TaxTMI 
TaxTMI 
2024 (8) TMI 797
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....im order 46-62 50-59 A. BACKGROUND: 1. The present proceeding is the result of an inspection conducted by the Securities and Exchange Board of India (hereinafter referred to as "SEBI") regarding the activities of Mr. Balu Motiram Bharati (here in after referred to as "Balu Motiram"), an Authorised Person of a registered Stock-Broker namely ABC Limited Note: The actual name of the stock-broker is not used in this order as the stock-broker is not a Noticee in the instant proceedings at this stage. ABC Limited is a disguised name for reference purpose and actual name would be supplied to the Noticees during inspection and to Hon'ble SAT and Courts, during court proceedings.. 2. Due to certain findings that emerged during the said inspection exercise, an independent examination of activities of Ravindra Bharti Education Institute Private Limited (here in after referred to as "RBEIPL" or Noticee no. 1) was carried out by the SEBI for the period from March 10, 2017 to September 30, 2023 (here in after referred to as "examination period"), as it was prima facie noticed during the inspection of Mr. Balu Motiram, Authorised Person of stock-broker ABC Limited, that RBEIPL was ....
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....rcular bearing Circular no. SEBI/HO/MIRSD/DOP1/CIR/P/2018/54 (hereinafter referred to as "2018 Circular"). Vide the afore-stated circular, it has been mandated for Stock Brokers that for executing trade of every client, it is essential to keep evidence of mode of placement of such order(s) by the client. The evidence of order placement of each client is required to be maintained and preserved for certain specified period and such mode of placement of order could be in the form of telephone recording, written order through emails, personal visit etc. Being agents of stock brokers, the said 2018 Circular is equally applicable on the Authorised Persons of stock brokers. As stated above that an inspection of Mr. Balu Motiram, one of the Authorised Persons of the stock broker ABC Limited was carried out. During the aforesaid inspection, perusal of call recordings and emails pertaining to pre- confirmation of trades revealed that instead of clients approaching the said Authorised Person to execute the trades, the representatives of the Authorised Person were first approaching the clients, and were recommending the clients with specific recommendation to either buy or sell the securities ....
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....ptember 22, 2023. Interestingly, in the records of NSE, he was observed to be enrolled as a Dealer of the Authorised Person (Mr. Balu Motiram) and the terminal was allotted to him in the month of August, 2023. It is pertinent to note that both RBEIPL and the Authorised Person (Mr. Balu Motiram) have been operating from the same premises. It has further been noticed that the said Mr. Rahul Ananta Gosavi has later on become a Director of RBEIPL. 9. Similarly, another dealer of Mr. Balu Motiram, namely Mr. Harshad Bodhe is also found to be employed with Noticee no. 1, RBEIPL. In this respect, the appointment letter dated September 22, 2023 of Mr Harshad Bodhe is reproduced herein below: Image no. 3 10. From the above, it is noticed that Mr. Harshad Bodhe was employed with RBEIPL as a Team Leader w.e.f. January 17, 2022. However, the appointment letter was issued on September 23, 2023. 11. Similarly, the Approved Person of Mr Balu Motiram, namely Mr. Vishwas Nana Giri, is also employed with RBEIPL. Perusal of the appointment letter and the salary slip reveals that though Mr. Vishwas Nana Giri was employed with Noticee no. 1, RBEIPL, from April 18, 2017, the appointment lett....
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....atement of RBEIPL, Noticee no. 1, reveals that a total amount of INR 101,33,53,118.58 has been credited during the period of January, 2018 to September, 2023. As stated in the preceding paragraph, the fee for trading related courses was in the range of INR 28,800 to INR 47,200 and the fee for advisory services was normally above INR 50,000. Therefore, entries in the accounts of Noticee no. 1 were examined to ascertain fee collected/ received out of investment advisory activities. It has also been noticed that the bank accounts of RBEIPL had certain credit entries which were observed to be transferred either: (i) from its other accounts, (ii) from its related entities, (iii) from financial institutions or (iv) were high value credits with narration not pertaining to investment advisory. Considering the above, in order to arrive at an amount which RBEIPL appears to have collected from advisory services during the period January 10, 2018 to September 30, 2023, the amount of "fees for trading courses" and the other entries listed above (i.e. from other accounts or from related entities or from financial institutions or of high value credit with narration not pertaining to investment ad....
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.... of agreements, copies of emails sent to the investors, details of fee collected. In response to the same, Noticee no. 1 vide its email of even date had inter alia provided a list of 222 unique clients of its Wealth Management program and copy of an agreement executed with one of its clients for Wealth Management program. Since, the complete information was not furnished, the Noticee no. 1 (RBEIPL) was further reminded vide email dated December 12, 2023 to provide the complete details of its advisory services including copy of all emails sent to the advisory clients. However, copies of all the emails issued by the Noticee no. 1 to its clients (email dump), were not shared despite sending reminders. Subsequently, vide its email and letter dated December 18, 2023, the Noticee no. 1 has inter alia provided details of 235 active Wealth Management clients. In addition, details of 55 clients with status as "closed"; and details of 17 clients with status "refunded" were provided. However, many names were duplicate in the said list and after removing those duplicate names, a total 290 unique clients were found. Vide the aforesaid letter, RBEIPL has also furnished copies of Wealth Managemen....
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....of the service plans, as culled from the said agreement is mentioned below: Table no. 4 (1) Management Plan (2) Management Fee (3) Expected Return † (4) Profit Sharing † Lump sum For 1 year 5% 25% 40% Lump sum For 3 years 10% 100% 30% Lump sum For 5 years 15% 200% 20% Lump sum For 10 years 25% 1000% 10% SIP for 3 years 5% 50% 40% SIP for 5 years 10% 100% 20% SIP for 10 years 15% 500% 10% † NOTE: The profit Sharing will be applicable on the amount above Expected returns III. It has further been noticed that once investors get themselves enrolled in the Wealth Management program of the Noticee no. 1, representative of the Noticee no. 1 approaches such investor via email, recommending transactions pertaining to the stock market to be executed in the respective account of investors. The said recommendation contains the names of the scrip/contract along with the quantities of the shares/contracts recommended to be transacted by investors. IV. One such email issued by and on behalf of the Noticee no.1 to one of its Wealth Management clients containi....
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.... I will call you again for confirmation. Sir, do you have any other doubts? CLIENT - No. Please proceed with the list of stocks. RBEIPL - Sir we require confirmation, recording I will call you again. CLIENT - Okay. VIII. Once the client agrees in principle to accept the advice, another call is made by the Office of the Authorised Person on the same day (September 21, 2023) and the details of stocks and quantities are read over to seek confirmation from the client, as the call recording is required to be maintained in terms of the 2018 Circular. The transcript of the said call (translated from Marathi to English) is given below (name of the client redacted): RBEIPL - Hello Sir, good morning. This is ..... from Bharti Share Market Wealth Service. I'm calling for your confirmation for purchasing some stocks in your account, BXXXXXX1 MXXXj PXXXl. I'll read the names and quantities of the shares now. (Representative reads list of 17 shares). We have to buy all this stock at market price in account BXXXXXX1 MXXXj PXXXl.. Should I buy this stocks? CLIENT - Yes please buy. RBEIPL - Okay Sir. Thanks You. ....
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.... on phone. Then we will sell the shares. o CLIENT - Okay. Do as per your process. o RBEIPL - Okay. I will call you again. I will tell you names and quantities of shares. You say Okay to that. Then I will sell shares from here. o CLIENT - Okay. B. Call Recording (Call from RBEIPL to MXXXa DXXXu AXXi made on September 13, 2023 for the purpose of trade authorisation: o CLIENT - Hello. o RBEIPL - Hello Madam Namaskar ... here from Bharti Share Market Wealth Service. Madam we are selling some share from your portfolio ..... I will read names and quantities of share now. (Representative reads list of 18 shares). We are selling this share at current market price from account no. ..... o CLIENT - Okay o RBEIPL - Okay Madam." (underline supplied) 20. From the above, it is revealed that the call was made first by the Noticee no.1 asking the investor that some transactions would be made in the account of the investor and further investor was asked to behave in a particular fashion as suggested by the representative of the Noticee no. 1 for executing trades as per recommendations. Subsequently, the confirmation from the....
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....ting of the online information and paying the Fees to Ravindra Bharti Wealth Management would amount to entering into a legal contract by me with Ravindra Bharti Wealth Management and I agree and confirm that no separate document/Agreement will be required for the said purpose. I agree that the said form is filled by me and the terms and conditions contained therein are legally binding on me and enforceable by and against me. I agree and confirm that I have read and understood all the terms and conditions of the contract and that I wish to enter into the said Agreement with Ravindra Bharti Wealth Management . 3.2 I agree to pay the Advisory fee as per the plan selected by me plus applicable government taxes and levies. The fixed fee shall be paid up front at the time of the start of advisory services. Thereafter, I shall be liable to pay fixed fee to Ravindra Bharti Wealth Management based on the plan selected by me at that point of time as per Ravindra Bharti Wealth Management 's fee structure. Ravindra Bharti Wealth Management shall intimate me about the same from time to time. 3.4 Performance fee: I shall be liable to pay a performance fee as per the plan selec....
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.... under this contract is confidential and shall be specific to the funds proposed to be invested by me under this contract. I shall not use this advisory out of scope of this contract. ... 8.4 Upon termination of this contract, I undertake to settle the accounts including performance fee with Ravindra Bharti Wealth Management within three (3) days of the termination. I also undertake to sell all the holdings advised by Ravindra Bharti Wealth Management during the term of this contract and provide the sell contract notes to Ravindra Bharti Wealth Management within one month from the date of termination of this contract. I further understand that, in case I fail to provide the said sell contract notes to Ravindra Bharti Wealth Management within a said period of one month, Ravindra Bharti Wealth Management may take necessary action against me for breach of present contract. ... 10 Miscellaneous 10.1 I hereby undertake that, I shall furnish my financial information & fill in the risk profiling questionnaire after every 2 years during the subsistence of this contract to Ravindra Bharti Wealth Management for portfolio renewal. 10.2 I h....
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....ices as "Wealth Management", the same signifies that on a single day, the investors are being sold more than one advisory packages. The said invoices are reproduced hereunder for ready reference: Image no. 11 Image no. 12 III. In order to induce investors to deal in securities by subscribing to the advisory services of the Noticee no. 1, the application form/agreements of the Noticee no. 1 projected returns of 25 % (1 year) to 1000% (10 years) there by giving a kind of assurance that investors trading in securities based on the recommendation rendered by the Noticee no. 1 would be successful in earning return ranging from 25 % to 1000% on its investment over the period. IV. Regarding the investment advisory activities, Noticee no. 1 vide its letter dated December 18, 2023 has acknowledged to have collected INR 5.44 Crore as a fee from 290 unique investors from March 11, 2020 to August 29, 2023. It is noted that the amounts received as fee from clients by the Noticee no. 1, out of investment advisory were collected in the following accounts/payment gateways of the Noticee no. 1: Table no. 5 (1) Sr.No. (2) Name of the account holder (3) Account Num....
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.... nature of providing "investment advice" in terms of clause (i) of sub-regulation (1) of regulation 2 of the IA Regulations which defines "investment advice" as: "investment advice" means advice relating to investing in, purchasing, selling or otherwise dealing in securities or investment products, and advice on investment portfolio containing securities or investment products, whether written, oral or through any other means of communication for the benefit of the client and shall include financial planning: Provided that investment advice given through newspaper, magazines, any electronic or broadcasting or telecommunications medium, which is widely available to the public shall not be considered as investment advice for the purpose of these regulations" VII. In terms of clause (m) of sub-regulation (1) of regulation 2 of the IA Regulations, an entity engaged in providing advice relating to investing in, purchasing, selling or otherwise dealing in securities or investment products, and advice on investment portfolio containing securities or investment products, whether written, oral or through any other means of communication for the benefit of the clie....
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....making the choice of buy as well as sell and it was also the Noticee no.1, who was selecting the scrip to be transacted in the accounts of its clients. Looking holistically, the evidence and acts of Noticee no. 1, it is apparent that the Noticee no. 1 is providing investment advice to its clients in pursuance of the contract named as "Wealth Management". It is noted that the entity (Noticee no. 1) is not merely issuing advice to invest in particular securities but is also mentioning the price at which the securities are to be purchased and also the quantities of respective securities to be transacted in the respective account of its clients. Further, the Noticee no. 1 is having full control on the buy as well as sell transactions of the clients so that both transactions are carried out as per its recommendation. XII. Therefore, based on the examination and analysis of facts gathered in the course of examination and as narrated in the preceding paras, I hold that activities of the Noticee no. 1 prima facie fall within the ambit of "investment adviser". E. EXAMINATION OF LEGAL ISSUES TO DETERMINE IF THERE IS A VIOLATION 26. After recording prima facie findings on the f....
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....pment of securities market; or (ii) to prevent the affairs of any intermediary or other persons referred to in section 12 being conducted in a manner detrimental to the interest of investors or securities market; or (iii) to secure the proper management of any such intermediary or person, it may issue such directions,- (a) to any person or class of persons referred to in section 12, or associated with the securities market; or (b) to any company in respect of matters specified in section 11A, as may be appropriate in the interests of investors in securities and the securities market. Explanation.-For the removal of doubts, it is hereby declared that the power to issue directions under this section shall include and always be deemed to have been included the power to direct any person, who made profit or averted loss by indulging in any transaction or activity in contravention of the provisions of this Act or regulations made thereunder, to disgorge an amount equivalent to the wrongful gain made or loss averted by such contravention. (2) Without prejudice to the provisions contained in sub-section (1), sub-section (4A) o....
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....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; Penalty for failure to furnish information, return, etc. 15A. If any person, who is required under this Act or any rules or regulations made thereunder,- (a) to furnish any document, return or report to the Board, fails to furnish the same or who furnishes or files false, incorrect or incomplete information, return, report, books or other documents, he shall be liable to a penalty which shall not be less than one lakh rupees but which may extend to one lakh rupees for each day during which such failure continues subject to a maximum of one crore rupees. Penalty for default in case of investment adviser and research analyst. 15EB. Where an investment adviser or a research analyst fails to comply with the regulations made by the Board or dir....
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....ock exchange; (d) engage in any act, practice, course of business which operates or would operate as fraud or deceit upon any person in connection with any dealing in or issue of securities which are listed or proposed to be listed on a recognized stock exchange in contravention of the provisions of the Act or the rules and the regulations made there under. 4. Prohibition of manipulative, fraudulent and unfair trade practices (1) Without prejudice to the provisions of regulation 3, no person shall indulge in a manipulative, fraudulent or an unfair trade practice in securities markets. Explanation.- For the removal of doubts, it is clarified that any act of diversion, misutilisation or siphoning off of assets or earnings of a company whose securities are listed or any concealment of such act or any device, scheme or artifice to manipulate the books of accounts or financial statement of such a company that would directly or indirectly manipulate the price of securities of that company shall be and shall always be deemed to have been considered as manipulative, fraudulent and an unfair trade practice in the securities market. (2) D....
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....the Noticee no.1 has executed agreement containing detailed clauses with investors and acting in pursuance of such agreements, it has prima facie engaged himself in providing investment advisory to its subscribers/investors. It has also been seen that evidence on record prima facie shows that in lieu of providing such investment advice, the Noticee no. 1 is charging "management fee" from its clients. As can be noted from the Image no. 6 above that against a lump sum investment of an investor for an amount of INR 25,00,000 invested for a period of 10 years, the Noticee no. 1 has charged 22% of the said amount, i.e. INR 5,50,847 (excluding taxes) as fee. This is just one of many instances. 31. The records further show that in addition to charging upfront Management Fee (as specified under Column 2 of Table no. 4) from its clients against rendering of investment advisory services, the agreement entered into by the Noticee no. 1 with its clients, contains a clause which has additional provision to share profits earned by the investors out of the investment advisory rendered by the Noticee no. 1. In this respect in terms of clause 3.4 of the agreement executed with an investor (quote....
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....aud in connection with dealing with securities; Iv engagement in any act, practice, course of business which operate/would operate as fraud or deceit upon any person in contravention of the provisions of the SEBI Act or rules or regulations; V dealing in securities which is manipulative, fraudulent or an unfair trade practice; Vi disseminating information or advice through any media, which the disseminator knows to be false or misleading, or which is either designed to or likely to influence the decisions of investors; Vii fraudulently inducing any person to deal in securities to increase the income; Viii mis-selling of services relating to securities market. 35. In the preceding parts of the present order, it has been elaborated in detail as to how the Noticee no. 1 has indulged in investment advisory services and has collected more than INR 12 Crore during the period January 10, 2018 to September 30, 2023, which is prima facie in violation of sub-section (1) of section 12 of the SEBI Act, 1992 read with sub-regulation (1) of regulation 3 of the IA Regulations. In addition it can be seen that the Noticee no.1 has created a scheme/dev....
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....ncome. 37. It is further noted that the disclaimer part of the agreement has a standard paragraph, as per which all the investors have not been given option and all have been asked to opt for 100% investment in equity segment only. The same is prima facie a mis-selling to the investor as all investors may not have equivalent risk appetite and some may need lesser exposure to equity investments. 38. In view of above discussion, I hold that the Noticee no. 1 has violated clauses (a), (b) and (c) of section 12A of the SEBI Act, 1992 read with the provisions of sub- regulations (a) to (d) of regulation 3 as well as sub-regulation (1) of regulation 4 and clauses (k), (o) and (s) of sub-regulation 4 of PFUTP Regulations. Though any of these violation would satisfy invocation of powers to issue directions but in this case, all the above violations have been noticed due to overlapping nature of violation. C. Violations by Noticees nos. 2, 3 , 4 and 5 39. As the prima facie violation on the part of the Noticee no. 1 has been established, it is to be seen as to who all are the natural persons, who are to be held liable in terms of section 27 of the SEBI Act. 40.....
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....hen Noticee no. 2 and Noticee no. 3, being its Executive Directors, were at the helm of the affairs and responsible for the management of the business of the Noticee no.1. Hence, under section 27 of the SEBI Act, they are prima facie guilty of contravention committed by the Noticee no 1. 44. The activities of providing investors advisory or other activities for which registration is essential, have not stopped and are on-going. It has also noticed that the Noticee no. 4, Mr. Rahul Ananta Gosavi, who was employed with the Noticee no. 1 as Executive Assistant to CMD (since October, 2015) has become its Director w.e.f September 22, 2023. Therefore, the above two persons i.e. Noticees nos. 4 and 5 are also alleged to be liable for the acts and omissions on part of the Noticee no. 1, and further making them liable for the directions to be issued which need to be complied with by the Noticee no.1. There is nothing on record to indicate that subsequent to the resignation of Noticees nos. 2 and 3, the alleged activities of providing investment advisory has stopped, as agreements entered into by the Noticee no. 1 are long duration agreements. 45. Thus, I hold that for the violations w....
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....r the IA Regulations, a comprehensive framework has been laid down with the sole objective of protection of investors' interest. There are entry barriers in terms of networth requirements; educational qualification and experience. Further, after grant of registration, there are responsibilities cast upon the entity like maintaining risk profiles and issuing advice suitable to the risk profile; making disclosures to the clients etc. However, by acting as an unregistered investment advisor, the Noticee no. 1 has been able to circumvent all the regulatory requirements pertaining to an investment adviser and has collected large amounts of fee from the investors thereby harming investors' interest. 50. The number of subscribers of the YouTube channel of Noticee no. 2 (refer Table no. 1), who continue to be major shareholder of the Noticee no. 1, are increasing further. There is a likely chance that being influenced by the social media presence and followership of the Noticee no. 2, gullible investors may continue to fall prey to the unregistered investment advisory activities of the Noticee no. 1. Another factor to infer that the unregistered activities are still being carried on eme....
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....registered investment advisory activity of the Noticee no. 1, in case the same is not stopped through urgent intervention and therefore, the same needs to be stopped immediately by regulatory intervention. 54. At this stage, I seek to place reliance on the order of the Hon'ble Securities Appellate Tribunal, passed in the matter of Amalendu Mukherjee Vs. SEBI (Appeal (L) no. 169 of 2020), wherein the Hon'ble Tribunal has underscored the necessity of passing impounding orders by inter alia observing as: "We are of the opinion that the WTM is empowered under the SEBI Act and the Regulations to pass an ex-parte order in order to protect the interests of securities market and the investors. If such impounding order is not passed, it may result in defeating the ultimate direction of disgorgement if any, as there would be chances of such monies being dissipated by the appellant. ..." 55. I observe that the stock market of a country is a barometer of its economic development. It is also an established fact the primary responsibility of a securities market regulator like SEBI is to protect the interest of investors and in pursuance of the said responsibility, SEBI has inter a....
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....lable to market. Market abuse impairs economic growth and erodes investors confidence. Market abuse refers to the use of manipulative and deceptive devices, giving out incorrect or misleading information, so as to encourage investors to jump into conclusions, on wrong premises, which is known to be wrong to the abusers..... " 57. In view of the discussion recorded above and being guided by the aforesaid order of the Hon'ble Courts, I am of the view that this is a fit case to exercise powers of passing interim impounding order so as to protect the securities market and to protect the unlawful gains, which may be siphoned off beyond regulatory reach. Accordingly, I, in exercise of the powers conferred upon me under sub-section (1) of section 11, clause (d) of sub-section (4) of section 11, sub-section (1) of section 11B, section 11D read with section 19 of the SEBI Act, 1992 read with clause (d) of sub-regulation (1) of regulation 11 of PFUTP Regulations, hereby by way of the present interim order cum show cause notice, issue the following directions, which shall remain in force until further orders: I. The Noticees shall cease and desist from offering investment ad....
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....mount to be impounded (INR 12,03,82,130.91). Banks are allowed to debit the accounts for the purpose of complying with this Order. VII. The Registrar and Transfer Agents are directed to ensure that, they neither permit any transfer nor redemption of the securities, including Mutual Funds units, held by the Noticee no. 1. VIII. The Noticees are directed not to dispose of or alienate any of their assets/properties/securities, till such time the amount of unlawful gain is credited to an Escrow Account except with the prior permission of SEBI. IX. The Noticees are further directed to provide a full inventory of all their assets whether movable or immovable, or any interest or investment or charge in any of such assets, including property, details of all their bank accounts, demat accounts, holdings of shares/securities if held in physical form and mutual fund investments and details of companies in which they hold substantial or controlling interest immediately but not later than 7 working days of this Order. X. The Noticees nos. 1, 4 and 5 are further directed not to collect any money or fee from the existing clients on account of investment advisor....
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....hearing in the matter, if they so desire. 60. This Order is without prejudice to any other action that SEBI may initiate under the securities laws, as deemed appropriate, against the above mentioned persons/entities. 61. This Order shall come into force with immediate effect and shall be in force till further Orders. 62. A copy of this Order shall be forwarded to the Stock Exchanges, Depositories, Registrar and Share Transfer Agents and Banks to ensure necessary compliance. ============= Document 1 Ravindra Bharti Education Institute Pvt. Ltd. 4010. Marvel F Opp Seal Маркрака Payslip for the month of August 2023 Name: Joining Date: Designation Rahol Ananta Gosavi 02 Oct 2015 Bank: HDFC Bank Department: Location: Wealth Manager Wealth Management Head Office Bank Account No: PF No EMP EFFECTIVE WORKDAYS: 31 DAYS IN MONTH 31 PF UAN: ESI: PAN Number LOP 50100505320344 PU/PUN/1601047/000/0010003 101339382636 0 ВОРРООЗ17Е 0 EXTRA DAYS: 0 Earnings Full Actual Deductions BASIC 19200 19200 PF HRA 7....
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....ining the organization. The organization reserves its right to amend the grade, designation, and salary structure offered to you from time to time *You shall be governed by the rules and regulations of the organization as stipulated in the standing orders, employee handbook, or in any other manner that are currently in force or amendid in future from time to time. The appointment is made on the understanding that the information given by you is correct true and complete. F found incorrect, this appointment may be withdrawn before you join service with us, or your services may be terminated at any time after you have taken up employment with us If, for a period of 5 consecutive working days you are absent without sanction of leave or overstay, you shall lose your lien on your employment, and shall be deemed to have abandoned employment voluntarily. You shall take excellent care of and be responsible for the work equipment, oficial documents, tools, and other items/materials entrusted to you. This offer is made in duplicate. Please retum the duplicate copy duly signed by you as a tokenof your having read. understood, and accepted the te....
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.... intemation to anyone who is same. You would be recited to sign a Non Disclosure Agreement (NDA) in this regars at the time of your joining the organization The organization reserves its right to amend the grede, designation, and salary structure offered ushat be governed by the rules and regulations of the organization as stipulated in the standing orders, employee handbook, or in any other manner that are currently in force of amended in future from time to time. The appoinment is made on the understanding that the information given by you is correct true and compiere I found incorrect, this appointment may be withdrawn before you join service with us, or your services may be terminaned at any time after you have taken p employment with us If, for a period of 3 consecutive working days you are absent without sanction of leave or overstay, you she lose your lien on your employment, and shall be deemed to have abandoned employment voluntarily. You shall take excelent care of and be response fee work sonment, official documents. tools, and other emraterisis entrusted to your This offer is made in duplicate, Please retum the duplicate c....