2015 (6) TMI 1216
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....BSE on different dates during January 2013 to March 2013. Securities and Exchange Board of India ("SEBI") noticed huge rise in the traded volumes and prices of these scrips during the period from January 01, 2013 to December 31, 2014 and in this background undertook a preliminary inquiry in the dealings in the aforesaid scrips. 3. It was noticed in the preliminary inquiry that the price of all theses rips increased astronomically during the period from the date of listing of the said scrips till December 31, 2014 in the following manner: - a) the price of the scrip of Eco rose by 6,265% (approx. 64 times) during the period January 14, 2013 to December 31, 2014 within a span of 234 trading days. b) the price of the scrip of Esteem rose by 3,150% (approx. 32 times) during the period February 07, 2013 to December 31, 2014 within a span of 244 trading days. c) the price of the scrip of CNE rose by 2,882% (approx. 30 times)during the period March 12, 2013 to December 31, 2014 in a span of 225 trading days. d) the price of the scrip of HPC rose by 1,782% (approx. 19 times) during the period March 19, 2013 to December 31, 2014 in a span of 252 trading days. 4. The unusua....
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....m, CNE, respectively. Goldline was further allotted equity shares on preferential basis by these companies on different dates as described below: l On May 19, 2012, Eco issued additional 2,02,500 shares at a price of Rs. 10/- per share . l On May 18, 2012, Esteem issued additional 3,02,600 shares at a price of Rs. 10/- per share. l During the period 30/04/2011 to 25/10/2012, CNE issued additional 3,33,000 shares (63,000 shares at a price of Rs. 750 and 2,70,000 shares at a price of Rs. 130). 9. It was noted that HPC also issued shares in preferential allotment during December 2012 to January 2013. Mayfair Infosolution Private Limited (8,00,000 shares), All Time Builtech Private Limited (6,80,300 shares) and AMS Powertronic Private Limited (5,80,000 shares) were from amongst the entities who were issued majority of shares in the said preferential allotment by HPC. 10. Further, immediately after issuing shares on preferential basis, Eco, Esteem and CNE issued bonus shares in the ratio of 1:3 and HPC issued bonus shares in the ratio of 1:1. Consequent to the preferential allotments and bonus issues, the share capital of these companies increased manifold as detail....
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....ions"), the pre-IPO holdings of promoters of all the issuer companies were locked-in for a period of three years and that of persons other than promoters were locked-in for a period of one year from the date of allotment in respective IPO. 14. It was observed that 30,24,000 shares were allotted to 295 entities in the IPO of Eco, 45,18,000 shares were allotted to 471 entities in the IPO of Esteem, 46,86,000 shares were allotted to 321 entities in the IPO of CNE and 45,60,000 shares were allotted to 541 entities in the IPO of HPC. It has been observed during preliminary inquiry that a set of common entities were funding the IPO of all the aforesaid companies either through directly transferring the amount in the escrow account of the companies on behalf of certain IPO allottees or by transferring the amount to the concerned IPO Allottees' bank accounts, who, in turn, applied for the shares in IPO. Based on Ministry of Corporate Affairs ("MCA") website, bank statement analysis and KYCs of all the entities who funded the aforesaid IPOs, it is observed that they are related/connected with each other. All these entities are hereinafter collectively referred to as "Funding Group". ....
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....ltech Private Limited. Further, Ram Prakash and Sumit Kumar share common Mobile No. 8527896710 registered with the broker 'Century Finvest Private Limited'. Ram Prakash received funds in the bank account of his proprietary firm, Aggarwal Traders, from Shiv Traders, Proprietary Firm of Mr. Prakash Gupta, which he used for funding 6 entities for subscribing to the IPO of Eco. 9 Mr. Prakash Gupta through his proprietary firm Shiv Traders ARVPG7849R (Bank Account No. 211150050800237 with Tamilnad Mercantile Bank) Shiv Traders transferred an amount of Rs. 48.02 Lakh to Ram Prakash, who, in turn, funded the IPO of Eco. Further, Shiv traders also have fund transactions with AMS and Mayfair 15. It is observed that the Funding Group financed Rs. 5,25,00,000/- for the IPO of Eco, which constitutes 69.44% of the issue size; Rs. 4,06,50,000/- for the IPO of Esteem, which constitutes 35.99% of the issue size; Rs. 4,08,00,000/- for the IPO of CNE, which constitutes 34.83% of the issue size; and Rs. 4,22,80,000/- for the IPO of HPC, which constitutes 26.49% of the issue size. The summary of funding and subscriptions in all the companies by Funding Group is given below: ....
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.... Solar Fencing 0.65 - - - Brand Building and General Corporate purposes 0.6 0.8 0.6 1 Issue Expenses 0.6 0.7 0.57 0.8 Setting up of Shade Net Cultivation facility - 3.8 - - Procurement of farm tools and equipments - 0.3 - 0.38 To finance the estimated expenditure of production of 2 films - - 7 - Strengthening Distribution operations - - 3.5 - Development of Green House cultivation - - - 3.27 Strengthen Supply Chain Management - - - 2.5 Total 8.05 11.25 11.67 15.85 18. It was noted that Eco in its ICICI Bank account No 663005119443, received Rs. 7,30,00,000/- as IPO proceeds on January 12, 2013 and Rs. 16,00,000/- on January 16, 2013. Esteem, in its HDFC Bank Account No.00032560005478, had received Rs. 11,07,50,000/- on February 07, 2013 and Rs. 12,50,000/-on February 16, 2013. CNE, in its HDFC Bank Account No.00032000044469, had received Rs. 11,53,50,000/- on March 12, 2013 and Rs. 18,00,000 on March 20, 2013 and HPC, in its Oriental Bank of Commerce Bank Account No. 10481010067720, had received Rs. 15,75,00,000/- on March 19....
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....0 26 Ridhisidhi Financial Services pvt Ltd 5,000,000 27 Saroj Mittal 5,000,000 28 Sirohi Investment 5,000,000 29 Vam Realcon Pvt Ltd 5,000,000 30 Zealous Financial Services Pvt Ltd 5,000,000 31 IRA MALHOTRA 4,800,000 32 Garg traders and Suppliers 4,500,000 33 Raj Marketing India 4,500,000 34 KHALID ALI 2,500,000 35 Moongipa Commodities 2,500,000 36 Jindal Infrastructure 2,000,000 37 Avisha Credit Capital Ltd * 15,50,000 1,600,000 38 Amit Jain 1,500,000 39 Farhat U Nisa 1,500,000 40 Agi Hospitality 1,000,000 41 INNTAL TRADING PV 1,000,000 42 Mehnaz Faizan &nb....
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...., the return of IPO proceeds to financers of the allottees does not appear to be for any legally authorised purpose. Further, the said companies did not make any disclosure under clause 46 (a) read with (c) of SME Listing Agreement indicating such deviation in the use of IPO proceeds. 25. It was observed that during the period when the pre -IPO shares were under lock-in, the volume in the scrips was very low, but the price of all the scrips increased manifold. It was also observed that after the release of lock-in, there was substantial increase in traded volume and price of the scrips. As mentioned above, all these companies had poor fundamentals. It was further noted that none of these companies had made any announcement regarding their business or any other corporate action, which could impact the price of the scrips in the manner as observed hereinabove. Thus, the sharp rise in the price of these scrips during the examination period was not supported by fundamentals or any other genuine factor. The summary of average traded volume and astronomical price rise in the scrips during the relevant period is given in the following tables: Table 9:- Average Traded Volume in all t....
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.... & RamPrakash (5231919). Ramprakash (AXFPR4439L) and Ramprakash ( Din No. 5231919) have common address i.e. 290B, JATWARA, SIHANIGATE, GHAZIABAD, 201001, Uttar Pradesh, INDIA 4 AKFPV6256L Ashvin Verma On analysis of Axis Bank Account statement of Ashvin Verma A/c no. 913020041958004, it was found that it has received Rs. 26.21 crore funds from A- one furnitutre ( Proprietary firm of Mr. Madhukar Dubey) during the period 07/02/2014- 02/04/2014 which was immediately transferred to the broker Integrated Master Securities Pvt. Ltd.. It has been observed that there is no transfer of funds to A one furniture which raises suspicion. 5 ASPPV7875F Sunila Rai Verma As per KYC Submitted by Integrated Master Securities Pvt Ltd & Ashlar Securities Pvt Ltd to BSE, it was observed that Sunila Rai Verma &Ashvin Verma share common address viz:- 46-C/2, Gali No.15, East Azad nagar, Delhi 110051 6 APJPK8855K Pawan Kumar Kaul Pawan Kumar Kaul is connected to Ashvin Verma on the basis of common contact number i.e. 8130034611 & 9810514638. They are also connected on the basis of same email id i.e. [email protected] 7 AALCS3282L Surya Medi Tech Limited Sur....
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.... Impex Private Limited Dharmendra Kumar is one of the directors of Blue Star Impex Private Limited and Maheshiv Metals Alloys Pvt Ltd. Mr. Dharmendra Kumar subscribed to the IPO of HPC and CNE, for subscription he received funds from Funding Group entities.. 22 AAFCM3345L Mahashiv Metal And Alloys Private Limited 23 APBPK8097B Jai Kishan Jai Kishan is director of Kirti Advertisement Pvt Ltd which received Rs. 1Crore from CNE. 24 AKEPG0828N Shankar Lal Gupta Jai Kishan and Shankar Lal Gupta are common directors in G-Trading India Private Limited. 25 AABCU4900D Unite Buildcreate Private Limited As per MCA database, Jai Kishan is director in Unite Buildcreate Pvt Ltd. 26 AETPG3006K Baidya Nath Gupta Baidya Nath Gupta & Santosh Kumar share Same address i.e. . Further there is off market transfer with Aavia Softech Pvt ltd on 31/03/3014. Ram Prakash is one of the directors of Aavia Softech Pvt. Ltd. 27 AEKPK6751Q Santosh Kumar 27. It was observed that the Trading Group had contributed to the rise in price of the all four scrips by pushing up the price through positive contribution to the last traded price (LTP) on s....
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.... 2 0.85 3 0 0 18 3 AAFCM3345L Mahashiv Metal And Alloys Pvt Ltd 0 0 22.55 13 4.15 4 15.2 23 AAICA0771D Ahuja Metalloys Private Limited 0 0 0 0 3.9 5 10.35 10 AAICM3230H Murlidhargiri Trading Pvt. Ltd. 0 0 0 0 26.7 21 530 62 AETPG3006K Baidya Nath Gupta 1.85 3 11.55 7 0 0 0 0 ASPPV7875F Sunila Rai Verma 15.2 22 6.1 2 0 0 0 0 DWOPS8186Q Amit Kumar Saxena 23.2 8 0 0 0 0 0.05 1 AABCU4900D Unite Buildcreate Pvt Ltd 0 0 0 0 11.5 7 4.85 10 AAACC2840D Core Capital Services Limited 0 0 14.5 1 0 0 0 0 AALCS3282L Surya Medi Tech Limited 0.25 4 0 0 0 0 0 0 AATCS2130B Steady Capital Advisory Sercices Pvt Ltd 0 0 0.9 7 0 0 0 0 AATCS2129L Sure Portfolio Services Pvt Ltd 0 0 34.15 14 0 0 0 0 Trading Group Total 733.75 343 656.5 357 337.85 214 1755.85 390 Market Total 1123.8 516 1116.55 522 1770.6 677 612....
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....tial allottees and 36 pre-IPO transferees made a collective profit of Rs. 171.82 crore on a collective investment of Rs. 0.97 Crore, i.e. a whopping return of approximately 17,606%. Likewise, in the scrip of Eco, 32 preferential allottees and 27 pre-IPO transferees made a collective profit of Rs. 87.23 crore on a collective investment of Rs. 0.49 Crore, a whopping return of approximately 17,566%. Also in the scrip of CNE, 75 preferential allottees made a collective profit of Rs. 103.93 crore on a collective investment of Rs. 0.62 Crore, a whopping return of approximately 16,713%. It is noteworthy that the aforesaid returns by the preferential allottees and the pre-IPO transferees were made only within a period of 20-24 months (including the lock in period of the shares allotted in the preferential allotment) and the profits were made in scrips where not only the fundamentals/financials of the companies do not justify the substantial price rise but also the price was increased to unrealistic levels by manipulative trading by the Trading Group. 32. Further, on analysis of bank statements of few entities belonging to Trading Group it was noted that bank accounts of these entities h....
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....and net worth declared by it. 34. Considering the large number of preferential allottees and pre IPO transferees, at this stage, all those entities who have made a profit of Rs. 1 crore or more in a scrip were shortlisted. Accordingly, a set of 186 such entities (hereinafter referred to as "shortlisted Group"), were identified. The particulars of members of Shortlisted Group are given in the following table: Table 14: Members of Shortlisted Group S. No. PAN Name Basis of relationship 1 AAAHO4138H Prakash Agarwal Om The entity is Pre IPO Transferee in the scrip of Eco 2 AAAPJ3918J Sangeeta Devi The entity is Preferential Allottee in the scrip of HPC 3 AAAPN2282K Sandeep Narang The entity is Preferential Allottee in the scrip of Eco 4 AABPA7646R Ahmad Sadat The entity is Preferential Allottee in the scrip of Eco 5 AABPI1183M Seemeen Ikram The entity is Pre IPO Transferee in the scrip of Esteem 6 AACCM0442K Moran Plantation Pvt Ltd The entity is Preferential Allottee in the scrip of HPC 7 AACCP2436Q Parasramka Holdings (P) Limited The entity is Preferential Allottee in the scrip of HP....
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.... entity is Preferential Allottee in the scrip of CNE 33 AAIPG1121A Monika Goel The entity is Preferential Allottee in the scrip of Eco 34 AAIPP1301R Neeraj Prakash The entity is Pre IPO Transferee in the scrip of HPC 35 AAJPK2929F Virender Kumar The entity is Pre IPO Transferee in the scrip of HPC 36 AAKPB9944J Rajesh Bajaj The entity is Preferential Allottee in the scrip of HPC 37 AAKPB9945K Rajiv Bajaj The entity is Preferential Allottee in the scrip of HPC 38 AAKPG4084E Vinita Gupta' The entity is Preferential Allottee in the scrip of CNE 39 AALHA3711R Amit Goyal Huf The entity is Pre IPO Transferee in the scrip of HPC 40 AALHM9796E Manish Kataria The entity is Pre IPO Transferee in the scrip of HPC 41 AALPA1253A Sourabh Aggarwal The entity is Preferential Allottee in the scrip of HPC 42 AALPD0474G Satish Kumar Dhawan The entity is Pre IPO Transferee in the scrip of HPC 43 AAMHS1255B Sanjeev Tandon (Huf) The entity is Preferential Allottee in the scrip of Eco 44 AAMPG5487F Namita Gupta The entity is Pre IPO Transferee in the scrip of....
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.... 69 ABFPK4763L Ajay Kumar The entity is Pre IPO Transferee in the scrip of HPC 70 ABGPS0921H Rajan Sahni The entity is Preferential Allottee in the scrip of CNE 71 ABGPS0922E Navin Sahni The entity is Preferential Allottee in the scrip of CNE 72 ABHPB1469L Munish Bajaj The entity is Preferential Allottee in the scrip of Eco 73 ABHPM7083M Sangeeta Naresh Mittal The entity is Preferential Allottee in the scrip of HPC 74 ABHPT6904C Jayanaben Nayanbhai Thakkar The entity is Preferential Allottee in the scrip of HPC 75 ABIPS4714N Arun Sankhwal The entity is Preferential Allottee in the scrip of CNE 76 ABIPS4715P Madhu Sankhwal The entity is Preferential Allottee in the scrip of CNE 77 ABJPG7690J Rajesh Gaba The entity is Pre IPO Transferee in the scrip of HPC 78 ABKPH4283M Mohit Hissaria The entity is Preferential Allottee in the scrip of Esteem 79 ABOPB8988M Ashok Batra The entity is Pre IPO Transferee in the scrip of Eco 80 ABRPG5287F Vijendra Goyal The entity is Preferential Allottee in the scrip of HPC 81 ABTPS0061P Reeta Singhal....
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....Preferential Allottee in the scrip of HPC 106 ADJPR7115B Vikas Raj The entity is Preferential Allottee in the scrip of CNE 107 ADMPK9802D Hira Lal Khatri The entity is Preferential Allottee in the scrip of Esteem 108 ADNPA7732P Kailash Chandra Agarwal The entity is Preferential Allottee in the scrip of CNE 109 ADNPK1527C Pawankumar Singhal The entity is Preferential Allottee in the scrip of Esteem 110 ADQPA4236R Manju Aggarwal The entity is Pre IPO Transferee in the scrip of Eco and Preferential Allottee in HPC 111 ADQPV7816E Bimla Vij The entity is Preferential Allottee in the scrip of HPC 112 ADUPG2221J Minakshi Gupta The entity is Preferential Allottee in the scrip of Esteem 113 ADVPJ1356J Suresh Chand Jain The entity is Preferential Allottee in the scrip of HPC 114 AEAPG2172B Pulkit Gupta The entity is Preferential Allottee in the scrip of HPC 115 AEEPG7895K Nitin Kumar Gupta The entity is Preferential Allottee in the scrip of Esteem 116 AEFPG8410F Savita Gupta The entity is Preferential Allottee in the scrip of Esteem 117 AEHPT6622C ....
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....ip of HPC 142 AHVPA2998M Urvashi Ahalawat The entity is Preferential Allottee in the scrip of HPC 143 AHWPK6613J Bhag Kataria The entity is Pre IPO Transferee in the scrip of HPC 144 AHWPM2448P Shweta Rathi The entity is Preferential Allottee in the scrip of HPC 145 AICPK7883R Poonam Kansal The entity is Preferential Allottee in the scrip of Esteem 146 AIEPG1462E Prateek Gupta The entity is Preferential Allottee in the scrip of Esteem 147 AIHPC0099A Vipul Chandra The entity is Pre IPO Transferee in the scrip of HPC 148 AIKPG3052G Nishil Gupta The entity is Preferential Allottee in the scrip of Esteem 149 AIMPB4769K Sushma Bajaj The entity is Preferential Allottee in the scrip of Eco 150 AIMPB9015E Nikesh Bardia The entity is Pre IPO Transferee in the scrip of HPC 151 AIVPJ9518R Bhawna Aggarwal The entity is Pre IPO Transferee in the scrip of HPC 152 AJUPS9413N Satya Narain Saria The entity is Preferential Allottee in the scrip of Esteem 153 AJZPM7650C Sushant Muttreja The entity is Preferential Allottee in the scrip of CNE 154 AKEPG46....
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....Asseja The entity is Pre IPO Transferee in the scrip of HPC 179 AZKPC1170A Lokesh Chandna The entity is Pre IPO Transferee in the scrip of HPC 180 BBWPS2176R Naz Shazia The entity is Pre IPO Transferee in the scrip of Esteem 181 BKEPS8583H Ekta Sachdeva The entity is Preferential Allottee in the scrip of Esteem 182 BUFPK8522D Khushboo Kanodia The entity is Preferential Allottee in the scrip of HPC 183 CGPPS3517P Akansha Singhal The entity is Preferential Allottee in the scrip of Esteem 184 CLFPK3259R Nischint Kanodia The entity is Preferential Allottee in the scrip of HPC 185 CWYPS1114B Rahul Solanki The entity is Preferential Allottee in the scrip of HPC 186 DNUPS8667F Urvashi Sachdeva The entity is Preferential Allottee in the scrip of Esteem 35. The summary of profit/gain earned by the preferential allottees and pre-IPO transferees belonging to Shortlisted Group in all the scrips is provided in Annexure D. 36. It is matter of common knowledge that in a private placement, wherein allotment is made to select persons or group of persons on one -to- one basis, the issuer and thei....
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.... brought out hereinabove, when seen holistically, indicate high preponderance of probability of manipulative intention. From the aforesaid observations of preliminary inquiry it is inter alia noted that :- a) All the companies had very small share capital prior to the year 2011. In the year 2011 and 2012 the companies increased their capital base by issuing shares to several entities by way of preferential allotment and later by issuing bonus shares. Certain preferential allottees transferred their shares in the respective company to pre IP transferees. b) Thereafter, all the companies came out with IPOs and the entities belonging to Funding Group funded substantial portion of the IPOs. IPO proceeds of respective IPO were immediately routed back to the entities of the Funding Group by the concerned companies and thus they financed their own IPO and allotted shares without receipt of consideration to the extent they returned the subscription monies to the Funding Group from IPO proceeds. c) The respective companies had actively concealed the deviation in utilisation of IPO proceeds as they deliberately did not make any disclosures as required under clause 46 of SME Listing ....
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....mand against the supply from the preferential allottees/pre IPO transferees. In the whole process, the principle of price discovery was kept aside and the market lost its purpose. It is evident from the above analysis that the Trading Group entities provided a hugely profitable exit to the preferential allottees and pre IPO transferees. 42. The analysis of trading during the examination period shows uniform pattern of repeated placing of buy orders at price above LTP in four fundamentally weak newly listed companies to push the price up significantly and provide hugely profitable exit to the preferential allottees and pre-IPO transferees. Since all the aforesaid companies did not have any financial standing in the securities market, in my view, the only way they could have increased their share value is by way of market manipulation. I further note that, Trading Group entities and preferential allottees/pre-IPO transferees traded amongst themselves as substantiated by their matching contribution to net buy and net sell. Further, as mentioned earlier the Trading Group entities did not have the financial capacity to buy shares at such high price and they are found to have been fun....
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....), (b) and (c) of the Securities and Exchange Board of India Act, 1992. 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 exchange; (c) engage in any act, practice, course of business which operates or would operate as fraud or deceit upon any person, in connection with the issue, dealing in securities which are listed or proposed to be listed on a recognised stock exchange, in contravention of the provisions of this Act or the rules or the regulations made thereunder;" PFUTP Regulations "3. Prohibition of certain dealings in securiti....
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....ty;" 46. I note that the directors of HPC (i.e. Tarun Chauhan, Sakshi Saxena, Madhu Anand, Arun Kumar Gupta and Avinash Kumar Singh), directors of Esteem (i.e. Vinod Kumar Garg, Brij Kishore Sabharwal, Neeraj Mittal, Jai Kumar and Anshul Kumari), directors of Eco (i.e. Vinod Kumar Garg, Brij Kishore Sabharwal, Amar Singh Bisht, Neeraj Mittal and Neha Khandelwal)and directors of CNE(i.e. Gajraj Singh, Kirti, Dinesh Kumar Jindal, Neena Sood and Gagan Goel)during the relevant time, being in control of the day to day affairs of respective companies, had the knowledge of their acts and omissions. They were also under an obligation to ensure that the acts and transactions of their respective company were not in violation of any of the applicable provisions of SEBI Regulations or other applicable laws. I, therefore, prima facie find that the said directors were responsible for their respective company's acts and omissions in this case. 47. I am of the opinion that a detailed investigation of the entire scheme employed in this case is necessary to find out the role of any other entity in the said scheme, connection amongst the concerned entities, the ultimate owners of funds used....
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....oup, Trading Group and the promoters/directors of these companies. It is also pertinent to mention that Eco and Esteem have already obtained approval of shareholders for migrating from SME platform to Main Board of BSE. If these companies are allowed to shift to Main Board of BSE, the minimum Bid Size of Rs. 1 Lakh, which is currently present in SME segment of the exchange, will not be applicable in the Main Board. Consequently, it will increase the liquidity in the scrips as well as very small investors, who are kept away from SME segment through Minimum Bid Size, may also be induced to invest in these companies. Unless prevented they may use the stock exchange mechanism in the same manner as discussed hereinabove for the purposes of their dubious plans as prima facie found in this case. In my view, the stock exchange system cannot be permitted to be used to achieve unlawful benefits whether tax related or otherwise. Considering these facts and the indulgence of a listed company in such a fraudulent scheme, plan, device and artifice as prima facie found in this case, I am convinced that this is a fit case where, pending investigation, effective and expeditious preventive and remed....
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....ker Dubey Funding Group 22 AWWPK8525E Satendra Kumar Funding Group 23 ARUPK1589P Sumit Kumar Funding Group 24 AXFPR4439L Ram Prakash Funding Group 25 AAFCM3716M Mayfair Infosolutions Pvt Ltd Funding Group 26 ARVPG7849R Prakash Gupta Funding Group 27 AATPS8461N Anilsharma Preferential Allotee 28 ALRPS8216N Shreyans Sankhwal Preferential Allotee 29 APZPV0747H Prithvi Sudhir Vora Preferential Allotee 30 AAAHO4138H Prakash Agarwal Om Pre IPO Transferee 31 AAEPA7336D Abhilasha Agarwal & Om Prakash Agarwal Pre IPO Transferee 32 AAIHS3951G Sanjay Agarwal Huf Pre IPO Transferee 33 AAOPA4656L Rama Aggarwal Pre IPO Transferee 34 ABOPB8988M Ashok Batra Pre IPO Transferee 35 ABVPA5824E Sarika Aggarwal Pre IPO Transferee 36 ACMPA2650C Anshu Agarwal And Sanju Agarwal Pre IPO Transferee 37 ADQPA4236R Manju Aggarwal Pre IPO Transferee 38 AKFPG3695N Saurabh Gupta Pre IPO Transferee 39 AABPI1183M Seemeen Ikram Pre IPO Transferee 40 AADPM9208K Mohammad Anwar Pre IPO T....
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....AIHPC0099A Vipul Chandra Pre IPO Transferee 82 AIMPB9015E Nikesh Bardia Pre IPO Transferee 83 AIVPJ9518R Bhawna Aggarwal Pre IPO Transferee 84 AKEPG4655R Yogesh Gaba Pre IPO Transferee 85 AMGPM9259F Virender Pal Singh Mainee Pre IPO Transferee 86 AMNPJ8901E Sagar Jain Pre IPO Transferee 87 AMQPA5671D Ankit Agarwal Pre IPO Transferee 88 AODPS9750A Deepa Sejwal Pre IPO Transferee 89 AOEPK7545Q Vidushi Kothari Pre IPO Transferee 90 AQXPS1846B Tejpal Singh Sejwal Pre IPO Transferee 91 AUKPC5480A Ekas Chhabra Pre IPO Transferee 92 AVBPS6306D Divjot Singh Pre IPO Transferee 93 AYIPA9888Q Kritika Asseja Pre IPO Transferee 94 AZKPC1170A Lokesh Chandna Pre IPO Transferee 95 AAEPR5593F Rajeshwari Preferential Allottee 96 AAFHA5045Q Ajay Kumar Huf Preferential Allottee 97 AAGPA8954P Sudhir Agarwal Preferential Allottee 98 AAGPB1427L V Balsubramaniam Preferential Allottee 99 AAGPK0723L Sanjay Kariwala Preferential Allottee 100 AAHPS9299N Manoj Singhal Preferential....
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....eferential Allottee 138 AMQPN9019G Prateek Nagpal Preferential Allottee 139 AMTPN9992M Abheek Nagpal Preferential Allottee 140 AQBPN5620N Tanya Narang Preferential Allottee 141 AACPC7067R Rajesh Chawla Preferential Allottee 142 AACPC7068A Mukesh Chawla Preferential Allottee 143 AADHP4727Q Pawan Kumar Singhal Huf Preferential Allottee 144 AADPV5705E Sanjeev Verma Preferential Allottee 145 AAHPG5906C Tarsem Chand Gupta Preferential Allottee 146 AAHPG5907D Neelam Gupta Preferential Allottee 147 AAMPG7571Q Ram Avtar Gupta Preferential Allottee 148 AAMPM2657F Riaz Munshi Preferential Allottee 149 AAPPG2434D Satinder Paul Gupta Preferential Allottee 150 ABAPS5155K Sudarshan Kumar Sachdeva Preferential Allottee 151 ABAPS5157M Vijay Laxmi Sachdeva Preferential Allottee 152 ABBPS5022Q Sanjay Sachdeva Preferential Allottee 153 ABKPH4283M Mohit Hissaria Preferential Allottee 154 ABTPS0061P Reeta Singhal Preferential Allottee 155 ACDPR7654N Atma Ram Khatri Preferential Allottee ....
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....llottee 193 ACJPA8351R Mohd. Arif Preferential Allottee 194 ADDPJ5506C Abhishek Jain Preferential Allottee 195 ADIPV6705E Vinita Preferential Allottee 196 ADQPV7816E Bimla Vij Preferential Allottee 197 ADVPJ1356J Suresh Chand Jain Preferential Allottee 198 AEAPG2172B Pulkit Gupta Preferential Allottee 199 AEQPM1717C Surekha Ashok Mittal Preferential Allottee 200 AEWPA2450G Anchal Rathi Preferential Allottee 201 AFBPA0663F Anjana Garg Preferential Allottee 202 AFOPG8341M Gaurav Gupta Preferential Allottee 203 AGPPK4328L Sunil Kumar Preferential Allottee 204 AGYPG1226G Shalini Gupta Preferential Allottee 205 AHPPA6148R Simpi Agarwal Preferential Allottee 206 AHVPA2998M Urvashi Ahalawat Preferential Allottee 207 AHWPM2448P Shweta Rathi Preferential Allottee 208 ALCPA3324L Rishab Preferential Allottee 209 ASPPS3078P Shaleen Kumar Singh Preferential Allottee 210 BUFPK8522D Khushboo Kanodia Preferential Allottee 211 CLFPK3259R Nischint Kanodia Preferen....
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....rsons/entities against whom this Order is passed may file their objections, if any, within twenty one days from the date of this order and, if they so desire, avail themselves of an opportunity of personal hearing before the Securities and Exchange Board of India, on a date and time to be fixed on a specific request, received from the said persons/entities. ============= Document 1 500000 400000 300000 200000 100000 14/01/2013 14/03/2013 14/05/2013 14/07/2013 14/09/2013 Chart 1: Price/Volume Movement in the Scrip of Eco 14/11/2013 14/01/2014 14/03/2014 Total Volume Close Price 600 500 400 300 200 100 0 14/05/2014 14/07/2014 14/09/2014 14/11/2014 Document 2 600000 500000 400000 300000 200000 100000 19/03/2013 19/04/2013 250000 200000 150000 100000 50000 1000000 800000 600000 400000 200000 0 Chart 2: Price/Volume Movement in the Scrip of Esteem 07/02/2013 07/04/2013 03/06/2013 07/05/2013 07/10/2013 Chart 3: Price/Volume Movement in the Scrip of CNE 12/03/2013 12/04/2013 12/05/2013 12/06/2013 12/07/2013 12/08/....


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