TaxTMI 
TaxTMI 
2015 (5) TMI 1265
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....rip 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 1,50,00,000 equity shares at the price of Rs. 10....
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.... 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 The suspension on trading in the securities of the scrip was revoked w.e.f June 22, 2012, however, trading in the scrip started only on March 28, 2013.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 revocation of suspension. Investment in a company having such poor and me....
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.... 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 Dhirendra Kumar Gupta And Sons Huf - 8.2 14.9 AAACJ8428J J M S Financial Services Ltd. - 4.4 8 AJSPS5543F Sanjay Kumar Shah - 3.1....
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....rporate 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 subsequently transferred the same to other Promoter related entities. D. All the Promoter related entities who have sold shares more than Rs. 1,00,00,000 as sale value, in the market, individually or collectively with ot....
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.... 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 30 ADSPA3332J NEHA BANSAL 31 AACPG7709G PANKAJ DHANJI GOSHAR 32 BGGPM9415G PEEYUSH MAKHIJA 33 ACHPB0564H POOJAMAHENDRA MITTAL 34 AAEPS7956D POONAM KAUSHAL BAGADIA 35 AABPS7441L PRADIP DAMJI SHAH 36 AAHHP7899B PRAKASH HIRALAL JAIN HUF 37 ABAPA2027N PRAVEEN KUMAR ARORA 38 APZPV0747H PRITHVI SUDHIR VORA 39 AADPR1704M PRIYANKA HARESH RAWANI 40 ARIPS3477L PRIYANKA MIGLANI 41 AAZPM0573H RAJESH CHAMPAKLAL MEHTA 42 ABSPJ2879F RAJESH DURGASHANKAR JOSHI 43 ABHPA9244J SADHA RANI 44 AATHS9775H SANJAY DNYANESHWER NIKAM HUF 45 ADQPT9711L SANTOSH YASHWANT TANDEL 46 AEJPB6903J SAVITA BANSAL 47 AKYPB3382J SHARAN MOHAN BABANI 48 ALV....
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....E LIMITED 46 AAGCR7017M ROCHI DEALCOM PRIVATE LIMITED 47 AAECR0580M RUNICHA MERCHANTS PRIVATE LIMITED 48 ACIPS8803M S N SRINIVASAN 49 AAMCS1711P SANKLAP VINCOM P LTD 50 AARCS9144H SEBIKA COMMODITIES PVT LTD 51 AAPCS7850L SHIVKHORI CONSTRUCTION PRIVATE LIMITED 52 AATCS3687H SIDHIMAN VYAPAAR PRIVATE LIMITED 53 AAMCS1712Q SIGNET VINIMAY PRIVATE LIMITED 54 AAICS0688K SKM TRAVELS PRIVATE LIMITED 55 AAOCS2216D SPARK COMMODEAL PRIVATE LIMITED 56 AAPCS7492G SPICE MERCHANTS PRIVATE LIMITED 57 AAJCS0597G SWARNA PUSHPA VANIJYA PRIVATE LIMITED 58 AATCS6718D SWARNPRAKASH TRADERS PRIVATE LIMITED 59 AADCS5411K SYMPHONY MERCHANT PVT LTD 60 AADCT8403C TOPWELL PROPERTIES PRIVATE LIMITED 61 AAACV8378B VIBGYOR FINANCIAL SERVICEPVT LTD 62 AAECV4988P VISHNUDHAM MARKETING PRIVATE LIMITED 63 AAACW8004B WINALL VINIMAY PRIVATE LIMITED LTD 16. It is observed that during Patch 3, the Preferential Allottees/Promoter related entities were net sellers and the Exit Providers were net buyers, a snapshot of which is given below:- Table 3 - Exit provided by Exit Providers to Preferential Allottees No. of shares sold % of total allotted/ received share....
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....216D SPARK COMMODEAL PRIVATE LIMITED 705374 740500 95.26 1.01 15 AAACE2862P ESHA SECURITIES LTD 670644 700150 95.79 0.95 20 AAGCR8144M REACHSMART DEVELOPERS PRIVATE LIMITED 666670 820282 81.27 1.11 18 AAECD5782B DREAMLIGHT EXIM PRIVATE LIMITED 647703 726610 89.14 0.99 14 AAECR9858C RIDHI VINCOM PRIVATE LIMITED 632995 654790 96.67 0.89 21 AADCD7017J DOVE SUPPLIERS PVT LTD 624434 995519 62.72 1.35 17 AAJCA4459K APEX COMMOTRADE PRIVATE LIMITED LTD 618981 904787 68.41 1.23 16 AADCD6028P DHANRAKSHA VINCOM PRIVATE LIMITED 615991 676045 91.12 0.92 19 AAJCA1784D ANJALI SUPPLIERS PRIVATE LIMITED 567120 449784 126.09 0.61 23 AAICM4750C MOBIXA DISTRIBUTORS PRIVATE LIMITED 518083 483330 107.19 0.66 24 AATCS3687H SIDHIMAN VYAPAAR PRIVATE LIMITED 469346 451088 104.05 0.61 27 AAFCG4773J GOLDENSIGHT TRADERS PRIVATE LIMITED 411950 446000 92.37 0.61 25 AALCA7880J ANTARYAMINI TRADERS PRIVATE LIMITED 367114 478572 76.71 0.65 26 AAFCG2554B GAJGAMINI MERCHANDISE PRIVATE LIMITED 359150 606936 59.17 0.82 31 AAECD8010E DHYANESHWAR DEALERS PVT LTD 337363 360763 93.51 0.49 40 AAGCR6009M RAMYA MERCANTILE ....
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.... 0.05 60 AABCB0636K BSR FINANCE AND CONSTRUCTION LTD 7000 7000 100.00 0.01 61 AAJCS0597G SWARNA PUSHPA VANIJYA PRIVATE LIMITED 3470 3470 100.00 0.00 63 AAMCS1711P SANKLAP VINCOM P LTD 3000 3000 100.00 0.00 62 AABCB2575P BURLINGTON FINANCE LIMITED 600 7100 8.45 0.01 GRAND TOTAL 28265949 34734934 81.38 47.14 18. During the same period, the Preferential Allottees were found to be selling and in the process making a huge profit/gain. It is observed that 52 allottees made a collective profit of Rs. 453.02 crore on a collective investment of Rs.5.23 crore, a whopping return of approximately 8661% on their investment in a period of 25 months (including the lock in period of the shares allotted in the preferential allotment). This profit was obtained in a stock where the fundamentals/ financials of the company do not justify the price. It is evident from the above analysis of Patch 3 that the Exit Providers provided a hugely profitable exit to the allottees. The profit/gain earned by the allottees during Patch 3 is given below:- Table 5- Profit made by the Preferential Allottees PAN Name No. of shares alloted No. of shares sold Cost purchase of shar....
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.... Kishor Pranjivan Mehta 250000 418481 418481 33494087.45 33075606.45 AAAPB5499G Balchand Jain 200000 391994 391994 31614679 31222685 AADPR1704M Priyanka Haresh Rawani 150000 300000 300000 26845250 26545250 AEJPB6903J Savita Bansal 140000 300000 300000 28256750 27956750 ABHPA9244J Sadha Rani 120000 297000 297000 27895200 27598200 AAACT8706B TVC Shares Stock & Investment Pvt Ltd 300000 280000 280000 26596870.75 26316870.75 AANPS2300L Archana Saluja 250000 270000 270000 22995750 22725750 AAAPV9144N Neena Sudhir Vora 150000 268000 268000 24731400 24463400 BGGPM9415G Peeyush Makhija 100000 266000 266000 22223694.05 21957694.05 AAEPG6125C Mayur Ishvardas Gandhi 200000 241000 241000 21957488.5 21716488.5 APZPV0747H Prithvi Sudhir Vora 150000 209000 209000 19526325 19317325 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 1....
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....omoter related entities. This could be only possible if Pine and its promoters/directors, Preferential Allottees, Promoter related entities and the Exit Providers were hand in glove with each other. 20. From the above examination and factors as described in Annexure A, I am of the prima facie view that Pine, Preferential Allottees, Promoter related entities and Exit Providers are connected to each other. In this regard, I note that the Hon'ble SAT has held in many cases such as Classic Credit Ltd. Vs. SEBI (SAT Appeal No. 68/2003, Order dated December 8, 2006), Classic Credit Ltd. Vs. SEBI (SAT Appeal No. 76/2003, Order dated January 09, 2007) 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 prom....
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....uld be repeated, demonstrates the mala fide of the Pine Group. Also the mechanism is presumably being used to deceive the authorities by laundering black money and making tax-free profits. 23. Further, from the copies of the special resolution, passed under section 81(1A) of the Companies Act, 1956 as available on BSE website it is noted that Pine had disclosed to its shareholders and public that the purpose of aforesaid fund raising through preferential allotment was to fulfil the additional funding requirements of the company for acquisition and development of moveable and immovable 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 Marktin....
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....ear ending March 31, 2014, which again was an exponential increase of 883%. On further examination of the "Management Discussion and Analysis" part of the annual reports, it is observed that the reports do not discuss the factors that contributed to such exponential increase in the revenue from operations. It is also pertinent to mention that the "Management Discussion and Analysis" indicates that during the relevant period, the animation industry faced various challenges 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....
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....he trading in its scrip during the Examination Period, Pine did not have any business or financial standing in the securities market, in my view, the only way it could have increased its share value is by way of market manipulation. In this case, it is noted that the traded volume and price of the scrip increased substantially only after the Exit Providers, preferential allotees and Promoter related entities started trading in the scrip. 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 th....
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.... (g) thereof and section 12A(a), (b) and (c) of the Securities and Exchange Board of India Act, 1992. The said provisions are reproduced hereunder:- SEBI ACT Prohibition of manipulative and deceptive devices, insider trading and substantial acquisition of securities or control. "12A. No person shall directly or indirectly- (a) use or employ, in connection with the issue, purchase or sale of any securities listed or proposed to be listed on a recognized stock exchange, any manipulative or deceptive device or contrivance in contravention of the provisions of this Act or the rules or the regulations made thereunder; (b) employ any device, scheme or artifice to defraud in connection with issue or dealing in securities which are listed or proposed to be listed on a recognised stock exchange; (c) engage in any act, practice, course of business which operates or would operate as fraud or deceit upon any person, in connection with the issue, dealing in securities which are listed or proposed to be listed on a recognised stock exchange, in contravention of the provisions of this Act or the rules or the regulations made thereunder;" PFUTP Regulations "3. Prohibition of ce....
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.... of the applicable provisions of SEBI Regulations or other applicable laws. I, therefore, prima facie find that these directors as well as Pine were responsible for Pine's acts and omissions in this case. 35. I am of the opinion that a detailed investigation of the entire scheme employed in this case is necessary to find out the role of any other entity 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 a....
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....d AADCS5411K First Financial Services Limited, Radford Global Limited and Mishka Finance and Trading Limited. 2 Bazigar Trading Private Limited AABCB3052B 3 East India Securities Ltd AABCE2412N First Financial Services Limited. 4 Padma 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 AA....
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....e 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, device and artifice as prima facie found in this case, I am convinced that this is a fit case where....
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....ODUCTION 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 JAIN 33 ABEPJ7147G MOOLCHAND JAIN 34 ACTPC4078P MANISHA NARPATKUMAR CHOPRA 35 ABFPK6567J ALOK NAVINCHANDRA KUBADIA 36 ADIPJ9498C MUKESH KUMAR JAIN 37 AFOPJ4431P VIKAS JAIN 38 ACIPM0237D SHAKUNTALA MARU 39 ADUPM7778C PARAS CHAND MARU 40 AJWPM1991R SAURABH MARU 41 AABPF1503E SUSHILKUMAR....
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....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 TRADERS PRIVATE LIMITED 113 AAJCA4459K APEX COMMOTRADE PRIVATE LIMITED LTD 114 AABCB3052B BAZIGAR TRADING PRIVATE LIMITED 115 AAFCB0211J BLUE HORIZON COMMOSALES PRIVATE LIMITED 116 AABCB0636K BSR FINANCE AND CONSTRUCTION LTD 117 AABCB2575P BURLINGTON FINANCE LIMITED 118 AAECC9285A CHEROOT VANIJYA PVT LTD 119 AADCD7140G DEVATMA DISTRIBUTORS PRIVATE LIMITED 120 AADCD6028P DHANRAKSHA VINCOM PRIVATE LIMITED 121 AAECD8235D DHLRITI TRADERS PRIVATE LIMITED 122 AAECD8010E DHYANESHWAR DEALERS PVT LTD 123 AABCD8146J DIVYA DRISHTI TRADERS PVT LTD 124 AABCD8147K DIVYADRISHTI MERCHANTS PVT LTD 125 AADCD7017J DOVE SUPPLIERS PVT LTD 126 AAECD5782B DREAMLIGHT EXIM PRIVATE LIMITED 127 AADCD0633J DREAMVALLEY TRADING PRIVATE LIMITED 128 AAECD932....
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....H 174 AFAPN8764M PREM LATA NAHAR 175 AAFHD9092L DHIRENDRA KUMAR GUPTA AND SONS HUF 176 AAACJ8428J J M S FINANCIAL SERVICES LTD. 177 AJSPS5543F SANJAY KUMAR SHAH 178 BGGPS9416R RAJESH KUMAR SHUKLA b. trading in the securities of Pine Animation Limited shall be suspended till further directions. 43. This order shall come into force with immediate effect. The Stock exchanges and the depositories are directed to ensure that all the above directions are strictly enforced. 44. This order is without prejudice to the right of SEBI to take any other action that may be initiated against the aforementioned entities in accordance with law. 45. The persons/entities against whom this Order is passed may file their objections, if any, within twenty one days from the date of this order and, if they so desire, avail themselves of an opportunity of personal hearing before the Securities and Exchange Board of India, on a date and time to be fixed on a specific request, received from the said persons/entities. Annexure - A Company Directors and its Promoter S. No. PAN Name Relationship 1 AAECM0267A PINE ANIMATION LTD. Pine Animation Ltd. (Allahbad Bank: A/c No: 5....
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....rm from the promoter First Entertainment Pvt. Ltd. 20 ANMPK4236D ROOPAL H KAWA Received shares in physical form from the promoter First Entertainment Pvt. Ltd. 21 ALDPG8381J AKASH RANCHHODBHAI GOLAKIA Received shares in physical form from Hitesh N Kawa 22 AAAPO8119J ALANKRUTA OMPRAKASH OSWAL Received shares in physical form from Gajakarna Trading Pvt Ltd 23 ABFPK6567J ALOK NAVINCHANDRA KUBADIA Received shares in physical form from Mahaganapati Financial Services Pvt. Ltd. 24 AAMPJ0021E ANURADHA JAJOO Received shares in physical form from Roopal H Kawa 25 AAEPG6708K ASHISH GOEL Received shares in physical form from Gajakarna Trading Pvt Ltd 26 AMCPS3169A BHARATI DHAVAL SHAH Received shares in physical form from Mahaganapati Financial Services Pvt. Ltd. 27 AAFCB1180N BHUSHIT TRADING PVT LTD Received shares in physical form from Mahaganapati Financial Services Pvt. Ltd. and Roshni N Joshi 28 AEZPD5474N BINA DEVI DHANUKA Received shares in physical form from Gajakarna Trading Pvt Ltd 29 AEEPG1294G CHINTAN RANCHHODBHAI GOLAKIA Received shares in physical form from Hitesh N Kawa 30 AGKPB3602K DARSHAN D BHANUSHALI Received shares in physical for....
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....ical form from Gajakarna Trading Pvt Ltd 55 ABFPB2995P PANKAJKUMAR RAJKUMAR BARIA Received shares in physical form from Nimesh S Joshi 56 ADUPM7778C PARAS CHAND MARU Received shares in physical form from Gajakarna Trading Pvt Ltd 57 AADPO5637Q PAWANKUMAR GULABCHAND OSWAL Received shares in physical form from Gajakarna Trading Pvt Ltd 58 AAPPA6951R PINKY RAJKUMAR AGRAWAL Received shares in physical form from Hitesh N Kawa 59 AFTPB8600D POONAM PANKAJ BERIA Received shares in physical form from Nimesh S Joshi 60 ANBPS0119C POONAM P JAIN Received shares in physical form from Mahaganapati Financial Services Pvt. Ltd. and Gajakarna Trading Pvt. Ltd. 61 AIGPD9671E PRACHI RANJEET BAPAT Received shares in physical form from Gajakarna Trading Pvt Ltd 62 ADUPD7020N RAJ KUMARI DHANUKA Received shares in physical form from Gajakarna Trading Pvt Ltd 63 AAPPA6950Q RAJKUMAR BUDHRAM AGARWAL Received shares in physical form from Hitesh N Kawa 64 ADOPA8945K RAJKUMAR HARISH CHANDER AGARWAL Received shares in physical form from Mahaganapati Financial Services Pvt. Ltd. 65 AAYPG3878J RANCHHODBHAI JASMATBHAI GOLAKIA Received shares in physical form from Hitesh ....
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....l Morzaria 200000 98 AEXPM7771B Lalit Navin Morzaria 200000 99 AADPM9918L Subhash Chottalal Morzaria 200000 100 AEIPG1584P Hemant Jayant Gogri 100000 101 AADHA7870F Ashok Jain Huf 200000 102 AAHHP7899B Prakash Hiralal Jain HUF 200000 103 AAEPG6125C/ AADPG3815E Mayur Gandhi Jointly with Pallavi Gandhi 200000 104 AAAPP9409N Gopal Nichaldas Pariani 200000 105 AADPR1704M Priyanka Haresh Rawani 150000 106 AAAPV9144N Neena Sudhir Vora 150000 107 APZPV0747H Prithvi Sudhir Vora 150000 108 AAAHH5526G Haresh Rawani Huf 150000 109 AABPM7288D Rajinder Kumar Miglani 600000 110 AAFPM7744L Neelam Miglani 600000 111 AABPM6332L Anuj Miglani 450000 112 AACPM1902D Ankit Miglani 440000 113 AREPS5118G Archana Miglani 400000 114 ARIPS3477L Priyanka Miglani 400000 115 AARPM7331B Praveen Kumar Miglani 400000 116 ABAPL3679D Brijesh Chowdhary Lavu 300000 117 AACPG7709G Pankaj Dhanji Goshar 600000 118 ABSPJ2879F Rajesh Durgashankar Joshi 300000 119 AAQPS5640E Lata V Shah 600000 120 AABPS7441L/AAWPS1354B Pradip Damji Shah Jointly with Chhaya Pradip Shah 300000 121 BEIPS9920L Vinod Saluja 500000 122 AQDPS8677G A....
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....gariya 100000 174 AAEPS7956D Poonam Bagariya 100000 Part III-List of Exit Providers S. No. PAN Relationship 175 AACCN9567A Navdurga Investment Consultants Pvt Ltd Pine Animation Ltd. (Allahbad Bank: A/c No: 50103075412) transferred funds to Blue Circle Services Ltd. (Axis Bank A/c No. 909020032026872) As per the KYC submitted by the trading member 'Comfort Securities Pvt Ltd' for its client 'Navdurga Investment Consultants Private Ltd.' has common director with that of the company 'Blue Circle Services Ltd' viz, 'Dhruvnarayan Jha'. 176 AAJCA1784D Anjali Suppliers Private Limited Pine Animation Ltd. (Allahbad Bank: A/c No: 50103075412) transferred funds to Mintage Solutions Pvt. Ltd. (Axis Bank A/c No.096121800000361) Anjali Suppliers Pvt. Ltd and Devatma Distributors Pvt. Ltd. have common Director - Raj Kumar Dabriwal with Mintage Solutions 177 AADCD7140G Devatma Distributors Private Limited 178 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.....
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....Arindam Roy 191 AAPCS7850L Shivkhori Construction Private Limited Common Directors with Topwell Properties - Chiranjit Mahanta and Debi Prasad Pal 192 AABCF5486H Function Financial Consultants Private Limited As per MCA website 'DEBI PRASAD PAL' is one of the directors of 'Helpful Investment Advisories Pvt. Ltd., Function Financial Consultants Private Limited and Topwell Properties Private Limited 193 AACCH4303G Helpful Investment Advisory Private Limited 194 AAMCS1712Q Signet Vinimay Private Limited On analyzing bank statement of the Topwell Properties Private Limited, it was observed that funds were also transferred to Signet Vinimay Pvt. Ltd.and Sankalp Vincom Pvt. Ltd. 195 AAECR0580M Runicha Merchants Private Limited Common Directors and Address with Signet 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 Ba....
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....ectors of Antaryami Traders Private Limited, Gajgamini Merchandise Private Limited and Muchmore Vincom Private Limited 213 AAICM6982C Muchmore Vincom Private Limited 214 AADCI5139E Indrawati Nirman Pvt Ltd Indrawati Nirman Private Limited has off-market transactions with Gajgamini Merchandise Private Limited, Rochak Vinimay Pvt Ltd, Sebika Commodities Private Limited, Reachsmart Construction Private Limited, Reachsmart Dealtrade Private Limited and Rangan Vincom Private Limited in different scrips. 215 AARCS9144H Sebika Commodities Pvt Ltd As per MCA website RAJIB RAJBANGSHI is one of the directors of Reachsmart Constructions Private 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 A....
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....imata Marketing Private Limited through off-market transactions. Saktimata Marketing Private Limited received shares from Rochak Vinimay Pvt Ltd, Rochi Dealcom Pvt Ltd and Duari Marketing Private Limited.Ramya Mercantile Pvt Ltd transferrd funds to Badamisati Apartments Private Limited 231 AAECD8235D Dhlriti Traders Private Limited There are numerous fund transactions between Dhlriti Traders Pvt.Ltd (The Ratnakar Bank : A/c no: 409000125799) and Ramya Mercantile Pvt. Ltd ( The Ratnakar Bank : A/c no: 409000115428). 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 Padm....