TaxTMI 
TaxTMI 
2024 (8) TMI 856
X X X X Extracts X X X X
X X X X Extracts X X X X
....nel (The entities mentioned above are individually known by their respective names or Noticee No. and collectively referred to as "Noticees"; unless the context specifies otherwise) TABLE OF CONTENTS Particulars Paragraph Nos. Page Nos. A. Background 1 - 4 3 - 5 B. Details of Noticees 5-8 5 - 7 C. Key evidences collected during the investigation 9-10 7-8 D. Connection amongst Noticees 11-20 8 - 27 E. Sharing of information in advance about stock recommendations by Guest Experts and trades carried out by Profit Makers based on such advance information 21-81 27 - 65 F. Increase in trade volume as well as positive movement of price in line with the direction of the recommendation 82 - 115 66 - 79 G. Role of Enablers 116 - 117 79-81 H. Summary of profit on intraday trade based on advance information of recommendation 118-131 81-92 I. Sharing of profits amongst Noticees 132-141 92-100 J. Determination of facts 142 - 143 100 - 103 K. Examination of violation of provisions of SEBI Act and regulations made thereunder 144 - 164 103- 117....
X X X X Extracts X X X X
X X X X Extracts X X X X
....s were recorded under oath. 4. During post-search investigation, inter alia, following steps were undertaken, namely:- a) Analysis of data contained in electronic devices seized during search and seizure operation; b) Analysis of KYC details and bank account statements of Noticees; c) Analysis of Client Application Forms (CAF) provided by Telecom Service Providers (TSP); d) Analysis of Call Data Records (CDR) of Noticees; e) Analysis of Geographical locations of Noticees during certain periods; f) Analysis of trading activities of Noticees; g) Analysis of recorded videos of shows provided by Zee Media Corporation Limited ("ZMCL"); h) Analysis of Account Opening Forms (AOF) provided by banks; and i) Analysis of relevant material available on Ministry of Corporate Affairs (MCA) website. B. Details of Noticees 5. In order to have a better understanding of the matter and the role played by suspected entities, Noticees have been divided into three categories as per immediately succeeding paragraphs. 6. First category- Profit Makers The first category is "Profit Makers" which comprises o....
X X X X Extracts X X X X
X X X X Extracts X X X X
....ng company. He has trained over 12,000 individuals in the field of Technical Analysis of shares. It is seen that he had a social media presence with over 1,40,000 followers on "X" (erstwhile Twitter) during the investigation period. b) Mr. Ashish Kelkar (Noticee No. 12), a Co-Promoter and CEO at Kiran Jadhav & Associates, appeared on shows broadcasted on Zee Business and provided stock recommendations under the tagline "KIRAN KA KAMAL". As per the website of Kiran Jadhav & Associates, he has trained over 14,000 individuals in the field of technical analysis of shares. c) Mr. Himanshu Gupta (Noticee No. 13) is a research professional and Senior Vice President (Research) at Globe Capital Market Limited (as per the website of this company). He provided stock recommendations under the tagline "HITMAN HIMANSHU" on shows broadcasted on Zee Business. It is seen that he had over 15,700 followers on "X" (erstwhile Twitter) during the investigation period. d) Mr. Mudit Goyal (Noticee No. 14) is a SEBI registered Research Analyst at present (not at the time during the investigation period). He provided stock recommendations under the tagline "MUDIT KE MUNAFE" on sho....
X X X X Extracts X X X X
X X X X Extracts X X X X
....me of / Used by Source 773XXXX742 931XXXX971 Nirmal Kumar Soni (Noticee No.1) Client Application Form received Telephone Service Provider (TSP); Account Opening Forms (AOF) provided by Bank; Statement recording of Nirmal Kumar Soni; At the time of search & seizure operation, Nirmal Kumar Soni was having possession of a mobile phone with the SIM card of this number 842XXXX686 810XXXX138 974XXXX921 Partha Sarathi Dhar (Noticee No. 2) Client Application Forms received from TSP; AOF provided by Bank; Statement recorded dated January 19, 2023 982XXXX688 SAAR Commodities (Noticee No.3) KYC details provided by Bank 773XXXX742 Manan Sharecom Pvt Ltd. (Noticee No.4) AOF provided by Bank 977XXXX111 Kanhya Trading Company (Noticee No.5) AOF provided by Bank 977XXXX111 Nitin Chhalani (Noticee No.6) Client Application Form received from TSP 981XXXX506 Rupesh Kumar Matoliya (Noticee No.7) Client Application Form received from TSP 981XXXX056 Ajaykumar Ramakant Sharma (Noticee No.8) Client Application Form received from TSP 981XXXX506 SAAR Securities (Noticee No.9) KYC details provided by Bank 98....
X X X X Extracts X X X X
X X X X Extracts X X X X
....vided by HDFC Bank, mobile number "977XXXX111" is linked with its bank account and Nitin Chhalani (Noticee No. 6) is listed as one of its Authorised Signatories. Further, as per AOF of Nitin Chhalani provided by HDFC Bank, same mobile number "977XXXX111" is also associated with bank account of Nitin Chhalani. 13. From the examination of CDR and various records including Whatsapp/ Telegram Chats retrieved from seized devices of Noticees and statements of bank accounts, further connections amongst Noticees have emerged which are discussed in immediately succeeding paragraphs. 14. Connection amongst Nirmal Kumar Soni, Kiran Jadhav and Ashish Kelkar a. The relevant CDRs/ Whatsapp chats/Telegram chats pertaining to the investigation period have been analysed and it is observed that Nirmal Kumar Soni (773XXXX742) had calls/Whatsapp chats/ Telegram chats with both Kiran Jadhav (982XXXX880) and Ashish Kelkar (988XXXX277). It is also observed from the said Whatsapp chats that Nirmal Kumar Soni had met Kiran Jadhav in Pune (December 24, 2022) and in Dubai(2022). The said fact is also corroborated by the Whatsapp chats/photos retrieved from the gallery of phone seized during th....
X X X X Extracts X X X X
X X X X Extracts X X X X
....31XXXX971) was found to be in possession of Nirmal Kumar Soni. Additionally, Nirmal Kumar Soni, in his statement recorded on January 19, 2023, confirmed that the mobile number 931XXXX971 belonged to him. The ownership of the said mobile number was also found to be in the name of Nirmal Kumar Soni and the same got corroborated with CAF provided by the TSP. d. From the above, it can be inferred that Simi Bhaumik and Nirmal Kumar Soni were connected to each other during the relevant period. Further, the number 931XXXX971 (termed as "Vikash Parasar" in the mobile phone of Simi Bhaumik) was in actuality being used by/registered in the name of Nirmal Kumar Soni and the same number was also being used to interact with each other. Thus, for the purposes of this order, Vikash Parasar is to be seen as another name for Nirmal Kumar Soni. e. Thus, it can be seen that Nirmal Kumar Soni is connected to Simi Bhaumik. 16. Connection between Nirmal Kumar Soni and Kanhya Trading Company/ Nitin Chhalani. a. The CDRs pertaining to the relevant period were analysed and it is observed that Nirmal Kumar Soni (773XXXX742) ....
X X X X Extracts X X X X
X X X X Extracts X X X X
..... b. Noticees Nos. 3 and 9 shared common directors (Rupesh Kumar Matoliya (Noticee No. 7) and Ajaykumar Ramakant Sharma (Noticee No.8) during the investigation period. Further, Ramawatar Lalchand Chotia (Noticee No. 10) was also a Director and Authorized Signatory of Noticee No. 9 during the relevant period. c. Nirmal Kumar Soni had frequently communicated with Rupesh Kumar Matoliya, Ajaykumar Ramakant Sharma and Ramawatar Lalchand Chotia during the investigation period. Nirmal Kumar Soni also met with Ramawatar L. Chotia on multiple occasions in Mumbai and Jaipur, as seen from the analysis of geographical locations of mobile phones determined from the cell phone towers. Some of the illustrations of their meetings in Jaipur and Mumbai are provided below- Illustration No. 6 Illustration No. 7 d. The mobile number of Ramawatar Lalchand Chotia was saved as "Ram Sharma SAAR" in the mobile phone of Nirmal Kumar Soni. In one of the Whatsapp chats dated December 07, 2022 between Nimal Kumar Soni and Ramawatar Lalchand Chotia, it is observed that Ramawatar Lalchand Chotia requested Nirmal to square off open positions in the Client code SC100. This Client Co....
X X X X Extracts X X X X
X X X X Extracts X X X X
....below- Table No. 2 MEMBER _CODE USER_ID SEGMENT DEALER _NAME PAN NO Address 12856 25967 CM Harsh Niraj Ruparelia BXVPR6249B 208, EVER SHINE TOWER 2ND, AMRAPALI CIRCLE VAISHALI NAGAR, JAIPUR, RAJASTHAN 302021 12856 16656 FO Vikash Shrivastava BXCPS8836E 12856 17132 FO Vimalkumar Ramcharan Sharma BOCPS2404F 12856 17147 FO Rakesh Shankarlal Sharma BLLPS6414H 12856 18567 FO Vikram Jangid AFXPJ7083C 12856 19386 FO Chandrakala Ramawatar Sharma AJLPS4480N 12856 44656 FO Narendra Kumar EGAPK0043R 12856 44656 FO Lokesh Kumar Solanki CIUPS3262C 12856 49662 FO ....
X X X X Extracts X X X X
X X X X Extracts X X X X
.... of Nirmal Kumar Soni with Ramawatar Lalchand Chotia, Rupesh Kumar Matoliya, Ajaykumar Ramakant Sharma and SAAR Securities, it can be seen that knowingly information regarding trading account of SAAR Commodities and NEAT Terminals of SAAR Securities was provided to Nirmal Kumar Soni. It can also be seen that Nirmal Kumar Soni had access to the trading account of SAAR Commodities for executing trades. m. Thus, it can be seen that Noticees Nos. 7, 8, 9 and 10, by accommodating Nirmal Kumar Soni, facilitated, aided and abetted him in executing trades in the account of SAAR Commodities Limited. n. The connection amongst Nirmal Kumar Soni, SAAR Commodities Private Limited and SAAR Securities India Private Limited is illustrated below- Illustration No. 11 18. Connection amongst Guest Experts: CDRs of phone numbers belonging to/used by the Guest Experts have been analysed along with Whatsapp/Telegram chats from seized devices and the key observations of the analysis are as below: a. Analysis of CDRs indicates frequent calls between the phone numbers 988XXXX277 (registered in the name of Ashish Kelkar) and 772XXXX688 (registered in the name of Rutvik Jadhav....
X X X X Extracts X X X X
X X X X Extracts X X X X
....Noticee Nos. 1 to 5 (Profit Makers) and whether they were squared off immediately after the said recommendations were broadcasted. 22. Based on analysis of the available records, many instances of sharing of advance information by Guest Experts to Profit Makers, and subsequent trading based on such information, have been observed. Details of such trades are being provided separately. However, some of these instances are being discussed in the immediately succeeding paragraphs. E.1. Sharing of advance information between Simi Bhaumik and Partha Sarathi Dhar followed with trade by Partha Sarathi Dhar and Nirmal Kumar Soni (Manan Share com Private Limited) 23. It is observed from the available records that on August 25, 2022, Simi Bhaumik recommended 'Buy' for BALRAMPUR CHINI' on Zee Business. The evidence in the form of video recording obtained from the said news channel shows that the recommendation "BALRAMPUR CHINI" appeared on the screen at around 10:42AM. The screenshot below depicts such recommendation. Screenshot no. 1 24. On analysis of the Whatsapp chats shared between Simi Bhaumik (974XXXX790) and Partha Sarathi Dhar (974XXX921), it is seen that th....
X X X X Extracts X X X X
X X X X Extracts X X X X
....8155H) (AAPCM9816L) Contract Name BALRAMPUR CHINI SEP Futures BALRAMPUR CHINI 360 CE Expiry Date September 29, 2022 Trade Leg First leg of Trade Second leg of Trade First leg of Trade Second leg of Trade Buy Sell Buy Sell Date August 25, 2022 Order Start Time 10:35:24 AM 10:41:56 AM 10:39:47 AM 10:41:35 AM Order End Time 10:39:53 AM 10:41:56 AM 10:39:56 AM 10:44:13 AM Trade Start Time 10:35:28 AM 10:42:14 AM 10:39:47 AM 10:42:12 AM Trade End Time 10:39:53 AM 10:42:15 AM 10:39:57 AM 10:44:14 AM Average Price 360.93 364.00 21.60 23.21 Traded Quantity 33,600 33,600 1,08,800 1,08,800 Total Value Traded (Rs.) 1,21,27,120 1,22,30,400 23,50,000 25,25,360 Client Traded Val to Market Val 0.44% 2.65% Client Traded Val in the select security vis-à-vis all securities in the market 25.61% 7.20% Profit 1,03,280 1,75,360 29. From the above it is observed that both Partha Sarathi Dhar and Manan Sharecom initiated their Buy orders at 10:35:24 Hrs and 10:39:47 Hrs,....
X X X X Extracts X X X X
X X X X Extracts X X X X
.... Table No. 5 DATE SYMBOL INSTR TYPE BUY QTY BUY VALUE BUY TRADE START TIME SEL L QTY SELL VALUE SELL TRADE END TIME Reco Time 13-May- 22 COROMA NDEL FUTS TK 625 5,66,250.00 12:44:28 625 5,67,531.25 12:46:41 12:46 20-May- 22 SBILIFE FUTS TK 2,250 24,32,437.50 12:36:42 2,250 24,33,900 12:48:35 12:48 33. On assessing the sequence of above events, it is seen that Simi Bhaumik received recommendations in advance from Mudit Goyal and in turn she passed on the information to her husband Partha Sarathi Dhar, who then executed trades based on receipt of those recommendations. It can further be seen that the trading activities/ decisions of Partha Sarathi Dhar were influenced by the advance information received from Simi Bhaumik, who in turn received those recommendations from Mudit Goyal. Considering the connections and other material evidence, the above sharing of information by Mudit Goyal to Simi Bhaumik and then to Partha Sarathi Dhar, who then executed trades in that segment suggest that sharing of information by Mudit Goyal was not in the ordinary course of sharing between two experts. ....
X X X X Extracts X X X X
X X X X Extracts X X X X
....n analysis of the trades executed by SAAR Commodities Private Limited and Partha Sarathi Dhar in "CHAMBLFERT" revealed as under: Table No. 6 DATE 22-Jun-22 SYMBOL CHAMBLFERT PAN AAJCS7343G ASCPD8155H Client Name SAAR Commodities Private Limited Partha Sarathi Dhar INSTRUMENT TYPE OPTSTK FUTSTK OPTION TYPE PE FF STRIKE PRICE 280.00 270.00 0.00 EXPIRY DATE 30-Jun-2022 BUY QTY 45,000 60,000 6,000 BUY VALUE (in lakhs) 4,65,825 3,55,275 16,62,975 BUY TRADE START TIME 14:00:20 14:00:34 - BUY TRADE END TIME - - 15:01:35 SELL QTY 45,000 60,000 6,000 SELL VALUE (in lakhs) 4,92,675.00 3,75,525.00 16,66,200.00 SELL TRADE END TIME 14:15:54 14:15:15 - SELL TRADE START TIME - - 14:09:30 Recommendation Time ~14:10 39. From the above, it can be seen that the "sell" recommendation pertaining to "CHAMBLFERT" was broadcasted at 14:10 Hrs. It is further observed that the first leg of the trades was initiated by SAAR Commodities at 14:00:20 Hrs (for buying of PUT option, quantity of 4....
X X X X Extracts X X X X
X X X X Extracts X X X X
....d. The trading details, as analysed, are as follows: Table No. 7 DATE SYMBOL OPTION TYPE STRIKE PRICE PAN Client Name BUY QTY BUY VALUE (in lakhs) BUY TRADE START TIME SELL QTY SELL VALUE (in lakhs) SELL TRADE END TIME Reco Time 18-Aug-22 INDIA CEM CE 200 AAXFK5345H Kanhya Trading Company 1,97,200 11.13 12:45:05 1,97,200 11.31 12:52:07 12:51 44. On the basis of the foregoing, it is seen that advance knowledge of the non-public information pertaining to the recommendations was shared amongst Simi Bhaumik, Mudit Goyal and Kiran Jadhav. It can also be seen that the advance information regarding the recommendations of Simi Bhaumik, Mudit Goyal and Kiran Jadhav was shared with Nirmal Kumar Soni, who used various trading accounts including that of Kanhya Trading Company for taking positions in the market and subsequently squaring them off on the same day af....
X X X X Extracts X X X X
X X X X Extracts X X X X
....r to sharing the same on Zee Business. As per this arrangement, he has paid me total cash of around Rs. 75 lacs in person each time at Haldirams, Rabindra Sadan, Kolkata in 3 installments till date. I am yet to receive around Rs. 1 crore more from him." 49. Similarly, it is noted that Mudit Goyal, in his statement recorded on January 19, 2023, inter alia, stated the following: "I Mudit Goyal hereby admitted that .........I share my Stock Recommendation to ......, Kiran Jadhav & Simi Bhaumik and Ashish Kelkar. We initiate position before appearing to media (Zee Business) and Exit positions after giving calls on Zee Business....." 50. Further, Kiran Jadhav, in his statement recorded on January 19, 2023, inter alia, stated as under: "I Kiran Jadhav, do hereby agree that we had given intra day stock recommendations in advance before coming on live television in Zee Business to Mr. Nirmal Soni and he parted some of the profits to us via cash......We also used to receive such recommendations from Mr. Mudit Goyal before going live and we used to share these recommendations with Mr. Nirmal Soni....." 51. Further, in the statement of examination on oath o....
X X X X Extracts X X X X
X X X X Extracts X X X X
....ELL VALUE 32,99,025.00 SELL TRADE END TIME 13:14:55 Guest Ashish Kelkar Reco Time ~13:13 56. From the above screenshots, it is observed that advance knowledge regarding the recommendation pertaining to 'ADANI ENT' was shared amongst Ashish Kelkar, Simi Bhaumik and Nirmal Kumar Soni. Further, it can be seen that advance information of the said recommendation was used by Nirmal Kumar Soni to execute trades in the trading account of Kanhya Trading Company. E.7. Sharing of advance information amongst Ashish Kelkar, Kiran Jadhav, Nirmal Kumar Soni and Nitin Chhalani 57. A Telegram chat dated March 16, 2022 between Ashish Kelkar and (988XXXX277) and Kiran Jadhav (982XXXX880) has been retrieved which indicates that they discussed about sharing stocks recommendation with Nirmal Kumar Soni (NS). The screenshot of the said chat is shown below- Screenshot no. 13 58. It is noticed that a whatsapp conversation took place on June 30, 2022 between Nirmal Kumar Soni and Ashish Kelkar. On July 01, 2022 Nirmal Kumar Soni (from his number 773XXXX742). had shared a screenshot of the aforesaid conservation with Nitin Chhalani (977XXXX111). Perusal of the said c....
X X X X Extracts X X X X
X X X X Extracts X X X X
.... 12 Date Guest Expert Time of message Recommendation as per message Actual Recommendation time Actual Recommendation Screenshot No. (Screenshot provided in following table) June 30, 2022 HG (Himanshu Gupta) 09:18 AM Buy Tata Motors 09:25 AM Buy Tata Motors Jul Fut 6 09:23 AM Buy India Cem 09:26 AM Buy India Cements Jul Fut 7 MG (Mudit Goyal) 09:47 AM ITC 270 CE JULY 09:49 AM Buy ITC 270 CE (JULY) 8 62. Below table further contains the screenshots of the video recording of Zee Business shows provided by ZMCL for June 30, 2022. Table no. 13 63. Relevant trades executed by one of the Profit Makers (SAAR Commodities) on June 30, 2022 is shown below- Table No. 14 DATE SYMBOL OPTION TYPE STRIKE PRICE PAN Client Name BUY QTY BUY VALUE (in lakhs) BUY TRADE START TIME SELL QTY &....
X X X X Extracts X X X X
X X X X Extracts X X X X
....9, 2022 Trade Leg First leg of Trade Second leg of Trade First leg of Trade Second leg of Trade Buy Sell Buy Sell Date Sep 02, 2022 Order Start Time 2:07:50 PM 2:15:46 PM 2:13:20 PM 2:15:16 PM Order End Time 2:11:35 PM 2:16:29 PM 2:15:38 PM 2:15:28 PM Trade Start Time 2:07:50 PM 2:15:46 PM 2:13:20 PM 2:15:16 PM Trade End Time 2:11:35 PM 2:16:31 PM 2:15:38 PM 2:15:31 PM Average Price 248.9 334.43 290.94 317.67 Traded Quantity 14,550 14,550 4,500 4,500 Total Value Traded (INR) 36,21,443 48,65,985 13,09,208 14,29,500 Client Traded Val to Market Val 2.33% 0.75% Client Traded Val in the select security vis-à-vis all securities in the market 8.39% 2.41% Profit INR 12,44,542 INR 1,20,292 67. From the above, it can be seen that both the entities Manan Sharecom and SAAR Commodities initiated their buy orders at 2:07:50 PM and 2:13:20 PM, respectively, which is immediately preceding the relevant recommendation that was broadcasted on the show around 02:15 PM. Further, sell orders were placed by M....
X X X X Extracts X X X X
X X X X Extracts X X X X
....Buy orders at 1:34:01 PM i.e. immediately before the recommendation was broadcasted on the show around 01:35 PM. Further, the sell orders were placed by the entity between 1:36:02 PM and 1:37:00 PM i.e. immediately after the recommendation was aired. The above table also shows that through the above mentioned trade, substantial amount of profit was earned by the Noticee. The connection of Nirmal Kumar Soni with Ashish Kelkar has been discussed at para 14. The connection of Nirmal Kumar Soni with Kanhya Trading Company has been discussed at para 16. Further the sharing of advance information between Ashish Kelkar and Nirmal Kumar Soni has been discussed at para 57-58. These communications were recovered from another phone of Nirmal Kumar Soni (773XXXX742). This establishes the complete connection of scrip/contract recommendation by Ashish Kelkar and trading by Kanhya Trading company based on such recommendations. E.10. Trades of SAAR Commodities Private Limited and Manan Sharecom Private Limited based on recommendations of 'Himanshu Gupta' 71. On September 20, 2022, Himanshu Gupta gave the following recommendation under the tagline 'Hitman Himanshu' on Zee Business for t....
X X X X Extracts X X X X
X X X X Extracts X X X X
.... and only a very insignificant part of the total trades was placed at 2:29:51 PM. The above table also shows the substantial amount of profit earned by those two Noticees through their trading in PNB 42 CE contract, wherein Himanshu Gupta had made recommendation on the channel of Zee Business. It has already been discussed in earlier part of this order that Nirmal Kumar Soni is a Director and Authorised Signatory of Manan Sharecom Private Limited (para 12.1). Connection of Nirmal Kumar Soni with SAAR commodities has already been discussed at para17. Further, sharing of advance information between Himanshu Gupta and Nirmal Kumar Soni (through Ashish Kelkar) has been discussed at para 58 and therefore, it can be evidently seen that trades in the account of Noticees Nos. 3 and 4 were influenced by the sharing of information pertaining to the recommendation to be made by Himanshu Gupta. E.11. Trades of SAAR Commodities based on recommendations of Mudit Goyal 75. It is observed that on August 08, 2022, Mudit Goyal gave the following recommendation under the tagline 'Munafe wale Mudit' on Zee Business for 'HINDCOPPER 105 CE'': Table No. 21 Scrip/contract Recommendati....
X X X X Extracts X X X X
X X X X Extracts X X X X
....etween Mudit Goyal and Nirmal Kumar Soni has been discussed at para 36-46. 80. The overall sharing of information/ recommendation between Guest Experts and Profit Makers can be summarized pictorially as below: Illustration 13 81. From the above, it is clear that the Guest Experts, directly/indirectly, used to share information with Nirmal Kumar Soni and Partha Sarathi Dhar, in advance, about the recommendations to be given by them on Zee Business. Certain instances have also been observed where the advance information about recommendations was shared amongst the Guest Experts. Further, it is noted from the above illustrations that the Noticees Nos. 1 to 5 took positions in the scrip/contract right before the recommendations were made to the public. Subsequently, those positions were squared off after the recommendations were telecasted, at a favourable price than at which the positions were taken in the scrip/contract, thereby generating profits. F. Increase in trade volumes as well as positive movement of price in line with the direction of the recommendations 82. Having seen how advance information about Guest Experts' recommendations were shared with Profit ....
X X X X Extracts X X X X
X X X X Extracts X X X X
....15 mins [t+15] (number of shares/underlying shares) 56,221 81,280 90,667 Relevant Price Sensitive Corporate Announcement on the day of the recommendation or the prior day No 85. The analysis of the price impact shows the following- * In the preceding 15 minutes before the recommendation, the average high/low price variation was relatively low at 0.24%, 0.26% and 2.26% for BALRAMCHIN (EQ), BALRAMCHIN Sep Futures and BALRAMCHIN 360CE respectively. * However, during the recommendation time and the subsequent 2 minutes (t and t+2), there was a significant surge in price volatility, with an average high/low variation of 0.48%, 0.47% and 3.77% for BALRAMCHIN (EQ), BALRAMCHIN Sep Futures and BALRAMCHIN 360CE respectively. * In the succeeding 15 minutes (t+15) after the recommendation, the average high/low variation stood at 0.29%, 0.27% and 2.23% for BALRAMCHIN (EQ), BALRAMCHIN Sep Futures and BALRAMCHIN 360CE respectively. 86. An analysis of the volume impact shows the following- * The average trading volume in the 15 minutes leading up to the recommendation (t-15) was 35,....
X X X X Extracts X X X X
X X X X Extracts X X X X
....price and volume of the scrip. 91. Analysis of the impact on the price and volume in the contract on being recommended in the show is given below- Illustration No. 16 Table No. 24 Recommendation date September 02, 2022 Recommendation time (t) ~02:15 PM Scrip/Contract Recommended INDIAMART 4600 CE Recommended Levels Recommended Price (INR) 290 Target Price (INR) 580/600 Stop Loss (INR) 240 Price Impact Post Recommen dation Average High/ Low Variation % in preceding 15 mins [t-15] 1.28 Average High/ Low Variation % during recommendation time and succeeding 2 mins [t and t+2] 12.64 Average High/ Low Variation % in succeeding 15 mins [t+15] 5.06 Volume Impact Post Recommen dation Avg Trading Vol in Preceding 15 mins [t-15] (number of underlying shares) 2411 Avg Trading Vol during recommendation time and succeeding 2 mins [t and t+2] (number of underlying shares) 36,300 Avg Trading Vol for succeeding 15 mins [t+15] (number of underlying shares) 14,540 Relevant Price Sensitive Corporate Announcement on the day of the recommendation or th....
X X X X Extracts X X X X
X X X X Extracts X X X X
....ul to examine the impact of such recommendation on price and volume of the said scrip/derivative contract. 97. Analysis of the impact on the price and volume in the contract on being recommended in the show is given below- Illustration No. 17 Table No.25 Recommendation date August 17,2022 Recommendation time (t) ~01:35 PM Scrip/Contract Recommended GNFC 800 CE Recommen ded Levels Recommended Price (INR) 20 Target Price (INR) 35 Stop Loss (INR) 17 Price Impact Post Recommen dation Average High/ Low Variation % in preceding 15 mins [t-15] 4.14 Average High/ Low Variation % during recommendation time and succeeding 2 mins [t and t+2] 9.45 Average High/ Low Variation % in succeeding 15 mins [t+15] 4.28 Volume Impact Post Recommen dation Avg Trading Vol in Preceding 15 mins [t-15] (number of underlying shares) 60,147 Avg Trading Vol during recommendation time and succeeding 2 mins [t and t+2] (number of underlying shares) 6,31,800 Avg Trading Vol for succeeding 15 mins [t+15] (number of underlying shares) 2,31,313 Relevant Price Sensitive Corporate Announcement on the day of the recommendation o....
X X X X Extracts X X X X
X X X X Extracts X X X X
....lume in the contract on being recommended in the show is given below- Illustration No. 18 Table No. 26 Recommendation date September 20,2022 Recommendation time (t) ~02:27 PM Scrip/Contract Recommended PNB 42 CE Recommended Levels Recommended Price (INR) 1.2 Target Price (INR) 2.50/2.75 Stop Loss (INR) 0.8 Price Impact Post Recommendation Average High/ Low Variation % in preceding 15 mins [t-15] 3.61 Average High/ Low Variation % during recommendation time and succeeding 2 mins [t and t+2] 9.72 Average High/ Low Variation % in succeeding 15 mins [t+15] 5.84 Volume Impact Post Recommendation Avg Trading Vol in Preceding 15 mins [t-15] (number of underlying shares) 16,21,333 Avg Trading Vol during recommendation time and succeeding 2 mins [t and t+2] (number of underlying shares) 73,92,000 Avg Trading Vol for succeeding 15 mins [t+15] (number of underlying shares) 25,98,400 Relevant Price Sensitive Corporate Announcement on the day of the recommendation or the prior day No 104. From the above, a sudden spurt in the price and trading volume of the contract can be witnessed right after the b....
X X X X Extracts X X X X
X X X X Extracts X X X X
.... Illustration No. 19 Table No. 27 Recommendation date August 08, 2022 Recommendation time (t) Appearance at 01:05 PM Recommendation at 1:06PM Scrip/Contract Recommended HINDCOPPER 105 CE Recommended Levels Recommended Price (INR) 6.5 Target Price (INR) 14 Stop Loss (INR) 4 Price Impact Post Recommendation Average High/ Low Variation % in preceding 15 mins [t-15] 3.83 Average High/ Low Variation % during recommendation time and succeeding 2 mins [t and t+2] 8.45 Average High/ Low Variation % in succeeding 15 mins [t+15] 3.22 Volume Impact Post Recommendation Avg Trading Vol in Preceding 15 mins [t-15] 98,900 Avg Trading Vol during recommendation time and succeeding 2 mins [t and t+2] 10,40,600 Avg Trading Vol for succeeding 15 mins [t+15] 3,03,580 Relevant Price Sensitive Corporate Announcement on the day of the recommendation or the prior day No 111. From the above, a sudden spurt in the price and trading volume of the contract can be witnessed right after the recommendation was made on Zee Business. 112. Analysis of price impact shows as under- * In the preceding 15 minutes b....
X X X X Extracts X X X X
X X X X Extracts X X X X
....ompany) through their Directors and authorised persons. It has been discussed earlier that Noticee No. 3 (SAAR Commodities) had executed trades through the terminal of Noticee No. 9 (SAAR Securities) and the above two entities were having common Directors viz., Noticeea Nos. 7 and 8 (Rupesh Kumar Matoliya and Ajaykumar Ramakant Sharma). The records have shown that Noticees Nos. 7 and 8 being Directors of Noticee No. 3 were aware that trades in the account of the Noticee No. 3 was being executed by the Noticee no 1, who was in possession of non-public information of recommendations of Guest Experts before being broadcasted. The connection between Nirmal Kumar Soni and Kanhya Trading Company/Nitin Chhalani has been discussed at para 16. Connection amongst Nirmal Kumar Soni, SAAR Commodities and SAAR securities have been discussed at para 17. Detailed discussion at para 16 and para 17 establishes how Enablers (Noticees Nos 6 to 10) helped Noticees Nos 1,3,4 and 5 in their trades based on advance information of recommendations of Guest Experts. 117. In particular, it is seen that the proximity of communication between the Noticee No. 1 and Director of Noticee No. 9, SAAR Securities,....
X X X X Extracts X X X X
X X X X Extracts X X X X
....ons based trades have been seen to be executed with the help of Enablers (Noticees Nos 6 to 10) 119. The role played by each of Noticees in successfully executing recommendation based trades and generating profit is explained through an illustration below- Illustration No. 20 120. The summary of the intraday trades executed by Profit Makers i.e. Noticees Nos. 1 to 5 in both equity and equity derivative segment and the profits earned through trades during the investigation period, is placed below. It is clarified that this is summary of all intraday trades and not necessarily on recommendations based trades covered in this order. Table No.28 Name Partha Sarathi Dhar Kanhya Trading Company SAAR Commodities Private Limited Manan Sharecom Private Limited Nirmal Soni PAN ASCPD8155H AAXFK5345H AAJCS7343G AAPCM9816L BCHPS4866G Equity No of instances 506 16 - - - Gross Traded Value (INR) 1,84,43,07,592 38,33,097 -....
X X X X Extracts X X X X
X X X X Extracts X X X X
....ounts of Profit Makers. It has also been noticed that on several instances the entire position taken in the first leg was not squared off during the second leg of the trades and therefore there may be a case for not including such trades as trade based on recommendations. Under the circumstances, for the purposes of calculating the profit earned by the Noticees (Profit Makers) on recommendations based trades, certain parameters have been considered to select only specific intraday trades and the selection criteria is mentioned below- i. Recommendation in the scrip/contract is provided by the Guest Expert on Zee Business on the same day the trade was executed. ii. The timing of the first leg of the trade is before the recommendation time. iii. First leg of the trade was executed in the direction of the recommendation i.e. if the recommendation was 'buy', then 'buy' trade was executed and if recommendation was 'sell' then 'sell' trade was executed. iv. The traded quantity of the second leg, post-recommendation, exceeded 50% of the total quantity traded in the first leg. 122. The profit from recommendation based trades has been calculated using t....
X X X X Extracts X X X X
X X X X Extracts X X X X
.... 14,17,822 63 22,505 4,43,975 6 73,996 31% 10% 329% Total 13,60,21,794 12,399 10,970 7,41,29,648 1,047 70,802 54% 8% 645% 124. Further, profit analysis of Profit Makers from recommendation based trades (Guest Expert wise) during the investigation period is provided below- Table No. 30 PAN Name Guest Expert Segment Profit (INR) Trade Instances AAJCS7 343G SAAR Commodities Private Limited KIRAN JADHAV EQ-DERV 1,41,75,013 113 ASHISH KELKAR EQ-DERV 1,02,00,019 106 HIMANSHU GUPTA EQ-DERV 96,71,340 136 MUDIT GOYAL EQ-DERV 58,74,892 95 SIMI BHAUMIK EQ-DERV 38,36,432 56 SAAR Commodities Private Limited Total 4,37,57,697 506 AAPCM9 816L Manan Sharecom Private Limited KIRAN JADHAV EQ-DERV 47,25,506 33 ASHISH KELKAR EQ-DERV 46,88,930 31 MUDIT GOYAL EQ-DERV 19,34,856 25 HIMANSHU GUPTA EQ-DER....
X X X X Extracts X X X X
X X X X Extracts X X X X
....stigation period, a profit of INR 2,46,54,590 was earned through 4,700 trade instances during the investigation period, out of which INR 1,35,01,336, was earned from 135 instances of recommendation based trades. Thus, more than half the profit is earned through recommendation based trading which were only 135 out of total 4700 trades. Further, it is seen that the average profit earned from recommendation based trades is around 1907% of the average profit earned from total trades. 128. In the case of Kanhya Trading Company, it is observed that it had earned a profit of INR 2,16,84,299 through 531 trade instances during the investigation period, out of which INR 1,10,41,979 was generated from 98 trade instances of recommendation based trades. Thus, more than half the profit is earned through recommendation based trading which were only 98 out of total 531 trades. Further, the average profit earned from recommendation based trades is around 276% of the average profit earned from total trades. 129. With respect to the Partha Sarathi Dhar, it is observed that he had earned a profit of INR 59,43,635 through 2,545 trade instances during the investigation period, out of which INR 53,....
X X X X Extracts X X X X
X X X X Extracts X X X X
....1 6L Manan Sharecom Private Limited EQ- DERV 8,13,155 13 AAXFK534 5H Kanhya Trading Company EQ- DERV 5,12,855 6 ASCPD815 5H Partha Sarathi Dhar EQ- DERV 17,59,015 72 EQ- CASH 26,12,126 139 SIMI BHAUMIK Total 95,33,583 286 Grand Total 7,41,29,648 1,047 131. In view of the above observations, it can be seen that profit generated in the accounts of the Profit Makers are quite substantial, when compared with the profits on trades otherwise executed in the accounts of these Profit Makers. It is also seen that from the trades that are observed to have been executed based on the advantage of advance receipt of information about recommendations of Guest Experts, the Noticees have collectively earned substantial profit to the tune of INR 7,41,29,648 from 1047 instances, constituting 54% of the total profit earned during the relevant period. From the above, it can be seen that a considerable portion of their respective profit was earned through trades based on recommendations vis- a-vis their total trades. Further, Table No. 31 also provides the detailed breakup of the profit earned by the Noticee No. 1 to 5 (Guest Exper....
X X X X Extracts X X X X
X X X X Extracts X X X X
....of INR 20 was used to settle his part of the profit in cash/ through mode other than banking channel. 3 Ashish (988XXXX277) WhatsApp chat and Lalu (8850614864) From the WhatsApp chat between Ashish and "Lalu", it is observed that image of one INR 10 note is exchanged between Ashish and Lalu with a mention of name along with mobile number as "Gupta ji - 844XXXX0469" As observed earlier, the mobile number (84XXXX0469) belongs to Himanshu Gupta. From the above, it is probable that the INR 10 was used to sharing commission generated out of trades executed based on the recommendation of Guest Experts. 4 Ashish WhatsApp chat and Lalu (885XXXX864) As observed from the WhatsApp chat between Ashish and "Lalu", image of one INR 10 note is exchanged between Ashish and Lalu with a mention of a name along with mobile number as "Mr Goyal -925XXXX511" It is to be noted from preceding paragraphs that same mobile number (i.e. 925XXXX511) belongs to Mudit Goyal and it is probable that the image or the Note was used to receive his (Mudit Goyal's) share of the profit/commission. 5 Nirmal(773XXXX742) WhatsApp Chat and Uncl New (+4475XXXXX587) In the WhatsApp chat dated Aug 05....
X X X X Extracts X X X X
X X X X Extracts X X X X
....sh, I confirm the share of gain received by us is 85% to me and 15% belongs to Mr. Ashish. We also used to receive such recommendations from Mr. Mudit Goyal before going live and we used to share these recommendations with Mr. Nirmal Soni. 25% of the gain is shared to Mr. Mudit and remaining amount we share between at 85% and 15% ratio as above. The said transactions took place in the last seven months involving around Rs. 60-70 lakhs approximately among all three of us, i.e. Mr. Mudit, Mr. Ashish and me." 138. In the statement of examination on oath of Mudit Goyal, which was recorded on January 19, 2023, the following was inter alia stated under oath: "With .......Kiran Jadhav/ Ashish Kelkar I had a profit sharing arrangement. As they told, I believe their profit figure which they would later share with me....25% from Kiran Jadhav/ Ashish Kelkar. All profit part I received in cash...." 139. In the statement of examination on oath of Simi Bhaumik, which was recorded on January 19, 2023, the following was inter alia stated under oath: "Further, I am also having profit-sharing arrangement (50:50) with Nirmal Kumar Soni (Jaipur, mobile no- 773XXXX742) ....
X X X X Extracts X X X X
X X X X Extracts X X X X
....f the substantial impact these recommendations wielded over prices and trading volumes of scrip/contract recommended. Around the time of the broadcast of recommendations of the Guest Experts, there was favourable movement in scrip/contract price and trading volumes, aligned to the recommendation made by Guest Experts. The average traded volume around the recommendation was substantially higher as compared to the average traded volume during the preceding 15-minutes period prior to the broadcasting of recommendations. c) Noticees had a reasonable expectation of an increase in the price and volume traded in the scrip/contract following the broadcasting of the recommendations on the channel. Hence, till the time the recommendations were made public, it remained a non-public information. d) Noticees devised a scheme to take advantage of the advance possession of non-public information about the recommendations given by Guest Experts on the shows. The scheme involved Guest Experts to share, directly or indirectly, their recommendations with Nirmal Kumar Soni and Partha Sarathi Dhar, before the same were broadcasted on Zee Channel. The exact timings of the shows were al....
X X X X Extracts X X X X
X X X X Extracts X X X X
....s of the SEBI Act, the PFUTP Regulations, SEBI (Research Analyst) Regulations and SEBI (Intermediaries) Regulations are reproduced below- SEBI Act 11 (4) Without prejudice to the provisions contained in sub-sections (1), (2), (2A) and (3) and section 11B, the Board may, by an order, for reasons to be recorded in writing, in the interests of investors or securities market, take any of the following measures, either pending investigation or inquiry or on completion of such investigation or inquiry, namely: - (a) suspend the trading of any security in a recognised stock exchange; (b) restrain persons from accessing the securities market and prohibit any person associated with securities market to buy, sell or deal in securities; (c) suspend any office-bearer of any stock exchange or self-regulatory organisation from holding such position; (d) impound and retain the proceeds or securities in respect of any transaction which is under investigation; .... Power to issue directions and levy penalty. 11B. Save as otherwise provided in section 11, if after making or causing to be made an enquiry, the Board is satisfie....
X X X X Extracts X X X X
X X X X Extracts X X X X
....to be listed on a recognised stock exchange, in contravention of the provisions of this Act or the rules or the regulations made thereunder; ... (e) deal in securities while in possession of material or non-public information or communicate such material or non-public information to any other person, in a manner which is in contravention of the provisions of this Act or the rules or the regulations made thereunder; PFUTP Regulations 3. Prohibition of certain dealings in securities (a) buy, sell or otherwise deal in securities in a fraudulent manner; (b) use or employ, in connection with issue, purchase or sale of any security listed or proposed to be listed in a recognized stock exchange, any manipulative or deceptive device or contrivance in contravention of the provisions of the Act or the rules or the regulations made there under; (c) employ any device, scheme or artifice to defraud in connection with dealing in or issue of securities which are listed or proposed to be listed on a recognized stock exchange; (d) engage in any act, practice, course of business which operates or would operate as fraud or deceit upon any person in c....
X X X X Extracts X X X X
X X X X Extracts X X X X
....SEBI Act and Regulations 3 and 4 of PFUTP Regulations; (ii) Regulation 2(1)(c) and Regulation 16(2) of SEBI (Research Analyst) Regulations, 2014 read with Regulation 2(1)(b) of SEBI (Intermediaries) Regulations, 2014; 147. If there is a violation of sections/regulations listed in the preceding paragraph, it will then be required to be examined whether there are sufficient grounds for issuance of direction under section 11(1), 11(4) and 11B (1) of SEBI Act. K.1. Violation of Section 12A of SEBI Act and Regulations 3 and 4 of PFUTP Regulations: 148. These provisions have been reproduced in the earlier paragraph. In brief, these provisions prohibit- (i) use of or employment of any manipulative or deceptive device or contrivance, in contravention of the provisions of the SEBI Act or rules or regulations; (ii) employment of any device scheme or artifice to defraud; (iii) 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; (iv) dealing in securities while in possession of material or non-publ....
X X X X Extracts X X X X
X X X X Extracts X X X X
....ntal to the interest of integrity of the securities market and also adverse to the interest of investors who invest based on recommendations of Guest Experts totally unaware of any scheme being employed by them. Further, it has been set out in detail that the unfair gains so earned by Profit Makers have also been shared with Guest Experts which has been admitted under statement on oath and there are evidences of such gains being shared through non-banking channels. Hence, not only Noticees have dealt in securities while in possession of non-public information, they have also devised a scheme to defraud investors in connection with dealing in listed securities. All this seen together would clearly demonstrate that there is a prima facie case of violation of provisions of section 12A of SEBI Act and Regulations 3 and 4 of PFUTP Regulations. This finding is further strengthened in subsequent paragraphs. 151. It will be relevant here to refer to the Palmer's Company Law, 25th Edition (2010), Volume 2 at page 11097 wherein the following has been stated: "Market manipulation is normally regarded as the "unwarranted" interference in the operation of ordinary market forces of supply and....
X X X X Extracts X X X X
X X X X Extracts X X X X
....ities based on recommendation without being aware of the manipulative scheme entered into by Profit Makers and Guest Experts with the help of Enablers. 154. Reliance is also placed on decision of Hon'ble Supreme Court in the matter of SEBI vs. Rakhi Trading Pvt. Ltd. and other connected appeals decided on February 8, 2018, wherein the Hon'ble Court while dealing with provisions of Regulation 4(1) of PFUTP Regulations held as follows: "35. Having regard to the fact that the dealings in the stock exchange are governed by the principles of fair play and transparency, one does not have to labour much on the meaning of unfair trade practices in securities. Contextually and in simple words, it means a practice which does not conform to the fair and transparent principles of trades in the stock market..." "...Securities market, as the 1956 Act provides in the preamble, does not permit "undesirable transactions in securities". The Act intends to prevent undesirable transactions in securities by regulating the business of dealing therein. Undesirable transactions would certainly include unfair practices in trade. The SEBI Act,1992 was enacted to protect the interest of the inves....
X X X X Extracts X X X X
X X X X Extracts X X X X
....d result in defeating the very object and purpose of SEBI Act. Prevention of market abuse and preservation of market integrity is the hallmark of Securities Law...Market manipulation is normally regarded as the "unwarranted" interference in the operation of ordinary market forces of supply and demand and thus undermines the "integrity" and efficiency of the market". 158. Further, in the matter of SEBI vs Rakhi Trading (supra), the Hon'ble Supreme Court observed "... market manipulation is a deliberate attempt to interfere with the free and fair operation of the market and create artificial, false or misleading appearances with respect to the price, market, product, security and currency". 159. In this case as well, there are evidences of market abuse and weakening of market integrity since there is no free and open access to information. The information is first shared with select few with an intention to make unlawful gains before being shared in an open manner. Such practices shake investors' confidence in stock market and interfere in the operation of ordinary market forces of supply and demand thereby challenging market integrity. 160. In view of the factual anal....
X X X X Extracts X X X X
X X X X Extracts X X X X
.... securities through any means including by paying, offering or agreeing to pay or offer any money or money's worth, directly or indirectly, to any person; (o) Fraudulent inducement of any person by a market participant to deal in securities with the objective of enhancing is brokerage or commission or income. 162. The evidences collected and discussed in earlier part of this order clearly brings out that (i) Noticees Nos 1 to 5 made profit and shared such profit with Noticees Nos. 11 to 15 (Guest Experts) whose recommendations induced person (viewers of their show) to dealing in securities recommended by them while at the same time Profit Makers front running in those securities. Thus, it is deemed to be fraudulent or an unfair trade practice under clause (d) of sub-regulation 2 of regulation 4 of PFUTP regulations; (ii) Out of five Guest Experts, two were registered RAs and one employee of registered RA during the investigation period. They have fraudulently induced viewers of their show to deal in securities with the objective of enhancing their income. This is deemed to be fraudulent or an unfair trade practice under clause (o) of sub-regulation 2 o....
X X X X Extracts X X X X
X X X X Extracts X X X X
....held prima facie that Simi Bhaumik has violated provisions of regulation 16(2) of SEBI (Research Analyst) Regulations, 2014 by sharing information with her husband who dealt in those securities and made unfair profits. L. Need for interim ex-parte order 165. Having discussed the acts being prima facie in violations of SEBI Act, and regulations made thereunder, it would be important to examine the requirement to pass this interim ex-parte order. Section 11(4) and 11B reproduced earlier (para 145) allow SEBI to restrain persons from accessing the securities market and prohibit any person associated with securities market to buy, sell or deal in securities and to issue "such directions as may be necessary" in the interest of investors of the securities market. In the present case, the investigation has been successfully able to prima facie highlight the scheme and device orchestrated intricately by Noticees where the non-public information about the impending stock recommendation was passed on by Guest Experts, knowing fully well that such a recommendation was going to cause an impact on the price/volume of the scrip/contract. The Profit Makers took position in the same scrip/co....
X X X X Extracts X X X X
X X X X Extracts X X X X
....estment in the securities market. 167. The facts of this case demonstrates clear scheme of manipulation to harm the interest of investors by misguiding them to take position in securities so that Profit Makers could make profit at the cost of such investors. Unlawful gains made by these Profit Makers come, directly or indirectly, from the pockets of innocent investors who follow the advice of Guest Experts unaware of the fraudulent scheme. Hence, it is necessary that whenever such schemes are noticed, steps are taken to intervene and stop further damage to securities market. Further, the wrongful gains generated from such schemes need to be disgorged. Legal discussion at paragraphs 151 to 158 further mandates SEBI to intervene and contain any further damage. 168. Keeping in views the above discussion, I am of the view that it is a fit case to pass ad interim ex parte order to insulate the securities market from the mischievous act of Noticees and also to prevent these Noticees in conducting similar activities which are prima facie against the interest of investors as well as against the development of securities market. Further, there is an urgency to protect the wrongful gai....
X X X X Extracts X X X X
X X X X Extracts X X X X
....if any, as there would be chances of such monies being dissipated by the appellant. " 172. In view of the foregoing compelling facts and circumstances and after careful consideration of the totality of the facts surrounding the case, I am of the view that this is a fit case to invoke the statutory powers vested in SEBI to pass interim directions against Noticees through this order, M. Joint and several liability 173. Having held that facts of this case warrant invocation of power for issuance of interim order, the issue which now merits discussion is who amongst Noticees, would be prima facie held liable for impounding of unlawful gains generated by the employment of the prima facie fraudulent scheme devised by Noticees. From the above discussion, I note that the Noticees have played specific roles at various stages which have, prima facie, been found to be in violation of the SEBI Act and the regulations made thereunder. Analysis of evidences gathered in the course of investigation reveal that Guest Experts shared advance information pertaining to recommendations to be made by them with Profit Makers (Noticee Nos. 1 and 2), before the broadcast of the recommendation....
X X X X Extracts X X X X
X X X X Extracts X X X X
....u Gupta (Noticee No. 13), Mudit Goyal (Noticee No. 14), Simi Bhaumik (Noticee No. 15). Manan Sharecom Pvt Ltd. (Noticee No. 4) 1,35,01,336 Nirmal Kumar Soni (Noticee No. 1), . Kiran Jadhav (Noticee No. 11), Ashish Kelkar (Noticee No. 12), Himanshu Gupta (Noticee No. 13), Mudit Goyal (Noticee No. 14), Simi Bhaumik (Noticee No. 15) Kanhya Trading Company (Noticee No. 5) 1,10,41,979 Nirmal Kumar Soni (Noticee No. 1), Kiran Jadhav (Noticee No. 11), Ashish Kelkar (Noticee No. 12), Himanshu Gupta (Noticee No. 13), Mudit Goyal (Noticee No. 14), Simi Bhaumik (Noticee No. 15). Total 7,41,29,648/- N. Ex-parte Interim Order 175. Keeping in view the foregoing discussions, the compelling evidences brought on record, factual analysis and my observations on various aspects of the matter wherein it has been seen as to how certain entities indulged in fraudulent and unfair acts and unlawfully enriched themselves by taking advantage of being in a position to influence innocent investors, I observe that it is a fit case to pass interim directions to insulate the securities market and investors from the mischievous acts of the entities and also to urgently preve....
X X X X Extracts X X X X
X X X X Extracts X X X X
.... be made, without permission of SEBI, in respect of the demat accounts held by the aforesaid Noticees. However, credits, if any, into the accounts maybe allowed. Banks and the Depositories are also directed to ensure that all the aforesaid directions are strictly enforced. Further, debits in the bank accounts may also be allowed for amounts available in the account in excess of the amount to be impounded. Banks are allowed to debit the accounts for the purposes of complying with this Order. g) 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 Noticees nos 1 to 5 and 11 to 15. h) Noticees nos 1 to 5 and 11 to 15.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. i) Zee Media Corporation Limited is advised to preserve and maintain all records, documents, material, video records, etc., along with their content, related to Noticee Nos. 11 to 15 and concerned shows til....
X X X X Extracts X X X X
X X X X Extracts X X X X
....ns, as the case may be. 180. Noticees may file their replies to SEBI within 21 days from the date of receipt of this Order and avail an opportunity of personal hearing in the matter, if they so desire. 181. This Order is without prejudice to the right of SEBI to take any other action that may be initiated against Noticees in accordance with law. 182. This Order shall come into force with immediate effect and shall be in force until further orders. 183. A copy of this order shall be served upon Noticees, Stock Exchanges, Banks, Zee Media Corporation Limited, Registrar and Transfer Agents and Depositories for necessary action and compliance with the above directions. ============= Document 1Business Partners Kiran Jadhav ACBPJ4456A Ashish Kelkar ACAPK0708P Nirmal Kumar Soni BCHPS4866G Document 2 veens Way M.P. Birla Planetarium Export/Print Records: 2 ISKCON Kolkata Sri Sri Radha Govinda Terole ( Pin CarNo Name Snow F F 98 90 Simi Bhaumik - BR Hotel nd Intern on 42 Nirmal Kumar Soni N bindra dan Forum Courtyard Mall Document 3 S. WhatsApp Chats of Nirmal (773XXXX742) with Nitin No. (977XX....
X X X X Extracts X X X X
X X X X Extracts X X X X
....TE LIMITED A/C NO.- CURRENT AC ACCOUNT-219010200007788 IFSC CODE-UTIB0000219 Axis Bank Ltd. Branch Goregaon Link Road, Mumbai Plz trf 1.25 as a Margin for one-two days Thanks Monday, Dec 12, 2022, 11:02 Try to trf Asap 24 Ok Document 10 Saar It 25630 Neat@CM1 Default password Ok Thursday, Jul 21, 2022, 17:39 Ok Friday, Jul 22, 2022, 14:46 Cash ka id 0- Password Mera wal remote le lo configure kar do Pro jo bhi Document 11 Saar It Ok done I'd password Thursday, Aug 04, 2022, 0804 16612 18567 ka be Saar It ID LIST PLEASE CHECK 16612 17147 16656 18567 17132 17133 19386 44056 25967 CM ID Total d hi Mns@1234 Puchta hu Man@2010 Wednesday Dec 21, 2022, 11:45 16656 Free h 100 24 Ok Document 12 Saar Securities (India) Pvt Ltd AAKCS2154C Directors Saar Commodities Pvt Ltd AAJCS7343G Common Directors Rajkumar Sharma ABEPS5013L Ramawatar L Chotia ADIPC7123K Rupesh Matoliya AFRPM8024J Ajay Sharma AZJPS8604Q Shanker R Sitaram Sharma Khandelwal APFPS2829K AMFPK53883 Fund Transfer of R....
X X X X Extracts X X X X
X X X X Extracts X X X X
....à¥à¤¦à¤¿à¤¤ गोयल की राय SBI लाइफ 1080 की कॉल @ 14 खरीदें TARGET 21/24 SBI Life 0.5m 5.05 BUZZING SECTOR STOP LOSS 11\\ 1079.55 +22.90 मà¥à¤¦à¤¿à¤¤ गोयल SMC गà¥à¤²à¥‹à¤¬à¤² Dow Futures Rolet 314 Biocon 5 2.2m 337.00 11.40 0.60 31407.00 205.00 14 BSE Cotton J34 GMR Infra' 2.8m 3 50490.00 190.00 Document 18 Mudit Goyal May 13, 2022 M&M? 1045 AM moved 10:45 AM zoomed 10:45 AM M&M top class 11:02 AM nifty also 1102AM grt calls 11:02 AM BUY COROMANDEL 900 CE CMP 30 12:36 PM coming? 12:36 PM u have closing show 12:36 PM Message Document 19 Mudit Goyal BUY SBILIFE 1080 CE CMP 13.30 YES 12:35 PM 12.45 PM 12:35 PM yes 2:03 PM Message 12:35 PM May 20, 2022 ok 12:35 PM coming? 12:35 PM good luck! 12:36 PM Document 20 S. WhatsApp Chat of Nirmal (931XXX971) with other mobile number of No. Nirmal (773XXX742) 1 +91 77370 75742 ....
X X X X Extracts X X X X
X X X X Extracts X X X X
....em? [12:53 PM 8/18/2022] Simi Bhaumk: from kiranji? 12:53 PM 8/18/20221 Vikash Parasar: Yes 112:54 PM 87 18/2uzz! Sami Baumk, hirimi see [12:53 PM 8/18/2022] Vikash Parasar: But not moб [12:54 PM 8/18/2022] Simi Bhaumk: that's y seen big ticks [12:54 PM 8/18/2022] Vikash Parasar: Mere se pahle ke h kiran ji or mudit ne buy kiya woh [12:55 PM 8/18/2022] Simi Bhaumk: mudit 2/3 lot hi karta hai Message Document 25 +91 97487 50790 June 22, 2022 Sentu changed to long for imme short term 2:36 PM [2:34 pm, 22/06/2022] Vikash Parasar: Maie ne tho abhi aasish Ji ko msg kiya h ki mudit ke call lena bandh kar do (2:35 pm, 22/06/2022] Vikash Parasar. Ye aapne ko hi supply de raha h [2:33 pm, 22/06/2022] Simi Bhaumk: achha (2:33 pm, 22/06/2022] Simi Bhaumk: samajh gaye 16 [2:33 pm, 22/06/2022] Simi Bhaumk: ho sakta hai Document 26 #Q18. कà¥à¤¯à¤¾ सिमी à¤à¥Œà¤®à¤¿à¤• Zee Business पे recommendation on stocks देने से पहले आपके साथ शेयर करती ....
X X X X Extracts X X X X
X X X X Extracts X X X X
.... Ok Tatamotor 70 Document 31 Description Screenshot 1 Screenshot Guest Expert- Himanshu Gupta Dow Futures 30918.00 Nasdaq Futures -81.00 11649.00 -42.00 Nifty 50 15857.85 0.37% ZEDBUSINESS सरकारी बैंक शेयर Punj & Sind BK 14.35 1.06% Bank of Maha 15870 15.65 0.97% fenter year UCO Bank 15770 INTEREST RATE HIKES BY 0.10% ON DEPOSIT BELOW 2 C Straits Times 11.10 09.23 गà¥à¤²à¥‹à¤¬ कैपिटल मारà¥à¤•à¥‡à¤Ÿà¥à¤¸ 0.91123 Karnataka Bank 65.20 5 Godrej Agrovet 10 0.8k 505.40 Wipro 0.3m 421.75 0.10 0.15% 2.80 3123.29 11.58 MCX BULLDEX 14243.87 1.00 4.98 Nifty Future Nifty Bank Future REDBUSINESS +17.00 33422.60 +149.55 हिटमैन हिमांश SECTOR TBC IF Bandhan Bank Jul Fut Vedanta 263.60 1.93% RE 223.10 3.86% Screenshot 2 Guest Expert- Himanshu Gupta 15796.90 276 09.15 MARKET TH....
X X X X Extracts X X X X
X X X X Extracts X X X X
....¾à¤° BTST CALL Tata Motors Jul Fut PRICE TARGET STOPLOSS खरीदें 423.60 432/435 417 बड़ी खबर Mahanagar Gas 10 46.7k M&M 9.3k 1104.50 fenterar veta bufet nga 768.35 6.50 Marut REBOUSINESS MOLDHAM BTST BUY Tata Steel Fut 888.00 6.65 TGT 902/912 SL 878 CRUDE CHECK 0.35 0.33 MCX Copper 694.25 0.00 Screenshot 7 30921.00 BTST CALL Dow Futures Nasdaq Futures INESS -0.25% 11651.25 34% India Cements Jul Fut खरीदें BTST CALL Tata Motors Jul Fut खरीदें PRICE TARGET STOPLOSS 163.10 170/172 160 TIES WITH BUNGE TO FORM ORIGEO IN BRAZIL UPL Ltd 641.70 432/435 417 2.70 0.42% Straits Times 3122.39 1.40 A 34.95 Prestige Est 10 8.8k 399.6 MCX Crude MIDCAP & SMALLCAP STOCKS 12.48 8680.00 94.00 PRICE TARGET STOPLOSS 423.60 Screenshot 8 अमेरिकी वायदा बाजार à¤....
X X X X Extracts X X X X
X X X X Extracts X X X X
....€ समीकà¥à¤·à¤¾ करे 1.25 1.05 3.4k 348.30 Divi's Lab 0.2m 3638.20 4.70 10 Venus Pipes 0.3m EEDBUSINESS | NBFC शेयर Bajaj Finance 7666.00 2.27% AB Capital 117.30 2.09% Bajaj Finserv 1800.80 1.97% utures 310 22.0 MCX Silver 56718.00 34.00 Dow Futures Nasdaq Futures 31095.00 -22.00 11993.00 -31.00 BUSINESS (हिटमैन हिमांश PNB 42 की कॉल @ 1.20 STOP LOSS 0.80 खरीदें TARGET PNB IDBI Bank 45.80 2.92% .30 2.50/2.75 41.50 +1.10 सरकार की RBI से पà¥à¤°à¥‹à¤®à¥‹à¤Ÿà¤° नियमों की समीकà¥à¤·à¤¾ की मांग Exide Ind 1.8m 167.15 A 1.65 Adani Ports 6.3m हिटमैन fecrior BUY Cipla Fut 1074.00 38.15 TGT 1100 SL 1065 Document 38 Nifty 50 ....
X X X X Extracts X X X X
X X X X Extracts X X X X
....0 Recommendation: September 02, 2022 "14:15 Close Price Volume Traded INDIAMART 4600 CE 60000 50000 14:21:00 14:22:00 14:23:00 14:24:00 14:25:00 14:26:00 14:27:00 14:28:00 14:29:00 30000 40000 20000 10000 0 Volume Traded Document 43 13:20:00 13:21:00 13:22:00 Close Price (*) 13:23:00 13:24:00 13:25:00 13:26:00 13:27:00 13:28:00 13:29:00 13:30:00 13:31:00 13:32:00 13:33:00 13:34:00 13:35:00 13:36:00 13:37:00 13:38:00 13:39:00 13:40:00 13:41:00 13:42:00 13:43:00 Recommendation: August 17, 2022 "13:35 Total Qty +Close Price GNFC 800 CE 1000000 800000 600000 400000 200000 13:44:00 13:45:00 13:46:00 13:47:00 13:48:00 13:40:00 13:50:00 ° Volume Traded Document 44 Close Price() 1.05 0.95 0.85 0.75 14:12:00 14:13:00 14:17:00 14:18:00 14:19:00 14:20:00 Reco 14:21:00 14:22:00 14:23:00 14:24:00 14:25:00 14:26:00 14:27:00 14:28:00 14:29:00 14:30:00 143100 14:32:00 14:33:00 14:34:00 14:35:00 14:36:00 14:37:00 Mp4:27 ....