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2015 (5) TMI 1265

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.... December 16, 2013, ("Patch 2") the scrip was traded only on 13 trading days and the price moved from Rs. 1006 (unadjusted and Rs. 100.6 adjusted to share split) to Rs. 910 (unadjusted and Rs. 91 adjusted to share split). Thereafter, there was a huge increase in the traded volume during the period December 17, 2013 to January 30, 2015 ("Patch 3"). The price of the scrip started falling from July 10, 2014 with volumes still being maintained and subsequently, there was a drastic fall in price from Rs. 707.5 (unadjusted and Rs. 70.75 adjusted to share split) on January 02, 2015 to Rs. 388.5 (unadjusted and Rs. 38.85 adjusted to share split) on January 30, 2015, in a span of 20 trading days. An illustration of the price/volume movement in the scrip of Pine during the Examination Period is given below: 3. As per the quarterly shareholding pattern submitted to BSE, as on September 30, 2012, Pine had a share capital of Rs. 3,00,00,000 comprising 30,00,000 equity shares of Rs.10 each, with the promoters holding 9,27,400 shares i.e. 30.91% of the total share holding. It was observed in the preliminary inquiry that: a) On December 13, 2012, Pine made a preferential allotment of 1....

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....12 the earning per shares ("EPS") of Pine was negative (i.e. Rs. - 0.24) and for the FY ended March 31, 2013, EPS was Rs. 0.15. During the Examination Period there was no material corporate announcement made by Pine which could support such price rise in its scrip. Thus, the sharp rise in the price of the scrip of Pine during the Examination Period was not supported by its fundamentals or any other genuine factor. The scrip was listed on BSE on March 25, 1994 and was subsequently suspended from trading w.e.f November 09, 1998. The suspension on trading in the securities of the scrip was revoked w.e.f June 22, 2012, however, trading in the scrip started only on March 28, 2013. Also, the shareholding of the promoters in the company became nil on account of transfer of shares by the promoters to the Promoter related entities. Strangely, in spite of such fundamentals and tarnished track record of long period of suspension of trading, exit by the promoters and no available market price on account of no trading in the scrip, Pine was able to garner funds aggregating to Rs.24,70,00,000 from aforesaid 92 entities at a premium of Rs. 10 per share within a short span of few months from the r....

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....are split), through first trades by certain entities. It was noticed that these entities by putting 1 or 2 trade(s) per day with negligible/ very less quantity of buy orders contributed significantly to the price rise. 9. It was observed that in Patch 1, out of a total of 31 instances of trades establishing new high price in the scrip, six entities namely, Nellakkara Raghunath, Prem Lata Nahar, Dhirendra Kumar Gupta and Sons, J M S Financial Services Ltd., Sanjay Kumar Shah and Rajesh Kumar Shukla established new high price on 25 instances. The contribution of these six entities in establishing new high price was Rs.45.75/- out of total price rise of Rs.54.9/-, which constitutes 83.3% of the total new high price. The details of contribution to price rise by these six entities during Patch 1 are as under: Table 1 - Contribution to price rise in Patch 1 by six entities. PAN Name Name reflected in the Interim Order Positive LTP Contribution as a buyer % to Total Positive LTP Contribution AESPN9474K Nellakkara Raghunath - 17.15 31.2 AFAPN8764M Prem Lata Nahar Radford Global Limited, First Financial Services Ltd 9.85 17.9 AAFHD9092L ....

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....elationship was established among these entities through Know Your Client ("KYC") details, bank statements, off-market transactions amongst them and the information available on the Ministry of Corporate Affairs ("MCA") website. List of these entities is annexed as Part III of Annexure - A and hereinafter they shall be referred to as the "Exit Providers". Since the Exit Providers, Preferential Allottees and Promoter related entities have been prima facie found to be connected/ related to Pine / its promoters/ directors, they shall hereinafter collectively be referred to as "Pine Group". 14. Considering the large number of these related/connected entities, it was deemed necessary to shortlist those who have bought/sold in the scrip on the basis of the gravity of their conduct and the nature of the prima facie evidence available in the matter. A set of 158 entities (hereinafter referred to as the "Shortlisted Group") were shortlisted on the basis of following parameters: A. All the Exit Providers. B. All the Preferential Allottees who have sold Pine's shares. C. All the Promoter related entities who received shares directly from the promoters and sub....

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.... 2 AABPD9375L ANIL VISHANJI DEDHIA 3 ADZPC5979N ANILKUMAR CHAMANLAL 4 AACPM1902D ANKIT RAJIDERKUMAR MIGLANI 5 AEUPB3427L ANMOL PRAKASH BABANI 6 AREPS5118G ARCHANA MIGLANI 7 AANPS2300L ARCHANA SALUJA 8 AEKPM9977L ARVIND CHHOTALAL MORZARIA 9 AAAPB5499G BALCHAND JAIN 10 AEFPS6298M BRIJ BHUSHAN SINGAL 11 ABAPL3679D BRIJESH CHOWDHARY LAVU 12 ADPPR2047A DAMJI ANANDJI RAMBHIA 13 AAAPP9409N GOPAL NIHCHALDAS PARIANI 14 AAAHH5526G HARESH RAWANI HUF 15 AEIPG1584P HEMANT JAYANT GOGRI 16 AAEPS8716P HIRJI MORARJI SHAH 17 AJLPC9910H JAY HANSRAJ CHHEDA 18 AAIPS4820L KANTILAL LALJI SHAH 19 AADPB1550B KAUSHAL KANHAYALAL BAGADIA 20 ACMPM6181A KISHOR PRANJIVAN MEHTA 21 AEUPB2920C KUNAL RAMESH BABANI 22 AEBPM1654H MAHENDRA BMITTAL 23 AACPP0931H MAHENDRA PANDHI 24 AAEPG6125C MAYUR ISHVARDAS GANDHI 25 AABPM6332L MIGLANI ANUJ RAJINDER 26 AAJPI8348E MONESH ISRANI 27 AALPS7124C NARESHKUMAR KISHANLAL SARAF 28 AFPPM2107Q NEELAM MOR 29 AAAPV9144N NEENA SUDHIR VORA ....

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....LIMITED 26 AACCH8885R HELOT PROPERTIES PRIVATE LIMITED 27 AACCH4303G HELPFUL INVESTMENT ADVISORY PRIVATE LIMITED 28 AADCI5139E INDRAWATI NIRMAN PVT LTD 29 AAECK7329P KAPEESHWAR VINTRADE PVT LTD 30 AACCL3868N LADIOS TRADING PRIVATE LIMITED 31 AADCR9508C LINUS HOLDINGS LTD 32 AAICM4750C MOBIXA DISTRIBUTORS PRIVATE LIMITED 33 AAICM6982C MUCHMORE VINCOM PRIVATE LIMITED 34 AACCN9567A NAVDURGA INVESTMENT CONSULTANTS PVT LTD 35 AABCO2236J ORCHID SOLUTION PRIVATE LIMITED 36 AABCO6950F OVERLOAD FINANCIAL ADVISORY PVT LTD 37 AAACL4269P PADMA IMPEX PRIVATE LIMITED 38 AACCM6582E PRIDE DISTILLERY PRIVATE LTD 39 AAGCR6009M RAMYA MERCANTILE PVT LTD 40 AAGCR1715E RANGAN VINCOM PRIVATE LIMITED 41 AAECR2312K RANGOLI DISTRIBUTORS PRIVATE LTD 42 AAFCR9881C REACHSMART DEALTRADE PRIVATE LIMITED 43 AAGCR8144M REACHSMART DEVELOPERS PRIVATE LIMITED 44 AAECR9858C RIDHI VINCOM PRIVATE LIMITED 45 AAGCR8142P ROCHAK VINIMAY PRIVATE LIMITED 46 AAGCR7017M ROCHI DEALCOM PRIVATE LIMITED 47 AAECR0580M RUNICHA MERCHANTS PR....

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.... Total no. of shares purchased from promoter related/preferential allotees Gross buy volume in Patch 3 % of shares bought from Promoter related entities /preferential allotees to the gross buy volume of the exit provider % to market gross buy volume 1 AADCD0633J DREAMVALLEY TRADING PRIVATE LIMITED 3459200 3797376 91.09 5.15 2 AAECR2312K RANGOLI DISTRIBUTORS PRIVATE LTD 1608411 1755756 91.61 2.38 3 AADCR9508C LINUS HOLDINGS LTD 1551830 1992505 77.88 2.70 4 AABCO2236J ORCHID SOLUTION PRIVATE LIMITED 1306167 1480408 88.23 2.01 8 AADCI5139E INDRAWATI NIRMAN PVT LTD 1032824 1314641 78.56 1.78 5 AADCH3599R HANSHIKA DEALERS PRIVATE LIMITED 1015335 1505943 67.42 2.04 22 AAECD8235D DHLRITI TRADERS PRIVATE LIMITED 956669 1612131 59.34 2.19 7 AAFCG5351A GANGESHWARI TRADERS PRIVATE LIMITED 956116 1134158 84.30 1.54 6 AAPCS7492G SPICE MERCHANTS PRIVATE LIMITED 927945 1285981 72.16 1.75 9 AAGCR8142P ROCHAK VINIMAY PRIVATE LIMITED 859672 1412932 60.84 1.92 10 AAECD9323N DU....

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.... AABCO6950F OVERLOAD FINANCIAL ADVISORY PVT LTD 173556 212556 81.65 0.29 37 AAFCB0211J BLUE HORIZON COMMOSALES PRIVATE LIMITED 170434 214184 79.57 0.29 36 AAGCR7017M ROCHI DEALCOM PRIVATE LIMITED 160758 200758 80.08 0.27 39 AAACW8004B WINALL VINIMAY PRIVATE LIMITED LTD 159800 202000 79.11 0.27 41 AAACV8378B VIBGYOR FINANCIAL SERVICEPVT LTD 146117 189000 77.31 0.26 42 AABCD8147K DIVYADRISHTI MERCHANTS PVT LTD 141000 156999 89.81 0.21 44 AACCH4303G HELPFUL INVESTMENT ADVISORY PRIVATE LIMITED 140625 161000 87.34 0.22 43 AADCT8403C TOPWELL PROPERTIES 125000 125000 100.00 0.17     PRIVATE LIMITED         45 AAACL4269P PADMA IMPEX PRIVATE LIMITED 100100 126700 79.01 0.17 46 AAGCR1715E RANGAN VINCOM PRIVATE LIMITED 82344 89244 92.27 0.12 47 AABCD8146J DIVYA DRISHTI TRADERS PVT LTD 81000 90900 89.11 0.12 48 AAMCS1712Q SIGNET VINIMAY PRIVATE LIMITED 80704 85500 94.39 0.12 49 AACCL3868N LA....

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....695.1 AABPM6332L Miglani Anuj Rajinder 450000 4750000 4750000 417632486.1 412882486.1 ADPPR2047A Damji Anandji Rambhia 300000 3000000 3000000 274482750 271482750 AALPS7124C Nareshkumar Kishanlal Saraf 250000 2500000 2500000 233471791.3 230971791.3 AREPS5118G Archana Miglani 400000 2430000 2430000 214649485.6 212219485.6 AAHHP7899B Prakash Hiralal Jain HUF 200000 2183180 2183180 201325339.5 199142159.5 ARIPS3477L Priyanka Miglani 400000 2161000 2161000 191785800 189624800 ALVPM6130D Sunny Mirchandani 200000 2000000 2000000 165202252 163202252 AACPM1902D Ankit Rajiderkumar Miglani 440000 1519617 1519617 131408264.8 129888647.8 AEBPM1654H Mahendra Bmittal 150000 1500000 1500000 141936826.5 140436826.5 ACHPB0564H Poojamahendra Mittal 150000 1500000 1500000 142097414.5 140597414.5 AFPPM2107Q Neelam Mor 200000 1421000 1421000 115230995 113809995 AAJPI8348E Monesh Israni 200000 1125300 1125300 97848475 96723175 ADZPC5979N Anilkumar Cha....

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....5 ABSPJ2879F Rajesh Durgashankar Joshi 300000 200000 200000 18787500 18587500 ADQPT9711L Santosh Yashwant Tandel 150000 189000 189000 17456750 17267750 ABAPL3679D Brijesh Chowdhary Lavu 300000 148000 148000 13388300 13240300 ADSPA3332J Neha Bansal 100000 147000 147000 13784500 13637500 ABAPA2027N Praveen Kumar Arora 100000 134500 134500 10898100 10763600 AEFPS6298M Brij Bhushan Singal 1200000 125000 125000 11847500 11722500 AATHS9775H Sanjay Dnyaneshwer Nikam Huf 300000 100800 100800 9223120 9122320 AAAPH6194E Vasudev Mahirwan Hemrajani 150000 95000 95000 8888471.65 8793471.65 AEUPB3427L Anmol Prakash Babani 150000 84500 84500 6840575 6756075 AEUPB2920C Kunal Ramesh Babani 150000 84500 84500 6831825 6747325 AKYPB3382J Sharan Mohan Babani 150000 84500 84500 6838475 6753975 AACPP0931H Mahendra Pandhi 150000 50000 50000 4760250 4710250 AAQPS5640E Lata V Shah* 6,00,000         Total 1,13,50,0....

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....7) and Veronica Financial Services Ltd Vs. SEBI (SAT Order dated August 24, 2012) that connection/relations can be established on the basis of factors including common addresses, common directors/shareholders, etc. 21. It is pertinent to mention that the key to the scheme of operations employed by Pine Group, prima facie, lies in the preferential allotment of shares made by Pine. Due to a lock-in of one year on shares, any gains made on the sale of such shares makes the allottees eligible for long term capital gains ("LTCG"). Further, the promoters of Pine namely, First Entertainment Private Limited and Unique image Production Pvt. Ltd, by offloading the shares to its connected entities in physical form and the entities selling the shares, after holding it for a period of one year, have also made the transferees eligible for LTCG. From the observations of the preliminary inquiry, it is inter alia noted that: * As on December 2012, Pine had 373 shareholders, with the two promoters (i.e. First Entertainment Private Limited and Unique image Production Pvt. Ltd ) holding 9,27,400 shares i.e. 30.91% of shares. * Thereafter, the aforesaid two promoters transferred a ....

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....able property. 24. During preliminary inquiry it was observed from the bank statement of Pine that money received through two preferential allotments of equity shares were immediately transferred to the following entities:- Table 6 - Transfer of money after the preferential allotment 1st Preferential Allotment Entities Values (Rs.) (approx.) Albright Consultants 2,00,00,000.00 Associated Finman Ltd 1,00,00,000.00 Biharji Constructions 25,00,000.00 Blue Circle Services 1,50,00,000.00 Denim Developers 50,00,000.00 Divya Momaya 9,25,000.00 Mehta Equities Ltd. 1,10,00,000.00 Newage Markting Ltd 1,00,00,000.00 Nextgen Infotel Pvt 1,00,00,000.00 Nirnidhi consultant 1,00,00,000.00 Pyramid Trading 1,60,00,000.00 RavindraKumar Grover 95,00,000.00 TOTAL 11,99,25,000.00 2nd Preferential Allotment Entities Values (Rs.) (approx.) N R Gada and Associates 12,00,000 Advent Neel Realty 50,00,000 Ajay A Rai 1,00,00,000 Divya Sameer Momaya 5,00,000 Laurus Textiles Pvt Ltd 10,00,000 Shubh Associates 50,00,000 Mehta Equities Ltd 7,25,00,000 Bihariji Construc....

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....due to global and economic slowdown and increasing rates of interest rates. When the animation industry was facing various challenges and the annual reports are silent about the reasons for the substantial increase in the revenue from operations, it gives rise to a doubt, whether the reported income figures are genuine. This issue requires further investigation from the forensic angle. 28. From the observations of the preliminary inquiry, it is inter alia noted that :- a) the fund brought in by way of preferential allotment was utilised for purposes other than those disclosed and extended by way of purported loans to companies through informal arrangements; b) even when substantial number of shares i.e. 24,70,00,000 shares (89.17% of the total shareholding of Pine) were locked-in and non transferable / tradable, price of the scrip increased from Rs. 472 (unadjusted and Rs. 47.2 adjusted to share split) to Rs. 1006 (unadjusted and Rs. 100.6 adjusted to share split) with small chunk of volume / purchases by certain entities; c) after the expiry of the lock-in period (i.e. in Patch 3), the average volume increased astronomically to the extent of 4433 time....

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.... The average volume increased by 4433 times during the Examination Period i.e. from 62 shares per day to 2,74,922 shares per day. It is further noted that on the days when Pine Group was not trading, the traded volumes in the scrip were very low and the substantial increase in traded volumes as observed in this case was mainly due to their trading. I further note that Exit Providers, Preferential Allottees and Promoter related entities traded amongst themselves as substantiated by their matching contribution to net buy and net sell in Patch 3. There was no change in the beneficial ownership of the substantial number of traded shares as the buyers and sellers both were part of the common group and were acting in concert to provide LTCG benefits to the Preferential Allottees and Promoter related entities . In view of the above, I prima facie find that Exit Providers, Preferential Allottees and Promoter related entities used securities market system to artificially increase volume and price of the scrip for creating bogus non taxable profits (i.e. LTCG). 32. In addition to the above, it is noted that after the preferential allotment and transfer of shares by the promoters to the Pr....

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....urities listed or proposed to be listed on a recognized stock exchange, any manipulative or deceptive device or contrivance in contravention of the provisions of this Act or the rules or the regulations made thereunder; (b) employ any device, scheme or artifice to defraud in connection with issue or dealing in securities which are listed or proposed to be listed on a recognised stock exchange; (c) engage in any act, practice, course of business which operates or would operate as fraud or deceit upon any person, in connection with the issue, dealing in securities which are listed or proposed to be listed on a recognised stock exchange, in contravention of the provisions of this Act or the rules or the regulations made thereunder;" PFUTP Regulations "3. Prohibition of certain dealings in securities No person shall directly or indirectly- (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 p....

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....d in this case is necessary to find out the role of any other entity therein, connection amongst the concerned entities and the ultimate owners of funds used for manipulating the price of the scrip of Pine. Also, an investigation of the annual accounts of Pine from the forensic angle would be necessary. Therefore, while SEBI would investigate into the probable violations of the securities laws, the matter may also be referred to other law enforcement agencies such as Income Tax Department, Enforcement Directorate and Financial Intelligence Unit for necessary action at their end as may be deemed appropriate by them. 36. SEBI strives to safeguard the interests of a genuine investor in the Indian securities market. The acts of artificially increasing the price of scrip misleads investors and the fundamental tenets of market integrity get violated with impunity due for such acts. Under the facts and circumstances of this case, I prima facie find that the acts and omissions of Pine Group as described above is inimical to the interests of participants in the securities market. Therefore, allowing the entities that are prima facie found to be involved in such fraudulent, unfair and ....

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....adma Impex Private Limited AAACL4269P 5 Pride Distillery Private Ltd AACCM6582E 6 Navdurga Investment Consultants Pvt Ltd AACCN9567A 7 Bsr Finance And Construction Ltd AABCB0636K 8 Swarna Pushpa Vanijya Private Limited AAJCS0597G 9 Ridhi Vincom Private Limited AAECR9858C Radford Global Limited. 10 Dhanraksha Vincom Private Limited AADCD6028P 11 Anjali Suppliers Private Limited AAJCA1784D 12 Devatma Distributors Private Limited AADCD7140G 13 Divyadrishti Merchants Pvt Ltd AABCD8147K 14 Divya Drishti Traders Pvt Ltd AABCD8146J 15 Shivkhori Construction Private Limited AAPCS7850L 16 Pine Animation Ltd AAECM0267A First Financial Services Limited and Radford Global Limited. 17 Burlington Finance Limited AABCB2575P 18 Prem Lata Nahar AFAPN8764M 19 Savita Bansal AEJPB6903J Mishka Finance and Trading Limited. 20 Rochak Vinimay Private Limited AAGCR8142P 21 Indrawati Nirman Pvt Ltd   AADCI5139E 22 Duari Marketing Private Limited AAECD9323N 23 Vishnudham Marketing Private Limited AAECV4988P 24 Sebika ....

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....ts respective Orders, it prima facie appears that certain market manipulations are taking place in the scrip of Pine. I note that currently a major portion of the shareholding (around 65.93%) lies with the Preferential Allottees and Promoter related entities . It is further noted that as on May 06, 2015, the allottees are still holding 18,03,34,724 shares of Pine that were allotted to them in the aforesaid preferential allotments. Further, the promoter related entities who bought shares from promoters are holding 23,00,645 shares of Pine as on May 06, 2015.The price of the scrip as on May 06,2015 was Rs.24/- per share. Thus, the preferential allottees and promoter related entities who are still holding these shares, may potentially book a bogus tax exempt LTCG of approximately Rs.420 crore. Unless prevented they may use the stock exchange mechanism in the same manner as discussed hereinabove for the purposes of their dubious plans as prima facie found in this case. In my view, the stock exchange system cannot be permitted to be used for any unlawful/forbidden activities. 40. Considering the above facts and the indulgence of a listed company in such a fraudulent scheme, plan, dev....

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....PRAKASH PETHE 9 BMKPK5626B SANTOSH KUMAR PROMOTERS OF PINE ANIMATION LTD. 10 AABCF0975D FIRST ENTERTAINMENT PRIVATE LIMITED 11 AAACU9294K UNIQUE IMAGE PRODUCTION PVT. LTD. DIRECTORS OF FIRST ENTERTAINMENT PVT. LTD. AND UNIQUE IMAGE PRODUCTION PVT. LTD. 12 AEZPM6900L MURALI SHANMUGAM 13 ARUPP1577G PRABU SEKAR 14 ADRPV2013N SEKAR VASU PROMOTER RELATED ENTITIES 15 AAECG2103R GAJAKARNA TRADING PVT LTD 16 AAHCM1333N MAHAGANAPATI FINANCIAL SERVICES PVT LTD 17 AAFPJ6734M NIMESH S JOSHI 18 AGSPJ6909M ROSHNI N JOSHI 19 AGYPK8780F HITESH N KAWA 20 ANMPK4236D ROOPAL H KAWA 21 ALDPG8381J AKASH RANCHHODBHAI GOLAKIA 22 AEEPG1294G CHINTAN RANCHHODBHAI GOLAKIA 23 AAYPG3878J RANCHHODBHAI JASMATBHAI GOLAKIA 24 AAWPG3157A VIJUBEN RANCHHODBHAI GOLAKIA 25 AEZPD5474N BINA DEVI DHANUKA 26 ADLPD5568J MAYANK DHANUKA 27 ADOPB3260E NEHA DHANUKA 28 ADNPD6220D NIKUNJ DHANUKA 29 ADUPD7020N RAJKUMARI DHANUKA 30 ADLPD0494K UMANG DHANUKA 31 ADQPD6035P MADAN MOHAN DHANUKA 32 ABEPJ7142D MADANLAL....

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.... AFPPM2107Q NEELAM MOR   88 AAAPV9144N NEENA SUDHIR VORA 89 ADSPA3332J NEHA BANSAL   90 AACPG7709G PANKAJ DHANJI GOSHAR 91 BGGPM9415G PEEYUSH MAKHIJA 92 ACHPB0564H POOJAMAHENDRA MITTAL 93 AAEPS7956D POONAM KAUSHAL BAGADIA   94 AABPS7441L PRADIP DAMJI SHAH 95 AAHHP7899B PRAKASH HIRALAL JAIN HUF 96 ABAPA2027N PRAVEEN KUMAR ARORA 97 APZPV0747H PRITHVI SUDHIR VORA 98 AADPR1704M PRIYANKA HARESH RAWANI 99 ARIPS3477L PRIYANKA MIGLANI 100 AAZPM0573H RAJESH CHAMPAKLAL MEHTA 101 ABSPJ2879F RAJESH DURGASHANKAR JOSHI 102 ABHPA9244J SADHA RANI   103 AATHS9775H SANJAY DNYANESHWER NIKAM HUF 104 ADQPT9711L SANTOSH YASHWANT TANDEL 105 AEJPB6903J SAVITA BANSAL 106 AKYPB3382J SHARAN MOHAN BABANI 107 ALVPM6130D SUNNY MIRCHANDANI 108 AAACT8706B TVC SHARES STOCK & INVESTMENT PVT LTD 109 AAAPH6194E VASUDEV MAHIRWAN HEMRAJANI XIT PROVIDERS 110 BABPS7447D AMIT SINGH    111 AAJCA1784D ANJALI SUPPLIERS PRIVATE LIMITED 112 AALCA7880J ANTARYAMINI TRADER....

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....142P ROCHAK VINIMAY PRIVATE LIMITED   155 AAGCR7017M ROCHI DEALCOM PRIVATE LIMITED   156 AAECR0580M RUNICHA MERCHANTS PRIVATE LIMITED 157 ACIPS8803M S N SRINIVASAN    158 AAMCS1711P SANKLAP VINCOM P LTD 159 AARCS9144H SEBIKA COMMODITIES PVT LTD   160 AAPCS7850L SHIVKHORI CONSTRUCTION PRIVATE LIMITED 161 AATCS3687H SIDHIMAN VYAPAAR PRIVATE LIMITED 162 AAMCS1712Q SIGNET VINIMAY PRIVATE LIMITED   163 AAICS0688K SKM TRAVELS PRIVATE LIMITED   164 AAOCS2216D SPARK COMMODEAL PRIVATE LIMITED 165 AAPCS7492G SPICE MERCHANTS PRIVATE LIMITED   166 AAJCS0597G SWARNA PUSHPA VANIJYA PRIVATE LIMITED 167 AATCS6718D SWARNPRAKASH TRADERS PRIVATE LIMITED 168 AADCS5411K SYMPHONY MERCHANT PVT LTD  169 AADCT8403C TOPWELL PROPERTIES PRIVATE LIMITED 170 AAACV8378B VIBGYOR FINANCIAL SERVICEPVT LTD   171 AAECV4988P VISHNUDHAM MARKETING PRIVATE LIMITED 172 AAACW8004B WINALL VINIMAY PRIVATE LIMITED LTD LTP CONTRIBUTORS 173 AESPN9474K NELLAKKARA RAGHUNATH 174 AFAPN8764M PREM LATA....

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....YESH PRAKASH PETHE Director of Pine as per its Annual Report for the year ending March 31, 2013 10 AAJPM6827G KRISHNAKUMAR OMPRAKASH MURARKA Director of Pine as per its Annual Report for the year ending March 31, 2014 11 BMKPK5626B SANTOSH KUMAR Director of Pine as per its Annual Report for the year ending March 31, 2014 12 AEZPM6900L MURALI SHANMUGAM Director of First Entertainment Pvt. Ltd. and Unique Image Production Pvt. Ltd. as per the MCA Website 13 ARUPP1577G PRABU SEKAR Director of First Entertainment Pvt. Ltd. as per the MCA Website 14 ADRPV2013N SEKAR VASU Director of Unique Image Production Pvt. Ltd. as per the MCA Website Part I-Promoter related entities S. No. PAN Name Relationship 15 AAECG2103R GAJAKARNA TRADING PVT LTD Received shares in physical form from the promoter First Entertainment Pvt. Ltd. 16 AAHCM1333N MAHAGANAPATI FINANCIAL SERVICES PVT LTD Received shares in physical form from the promoter Unique Image Production Pvt. Ltd. 17 AAFPJ6734M NIMESH S JOSHI Received shares in physical form from the promoter First Entertainment Pvt. Ltd. 18 AGS....

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....nancial Services Pvt. Ltd. 39 AQZPB2916M KAJRI NAGORI Received shares in physical form from Gajakarna Trading Pvt Ltd 40 AALPJ9757A KIRAN JAJOO Received shares in physical form from Roopal H Kawa 41 ADQPD6035P MADAN MOHAN DHANUKA Received shares in physical form from Gajakarna Trading Pvt Ltd 42 ABEPJ7142D MADANLAL JAIN Received shares in physical form from Nimesh S Joshi 43 AEUPB9878H MAMTA RISHIKUMAR BAGLA Received shares in physical form from Gajakarna Trading Pvt Ltd 44 ACTPC4078P MANISHA NARPATKUMAR CHOPRA Received shares in physical form from Mahaganapati Financial Services Pvt. Ltd. 45 ADLPD5568J MAYANK DHANUKA Received shares in physical form from Gajakarna Trading Pvt Ltd 46 ABEPJ7147G MOOL CHAND JAIN Received shares in physical form from Nimesh S Joshi 47 ADIPJ9498C MUKESH KUMAR JAIN Received shares in physical form from Roshni N Joshi 48 AAIHM2182H MURLIDHAR MUNDHRA (HUF) Received shares in physical form from Gajakarna Trading Pvt Ltd 49 AAPPT4897B NARAYAN B. TOSHNIWAL Received shares in physical form from Gajakarna Trading Pvt Ltd 50 ....

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....sh N Kawa 72 ACIPM0237D SHAKUNTALA MARU Received shares in physical form from Gajakarna Trading Pvt Ltd 73 AALPJ9756B SNEHLATA JAJOO Received shares in physical form from Roopal H Kawa 74 AAEPJ9602R SUDHESH JAJOO Received shares in physical form from Roopal H Kawa 75 AAEPJ9603Q SUNIL JAJOO Received shares in physical form from Hitesh N Kawa 76 AABPF1503E SUSHILKUMAR SHRIBHAGWAN FATEHPURIA Received shares in physical form from Nimesh S Joshi 77 AABPF1507A UMADEVI SUSHILKUMAR FATEHPURIA Received shares in physical form from Nimesh S Joshi 78 ADLPD0494K UMANG DHANUKA Received shares in physical form from Gajakarna Trading Pvt Ltd 79 AAWPG3157A VIJUBEN RANCHHODBHAI GOLAKIA Received shares in physical form from Hitesh N Kawa 80 AFOPJ4431P VIKAS JAIN Received shares in physical form from Mahaganapati Financial Services Pvt. Ltd. 81 AJTPJ3155F VIKAS JAIN Received shares in physical form from Gajakarna Trading Pvt Ltd 82 AEDPJ2960D VINEET JAIN Received shares in physical form from Gajakarna Trading Pvt Ltd Part II-List of Preferential Allottees S. No. ....

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....48E Monesh Israni 200000 127 AFPPM2107Q Neelam Mor 200000 128 AGMPK5927A Kasaraneni Anil Kumar 200000 129 AEDPK3759F Kasaraneni Vasundhara 200000 130 AAAPB5499G Bal Chand Jain 200000 131 AABPL2052J Kishore Premchand Lahrani 200000 132 AAAHK2645F Kishore Premchand Lahrani (HUF) 200000 133 ACQPL6691J Puneet Kishore Lahrani 200000 134 ABIPL5205F Reena Kishor Lahrani 200000 135 AFBPG4873R Lokesh Shankar Gurnani 200000 136 ASUPG4897M Mehar Lokesh Gurunani 200000 137 AJLPC9910H Jay Hansraj Chheda 150000 138 AAEPS8716P Hirji M Shah 150000 139 AABPD9375L/ADUPD6477F Anil Vishanji Dedhia jointly with Sandhya Anil Dedhia 350000 140 ADPPR2047A Damji Anandji Rambhia 300000 141 AEUPB2920C Kunal Ramesh Babani 150000 142 AEUPB3427L Anmol Prakash Babani 150000 143 AKYPB3382J Sharan Mohan Babani 150000 144 ADQPT9711L Santosh Yashwant Tandel 150000 145 AASCS2552A Shalu Multitrade Pvt.Ltd. 150000 146 AATHS9775H S.D.Nikam (HUF) 300000 147 AAHPD2883K So....

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....8 AAGCR1715E Rangan Vincom Private Limited Off-market transfer with Devatma Distributors 179 AACCL3868N Ladios Trading Private Limited Debendra Das - common director with Rangan Vincom 180 AAOCS2216D Spark Commodeal Private Limited Pine Animation Ltd. has off-market transaction with Compass Distributors Pvt Ltd. Compass Distributors Pvt Ltd. and Spark Commodeal have a common director - Jai Shankar Joshi 181 AADCD7017J Dove Suppliers Pvt Ltd Bluesnow Dealcom Pvt. Ltd. (Punjab National Bank A/c No. 4656002100003380) transferred funds to Spark Commodeal Privated Ltd. (Punjab National Bank A/c No. 4656002100003308) Bluesnow Dealcom (Punjab National Bank A/c No. 4656002100003380) transferred funds to Dove Suppliers Pvt. Ltd. (Punjab National Bank A/c No.4656002100003344) and to Rangoli Distributors Pvt. Ltd. (Punjab National Bank A/c No.4656002100003274) 182 AAECR2312K Rangoli Distributors Private Ltd 183 AABCO2236J Orchid Solution Private Limited Fund transfer from Rangoli Distributors Pvt. Ltd. (Punjab National Bank A/c No. 4656002100003274) to Orchid Solution Private Limeted (Punjab National Bank A/c No. 46560021000032....

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.... Vinimay - Pradip Dey and Abhiset Basu, 23/1, Principal Khudiram Bose Road, Kolkata - 700 006 196 AAACW8004B Winall Vinimay Private Limited Ltd Common Directors and Address with Signet Vinimay - Pradip Dey and Abhiset Basu, 23/1, Principal Khudiram Bose Road, Kolkata - 700 006 197 AAMCS1711P Sanklap Vincom P Ltd Common Directors and Address with Signet Vinimay - Pradip Dey and Abhiset Basu, 23/1, Principal Khudiram Bose Road, Kolkata - 700 006 198 ACIPS8803M S N Srinivasan S N Srinivasan transferred shares of Anukaran Commercial Enterprises Limited to Sanklap Vincom Pvt. Ltd. through off-market transactions 199 AAICS0688K Skm Travels Private Limited The company 'Winall Vinimay Private Limited' and 'SKM Travels Private Limited' have common director viz, 'Abhiset Basu'. 200 BABPS7447D Amit Singh Amit Singh has off market transactions in various scrips with Sanklap Vincom Pvt. Ltd., Signet Vinimay Pvt. Ltd. and Runicha Merchants Pvt. Ltd. 201 AAJCA4459K Apex Commotrade Private Limited Ltd Off-market transfer with Runicha Merchants 202 AAPCS7492G Spice Merchants Private Limited Common Di....

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.... Limited, Overload Financial Advisory Pvt Ltd and Sebika Commodities Private Limited 216 AABCO6950F Overload Financial Advisory Pvt Ltd 217 AAFCR9881C Reachsmart Dealtrade Private Limited 218 AAECD8010E Dhyaneshwar Dealers Pvt Ltd As per MCA website NIRAJ KUMAR RAY is one of the directors of Dhyaneshwar Dealers Pvt Ltd and Reachsmart Dealtrade Private Limited 219 AAFCG4773J Goldensight Traders Private Limited Pratap Chakraborty is one of the directors of Dhyaneshwar Dealers Pvt Ltd and Goldensight Traders Private Limited 220 AAECD5782B Dreamlight Exim Private Limited Dreamlight Exim Pvt. Ltd., had off-market transactions with Sebika Commodities Pvt. Ltd, Helot Properties Pvt. Ltd., Gajgamini Merchandise Pvt. Ltd., Mobixa Distributors Pvt. Ltd., Reachsmart Dealtrade Pvt. Ltd. and Rochak Vinimay Pvt. Ltd. 221 AAGCR8142P Rochak Vinimay Private Limited Rochak Vinimay Pvt. Ltd. had off-market transactions with Dreamlight Exim Pvt. Ltd., and Gajagamini Merchandise Pvt. Ltd. 222 AAGCR7017M Rochi Dealcom Private Limited Common Directors with Rochak Vinimay Pvt. Ltd. - Koushik Chatterjee and Rohit Agarwal 223 ....

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....232 AABCB0636K Bsr Finance And Construction Ltd BSR Finance and Construction Ltd. has made off-market transfers to Bikash Sureka. Bikash Sureka has off-market transactions wth Vishnudham Marketing Pvt. Ltd, Duarim Marketing Pvt. Ltd, Gajgamini Merchandise Pvt. Ltd. and Gangeshwarin Traders Pvt. Ltd. 233 AAACE2862P Esha Securities Ltd On analyzing the bank statement submitted by the trading member 'C.D Equisearch Pvt Ltd' for its client 'Pyramid Trading and Finance Limited', it was observed that the client has transferred funds to Esha Securities Private Limited. Pyramid Trading and Finance Limited received funds from Pine Animation Ltd. 234 AAACL4269P Padma Impex Private Limited Rani Sati Dealers Pvt. Ltd. is a shareholder of Padma Impex Pvt. Ltd. Rani Sati Dealers Pvt. Ltd. had off-market transaction with JMD Telefilms Industries. JMD Telefilms Industries Ltd. had fund transactions with Indrawati Nirman Pvt. Ltd., Rochak Vinimay Pvt. Ltd. and Duari Marketing Pvt. Ltd. JMD Telefilms Industries Ltd. has common director with JMD Sounds Ltd. and JMD Sounds Ltd. had fund transactions with Pine Animation Ltd. 235 AACCM6582E Pride Distillery Priv....