TaxTMI 
TaxTMI 
2025 (8) TMI 813
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...................50 F.3 Illustration of recommendation on ET NOW- InterGlobe Aviation Limited ........66 F.4 Illustration of Recommendation on ZEE Business news channel- Steel Authority of India Limited (SAIL) .....................75 F.5 Illustration of Recommendation on ZEE Business news channel- GODREJCP..............89 G. OTHER TRADES INVOLVING SIMILAR MODUS OPERANDI .........................105 H. ROLE OF NOTICEES ............................108 I. PROFIT SHARING AMONGST NOTICEES ......................114 J. EXAMINATION OF VIOLATION OF PROVISIONS OF THE SEBI ACT AND REGULATIONS MADE THEREUNDER ..........................124 K. LIABILITY OF DIRECTORS/ADVISOR OF THE PROFIT MAKERS ........................138 L. NEED FOR INTERIM EX-PARTE ORDER ................................................140 M. JOINT AND SEVERAL LIABILITY OF NOTICEES ..............................143 N. INTERIM ORDER ......................................................................146 A. BACKGROUND 1. The present proceedings emanate from an investigation conducted by the Securities and Exchange Board of India (hereinafter referred to as "SEBI"), for the ....
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....Residence: H. No. B-174A, Sushant Lok-I, Block-B, Gurugram, Haryana- 122001; and Sanjiv Bhasin Cabin, 1st Floor, Plot No. 98, Phase-IV, Udyog Vihar, Atlas Chowk, Gurgram, Haryana- 122015. 2. Ashish Kapur (Noticee No. 3) Residence: House No. M-48, Grater Kailash Part 1, Greater Kailash, South Delhi, New Delhi- 110048. 3. RRB Master Securities Delhi Limited (Noticee No. 4) Office: H-72, Connaught Place, New Delhi- 110001. 4. Rajiv Kapoor (Noticee No. 5) Residence: J7/47, 2nd Floor, Rajouri Garden, West Delhi- 110027. 5. Jagat Singh (Noticee No. 6) Residence: 901, Tower 7, Sunshine County, Sonipat, Haryana- 131023. 4. Further, data from electronic devices pertaining to Lalit Bhasin was also obtained during the said operation. Apart from above entities, search & seizure order was also issued by Competent Court against an entity, who is not a Noticee in the instant Order, however, on the day of search & seizure, the entity was neither found at the residential location nor at the official location and hence the search warrant could not be executed. Nothing adverse has also been found against this entity at this stage. B. DETAILS OF NOTICEES INVOL....
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....ed (HB/Noticee No. 10) contrary to his recommendations made in Media Channels during the investigation period. 5.4 Investigation revealed that the Times group signed an exclusive contract with the Noticee No. 1 for his appearances on TV channels run by the Times Group viz. "ET Now" and "ET Now Swadesh" from October 2023 onwards. The Noticee No. 1 was given this contract on the basis of his experience with IIFL and his popularity among the retail investors (both Hindi and English Channel followers). 5.5 As discussed earlier, IIFL is registered with SEBI as a Research Analyst (hereinafter referred to as "RA") and Investment Advisor (hereinafter referred to as "IA"), however, the Noticee No. 1 was not registered with SEBI either as an IA or as an RA, in his personal capacity. Investigation revealed that the Noticee No. 1 was popular on social media platforms as per the details of the followers/subscribers of his various social media channels: Table 3 SR. NO. SOCIAL MEDIA PLATFORM FOLLOWER/SUBSCRIBERS AS ON MARCH 26, 2025 1. X (formerly Twitter) 3,21,000 Followers 2. You Tube channel (Wealth Creation India) 4,12,000 Subscribers 3. L....
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.... Total for F.Y. 2020-202 2,738.70 77.98% F.Y 2021-2022 3,531.18 1 Venus Portfolios Pvt Ltd 1,778.37 50.36% 2 HB Stockholdings Limited 716.81 20.30% 3 Leo Portfolios Private Limited 290.84 8.24% 4 Ashish Kapur 165.75 4.69% 5 Gemini Portfolios Private Limited 101.41 2.87% Total for F.Y. 2021-2022 3,053.17 86.46% F.Y 2022-2023 5,272.60 1 Venus Portfolios Pvt Ltd 2,719.80 51.58% 2 HB Stockholdings Limited 1,502.67 28.50% 3 Mars Forge Private Limited 170.09 3.23% 4 Gemini Portfolios Private Limited 120.27 2.28% 5 Leo Portfolios Private Limited 110.80 2.10% Total for F.Y. 2022-2023 4,623.64 87.69% F.Y 2023-2024 & Qtr. I of F.Y. 2024-25 4,877.33 1 Venus Portfolios Pvt Ltd 2,567.61 52.64% 2 HB Stockholdings Limited 1,634.19 33.51% 3 RRB Securities Ltd 167.53 3.43% 4 Rima Arora 132.21 2.71% 5 HB Portfolio Limited 90.43 1.85% Total for F.Y 2023-2024 & Qtr. I of F.Y 2024-2025 4,591.96 94.15% 6.5 On a perusal of the d....
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....ed to him. Investigation also revealed that a CTCL Terminal having terminal ID- 110034002008 was allotted in the name of Ashish Kapur as Dealer of RRB Master. Details of the same are tabulated below: Table 8 DEALER NAME SEGMENT CTCL ID ADDRESS OF RRB MASTER MO. EMAIL Ashish Kapur CM & FO 110034002008 A-2,3,4 Third Floor, HB Twin Tower, Netaji Subhash Place, Pitampura, New Delhi, 110034 981****967 ********@investshoppe 7. Information Misusers (who may also be beneficiary/profit maker) 7.1 Rajiv Kapoor (Noticee No. 5) and Jagat Singh (Noticee No. 6) were dealers of RRB Master who placed orders in the trading accounts of Venus, Gemini and HB Stockholdings, as per the instructions of Sanjiv Bhasin as received from time to time over phone calls/WhatsApp chats before the same recommendations were made public by Sanjiv Bhasin on Media Channels. Further, Noticee Nos. 5 and 6 being privy to the recommendations of trades of Sanjiv Bhasin, mirrored the same trades as done in accounts of Venus, Gemini and HB in their own accounts also. 7.2 During the investigation period, the Noticee No. 5 used to place the orders of clients of RRB Ma....
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.... Table 11 Sl. Name Designation % Shareholding as on March 31, 2023 1 Megh Shyam Sharma Director (Independent) 0% (5 Shares) 2 Raj Kumar Sharma Director (Professional) Nil 3 Rakhi Nagpal Company Secretary Nil Table 12 Sl Name No. of shares %Shareholding as on March 31, 2023 1 Merrygold Investments Ltd. 50000 19.23 2 Jupiter Portfolios Pvt Ltd 50000 19.23 3 Aquarious Portfolios Pvt Ltd 80000 30.77 4 Bhasin Investments Ltd 30000 11.54 5 Gemini Portfolios Pvt Ltd 50000 19.23 6 Megh Shyam Sharma 5 0 7 Inder Prakash 2 0 8 Subhash Garg 13 0 Total 260020 100% 8.3 Upon a perusal of the shareholding structure of Venus in the above table, it was observed that there was a complex web of shareholding among connected entities and there was a cross shareholding among several connected entities (e.g. Venus, Gemini, Bhasin Investment, Aquarious etc.) to possibly obfuscate the identity as well as exact shareholding of the Ultimate Beneficial Owner. To calculate the ultimate shareholding of Venus held by vario....
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....y and the shareholders as on March 31, 2023 are tabulated in the below tables: Table 15 Sl. Name Designation % Shareholding as on March 31, 2023 1 Arvind Kumar Jain Director (Professiona) Nil 2 Murari Lal Director (Professional) Nil 3 Rashmi Company Secretary Nil Table 16 Sl. Name No. of shares % Shareholding as on March 31, 2023 1 Megh Shyam Sharma 10 0 2 Inder Prakash 4 0 3 Subhash Garg 26 0 4 RRB Securities Limited 30000 15 5 Aquarious Portfolios Pvt Ltd 100000 50 6 Venus Portfolios Pvt Ltd 70000 35 Total 200040 100 8.7 The details of the ultimate shareholding structure of Gemini as on March 31, 2023 (upto fourth level) are as follows: Table 17 Gemini Portfolios Pvt Ltd 1st Level (A) 2nd Level (B) Third Level (C) Fourth Level (D) Final Shareholding (E = A*B*C*D) Final Shareholder Venus Portfolios P Ltd 35.00% Merry Gold 19.23% Lalit Bhasin 12.60% 0.85% Lalit Bhasin Jupiter 19.23% 6.73% Jupiter A....
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....or and had authorised Sanjiv Bhasin to trade in accounts of Venus and Gemini and resultantly, Sanjiv Bhasin had carried out trades in the trading accounts of Venus, Gemini and HB contrary to his recommendations made in Media Channels, through the dealers of RRB Master. Investigation revealed that trades in the account of Venus were carried out by Sanjiv Bhasin through the dealers of RRB Master, which has also been confirmed by the Noticee No. 1 in his statement dated Jan 10, 2025 recorded under oath that Lalit Bhasin had authorized him to place trades in the account of Venus through RRB Master. HB 8.11 As per the details available on MCA website, HB Stock Holdings Limited ("HB") (CIN No. L65929HR1985PLC033936) is a listed company having registered address at "Plot No. 31, Echelon Institutional Area, Institutional Area Sector-32 Gurgaon Haryana 122001 India". The details of its directors/Company Secretary are tabulated in the table below: Table 19 Sl. Name DIN & PAN Designation % Shareholding as on March 31, 2024 1 Lalit Bhasin AFDPB2550A Executive Director-Chairperson related to Promoter 51.54% 2 Gulshan Rai AAEPR4235J Direct....
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.... 20.83% 8.16 The details of its shareholders are tabulated in the table below: Table 22 Sl. Name No. of shares % Shareholding as on March 31, 2023 1 Ashish Kapur 7,23,464 36.61% 2 Mamta Kapur 4,11,600 20.83% 3 Lalit Bhasin 2,36,800 11.98% 4 Kanishk Kapur 1,14,000 5.76% 5 Invest Shoppe India Private Limited* 4,90,000 24.79% Total 100% *Invest Shoppe is a company owned/held/controlled by Mr.******** (son of Ashish Kapur) holding 89% shareholding (approx.) 8.17 Ashish Kapur was the authorized signatory for placing orders for Leo with RRB Master and for operating the bank account of Leo. Upon perusal of the shareholding structure in the above table, it can be seen that Ashish Kapur was holding 36.61% shareholding in Leo in his name, 20.83% in his wife's name, and was also Director of Leo. Further, Ashish Kapur used to take all the trading related decisions in the account of Leo. 8.18 Leo carried out 86.62% trades (8826 out of 10189 trades) through RRB Master during the IP. It was found during the investigation that Ashish Kapur being aware of trades....
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....OTHER ENTITIES INVOLVED IN THE MATTER 11. Connection of Noticee Nos. 2 and 3 through ownership of Noticee Nos. 8 to 11 have already been discussed earlier. Their connection with RRB Master (Noticee No. 4) and dealers (Noticee Nos. 5 & 6) have also been discussed earlier. Further, it has been observed that Sanjiv Bhasin and Lalit Bhasin are cousin brothers. During the period Mar 2022- Feb 2024, there were 09 phone calls between Sanjiv Bhasin (981****162) and Lalit Bhasin (981****778). On December 08, 2023 Ms. ******** (wife of Sanjiv Bhasin) (HDFC A/c No. 03131*****1843) had received 15 Lacs rupees through cheque no. ****** from Lalit Bhasin (HDFC A/c No. 00030*****0379). It can be seen that Sanjiv Bhasin and Lalit Bhasin are connected with each other through natural relationship as well as through phone calls, WhatsApp chats (as shown in succeeding paras). 12. As per the statement of Lalit Bhasin recorded by the Investigating Authority on oath, it was stated by him that he, being the Director of RRB Master, had authorized dealers of RRB Master to allow Sanjiv Bhasin to place buy/sell orders and trades in the trading accounts of Venus and Gemini. He further clarified that he, ....
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....eding paragraphs, the details of which are provided in the table below: Table 23 A B A to B B to A Remarks No. of calls Duration (in seconds) No. of calls Duration (in seconds) Sanjiv Bhasin (981****162) Period: (March 2022 to Feb 2024) Praveen Gupta -(981****959) 5 125 2 37 Rajiv Kapoor-(981****406) 82 5557 23 1091 Dealer 2- (987****199) 26 2425 18 905 Jagat Singh- (836****616 & 852****988) 537 43636 257 20554 Lalit Bhasin- (981****778) 4 348 5 143 Sanjiv Bhasin (965****769*) Period: (May 2022 to Nov 2023) Rajiv Kapoor- (981****406) 5460 534186 647 39901 This mobile number was exclusively used for the purpose of placing orders. The top 3 contacted numbers on this mobile based on number of calls exchanged are to the dealers of RRB Master. Except a handful of the calls, all the thousands of calls made through this number were made around market hours i.e. 0830 to 1600 hrs. Dealer 2- (987****199) 29 2168 6 269 ....
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....nbsp; Text in the image Jagat Singh Sir Father in law is not well Will be on leave tomorrow Ashish Kapur Ok ....Get Well Soon.....Sanjiv Ji will deal with? Rajiv ? Jagat Singh Tough Task He will trade with ****(Dealer 2) I think Ashish Kapur - Ok Date: May 21, 2024 Inference: On May 21, 2024, Jagat informed Ashish that he would not be able to attend office and informed that Sanjiv Bhasin would trade with Rajiv Kapoor. In reply, Ashish permitted Jagat to take leave. At the same time, Ashish enquired Jagat that whether he had informed Sanjiv Bhasin and Rajiv Kapoor, as ******* (Dealer 2) was on leave. In reply, Jagat stated that he had already informed Sanjiv Bhasin. Thereafter, Ashish Kapur instructed Jagat to inform Rajiv as well. Accordingly, Jagat told Ashish that he would inform Rajiv. This substantiates that Ashish Kapur was aware of Sanjiv Bhasin trading through RRB Master Dealers, for placing orders. Text in the image Jagat Singh - Good Morning Sir..i Have to complete Discharge process of my dad from Hospital. Sanjiv JI has to trade with Rajiv Kapur till 12 pm. Ashish Kapur - Yes so hv u told Rajiv n Sanjeev? ....
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....(majorly buy) given to viewers/followers by Sanjiv Bhasin on Media channels and other social media platforms for long term perspectives, he squared off his positions (majorly sell) contrary to his own recommendations, within a few minutes, soon thereafter through dealers of RRB Master in accounts of Venus, Gemini and HB. The evidence collected during the investigation show that Sanjiv Bhasin would remain in continuous touch with dealers and direct them to follow buy/sell instructions, immediately. 24. During the investigation, it was also observed that Ashish Kapur (Noticee No. 3), Rajiv Kapoor (Noticee No. 5) and Jagat Singh (Noticee No. 6), following the above modus operandi, being privy/aware of these trades and recommendations pertaining to shares being given by Sanjiv Bhasin to dealers of RRB Master, had mirrored trades of Sanjiv Bhasin, in their personal accounts also. Ashish Kapur, being the MD of RRB Master traded in personal account as well as through the account of Leo. Further, Jagat and Rajiv, being dealers of RRB Master and being privy to the impending trades of Sanjiv Bhasin, placed trades in an identical manner in their respective personal accounts. 25. Investi....
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.... NOTICEES ON THE BASIS OF STOCK RECOMMENDATIONS GIVEN BY THE GUEST EXPERT 28. As discussed above, during the investigation period, Sanjiv Bhasin appeared in the media channels viz. 'CNBC Awaaz', 'CNBC English', 'ET Now', 'ET Now Swadesh' and 'Zee Business' and also gave recommendations on IIFL's Telegram Channel. For the purpose of investigation, details of recommendations given by Sanjiv Bhasin on Media Channels were obtained from such channels for the investigation period along with the recommendations' videos. Also, the data was obtained from IIFL for its Telegram Channel. In the succeeding paragraphs, I shall now examine the trades carried out at the behest of the Noticee No. 1 and trades by other profit makers in light of the recommendations to be given on Media Channels/Telegram, by Sanjiv Bhasin. It shall also be examined as to how the positions taken earlier were immediately squared off after said recommendations were aired/broadcasted. 29. For the purpose of analysis in this section, unless otherwise mentioned, trades have been considered in terms of scrip days. A Scrip day refers to a day in which the client has traded in a combination of trade date and unique symbo....
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.... were in Cash and Stock Futures segment i.e. 15040 (i.e. 2543 + 12497) scrip days out of 16319 scrip days which is 92.16% of total trades. Similarly, trades of other Noticees in cash and Stock Futures segment constituted 60.59 % (i.e. 14041 (i.e. 3787+10254) days out of 23170 scrip days). Further, it is pertinent to mention here that majority of recommendations of the Noticee No. 1 on Media Channels/Telegram, were mainly in Cash and Stock Futures Segment. F.1 Illustration of recommendation on Zee Business news channel- L&T Technology Services Limited 33. In the first illustration, Sanjiv Bhasin made a guest appearance on Zee Business news channel in the show "Bhasin ke Hasin share" on January 11, 2022. At 13:33 PM, he recommended to buy shares of L&T Technology Services Limited (scrip code "LTTS"). The screenshot below depicts such recommendation: Figure 3 34. The details of recommendation are as follows: Table 27 Date Scrip CMP Target Price Stop Loss Recommendation Jan 11, 2022 L&T Technology Services Limited ("LTTS"). 5644.80 Rs.5800 Rs.5520 Buy (Long term) Impact of the recommendation on the Price and Volume of the ....
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....lysis of the volume impact in the scrip shows the following: i. The average trading volume in the 15 minutes leading up to the recommendation (t-15) was 17 shares, 687 shares and 1350 shares for LTTS scrip at BSE (EQ), NSE (EQ) and NSE (Future) respectively. ii. During the recommendation time and the following 2 minutes (t and t+2), the trading volume experienced a substantial increase, reaching an average of 229 shares, 7302 shares, and 12467 shares for LTTS scrip at BSE (EQ), NSE (EQ) and NSE (Future) respectively. iii. In the succeeding 15 minutes (t+15) after the recommendation, the average trading volume remained elevated at 114 shares, 2674 shares and 4250 shares for LTTS scrip at BSE (EQ), NSE (EQ) and NSE (Future) respectively. 38. It is also noted that there were no relevant price-sensitive corporate announcements made by the company around the time of recommendation, which could justify the sudden rise in price and volume in the scrip of LTTS. 39. Investigation revealed that Sanjiv Bhasin made calls to Rajiv Kapoor before placement of buy orders in the account of Venus and instructed Rajiv to place orders. Further, he made calls to Rajiv K....
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....oticee No. 5, for which Rajiv informed that the average price of the shares bought was Rs.5660.48 per share. 39.5 Upon perusal of the trade log data obtained for the scrip day from NSE, it is observed that the Noticee No. 5, had placed a buy order in the future contract of LTTS scrip at 09:56, in the account of Venus through RRB Master, the details of which are as follows: Table 31 Date Buy Trading Member Name Buy Client Name Buy Client Pan Buy Symbol Buy_Instrument Buy Order Date & Time Buy Order Limit Price Trade Date Time Trade Qty Trade Price 11/01/2022 RRB MASTER SECURITIES DELHI LTD. VENUS PORTFOLIOS PVT LTD AAACV4306R LTTS FUTSTK 11/01/2022 9:56 5665 11/01/2022 9:56 200 5658.45 11/01/2022 RRB MASTER SECURITIES DELHI LTD. VENUS PORTFOLIOS PVT LTD AAACV4306R LTTS FUTSTK 11/01/2022 9:56 5665 11/01/2022 9:56 200 5658.5 11/01/2022 RRB MASTER SECURITIES DELHI LTD. VENUS PORTFOLIOS PVT LTD AAACV4306R ILTTS FUTSTK 11/01/2022 9:56 5665 11/01/2022 9:56 200 5661.25 11/01/2022 RRB MASTER SECURITIES DELHI LTD. VENUS PORTFOLIOS PVT LTD ....
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....0000008119910 400 5713 5655.05 NULL *NULL - Indicates non-execution of trades 39.9 The detailed transcript of third conversation exchanged between Sanjiv Bhasin and Rajiv Kapoor for the buy instance at 12:42 PM is as under: "Rajiv - Hello Sanjiv Bhasin - LTTS Dekhiyo.....40 Karke 5 lot aur lelo.... Rajiv - Ek reh gaya sir Sanjiv Bhasin - Aa gaye Rajiv Rajiv - Ek reh gaya sir Sanjiv - ok" 39.10 From the above call, it is clear that the Noticee No. 1 had already bought the Future contracts of scrip LTTS. Thereafter, the Noticee No. 1 first enquired the price of Future contracts of scrip LTTS from Noticee No. 5 and then instructed him to buy further 5 lots of LTTS. From a perusal of the trade data of LTTS as provided by NSE, it can be seen that the trade quantity and time of the trades exactly match with the contents of the aforesaid transcript. After the end of third call, the total bought quantity became 2000. The order log data is provided below: Table 33 Date Buy Trading Member Name Buy Client Name Buy Client Pan Buy Symbol Buy_Instrument Buy Order Date & Time Buy Orde....
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.... pending buy orders were standing @32, @30.50 and @35 which meant, Rs.5,632, Rs.5630.50 and Rs.5,635 per share. After the end of the fourth call, the total bought quantity became 3800. The instructions given by the Noticee No. 1 to Noticee No. 5 to place aforementioned orders in the scrip of LTTS Future can be seen in the order log data given below: Table 34 Buy Order Date Buy Order Time Buy Client Name Buy Order no. Buy order original Vol Trade Quantity Buy order limit price Buy LTP prior to order entry Trade no .* 11/01/2022 12:47:45 VENUS PORTFOLIOS PVT LTD 1500000032838810 400 0 5632 5635 NULL 11/01/2022 12:47:46 VENUS PORTFOLIOS PVT LTD 1500000032838810 400 200 5632 5635 20220111500208100 11/01/2022 12:47:46 VENUS PORTFOLIOS PVT LTD 1500000032838810 400 200 5632 5635 20220111500208100 11/01/2022 12:47:53 VENUS PORTFOLIOS PVT LTD 1500000032855220 400 0 5632 5632 NULL 11/01/2022 12:48:00 VENUS PORTFOLIOS PVT LTD 1500000032855220 400 200 5632 5632 20220111500208200 11/01/2022 12:48:10 VENUS PORTFOLIOS PVT LTD....
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....2 12:49 200 5635 11/01/2022 RRB MASTER SECURITIES DELHI LTD. VENUS PORTFOLIOS PVT LTD AAACV4306R LTTS FUTSTK 11/01/2022 12:49 5635 11/01/2022 12:49 200 5635 11/01/2022 RRB MASTER SECURITIES DELHI LTD. VENUS PORTFOLIOS PVT LTD AAACV4306R LTTS FUTSTK 11/01/2022 12:49 5632 11/01/2022 12:49 200 5632 11/01/2022 RRB MASTER SECURITIES DELHI LTD. VENUS PORTFOLIOS PVT LTD AAACV4306R LTTS FUTSTK 11/01/2022 12:49 5630.5 11/01/2022 12:49 200 5630.5 11/01/2022 RRB MASTER SECURITIES DELHI LTD. VENUS PORTFOLIOS PVT LTD AAACV4306R LTTS FUTSTK 11/01/2022 12:49 5630.5 11/01/2022 12:49 200 5630.5 Total 1800 5633 39.14 The detailed transcript of the fifth conversation exchanged between Sanjiv Bhasin and Rajiv Kapoor for the buy instance at 12:50 PM is as under: "Rajiv - Hello Sanjiv - Aa Gaye Rajiv....Kitne Hue.....Kitne ho gaye... Rajiv - Ye ho gaye....3800...5641.81 Sanjiv - 3800 go haye.....200 aur le le...abhi le le 15 main.....18....
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....5641.81 per share. It is also clear from the above conversation that as soon as the buy order was completed, the Noticee No. 1 instructed Noticee No. 5 to place sell orders (limit orders) in the range of Rs.5688 to Rs.5700. The same was done as can be seen from the log data below: Table 37 Sell Order Date Sell Order Time Sell Client Name Sell Order no. Sell order original Vol Sell order limit price Sell LTP prior to order entry Trade no .* 11/01/2022 13:10:00 VENUS PORTFOLIOS PVT LTD 1500000008119910 400 5713 5655.05 NULL 11/01/2022 13:10:03 VENUS PORTFOLIOS PVT LTD 1500000008106820 600 5708 5655.05 NULL 11/01/2022 13:10:18 VENUS PORTFOLIOS PVT LTD 1500000035588730 400 5688 5637.95 NULL 11/01/2022 13:10:36 VENUS PORTFOLIOS PVT LTD 1500000035634020 400 5690 5638 NULL 11/01/2022 13:10:42 VENUS PORTFOLIOS PVT LTD 1500000035651760 400 5692 5638 NULL 11/01/2022 13:10:46 VENUS PORTFOLIOS PVT LTD 1500000035658920 400 5694 5638 NULL 11/01/2022 13:10:51 VENUS PORTFOLIOS PVT LTD 1500000035671740 400 5696 ....
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.... Sanjiv - 80 - 81 - 82 main bicha de........ Bike aur.....Bik gaye aur Rajiv - haan bik rahe hain sir......1600 reh gaye mere... Sanjiv - Bas Rajiv - Hanji Sanjiv - 2200 bik gaye na Rajiv - Hanji Sanjiv - Chal 1600 tu karde......kya bhav laga rakhein hain.......upar ke sabh cancel kar diye na.... Rajiv - sare cancel kar diye Sanjiv - Ab bas 1600 reh gaye Rajiv - 1600 reh gaye Sanjiv - 4-80 main dal 4-82 main dal de...Chal ye bhi dekh ke kar de Rajiv ........sulta de....Kitne ke bik gaye Rajiv - Ye 80 wale to bik gaye Sanjiv - Kitne reh gaye Rajiv - 1200 Sanjiv - 82 aur 84 main laga de........82-83-84 main laga de....theek hain Rajiv.... Rajiv - Theek hain Theek hain" 39.19 In the aforesaid transcript, the Noticee No. 1 first enquired Noticee No. 5, whether he had already placed the sell orders at the price of Rs.5687 or above. To this, the Noticee No. 5 replied that all the orders in the scrip were standing at the price between Rs.5687 - Rs.5700. The same is reflected in the order log data provided in the preceding paras at Table 37. Ther....
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....22 13:37 5684 11/01/2022 13:37 200 5684 11/01/2022 RRB MASTER SECURITIES DELHI LTD. VENUS PORTFOLIOS PVT LTD AAACV4306R LTTS FUTSTK 11/01/2022 13:37 5684 11/01/2022 13:37 200 5684 11/01/2022 RRB MASTER SECURITIES DELHI LTD. VENUS PORTFOLIOS PVT LTD AAACV4306R LTTS FUTSTK 11/01/2022 13:37 5684 11/01/2022 13:37 200 5684 11/01/2022 RRB MASTER SECURITIES DELHI LTD. VENUS PORTFOLIOS PVT LTD AAACV4306R LTTS FUTSTK 11/01/2022 13:37 5684 11/01/2022 13:37 200 5684 11/01/2022 RRB MASTER SECURITIES DELHI LTD. VENUS PORTFOLIOS PVT LTD AAACV4306R ILTTS FUTSTK 11/01/2022 13:37 5680 11/01/2022 13:37 400 5680 11/01/2022 RRB MASTER SECURITIES DELHI LTD. VENUS PORTFOLIOS PVT LTD AAACV4306R LTTS FUTSTK 11/01/2022 13:38 5682 11/01/2022 13:38 200 5682 11/01/2022 RRB MASTER SECURITIES DELHI LTD. VENUS PORTFOLIOS PVT LTD AAACV4306R ILTTS FUTSTK 11/01/2022 13:38 5682 11/01/2022 13:38 200 5682 11/01/2022 RRB MASTER SECURITIES DELHI LTD. VENUS PORTFOLIOS PVT LTD AAACV4306R LTTS FUTST....
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.... order of 2 lots @5632 and bought 400 shares 2400+400= 2800 Sanjiv Bhasin to Rajiv Buy another 2 lots @30.50 12:48:10 Rajiv placed buy order of 2 lots @5630.50 and bought 400 shares @ 5630.50 2800+400= 3200 Sanjiv Bhasin to Rajiv Buy another 3 lots @28.50. As the price went up, Sanjiv Bhasin asked Rajiv to revised the price to 35 12:48:51 Rajiv first placed buy order of 3 lots @Rs.5628.50 later revised the same to 5635 and bought 600 shares @ Rs.5635. 3200+600= 3800 12:50 Sanjiv Bhasin instructed Rajiv Kapoor to place buy orders for 200 shares at price of Rs.5615 & Rs.5618. However, as per the Order log no buy order was executed at this price range. At last, Rajiv confirms that Average price of 3800 shares is Rs.5641.81 - 13:36 Sanjiv Bhasin instructed Rajiv Kapoor to place sell order at various prices and also instructed him to revised the price as per the prevailing market price of the scrip. 13:36:59 - 13:38:39 Rajiv placed orders to sell 2600 shares. Shares sold at average price of Rs.5682.31 3800 - 2600 = 120....
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....randi of his trading, also traded and carried out similar fraudulent trades in their respective accounts. As per the trade log made available, the trading member details along with the respective dealer name and their CTCL ID, through which order(s) were placed of the above entities are given as under: Table 40 Broker wise order placement details Client Name Trading Member Name CTCL_ID Dealer Name Ashish Kapur RRB Master 110034002006110 Rajiv Kapoor Jagat Singh Zerodha Broking Ltd. 111111111111100 IBT LEO RRB Master 110034002006110 Rajiv Kapoor Rajiv Kapoor SMC Global securities Ltd 333333333333110 IBT Venus RRB Master 110001001005110 Dealer 1 40.1 The Noticee No. 5 being privy to the orders of Noticee No. 1 by being in constant touch with the Noticee No. 1 over calls, upon placing orders in the account of Venus at 09:56, as instructed by the Noticee No. 1, also placed a similar type of trade in his personal trading account in the scrip of LTTS using Internet based trading. He placed two buy orders of LTTS Future (containing 400 shares) at 09:57 AM and 12:08 PM, and subsequently, placed two limit....
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....corded during the investigation, on oath, it has been stated by him that on an ongoing basis, he used to authorize the dealers of RRB Master, viz. Noticee Nos. 5 and 6 to place orders in the accounts of Noticee Nos. 8 and 9, on instructions of the Noticee No. 1. The scheme of placement of orders in the trading accounts of Noticee Nos. 3 and 11 indicates that the Noticee No. 3 was fully aware of the scheme of Noticee No. 1 and also mirrored the same trades in his account through Noticee No. 5, dealer who placed orders for Noticee No. 1 in the instant scrip. This pattern of placing mirrored trades further gets affirmed by the fact that in certain instances, the Noticee No. 1 had enquired from Noticee Nos. 5 and 6 when either of them was unavailable for placing orders, as to who would take care of the trades to be carried out by the Noticee No. 1, as already shown in preceding paras. 40.4 The Noticee No. 1 had placed buy orders in the account of Venus between 09:56 AM to 12:49 PM through Noticee No. 5. The Noticee No. 3, immediately thereafter, traded in the scrip in his account at 10:03 AM through Rajiv. Further, he also placed buy order in the scrip in the account of Leo be....
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....ysts, including Noticee No. 1, were broadcasted using publisher platforms like 'Yobee/Jamun', software/applications integrated with the trading applications of IIFL, and the recommendations given on Yobee platform were directly broadcasted to all the platforms such as IIFL Telegram Channel namely IIFL Capital (previously 'IIFL Capital Research'), IIFL Trading terminals and IIFL Markets App. The Telegram channel referred herein was not exclusively for the clients of IIFL and it was open for general public also. Further, it has been observed that research reports of stock recommendations by the Noticee No. 1 were circulated by IIFL to its employees and authorised persons of IIFL capital through emails. 42. Investigation revealed that the Noticee No. 1, on February 07, 2024 had recommended to buy the shares of Parag Milk Foods Limited. It was observed that the Noticee No. 1 initially recommended Parag Milk Foods at 13:18 PM through Yobee platform, which in turn, was automatically broadcasted to IIFL Telegram Channel, IIFL Trading terminals and the IIFL Markets App. The snapshot of the recommendation as visible on IIFL Telegram Channel is as follows: Table 42 Snapsho....
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....er, it is pertinent to mention that on that day, Parag Milk had also announced Financial Results for the quarter ended December 2023 at 14:36 PM, however, it may be noted that the price of the scrip and volume had already increased substantially upon recommendation by the Noticee No. 1 and prior to the dissemination of the Financial Results of Parag Milk which happened subsequently at 14:36 PM. 48. Impact of the recommendation on the Price and Volume of the scrip is shown in the following paragraphs. The price and volume chart, during 15 minutes pre and post the recommendation time (i.e. 13:18 PM) in the scrip of "PARAGMILK" in BSE Equity Cash segment, NSE equity cash segment was carried out, and can be seen below: Figure 7 49. The details of the significant impact on the price and trading volume of the scrip, as observed in the above graph is depicted below: Table 45 Recommendation date February 07, 2024 Recommendation time (t) 13:18 PM Scrip/Contract Recommended PARAGMILK Recommended Levels (For Cash) Recommended Price (Rs.) 210-220 Target Price (Rs.) 300 Stop Loss (Rs.) 202 Scrip/Contract Parag Milk Foods Limited ....
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....E (EQ) and NSE (EQ) respectively. 52. From examination of calls between Rajiv Kapoor and Sanjiv Bhasin, it is observed that there were calls between Rajiv and Sanjiv Bhasin on Feb 07, 2024 w.r.t scrip Parag Milk Food. It was observed that before making the said recommendation, Sanjiv Bhasin had made phone calls to Rajiv Kapoor, Praveen Gupta and Lalit Bhasin for placing buy orders in the scrip of Parag Milk Foods. Further, post the recommendation, he made phone calls to Lalit Bhasin for placing sell orders. 52.1 Transcript of first phone call between Sanjiv Bhasin and Rajiv Kapoor on Feb 07, 2024 at 09:28:50 AM - (1st Buy leg) "Rajiv - Yes sir Sanjiv Bhasin - Rajiv Indiabull or Parag milk ka bhaav bata de Rajiv - Ji sir, bata raha hu" The call placed on hold 52.2 From the above call, it is evident that Sanjiv Bhasin had enquired about the scrip price of Indiabulls and Parag Milk from Rajiv Kapoor and then it can be seen that the call was placed on hold by Sanjiv Bhasin. 52.3 Upon analysis of the CDR records of February 07, 2024 of Sanjiv Bhasin (Ph: 981****162), it is observed that Praveen Gupta (Noticee No. 7) (Ph: ....
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....made a call to Lalit Bhasin (981****778) at 09:38 AM. The call time matches exactly with the Order time of PARAGMILK. 52.7 The above WhatsApp call was initiated by Sanjiv Bhasin at around 09:38 AM to Lalit Bhasin through WhatsApp, which was immediately after the call with of Sanjiv Bhasin with Rajiv Kapoor (09:37 AM). It is seen that Sanjiv Bhasin on being frustrated, due to non-execution of trades by Rajiv had called Lalit Bhasin to ensure that his instruction is to be complied by Rajiv Kapoor immediately. This can be corroborated with the fact that, upon calling Lalit Bhasin, Rajiv Kapoor placed buy order in the scrip of ParagMilk at 09:39 AM which is detailed below. 26,500 shares of ParagMilk were purchased at an average price of Rs.218.23. The shares were purchased in the account of HB: Table 47 NAME: HB STOCKHOLDINGS LTD PAN: AAACH0637F DATE SYMBOL INSTRUMENT TYPE BUY QUANTITY BUY VALUE AVG. BUY PRICE BUY ORDER RECO. TIME Start Time End Time 07.02.2024 PARAGMILK CASH 26500 57,83,330.2 218.23 09:39:48 09:44:08 13:18 & 14:22 52.8 Wha....
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....hasin made a phone call to Mr. Lalit Bhasin. The sell orders in ParagMilk were placed immediately after this call. Content: "Sold 25000 Parag milk at Rs.234.85 mkt" Explanation: After receiving the call from Mr. Sanjiv Bhasin as stated above, Mr. Lalit Bhasin sends a confirmation message at 03:16 PM to Sanjiv Bhasin that 25000 shares of Parag Milk were sold at an average price of Rs.234.85. Content: 1. WhatsApp call from Sanjiv Bhasin to Lalit Bhasin. 2. "Total 51500 Parag sold at 235.45" Explanation: After receiving the call from Sanjiv Bhasin at 03:17 PM, Mr. Lalit Bhasin confirms at 03:30 PM to Sanjiv Bhasin that total 51500 shares of ParagMilk were sold at an average price of Rs.235.45. 52.12 The above images reveal that Sanjiv Bhasin called Lalit Bhasin at 3:07 PM and 3:17 PM through WhatsApp (981****162). After calls from Sanjiv Bhasin to Lalit Bhasin, sell orders in the scrip were placed immediately and upon execution of orders in the scrip, it was communicated that the average sell price was Rs.235.45 and number of shares was 51,500, which matched exactly with the trades carried out in the account of HB, as seen from the trade l....
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....ie fraudulent trades, a total profit of Rs.8,40,217.6 was made through the account of HB Stockholdings, in this illustration. Further, the details of trade quantity and price in the account of HB exactly matched with the content of WhatsApp chat between Sanjiv Bhasin and Lalit Bhasin. Table 53 NAME: HB STOCKHOLDINGS LTD PAN: AAACH0637F DATE SYMBOL INSTRUMENT TYPE BUY QUANTITY BUY VALUE BUY ORDER SELL QUANTITY SELL VALUE SELL ORDER Reco. Time Start Time End Time Start Time End Time 07.02.2024 ParagMilk Cash 51500 1,12,85,480 09.39 11:34 51500 1,21,25,698 15:08 15:36 13:18 & 14:22 Profit Rs.8,40,217.6 52.16 Investigation revealed that Praveen Gupta (Noticee No. 7), dealer of RRB Master, by being privy to the impending order related information of Sanjiv Bhasin through the call details, as evidenced in the transcript of call between Sanjiv Bhasin and Rajiv Kapoor wherein Rajiv Kapoor had stated "Sir, wo phone ab aya mere ....
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.... 14:48 14:48 13:18 & 14:22 Avg. Buy price 215.50 Avg. Sell Price 235.00 Profit Rs.7,780 52.19 A brief analysis of trades in PARAGMILK by HB and Babita Gupta wife of Praveen Gupta based on NPI of trades placed by Sanjiv Bhasin in the account of HB has been given below: Table 55 DATE 07.02.2024 07.02.2024 SYMBOL PARAGMILK PARAGMILK PAN AAACH0637F AAEPG1745N Client Name HB STOCKHOLDINGS LIMITED BABITA GUPTA INSTRUMENT TYPE CASH CASH Trade Leg Buy Leg of Trade Sell Leg of Trade Buy Leg of Trade Sell Leg of Trade Order Start Time 09:39 15:08 09:34 14:48 Order End Time 11:34 15:28 09:34 14:48 Trade Start Time 09:39 15:08 09:34 15:08 Trade End Time 11:34 15:28 09:34 15:08 Average Price 219.13 235.45 215.5 235 Traded Quantity 51,500 51,500 400 400 Total Value Traded Rs. 1,12,85,480 1,21,25,698 86,220 94,000 Recommendation Time 13:18 & 14:22 13:18 & 14:22 Client Traded Vol (Gross) to Market Vol. 0.47% 0.003% Client Traded Val in the....
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.... recommendation in the show, as shown below: Table 57 Recommendation date January 30, 2024 Recommendation time (t) 08:51 AM Scrip/Contract Recommended INDIGO Recommended Levels (For Cash) Recommended Price (Rs.) Rs.3100 Target Price (Rs.) Rs.3100 Stop Loss (Rs.) 2835 Scrip/Contract INDIGO BSE (EQ) NSE (EQ) NSE (FF) Price Impact Post Recommendation Average High/ Low Variation % in preceding 15 min [3:15 -3:30 PM, Jan 29, 2024] 0.10 0.12 0.11 Average High/ Low Variation % during recommendation time and succeeding 2 min [9:15 - 9:17 AM, Jan 30, 2024] 0.99 0.55 0.60 Average High/ Low Variation % in succeeding 15 Min [9:15 - 9:30 AM, Jan 30, 2024] 0.27 0.30 0.26 Volume Impact Post Avg. Trading Vol in Preceding 15 min [3:15 -3:30 PM, Jan 29, 2024] (number of shares/underlying shares) 95 9053 10220 Avg. Trading Vol during recommendation time and succeeding 2 min [9:15 - 9:17 AM, Jan 30, 2024] (number of shares/underlying shares) 246 9576 37800 Avg. Trading Vol for succeeding 15 min [9:15 - 9:17 AM, Jan 30, 2024] (number of shares/underlying shar....
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.... in INDIGO24FEBFUT on January 29, 2024 and squared off the positon on the day of recommendation i.e. on January 30, 2024. The summary of trading activity of Venus is as under: Table 58 VENUS PORTFOLIOS PRIVATE LIMITED Instrument INDIGO24FEBFUT Date of Buy Leg Tuesday, January 29, 2024 Net Qty 9900 Average Price (Rs.) 2909.23 Total Traded Value (Rs.) 2,88,01,395.00 Date of Sell Leg Wednesday, January 30, 2024 Net Qty 9900 Average Price (Rs.) 2958.39 Total Traded Value (Rs.) 2,92,88,100.00 Profit 4,86,705.00 62.1 The aforesaid buy and sell trades were done through CTCL ID - 110034002002, registered in the name of Jagat Singh, Dealer at RRB Master. The details of the order placement both during the buy and the sell leg are given below: Table 59 Date Buy/Sell Traded Qty Trade Qty Range No. of orders Order Time Order modified time Order Limit Price Range (Rs.) Trade Time Trade Price Range (Rs.) 29/01/2024 Buy 9900 300 6 13:08:39-13:11:48 13:08:39-13:11:48 2906.15- 2915 13:08:39-13:11:48 2906.15- 2915 30/01/2024 Sell 9900 300-1500 10 ....
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....DIGO24FEBFUT matched with the timing of calls between Sanjiv Bhasin and Jagat Singh, which is explained through the below table: Table 61 Date Timing Nos. of Call Sanjiv to Jagat Jagat to Sanjiv Jan 29, 2024 09:12:40 - 13:07:17 5 4 1 Jan 30, 2024 09:14:15 - 15:18:31 17 15 2 Total 22 19 3 62.7 On Jan 29, 2024, Sanjiv Bhasin (981****162) called Jagat (836****616) during 13:07:17 PM-13:12:33 PM (Duration- 317 seconds). Investigation revealed that during this call, the buy orders (buy order timing i.e. 13:08:39 PM-13:11:48 PM) were placed in the account of Venus by Jagat. Further, On Jan 30, 2024, there were 17 calls between Sanjiv Bhasin (981****162) and Jagat (836****616) and it was during/around such calls, the sell orders were placed/modified in the account (sell orders time- 09:15:00 AM - 12:11:28 PM. The same is evident from the following tables which provide the details of timing of placement of sell orders vs timings of calls: Table 62 SALE ORDER NO. SELL ORDER TIME CALL TIMING TRADED QTY 2300000000009680 09:15:00-09:15:00 09:14:15-09:17:51 1500 2300000001099760 09:17:06-09....
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....ent - The screenshot of trades executed. Explanation: In reply to the above message, on Jan 30, 2024, around 1:08 PM, Jagat forwarded the details of the trades executed. This screen shot includes the details of the sell order executed in the scrip of Indigo. Screenshot sent on Jan 30, 2024: The aforesaid chats were also found in seized data from Jagat Singh's Mobile (852****988). 63. From the above, it can be seen that Jagat had executed trades in the scrip in INDIGO24FEBFUT as per the instructions of Sanjiv Bhasin, which was further confirmed by Jagat and the screenshots of the same were also shared with Sanjiv Bhasin. The same can be verified from the pictorial representations shown hereinabove. Accordingly, a profit of Rs.4,86,705.00/- was made by the Noticee No. 1 by doing trades in the pattern of Buy Today Sell Tomorrow ("BTST") trades in INDIGO24FEBFUT during Jan 29, 2024 - Jan 30, 2024 in the account of Venus. 64. It is pertinent to note that on one hand the Noticee No. 1 recommended the viewers to buy INDIGO on a long term basis just during the pre-market hours at 08:51 AM and on the other hand, contrary to his recommendation for the viewers, he ....
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....ct Steel Authority of India Limited BSE (EQ) NSE (EQ) NSE (FF) Price Impact Post Recommendation Average High/ Low Variation % in preceding 15 mins [t-15] 0.13% 0.11% 0.09% Average High/ Low Variation % during recommendation time and succeeding 2 mins [t and t+2] 0.14% 0.16% 0.18% Average High/ Low Variation % in succeeding 15 mins [t+15] 0.14% 0.14% 0.10% Volume Impact Post Recommendation Avg Trading Vol in Preceding 15 mins [t-15] (number of shares/underlying shares) 8727 65737 85600 Avg Trading Vol during recommendation time and succeeding 2 mins [t and t+2] (number of shares/underlying shares) 16998 131575 176000 Avg Trading Vol for succeeding 15 mins [t+15] (number of shares/underlying shares) 8006 64889 64800 Relevant Price Sensitive Corporate Announcement on the day of the recommendation or the prior day NA 70. The analysis of the price impact in the scrip shows the following: i. In the preceding 15 minutes before the recommendation, the average high/low price variation was at 0.13%, 0.11%, 0.09% for SAIL scrip at BSE (EQ), NSE (EQ) and NSE (Future) ....
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....ring-off the positions taken earlier. The summary of calls exchanged between Noticee No. 1 and Noticee No. 5 during the recommendation day (before and after the recommendation time of 09:52 AM), is tabulated below: Table 66 Call Details Time Instruction (On call) First Call 09:14 AM Buy SAIL Second Call 09:25 AM Buy SAIL Third Call 09:31 AM Buy SAIL & Sell SAIL* Fourth Call 09:40 AM Buy SAIL Recommendation on ZEE Business Media Channel at 09:52 AM Fifth Call 10:19 AM Sell SAIL Sixth Call 10:40 AM Sell SAIL *As per the trade logs, the orders instructed by Sanjiv Bhasin during his call could not be executed. 73.2 The details of trades done in the trading account of HB are given below: Table 67 Date and Recommendation time - Aug 26, 2022, 09:52 AM (Contract- SAIL22SEPFUT) Buy (First Leg) Sell (Second Leg) Client Name PAN Order Time Trade Time Buy Price Range Traded Quantity Total Value Traded Rs. Order Time Trade Time Sell Price Range Traded Quantity Total Value Traded Rs. HB Stockholdings Limited AAACH0637F 09:15 - ....
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....STK 26/08/2022 09:15 82 26/08/2022 09:15 6000 81.9 Total 36000 81.83 73.5 From the above, it is seen that the average price (Rs.81.83) of the executed trades is matching exactly with the price mentioned by the Noticee No. 5 in the transcript. 73.6 Transcript of 2nd call at 09:25 AM on Aug 26, 2022- Buy Side is given below: "Sanjiv - SAIL kya aa raha Rajiv- SAIL aa raha hain 10 81 20 Sanjiv - Thik hain OK" From the above, it can be seen that Noticee No. 1 called Noticee No. 5 in a gap of 10 minutes again at 09:25 AM to enquire about the share price of SAIL, to which Rajiv replied that the scrip price was in the range of Rs.81.10 - 81.20. 73.7 Transcript of 3rd call at 09:31 AM on Aug 26, 2022- Buy Side as well as Sell Side: "Sanjiv - Aur SAIL dekhiyo Rajiv- 82 15 20 Sanjiv - Lele 5 lot Rajiv- laga diya Sanjiv -aa gaye Rajiv- 2 hi aaye,10 se 20 main 3 aaye Sanjiv - Thik hain, 83 main aaj ki selling dal diyo puri haan Rajiv- aaj wali Sanjiv ....
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....de Rajiv- ok" 73.10 From the above, it can be seen that Sanjiv Bhasin called Rajiv at 09:40 AM and enquired about the share price of SAIL. He then instructed Rajiv to buy 5 more lots. Further, it can be seen that Sanjiv Bhasin is instructing Rajiv desperately to place sell orders in the price range of Rs.82.90-82.95. As per the instructions of Sanjiv Bhasin, Rajiv Kapoor placed buy orders for 5 lots at 09:40 AM. The same can be confirmed from the trade data presented below: Table 70 Date Buy Trading Member Name Buy Client Name Buy Client PAN Buy Symbol Buy Instrume nt Buy Order Date & Time Buy Order Limit Price Trade Date & Time Trade Quantity Trade Price 26/08/2022 RRB MASTER SECURITIES DELHI LTD. HB STOCKHOLDINGS LIMITED AAACH0637F SAIL FUTSTK 26/08/2022 09:40 82.15 26/08/2022 09:40 6000 82.15 26/08/2022 RRB MASTER SECURITIES DELHI LTD. HB STOCKHOLDINGS LIMITED AAACH0637F SAIL FUTSTK 26/08/2022 09:40 82.15 26/08/2022 09:40 6000 82.15 26/08/2022 RRB MASTER SECURITIES DELHI LTD. HB STOCKHOLDINGS LIMITED AAACH0637F SAIL FUTSTK 26/08/2022 09:40 ....
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....ipts: Table 72 Date Sell Trading Member Name Sell Client Name Sell Client PAN Sell Symbol Sell Instrument Sell Order Date & Time Sell Order Limit Price Trade Date & Time Trade Quantity Trade Price 26/08/2022 RRB MASTER SECURITIES DELHI LTD. HB STOCKHOLDINGS LIMITED AAACH0637F SAIL FUTSTK 26/08/2022 10:40 82.6 26/08/2022 10:40 12000 82.6 26/08/2022 RRB MASTER SECURITIES DELHI LTD. HB STOCKHOLDINGS LIMITED AAACH0637F SAIL FUTSTK 26/08/2022 10:40 82.6 26/08/2022 10:40 6000 82.6 26/08/2022 RRB MASTER SECURITIES DELHI LTD. HB STOCKHOLDINGS LIMITED AAACH0637F SAIL FUTSTK 26/08/2022 10:40 82.6 26/08/2022 10:40 18000 82.6 73.15 Further, Sanjiv Bhasin informed Rajiv to cancel all pending sell orders of the remaining lots and instructed him to place sell orders for 36000 shares at Rs.82.75 and the remaining (i.e. 24000 shares) at Rs.82.80. To which Rajiv confirmed that the sell order placed for 36000 shares at Rs.82.75 got executed and the one placed at Rs.82.80 got executed for 18000 shares and one lot (6000 shares) is remaining. The same can be con....
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....:42 73.17 For the sake of clarity, a table detailing calls between Sanjiv Bhasin and Rajiv Kapoor vis-à-vis order placement is given in the below table: Table 75 Call Time Order Time Particulars Shares Inventory 09:14 Sanjiv Bhasin instructed Rajiv Kapoor to buy 36000 shares of SAIL (i.e. 1 lot of SAIL FUT = 6000 shares) 09:15 Rajiv Kapoor placed buy orders for 36000 shares at an average price of Rs.81.83 36000 09:25 Sanjiv Bhasin enquired Rajiv the share price of SAIL, to which Rajiv replied that the price is in the range of Rs.81.10 - 81.20. No order was executed during this call. 09:31 Sanjiv Bhasin instructed Rajiv Kapoor to buy 5 lots 09:32 Rajiv Kapoor placed buy orders for 5 lots (30000 shares) at Rs.82.20 30000 Sanjiv Bhasin instructed Rajiv Kapoor to place sell orders for the entire quantity (66000 shares) at Rs.83 As per trade log, it appears that no sell order was executed 09:40 Sanjiv Bhasin instructed Rajiv Kapoor to buy 5 lots &nb....
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....seen that post his recommendation, there was significant price and volume impact on the scrip of SAIL. 73.20 He utilised the momentum and instructed Rajiv Kapoor to place sell trades contrary to his own recommendation immediately after/during the recommendation. By virtue of carrying out these trades, a profit of Rs.63,000 was made in the scrip of SAIL. 73.21 Investigation also revealed that certain connected/related entities privy to the order placement in the trading account HB Stockholdings such as Babita Gupta (Noticee No. 12), Leo Portfolios Pvt Ltd (Noticee No. 11), Rajiv Kapoor (Noticee No. 5) and Jagat Singh (Noticee No. 6) also placed orders in the scrip of SAIL around the same time and followed the same trading pattern as of Sanjiv Bhasin and made profit. It can be seen that, similar to the trades carried out by HB, all other aforesaid Noticees also followed the same trading methodology i.e. creating position in the same scrip before the recommendation and squaring-off the positon afterwards. A brief analysis of trades of these Noticees vis -a-vis trades of Sanjiv Bhasin through the account of HB are as follows: Table 76 Analysis of trades carried ....
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....fraudulent trades through the trading account of his wife Noticee No. 12 by placing two buy orders of 6000 shares each at 09:32 AM and 09:43 AM, respectively. The orders got executed at the same time. Further, upon perusal of the trade data, it was observed that all 12000 shares were squared off at 09:54 AM (i.e. immediately post the recommendation of Sanjiv Bhasin on Zee Media Channel). 74.2 On the basis of the information received from Sanjiv Bhasin, after placing orders in the trading account of HB, investigation revealed that the Noticee No. 5 also placed the buy orders for 6000 shares at 09:35 AM (reference may also be drawn to three transcripts earlier at 09:14 AM, 09:25 AM and 09:31 AM, through which the Noticee No. 5 was placing orders in account of HB), in his own trading account held with broker SMC Global Securities Ltd. Further, upon perusal of the trade data, it was observed that he squared off his entire position at 10:36 AM (i.e. post the recommendation of Sanjiv Bhasin at 09:52 AM), and earned profit of Rs.3,000. With regard to trades carried out by the Noticee No. 5 in the trading account of HB as per the instructions of Noticee No. 1, Dealer 1, in his sta....
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....3 77. From the above, it can be seen that the Noticee No. 1 has recommended the following w.r.t. the scrip of GODREJCP: Table 78 Date Scrip Name & Code CMP Target Price Stop Loss Recommendation September 13, 2022 Godrej Consumer Products Ltd ("GODREJCP") Rs.948.30 Rs.1020 Rs.925 BUY 78. The price and volume chart, during 15 minutes pre and post the recommendation time (i.e. 13:35 PM) in the scrip of "GODREJCP" in BSE Equity Cash segment, NSE equity cash segment and NSE Futures is given below: Figure 14 79. It can be seen that a significant impact on the price and the trading volume of the scrip was observed post the recommendation in the show, the details of which are given in the table below: Table 79 Recommendation date September 13, 2022 Recommendation time (t) 13:35 Scrip/Contract Recommended GODREJCP Recommended Levels (For Cash) CMP (Rs.) 948.30 Target Price (Rs.) 1020 Stop Loss (Rs.) 925 Scrip/Contract Godrej Consumer Products Limited BSE (EQ) NSE (EQ) NSE (FF) Price Impact Post Recommendation Average High/ Low Variation % in preceding 15 mins....
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....ve corporate announcements around the time of recommendation, which could explain the sudden rise in price and volume in the scrip of GODREJCP. 83. Investigation revealed that the Noticee No. 1 had traded in the scrip of GODREJCP on the recommendation date (i.e. September 13, 2022), through Venus and Gemini and made a profit of Rs.25,950. The following paragraphs detail the trades done in the trading account of Venus & Gemini with the same modus operandi as discussed in the other examples discussed above. 83.1 Upon analysis of the evidence, it is prima facie observed that, before making the said recommendation on the news channel, the Noticee No. 1 had made many phone calls to Noticee No. 5 for placing buy orders in the scrip of GODREJCP. The summary of calls exchanged between Noticee No. 1 and Noticee No. 5 during the recommendation day (before and after the recommendation time of 13:35 PM), is tabulated in the below table: Table 80 Call details Time Instruction (On call) First Call 10:35 AM Buy GODREJCP Second Call 10:47 AM Buy GODREJCP Third Call 11:09 AM Buy GODREJCP* Fourth Call 11:33 AM Sell GODREJCP* Fifth Call ....
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.... with the contents of the transcript. The same is presented in the table below for reference: Table 81 Trade_Date Buy Trading Member Name Buy Client Name Buy Client PAN Buy Symbol Buy Instrume Buy Order Time Buy order Trade time Trade Quantity Trade Price 2022-09-13 RRB MASTER SECURITIES DELHI LTD. VENUS PORTFOLIOS PVT LTD AAACV4306R GODREJCP Fut 10:36:09 948 10:36:09 1000 947.9 2022-09-13 RRB MASTER SECURITIES DELHI LTD. VENUS PORTFOLIOS PVT LTD AAACV4306R GODREJCP Fut 10:36:09 948 10:36:09 1000 947.9 2022-09-13 RRB MASTER SECURITIES DELHI LTD. VENUS PORTFOLIOS PVT LTD AAACV4306R GODREJCP Fut 10:36:09 948 10:36:09 1000 948 2022-09-13 RRB MASTER SECURITIES DELHI LTD. VENUS PORTFOLIOS PVT LTD AAACV4306R GODREJCP Fut 10:36:09 948 10:36:09 2000 948 2022-09-13 RRB MASTER SECURITIES DELHI LTD. VENUS PORTFOLIOS PVT LTD AAACV4306R GODREJCP Fut 10:36:16 948 10:36:19 1000 948 TOTAL 6000 947.96 83.....
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....er log as obtained from NSE, it can be seen that, Rajiv Kapoor as instructed by Sanjiv Bhasin, placed buy orders in the account of Venus for 2000 shares each at Rs.944.55 and Rs.944.65 respectively. However, since the CMP was higher than the buy order limit price, the orders didn't get executed. The order details are furnished below: Table 83 Buy Order Date Buy Order Time Buy Client Name Buy Order no. Buy order original Vol Buy order limit price Buy LTP prior to order entry Buy LTP prior to order mod Trade no .* 13/09/2022 11:09:56 VENUS PORTFOLIOS PVT LTD 2500000016022320 2000 944.65 948 948 NULL 13/09/2022 11:10:01 VENUS PORTFOLIOS PVT LTD | 2500000016032540 2000 944.55 948 948 NULL *NULL - Indicates non-execution of trades 83.7 Transcript of 4th call at 11:33 AM on Sep 26, 2022 - Sell Side "Sanjiv Bhasin - Aawaj aa rahi hain, Rajiv Kapoor - aa rahi hain Sanjiv Bhasin - Godrej CP kya aa raha hain Rajiv Kapoor - 48.60 - 48.45 Sanjiv Bhasin - aur hamari kya average hain Rajiv Kapoor - 47.42 Sanjiv Bhasin - 49.25-30-35 main 10....
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.... on Sep 13, 2022 - Buy Side "Sanjiv Bhasin - kya hai Godrej Rajiv Kapoor - 46.50 - 47.40 Sanjiv Bhasin - Godrej niche kya bika hain Rajiv Kapoor - 943.80 Sanjiv Bhasin - Abhi kya hain 45 Rajiv Kapoor - Abhi hain 46.55 - 47.40 Sanjiv Bhasin - Aur spot main kya hain Rajiv Rajiv Kapoor - 944.50 - 945 Sanjiv Bhasin - Aur 46.5 kya bhav hain Rajiv Kapoor - Abhi Hanji 46.50 - 47.50 Sanjiv Bhasin - 44.65 aur 44.55 main 2000-2000 dal de" 83.11 From the above, it can be seen that Sanjiv Bhasin enquired the current market price of GODREJCP, to which Rajiv informed him that the share price is at Rs.944.50 - 945. Subsequently, Sanjiv Bhasin instructed Rajiv to place buy orders for 2000 shares at Rs.944.65 and another 2000 shares at Rs.944.55. As per the instructions of Sanjiv Bhasin, Rajiv Kapoor placed buy orders for 2 lots each at Rs.944.65 and Rs.944.55 respectively in the account of Gemini. The same can be confirmed from the trade data presented in the below table: Table 85 Trade_Date Buy Trading Member Name Buy Client Name Buy Client PAN Buy Symbol Buy Instrument....
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....Name Buy Order No. Buy Order Original Vol Buy Order Limit Price Buy LTP Prior to Order Entry Buy LTP Prior to Order Mod Trade No. 13/09/2022 12:15:34 VENUS PORTFOLIOS PVT LTD 2500000023453150 2000 943.55 945.35 945.35 NULL 83.14 Transcript of 8th call at 12:26 PM on Sep 13, 2022 - Buy Side "Sanjiv Bhasin - kya aaya Rajiv, Kitna aaya Rajiv Kapoor - 16000 Sanjiv Bhasin - Kya average hain Rajiv Kapoor - 46.24 Sanjiv Bhasin - Aur kya hain..." 83.15 From the above, it can be seen that Sanjiv Bhasin enquired from Rajiv about the total number of shares bought till now and the average price of the same. To which Rajiv informed Sanjiv Bhasin he had bought 16000 shares and the average buy price was Rs.946.24 per share. The same is confirmed with the trade log shown in the table below: Table 88 Trade_Date Buy Trading Member Name Buy Client Name Buy Client PAN Buy Symbol Buy Instrument Buy Order Time Buy order Price Trade time Trade Quantity Trade Price 2022-09-13 RRB MASTER SECURITIES DELHI LTD. VENUS PORTFOLIOS PVT LTD AAACV4306....
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....iv Kapoor - main dekh leta hu sir Sanjiv Bhasin - theek hai ok" 83.17 From the above, it can be seen that Sanjiv Bhasin instructed Rajiv to place sell orders for 2 lots each at Rs.947.20, Rs.947.30 and Rs.947.40 and also he enquired whether Rajiv had already placed one sell order for 1 lot at Rs.947. Further, Sanjiv Bhasin informed that once 7 lots are sold, place orders for 4 lots in the price range of Rs.947.80 - 947.90. From the transcript above, it is clear that Sanjiv Bhasin had instructed Rajiv to place sell orders for 13 lots (13000 shares) at various limit prices. Accordingly, from the order log data, it is evident that Rajiv Kapoor placed sell orders for 13000 shares at the afore-mentioned limit prices as instructed by Sanjiv Bhasin. Further, it can be seen that Rajiv Kapoor placed sell orders for 4000 more shares (3000 shares at Rs.947.90 and 1000 shares at Rs.947.40). However, since the current market price was lower than the sell order limit prices, the orders didn't get executed. NULL in the last column in the below table indicates that the orders didn't get executed: Table 89 Sell Order Date Sell Order Time Sell Client Name Sell Order ....
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....e table below: Table 90 Trade_Date Sell Trading Member Name Sell Client Name Sell Client PAN Sell Symbol Sell Instrume nt Sell Order Time Sell order Price Trade time Trade Quantity Trade Price 2022-09-13 RRB MASTER SECURITIES DELHI LTD. VENUS PORTFOLIOS PVT LTD AAACV4306R GODREJCP Fut 13:06:48 949 13:37:04 1000 949 2022-09-13 RRB MASTER SECURITIES DELHI LTD. VENUS PORTFOLIOS PVT LTD | AAACV4306R GODREJCP Fut 13:06:48 949 13:37:06 1000 949 2022-09-13 RRB MASTER SECURITIES DELHI LTD. VENUS PORTFOLIOS PVT LTD AAACV4306R GODREJCP Fut 13:06:48 949 13:37:06 1000 949 2022-09-13 RRB MASTER SECURITIES DELHI LTD. VENUS PORTFOLIOS PVT LTD AAACV4306R GODREJCP Fut 13:07:21 949.2 13:37:56 3000 949.2 83.20 Transcript of 11th call at 13:12 PM on Sep 13, 2022 - Sell Side "Sanjiv Bhasin - Ek bech de GodrejCP 46.25 main Rajiv Kapoor - Lagaya hain par bika nahi Sanjiv Bhasin - Cancel kar de yaar Rajiv Kapoor - kar diya Sanjiv Bhasin - Ab 46.50 par laga de 2 lot Rajiv Kapoor ....
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.... 83.24 Investigation also revealed that Leo Portfolios Pvt Ltd, an entity which is related/connected to Ashish Kapur, RRB Master Securities Delhi Ltd and Lalit Bhasin, was aware of the modus operandi of the trades of Sanjiv Bhasin. Upon perusal of the trade log obtained from NSE, it is observed that Leo Portfolios had also traded in the scrip GODREJCP on September 13, 2022 and made profit. 83.25 A brief analysis of all the entities trades based on such advance information of recommendations given by Sanjiv Bhasin is given below: Table 91 Analysis of trades carried out by the entities in the scrip "GODREJCP" Date and Recommendation time - Sept 13, 2022, 13:35 (Contract- GODREJCP22SEPFUT) Client Name PAN Buy (First Leg) Sell (Second Leg) Gross Trd. Vol to Mkt Vol. Scrip Trd Val. to all scrips trd val. Profit Rs. Order Time Trade Time Buy Price range Traded Quantity Total Value Traded Rs. Order Time Trade Time Sell Price range Traded Quantity Total Value Traded Rs. Gemini Portfolios Private Limited AAACG4847Q 12:01 - 12:02 12:15 944.65 4000 3778400 14:14 14:14 949.20 4000 3796800 ....
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....nce Rajiv Kapoor had placed the limit order for Leo at a price less than the sell order limit price of Venus, the sell order of Leo had got executed before the recommendation at a lesser selling price than that of Venus. 88. From the order placement analysis, it is inferred that entities executed their trades aiming to capitalize on the price-volume movement in the scrip/contract GODREJCP as a result of the recommendation made on the show by Noticee No. 1. 89. Accordingly, a total profit of Rs.27,200 was made by Noticees namely Venus, Gemini and Leo in the scrip of GODREJCP. G. OTHER TRADES INVOLVING SIMILAR MODUS OPERANDI 90. On sample basis, similar analysis was carried out for more than 100 instances during the Investigation Period, where corroborative evidence similar to what is detailed in above five illustations are available, and it is found that the Noticee No. 1 along with other Noticees, employed similar strategy in these other instances too and made huge profits. In addition, it was seen that there are thousands of instances where the buy recommendations by the Noticee No. 1 on Media Channels/Telegram were preceded by buy trade in the accounts of profit maker....
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....rivatives segment (stock futures) on positional trades, 1977 scrip days (22.68%) were matching trades. 93. The aforesaid matching trades have been further compared vis-à-vis total trades done by Noticees during the IP, based on Gross Traded Value ("GTV") (i.e. sum of buy and sell value on scrip days). The details of the same are tabulated in the table below: Table 93 Gross Trade Value* (GTV) of matching trades (In Rs.Crores) Entity Name Cash Stock Futures Intraday Positional Intraday Positional Total trades Matching trades Total trades Matching trades Total trades Matching trades Total trades Matching trades Gemini Portfolios Private Limited 2.52 0.44 33.16 0.52 170.78 101.79 398.89 53.20 HB Stockholdings Limited 29.46 8.66 421.73 27.81 1,030.10 511.33 2,516.83 306.84 Venus Portfolios Pvt. Ltd 2.87 2.64 17.99 0.68 4,532.63 2,750.60 3,125.72 1,212.18 Leo Portfolios Private Limited 16.08 8.01 47.16 1.45 712.90 470.84 59.43 8.85 Babita Gupta 1.70 0.97 2.07 0.21 497.95 323.74 8.36 4.10 Ashi....
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....he instructions of the Noticee No. 1 to different dealers of Noticee No. 4, as revealed from the transcripts, generating profit. During this time, some of Noticees also used the information to make profit in their own accounts. Noticee No. 1 98. The Noticee No. 1 was a Consultant/Director of IIFL during the investigation period. He was a guest expert appearing on various News Channels. He, prima facie was the mastermind of the alleged fraudulent scheme devised to generate profit. He used to make recommendations on media channels and social media platforms including telegram and internal platforms of IIFL. Before appearing on Media Channels, he would first create positions (majorly buy) in Gemini, Venus and HB Stock Holdings through Noticee Nos. 5 and 6, dealers of RRB Master. 99. Subsequently, he used to recommend majorly buy recommendations in certain scrips on TV Channels, which included those scrips in which he had already taken huge buy positions. Thereafter, contrary to his own buy recommendations given to the viewers en masse, he would give instructions to Noticee Nos. 5 and 6 to carry out opposite trades (sell). In his statement recorded under oath, the Noticee No. ....
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....icee No. 4, provided the required setup/infrastructure to Noticee No. 1 to run his alleged fraudulent scheme by placing orders in accounts of certain Profit Makers. Noticee Nos. 3 also misused the privy information, obtained directly/indirectly from Sanjiv Bhasin by virtue of Sanjiv Bhasin placing orders through the dealers of RRB Master and made profit in their own/associated person's accounts. 103. It may be noted that w.r.t. the orders being placed in the accounts of the Profit Makers by the dealers of Noticee No. 4, as per the instructions of the Noticee No. 1, Noticee No. 1 submitted the following during the statement recorded under oath: "Q.7 Did you meet authorized persons/ shareholders / Directors of/in Venus Portfolios Limited, Gemini Portfolios Limited, HB Stock Holdings Limited and RRB Master Securities Delhi Limited? A.7. I have met the authorized person; the details are below. 1. Venus Portfolios Limited- Mr. Raj Kumar Sharma and Mr. M.S. Sharma 2. Gemini Portfolios Limited- I don't recollect now 3. HB Stock Holdings Limited- Lalit Bhasin 4. RRB Master Securities Delhi Ltd- Ashish Kapur They were aware o....
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....Makers at the behest of Noticee No. 1, and Noticee Nos. 2 and 3 have acted as Enablers in the alleged scheme, aiding in generating profit based on placement of such contrary trades. Noticee Nos. 5, 6 and 7 108. Noticee Nos. 5 and 6, dealers of RRB Master, and Noticee No. 7, who was authorized signatory of Noticee No. 4 misused the privy information, obtained directly/indirectly from Noticee No. 1 by virtue of him giving instructions to Noticee Nos. 5, 6 and 7 while placing orders through them. Accordingly, by emulating the same trading strategy as that of Noticee No. 1, (i) Noticee Nos. 5 and 6 placed orders in their own trading accounts; (ii) Noticee No. 7 placed orders in the trading account of his wife Babita Gupta (Noticee No. 12) and made profits. 109. With respect to the BTST trades carried out by the Noticee No. 1, the Noticee No. 5 in his statement recorded under oath on June 13, 2024 stated that Lalit Bhasin had instructed him to place orders as per instructions of the Noticee No. 1 and he merely followed instructions of Sanjiv Bhasin. He further stated that when he used to handle the account of Venus and place orders, following instructions of Sanjiv Bhasin, ther....
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....l trades carried out by Noticees were analysed vis-a-vis the stock recommendations made by Sanjiv Bhasin in the Media channels/Telegram during the investigation period ranging from January 01, 2020 to June 12, 2024. Noticees have allegedly earned huge ill-gotten gains by manipulating the price/volume momentum driven by the recommendations of Noticee No. 1 on Media Channels. The alleged ill-gotten gains earned by Noticees are tabulated in the table below: Table 94 Sl. no. Name Positional Trades Intraday Trades Grand Total (in Rs.) Futures (in Rs.) Cash (in Rs.) Futures (in Rs.) Cash (in Rs.) 1 Gemini Portfolios Private Limited -26,36,495.83 38,043.45 78,699.90 52,89,788.45 27,70,036 2 Venus Portfolios Private Limited 51,69,756.93 5,31,386.43 2,24,911.50 5,72,70,843.60 6,31,96,898 3 HB Stockholdings Limited 80,58,897.99 56,31,985.01 17,32,352.70 88,14,561.90 2,42,37,798 4 Leo Portfolios Private Limited 44,668.75 1,23,895.38 4,56,368.60 59,40,600.25 65,65,533 5 Ashish Kapur 8,870.83 1,64,612.97 2,504.30 30,65,808.60 32,41,797 6 Babita Gupta -5....
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....ins the scrip details, dates of trades and the MTOM details, which is loss in the instant case. It is noted that on July 27, 2023, Sanjiv Bhasin bought 15000 quantities of SBILIFE AUG 2023 scrip in the future segment through HB, just prior to recommendations on IIFL Telegram Channel and sold 6000 quantities after the said recommendation. The remaining quantities of 9000 were unsold on July 28, 2023, which has been shown as outstanding with a Mark to Market value as on July 28, 2023. Date: July 28, 2023 Content: Sanjiv Bhasin texted Lalit Bhasin: "Mtm is wrong sbi life rate is 1305 not 993. Kindly send new mtm" Inference: Subsequent to forwarding of MOTM sheet dated July 28, 2023, Sanjiv Bhasin pointed out a discrepancy in Closing Price of scrip SBILIFE in FUTURE segment, which need to be corrected. Date: July 28, 2023 Content: Sanjiv Bhasin texted Lalit Bhasin: "Also ICICI Close is 993 and not 773" Inference: Additionally, Sanjiv Bhasin also pointed out another discrepancy in the scrip of ICICIBANK AUG 2023 in the future segment. Date: July 28, 2023 Content: Sanjiv Bhasin texted Lalit Bhasin: "Got the new one" Inference: Upon sharing ....
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....the above WhatsApp Chats between Sanjiv Bhasin and Lalit Bhasin, it is noted that there was maintenance of records of trades carried out in Cash Segment along with details of profits made in such trades. 115. Investigation has revealed that fund transfers used to happen amongst Noticees which has further been corroborated with evidence of meetings on the day of such fund transfers. It has been shown in the earlier paras that there was maintenance of records of trades carried out/open positions along with profits in both Cash Segment and Futures segment. Such records were shared between Sanjiv Bhasin and Lalit Bhasin regularly and also discussed amongst them for its accuracy on a regular basis. The following paragraphs illustrate date wise records of funds received by Sanjiv Bhasin from Lalit Bhasin and corroborated by evidence of their meeting on such dates, as extracted from the seized data. Table 97 Image of Records of funds received by Sanjiv Bhasin from Lalit Bhasin This image is a record of "Notes" saved by Sanjiv Bhasin in his phone. Contents of the image: Received (25 + 15 + 20+ 13.75 + 9.15 + 15.5 + 9.5 + 22.5 + 15 + 16 + 11.5 + 13.5 + 21.5 = Total 207.9) ....
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....sage from Sanjiv Bhasin, Lalit Bhasin thanked Sanjiv Bhasin. 2. Evidence of Meeting on Jan 09, 2024 As per the 'Notes' extracted from phone of Sanjiv Bhasin, it is observed that on this date, Sanjiv Bhasin had received amount of Rs.16.00 lacs from Lalit Bhasin. The following WhatsApp Chats exchanged between Sanjiv Bhasin and Lalit Bhasin indicates that they met on Jan 09,2024 at Connaught Place, Delhi. It is to be noted that registered offices of Venus, RRB Master and Leo are located at Connaught Place. Date: Jan 09, 2024 Content: Lalit Bhasin texted Sanjiv Bhasin - "I will leave by 06:30 - 06:45" Inference: On this day, Lalit Bhasin informed Sanjiv Bhasin that he would leave by 06:30 - 06.45. Date: Jan 09, 2024 Content: Sanjiv Bhasin texted Lalit Bhasin- "Ok " Inference: Sanjiv Bhasin acknowledged the message of Lalit Bhasin. Date: Jan 09, 2024 Content: Sanjiv Bhasin texted Lalit Bhasin - "Will make it by 5" Inference: As per the message of Lalit Bhasin of leaving early, Sanjiv Bhasin preponed the meeting time to 05 PM. Date: Jan 09, 2024 Content: Lalit Bhasin texted Sanjiv Bhasin: "Ok" Inference: Subsequently, Lali....
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....th Cash Segment and Future segments. Such records were shared between Sanjiv Bhasin and Lalit Bhasin regularly. These records were also verified and modified based on actuals as pointed out by Sanjiv Bhasin. The notes maintained by Sanjiv Bhasin collected during the investigation conclusively establish that Sanjiv Bhasin received funds from Lalit Bhasin during in person meetings mostly held at Connaught Place. 119. In view of the above, it is prima facie seen that the profit earned through trades being carried out by Sanjiv Bhasin through dealers of RRB Master in trading accounts of Venus, Gemini and HB was regularly being shared with him by Lalit Bhasin through non-banking/cash channels on several dates and the same is also corroborated by their meetings on those dates. J. EXAMINATION OF VIOLATION OF PROVISIONS OF THE SEBI ACT AND REGULATIONS MADE THEREUNDER 120. Having examined the matching trades executed in the accounts of Profit Makers, it become imperative, now to carry out further examination as to whether these acts on the part of Noticees can prima facie be held in violation of provisions of clauses (a), (b), (c) and (e) of section 12A of the Securities and Exchan....
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....ction 11, if after making or causing to be made an enquiry, the Board is satisfied that it is necessary,- (i) in the interest of investors, or orderly development of securities market; or (ii) to prevent the affairs of any intermediary or other persons referred to in section 12 being conducted in a manner detrimental to the interest of investors or securities market; or (iii) to secure the proper management of any such intermediary or person, it may issue such directions,- (a) to any person or class of persons referred to in section 12, or associated with the securities market; or (b) to any company in respect of matters specified in section 11A, as may be appropriate in the interests of investors in securities and the securities market. Explanation. - For the removal of doubts, it is hereby declared that the power to issue directions under this section shall include and always be deemed to have been included the power to direct any person, who made profit or averted loss by indulging in any transaction or activity in contravention of the provisions of this Act or regulations made thereunder, to disgorge an amount equivalent to ....
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....ponsible to, the company for the conduct of the business of the company, as well as the company, shall be deemed to be guilty of the contravention and shall be liable to be proceeded against and punished accordingly: Provided that nothing contained in this sub-section shall render any such person liable to any punishment provided in this Act, if he proves that the contravention was committed without his knowledge or that he had exercised all due diligence to prevent the commission of such contravention. (2) Notwithstanding anything contained in sub-section (1), where an contravention under this Act has been committed by a company and it is proved that the contravention has been committed with the consent or connivance of, or is attributable to any neglect on the part of, any director, manager, secretary or other officer of the company, such director, manager, secretary or other officer shall also be deemed to be guilty of the contravention and shall be liable to be proceeded against and punished accordingly. Explanation.- For the purposes of this section,- (a) "company" means any body corporate and includes a firm or other association of individu....
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....r sale of any security listed or proposed to be listed in a recognized stock exchange, any manipulative or deceptive device or contrivance in contravention of the provisions of the Act or the rules or the regulations made thereunder; (c) employ any device, scheme or artifice to defraud in connection with dealing in or issue of securities which are listed or proposed to be listed on a recognized stock exchange; (d) engage in any act, practice, course of business which operates or would operate as fraud or deceit upon any person in connection with any dealing in or issue of securities which are listed or proposed to be listed on a recognized stock exchange in contravention of the provisions of the Act or the rules and the regulations made thereunder. Prohibition of manipulative, fraudulent and unfair trade practices Regulation 4 (1) Without prejudice to the provisions of regulation 3, no person shall indulge in a manipulative, fraudulent or an unfair trade practice in securities markets. Explanation. - For the removal of doubts, it is clarified that- (i) any act of diversion, misutilisation or siphoning off of assets or e....
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....bit the person concerned from disposing of any of the securities acquired in contravention of these regulations; (h) direct the person concerned to dispose of any such securities acquired in contravention of these regulations, in such manner as the Board may deem fit, for restoring the status quo ante; SEBI (Research Analyst) Regulations, 2014 Regulation 2(1) (c) "associate" means an associate as defined in Securities and Exchange Board of India (Intermediaries)Regulations, 2008; (u) "research analyst" means a person who is primarily responsible for,- i. preparation or publication of the content of the research report; or ii. providing research report; or iii. making 'buy/sell/hold' recommendation; or iv. giving price target; or v. offering an opinion concerning public offer, with respect to securities that are listed or to be listed in a stock exchange, whether or not any such person has the job title of 'research analyst' and includes any other entities engaged in issuance of research report or research analysis. Explanation.- The term also includes any associated pe....
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....FUTP Regulations quoted above, prohibit: i. dealing in securities which is manipulative, fraudulent or an unfair trade practice; ii. use of or employment of any manipulative or deceptive device or contrivance, in contravention of the provisions of the SEBI Act or rules or regulations made thereunder; iii. employment of any device scheme or artifice to defraud; iv. engagement in any act, practice, course of business which operate/would operate as fraud or deceit upon any person in contravention of the provisions of the SEBI Act or rules or regulations; or v. dealing in securities while in possession of material or non-public information or communicate such material or non-public information to any other person in contravention of the provisions of the SEBI Act or rules or regulations made thereunder. 122. In the earlier part of this Order, it has been examined and demonstrated with evidence that how Noticees devised/employed a scheme wherein positions (mostly buy) were created in scrips prior to recommendations and as per the instructions of the Noticee No. 1 to dealers. The information regarding the scrip to be recommended was a mater....
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....actice may be unfair, if the conduct undermines the good faith dealings involved in the transaction. Moreover, the concept of 'unfairness' appears to be broader than and includes the concept of 'deception' or 'fraud'. .....Coupled with the above, is the fact, the said conduct can also be construed to be an act of unfair trade practice, which though not a defined expression, has to be understood comprehensively to include any act beyond a fair conduct of business including the business in sale and purchase of securities." 125. In the instant case also, it can be seen that the conduct of Noticees cannot be said to be in conformity with the ethical standards and good faith dealings between Guest Expert and the investors. Investors who follow Guest Expert's advice could not have believed that the recommendations are made not on the basis of research but on the basis of malafide intention of making profit in own accounts by increasing volume and price through the recommendations. The Noticees prima facie devised a manipulative practice which has been further corroborated by transcripts between the Noticee No. 1 and dealers while placing orders in the trading accounts of Profit Makers....
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.... and the Noticee No. 1 was associated with IIFL and used to make stock recommendations by making public appearances in the Media channels. In terms of clause (u) of sub-regulation (1) of regulation (2) of the RA Regulations, the Noticee No. 1 falls under the definition of a Research Analyst. Sub-regulation (2) of regulation 16 of the RA Regulations restricts dealing/trading in the securities by an associate of Research Analyst in the recommended scrips for a specified time period. Further sub-regulation (2) of regulation (21) of the RA Regulations provides that the research analyst shall disclose his name, registration status and details of financial interest in the subject company at the time of making such recommendation or communicating the substance of research report through the public media. As brought out hereinabove in various examples, investigation revealed that the Noticee No. 1 had dealt in the scrips, by placing orders through instructions to dealers of the Noticee No. 4, which he had earlier recommended through public appearances, within the time stipulated in sub-regulation (2) of regulation 16 of the RA Regulations, thereby violating the same. 130. It is therefor....
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....me of contravention by these companies and in charge of and responsible for the conduct of their business. Further, Noticee No. 2 was an Executive Director in HB and managed day to day affairs of HB. Noticee No. 2 was also Director of RRB Master and played an active role in the manipulation. The details of role played by Noticee No. 2 in the matter have been elaborated in the preceding paras of this Order. Hence, he is prima facie liable for the contraventions committed by Venus, Gemini, HB and RRB Master. Ashish Kapur (Noticee No. 3) i. Director in Leo Portfolios Pvt. Ltd. ii. Managing Director in RRB Master Yes Noticee No. 3 was the Managing Director of RRB Master. Noticee No. 3 had authorised dealers of Noticee No. 4 to place trades in trading accounts of Venus and Gemini as per instructions of Noticee No. 1. Further, Noticee No. 3 was the authorised signatory for placing orders in the trading account of Leo with RRB Master. Hence, he is prima facie liable for the contraventions committed by RRB Master and Leo. Megh Shyam Sharma Independent Director in in Venus Portfolios Pvt. Ltd. No These individuals were Directors of Venus during the perio....
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....he dealers of RRB Master on the basis of recommendations given by Sanjiv Bhasin were immediately reversed by the dealers as soon as the views of such recommendations were aired on the Media Channels, and huge profits were made at the cost of gullible investors driving the price/volume believing the recommendations to be genuine and true. 137. If such fraudulent/manipulative trade practices are not looked down upon by the Regulator of the capital markets, proper message would not go to violators and the faith of investors would be shaken. Thus, it becomes imperative that through interim orders such as the instant one, deterrence is created in the mind of violators to avoid adopting such strategies. At the same time, there is a message required to be given that the regulator is watchful of all such unlawful activities. These steps are essential to ensure that trust of investors is maintained. 138. One of the primary duties that has been cast upon SEBI as per provisions of the SEBI Act, 1992 is to protect interests of the investors in the securities markets. In my view, that objective can only be achieved by keeping the securities markets, a level playing field for everyone. No ....
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....ns mentioned earlier deal with the situations where a person, who deals in securities, takes advantage of the impact of an action, may be manipulative, on the anticipated impact on the market resulting in the "creation of artificiality'." 141. In the matter of SEBI vs Rakhi Trading Pvt. Ltd., and other connected appeals decided on February 08, 2018, the Hon'ble Supreme Court observed that "... market manipulation is a deliberate attempt to interfere with the free and fair operation of the market and create artificial, false or misleading appearances with respect to the price, market, product, security and currency". 142. In view the above discussion, I am of the view that it is a fit case to pass an interim ex parte order to insulate the securities market from the mischievous acts of Noticees and also to prevent these Noticees in conducting similar activities which are prima facie against the interest of investors as well as against the development of securities market. Further, there is an urgency to protect the unlawful gains from getting siphoned off beyond the regulatory reach. Further, this interim order would also send a message to the market participants that the regul....
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....e actually been made by Noticees by incorporating fraudulent strategies and placing trades on the advice of Noticee No. 1 contrary to recommendations given by him on Media Channels. 146. In view of the aforesaid discussion and the calculation of unlawful gains made by Noticees as detailed in Table 94 above, I hold Noticees to be prima facie jointly and severally liable for impounding of unlawful gains as detailed in the following table. In this table, joint and several liability is calculated based on the role played by each Noticee with respect to profit made in various accounts. To illustrate, Sanjiv Bhasin is jointly and severally liable for profit in accounts of Noticee Nos. 8 to 10 but not in others as profit in these accounts was earned using his information but without his knowledge. Table 100 S. No. Profit Maker / Enabler/ Beneficiary / Information misuser (A) Amount of wrongful gains made (Rs.) (B) Noticees jointly and severally liable for impounding of wrongful gains (C) 1 Ashish Kapur (Noticee No. 3) 32,41,797 Ashish Kapur 2 Rajiv Kapoor (Noticee No. 5) 15,33,848 Rajiv Kapoor 3 Jagat Singh (Noticee No. 6) 89,53,370 Ja....
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....lly liable for the impounding of unlawful gains made by them as per the aforesaid Table. N. INTERIM ORDER 149. Thus, after analysing all evidences on record, I hold that this is a fit case to exercise powers of passing interim order so as to insulate the securities market and to protect the unlawful gains from being dissipated further, which may go beyond the regulatory reach. Accordingly, I, in exercise of the powers conferred upon me under sub-section (1) of section 11, sub-section (4) of section 11, sub-section (1) of section 11B read with section 19 of the SEBI Act read with regulation 11 of the PFUTP Regulations, hereby by way of the present interim order cum show cause notice, issue the following directions, which shall remain in force until further orders: i. An amount of Rs.11,37,19,170/- (Rupees eleven crores thirty-seven lacs nineteen thousand one hundred and seventy only), being the total amount of unlawful gains earned from the alleged violations, shall be impounded, jointly and severally in the manner as provided in Table 100 and Noticees are directed to open fixed deposit account(s) in a Scheduled Commercial Bank to credit/deposit jointly and severally ....
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....) except with the prior permission of SEBI. ix. Noticees are further directed to provide a full inventory of all their assets whether movable or immovable, or any interest or investment or charge in any of such assets, including property, details of all their bank accounts, demat accounts, holdings of shares/securities if held in physical form and mutual fund investments and details of companies in which they hold substantial or controlling interest immediately but not later than 15 days of this Order. x. The directions stipulated in clauses (ii), (iv), (v), (vi), (vii) and (viii) shall cease to apply upon crediting of the impounding amount to the fixed deposit account(s) as per clause (i). xi. If the Noticees have any open position(s) in any exchange traded derivative contracts, as on the date of this Interim order, they can close out/square off such open positions within 3 months from the date of order or at the expiry of such contracts, whichever is earlier. The Noticees are permitted to settle the pay-in and pay-out obligations in respect of transactions, if any, which have taken place before the close of trading on the date of this order. Banks are a....
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....Rajiv Babita 1 Husband and Wife Dealers, RRB HB Cousin Brothers @ $ Praveen 1 broker Controlling Shareholders & Director RRB, Broker Auth. Signatory for Bank A/c MD Largest Shareholder & Director Brother & Sister Places Trades Leo Clients, RRB Ashish, MD, RRB Lalit Mamta Controlling Shareholders Husband- Wife Document 2 × Local Backups Model : iPhone 14 Pro I as Text = fi as csv = & as PDF - 8 as HTML . a 13 Thursday, Cục 7, 2003 19:30 00/08/2024 2,50,000 JP Power bought (2 14.17 Thursday, Dec 7, 2003 20 56 06/07/2024 Caught in high fever .. Will not be able to attend office 06/07/2024 Oh ok get well soon ashish sir MG_9064 Inform sanjiv ji Will message to Sangy ji and pandey to reach on time 06/07-2024 Friday, Äá»c 8, 2023 08:36 Sell box 77800 call @] 6.75mg How r u feeling jaggu ? 200/778 threads 277 messages 430.33 Document 3 mirist PerSPCDCSVRRACOR 2019- WindowsRCP × Backup Viewer - Free Local Backups Unique ID : 00008120-0011456121E8401E & as Text - D as CSV - as PDF . 5 as HTML - Thu....
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....0.00 5650.00 5660.00 5670.00 5680.00 5690.00 13:18:00 13:19:00 Vol_BSE 13:20:00 13:21:00 13:22:00 13:23:00 Time Recommendation 13:24:00 - Vol_NSE 13:25:00 13:33 13:26:00 13:27:00 13:28:00 13:29:00 13:30:00 Vol_FF 13:31:00 13:32:00 - 13:33:00 . 13:34:00 13:35:00 Close_BSE 13:36:00 13:37:00 13:38:00 - 13:39:00 - 13:40:00 - 13:41:00 13:42:00 13:43:00 Close_NSE 13:44:00 13:45:00 13:46:00 13:47:00 -Close_FF 13:48:00 18000.00 16000.00 14000.00 12000.00 10000.00 8000.00 6000.00 0.00 2000.00 4000.00 Document 7 IIFL Capital Research 62.4K subscribers € 3712.45 February 7. 2024 , @ 1 IK HEL Securities Research, 1933 NIFTY 08 Feb 2024 PE 22000 SL hit @ 177. Exit Trade 7 @ 14.2K HEL Securities Research, 11:38 Jana Small Finance Bank RHP_edited.pdf 287.0 KR PDF Jana Small Finance Bank IPO Note 11.AK IIFL Advice, edited 12)06 HIFL Capital Research Exit Now! Book profit in SBIN now @ 673 10 8 @ 13.7K HEL Securities Research9, 72156 IIFL Capital Research Buy PARAGMILK @ 210-220 ....
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.... @s whats 2/7/2024 2/7/2024 app.net Lalit bhasin 2 11:50:53 11:57:23 AM(UTC+5:30) AM(UTC +5:30) Sluluk: Raad Plutoem: Mobile 2/7/2024 11:50:52 AM(UTC+5:30) Document 14 From: Öyster Message System Message w.whatsapp.nel owner) started a cal. sanjiv bhasin status: Answered type: audio call duration: 00:00:16 2 joined: sanjiv bhasin Lait bhasin 2 Bo whatsapp.net owner) Ps. whatsapp.net) 2/7/2024 3:0 7:09 PM(UTC+5:30) Document 15 @w.whatsapp.net Lalit bhasin 2 From: Sold 25000 Parag milk at 234.85 mkt Dibus: Read Platfome Mobile 2/7/2024 3:16:45 PM(UTC+5:30) Document 16 From: System Message System Message sanjiv bhasin status: Answers type: audio call duration: 00:00:30 2 joined: sanjv bhasin @hs.whatsapp.net owner) started a cail. @s.whatsapp.net owner) tbs.whatsapp.net) Lait bhasin Pallone Mobile 2/7/2024 3:17:19 PM(UTC+5:30) @s. whatsapp,nol Luft bhasin 2 Total 51500 Parag sold at 235.45 mkt 2/7/2024 3:30:06 PM(UTC+5:30) O Document 17 @s.whatsapp.net sanjy bhasin (owner) s.whatsapp.net Lilit bhasin 2 To From: Now 1.22 or is my cash Participant Delivered Read Played B's whats app.not Lall....
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....ol_BSE Vol_NSE Vol_FF - . Close_BSE - - - Close_NSE -Close_FF Vol_BSE Document 22 INDIGO24FEBFUT Jan 29 2024-Jan 30, 2024 Jan 30, 2024 Sell - 4800 QTY 11:54:58-12:11:28 Jan 30, 2024 Sell - 4200 QTY 09:15:00-09:18:35 Jan 29, 2024 Buy - 9900 QTY 13:08:39-13:11:48 50000 No. of Shares 40000 30000 Jan 30, 2024 Sell - 900 QTY 10:15:41 Buy Recommendation at 08:52 AM on Jan 30 7074 2900 20000 2060 25/01/222413:38:2 29/01/2:241112:00 29/01/222413.06:00 12:20:00 12:53:31 2200 30/01/2409 4 3 1:2410 2/10/62 2/10/64 2/10/6 E/ID/CE O/ID/CE T/ID/CE 2/10/0 4/10/0 0/100 traded_Quantity -tlow_prica Document 23 @s.whatsapp.net sanjiv bhasin (owner) whatsapp.net Jagat Yadav From: To Kindly send screenshot Participant Delivered Read Played Is whats 1/29/2024 1/29/202 app.net Jagat Yadav 3:36:29 4 PM(UTC+5:30) 3:36:51 PM(UTC +5:30) Status: Read Platform: Mobile 1/29/2024 3:36:28 PM(UTC+5:30) Document 24 @s.whatsapp.net Jagat Yadav From Attachments: Size: 41727 Path: https://mmg. whatsapp.net/of/wt62.7118-24/11/m238/up-oil-image-c4d1914....
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.....4 O 81.2 10:08:00 -Close_FF 9:53:00 - 9:54:00 . 9:55:00 - 9:57:00 Close_BSE 9:59:00 = 10:01:00 = 10:02:00 Close_NSE 10:03:00 9:46:00 Vol_NSE 9:49:00 9:51:00 Vol_FF 9:41:00 Vol_BSE Vol_NSE Vol_FF - . - Close_BSE = = Close_NSE -Close_FF Vol_BSE Document 31 Zee Business LIVE 13th September 2022 | Business & Financial News | Share Bazaar | Anil Singhvi ZEEBUSINESS 13:35 à¤à¤¸à¥€à¤¨ केहसीन शेयर à¤à¤¸à¥€à¤¨ केहसीन शेयर Godrej Cons Fut Nureca Ltd खरीदें खरीदें PRICE 948.30 PRICE 1009.40 TARGET 1020 TARGET 1400 STOP LOSS 925 STOP LOSS BUZZING STOCK aiwan Rallis India 14887.65 237.80 +9.80 80.22 Dollar Index Prestige Est 5 50 0.3m 2642.50 10 92.80 1 108.05 0 85 425 70 0.29 Z T Scroll for details 6:41:30 / 8:57:59 + CC V Document 32 938 940 942 944 946 948 950 952 13:20 13:21 13:22 Vol_BSE 13:23 Ti....
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....7 @s.whatsapp.net sanjiv bhasin (owner) @s.whatsapp.net Lalit bhasin 2 From: To: Got the new one Participant Delivered Read Played @s.whats 7/28/2023 7/28/202 app.net Lalit bhasin 2 6:30:41 3 PM(UTC+5:30) 6:30:44 PM(UTC +5:30) Status: Read Platform: Mobile 7/28/2023 6:30:39 PM(UTC+5:30) Document 38 @s.whatsapp.net Lalit bhasin 2 From: Ok great Platform: Mobile 7/28/2023 6:30:49 PM(UTC+5:30) Document 39 @s.whatsapp.net sanjiv bhasin (owner) @s.whatsapp.net Lalit bhasin 2 From: To: Rawat has not included Vodafone buy/sell in cash sheet Participant Delivered Read Played @s.whatsapp. net Lalit bhasin 2 1/10/2024 1/10/2024 10:45:02 11:05:16 AM(UTC+5:30) AM(UTC+ 5:30) @s.whatsapp. net Lalit bhasin 2 Status: Read Platform: Mobile 1/10/2024 10:44:59 AM(UTC+5:30) Document 40 @s.whatsapp.net sanjiv bhasin (owner) .whatsapp.net Lalit bhasin 2 From To: Attachments: Size: 131442 File name: 9d9d1c11-6bd9-4d74-aea8-6b99a79eefea.jpg Path: https://mmg.whatsapp.net/v/162.7118 24/24268322_28518837418637 3 341973524118178325_n.enc?ccb= 11- 4&oh=01_AdR8cQEWfvqrgn34u_RW8BOMORNGHLD131888Mor77jSZQ&00=65C58 CFE....
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....eptember 13.75 received 11th November 9.15 received February 15.5 received 26th April 2023 9.5 received 12th may 2023 22.5 received August 2023 15 received 7th October 2023 16 received 9th January 2024 11.5 received 26th February 2024 13.5 received 18th March 2024 21.5 received 18th May 2024 Document 43 @s.whatsapp.net sanjiv bhasin (owner) @s.whatsapp.net Lalit bhasin 2 From To: See you today evening around 6 in cp Participant Delivered Read Played @s.whats 11/11/2022 11/11/20 app.net Lalit bhasin 2 10:45:04 22 AM(UTC+5:30) 10:51:19 AM(UTC +5:30) Status: Read Platform: Mobile 11/11/2022 10:45:03 AM(UTC+5:30) Document 44 @s.whatsapp.net Lalit bhasin 2 From: Hi request to pl meet at 5 or 5.30 as hv to leave a litle early. Platform: Mobile 11/11/2022 10:51:58 AM(UTC+5:30) Document 45 @s.whatsapp.net sanjiv bhasin (owner) ps.whatsapp.net Lalit bhasin 2 From To: Ok 5. Participant Delivered Read Played @s.whats 11/11/2022 11/11/20 app.net Lalit bhasin 2 11:05:47 22 AM(UTC+5:30) 11:06:06 AM(UTC +5:30) Status: Read Platform: Mobile 11/11/2022 11:05:45 AM(UTC+5:30) Document 46 @s.whatsa....