - Less than 10 lakh 38 2,71,32,692 5.83 92,25,11,528 5 lakh and more - Less than 6 lakh 41 2,08,81,373 4.48 70,99,66,682 2 lakh and more- Less than 5 lakh 530 14,19,23,451 30.48 4,82,53,97,334 1 lakh and more - less than 2 lakh 939 10,69,55,216 22.97 3,63,64,77,344 below 1 lakh 2005 8,94,82,608 19.22 3,04,24,08,672 Total 3592 465690392 100 15,83,34,73,328 13. At this stage, it was observed that 118 beneficiaries had sold 5 lakh shares or mo....
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.... identity of ultimate owners of fund. 16. Immediately after receipt of funds in the above manner, the entities of Kailash Auto Group I and Kailash Auto Group II traded in this scrip only through purchase transactions from beneficiaries in Patch II and created substantial traded volume during this period. These entities had transferred these funds, directly /indirectly to trading members through whom they had traded in this scrip and other scrips involving transactions for the purpose of alleged bogus long term capital gains tax exemption. Considering the income of these entities as shown in their KYC documents and the volume of their transactions, it was noted that their transaction were not commensurate with their disclosed income. Thus, it was observed that such fund transactions between promoter/promoter related entities of Kailash Auto and the entities of Kailash Auto Group I and Kailash Auto Group II were primarily for the purchase of equity shares of Kailash Auto by them from beneficiaries who are also connected /related, directly or indirectly, with CPAL and PML as discussed hereinafter. 17. From the bank statements of few beneficiaries (considering the volume of trans....
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....of 185.88%, again during the period from June 22, 2015 to December 31, 2015, price of the scrip plunged to Rs. 2.01/- on December 31, 2015 amounting to price fall of 83.45%. During Patch -3 daily average trading volume was reduced to 7 lakh shares in comparison of daily average trading volume of 15 lakh shares during Patch -2. During Patch -3 total volume traded in the scrip of Kailash Auto was 20.49 crores shares and out of this, 352 beneficiaries had offloaded 4.96 crores shares of Kailash Auto in the market at an average price of Rs. 12.65/-. Counterparties to such trade forming part of Kailash Auto Group I and Kailash Auto Group II contributes to 40 % of total volume offloaded by beneficiaries in Patch -3. It is noted that in the Patch -3 trading volume concentration by beneficiaries and entities of Kailash Auto Group I and Kailash Auto Group II was significantly low compared to Patch -2. During Patch -2 beneficiaries accounted for 94.32% of gross sell volume and Kailash Auto Group I and Kailash Auto Group II cumulatively accounted for 35.47% of gross buy volume, however in Patch -3 beneficiaries accounted for only 24.21% of gross sell volume and Kailash Auto Group I and Kailas....
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....ch -3 the downward trend in the trading volume and price of the scrip of Kailash Auto was on account of the trades of the beneficiaries who were exiting from the market. (c). Purported consideration for transfer of equity shares of CPAL and PML by the recipients of CPAL shares and recipients of PML shares was paid by the beneficiaries and the same was transferred, directly or through multiple layering, by recipients of CPAL shares and recipients of PML shares to the entities belonging to Kailash Auto Group I and Kailash Auto Group II or entities controlled by CPAL/PML. (d). Entities of Kailash Auto Group I and Kailash Auto Group II were being funded by different sources including the current promoter group of Kailash Auto to buy shares of Kailash Auto from the beneficiaries and provide exit to them from the market. Kailash Auto Group I and Kailash Auto Group II had received the funds via multiple layering /transfer of funds so as to mask the true identity of ultimate owner of fund. (e). The key financial figure/ratio of Kailash Auto was unfavourable and well below the industry standards. The company operating revenue and operating expenditure depicts that....
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.... by primary allottees to recipients of CPAL shares/recipients of PML shares and bonus issues were prima facie sham transactions. Such increase in paid up share capital of CPAL and PML through sham transactions gave rise to an elaborate edifice of unrealistic liquidity, i.e., the trading volume surged by 5577 times during Patch- 2 as compared to trading volume in Patch- 1. 22. After receipt of shares of CPAL and PML from the primary allottees, the recipients of CPAL shares and recipients of PML shares transferred those shares to a large number of beneficiaries, who are also connected /related with recipients of CPAL shares and recipients of PML shares and these companies on the basis of fund transfers, at the average price of Rs. 1/- per share. Fund received by recipients of CPAL shares and recipients of PML shares from beneficiaries, as purported consideration for transfer of shares of CPAL and PML, were transferred to various other entities including CPAL and PML. Thus, CPAL and PML had used the recipients of CPAL shares and recipients of PML shares as conduit to facilitate the transfer of their shares to the beneficiaries. The beneficiaries who received the shares of CPAL and ....
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....stors in the scrip was created. After Patch -1 when beneficiaries started exiting to connected/related entities of Kailash Auto Group I and Kailash Auto Group II trading by gullible investors was witnessed. In Patch -2, substantial traded volume in the scrip was created on account of trading amongst the connected /related parties , namely, beneficiaries and the entities of Kailash Auto Group I and Kailash Auto Group II. Further, in Patch-3, price of the scrip plunged from Rs. 28.50/- to Rs. 2.01/- due to lower trading concentration by beneficiaries and entities of Kailash Auto Group I and Kailash Auto Group II. Thus during Patch- 2 the price in the scrip of Kailash Auto was maintained by the artificial demand supply forces fabricated through the phalanx of beneficiaries and entities of Kailash Auto Group I and Kailash Auto Group II. It has been observed that in Patch -3 the innocent and gullible investors had been lured into trading in the scrip of Kailash Auto and they had been entrapped in the price fluctuations of the scrip. In these facts and circumstances, I, prima facie, find that these connected entities, namely, the LTP contributors and connected counterparties to their tra....
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....discussed hereinabove are 'fraudulent', manipulative and deceptive under regulation 2(1)(c) of the SEBI (Prohibition of Fraudulent and Unfair Trade Practices relating to Securities Market) Regulations, 2003 ('PFUTP Regulations') and they have prima facie contravened the provisions of regulations 3(a), (b), (c) and (d) and 4(1), 4(2)(a), (b), (e) and (g) thereof and section 12A(a), (b) and (c) of the Securities and Exchange Board of India Act, 1992 (the SEBI Act). The said provisions are reproduced hereunder:- SEBI ACT Prohibition of manipulative and deceptive devices, insider trading and substantial acquisition of securities or control. "12A. No person shall directly or indirectly- (a) use or employ, in connection with the issue, purchase or sale of any securities listed or proposed to be listed on a recognized stock exchange, any manipulative or deceptive device or contrivance in contravention of the provisions of this Act or the rules or the regulations made thereunder; (b) employ any device, scheme or artifice to defraud in connection with issue or dealing in securities which are listed or proposed to be listed on a recognised stock e....
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....ange of ownership of such security;" 27. I am of the opinion that a detailed investigation of the entire scheme, plan, device and artifice employed by concerned entities and to find out the ultimate owners of funds used for facilitating the entire scheme, plan, device and artifice is necessary . I further note that during preliminary inquiry it has been observed that few of the recipients of CPAL shares and recipients of PML shares are connected with Vimit Consulting limited and Lahoti India Limited on the basis of common address and email Id. In view of the same, role of Vimit Consulting Limited, Lahoti India Limited and other entities may also be looked into during investigation in this matter. While SEBI would investigate into the probable violations of the securities laws, the matter may also be referred to other law enforcement agencies such as Income Tax Department, Enforcement Directorate and Financial Intelligence Unit for necessary action at their end as may be deemed appropriate by them. 28. It is pertinent to mention that there is no scale to measure fraudulent, deceptive and manipulative device, plan and artifice or its impact and the findings in that regard alway....
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..... The manipulation in the traded volume and price of the scrip by a group of connected entities as observed in this case has potential to further induce unsuspecting and gullible investors to trade in the scrip and harm them. Further, these connected parties have grossly misused the stock exchange system to generate bogus LTCG to aid and help beneficiaries to convert their unaccounted income into accounted one with no payment of taxes as LTCG is tax exempt. 30. SEBI strives to safeguard and protect the interests of a genuine investor in the Indian securities market. The acts of artificially increasing the price and traded volume in the scrip with mala fide intention to mislead investors and the fundamental tenets of market integrity get violated with impunity due for such acts. Under the facts and circumstances of this case, I, prima facie, find that the acts of Kailsah Auto Group I, Kailsah Auto Group II, beneficiaries, primary allottees of CPAL, recipients of CPAL shares, primary allottees of PML, recipients of PML shares and the LTP contributors as described above is inimical to the interests of participants in the securities market. Allowing the entities that are prima facie....
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....BPA9883M 7 Om Prakash Agarwal ACIPA3823H 8 Hitesh Ramprakash Chhatwal ADSPC4388E 9 Om Prakash Agarwal HUF AAAHO5501J 10 Rajesh Ramswarup Sarda AHAPS4925M 11 Shilpa Agarwal AHQPK3316G 12 Dharam Paul ACGPP5575P 13 Neeraj Kumar AGVPK7036P 14 Charanjeet Singh ADWPS5227Q 15 Rajesh Ramswarup Sarda HUF AADHS2286M 16 Kavita Jain AANPJ9910B 17 Sanjeev Jain ACFPJ3817P 18 Geetha Jain ADEPG7030K 19 Veena Rajesh Sarda AHAPS4880R 20 Ramasamy Santhamani ALJPS3141G 21 Satish Jain AAFPJ6142B 22 Dhirajkumar Khetan AAWPK2634C 23 Vikrant Kumar Khetan AAWPK2621F 24 GauravBhalotia ADAPB9680Q 25 Bhagwati Devi Patwari AEYPP3706L 26 N.Kanniah AAHPK8800D 27 Nikita Agarwal AOTPA7379H 28 Sanjib Kumar Patwari HUF AAPHS3236R 29 Priyanka Patwari ALSPK8179K 30 Sarika P....
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....m AFVPR5490R 78 Saloni Bhalotia AIKPK2010L 79 Prashant Singh Gaur APBPG5512R 80 Mohan Sharma ATUPS1008F 81 Hardik Loknath Gambhir AWPPG7383P 82 Sunil Kumar Patwari HUF AANHS6750A 83 Dhruv Gaba AQNPG3627J 84 Sandeep Mahendrabhai Shah AADPS4022M 85 Bal Krishna Saraf HUF AAFHB5197N 86 Neena Gaba AHQPG7050H 87 Jolly Pathak AHGPP6057P 88 Sunita Goyal AAFPG2351M 89 Pratapsinh Ganpatrao Jadhav AAYPJ1003C 90 Sher Singh Agarwal AAAHS9623K 91 Dinesh Shersingh Agarwal AAAPA5629D 92 Shiv Kumar HUF AABHS3053G 93 Pushpa Rani Nagpal AABPN0865H 94 Rajendra Neminath Shete AACHR9687J 95 Sitaram Ashok Kumar HUF AACHS4243P 96 Ramachandran Ananthan Pothi AACPP8620K 97 ShersinghAgarwal AADPA3198C 98 Sarda AAEHS0587A 99 Sanjay Kumar Agarwal AAOPA1798H 100 Anand Swaroop Rathi ....
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....Realinfra Pvt. Ltd. AASCS4307H 142 Dhanaasha Developers Pvt. Ltd. AAECD6470G 143 Tremendous Commodeal Pvt. Ltd. AAJCA0881H 144 Arrowlink Enclave Arrowlink Enclave Pvt. Limi AALCA5948F 145 Dhanaseth Properties Pvt. Ltd. AAECD6471H 146 Profitus Commodities Pvt.Ltd. AAHCP2079E 147 Casuarina Projects Pvt. Ltd. AAFCC2180B 148 Sarda Solutions Pvt. Ltd. AATCS2316K 149 Maxtor Conclave Pvt. Ltd. AAICM5727H 150 Seguro Construction Ltd. AASCS9516J KAILASH AUTO GROUP II 151 Nirdesh Trading Pvt. Ltd. AABCN1526E 152 Triala Dealers Pvt. Ltd. AAECT5548F 153 Cheroot Vanijya Pvt. Ltd. AAECC9285A 154 Quickscope Dealers Pvt. Ltd. AANCS8376B 155 Saktimata Marketing Pvt. Ltd. AARCS1549Q 156 Gainsay Property Pvt. Ltd. AAFCG2185A 157 Shivsathi Mercantile Pvt. Ltd. AASCS6284R 158 Sanmati Goods Pvt. Ltd. AAICS9154Q 159 Albino Overseas Pvt. Ltd. AAHCA6112B 160 Levia Trading Pvt. Ltd. AACCL5027D 161 Camellia Vinimay Pvt. ....
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....93J 207 Fairlink Realtors Consultants Pvt. Ltd. AABCF6890P 208 Intecity Complex Consultants Pvt. Ltd. AACCI4596G 209 Luckydhan Dealtrade Pvt. Ltd. AABCL9100E 210 Mahadhan Vincom Pvt. Ltd. AAGCM8231Q 211 Pushpdant Tradelink Pvt. Ltd. AAFCP7632P 212 Pushpdhara Dealer Pvt. Ltd. AAFCP7061C 213 Pushpmala Vinimay Pvt. Ltd. AAFCP7062B 214 Ranpriya Tradevin Pvt. Ltd. AAECR6282Q 215 Safeline Developers Advisory Pvt. Ltd. AAPCS1176D 216 Saptrishi Agencies Pvt. Ltd. AAPCS0805H 217 Speedwell Enclave Consultancy Pvt. Ltd. AAOCS9967P 218 Superdeal Vincom Pvt. Ltd. AAQCS3088M 219 Timeless Suppliers Pvt. Ltd. AADCT6337P 220 Dhankuber dealcomm Pvt. Ltd. AADCD6491L 221 Gannayak Sales Pvt. Ltd. AAECG0461G 222 Heaven Sales Pvt. Ltd. AACCH1686G 223 Manikaran Dealtrade Pvt. Ltd. AAHCM0524B 224 Needful Projects Advisory Pvt. Ltd. AADCN4461C 225 Panchshul Marketing Pvt. Ltd. AAFCP7060D 226 Shivratri Merchants Pvt. Ltd. AAOCS9331B 227 Solty Dealtrade Pvt. Ltd. AAPCS2058G RECIPIENTS OF CPAL AND PML SHARES ....
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....DFUL PROJECTS ADVISORY PVT. LTD. HEAVEN SALES PVT.LTD. CPAL SIMPLICITY ESTATE ADVISORY PVT. LTD. INTECITY COMPLEX CONSULTANTS PVT. LTD. SPEEDWELL ENCLAVE CONSULTANCY PVT. LTD. FAIRLINK REALTORS CONSULTANTS PVT. LTD. Circulation of fund of Rs.11,00,000/- through investment between CPAL and primary allottees on December 06, 2010 Document 3 MAHADHAN VINCOM PVT. LTD. FAIRLINK REALTORS CONSULTANTS PVT. LTD. HEAVEN SALES PVT. LTD. TIMELESS SUPPLIERS PVT. LTD. PML CPAL PUSHPADHARA DEALERS PVT. LTD. PUSHPAMALA VINIMAY PVT. LTD. NEEDFUL PROJECTS ADVISORY PVT. LTD. SPEEDWELL ENCLAVE CONSULTANCY PVT. LTD. CAREFUL MARKETING PVT. LTD. SIMPLICITY ESTATE ADVISORY PVT. LTD. INTECITY COMPLEX CONSULTANTS PVT. LTD. Circulation of fund of Rs.12,00,000/- through investment between PML, CPAL and primary allottees on December 13, 2010. Document 4 Step-1 •September 2010 •Incorporation of CPAL and PML with Share capital *1,00,000/- each. •March 31, 2011 •Private placement made by C....