K.M. Abraham, Member

1. There were several media reports on December 21 and 22, 2008 that Securities and Exchange Board of India (hereinafter referred to as SEBI) had ordered Shri P.S. Saminathan, one of the promoters of M/s. Pyramid Saimira Theatre Limited (herein after referred as PSTL), to make an open offer under the Securities and Exchange Board of India (Substantial Acquisition of Shares and Takeovers) Regulations, 1997 (herein after referred to as SEBI (SAST) Regulations, 1997) for an additional 20% stake, at a price not less than Rs 250/- within 14 days, for allegedly violating creeping acquisition norms.

2. With the reports in the media appearing about the impending offer at Rs 250/-, the shares of the company shot up on Monday morning i.e. December 22, 2008, when the stock markets opened for the day. On the same day, PSTL first informed the exchanges Bombay Stock Exchange Limited (herein after referred to as BSE) and National Stock Exchange of India Limited (herein after referred to as NSE) in the morning that the company had not received any communication from SEBI regarding the media reports on Open Offer. Subsequently, PSTL received the said order at around 10.30 a.m. on the same day i.e. December 22, 2008, when the courier company Blue Dart delivered the purported SEBI letter to the company. Shri Saminathan informed BSE and NSE on December 23, 2008 about the receipt of the letter from SEBI. On December 23, 2008, SEBI too issued Press Release clarifying that no order or letter has been issued by SEBI to Shri P.S. Saminathan on December 19, 2008 and it appears that the said letter is being circulated with ulterior motives.

3. On a careful examination of the letter purported to have been sent by SEBI to Shri Saminathan, it was found that no such letter had been issued by SEBI. This letter clearly, therefore, has been forged. Further, on perusal of the said letter, it was found that the letter was dispatched through Blue Dart Couriers. The courier company revealed that they had been instructed by the person who had handed over the purported letter NOT to deliver the letter on Saturday to PSTL and to deliver it ONLY on Monday - the December 22, 2008.

4. It was further gathered that one Rakesh Sharma, then an executive with M/s. Adfactors PR Pvt. Ltd., was responsible in forwarding the letter that was sent to Shri P.S. Saminathan, CMD of PSTL. Further, the Company Secretary of PSTL also faxed to SEBI a copy of the other letter purportedly issued by SEBI, also dated December 19, 2008, that was addressed to Shri Nirmal Kotecha, HNI and a part of the promoter group, at his residential address at 601, Sukh Niwas, Bhandarkar Road, Matunga, Mumbai - 400019. Though, Shri Nirmal Kotecha later claimed in his statement to SEBI that the said purported letter was received at his residence by his wife on Saturday, (December 20th, 2008) through courier, he stated that his wife was unable to recollect the name of the courier who delivered the letter. The said letter sought details about Shri Nirmal Kotechas acquisitions in the company, his relationship with Shri Saminathan and Shri N.C.Ravichandran, agreement entered into with Shri Saminathan, if any, for the interse transfer of shares, copies of his bank accounts and demat statements for the period January 2007 till December 2008, advances made to the company, if any, and details of his networth certificate and IT Returns for the period 2006-97 and 2007-08 to be furnished within 14 days period. The original letter was later received from Shri Nirmal Kotecha. Though he claimed that the letter was received through a courier at his residence, he could not produce the cover enclosing the letter, nor name the courier agency through which the same was received.

5. SEBI, thus, prima facie found that communications on letter head and stationary styled on the pattern of the official SEBI stationary were sent to two promoters of the company. These were intended to convey the impression that SEBI has issued such communication. Hence, an FIR was registered with the BKC Police Station on January 01, 2009 in the matter of forgery of SEBI communications, for action under the relevant provisions of law. Subsequent to the lodging of FIR, it also prima facie appeared that the forgery was done to manipulate the price of PSTL shares and that Shri Nirmal Kotecha was one of the major beneficiaries of the said manipulation exercise. Therefore, an Investigating Authority was appointed to investigate into the market manipulation, which in this case, appeared to be linked to the forged SEBI letters.

6. From the interim Investigation Report submitted to me, I note that in NSE, the scrip opened on December 22, 2008 at Rs. 83, a rise of 10% from the previous days closing price of Rs. 75.45, before closing at Rs. 67.90, a fall of 10% on close to close basis. Similar trend was seen on BSE on that day. A total of 40,29,254 shares were traded on this date in NSE, representing a rise of 310.03% over the previous date. Similar trading pattern was observed in BSE as well.

7. On BSE, based on the intraday price movement on December 22, 2008, transactions in three time slots viz. (between 09:55:00 am and 10:28:04 am, 10.28.05 a.m. and 12:16:33 pm and between 12.16.34 p.m. and the end of the day) were analysed:

a. Patch I: (9:55 a.m. and 10:28:04 a.m) On BSE, the denial by the company was put out at 10.28:04. The scrip opened at Rs. 82.90 and decreased to Rs. 79.60 at 10:28:04 i.e. prior to the denial by the company of the letter purportedly issued by SEBI. The total traded quantity during this patch was 23,22,338 shares It was observed that trading member, M/s. Wallfort Financial Services Ltd. dealing on its own account was the highest net purchaser for 25,000 shares at an average price of Rs. 82.64 per share whereas the highest net seller was Shri Nirmal Kotecha dealing through trading members, Kotak Securities Ltd. and IL&FS Investsmart Ltd., who sold 2,25,444 shares at an average price of Rs. 81.02.

b. Patch II: (10.28.05 a.m. and 12:16:33 p.m) After the denial by the company, the price fell from Rs. 79.60 to Rs. 74.10 at 12.16.33 p.m. The total traded quantity during this patch was 24,84,862 shares. It was observed that M/s. Mumbai Stock Broking Pvt. Ltd. (Ratna Bhatia), dealing through the trading member, M/s. Joindre Capital Services Ltd. was the highest net purchaser for 7,500 shares at an average price of Rs. 76.96 whereas the highest net seller was Shri Nirmal Kotecha, dealing through the trading members, IL&FS Investsmart Ltd. and M/s. India Capital Markets Pvt. Ltd., who sold 67,983 shares at an average rate of Rs. 76.

c. Patch III: (12.16.34 p.m. till the end of the day) During this period, the price decreased from Rs. 74.10 to Rs. 67.90, its intra-day low. The total traded quantity during this patch was 15,97,236 shares. It was observed that M/s. Amisha Developers Ltd. (Amar Shah), dealing through the trading member, M/s. Goldmine Stocks Pvt. Ltd. was the highest net purchaser for 50,000 shares at an average price of Rs. 68.00 whereas the highest net seller was Shri Nirmal Kotecha dealing through the trading members, M/s. JM Financial Services Pvt. Ltd., M/s. Indiabulls Securities Ltd. and M/s. India Capital Markets Pvt. Ltd. who sold 3,71,768 shares at an average rate of Rs. 68.36.

8. On NSE, based on the intraday price movement on December 22, 2008, transactions in three time slots (viz. between 09:55:00 am and 10:37:00 am, 10:37:01 am and 12:25:00 pm and between 12:25:01 pm to 15:30:00 pm) were analysed:

a. In the first time slot (Price Movement: Rs. 83 to Rs. 77.50), M/s. Escort Opportunities was the top net buyer with net buy of 1 lac shares accounting for 9.48% to market (net). Shri Nirmal Kotecha trading through 4 Trading members was the top net seller and has net sold 4.45 lac shares and accounted for 39.87% to market (net).

b. In the second time slot (Price Movement: Rs. 77.50 to Rs. 67.90), M/s. Meet Shares and Stocks was the top net buyer with net buy of 0.32 lac shares accounting for 6.05% to market (net). Shri Nirmal Kotecha trading through 3 Trading members was the top net seller and sold 3.45 lac shares (net) and accounted for 66.20% to market (net).

c. In the third time slot, when the scrip hit the lower circuit, M/s. Regent Finance Corporation was the top net buyer with net buy of 0.25 lac shares accounting for 10.67% to market net. Shri Nirmal Kotecha trading through 2 Trading members was the top net seller and has net sold 0.51 lac shares and accounted for 66.20% to market (net).

9. From the above, I note that Shri Nirmal Kotecha, a HNI and a part of the then promoter group, was a major seller in the PSTL scrip on December 22, 2008, having sold 15,05,862 shares on market at an average price of Rs. 75.85 per share on that day. It is seen that out of the same, he sold 6,69,611 shares on BSE and NSE at an average rate of Rs. 80.92 per share on December 22, 2008, before Shri Saminathan denied receipt of the purported SEBI letter that morning.

10. I further observe from the interim Investigation Report that Shri Deepak Thakkar, who is the maternal uncle of Shri Nirmal Kotecha, bought 19,758 shares, 80,000 shares and 85 PSTL shares on December 16, 2008, December, 17, 2008 and December 22, 2008 respectively and sold 99,843 PSTL shares on December 22, 2008. The purchase price was in the range of Rs. 53.96 and Rs. 62.04 and only 85 shares were bought by Shri Deepak Thakkar at Rs. 80.49 on December 22, 2008. The sale price was in the range of Rs. 80.10 to Rs. 82.30. I find that Shri Deepak Thakkar, in the bargain, has made a profit of Rs. 20,76,064 from the said transaction.

11. I further note that the purchases by Shri Deepak Thakkar were just prior to the publication of the news about the forged SEBI open offer letter that was sent to Shri P S Saminathan on December 19, 2008. The sale of shares by Shri Thakkar were again prior to the announcement by Shri Saminathan denying the open offer, on the morning of December 22, 2008. I further note that the buy and sell instructions to the broker on Shri Thakkars behalf were given by Shri Nirmal Kotecha.

12. From the interim Investigation Report placed before me, I further find that the bank trail of Shri Nirmal Kotecha and his related/ associated persons/ entities has revealed details of certain persons/ entities through whom he had routed funds. Prima facie, it appears that this was done to disguise the trail of his trading. I find that on November 19, 2008, Rs. 15 lacs were transferred from the account of M/s. Nirman Management Services Pvt. Ltd. (herein after referred to as Nirman), one of the companies of Shri Nirmal Kotecha, to Shri Deepak Thakkars account. On December 02, 2008, I again find that Rs. 15 lacs were transferred by Shri Nirmal Kotecha from his account to the account of Nirman, and from there, this amount was transferred to the account of Shri Deepak Thakkar on December 04, 2008. Subsequently, I find that on December 16, 2008, Shri Deepak Thakkar, in turn, has transferred Rs. 25 lacs to his client account held with M/s. Kotak Securities Ltd. (herein after referred as Kotak). I further find that Shri Deepak Thakkar had bought 19,758 shares of PSTL on December 16, 2008 and 80,000 shares on December 17, 2008 through Kotak. I observe that the buy orders in Shri Deepak Thakkars account were placed by his representative Shri Nirmal Kotecha. The pay-in of the funds for shares bought on December 16, 2008 was due on December 18, 2008. On that day, Shri Thakkar had a credit balance of Rs. 19,84,225.05 in his account after adjusting Rs. 25 lacs transferred to his client account with Kotak. The pay-in of the funds for shares bought on December 17, 2008 was due on December 19, 2008. However, Shri Thakkar did not make any further payment on December 19, 2008, and as a result, there was an outstanding debit of Rs. 35,15,874.82 in the account of Shri Thakkar as on December 19, 2008. Instead of bringing in the funds, I observe that Shri Nirmal Kotecha had in the morning of December 22, 2008, instructed Shri Thakkars broker to sell the shares of PSTL lying in the account of Shri Deepak Thakkar.

13. Further, from the interim investigation report, I find that though Shri Nirmal Kotecha claimed that mobile number 9819988816 belonged to him, I note that the investigation has revealed that the mobile number 9819988816 is actually registered in the name of Shri Amol Anand Kokane, 24 (resident of 622/B, Kushaba Kale Chawl, N.M. Joshi Marg, Byculla, Mumbai - 400027). I further note that Shri Amol Kokane has claimed that he is a student of Engineering College at Navi Mumbai and that he did not have any personal income. He claimed to have opened an account with the broker M/s. India Capital Markets Pvt. Ltd. on the recommendation of his late brother-in-law, Shri Sandeep Shripati Gavhane, who worked as an accountant with M/s. Kotecha Capital Services Pvt. Ltd. In his statement, I find that Shri Amol Kokane has also claimed that his brother-in-law was operating that account for his boss Shri Nirmal Kotecha and that he used to take his signatures on forms and documents. I note that Shri Kokane has also claimed that he does not have any idea about the share market, that he has never visited the brokers office, and had never given any order (buy or sell) to the broker. Further, I note that he has also claimed that his account was being operated by his brother-in-law, till his brother-in-law met with an accident on October 16, 2008 and had to be hospitalized. Further, after the death of his brother-in-law on November 01, 2008, Shri Kokane avers that Shri Nirmal Kotecha was operating all his accounts. Shri Kokane claimed that Shri Nirmal Kotecha used to send one Shri Anil to get his signature affixed on the cheque book and the Depository Instruction Slip (herein after referred to as DIS) and that he had signed as many as 8-10 blank cheque leaves and full DIS.

14. I further also note that cash payments as high as Rs. 40,000 in a month, has been made towards charges incurred on the aforesaid mobile number. The details of the monthly charges incurred on the said mobile number and the cash payments made are at Annexure - A. I also find it pertinent that Shri Kokane has claimed that the mobile number 9819988816, which was registered in his name, was never used by him nor his brother-in-law, but was used by his brother-in-laws office staff. Considering that Shri Amol Kokane was a student and also the fact that the familys annual income as disclosed in the Client Registration form of the broker (M/s. India Capital Markets Pvt. Ltd.) was only in the range of Rs. 1-5 lacs, it becomes clear that such sizable cash outflow was beyond the familys capacity. Therefore, I can only infer that such payments could have been funded only by a third party.

15. As per the trade data provided by the Exchanges BSE and NSE, I observe that Shri Amol Kokane has traded from September 16, 2008 to November 17, 2008 on NSE and from September 16, 2008 to November 20, 2008 on BSE. I find that Shri Kokane traded in the scrips of PSTL, Usher Agro, SEL Mfg. Suzlon Energy, Akruti City, RIL, REL, Unitech Ltd. etc. through the broker M/s. India Capital Markets Pvt. Ltd. (herein after referred to as India Capital Market). I find that the client account with India Capital Market was opened in his name on September 12, 2008 and on the same day, Shri Nirmal Kotecha too has opened a new client account with India Capital Market.

16. I also note from the interim Investigation Report that during the period from September 29, 2008 to November 17, 2008, Shri Kokane was generally buying at a higher rate and selling at a lower rate on both Exchanges (BSE and NSE) in the PSTL scrip. A detailed analysis of the same is at Annexure - B. I further find that during the period October 10, 2008 to November 27, 2008, 218 of the trades in PSTL on BSE of Shri Amol A. Kokane were at prices 0.5% higher than the last traded price during this period and were in the range of Rs. 0.25 to Rs. 5.1, higher than the last traded price on BSE. It would be correct to deduce that this has contributed to the price movement from Rs. 40.45 to Rs. 65.45 during that period. On NSE too, in the scrip of PSTL, I note that in 120 instances, the trades of Shri Amol A. Kokane were at price 0.5% higher than the last traded price. I further find that the trading of Shri Kokane in PSTL scrip on BSE during the period October 10 to November 27, 2008 accounted for around 14.98% of the total traded volume during the ten trading days on which he has traded on BSE. I also find that on two consecutive trading days in November 2008, Shri Kokane has contributed to more than 20% of the market volume on those days, thereby influencing the price considerably. These trades done from Shri Kokanes trading account have, thus, influenced volumes and price of the scrip. A detailed analysis of the same is at Annexure - C.

17. Besides, I note from the interim investigation report that as on September 30, 2008, Shri Nirmal Kotecha was holding around 4% shareholding (7,24,536 shares) in M/s. Usher Agro Ltd., one of the scrips in which 86,372 shares were bought and sold on BSE in the name of Shri Amol Konkane in a period of 4 days from September 16 to 19, 2008 at a profit of Rs. 4,66,753.25. Shri Nirmal Kotecha evidently had a close link with M/s. Usher Agro Ltd., as seen from the fact that Shri Kotecha was constantly in touch with one Shri Pandoo Prabhakar Naig, (understood to be on the Board of various companies, and is one of the independent directors on Board of M/s. Usher Agro Ltd., as per the information available on M/s. Usher Agro Ltd.s website). I further find that Shri Nirmal Kotecha, was holding more than 10% stake (18,74,755 shares) as on June 30 2008 in M/s. SEL Mfg. Co. Ltd., one of the other scrips in which 96,938 shares were bought and sold on BSE and NSE in the name of Shri Amol Konkane during the period September to November 2008 at a profit of Rs. 8,46,761. The stock price of M/s. SEL Manufacturing Company is understood to have plunged from Rs. 626.10 on 7 August 2008 to Rs. 400.75 on BSE after Nirmal Kotecha offloaded 3.4% of the companys equity stake in open market between 7 August 2008 and 11 August 2008. It is also understood that M/s. SEL Mfg. which came out with its IPO in July 2007 at a price band of Rs. 80-90 per share (face value Rs. 10 each) had made a pre-IPO placement of 5 lac shares to Shri Nirmal Kotecha at Rs. 75 per share. I also observe Shri Nirmal Kotechas close link with M/s. SEL Mfg. Co. Ltd. from the fact that Shri Nirmal Kotecha was constantly in touch with Shri Neeraj Saluja, MD of M/s. SEL Manufacturing Company. Further, I note that on February 27, 2008, when the process of recording of Shri Amol Kokanes statement by SEBI officials was in progress at his residence, Shri Nirmal Kotecha came to Shri Kokanes residence and directed him not to disclose any material information to SEBI officials and only to record the statement to the effect that he does not have any knowledge of anything in the matter of PSTL. He also advised him to say "I dont know" to any question that SEBI officials would ask him in the matter. Shri Kotecha was advised by the concerned officers of SEBI, that he should not interfere and disrupt the recording of the statement. However, he remained there and tried to influence Shri Kokane and prevent him from disclosing any further material information to SEBI. He also advised Shri Kokane to change his statement that had already been recorded. As a result, further statement of Shri Kokane could not be recorded. This act of Shri Kotecha, I find, was a clear interference by him in preventing SEBI officials in carrying out their activities as public servants. I note that a complaint was lodged by SEBI officials with the Sr. Inspector, Agripada Police Station immediately thereafter to take necessary action under law in the matter.

18. I further find that in the PSTL scrip, in particular, Shri Kokane has made gross purchases of 4,59,084 shares against gross sales of 4,21,974 shares on BSE and gross purchases of 73,509 shares against gross sales of 1,09,619 shares on NSE. I also find that, on BSE, he had a net purchase value of Rs. 47,76,022 as against net sales value of Rs. 19,33,354 on NSE in the PSTL scrip. Thus, based on his transactions in PSTL on BSE and NSE taken together, I find that Shri Kokane has incurred an overall loss of Rs. 28,42,668.

19. Further, considering the overall trading done on behalf of Shri Kokane across scrips, I observe that Shri Kokane has made gross purchases of 6,01,554 shares against gross sales of 5,75,978 shares on BSE and gross purchases of 1,66,097 shares against gross sales of 1,01,695 shares on NSE. Again, taking his overall trading on BSE into consideration, I find that he had purchased shares for a value of Rs. 23,78,347.55 (net) and on NSE he had further purchased shares for a value of Rs. 3,11,134 (net). Thus, I find that based on the overall trading done by him, Shri Kokane has incurred an overall loss of Rs. 26,89,481.55.

20. I also observe that Shri Kokane had bought 1,60,883 shares and 1,52,095 shares at a price of Rs. 49.97 and Rs. 56.21 respectively through bulk deals in the PSTL scrip in BSE on November 03, 2008 and November 04, 2008. However, I note that Shri Kokane in his statement has stated that his brother-in-law expired on November 01, 2008 and so his family had gone to his village at post Salgaon, Tal. Ambegaon, Dist. Pune and returned only on November 15, 2008. He also claimed that he has never given any order of buy/ sell to the broker. After the death of his brother-in-law on November 01, 2008, Shri Kokane further claimed that Shri Nirmal Kotecha was operating all his accounts.

21. I find that the above facts taken together with other related observations (viz. volume of trades done by Shri Amol Kokane through India Capital Market, the scrips that were selected for trading in his name and the losses incurred by him on these trades, the counterparty details that have emerged from the bank trail and the call/ Short Messaging Service (SMS) charges incurred by Shri Kokane on his mobile number 9819988816, relative to his familys annual income) prime facie, go to establish that Shri Nirmal Kotecha was using Shri Amol Kokane as an instrument for his own trades. Prima facie, it emerges from the evidence discussed above that Shri Nirmal Kotecha was fraudulently carrying out manipulative activities, in an otherwise falling market, using Shri Amol Kokanes name and his various linkages, even prior to the forged SEBI letter and this further stands established from the pattern of his trades described earlier in this order.

22. Shri Amol Kokane in his statement has admitted that Shri Nirmal Kotecha was operating all his accounts. All of the above, I note, prime-facie confirms an inference that the only intention behind these trades of Shri Nirmal Kotecha through Shri Amol Kokane, was to artificially inflate the price of PSTL scrip. This coupled with the claim of Shri Amol Kokane that Shri Nirmal Kotecha was operating his accounts, clearly indicates that the whole plot involving the forgery of SEBI letters has been for the purpose of enabling Shri Nirmal Kotecha to sell in the market at artificially raised prices.

23. The above inference is further strengthened by the fact that the bank trail of the high value funds transferred to Shri Kokanes account, from where they were transferred to the stock market, has revealed that these funds have been received from various entities/ persons who appear to be connected to each other, and in whose bank accounts, funds appear to have been circulated through a large network of their connected accounts, in a complex pattern and without any ostensible and bonafide business purpose. The investigation has also revealed frequent high value cash withdrawals and cash deposits, by limiting individual cash withdrawals and deposits to below Rupees ten lacs, in these accounts. From the above, I infer that these numerous bank accounts may have been opened with the sole purpose to disguise the trail of the suspicious transactions being carried out in these accounts. It is also seen that some of these persons/ entities, in whose names these accounts stood, have traded in the stock market. These high value money transactions through Shri Kokanes accounts and his trades, only indicate that he was a necessary party to the events, which culminated in the execution of trades in the shares of the company. The details of bank trail of Shri Amol Kokanes bank account carried out so far is at Annexure - D.

24. Further more, the examination done so far, of the bank accounts of Shri Nirmal Kotecha and his immediate relatives/ entities, over a six month period from June to December 2008, has revealed that he has withdrawn cash of about Rs. 1.25 crore around August end and mid-September, 2008. For this purpose, I find, he has also transferred funds from his account to his immediate relatives/ his related entities account. Further, I find that that the same modus operandi (withdrawing high value cash by keeping individual cash withdrawals below Rupees 10 lacs, to avoid triggering of Rules framed under the Prevention of Money Laundering Act in the aforesaid suspicious transactions accounts, discussed earlier in the order, and subsequently transferring the funds to Shri Amol Kokanes account), has been adopted in the transfer of funds into and out of Shri Nirmal Kotechas account, as well as the accounts of his immediate relatives/ his related entities. I also find that significant amount of cash has been withdrawn by Shri Kotecha, a day before the forged letter was dispatched to Shri Saminathan by courier, on the day the forgery received wide media publicity, and again, immediately thereafter. The details of bank trail of Shri Nirmal Kotechas bank accounts and that of his immediate relatives / his related entities bank accounts, available at this stage of the investigation are at Annexure - E. Considering all these facts together, I am compelled to prima facie arrive at the conclusion that Shri Nirmal Kotecha has masterminded the forged SEBI letter that was sent to Shri Saminathan.

25. Further, from the interim investigation report before me, I find that an amount of Rs. 10 lacs has been transferred from Shri Nirmal Kotechas account to his wife Ms. Viral Doshis account on September 25, 2008, and from here these funds, in turn, have been transferred to one Shailesh Jayantilal Shahs account on the very same day. This amount of Rs. 10 lacs has been returned to Ms. Viral Doshis account by Shri Shailesh Jayantilal Shah in three tranches of Rs. 4 lacs, Rs. 5 lacs and Rs. 1 lac on December 26, 27 and 31, 2008 respectively. I note that Shri Shailesh Jayantilal Shahs account also reflects repeated cash deposits of Rs. 90,000, Rs. 32,000, Rs. 1.5 lacs and Rs. 1 lac on December 01, 04, 23 and 31, 2008 respectively, Rs. 1.6 lacs on January 05, 2009 and two cash deposits of Rs. 45,000 and Rs. 1.5 lacs on the same day i.e. January 07, 2009.

26. I further find that Shri Shailesh Jayantilal Shah had bought 8,336 PSTL shares (net) from December 16, 2008 to December 19, 2008 at an average price of Rs. 69.67 per share. On December 22, 2008, he sold 32,000 shares (between 9:57:20 and 10:35:32) at an average price of Rs. 79.18 per share, before the announcement denying the open offer was made by Shri Saminathan. The investigation, so far, has also revealed that on the same day, he bought 28,700 shares after the said sale, out of which 21,557 shares match with Shri Nirmal Kotechas sales on the same day at an average price of Rs. 77.50 per share. The trade details of Shri Shailesh Jayantilal Shah in the PSTL scrip during the period December 15, 2008 to December 23, 2008 are at Annexure - F.

27. Here again, I find prima facie, that the sequence of events (i.e. transfer of funds from Shri Nirmal Kotechas account to his wife Ms. Viral Doshis account on September 25, 2008 and from there to Shri Shailesh Jayantilal Shahs account, repeated cash deposits made in Shri Shailesh Jayantilal Shahs account during the period, purchases just prior to the forgery and sale immediately on opening of the market after the news of the purported issue of the letter by SEBI became public, but, before its denial by Shri Saminathan, matching of subsequent purchases on December 22, 2008 with Shri Nirmal Kotechas sales and returning of funds back to Ms. Viral Doshis account on December 26, 27 and 31, 2008) leads to the conclusion that Shri Shailesh Jayantilal Shah had aided and abetted Shri Nirmal Kotecha in disguising his manipulative trading.

28. I also find from the interim investigation report that Shri Rajesh Jayantilal Shah, Ms. Binaben Shaileshkumar Shah, Shri Nirmal Rohitbhai Shah, Ms. Ritaben Rohitkumar Shah, Ms. Manishaben Rajeshkumar Shah, all of whom share the same address with Shri Shailesh Jayantilal Shah (hereinafter referred to as Shah group), traded during the period December 15, 2008 to December 23, 2008 in PSTL scrip. The details of their trades are at Annexure - G. Shri Rajesh Jayantilal Shah, in particular, is found to be one of the top five net sellers on December 22, 2008 till 10.28.04 a.m. i.e. prior to the denial by the company of the letter purportedly issued by SEBI. He has sold 49,000 shares on December 22, 2008 at an average rate of Rs. 82.87 per share through trading member M/s. J M Financial Services, prior to this denial. From the trading pattern of the Shah Group, it prima facie, emerges that the all the entities in the Shah group have abetted Shri Nirmal Kotecha in disguising his manipulative trading and gaining undue profits.

29. I further observe that one Raju G. Shah traded in the scrip of PSTL through the broker India Capital Market on two trading days viz. December 19 and 22, 2008 on BSE. Shri Raju G. Shahs client account was opened with the Borivali branch of India Capital Market in July 2008. From the interim investigation report before me, I find that on December 19, 2008, Shri Raju G. Shah bought and sold 71,805 shares on BSE. Out of the total buy of 71,805 shares of Shri Raju G. Shah on December 19, 2005, 13,731 shares matched with the sales by Shri Nirmal Kotecha. On December 22, 2008, 7,345 shares bought by Shri Raju G. Shah matched with the sales of Shri Nirmal Kotecha. Again on NSE I find that out of the 51,738 shares bought by Shri Raju G. Shah on December 19, 2008, 4006 shares matched with the sales by Shri Nirmal Kotecha. Similarly, out of 1,05,202 shares bought by Shri Raju G. Shah on December 22, 2008, 22,460 shares matched with the sales by Shri Nirmal Kotecha. Therefore, a total of 47,542 shares bought by Shri Raju G. Shah matched with Shri Nirmal Kotechas sales on December 19 and 22, 2008. I find it significant to mention here that the bank trail has revealed that Shri Raju G. Shah had received Rs. 5 lacs from Shri Nigam Vinod Shah on November 04, 2008, and Shri Nigam Vinod Shah, in turn, had received these funds from Shri Rajesh Jani, who is the Director of M/s. Dynamic Stock Broking (India) Pvt. Ltd. From the interim Investigation Report, I find that Shri Nigam Vinod Shah was introduced by one Nimesh Chitalia, who is the Head, Business Development of India Capital Market, where Shri Raju G. Shah himself had opened his trading account in July 2008. I have also noted the fact that Shri Nigam Vinod Shah is the person who had on an earlier occasion on October 10, 2008, transferred Rs. 15 lacs to Shri Amol Kokanes account. In view of the above, I find prima facie that Shri Raju G. Shah has also abetted Shri Nirmal Kotecha in carrying out the suspicious banking transactions observed and disguising his manipulative intent in the transactions in PSTL scrip.

30. I further find that during the period November 19, 2008 to January 07, 2009, Shri Nirmal Kotecha has off-loaded almost his entire stake in PSTL on BSE and NSE. In this period, Shri Nirmal Kotecha was a net seller in the scrip of PSTL having sold 70,99,117 shares (net). The details of his transactions in PSTL scrip during the period are at Annexure - H. I prima facie find from the above that Shri Nirmal Kotecha was operating in the PSTL scrip during the period October to mid-November 2008, primarily through Shri Amol Kokane to disguise his manipulative transactions. During the later stages, it appears that Shri Nirmal Kotecha used the trading account of his uncle Shri Deepak Thakkar, the Shah Group and Shri Raju G. Shah to disguise his manipulative transactions and the profits earned by him. I find that Shri Nirmal Kotecha last traded in the scrip of PSTL on January 7, 2009. On the previous day i.e. January 6, 2009 the scrip closed at Rs. 41.40 at BSE. I observe that subsequent to the transactions of Shri Nirmal Kotecha in PSTL shares as mentioned above, the scrip witnessed a significant fall and closed at Rs. 26.25 on January 20, 2009 on BSE. The fall in the price of the scrip continued further and the price of the scrip reached a low of Rs. 13.15 on March 5, 2009 on BSE. Hence, I observe that Shri Nirmal Kotecha off-loaded almost his entire stake at artificially inflated price levels, before the scrip witnessed significant value erosion. Thus, in short Shri Nirmal Kotecha has transferred the shares of PSTL to the investors at inflated prices.

31. The above shows that besides Shri Amol Kokane, a number of entities who have traded in PSTL scrip, have connections with Shri Nirmal Kotecha, who has directly or indirectly used these entities, to disguise his manipulation of the volume and price of trades in the scrip of PSTL. From the above, I find prima facie evidence of both - the manipulative intent of Shri Nirmal Kotecha in his trading in the market through front entities, as well as his knowledge of the forgery. I, therefore, find prima facie that Shri Nirmal Kotecha has engaged in fraudulent, abusive, manipulative and illegal activities, detrimental to the interests of investors and to the integrity of securities market and that this warrants immediate preventive action by SEBI.

32. Shri Amol Kokane had lent his name for facilitating Shri Nirmal Kotecha to carry out his fraudulent, abusive, manipulative and illegal activities, detrimental to the interests of investors and to the integrity of the securities market. I am of the view that he has, whether willfully or not, aided Shri Nirmal Kotecha in carrying out his fraudulent activities.

33. I also find prima facie that Shri Deepak Thakkar, the maternal uncle of Shri Nirmal Kotecha, the Shah Group and Shri Raju G. Shah - have all played a key role in facilitating Shri Nirmal Kotecha in carrying out suspicious banking transactions, carrying out and disguising his manipulative intent and gaining advantage from the forgery.

34. Further, I find that the operations appear to have involved activities which are potentially money laundering in nature, and are detrimental to the genuine investors, at large. The persons/ entities and their proprietors/ partners/ directors (including Shri Nirmal Kotecha and his immediate relatives/ related entities), identified in this order have primia facie carried out suspicious banking transactions and have routed these funds, either directly or indirectly in the stock markets, to finance spurious transactions, thereby defrauding genuine investors.

35. From the interim investigation report, I also find that one Rakesh Sharma played a major role and was instrumental in publicizing the contents of the forged SEBI letter that was sent to Shri Saminathan, through his circle of friends connected to the media, and also, ensuring that they publish the news of the open offer before the opening of the markets on December 22, 2008. Shri Rakesh Sharma, then an executive with M/s. Adfactors PR Pvt. Ltd. (herein after referred to as Adfactors) and is one of the accused in the FIR filed by SEBI. He had made certain oral statements to SEBI officials, before he was arrested by the police in respect of the FIR lodged by SEBI. He subsequently changed his statement when he appeared before SEBI after his release on bail for recording of his statement. However, the mobile tower locations as stated below in this Order (obtained from mobile service providers) clearly corroborate the earlier version given by him. As seen below in this order, another person Shri Rajesh Unnikrishnan, also appears to have facilitated the publication in the media of the forged letter that was sent to Shri Saminathan. Shri. Rajesh Unnikrishnan is presently the Assistant Editor of Economic Times. He was also a former colleague of Shri Rakesh Sharma in Business Standard. Shri. Unnikrishnan had also covered some stories for Economic Times on transfer of PSTL shares from one promoter to another, prior to the forgery. It was also further observed that Shri Unnikrishnan was in touch with Shri Nirmal Kotecha, particularly after December 10, 2008.

36. The tower locations of Shri Kotechas number (registered in the name of Shri Amol Kokane), Shri Rakesh Sharmas number and Shri Rajesh Unnikrishnans number indicate that the three had met in the afternoon of December 20, 2008 i.e. the day and around the time when the forged SEBI letter was circulated to the media through Shri Rakesh Sharmas contacts in the media. An analysis of the data received from the mobile service providers reveals that on December 20, 2008, at 12:13 p.m., Shri Nirmal Kotecha was at (opposite) Swami Narayan Mandir and at 12:23 p.m., he was at Pritam Hotel. Shri Rajesh Unnikrishnan too was near Pritam Hotel at 12:03 p.m., 12:09 p.m. and at 12:23 p.m. on the same day. Shri Rakesh Sharma was also at Hindu Colony, Dadar TT at 12:11 p.m.. I find that the tower location details indicates that Shri Nirmal Kotecha was at Matunga (E) (from 1:12 p.m. to 2:27 p.m.). Similarly, the tower location details shows that Shri Rajesh Unnikrishnan was also at Matunga (E) between 12:57 p.m. and 1:44 p.m. I find that the tower location details too indicates that Shri Rakesh Sharma was at Maheshwari Udyan, Matunga at 1:52 p.m. and King Circle at 1:53 p.m. The above seems to corroborate the admission made by Shri Rakesh Sharma, before he was arrested by the police that the three of them had met at Hotel Pritam at Dadar TT. I also note that in the same statement, later retracted by Shri Rakesh Sharma, he had further admitted that they had gone to Shri Nirmal Kotechas residence by taxi between 12:30 p.m. to 1:30 p.m. from where Shri Rakesh Sharma had e-mailed the forged SEBI letter that was addressed to Shri Saminathan, CMD, PSTL, to some of his friends in the media.

37. Shri Rakesh Sharma, before being arrested had claimed that the forged SEBI letter was e-mailed by him from Shri Nirmal Kotechas residence by using his own personal e-mail ID to his following media contacts, (Shri Raj Nambisan of DNA, Shri Partha Sinha of TOI and Shri Ashish Rukhaiyar of ET) before accompanying Shri Rajesh Unnikrishnan to Dalal Street side around 2:00 p.m. Based on the copies of the e-mail submitted to SEBI by the reporters, I find that the Investigation has revealed that the e-mail to Shri Partha Sinha was sent at 1:43 p.m. i.e. around the time when the tower location for all three of them as seen in the data was Matunga (East)/ King Circle. Shri Kotechas residence is also at Matunga (East)/ King Circle. This corroborates Shri Rakesh Sharmas initial admission that the e-mail to Shri Partha Sinha was forwarded from the computer in Shri Kotechas residence, when all three of them were at his residence. Shri Raj Nambisan of DNA informed the investigation team that he seemed to have deleted the e-mail that was sent to him. The e-mail details forwarded by Shri Ashish Rukhaiyar of Economic Times shows that the e-mail was sent by Shri Rakesh Shrama from his personal e-mail ID to Shri Rukhaiyars personal e-mail ID at 3:03 p.m. Further, though Shri Rakesh Sharma claimed that the forged SEBI letter was e-mailed by him to only three of his friends in the media, I find that he had also forwarded the forged SEBI letter by e-mail to Shri Dheer Kothari (one of his ex-colleagues in Adfactors who is based in Kolkata). From the copy of the e-mail made available by Shri Dheer Kothari, I observe that Shri Rakesh Sharma had forwarded the e-mail to him at 1:43 p.m. on December 20, 2008 i.e. again at a time when all three of them were at Matunga.

38. Further, I find that the telephone records show that Shri Rakesh Sharma was in constant touch with Shri Dheer Kothari on December 20, 2008 from about 12:30 p.m. in the afternoon to about 10:00 p.m.at night. Shri Dheer Kothari informed that he, as per their understanding, had disseminated the information to three newspapers - Business Standard, Telegraph and Hindu Business Line. Shri Dheer Kothari further informed SEBI that he was paid Rs. 10,000/- for doing this. From the bank statement of the concerned period made available by him, I observe that funds of Rs. 10,000/- were transferred to Shri Dheer Kotharis account on December 23, 2008. From the trail of these funds, I find that Rs. 10,000/- was transferred to Shri Dheer Kotharis account from Shri Rakesh Sharmas account with HDFC Bank, Borivali (West) branch (opened in July 2008).

39. I see from the interim Investigation Report that Shri Rakesh Sharma had prior to his arrest, admitted that after sending the e-mails as above to the persons in the media from Shri Nirmal Kotechas residence, he and Shri Rajesh Unnikrishnan proceeded to Dalal Street side in a cab around 2:00 p,m., and that Shri Rajesh Unnikrishnan went to his office and that he himself had gone to Shri Ashok Jainanis office at M/s. Khandwala Securities Ltd. He had further claimed that through Shri Ashok Jainanis computer, he e-mailed the scanned letter from his e-mail account to Shri Ashok Jainanis email account, and then, Shri Ashok Jainani sent the same to Business Standard (herein after referred to as BS) at around 3:00 - 3:30 p.m. From the e-mail copies received by Shri Ashok Jainani, I find that the e-mail from Shri Rakesh Sharmas personal e-mail ID to Shri Ashok Jainans office account was sent at 3:02 p.m. and that on his personal e-mail ID was sent at 3:03 p.m. The e-mail receipt details forwarded by the BS reporter Ms. Priya Nadkarni, indicates that the e-mail was sent to her by Shri Ashok Jainani from his personal e-mail ID to her personal email ID at 3.22 p.m. This too, substantively confirms the e-mail sequences and the timings in the admission made by Shri Rakesh Sharma prior to being arrested.

40. From the above, I find prime facie, that Shri Rakesh Sharma has abetted in providing wide media publicity to the forged letter (containing the SEBI directives on the open offer) that was sent to Shri Saminathan.

41. I further observe that Shri Rakesh Sharma had admitted before his arrest that that when one of the reporters to whom Shri Ashok Jainani had e-mailed the forged letter, desired to ascertain the authenticity of the information by counter checking with the company officials, he contacted Shri Nirmal Kotecha (around 4:30 -5:00 p.m.) on his mobile. He had further stated that Shri Kotecha responded and sent an SMS to him providing the Company Secretarys telephone number and his name (as one Shri Ganesan, serving at Chennai office). This, Shri Sharma admitted was passed on by Shri Ashok Jainani to the BS reporter. However, Shri Rakesh Sharma had claimed that Shri Ganesan had informed the BS reporter that there was no such development and denied the contents of the letter. Shri Rakesh Sharma had further admitted that at about 6:00- 6:30 p.m., the reporter of BS had called back Shri Ashok Jainani to inform him about this response from Shri Ganesan. Shri Rakesh Sharma also claimed to have informed Shri Nirmal Kotecha then that the Company Secretary had denied the development and that, in turn, Shri Nirmal Kotecha gave details of another Company Secretary, (name and telephone number of Shri Kanu Sahu) by SMS to him (between 7.00 to 8.00 p.m.). He further claimed that Shri Rajesh Unnikrishnan also sent two SMSs to him - one to inform the telephone number and the second to inform the name of the Company Secretary (Shri Kanu Sahu). Shri Rakesh Sharma, before his arrest had then stated that he also sent this number through an SMS to all those whom he had forwarded the e-mail earlier, so that, they could confirm the information by talking to Shri Kanu Sahu.

42. I find that the call records indicate that Shri Rakesh Sharma had called Shri Nirmal Kotecha on his number (registered in the name of Shri Amol Kokane) at about 6.13 p.m.. Immediately thereafter, I find that Shri Nirmal Kotecha from his number (registered in the name of Shri Amol Kokane) has called Shri Rajesh Unnikrishnan at about 6.14 p.m. and again at about 6.35 p.m. Shri Rakesh Sharma too, called Shri Rajesh Unnikrishnan at around 6.41 p.m. and Shri Ashok Jainani at around 6.51 p.m. Subsequently, thereafter, I find, there had been repeated and long exchange of calls between the three of them. Subsequently, Shri Nirmal Kotecha sent four SMSes, of which two were sent to Shri Rakesh Sharma and two to Shri Rajesh Unnikrishnan between 7.31 p.m. to 7.33 p.m. Shri Rajesh Unnikrishnan, I find, thereafter also sent two SMSes to Shri Rakesh Sharma at about 7.36 p.m. The flow of calls and SMSes continued between the three till about 7.40 p.m. Further, after receiving the SMSes from Shri Kotechas number (registered in the name of Shri Amol Kokane) and from Shri Rajesh Unnikrishnan, Shri Rakesh Sharmas call/ SMS records, I find, indicate that he had sent SMSes to - Shri Raj Nambisan of DNA, Shri Ashish Rukhaiyar of ET, Shri Partha Sinha of TOI, Shri Ashok Jainani of M/s. Khandelwal Securities Ltd., Shri Dheer Kothari, ex-Adactors and Shri Sudhir Shetty, Adfactors. This, therefore, further corroborates Shri Rakesh Sharmas admission made before his arrest, that he had received two SMSes each from Shri Nirmal Kotecha and Shri Rajesh Unnikrishnan informing the name and number of the Company Secretary of PSTL (Shri Kanhucharan Sahu) and, that he in turn, had passed on the same to all those to whom he had forwarded the e-mail earlier.

43. From the interim Investigation report, I further note that Shri Kanhucharan Sahu is the Compliance Officer and Company Secretary of PSTL since March 2008. In his statement recorded on January 28, 2009 at SEBI, he claimed that only mobile numbers 9790910824 and 9940249404 belong to him. He further stated that he did not receive any calls on December 19, 20 and 21, 2008 in the matter of the forged SEBI letter advising Shri P.S. Saminathan to make an open offer. I further note that he has also stated that neither any person from the media or any reporter called him on those days, nor did he receive any calls from Shri Nirmal Kotecha on those days. In his statement given to the investigation team, he has stated that he had not confirmed to anybody regarding the receipt of the letter by the company, and that, he spoke to Shri Nirmal Kotecha only after issue of SEBIs press release and that the conversations were in the routine matters including the forged SEBI letter.

44. In view of the statement as above made by actual Shri Kanhucharan Sahu, the actual Compliance Officer and Company Secretary of PSTL, the billing name and address of mobile number 9947219100 was called for from the service provider. I find that the number belongs to one Shri Pratheesh Kumar v. K. with billing address as (Vanury House, Palakkat Lane, Thrissur). The call records of Shri Kotechas number (registered in the name of Shri Amol Kokane), I find, also indicates that immediately thereafter, Shri Nirmal Kotecha has sent two SMSes each at (about 7:32 p.m. and 7:33 p.m.) to Shri Rakesh Sharma and Shri Rajesh Unnikrishnan conveying Shri Kanhucharan Sahus number as 9947219100. At about 7:43 p.m. Shri Kotecha called Shri Pratheesh Kumar v. K. (the billing name and address of whom is given as above) and the call lasted for around 320 seconds, after which he SMSed him at around 08:06 p.m. Further, the call records also indicate that Shri Pratheesh Kumar too called him back around 10:28 p.m. and the call lasted for about 847 seconds. The tower location details pertaining to the mobile number of Shri Pratheesh Kumar V.K. indicates that he was in Cochin during that period. However, he failed to present himself when he was summoned by SEBI to record his statement.

45. I further observe that the reporters in their statements given to the Investigation team have also stated that when they contacted Shri Rakesh Sharma or Shri Ashok Jainani to verify the authenticity of the facts mentioned in the forged letter that was e-mailed to them, they were directed to Shri Kanhucharan Sahu, the Company Secretary and given his mobile number 9947219100. Some of the reporters who called that number either on December 20 or 21, 2008, have further informed that the person who took the call confirmed that they had received the letter and were looking into the matter. Details of the reporters versions given to SEBI are at Annexure - I.

46. Thus, I find prima facie, from the above that the trio of Shri Nirmal Kotecha, Shri Rakesh Sharma and Shri Rajesh Unnikrishnan had plotted to mislead the media into believing the authenticity of the information that was circulated by them. I further find prima facie, that they had together designed and executed a plan with great precision, that the reporters who called them to confirm the genuineness of the information, were actually led to believe in its genuineness. In this manner, i.e. by using Shri Pratheesh Kumar v. K as an imposter in place of the actual Company Secretary, Shri Kanhu Charan Sahu, I find, that the trio of Shri Nirmal Kotecha, Shri Rakesh Sharma, Shri Rajesh Unnikrishnan had ensured that the reporters published the news item the very next day. This helped achieve the objective to ensure wide publicity for the news on the open offer through media circles before the opening of the market on December 22, 2008. In turn, this helped achieve what prima facie appears to have been the end objective - to facilitate Shri Nirmal Kotecha to offload his stake on December 22, 2008 when the market opened, at artificially inflated price as against the last traded price, and earn a sizable profit (both directly as well as indirectly by using persons such as his maternal uncle Shri Deepak Thakkar, Shah Group etc.) as observed previously in the order, before news of the forgery became public. I, thus, find that prima facie, Shri Nirmal Kotecha planned and executed the forgery as a means to accelerate the upward movement of the share price of PSTL and to derive unlawful profit, whether directly or indirectly, before the forgery came to light. That the person who delivered the forged letter to the courier company Blue Dart for dispatching it to Shri Saminathan would have been advised to give instructions to the courier company - NOT to deliver the letter on Saturday to PSTL and to deliver it ONLY on Monday (December 22, 2008) seems to therefore fit into well in what prima facie appears to be a very devious plan.

47. In view of the above, I have no hesitation in concluding that Shri Nirmal Kotecha, Shri Rakesh Sharma and Shri Rajesh Unnikrishnan, have jointly played a key role in an arrangement contrived to defraud investors in the market and derive illegal profits thereof. As brought out above in this order, this scheme was elaborate in its design with several elements which included forgery, dissemination of the false information contained in the forged letter to the media and an attempt to mislead the media to believe in the authenticity of the information that was circulated to them. 48. I further note that certain corporate announcements which prime-facie are misleading in nature were made by Shri P.S. Saminathan, promoter and CMD of PSTL, just prior to the issue of the purported SEBI letter. PSTL had come out with a public issue of 84,44,000 shares in December 2006. I find that vide its letter dated June 20, 2008, PSTL had informed the stock Exchanges (NSE and BSE) that Shri P.S. Saminathan, Chairman and Managing Director had purchased 13,70,000 equity shares of the company, representing 4.845% of the paid-up capital of the Company, from Shri Nirmal Kotecha, belonging to the Promoters Group. From the interim Investigation Report before me, I observe that the above transaction was done through the stock broker M/s. Keynote Capital Ltd. (hereinafter referred as Keynote) in the form of a cross deal. The trade was executed at a price of Rs. 250 per share, and thus, the total value of the sale was Rs. 34.25 crore. Shri Nirmal Kotecha had requested broker Keynote to transfer the credit of Rs. 34 crore lying in his account with Keynote on account of sale of shares on June 20, 2008 to the account of Shri P.S. Saminathan by debiting his account with Rs. 34 crore, as per his mutual understanding with Shri Saminathan. It is seen from the client ledger provided by Keynote that the money was not actually received in Shri Nirmal Kotechas account and that only a ledger entry was passed in the books for transferring an amount of Rs. 33,99,04,292.28 (i.e. credit lying in Shri Nirmal Kotechas account after adjusting the debit accumulated in his account of Rs. 1,57,837.24) towards balance transferred to Shri Saminathans account, as per client (Shri Nirmal Kotechas) written instruction. It is seen that Shri Kotecha paid Rs. 25,95,707.26 (vide post dated cheque) dated December 02, 2008 to Keynote and requested Keynote to credit the said amount to the account of Shri P.S. Saminathan with Keynote and also requested that 13.70 lac shares be transferred to the Depository Participant (DP) account of Shri P.S. Saminathan. It is seen that though the transaction was executed on June 20, 2008 on BSE, the settlement by delivery of shares was done only on July 24, 2008 by Keynote i.e. after more than one month from the date of the transaction and after it received the post dated cheque from Shri Kotecha on behalf of Shri Saminathan. The balance amount was also paid by Shri Saminathan on July 24, 2008. I observe that there was no receipt of funds by Shri Nirmal Kotecha from Shri Saminathan on the date of the transaction and that on the basis of the letter from Shri Nirmal Kotecha, Keynote has only made book entries. The shares were also not exchanged on the pay-out date. The announcement and the timing by the company, based on information provided by Shri Saminathan and Shri Nirmal Kotecha to the company, were therefore misleading.

49. Further, any acquirer who intends to acquire shares, which along with his existing shareholding would entitle him to more than 15% voting rights, can acquire such additional shares only after making a public announcement ("PA") to acquire at least additional 20% of the voting capital of the target company from the shareholders through an open offer, unless he is exempted under Regulation 3 of the SEBI (SAST) Regulations, 1997.

50. On April 03, 2008 and April 14, 2008, Shri P.S. Saminathan bought 1,11,335 shares and 8,90,665 shares respectively from Shri v. Natarajan, one of the other promoter in off market transaction, as a result of which, Shri Saminathans holding increased from 13.75% to 17.29%. Hence, Shri P.S.Saminathan was already holding more than 15% stake in the company, when he acquired the aforesaid 13,70,000 shares from Shri Nirmal Kotecha.

51. As per Regulation 3(1)(e)(iii)(b) of the SEBI (SAST) Regulations, 1997, an acquisition pursuant to inter-se transfer of shares amongst promoters is eligible for exemption from the applicability of the Regulations 10, 11 and 12 of the SEBI (SAST) Regulations, 1997, as the case may be, subject to certain conditions. One of these conditions is that the transferees (collectively) as well as the transferors (collectively) should have been holding the shares in the target company for a period of at least three years prior to the date of acquisition.

52. I observe that the transferor promoter Shri v. Natarajan and transferee promoter Shri P.S. Saminathan were both holding shares for a period more than three years at the time of the April transaction, hence, the transaction was exempt under Regulation 3(1)(e)(iii)(b) of the SEBI (SAST) Regulations, 1997. However, I observe that Shri Nirmal Kotecha was holding shares in PSTL since April 27, 2006. Hence, as the transferor, i.e. Shri Nirmal N. Kotecha did not satisfy the condition that he should have held the shares for three years, such a transaction prima facie was not eligble to be considered for grant of exemption under Regulation 3(1)(e)(iii)(b) of the SEBI (SAST) Regulations, 1997. I find that, in this case, the acquirer was bound by the regulations to make a public announcement in terms of the SEBI (SAST) Regulations, 1997, in respect of his acquisitions, as it triggers the provisions of the SEBI (SAST) Regulations, 1997.

53. Besides the above, it is also seen that Shri P.S. Saminathan had informed the stock Exchanges (BSE and NSE) on October 10, 2008 that he proposed to acquire 70,45,619 equity shares aggregating to 24.9169% of the shareholding rights of PSTL from Shri N.C. Ravichandran and Shri Nirmal Kotecha, by way of inter-se transfer. The date of the proposed acquisition communicated was November 28, 2008 and the price per share was Rs. 200/-. The shareholding of Shri P.S. Saminathan after the proposed acquisition would have been 1,32,58,575 shares aggregating to 46.8891% of the shares/ voting rights of PSTL. Subsequently, on November 27, 2008, I find that Shri Saminathan again informed the Exchanges (BSE and NSE) that after discussions with the transferees and considering the present market conditions, the price of the proposed acquisition had been revised to Rs. 200/- or market price, whichever is lower, and the that the deal would take place on December 22, 2008 and not on November 28, 2008.

54. However, from the interim investigation report, I find that despite announcing on October 10, 2008, the above proposal to acquire shares through interse transfer at Rs. 200/- per share and even before revising the proposed acquisition price, Shri Saminathan acquired 2,80,000 shares from Shri Nirmal Kotecha on November 19, 2008 at an average price of Rs. 50/- per share on BSE. He also subsequently purchased 61,757, 50,000 and 48,071 shares on November 28, 2008, December 01, 2008 and December 05, 2008 respectively from Shri Nirmal Kotecha. The details of his purchases from Shri Nirmal Kotecha are at Annexure - J.

55. From all of the above, I am of the view that prima facie, the above mentioned public announcements by Shri Saminathan were made only to create public interest in the scrip so as to facilitate Shri Nirmal Kotecha in offloading his PSTL shares in the market at artificially inflated prices.

56. I also note, that that despite Shri Saminathans claims to the media that PSTL was grossly undervalued and Rs. 200/- was a fair price, Shri Saminathan himself had purchased a total of 8,43,942 shares of PSTL in market transactions at an average price of Rs. 45.67 per share during the period from October 24, 2008 to December 5, 2008. I also find that Shri Saminathan had sold a total of 6,000 shares at an average price of Rs. 46.66 per share, during this period. The details of the said transactions are at Annexure - K.

57. The interim investigation, so far, has also revealed that Shri Saminathan and Shri Nirmal Kotecha were in touch with each other immediately before the forgery came to light. There was also a sudden spurt in the calls between the Group Company Secretary, Shri S. Ganesan and Shri Nirmal Kotecha in the month of December 2008. The investigation has further revealed that an amount of Rs. 5 lacs was paid by Shri Nirmal Kotecha to the Group Company Secretary, Shri S. Ganesan, through his entity Nirman on December 17, 2008, i.e. two days prior to the dispatching of the forged SEBI letter to Shri Saminathan. This coupled with the misleading announcements made by Shri Saminathan just prior to the forgery, as discussed above, I find, is clearly indicative of the fact that Shri Saminathan was facilitating Shri Nirmal Kotecha in offloading the shares of PSTL in the market at artificially raised price.

58. I also see from the records that Keynote research report dated February 05, 2008 maintained "buy" recommendation on PSTL with 13-month target price of Rs. 1,074/- in February 2008, when the market price was around Rs. 408/- (average price on NSE). From the perusal of other available research reports of other brokers on PSTL, I find that the recommended buy price around that period was in the range of Rs. 400/- to Rs. 600/-. For example, M/s. Anand Rathi Securities Ltd. had recommended a target price of Rs. 575/- as on January 30, 2008, when the then prevailing market price was around Rs. 350/- (average price on NSE). M/s. Religare Securities Ltd. had recommended a target price of Rs. 557/- as on April 21, 2008, when the prevailing market price was around Rs. 353/- (average price on NSE). M/s. Goldman Sachs Ltd. had recommended a target price of Rs. 499/- as on May 29, 2008, when the prevailing market price was around Rs. 353/- (average price on NSE). M/s. Religare Securities Ltd. had recommended a target price of Rs. 480/- as on July 07, 2008, when the market price was around Rs. 177/- (average price on NSE). I find that it was only on August 05, 2008 update, that Keynote had cut the 18-month target price of PSTL to Rs. 285/-, when the market price of the stock was around Rs. 163/- (average price on NSE). It is also pertinent to observe here that Keynotes Research team had not published any other media/ entertainment industry sector report giving target/ recommended price since November 2004. It is also important to note that Keynote had lead managed and had underwritten PSTL IPO in December 2006. It had also acted as Advisors to PSTL for raising of 90 million dollar (Rs 369 crore) through issue of Foreign Currency Convertible Bonds (FCCBs) in the international market to fund PSTLs overseas acquisition plans. Further more, Keynote was also associated with the company in the deal to acquire Dimple Cine Advertisers. I, therefore, prima facie find that the recommendations of Keynote and the related valuation of the PSTL scrip, are not genuine and were intended to facilitate fraudulent transactions in PSTL scrip at an artificially inflated price. Such action on the part of Keynote, breaches all professional and ethical standards, besides misleading unsuspecting investors in the market.

59. Further, I find that the client account in the name of Shri Amol Kokane was opened with India Capital Market, a Corporate member of NSE and BSE on September 12, 2008. On the same day, a new client account in the name of Shri Nirmal Kotecha too was also opened. I observe that trades in the name of Shri Amol Kokane through India Capital Market on NSE Cash were done from September 16, 2008 to November 17, 2008, in the Futures and Options (F&O) segment of NSE from September 18 to September 25, 2008 and on Cash segment of BSE from September 16, 2008 to November 20, 2008, in several scrips that included PSTL, Usher Agro, SEL Mfg. Suzlon Energy, Akruti City, RIL, REL and Unitech Ltd. I note that Shri Harsh Shah, Vice President of India Capital Market, in his statement recorded on March 05, 2009, informed that details about the opening of the new account in the name of Shri Amol Kokane and Shri Nirmal Kotecha and also the details about the orders placed by them can be obtained from the Branch Manager Shri Darshan Desai of Borivali (West) branch located at Goyal Shopping Centre. On a visit by SEBI officials to the Borivali (West) office of India Capital Market, Shri Darshan Desai claimed that he was the Branch Head of the Borivali (West) branch of India Capital Market. I find that he informed SEBI officials that one of the peons by the name Siddhartha, who worked with him for only 15 days had introduced him to Shri Sandeep Guvhane, who in turn, introduced Shri Amol Kokane and Shri Nirmal Kotecha to him. Shri Darshan Desai further informed that before November 03, 2008, Shri Sandeep Guvhane used to place orders on behalf of Shri Kokane and subsequently he himself had traded in the account of Shri Kokane by debiting other client accounts that had credit balances. He, however, stated that though it was he who was trading in Kokanes account, the trade confirmations were automatically transmitted by SMS to Shri Kokane on his mobile number 9967838402 (reflected in the record with India Capital Market). It was seen that trading was done on 13 trading days in the account of Shri Kokane since November 03, 2008 i.e. after the death of Shri Kokanes brother in law, Shri Sandeep Guvhane, and on January 15, 2009, a pay out of Rs. 4,29,562 was issued to Shri Amol Kokane. Shri Darshan Desai, in his statement first stated that it was only in the account of Shri Amol Kokane that he had traded without any instructions/ knowledge of the client, by adjusting the credits lying to the other clients accounts; however, he subsequently stated that he was carrying out such trades in one or two more client accounts also. He also stated that he was one of the Directors of Nine Group Securities Pvt. Ltd. and that his wife Ms. Priyanka Desai was a remisier of BSE and also that, Borivali branch of India Capital Market was registered in his wifes name. From the interim Investigation Report, I find that SEBI officials who visited India Capital Market, found from a perusal of a few Client Registration Forms of clients registered with India Capital Market, that the details of Reference/ Introducer, were always left blank in these forms.

60. From the interim Investigation Report, I further find that, though Shri Darshan Desai claimed to be the branch head, neither he nor Shri Harsh Shah could produce any document proving Shri Darshan Desais employment with India Capital Market. It is understood that the Borivali (West) branch is in the name of Smt. Priyanka Desai, Shri Darshan Desais wife. Further, the bank trail of Shri Kokanes account has revealed that the credit of Rs. 15 lacs on October 10, 2008 was received in Shri Kokanes account from one Shri Nigam Vinod Shah (of 203, A Wing, Ratna Sagar CHS, 80 feet Road, Near Jain Temple, Bhayander (West) Dist. Thane). In the Know Your Customer (KYC) records, it is seen that Shri Nigam Vinod Shah was introduced by one Shri Nimesh Chitalia, who is the Head, Business Development of India Capital Market. An examination of the details of the bank account of Shri Nigam Vinod Shah further showed that an amount of Rs. 5 lacs was also transferred from Shri Nigam Vinod Shahs account to Shri Raju G. Shahs account on November 04, 2008. Shri Raju G.Shahs client account was opened with the Borivali branch of India Capital Market in July 2008 and as stated earlier in the order, Shri Raju G. Shah has traded in the PSTL scrip through broker India Capital Market, on the two trading days viz. December 19 and December 22, 2008 on BSE. The trading accounts of Shri Raju G. Shah, Shri Amol Kokane and Shri Nirmal Kotecha were opened at the same branch of the broker India Capital Market and around the same period. Further, I find, from the documents submitted by Shri Raju G. Shah at the time of opening of the bank account in November 2006, that Shri Raju G. Shahs annual family income was Rs. 30,000/- only.

61. I note here that Shri Darshan Desai, as per his own admission, appears to have carried out fraudulent trades in the account of Shri Amol Kokane.

62. Further, I find that Shri Kokanes account had received credits of Rs. 5.25 lacs, Rs. 2.75 lacs, Rs. 15 lacs and Rs. 12 lacs from different parties viz. Shri Praful P. Vora of M/s. Viren Trading Agency, Shri Hemal H. Gandhi HUF of Datapro, Shri Nigam Vinod Shah and Shri Janak H. Chitalia of M/s. J.H. Chitalia & Co., respectively on October 10, 2008. I find that each of these persons, in turn, had received credit of similar amounts in their account from one Shri Rajesh Jani, just immediately before they transferred the funds to Shri Kokane on October 10, 2008. I also find that an amount of Rs. 5 lacs that was transferred from Shri Nigam Vinod Shahs account to Shri Raju Shahs account on November 04, 2008, as stated in the earlier para, in turn, was also received in Shri Nigam Shahs account from Shri Rajesh Jani. The interim investigation report has revealed that Shri Rajesh Jani is the Director of M/s. Dynamic Stock Broking (India) Pvt. Ltd. (herein after referred to as Dynamic).

63. Shri Rajesh Jani in his statement recorded on April 17, 2009, at his office had claimed that these credits from his bank account to those of Shri Nigam. v. Shah and Shri Janak. H. Chitalia are repayments of loans taken from them in the year 2007-08. As per his statement, these loans were arranged by one Chartered Accountant Shri Nitin Goradia. However during the process of investigation, it was found that there is no loan agreement to substantiate Shri Nitin Goradia and/ or Shri Janis statement that these amounts were actually loans. Further, as per the documents submitted by Shri Nigam Vinod Shah to Dynamic at the time of opening of client account with broker Dynamic, I find that his familys annual income is only Rs. 50,000/-. I observe that it is less than credible that Shri Nigam Shah (25 years in age), whose family income is relatively so low, can advance a loan of Rs. 25 lacs in the year 2007-08 to Shri Rajesh Jani, and that too, without any loan agreement regarding interest rate and repayment schedule. It is further seen that Shri Nitin Goradias client account with Dynamic reflects a debit balance of Rs. 15 lacs since April 2008, which has not been cleared. Shri Jani in his statement has informed that as he is not able to pay interest to parties from whom Shri Nitin Goradia had arranged loans for him, the outstanding amount due to Dynamic has also not been cleared by Shri Garodia. Further, a perusal of the KYC of M/s. Kankeshwari Securities Pvt. Ltd., who had lent an amount of Rs. 30 lacs to Shri Rajesh Jani in April 2006, by way of friendly interest free loan as claimed by Shri Jani in his statement, shows that its directors are/ were Ms. Rita N. Goradia, wife of Shri Nitin Goradia, Shri Nimesh H. Chitalia, who is the Head, Business Development of India Capital Market and the brother-in-law of Shri Nitin Goradia and one Shri Vilas P. Shah. Further, Shri Janak H. Chitalia, who had lent an amount of Rs. 12 lacs to Shri Jani in December 2007, and subsequently lent the said funds to Shri Amol Kokane in October 2008 immediately after receiving the amount from Shri Jani, is also the brother-in-law of Shri Nitin Goradia. Shri Nitin Goradia, in the statement of Shri Rajesh Jani, has also admitted that on the guarantee of Shri Darshan Desai, he had further arranged loan of Rs. 15 lacs from his client Shri Nigam v. Shah and Rs. 2.75 lacs from his other client Shri Hemal Gandhi for Shri Amol Kokane in October 2008.

64. I find the investigation done so far, thus reveals, that Shri Nitin Goradia, the Chartered Accountant of Shri Rajesh Jani, is the link through Shri Rajesh Jani, Shri Darshan Desai and Shri Nimesh Chitalia, for transfer of funds of Rs. 5.25 lacs, Rs. 2.75 lacs, Rs. 15 lacs and Rs. 12 lacs from the accounts of Shri Praful P. Vora of M/s. Viren Trading Agency, Shri Hemal H. Gandhi HUF of Datapro, Shri Nigam Vinod Shah and Shri Janak H. Chitalia of M/s. J.H. Chitalia & Co. to Shri Amol Kokanes account on October 10, 2008. Further, since It has been brought out that all Shri Amol Kokanes accounts were operated by Shri Nirmal Kotecha, I find, there is clear nexus between Shri Nirmal Kotecha and the above mentioned persons. It has also become evident from the above, that persons with either meager family income, or, families below poverty line, appear to have been extensively used in the operation which appears to have involved potential money laundering activities detrimental to the genuine investors at large.

65. I further find that Shri Nigam v. Shahs occupation details, his financial details, name and designation of the employee who had interviewed him, as also, the agreement between the stock broker and the client have all been left blank in his Client Registration Form with Dynamic. A perusal of some other clients KYCs, of clients registered with Dynamic, also similarly revealed that all of the above crucial information have been kept blank in these KYCs as well. I further find from the Unique Client Code (UCC) database of Dynamic that 8 client codes have been assigned in the name of Shri Sameer C. Sanghvi, the other director of Dynamic. The explanation given by him does not appear to be satisfactory. As per the trade log of BSE, for the period June to January 20, 2009, I find that Dynamic has traded on BSE in the scrip of PSTL on its own account on a regular and continuous basis during the period, and some of the trades, though in very small quantities, have matched with the trades of Shri Nirmal Kotecha and Shri Amol Kokane. Of the bulk purchase of 1,52,789 shares done by Dynamic on January 01, 2009, I find that 5523 shares sold by Shri Nirmal Kotecha through broker M/s. J M Financial Services Ltd. and 2000 shares sold by Shri Kotecha through M/s. Vertex Securities Ltd. on that day has matched with Dynamics purchase. On the previous day, i.e. December 31, 2008, I find that again 1000 shares bought by Dynamic through M/s. Kotak Securities Ltd. have matched with the sale by Shri Kotecha.

ORDER

1. In view of the grave emergency arising out of the fact that a forged letter (purported to have been issued by SEBI) was sent to the promoters/Persons Acting in Concert of a listed company, Pyramid Saimira Theatre Limited, and taking into consideration the fraudulent, abusive, manipulative and illegal activities committed by certain entities/persons to the detriment of the genuine investors and adversely affecting the integrity of securities market, I find it necessary that SEBI as a Regulator should immediately intervene to restore the confidence of the investors and to stop further harm to investors from being committed by the persons, who prima facie have indulged in such activities. I find that the manipulative conduct has resulted in substantial losses to investors, who are left holding stocks with little or no value. It is SEBIs sacrosanct duty to make the securities market more credible and efficient by establishing and enforcing principles which ensure fairness, and, which prevent activities which damage investor confidence. In the instant case, the forgery was prima facie done to manipulate the stock price of Pyramid Saimira Theatre Limited. As brought out above, it prima facie emerges that Shri Nirmal Kotecha was one of the major beneficiaries of the said manipulation and has masterminded the forgery. Therefore, with a view to protect the interest of investors and securities market from further such acts, in exercise of the powers delegated to me in terms of Section 19 of the Securities and Exchange Board of India Act, 1992 read with Section 11, 11B and 11(4) (b) thereof and read with Regulation 11 of SEBI (Prohibition of Fraudulent and Unfair Trade Practices relating to Securities Market) Regulations, 2003, pending investigation and passing of final order, I hereby issue the following directions, by way of ad interim, ex-parte order:

2. The following persons/ entities who prima facie have, played a key role in the forgery, dissemination of the information contained in the forged letter to the media, and misleading the media to believe in the authenticity of the information that was circulated to them are directed not to buy, sell or deal in the securities market including in Initial Public Offerings, in any manner, either directly or indirectly, till further directions:

SR NO

NAME

BANK

BRANCH

BANK ACCOUNT NO.

PAN NO.

1

Nirmal Narendra Kotecha

HDFC BANK

MATUNGA

4241000014692

AEZPK2016H

2

Rakesh Sharma

HDFC BANK

BORIVALI (WEST)

5461000013182

AGZPS8586N

3

Rajesh Unnikrishnan









4

Pratheesh Kumar V. K.









3. The following persons/ entities of/ related/associated with Shri Nirmal Kotecha, who prima facie have played a key role in facilitating Shri Nirmal Kotecha in carrying out suspicious banking transactions, carrying out and disguising his manipulative intent and gaining advantage from the forgery, or otherwise, are directed not to buy, sell or deal in the securities market including in IPOs, directly or indirectly, till further directions:

SR NO

NAME

BANK

BRANCH

BANK ACCOUNT NO.

NAME OF PROPRIETOR/ DIRECTOR

PAN NO.

1

MANILAL DAMJI KOTECHA

HDFC BANK

MATUNGA

4241000014884



AEZPK2015E

2

VEENA N KOTECHA

HDFC BANK

MATUNGA

4241000019158





3

VIRAL DINESH DOSHI

HDFC BANK

MATUNGA

4241000033671



AJSPD4942P

4

KOTECHA CAPITAL SERVICES PVT LTD

HDFC BANK

MATUNGA

4242320000482

NIRMAL KOTECHA



5

NIRMAN MGT. SERVICES PVT. LTD.

HDFC BANK

MATUNGA

4242020000341

NIRMAL KOTECHA AND MANILAL D KOTECHA

AACCN3493P

6

NISHWET MGT. SERVICES PVT. LTD.

HDFC BANK

MATUNGA

4242020000238

NIRMAL KOTECHA AND SHWETA KOTECHA

AACCN2307A

7

DEEPAK THAKKAR









AAAPT5512C

8

AMOL ANAND KOKANE

BANK OF INDIA

D N ROAD BRANCH

1710100058428



AZZPK1169N

9

DARSHAN DESAI









ADTPD8926G

10

RAJESH VAMANRAI JANI

ICICI BANK

NARIMAN POINT

401009554



ACNPJ4374R, AABHJ9273K

11

RAJU GHANSHYAMDAS SHAH

AXIS BANK

VIRAR

023010100247221



AZHPS2985G

12

SHAILESH JAYANTILAL SHAH









AFDPS6203H

13

RAJESH JAYANTILAL SHAH









AFDPS6216A

14

BINABEN SHAILESHKUMAR SHAH









ANYPS5527K

15

NIRMAL ROHITBHAI SHAH









ANYPS5526J

16

RITABEN ROHITKUMAR SHAH









AFDPS6214C

17

MANISHABEN RAJESHKUMAR SHAH









ANYPS5523P

18

NITIN GORODIA









AAMPG0512D

19

NIMESH H. CHITALIA









ADGPC5953K

4. The promoter Shri P.S. Saminathan has prime-facie made misleading public announcements, only to create public interest in the scrip of PSTL, for facilitating Shri Nirmal Kotecha in offloading his shares in PSTL at artificially inflated price in the market, is directed not to access or buy, sell or deal in the securities market, including in Initial Public Offerings, in any manner, either directly or indirectly, till further directions.

5. From the evidence available till date that has been discussed in the order, I find that the acts of the above mentioned persons/entities including that of Shri Nirmal Kotecha, Shri P. S. Saminathan and other connected entites /associates/ persons are prima-facie in violation of Regulations 3 and 4 of Securities and Exchange Board of India (Prohibition of Fraudulent and Unfair Trade Practices Relating to Securities Market) Regulations, 2003.

6. In view of prima facie violation of code of conduct as specified under Schedule II of SEBI (Stock Brokers and Sub-Brokers) Regulations, 1992, I, in exercise of powers conferred on me in terms of Section 19 read with Sections 11(1), 11B and 11(4) of the Securities and Exchange Board of India Act, 1992 hereby prohibit M/s. India Capital Markets Pvt. Ltd. from entering into any fresh agreements with new clients in its operations as stock broker till further orders. I also simultaneously direct the Market Intermediaries Regulation and Supervisory Department (MIRSD) of SEBI to look into whether the transactions, being carried out in any of the client accounts registered at M/s. India Capital Market Pvt. Ltd. are suspicious in nature and whether there has been any unlawful breach of requirements prescribed in the margin collection system being followed at the branch, and submit their report within a months time, to enable the Board take a further view in the matter.

7. In view of prima facie violation of code of conduct as specified under Schedule II of SEBI (Stock Brokers and Sub-Brokers) Regulations, 1992, I, in exercise of powers conferred on me in terms of Section 19 read with Sections 11(1), 11B and 11(4) of the Securities and Exchange Board of India Act, 1992 also hereby prohibit M/s. Dynamic Stock Broking (India) Pvt. Ltd. from entering into any fresh agreements with new clients, in its operations as stock broker, till further orders. I also simultaneously direct the Market Intermediaries Regulation and Supervisory Department (MIRSD) of SEBI to carry out a detailed inspection of all activities of the broker M/s. Dynamic Stock Broking (India) Pvt. Ltd., including the conformance with the KYC requirements prescribed, and, submit their report within a months time, to enable the Board take a further view in the matter.

8. For the reason that M/s. Keynote Capital Limited has issued unfounded and questionable trade recommendation about the shares of PSTL which has had the effect of misleading investors, it is hereby prohibited from giving any trade recommendations in respect of companies listed in any of the recognized stock exchanges till further directions in this regard.

9. The following persons/ entities and their proprietors/ partners/ directors who, as per the investigation carried out so far, prima facie appear to have carried out suspicious banking transactions and have channeled these funds either directly or indirectly in the stock markets, are directed not to buy, sell or deal in the securities market including in Initial Public Offerings, in any manner, either directly or indirectly, till further directions:

SR NO

NAME

BANK

BRANCH

BANK ACCOUNT NO.

NAME OF PROPRIETOR/ DIRECTOR

PAN NO.

1

ADINO TRADING COMPANY PVT LTD

AXIS BANK

LAMINGTON ROAD

465010200004558

DINESH BAFNA/VINOD BAFNA



2

ADVANCE FINSTOCK PVT LTD.

AXIS BANK

PALANPUR, GUJARAT

256010200005289

ANAND HUNIA/POPATL AL SHAH/SANJAY HUNDIA/RAJES H HUDIA, KARUL SHAH



3

ALFA CERAMIC TRADING AGENCIES PVT LTD

AXIS BANK

THAKUR VILLAGE

572010200002639

MUKESH CHOKSI/JAYES H SAMPAT



4

ALKA DIAMOND

AXIS BANK

POWAI

246010200005258

GOPAL VERMA



5

ALLIANCE INTERMEDIARIES & I NETWORK

AXIS BANK

THAKUR VILLAGE

572010200001946

MUKESH CHOKSI/JAYES H SAMPAT



6

AMAN ENTERPRISES

AXIS BANK

CHURCHGA TE

695010200000480

GANESH JAIN

ACVPJ7984R

7

AMAR ENTERPRISES

AXIS BANK

NEWMARIN E LINES

233010200018179

PATEL RAKESH ROHITBHAI

APBPP1077N

8

AMAR TRADING CO.

I.O.B.

ASHRAM ROAD AHMEDABA D

CD-3069

BHAVIK H.SHAH

AQZPS 5222M

9

AMBE SALES CORPORATION

ICICI BANK LTD

GIRGAUN

641105000072

OMPRAKAHSAG ARMAL JAIN

AGYPJ8762C

10

AMOL ANAND KOKANE

BANK OF INDIA

D N ROAD

1710100058428



AZZPK1169N

11

AMRUT TRADING CO.

INDIAN OVERSEA S BANK

KALBADEVI ROAD

CD6704

BHAVIK HASMUKH SHAH

AQZPS5222M

12

ANAND MARATHE

AXIS BANK

FORT

004010200983075

ANAND MARATHE

AKWPM0699M

13

ANCHAL PROPERTIES PVT LTD

AXIS BANK

POWAI

246010200005951

PRAVEEN KUMAR JAIN/DATTARA M LADE



14

ANJALI AKHADE

AXIS BANK

NEW MARINE LINES

233010100203142

ANJALI AKHADE

AHKPA4470D

15

ANKIT ENTERPRISES

AXIS BANK

CHURCHGA TE

695010200000471

PARVIN SHAH

ALVPS52685M

16

ANKIT KUMAR PAGARIYA

AXIS BANK

LAMINGTON ROAD

465010100010177



ASLPP8026A

17

ARAVIND KUMAR SONI

AXIS BANK

BORIVALI(W)

018010100504942

ARVIND KUMAR SONI



18

ARIHANT GEMS

AXIS BANK

NEW MARINE LINES

233010200015446

ANKIT KUMAR PAGARIYA

ASLPP8026A

19

ASHOK METAL & TUBES

STANDAR D CHARTER ED BANK

23-25 M.G.ROAD

22506013282

JOSHI TARACHAND BHURARAM

AFRPJ9303F

20

ASHOK METAL CORP

AXIS BANK

NEWMARIN E LINES

233010200015950

DIRECTORS 1) KISHORMAL B JAIN, KIRAN K JAIN

AADPJ2942H

21

BAFNA EXIM P LTD

AXIS BANK

SPRINGFIEL DS

415010200001205

MUKESH JAIN / PRAVEEN KUMAR JAIN



22

BAGORIA ENTERPRISE

AXIS BANK

BURRA BAZAR

277010200019211

AMIT KUMAR BAGORIA

AHMPB7273R

23

BALAJEE DIAMOND

AXIS BANK

NARIMAN POINT BRANCH

173010200012005

ARVIND KUMAR SONI



24

BALAJI CORPORATION

STANDAR D CHARTER ED BANK,

23-25 M.G.ROAD

000022506031191

SHAH BANTY DINESH

BOMPS6427Q

25

BHAIRAV DIAMONDS

AXIS BANK

LAMINGTON ROAD

465010200002127

RAJENDRAKUM AR M JAIN

AFNPJ7710E

26

BHAIRAV TRADING CO

AXIS BANK

BHAYANDA R-WEST

575010200003339

BHIVRAJ B GUJAR

AMDPG8940L

27

BHAKTI TRADING

STANDAR D CHARTER ED BANK

23-25 M.G.ROAD

22505894587

BAFNA VINOD KUMAR

AIFPB1312F

28

BHAVANI TRADING CO

AXIS BANK

NARIMAN POINT

173010200015491

CHIRAG PATEL

ARSPP2297H

29

BINAL SHAH

AXIS BANK

NEW MARINE LINES

233010100120333

BINAL SHAH



30

BOSTON AGENCY

AXIS BANK

NEW MARINE LINES

233010200005050

MANGALRAM SHAH

AMFPS2966N

31

CAPETOWN MERCANTILE CO PVT

AXIS BANK

POWAI

246010200005234

PANKAJ JAIN



32

CHANDAN GEMS

AXIS BANK

NARIMAN POINT

173010200012139

UMESH NEMCHAND BUNTH

AMXPB1214G

33

CHANDU KHIMAVAT

AXIS BANK

CRAWFORD MARKET

294010100033345

CHANDU KHIMAVAT



34

CHOKNI DANI RESORT

AXIS BANK

NEW MARINE LINES

233010200002653

HUKUMCHAND JAIN

AAMCS29882L

35

CLASSIC ENTERPRISES

INDIAN OVERSEA S BANK

KALBADEVI ROAD

CD6707

JIGNESH AMRUTBHAI PATEL



36

CROWN METAL INDIA

STANDAR D CHARTER ED BANK

23-25 M.G.ROAD

22505684329

SHAH SURESH P

NOT AVAILABLE

37

D AMIT KUMAR

I.O.B.

KALBA DEVI RD

CD-6705

AMIT KUMAR S. SONETHA

BHOPS 7325A

38

DADA TRADING CO

AXIS BANK

BHAYANDA R-WEST

575010200003513

SANJAY RAI/RAMBHAR OS YADAV



39

DARSHAN TRADING CO.

AXIS BANK

VILE PARLE (WEST) BR

064010200009942

SOURABH RAJENDRA JAIN

AKDPJ4570F

40

DARSHANA CORPORATION

STANDAR D CHARTER ED BANK

23-25 M.G.ROAD

22505894773

SHAH MANGLARAM H

AMFPS2966N

41

DATAPRO

THE KAPOL CO-OP. BANK

BORIVALI (WEST)

CA4015

HEMAL H. GANDHI HUF



42

DEEP ENTERPRISE

AXISBAN K

NARIMAN POINT

173010200016074

DEEPAK BHATEVARA



43

DEEPAK STEEL CENTRE

STANDAR D CHARTER ED BANK

CHOWPATT Y

22405268218

RANMAL J BHANSALI

ACUPB4642D

44

DELUX METAL CORPORATION

STANDAR D CHARTER ED BANK

CHOWPATT Y

22405266975

CHAUHAN HASTIMAL P

NOT AVAILABLE

45

DEVAM IMPEX PVT LTD

AXIS BANK

AHMEDABA D

003010200066121

PIYUSH DAND



46

DHANLAXMI TUBES AND METAL

BANK OF BARODA,

V P ROAD BRANCH, MUMBAI - 400004



RAJUKUMAR AMARCHAND . BHANSALI

AABPB3080G

47

DIAMOND EXPORT

AXIS BANK

FORT

004010200517423

HUKMICHAND JAIN

ADCPJ9311Q

48

DINESH KUMAR M GUPTA

ICICI BANK LTD

DADAR BRANCH

3201016671

DINESH KUMAR M GUPTA

AABPG5149F

49

DOSHI TRADING CO.

ICICI BANK LTD

OPERA HOUSE BRANCH

34805003271

JAGDISH R DOSHI

ALOPB9958K

50

EDEX PRODUCTION AND BROADCASTING PVT

AXIS BANK

DADAR

124010200006002

PRITHI PAUL SETHI



51

EKTA SHARES AND

AXIS BANK

BORIVALI(W EST) BR

018010200030241

PRAMOD GADIA

ADUPG6871G

52

FASTSTONE TRADING CO PVT LTD

AXIS BANK

POWAI

246010200005302

PANKAJ JAIN



53

FERRO N ALLOYS

ICICI BANK,

OPERA HOUSE

000088106140661

SOHANLAL S. BISHNOI



54

FOREMOST MERCHANDISE

AXIS BANK

BORIVALI (WEST) BR

018010200029120

DINESH KUMAR JAIN

AABCF1921D

55

FUNKE HEAT EXCHANGER INDIA

ICICI BANK LTD

BUNDGRAD EN RD, PUNE

505008462

PETER FUNKE



56

GANESH TRADING CO

AXIS BANK

NEW MARINE LINES

233010200019062

DEEPAK D WAGHE

AAVPW1401E

57

GAUTAM KUMAR BHANSALI

AXIS BANK

NEW MARINE LINES

233010100265423



AJJPB5305N

58

GAYATRI GEMS

AXIS BANK

NEW MARINE

233010200018373

RATAN KUMAR AGRAWAL

AGFPA0894B







LINES







59

GENUS COMMU TRADE LIMITED

AXIS BANK

NEW MARINE LINES

233010200010265

VIRAG PATEL/HITESH PANCHAL



60

HARE KRISHNA EXPORT

AXIS BANK

NARIMAN POINT BRANCH

173010200012023

SONU BAFNA



61

HARI OM TRADING CO.

AXIS BANK

SPRINGFIEL DS, LOKHANDW ALA

415010200001250

APNESH RANGNATH SANGLE

BESPS6459A

62

HARISH METAL & TUBES

HDFC BANK

LOWER PAREL (WEST)

003562560005149

HARISH S JAIN

AHYPJ8223D

63

HEMA TRADING CO PVT LTD

AXIS BANK

POWAI

246010200005319

VASUDEO SOLIWAL



64

HETAL RAJESH PATEL

AXIS BANK

NASHIK

115010100385909





65

HI-CLASS DIAMOND EXPORTS P LTD

AXIS BANK

NEW MARINE LINES

233010200015905

PRAVEEN KUMAR LODHA, SANJAY KUMAR LODHA

AABCH9360G

66

HONEY INTERNATIONAL

AXIS BANK

NARIMAN POINT

173010200012245

OMPRAKASH SHRISHRIMAL

ASYPJ2705J

67

IMPEX SALES CORPN

AXIS BANK

NEW MARINE LINES

233010200004633

MANGLARAM SHAH

AMFPS2966N

68

INDIAN CORPN.

AXIS BANK

SPRINGFIEL DS

415010200001243

JAFARBHAI DANAVALA

AJGPD9220L

69

J H CHITALIA & CO.

BANK OF MAHARAS HTRA

BORIVALI (WEST)

000020115901202

JANAK HARKINSHAND AS. CHITALIA



70

J P ENTERPRISES

AXIS BANK

CRAWFORD MARKET

294010200007856

PANKAJ KUMAR JAIN

ADIPJ4296J

71

JAGAT ENTERPRISE

I.O.B.

ASHRAM ROAD AHMEDABA D

CD-3097

JIGNESH A.PATEL

AGAPP 3290K

72

JANAK METAL INDIA

STANDAR D CHARTER ED BANK

23-25 M.G.ROAD

22505922297

VISHNOI MANGILAL R

AEHPV3945C

73

JAVDA INDIA IMPEX LTD

AXIS BANK

POWAI

246010200005272

RAMESH JAVDA



74

JAY AMBE MARBLES

STANDAR D CHARTER ED BANK

23-25 M.G.ROAD

22505752766

SURESH JAIN

AFFPJ8944J

75

JODHARAM BISHNOI

AXIS BANK

CRAWFORD MARKET

294010100033327

JODHARAM BISHNOI

AJIPB7825P

76

JPK TRADING I PVT LTD

AXIS BANK

NEW MARINE LINES

233010200019257

MANISH JAIN



77

JYOTI ENTERPRISES

AXIS BANK

BHAYANDA R-WEST

575010200003896

RAKESH KUMAR SEN

BATPS1606L

78

KALASH DIAM

AXIS BANK

BHAYANDE R WEST

575010200002967

PAWANKUMAR S TIWARI

AFWPT7162H

79

KALASH DIAMONDS

AXIS BANK

NARIMAN POINT

173010200015969

PAWAN KUMAR TIWARI

AFWPT7162H

80

KALPANA CORPORATION

AXIS BANK

CRAWFORD MARKET

294010200007061

KALPANA A SHAH

BHHPS5861S

81

KALYAN KIRTI INTERNATIONAL

AXIS BANK

CHURCHGA TE

695010200000453

MANGLARAM SHAH

AMFPS2966N

82

KAMAL DIAMONDS

AXIS BANK

NARIMANPO INT

173010200010885

SONU BAFNA, KAMLESH

NOT AVAILABLE











DHAMMANI



83

KAMLESH DHAMMAN

AXIS BNAK

NEW MARINE LINES

233010100315692

KAMLESH DHAMMAN



84

KANAK IMPEX

AXIS BANK

NARIMAN POINT

173010200015826

MAHENDRA JAIN

AIIPJ8463C

85

KANCHAN IMPEX

AXIS BANK

NEW MARINE LINES

233010200018160

SUSHIL MEHTA

AHPPM9754K

86

KASTBHANJANDEV DEVELOPERS

AXIS BANK

AHMEDABA D

003010200051484

ASHWINBHAI PATEL/BIPINCH ANDRA BHATT

ANMPP3820G /ACLDB9082C

87

KESHARIYA DIAM PVT LTD

AXIS BANK

BHAYANDA R-WEST

575010200003032

VIJAY NARENDRA KOTHARI, PAWANKUMAR TIWARI

AADCK2217M

88

KESHAV IMPEX

AXIS BANK

NARIMAN POINT

173010200014155

ANIL CHOKHARA

AGZPC7831L

89

KHUSHI CORPORATION

AXIS BANK

NARIMAN POINT

173010200013998

PREM PRAKASH TAILOR

AHSPT9280G

90

KIRTI ENTERPRISES

AXIS BANK

NARIMAN POINT

173010200014757

PREM PRAKASH TAILOR

AHSPT9280G

91

KOHINOOR INVESTMENT

HDFC BANK LTD

FORT BRANCH

00602020003219

AMOL ANAND KOKANE

AZZPK1169N

92

KOTSONS IMPEX PVT. LTD.

AXIS BANK

LAMINGTON ROAD

465010200002189

DHARMENDRA KOTHARI, CHANDRAMOH AN VERMA

AACCK9104C

93

KRINA GEMS

AXIS BANK

NARIMANPO INT

173010200003537

KAMLESH SHAH

NOT AVAILABLE

94

KUNAL GEMS

AXIS BANK

POWAI

246010200005609

ASHOK RATAN SONI

AAOPV6321K

95

KUSH HINDUSTAN ENT

AXIS BANK

POWAI

246010200005289

AJAY DIXIT



96

KUSH INTERNATIONAL

AXIS BANK

POWAI

246010200005616

RAMESH JAVDA

ABCPJ7139G

97

LANKA DIAM

AXIS BANK

LAMINGTON ROAD

465010200002240

GANPAT P BHADIRKE



98

LARSEN EXPORTS

AXIS BANK

LAMINGTON ROAD

465010200001625

LAXMANCHAN D JAIN

ACXPJ4337Q

99

LEENA GEMS

AXIS BANK

LAMINGTON RD

465010200001083

RAJESH ZAVERI

NOT UPDATED

100

LEXUS INFOTECH LTD

AXIS BANK

POWAI

246010200005265

ROSE PADBIDRI



101

LOVE KHUSH

AXIS BANK

CRAWFORD MARKET

294010200005210

JODHARAM BISHNOI

AJJPB7825P

102

LUXURY TRADING CO.

AXIS BANK

BHAYANDA R-WEST

575010200003520

SANJAY RAI/ RAM BHAROS YADAV



103

M G CORPORATION

AXIS BANK

CRAWFURD MARKET

294010200005562

NANDALAL G NAGPAL

ADFPN5684B

104

M M DIAMOND P LTD

AXIS BANK

NEW MARINE LINES

233010200015604

MAHESH PYARELAL MEHTA

AEQPM5416E

105

MAHAK IMPEX

AXIS BANK

NEW MARINE LINES

233010200011060

MOHANLAL JAIN (HUF)

AAEHM7566H

106

MAHALAXMI CORP.

AXIS BANK

NEW MARINE LINES

233010200019053

ASHWIN PATEL

ANFPP7250H

107

MAHAVIR CORPORATION

STANDAR D CHARTER ED BANK

23-25 M.G.ROAD

22505894846

BAFNA VINOD KUMAR

AIFPB1312F

108

MAHENDRA JAIN

AXIS BANK

NEW MARINE LINES

233010100277983



AIIPJ8463C

109

MANAN TRADING PVT LTD

AXIS BANK

NARIMAN POINT

173010200015084

JITENDRA K JAIN & RAJENDRA RANKA & PRAKASH JAIN

AADCM5896J

110

MANISH ENTERPRISES

AXIS BANK

DAHISAR(W)

701010200000620

RAMU PEMA GUJJAR



111

MANN IMPEX

AXIS BANK

BHAYANDA R-WEST

575010200003063

BHAGWAN SINGH

BSWPS8701D

112

MANOJ KUMAR

AXIS BANK

LAMINGTON ROAD

465010100009928



AKKPM3857F

113

MASTER SURVEYORS & CONTRACTORS

AXIS BANK

DEVALALI, NASHIK

779010200000231

SURESH THANAGE



114

MATRIX EXPORTS

AXIS BANK

BORIVALI (WEST) BR

18010200028495

VASANT KUMAR P

AMXPM9372L

115

MAULIK DIAMONDS

AXIS BANK

NARIMAN POINT

173010200015039

DILKUSH BABEL

AMLPB2470Q

116

MAYA JEWELS PVT LTD

AXIS BANK

CRAWFORD MARKET

294010200006040

DIRECTOR 1) MAHENDRA AMRITLAL JAIN, VIKRAM AMRITLAL JAIN, GIRISH AMRITLAL JAIN

AAFCM5335G

117

MEET CORPORATION

AXIS BANK

POWAI

246010200005227

AASHISH MAHAWAR

APMPM2937B

118

MEGHA TRADERS

AXIS BANK

NARIMAN POINT

173010200012236

DESHRAJ JAT

AFHPJ6071J

119

MIHIR AGENCIES P LTD

AXIS BANK

THAKUR VILLAGE

572010200002592

MUKESH CHOKSHI / JAYESH SAMPAT



120

MILAN GEMS

AXIS BANK

NEW MARINE LINES

233010200015437

MANOJ KUMAR MEHTA

AKKPM3857F

121

MOHANLAL B JAIN

AXIS BANK

NEW MARINE LINES

233010100177726



AABPJ1092Q

122

MOHIT INTERNATIONAL

AXIS BANK

POWAI

246010200005586

NILESH PARMAR

AIXPP8680Q

123

MUKTA INTERNATIONAL

AXIS BANK

NEW MARINE LINES

233010200013934

RAKESH H JAIN



124

N R SECURITIES

HDFC BANK

FORT

000602020003184

AMOL ANAND KOKANE

AZZPK1169N

125

NATASHA ENTERPRISE

AXIS BANK

POWAI

246010200005593

ROSE PADBIDRI

AIPPP6372H

126

NAVKAR TRADING CO

AXIS BANK

PANIPAT

240102000008839

ASHISH JAIN

NOT UPDATED

127

NAVKAR TRADING CO

AXIS BANK

BHAYANDA R-WEST

575010200003322



AOHPG2600R

128

NEER TRADERS

AXIS BANK

NEW MARINE LINES

233010200010539

GEETA JADHAV/HUKM ICHAND JAIN

AACPJ9676P

129

NEW PLANET TRADING CO LTD

AXIS BANK

NEW MARINE LINES

233010200019512

VIRENDRA ABHANI & ROSE PADDIBIRI

AABCN8176E

130

NEW WAVE MERCANTILECOMPANY

AXIS BANK

NEW MARINE LINES

233010200004732

GOPAL KHATRI/AVINA SH TRIMAKE



131

NIGAM VINOD SHAH

AXIS BANK

SODAWALA LANE, BORIVALI (WEST)

018010100237734



AWEPS0987Q

132

NIRMAL ENTERPRISES

STANDAR D CHARTER ED BANK

PUNE

22905026957

SHARMA SANJAY MANILAL

AQQPS1225P

133

OM ASSOCIATES

AXIS BANK

THAKUR VILLAGE , KANDIVALI EAST

572010200003001

KANTILAL SAMELAJI PUROHIT

APTPP6092D

134

OM CORPORATION

AXIS BANK

NEWMARIN E LINES

233010200017754

CHIRAG PATEL

ARSPP2297H

135

OM CORPORATION

AXIS BANK

BORIVALI

018010200029023

SHANTILAL PRAJAPAT

NOT UPDATED

136

OMEGA PETRO PLAST

I.O.B.

BORIVALI

CD-2770

SURYAJI K BHONDE

AMJPBS 4612J

137

ORBIT GEMS

AXIS BANK

NARIMAN POINT

173010200013138

VINIT JAIN

AHMPJ0332K

138

OSTWAL TRADING I PVT LTD

AXIS BANK

POWAI

246010200005524

MANISH JAIN

AAACO7995M

139

P R DIAMONDS

AXIS BANK

NARIMAN POINT

173010200015020

NARAYAN LAL SHARMA

AEUPS4865H

140

PADMAVATI METAL & ALLOYS

STANDAR D CHARTER ED BANK

23-25 M.G.ROAD

22506013231

JAIN SURESH

AFSPJ4124P

141

PARAS GEMS

AXIS BANK

NEW MARINE LINES

233010200007627

RATANKUMAR D AGARWAL

AGFPA0894B

142

PARASMANI TUBES PVT LTD

STANDAR D CHARTER ED BANK

CHOWPATT Y

22405343341

VOHERA PIYUSH CHANDULAL

AABCP7664D

143

PATTANI YOGESH B

AXIS BANK

NASHIK

115010200017091





144

PRACHI GEMS

AXIS BANK

NARIMAN POINT

173010200015057

RAJENDRA K RANKA

ACRPR7932F

145

PRITESH A PATEL

AXIS BANK

DEVALALI, NASHIK

779010100046774





146

PRIYANSH EXPORTS

AXIS BANK

SPRINGFIEL DS

415010200001267

JITENDRA KUMAR JAIN

AHNPJ5721D

147

PROFICIENT INFRA P LTD

AXIS BANK

NARIMAN POINT

173010200013396

ASHOK JAIN

AAECP5791Q

148

PUSHPA DIAM PVT LTD

AXIS BANK

NARIMAN POINT

173010200010894

DULRAJ JAIN & ASHOK JAIN

NOT UPDATED

149

R B TRADERS

AXIS BANK

WORLINAKA

653010200001601

RAVI KUMAR JAIN



150

R K TRAVELS

AXIS BANK

SPRINGFIEL DS

415010200001151



AJGPD9220L

151

R S ENTERPRISES

AXIS BANK

NEW MARINE LINES

233010200007634

RATANKUMAR AGARWAL & SUNIL KUMAR AGARWAL

AFSPA5223J

152

RAGHUKUL DIAM PVT LTD

AXIS BANK

NEW MARINE LINES

233010200021049

NIRMAL JAIN & SANJAY TIWARI

AADCR6608P

153

RAGHUNANDAN RAYONS LTD

AXIS BANK

NEW MARINE LINES

233010200019017

UTTAMCHAND HINGER



154

RAJ ALLOYS AND STEEL PVT LTD

AXIS BANK

LAMINGTON ROAD

465010200002714

RAJKUMAR JAIN/NITIN SHAH



155

RAJ DIAMONDS

AXIS BANK

NARIMAN POINT

173010200015093

PANKAJ SINGHI

BLFPS2616R

156

RAJ RATNA JEWELLERS

AXIS BANK

KANDIVALI WEST, MAHAVIR NAGAR

201010200006781

NIRMAL K BHAVSAR

AFZPB3668K

157

RAJ TRADERS

AXIS BANK

THAKUR VILLAGE

572010200002998

AVICHAL SONI

BHTPS1033E

158

RAJESH JAIN

AXIS BANK

LAMINGTON ROAD

465010100011714



AIJPS3849H

159

RAJESH PAMECHA

AXIS BANK

NEW MARINE LINES

233010100001342



AEZPP6573L

160

RAJESH VAMANRAI JANI

ICICI BANK

NARIMAN POINT

000000401009554





161

RAJKAMAL STEEL

STANDAR D CHARTER ED BANK

23-25 M.G.ROAD

22505894544

BAFNA VINOD KUMAR

AIFPB1312F

162

RAJU G SHAH

AXIS BANK

VIRAR

023010100247221



AZHPS2985G

163

RAKHI GEMS

AXIS BANK

NEW MARINE LINES

233010200016986

VIPUL SHARMA



164

RATAN ENTERPRISES

AXIS BANK

CRAWFORD MARKET

294010200006804

OATMAL PUROHIT



165

RATAN EXPORTS

AXIS BANK

NEW MARINE LINES

233010200015020

YOGESH KUMAR SANCHETI

AHEPS6566L

166

RAVI ENTERPRISES

AXIS BANK

NARIMAN POINT

173010200012698

BABULAL JAIN



167

RAVI EXPORTS

AXIS BANK

NEW MARINE LINES

173010200013855

RAVI PRAKASH JAIN

AKJPJ6022E

168

REALGOLD TRADING CO. PVT LTD

AXIS BANK

POWAI

246010200005326

NILESH PARMAR



169

RELIANT METAL CORPORATION

STANDAR D CHARTER ED BANK

23-25 M.G.ROAD

22505894315

RAJPUROHIT ARJUN P

ALAPR6303A

170

RENISHA IMPEX PVT LTD

AXIS BANK

NARIMAN POINT

173010200009591

DINESH JAIN / DULRAJ JAIN



171

RIDDHI SIDDHI MULTITRADE LTD

AXIS BANK

NEW MARINE LINES

233010200019114

PANKAJ JAIN



172

RIDHAM ENTERPRISES

AXIS BANK

NEW MARINE LINES

233010100008853

RAJKUMAR AGRAWAL

AFSPA5222K

173

ROHIT TRADING CO.

AXIS BANK

NEW MARINE LINES

233010200017329

KAMAL THAKUR

ADXPT2249Q

174

ROOP IMPEX

AXIS BANK

NARIMAN POINT

173010200008716

DULRAJ U JAIN

ABTPJ4754E

175

RUKAMANI GEMS

AXIS BANK

NEWMARIN E LINES

233010200013989

RAJESH JAIN

AIJPJ3849H

176

S K IMPEX

AXIS BANK

LAMINGTON ROAD

465010200003049

MAHENDRAKU MAR BISHNOI

ACRPB9546E

177

SAGAR TRADING CO

STANDAR D CHARTER ED BANK

23-25 M.G.ROAD

22505551442

SHAH SURESH P

NOT AVAILABLE

178

SAHARA IMPEX (INDIA)

BANK OF BARODA,

V P ROAD BRANCH, MUMBAI -



VASTUPAL M. JAIN

ADOPJ2732P







400004







179

SAHIL JEWEL

AXIS BANK

NARIMAN POINT

173010200011857

POONAM JAIN

AIZPJ6835D

180

SAI KRUPA TRADING

AXIS BANK

NARIMAN POINT

173010200015066

NAVRATAN S JAIN

AHYPJ4038J

181

SAI LEELA TRADING PVT LTD

AXIS BANK

LAMINGTON ROAD

465010200002172

VIJAY SURESH TAWARE, NITIN ARJUN GHARAT

AAKCS4578C

182

SANDEEP STEEL INDUSTRIES

ICICI BANK LTD

GIRGAUN

641105000101

BABULAL K BISHNOI

AHZPB11158

183

SANJIVANI ENVIRO PROTECTION LTD

AXIS BANK

NEW MARINE LINES

233010200019150

VIRENDRA ABHANI/ JITENDRA TATER/VASUD EV SOLIWAL



184

SANSKAR TRADING CO

AXIS BANK

BHAYANDE R WEST

575010200003049

GANAPAT LAL

ADGPL2513A

185

SAPNA DIAMOND

AXIS BANK

NEW MARINE LINES

233010200010548

SUSHIL MEHTA

AHPPM9754K

186

SARITA DIAMONDS

AXIS BANK

NEW MARINE LINES

233010200016977

JITENDER JAIN

AFOPJ3543C

187

SBJ TRADING PVT LTD

AXIS BANK

NEW MARINE LINES

233010200019044

MANISH JAIN/ PRAVEEN JAIN



188

SHAH TRADING CO

AXIS BANK

VIRAR

023010200019752

HETAL R SHAH

NOT UPDATED

189

SHAKTI TRADING CO

STANDAR D CHARTER ED BANK

23-25 M.G.ROAD

22506013487

BAFNA VINOD KUMAR

AIFPB1312F

190

SHANKESHWAR TRADERS PVT LTD

AXIS BANK

BHAYANDA R-WEST

575010200003346

JAVARILAL GAUTAMCHAH D JAIN



191

SHASHIKANT P BAYANI

ICICI BANK LTD

NARIMAN POINT BRANCH

401138671

SHASHIKANT P BAYANI

AAHPB3652Q

192

SHIYON ENTERPRISE

AXIS BANK

NEWMARIN E LINES

233010200015039

CHANDRAKAN T PATEL

AOZPP4246C

193

SHREE EARTH MOVERS & LAND DEVELOPERS

AXIS BANK

NASHIK

115010200013299

RAJEMDRA JANARDAN SURVE



194

SHREE EXPORT

AXIS BANK

NARIMAN POINT

173010200009140

ASHOK SHRISHRIMAL

NOT UPDATED

195

SHREE FORGE INDUSTRIES

ICICI BANK LTD

HUGES ROAD

41605000091

BABULAL K BISHNOI

AERPB1242C

196

SHREE RAMDEV METAL

AXIS BANK

LAMINGTON ROAD

465010200002790

OKHARAM RAMSHIJI CHOUDHARY

AGFPC9225L

197

SHRI GANESH GEMS

AXIS BANK

NEW MARINE LINES

233010200016524

SUKHPAL PRAJAPAT

NOT UPDATED

198

SHUBH TRADING CO

AXIS BANK

BHAYANDA R-WEST

575010200003902

LALARAM GUJAR

APRPG3369G

199

SHUBHAM EXPORTS

AXIS BANK

NEW MARINE LINES

233010200016056

GAUTAM KUMAR BHANSALI

AJJPB5305N

200

SIDDHAM EXPORTS

AXIS BANK

BHAYENDE R(W)

575010200003117

JAFARBHAI DANAVAL A



201

SIGMA TOURS & TRAVELS

AXIS BANK

NARIMAN POINT

173010200014331

KAMAL B THAKUR

ADXPT2249Q

202

SIMI IMPEX

AXIS BANK

NARIMAN POINT

173010200011705

SANDEEP S RATHORE

ALUPR5979E

203

SONAL GEMS TRADING P LTD

AXIS BANK

NEW MARINE LINES

233010200016834

HUKMICHAND JAIN / GEETA JADHAV



204

SOUNDARYA GRANITE & MARBLE

STANDAR D CHARTER ED BANK

23-25 M.G.ROAD

22505752758

SURESH JAIN

AFFPJ8944J

205

STAR ENTERPRISES

AXIS BANK

NEW MARINE LINES

233010200015677

PAWAN TARACHAND JAIN

AIAPJ2539D

206

STAR GEMS

AXIS BANK

NARIMANPO INT

173010200011875

BHAGIRATHI PUHAN

ARTPP7106J

207

SU JEWELS EXIM PRIVATE LIMITED (ERSTWHILE CHOKHI DHANI RESORTS P LTD)

AXIS BANK

NEW MARINE LINES

233010200002653

HUKMICHAND JAIN, GULAB JAIN



208

SUNBLINK TRADING AND INVT LTD

AXIS BANK

CRAWFORD MARKET

294010200004787

SANDEEP DALAL/RAJEND RAKUMAR BHIMRAJKA



209

SUNCHAN SECURITIES LTD

AXIS BANK

BANDRA

028010200004954

SUNIL MANSINGHANI /KANCHAN MANSINGHANI



210

SUPER GOLD TRADIN CO PVT LTD

AXIS BANK

NEW MARINE LINES

233010200012740

GEETA JADHAV & HUKUMCHAND JAIN

AAHCS7254E

211

SUPRE GOLD TRADERS

AXIS BANK

NEW MARINE LINES

233010200012740

GEETA JADHAV



212

SWASTIK DIAM PVT LTD

AXIS BANK

NARIMAN POINT

173010200009164

DULRAJ JAIN & DINESH JAIN

ABOPJ2176M

213

TAMANNA GEM

AXIS BANK

NEW MARINE LINES

233010200016533

GHEVARCHAN D B PAMECHA

AFWPP6341Q

214

TARACHAND BHOORCHAND JAIN

STANDAR D CHARTER ED BANK

CHOWPATT Y

22410417102

-

NOT AVAILABLE

215

TRITOP TRADING PVT LTD

AXIS BANK

BORIVALI- WEST

018010200029953

BHASKAR UBARE



216

U M EXPORTS

AXIS BANK

NEWMARIN E LINES

233010200010973

MAHESH MEHTA

AEQPM5416E

217

U P MERCANTILE CREDIT SAHAKARI LTD

AXIS BANK

INDORE

043010100641593

RAKHI GAUTAM/DINE SH TRIPATHI/VIRE NDRA YADAV



218

UMA EXPORT

AXIS BANK

NARIMAN POINT

173010200013545

UMAKANT MUDULI

ABTPJ4754E

219

UMESH BUNTH

AXIS BANK

NARIMAN POINT

173010100106825

UMESH N BUNTH

AMXPB1214G

220

UNIVERSAL TRADERS

AXIS BANK

NARIMAN POINT

173010200013253

BHAGIRATHI PUHAN

ARTPP7106J

221

VALIANT METAL

STANDAR D CHARTER ED BANK

23-25 M.G.ROAD

22505893653

KANUNGO PIYUSH

APTPK5975N

222

VANGUARD JEWELS LIMITED

AXIS BANK

POWAI

246010200005241

UMA KANSARIA



223

VIJAYLAXMI CORPN.

AXIS BANK

THAKUR VILLAGE

572010200002653

MUKESH CHOKSI

AAAPC7767J

224

VIMAL DIAMOND

AXIS BANK

NARIMAN POINT

173010200012254

VIMAL JAIN

AEUPJ3948Q

225

VINOD KUMAR BAFNA

STANDAR D CHARTER ED BANK

23-25 M.G.ROAD

22510936721

-

AIFPB1312F

226

VIRAT STAINLESS INDIA

KOTAK MAHINDR A

MODEL TOWN NEW DELHI

001852000001294

RAM MILAN PAL

ALHPP5125B

227

VIREN TRADE AGENCY

THE JAIN SAHAKAR I BANK LTD.

BORIVALI (WEST)

056/0000700

PRAFUL PARSHOTTAMD AS VORA



228

VISHNULENE SYNTHETICS PRIVATE LIMITED

AXIS BANK

NEW MARINE LINES

233010200013800

HUKMICHAND JAIN / GULAB JAIN



229

YASH V JEWELS LTD

AXIS BANK

POWAI

246010200005296

JAYANT KANSARA



230

YASHRAJ ENTERPRISE

AXIS BANK

BHAYANDA R-WEST

575010200003636

SUKHRAJ TARACHAND JAIN

ACQPJ7210D

10. As the transactions discussed in the Order (including Shri Nirmal Kotechas transactions and his relatives/related entities transactions) prima facie, appears to be linked to potential money laundering activities detrimental to the genuine investors at large, a copy of this Order is also being sent to the Director, Financial Intelligence Unit (FIU) - India and to the Reserve Bank of India (RBI) for necessary action against the concerned entitles/persons as deemed fit by them.

11. It was observed that number of front accounts were used prima facie by Shri. Nirmal Kotecha and his associates/ relatives, as stated above, to manipulate the securities market. I also find it appropriate to bring the financial transactions observed in this Order to the attention of the Income Tax Department. Hence, a copy of the order is also being sent to the Income Tax Department for their information and further necessary action, as the Income Tax Department deems fit.

12. A copy of the order shall also be sent to the Depositories for necessary action.

13. This order shall be treated as show cause notice against the entities/persons named hereinabove. The entities/persons against whom this order is issued may file their objections, if any, to this order within thirty days from the date of this order and, if they so desire, avail of an opportunity of personal hearing (after making a request in this regard) at the Securities and Exchange Board of India, Head Office, SEBI Bhavan, C-4A, G Block, Bandra Kurla Complex, Bandra (East) Mumbai - 400051. They may also inspect the relevant documents, if they so desire, on any working day prior to the hearing during office hours at the above mentioned address

14. This order shall come into force with immediate effect.