TaxTMI 
TaxTMI 
2025 (8) TMI 414
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....LOGY LTD) ON AUGUST 29, 2022.........................15 E.1. PATCH 1 - BUY SPOOFING ......................................................................17 E.2. PATCH 4 - SELL SPOOFING ..........................................................................21 G. EXAMINATION OF LEGAL ISSUES TO DETERMINE IF THERE IS A VIOLATION ..................27 H. LIABILITY OF DIRECTORS OF PWAPL ...............................................................................32 I. UNIQUE NATURE OF THE MODUS OPERANDI ..................................................................34 J. NEED FOR AN INTERIM ORDER...............................................................................35 K. BASIS OF DISGORGEMENT AND DEBARMENT .......................................................37 L. INTERIM ORDER ........................................................................................................37 LIST OF TABLES AND FIGURES MENTIONED IN THE ORDER ......................................41 A. BACKGROUND 1. Securities and Exchange Board of India (hereinafter referred to as "SEBI") had conducted an examination into the trading activities of M/s Patel W....
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....g activities that can disrupt market integrity and mislead other market participants. VII. The aforesaid peculiar pattern of trading has been allegedly followed by PWAPL over 292 scrip contract days spread over 173 different scrips. B. NATURE OF SPOOFING ACTIVITY 3. Order spoofing is a type of manipulative trading activity which involves placing bid or ask orders, with the intent of cancelling the said orders before execution while simultaneously executing trades on the opposite side of the book. The side (i.e. buy or sell) on which such large orders are placed and cancelled is known as "Spoof" side and the suspect trader involved in such kind of activity is known as "Spoofer". 4. A spoofer manipulates the order book by creating a false sense of demand or supply by placing large orders at a price which is far away from market prices. Such large orders on one side of the order book creates asymmetry in the book, thereby, influencing other market participants to trade. When such trading leads to movement in the price of the scrip, the Spoofer trades on the opposite side of the book thereby making unlawful gains. 5. The Spoofing activity is generally characterized....
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....et dynamics through this tactic, spoofers can effectively buy at lower prices and sell at higher prices (or vice versa), profiting from the artificial price movements they have induces. 6. The details of the Noticees and their modus operandi with respect to the alleged spoofing activities are provided in the subsequent paragraphs. C. DETAILS OF NOTICEES and MODUS OPERANDI 7. PWAPL was incorporated on June 25, 2015, and is registered as a stock broker with SEBI and is also Trading Member (TM) of three recognized stock exchanges namely, NSE, BSE and MCX. 8. PWAPL offers a range of financial services including retail and institutional brokerage of equity, derivatives, currency, commodities, online trading depository services, distribution of IPOs, Mutual Funds, and dedicated desk for NRIs and institutional clients. PWAPL is also actively participating in proprietary trading activity. 9. The details of person acting as directors of PWAPL during the examination period are given in the table below: Table 1 Details of directors of PWAPL Sr. No Name DIN PAN Date of appointment 1 Denish Maheshbhai Patel 07184269 AJZPP8683J 25/06/2015 2 ....
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....09 0.50 537.59 99.91% 22.32 1.33 20.99 94.04% Patch 2 Sell 09:37:27 09:51:13 413.12 0.25 412.87 99.94% 32.44 2.67 29.77 91.77% Patch 3 Buy 09:51:26 09:56:55 420.38 0.22 420.16 99.95% 31.96 2.48 29.93 93.65% Patch 4 Sell 09:56:58 11:35:40 293.87 0.40 293.47 99.86% 150.09 2.76 147.55 98.31% Patch 5 Buy 11:33:14 11:42:16 368.71 0.00 368.71 100.00% 8.59 2.38 6.21 72.29% Patch 6 Sell 11:43:26 14:42:48 354.13 0.20 353.76 99.90% 72.39 1.48 70.91 97.96% Patch 7 Buy 14:42:25 14:48:28 353.07 0.00 353.07 100.00% 1.08 0.8 0.46 42.59% 16. From the table above, it is prima facie observed that PWAPL had indulged in buy order spoofing in 4 patches i.e., PWAPL had placed large buy orders at prices significantly lower than the LTP of the scrip, contributing significantly to the pending market quantity in the scrip on the buy side. When the said large orders were pending on the buy side PWAPL executed sell orders at higher prices, caused as a result of the artifici....
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....uy) Overall 09:24:36 09:37:25 548 538.09 538.04 53.20 - 72.55 0.00 - 26.53 50,000 71.60-72.55 09:26:16 09:36:34 537.59 09:37:11 09:37:27 537.59 Order Price > 5% of LTP 09:25:22 09:36:06 543 537.57 537.57 53.20 - 58.00 20.33 - 26.530 0 - - - 537.57 09:37:11 09:37:27 537.57 Order Price <= 5% of LTP 09:25:45 09:31:40 5 0.52 0.47 70.10 - 72.55 0.00 - 1.06 50,000 71.60-72.55 09:26:16 09:36:34 0.02 09:37:27 09:37:27 0.02 Opposite Side (Sell) Laying grounds for next patch (Sell side spoofing) Overall 09:25:43 09:37:07 36 22.32 18.79 70.75 - 79.00 0.00 - 10.18 1,32,869 70.75 - 73.35 09:25:43 09:36:21 20.99 09:35:53 09:51:14 18.19 Order Price <= 5% of LTP 09:25:43 09:36:12 18 4.37 0.84 70.75 - 73.35 0.00 - 0.28 1,32,869 70.75 - 73.35 09:25:43 09:36:21 3.04 09:35:53 09:37:12 0.24 Order Price > 5% of LTP 09:36:30 09:37:07 18 17.95 17.95 79.00 9.27 - 10.18 - - - - 17.95 09:51:14 09:51:14 17.95 23. F....
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....uring Patch (09:24:36 - 09:37:25) Last instance before PWAPL's order started entering in the order book on spoof side (before the patch) Last instance when PWAPL's pending quantity in order book <=10% Last instance when PWAPL's pending quantity in order book <=20% At first instance of 80% of Order Book At first instance of 90% of Order Book Instance of Maximum pending quantity Time 09:20:05 09:20:11 09:20:24 09:26:45 09:34:43 09:36:06 Price (A) 69.45 69.55 69.50 71.70 73.15 72.75 PWAPL's Pending buy quantity (B) (in lakhs) - 2.97 5.94 73.28 484.13 566.30 Market Pending buy quantity ( C) (in lakhs) 27.94 31.33 33.16 91.44 537.82 618.16 % of Market Pending on buy side (D) = (B/C)*100 - 9.48 17.91 80.14 90.02 91.61 PWAPL's Pending sell quantity (E) (in lakhs) - - - - - 0.00 Market Pending sell quantity ( F) (in lakhs) 21.04 20.59 20.47 32.83 29.81 31.62 % of Market Pending on sell side (G) = (E/F)*100 - - - - - 0.00 25. From the table above, it is prima facie observed that: I. Pre-p....
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.... below: Table 5 Details of the activity of PWAPL during Patch Nature of Orders Patch Timing Orders Entered Trade Executed Orders Cancelled Start Time End Time No. of Orders Total Qty (in lakhs) Disc Qty (in lakhs) Order Price Range (INR) Diff in LTP and Order Price (in %) Trade Qty Trade Price Range (INR) Start Time End Time Cancelled Qty (in lakhs) Start Time End Time Fully Disc Qty Cancelled (in lakhs) Spoof Side (Sell) Overall 09:37:27 09:51:13 419 413.12 412.90 70.90 - 79.00 0.21 - 14.49 25,000 70.90 09:51:11 09:51:11 412.87 09:49:38 09:51:14 412.87 Order Price > 5% of LTP 09:37:28 09:49:45 418 412.87 412.87 79.00 10.96-14.49 - - - - 412.87 09:49:38 09:51:14 412.87 Order Price <= 5% of LTP 09:51:10 09:51:10 1 0.25 0.03 70.90 0.21 25,000 70.90 09:51:11 09:51:11 - - - - Opposite Side (Buy) Laying grounds for next patch (Buy side spoofing) Overall 09:37:28 09:51:07 45 32.44 29.58 53.20 - 71.40 0.00 - 24.91 2,67,282 69.05 - 71.05 09:37:2....
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....oing spoofing on the sell side, it initiated laying grounds for spoofing on the buy side. 31. The price impact of the large sell orders of PWAPL, which had created an artificial increase in the supply of the scrip, is shown in the table below: Table 6 Details of the impact of the artificial supply created by PWAPL, during the patch. Particulars Pre-Patch (Time Period prior to Patch 2) During Patch (09:37:27 - 09:51:13) Last instance before PWAPL's order started entering in order Book on spoof side (before the patch) Last instance when PWAPL's pending quantity in the order book <=10% Last instance when PWAPL's pending quantity in the order book <=20% At first instance of 80% of Order Book At first instance of 90% of Order Book Instances of Maximum pending quantity Time 09:35:03 09:36:33 09:36:43 09:40:14 09:45:54 09:50:05 Price (A) 73.25 72.25 72.25 69.50 69.70 69.85 PWAPL's Pending buy quantity (B) (in lakhs) 493.04 566.30 566.30 0.03 0.05 0.05 Market Pending buy quantity ( C) (in lakhs) 547.23 617.96 618.04 48.86 52.05 52.23 % of Market Pending on buy side....
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....red off Profit 14/09/2022 COFFEEDAY 7,86,550 5,53,34,916.10 70.35 7,86,550 5,62,35,146.85 71.50 9,00,230.75 E. ILLUSTRATION 2- TRADING IN THE SCRIP OF SYRMA (SYRMA SGS TECHNOLOGY LTD) ON AUGUST 29, 2022 35. It is prime facie observed that PWAPL indulged in order spoofing activity in the scrip of Syrma SGS Technology Ltd. on August 29, 2022, in several patches during the day. The details of the same are given in the table below: Table 8 Details of the spoofing patches in Syrma SGS Technology Ltd. Patch Spoof Side Start Time End Time Spoof Side Opposite Side Order Qty (in lakhs) Trade Qty (in lakhs) Cancelled Qty (in lakhs) Percentage Quantity Cancelled Order Qty (in lakhs) Trade Qty (in lakhs) Cancelled Qty (in lakhs) Percentage Quantity Cancelled Patch 1 Buy 09:15:00 10:01:00 97.21 0.12 97.09 99.88% 17.65 0.49 17.16 97.22% Patch 2 Sell 10:00:27 10:02:16 19.76 - 19.76 100.00% 1.72 0.40 1.32 76.74% Patch 3 Buy 10:02:59 11:49:49 73.14 0.04 73.10 99.95% 31.07 0.32 30.75 98.97% Patch 4 Sell 1....
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.... for creating a perception of high demand in the scrip. The pending quantities of PWAPL and the market on the buy side are represented in Figure 2 by Moss Green line and Yellow line respectively. 41. In parallel, PWAPL executed partially disclosed sell orders at higher prices (higher prices resulting due to the artificial demand created in the scrip due to the large buy orders of PWAPL). 42. The details of the spoofing activity in this time patch i.e. spoofing on the buy side and the trades on the sell side, is given in the table below: Table 9 Details of the spoofing activity of PWAPL on the buy side. Nature of Orders Patch Timing Orders Entered Trade Executed Orders Cancelled Start Time End Time No. of Orders Total Qty (in lakhs) Disc Qty (in lakhs) Order Price Range (INR) Diff in LTP and Order Price (in %) Trade Qty Trade Price Range (INR) Start Time End Time Cancelled Qty (in lakhs) Start Time End Time Fully Disc Qty Cancelled (in lakhs) Spoof Side (Buy) Overall 09:15:00 10:01:00 185 97.21 97.17 248.40 - 337.05 0.00 - 27.02 12,001 310.0-336.8 09:16:54 09:56:33 97.09....
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....uantity of 49,328 shares got executed during the patch. c) The remaining 59 sell orders, for a total quantity of 16.96 lakh shares were fully disclosed and were placed at prices 11.11% - 13.09% higher than the LTP of the scrip, at the time of placement of the orders. However, the important thing to notice is that the said sell orders were placed just prior to the end of the patch i.e. between 09:59:18 and 10:01:00. Further, all these orders were cancelled between 10:02:15 and 10:02:40, i.e. at the end of the subsequent spoof patch on the sell side (Patch 2). This showcases that by the time PWAPL is done doing spoofing on buy side, it initiated laying grounds for spoofing on the other side. 44. The impact of the large buy orders of PWAPL, which had created an artificial increase in the demand of the scrip, is shown the table below: Table 10 Details of the impact of the artificial demand created by PWAPL on the buy side during the patch. Particulars Pre-Patch (Time period prior to Patch 1) During Patch (09:15:00 - 10:01:00) Last instance before PWAPL's order started entering in the order Book on spoof side (before the patch)* Last instance when PWAPL'....
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....price of the scrip, helping PWAPL to execute the orders on the opposite side at favorable higher prices. E.2. PATCH 4 - SELL SPOOFING 47. PWAPL indulged in sell order spoofing in the aforesaid patch i.e., it placed large sell orders at prices significantly higher than the LTP of the scrip, which were fully disclosed. These orders constituted a significant portion of the pending market quantity on the sell side. This was done for creating a perception of high supply in the scrip. The pending quantities of PWAPL and the market on the buy side are represented in Figure 2 by Sky Blue line and Blue line respectively. 48. In parallel, PWAPL executed partially disclosed buy orders at lower prices (lower prices resulting due to the artificial supply created in the scrip by the large sell orders of PWAPL). 49. The details of the spoofing activity of PWAPL in Patch 4 i.e. spoofing on the sell side and the trades on buy side, is shown in the table below: Table 11 Details of the spoofing activity of PWAPL on the sell side Nature of Orders Patch Timing Orders Entered Trade Executed Orders Cancelled* Start Time End Time No. of Orders Total Qty (in lak....
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....uantity of 29.94 Lakh shares, out of which 29.62 Lakh shares were disclosed. b) On closer look it is noted that of these buy orders, 10 orders for a total quantity of 0.39 Lakh shares, of which 0.06 Lakh shares were disclosed, were placed at prices 0.00 - 0.63 % lower than the LTP of the scrip, at the time of placement of the orders. Of these orders, a quantity of 29,899 shares was executed during the patch. c) The remaining 73 buy orders, for a total quantity of 29.55 Lakh shares, were fully disclosed and were placed at prices 22.09 - 24.77% lower than the LTP of the scrip, at the time of placement of the orders. However, the important thing to notice is that the said buy orders were placed, just prior to the end of the patch i.e. between 11:51:50 and 11:53:08. Further, all these orders were cancelled between 14:37:18 - 14:37:29, i.e. at the end of the subsequent spoof patch on the buy side (Patch 5). This showcases that by the time PWAPL is done doing spoofing on the sell side, it initiated laying grounds for spoofing on the other side. 51. The price impact of the large sell orders of PWAPL, which had created an artificial increase in the supply of the scrip,....
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...., when pending sell quantity of PWAPL was 80% and remain maintained at those levels, till the time PWAPL's position was substantial part of the market pending quantity. 53. From the above, it is prima facie observed that: I. PWAPL placed large sell orders, which were fully disclosed and placed at prices substantially higher than the LTP of the scrip, at the time of placement of the orders, with an intent of cancelling the orders once the trades on the opposite side were executed. II. The aforesaid large sell orders constituted significant proportion of the pending market quantity on the sell side. The said artificial supply resulted in decrease in the price of the scrip, helping PWAPL to execute the orders on the opposite side at favorable lower prices. 54. Thus, it is prime facie observed that PWAPL has indulged in order spoofing in the scrip of Syrma SGS Technology Ltd during 7 patches (as shown in Table 8), thereby, earning an approximate profit of INR 4.44 Lakhs as calculated in the table below: Table 13 Calculation of unlawful gains made by PWAPL Date Scrip Buy Qty Buy Value Avg Buy Price Sell Qty Sell Value Avg Sell Price ....
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....site side (sell/buy) and cancelling the orders containing large orders [Note: Same part of the large artificial order which is close to the LTP may get executed]. By following such an unfair trade practice, the spoofer may enrich itself as the large orders which are displayed to the investors carry a potential to impact the price of the scrip. 58. While the issue of excessive modification and cancellation of orders placed on exchanges is specifically dealt with by exchanges under their respective bye laws, section 12A of the SEBI Act read with regulations 3 and 4 of the PFUTP Regulations implicitly prohibits any person from engaging in fraudulent and unfair trade practices spoofing activities. The text of the relevant provisions is reproduced below: "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 ....
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....ecurity for wrongful gain or avoidance of loss; (g) entering into a transaction in securities without intention of performing it or without intention of change of ownership of such security;" 59. From the plain reading of the aforesaid provisions, it is clear that if a person indulges in dealing in securities which creates false or misleading appearance of trading in the securities market, the same amounts to manipulative, fraudulent and unfair trade practice under regulations 3 and 4 of the PFUTP Regulations. In the past also, SEBI has relied on the aforesaid provisions to penalise spoofing activities. In the matter of Nimi Enterprises (WTM/SM/IVD/ID2 /26026/2023-24), SEBI held as follows: "....the practice followed in the trading account of the Noticee no. 1 wherein large quantities of buy/sell orders in different scrips were being first placed, which were followed by execution of trades in smaller quantities on the opposite side in the same scrips, and further the earlier orders were subsequently cancelled, was nothing but a deliberate chain of acts done only for spoofing of the order book. ..... ......... though the term spoofing has not been defin....
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....rading activity occurs over the course of seconds, in multiple cycles that the trader repeats throughout the trading day. Given the speed and near simultaneity of market activity in a successful layering scheme, such schemes are aided by custom-programmed, automated trading software. ....... 24. I readily accept that in this market many offers appear on the trading screens which are thereafter cancelled prior to acceptance - for a variety of unexceptionable reasons. To my mind, however, a clear distinction is capable of being drawn between the conduct involved: (1) in placing an offer which at the time it is placed is intended by the offeror to be open for acceptance, though it might subsequently be cancelled prior to acceptance; and (2) in placing an offer which, at the time it is placed, the offeror does not genuinely intend should be accepted. The allegation against the Applicant in the Request is that his conduct fell squarely within category (2) and involved deceiving (or spoofing) market participants, so creating a false market picture with the intention of creating artificial price movements. Such conduct, if proven here, would constitute an offence under a....
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....lly pushes the price in a direction favorable to the trader, and permits the trader to obtain better prices on the bona fide orders, or better prices for that quantity and at that point in time, than would otherwise be available. The manipulation that results from placement of the non-bona fide orders enables the bona fide orders to execute profitably, on average, and makes the bona fide orders more profitable than they would have been absent the manipulation." "39. Once the trader's bona fide orders are executed, the trader typically cancels the non-bona fide orders promptly. By that time, the non-bona fide orders have fulfilled the trader's illicit purpose of manipulating supply and demand for that particular security to receive more favorable execution of the bona fide orders. Layering typically occurs over very short time frames, often just seconds." [emphasis supplied] 62. In the instant matter, it is prime facie observed from the trading pattern of PWAPL that it punched spoof orders at price significantly above or below the CMP with an intention of it not being executed. The opposite side orders are executed once the price was in favour of PWAPL's opposite....
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.... of its business and hence is prima facie held to be guilty of the contravention committed by the company Minish Maheshbhai Patel Director 25/06/2015 01/04/2024 Minish Maheshbhai Patel was a director of Patel Wealth Advisors Ltd. at the time the contravention was alleged to be committed and was in such capacity in charge of, and responsible to, the company for the conduct of its business and hence is prima facie held to be guilty of the contravention committed by the company 65. In the matter of KK Ahuja v. V.K Arora (2009 10 SCC 48.), the Hon'ble Supreme Court analysed the terms 'in charge of' and 'responsible to' in the context of vicarious liability provisions and held that the 'in-charge' principle presents a factual test and the 'responsible to' principle presents a legal test. The court held that a person would be in-charge of the business of the company if the person is in overall control of the day-to-day business of the company. 66. Thus, while an executive or whole-time director of the defaulting company can be called to be 'in charge of the business of the company', an independent director or a non-executive director, having no control over the day-t....
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....analysis of the Order Book of each individual scrip. It is important to underscore that order book manipulation presents a unique and significantly more complex challenge compared to traditional trade book analysis in the securities market. Unlike trade book analysis, which focuses on executed transactions, order book surveillance involves scrutinizing a vast volume of unexecuted orders-including placements, modifications, and cancellations-to detect patterns of potential manipulation, such as spoofing or layering. What makes order book manipulation particularly distinct is that it often leaves no trace in the executed trades, making it harder to detect and prove the violation. 72. This complexity is further magnified by the massive growth in market volumes. The average number of trades per day, in 2025, is around 100 million. However, the scale of order activity is far greater, with average daily orders reaching approximately 16 billion in 2025. In this environment, sophisticated manipulation can occur in microseconds and may involve fleeting orders that are never intended to be executed. Detecting such behaviour requires advanced surveillance infrastructure capable of interpre....
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....EBI has been empowered to take any measures, as it deems fit to achieve the mandate. The PFUTP Regulations have been framed with an objective of preventing fraudulent and unfair trade practices relating to securities market, which will aid in achieving the mandate of investor protection, regulation and development of securities market. 78. I seek to place reliance on the order of the Hon'ble Securities Appellate Tribunal, passed in the matter of Amalendu Mukherjee Vs. SEBI (Appeal (L) no. 169 of 2020), wherein the Hon'ble Tribunal has underscored the necessity of passing impounding orders by inter alia observing as: "We are of the opinion that the WTM is empowered under the SEBI Act and the Regulations to pass an ex-parte order in order to protect the interests of securities market and the investors. If such impounding order is not passed, it may result in defeating the ultimate direction of disgorgement if any, as there would be chances of such monies being dissipated by the appellant. ..." 79. A prima facie case of violation of various provisions of the SEBI Act, 1992 and the PFUTP Regulations has already been made out against Noticees which is largely backed by di....
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....e directions to any person, for disgorgement of wrongful gains made by him, by contravention of any provision of the SEBI Act or the regulations made thereunder. 82. The directors of PWAPL are also liable to be proceeded against for the unlawful profits that accrued to the Noticees and are held jointly and severally liable with PWAPL, by virtue of section 27 of the SEBI Act, 1992. 83. In view of the aforesaid discussion and the calculation of unlawful gains made by Noticees as detailed in Table 14, I hold that the Noticees are prima facie jointly and severally liable for impounding of unlawful gains made by them. 84. Further, PWAPL, being a registered stock broker, is expected to maintain high standard of integrity and ensure compliance with securities laws. In the present matter, it is prima facie evident that PWAPL has engaged in extensive spoofing activities in 173 scrips across 292 scrip-days in both cash as well as derivatives segment over a period of three years, which has resulted in unlawful gains of INR 3.22 crores. 85. The alleged illegal activities of PWAPL persisted despite repeated communications and issuance of SCN by NSE. Considering the fact that PWAPL w....
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.... with SEBI and deals with securities of clients. V. Banks and the Depositories are 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 purpose of complying with this Order. VI. The Registrar and Transfer Agents shall ensure that, they neither permit any transfer nor redemption of securities, including Mutual Funds units, held by Noticees. VII. Noticees shall not dispose of or alienate any of their assets/properties, till such time the amount of unlawful gain is credited to fixed deposit account(s) except with the prior permission of SEBI. VIII. Noticees are further directed to provide a full inventory of all their assets whether movable or immovable, or any interest or investment or charge in any of such assets, including property, details of all their bank accounts, demat accounts, holdings of shares/securities if held in physical form and mutual fund investments and details of companies in which they hold substantial or controlling interest ....