BEFORE THE ADJUDICATING · PDF fileGangotri was traded in both NSE & BSE. Details of price volume data at BSE & NSE for the period April 07, 2006 to May 31, 2006 are as follows:

Adjudication Order in respect of M/s Quantum Global Securities and Leasing Company Limited in the matter

of M/s Gangotri Textiles Limited

Page 1 of 29 July 22, 2014

BEFORE THE ADJUDICATING OFFICER

SECURITIES AND EXCHANGE BOARD OF INDIA

[ADJUDICATION ORDER NO. JJ/AK/AO-105/2014]

UNDER SECTION 15-I OF SECURITIES AND EXCHANGE BOARD OF INDIA

ACT, 1992 READ WITH RULE 5 OF SEBI (PROCEDURE FOR HOLDING

INQUIRY AND IMPOSING PENALTIES BY ADJUDICATING OFFICER) RULES,

1995

In respect of

M/s Quantum Global Securities and Leasing Company Limited

(PAN No. AAACQ0053A)

In the matter of Gangotri Textiles Limited

FACTS OF THE CASE IN BRIEF

1. Securities and Exchange Board of India (hereinafter referred to as “SEBI”)

conducted investigation in respect of buying, selling and dealing in the

shares of Gangotri Textiles Limited (hereafter referred to as

“Gangotri”/“Company”/“scrip”), during the period from April 07, 2006 to

May 31, 2006 (hereinafter referred to as “Investigation Period”). The

shares of Gangotri are listed on the BSE Limited (hereinafter referred to as

“BSE”), National Stock Exchange (hereinafter referred to as “NSE”),

Calcutta Stock Exchange, Madras Stock Exchange and Coimbatore Stock

Exchange, but during the investigation period the scrip was traded only at

NSE and BSE.

Price-Volume Analysis:

2. Before Investigation Period (January 2006 to April 6, 2006): It was observed

that the scrip of Gangotri was not listed in NSE during January 2006 to April

6, 2006 and it was only traded in BSE. The highest price during this period



Page 2 of 29 July 22, 2014

was ` 52.25 (intra day high on February 6, 2006) and lowest price during

this period was ` 40.55 (intra day low on March 28, 2006). The average

daily traded quantity during this period was for 77,036 shares.

3. During Investigation Period (April 7, 2006 to May 31, 2006): The scrip of

Gangotri was traded in both NSE & BSE. Details of price volume data at

BSE & NSE for the period April 07, 2006 to May 31, 2006 are as follows:-

It was observed that during investigation period the price of the scrip

went up by 33.24% in BSE and 26.88% in NSE while the Sensex

recorded a decrease of 12.21% (from 11845.13 on April 07, 2006 to

10398.61 on May 31, 2006) and Nifty recorded a decrease of 12.89%

(from 3525.6 on April 07, 2006 to 3071.05 on May 31, 2006).

The price of the scrip mainly increased from April 20, 2006 to May 05,

2006, i.e. during these 12 trading days, the price of the scrip has

increased from ` 41.2 / 43 (NSE/BSE) on April 19, 2006 to `

71.05/70.95 (NSE/BSE) on May 05, 2006 a rise of 72.45%/65%

(NSE/BSE) along with volume spurt.

As on March 06, 2013 the price of the scrip at NSE and BSE was

`2.55 and `2.24 respectively.

4. After Investigation Period (June 2006 to December 2006): The scrip of

Gangotri was opened at ` 45.95 / 45.2 (NSE/BSE) on June 1, 2006 and

closed at `27.35 / 26.7 (NSE/BSE) on December 29, 2006. The highest

price during this period was ` 46.25 in (intra day high on June 2, 2006) in

NSE and ` 46.65 (intra day high on June 5, 2006) in BSE. The lowest price

Exchange Open High Low Close Volume Average Daily Volume

BSE 53.25 April 07, 2006

70.95 May 05, 2006

43.00 April 19, 2006

44.35 May 31, 2006

8941975 241675

NSE 56.00 April 07, 2006

71.05 May 05, 2006

41.25 April 19, 2006

45.40 May 31, 2006

6816750 184236



Page 3 of 29 July 22, 2014

during this period was ` 24 (intra day low on December 13, 2006) in both

NSE and BSE. The average daily traded quantity during this period was for

34,080 / 43,717 (NSE/BSE) shares.

5. The role of the entities who had traded in the scrip of Gangotri was

scrutinized. It was observed during the investigation period that certain

entities viz. Sunita Gupta (hereinafter referred to as "Sunita"), Purshottam

Khandelwal (hereinafter referred to as "Purshottam") Cosmo Corporate

Services Limited (hereinafter referred to as "Cosmo"), Ishita Finstock

Limited (hereinafter referred to as "Ishita"), Master Finlease Limited

(hereinafter referred to as "Master"), Avisha Credit capital Limited

(hereinafter referred to as "Avisha"), Vishvas Projects Limited (hereinafter

referred to as "VPL"), Praveen Poddar (hereinafter referred to as

"Praveen"), Quantum Global Securities and Leasing Company Limited

(hereinafter referred to as “Quantum”), Mefcom Securities Limited

(hereinafter referred to as “Mefcom” ), ISF Securities Ltd (hereinafter

referred to as “ISF”), Vishvas Securities Limited (hereinafter referred to as

“VSL”), Anupama Communications Private Limited (hereinafter referred to

as “Anupama”) and SIC Stock Brokers and Services Private Limited

(hereinafter referred to as “SIC”) {collectively referred to as Vishvas

Group} had allegedly executed synchronized trades, circular trades and

reversal trades among themselves and traded in significant variation to the

Last Traded Price (LTP) in the shares of Gangotri.

6. It was alleged that one of the entities, M/s Quantum Global Securities and

Leasing Company Limited (hereinafter referred to as

"Quantum"/"Noticee") had violated the provisions of section 12A(a),

12A(b), 12A(c) of Securities and Exchange Board of India Act, 1992

(hereinafter referred to as "SEBI Act") and Regulations 3(a), 3(b), 3(c),

3(d), 4(1), 4(2)(a), 4(2)(e) and 4(2)(g) of SEBI (Prohibition of Fraudulent and

Unfair Trade Practices relating to Securities Markets) Regulations, 2003



Page 4 of 29 July 22, 2014

(hereinafter referred to as “PFUTP Regulations”) and regulation 7 read

with clause A(1), A(2), A(3), A(4) and A(5) of Code of Conduct for Stock

Brokers specified under schedule II of the SEBI (Stock Brokers and Sub

Brokers) Regulations 1992, (hereinafter referred to as “Broker

Regulations”) and therefore, liable for monetary penalty under sections

15HA & 15HB of SEBI Act.

APPOINTMENT OF ADJUDICATING OFFICER

7. Shri Piyoosh Gupta was appointed as Adjudicating Officer, vide order dated

August 08, 2013 under section 15-I of Securities and Exchange Board of

India Act, 1992 (hereinafter referred to as “SEBI Act”) and rule 3 of SEBI

(Procedure for Holding Inquiry and Imposing Penalties by Adjudicating

Officer) Rules, 1995 (hereinafter referred to as “Rules”) to enquire into and

adjudge under sections 15HA & 15HB of the SEBI Act for the alleged

violations of provisions of sections 12A(a), 12A(b), 12A(c) of SEBI Act and

Regulations 3(a), 3(b), 3(c), 3(d), 4(1), 4(2)(a), 4(2)(e) & 4(2)(g) of PFUTP

Regulations and regulation 7 read with clause A(1), A(2), A(3), A(4) and

A(5) of Code of Conduct for Stock Brokers specified under schedule II of

Broker Regulations by Quantum. Consequent, to the transfer of Shri

Piyoosh Gupta, the undersigned was appointed as Adjudicating Officer vide

order dated November 08, 2013 to enquire and adjudge the matter.

SHOW CAUSE NOTICE, HEARING AND REPLY

8. Show Cause Notice reference no. EAD/JJ/AK/32193/2013 dated

December 12, 2013 (hereinafter referred to as “SCN”) was issued to the

Noticee under rule 4(1) of the Rules to show cause as to why an inquiry

should not be held against the Noticee and penalty be not imposed under

sections 15HA and 15HB of SEBI Act for the alleged violations specified in

the said SCN. The said SCN was duly delivered to the Noticee.



Page 5 of 29 July 22, 2014

9. In the interest of natural justice and in order to conduct an inquiry as per

rule 4(3) of the Rules, the Noticee was granted an opportunity of personal

hearing on February 28, 2014 at SEBI, Head Office, Mumbai, vide notice

dated February 11, 2014. The said Notice of Inquiry dated February 11,

2014 was duly delivered to the Noticee. However, I find that Noticee

neither appeared for hearing scheduled on February 28, 2014 nor

requested for adjournment of hearing.

10. The Noticee vide letter dated February 21, 2013 and May 13, 2014, inter

alia made the following submissions:

“……….

In reference to your abovesaid notice, it is being submitted that we are not

directly or indirectly connected with the brokers mentioned in SCN para

No.6. with entities mentioned at Sr. No. 4,5,7,10 and 12.

We are doing business in normal course and have no malafide intention to

cheat any one.

we are unable to understand how we have been implicated in the SCN and

if it is true we are not aware of it.

We regret the mistake on our part and request you to take lenient view

because we are small broker which can be judge for our turnover for the

last three years.

We again regret our mistake.

..............."

11. Further, in the interest of natural justice and in order to conduct an inquiry

as per rule 4 (3) of the Rules, the Noticee was granted a final opportunity of

personal hearing on May 29, 2014 at SEBI, Head Office, Mumbai vide

notice dated May 08, 2014. The said Notice of Inquiry dated May 08, 2014

was duly delivered to the Noticee. However, I again find that Noticee neither

appeared for hearing scheduled on May 29, 2014 nor requested for

adjournment of the hearing. For the reasons mentioned above, I observe

that the Noticee was provided with enough opportunity of being heard and

hence, I am proceeding with the inquiry taking into account the material

available on record.



Page 6 of 29 July 22, 2014

CONSIDERATION OF ISSUES AND FINDINGS

12. After perusal of the material available on record, the issues that arise for

consideration in the present case are as under:

A. Whether the Noticee have violated the provisions of sections 12A(a),

12A(b), 12A(c) of SEBI Act and Regulations 3(a), 3(b), 3(c), 3(d), 4(1),

4(2)(a), 4(2)(e) & 4(2)(g) of PFUTP Regulations and regulation 7 read

with clause A(1), A(2), A(3), A(4), A(5) of Code of Conduct for Stock

Brokers specified under schedule II of Broker Regulations?

B. Whether the Noticee is liable for monetary penalty under sections 15HA

and 15HB of the SEBI Act ?

C. What quantum of monetary penalty should be imposed on the Noticee

taking into consideration the factors mentioned in Section 15J of SEBI

Act ?

FINDINGS

13. On perusal of the material available on record and giving regard to the facts

and circumstances of the case, I record my findings hereunder:

ISSUE 1: Whether the Noticee have violated the provisions of sections

12A(a), 12A(b), 12A(c) of SEBI Act and Regulations 3(a), 3(b),

3(c), 3(d), 4(1), 4(2)(a), 4(2)(e) & 4(2)(g) of PFUTP Regulations

and regulation 7 read with clause A(1), A(2), A(3), A(4), A(5)

of Code of Conduct for Stock Brokers specified under

schedule II of Broker Regulations?



Page 7 of 29 July 22, 2014

14. Before moving forward, it will be appropriate to refer to the relevant

provisions of SEBI Act, PFUTP Regulations and Broker Regulations, which

read as under:

SEBI Act

Prohibition of manipulative and deceptive devices, insider trading and

substantial acquisition of securities or control.

Section 12A. No person shall directly or indirectly—

(a) use or employ, in connection with the issue, purchase or sale of any

securities listed or proposed to be listed on a recognized stock

exchange, any manipulative or deceptive device or contrivance in

contravention of the provisions of this Act or the rules or the

regulations made thereunder;

(b) employ any device, scheme or artifice to defraud in connection with

issue or dealing in securities which are listed or proposed to be listed

on a recognised stock exchange;

(c) engage in any act, practice, course of business which operates or

would operate as fraud or deceit upon any person, in connection with

the issue, dealing in securities which are listed or proposed to be listed

on a recognised stock exchange, in contravention of the provisions of

this Act or the rules or the regulations made thereunder;

PFUTP Regulations

Regulation 3: - Prohibition of certain dealings in securities

3. No person shall directly or indirectly—

(a) buy, sell or otherwise deal in securities in a fraudulent manner;

(b) use or employ, in connection with issue, purchase or sale of any

security listed or proposed to be listed in a recognized stock exchange,

any manipulative or deceptive device or contrivance in contravention of

the provisions of the Act or the rules or the regulations made

thereunder;

(c) employ any device, scheme or artifice to defraud in connection with

dealing in or issue of securities which are listed or proposed to be listed

on a recognized stock exchange;

(d) engage in any act, practice, course of business which operates or would

operate as fraud or deceit upon any person in connection with any

dealing in or issue of securities which are listed or proposed to be listed

on a recognized stock exchange in contravention of the provisions of the

Act or the rules and the regulations made thereunder.



Page 8 of 29 July 22, 2014

Regulation 4:-Prohibition of manipulative, fraudulent and unfair trade practices

(1) Without prejudice to the provisions of regulation 3, no person shall indulge in

a fraudulent or an unfair trade practice in securities.

(2) Dealing in securities shall be deemed to be a fraudulent or an unfair trade

practice if it involves fraud and may include all or any of the following,

namely:-

(a) indulging in an act which creates false or misleading appearance of

trading in the securities market;

(b) ………..

(c) ………..

(d) ……………..;

(e) any act or omission amounting to manipulation of the price of a

security;

(f) …………….

(g) entering into a transaction in securities without intention of performing

it or without intention of change of ownership of such security;

Broker Regulations

Stock brokers to abide by Code of Conduct.

Regulation 7. The stock broker holding a certificate shall at all times abide by the

Code of Conduct as specified in Schedule II.

SCHEDULE II

Securities and Exchange Board of India (Stock Brokers and Sub-brokers)

Regulations, 1992

CODE OF CONDUCT FOR STOCK BROKERS

[Regulation 7]

A. General.

1) Integrity: A stock-broker, shall maintain high standards of integrity,

promptitude and fairness in the conduct of all his business.

2) Exercise of due skill and care: A stock-broker shall act with due skill,

care and diligence in the conduct of all his business.

3) Manipulation: A stock-broker shall not indulge in manipulative,

fraudulent or deceptive transactions or schemes or spread rumours with

a view to distorting market equilibrium or making personal gains.

4) Malpractices: A stock-broker shall not create false market either singly

or in concert with others or indulge in any act detrimental to the

investors interest or which leads to interference with the fair and

smooth functioning of the market. A stockbroker shall not involve



Page 9 of 29 July 22, 2014

himself in excessive speculative business in the market beyond

reasonable levels not commensurate with his financial soundness.

5) Compliance with statutory requirements: A stock-broker shall abide

by all the provisions of the Act and the rules, regulations issued by the

Government, the Board and the Stock Exchange from time to time as

may be applicable to him.

Connections between Vishvas Group entities:

15. From the documents available on records, following details were observed

with respect to the connection between Vishvas Group entities:

Sr. No

Entity Name (Broker’s Name)

Connection with other entities of Group

Traded Qty. (During Investigation Period)

1 Master Finlease Ltd. (Integrated Master securities Pvt. Ltd.)

Same address as Avisha Credit Capital & Vishvas Projects Ltd. (Mefcom Agro. Industries Ltd.)

Share holder in Vishvas securities Ltd. (Unlisted Company - 19.24% shareholding as on 30.09.2006)

Off market transfers with Vishvas Securities limited.

BSE: Buy-38000 Sell-18386 NSE: Buy-20500 Sell-111400

2 Purshottam Khandelwal (SIC Stock and Services Pvt. Ltd.)

Off Market Transfers from Anupama Communications Pvt. Ltd.

Entered into Synchronized trades with entities at sr. no. 8, 9.

BSE: Buy 2927835 Sell 2882486 NSE:-Buy-NIL Sell-NIL

3 Anupama Communications Pvt. Ltd.

Transferred shares off market to Purshottam Khandewal.

Directors of Anupama Communications Pvt. Ltd. ( Rakesh Mishra, Ram dutt joshi) are also directors in Cosmo corporate services Ltd.

Nil Trading

4 Cosmo Corporate services limited. (Integrated Master securities Ltd.)

Entered into Off Market Transfers with Master Finlease Ltd.

Entered into Synchronized trades with entities at sr. no. 6,7,8,9.

BSE:Buy-445643 Sell-320630 NSE:Buy-401520 Sell-471184

5 ISF Securities limited (BSE:-Sam Global Securities Ltd. NSE:-ISF Securities Ltd.)

Off Market Transfers from Master Finlease Ltd.

Entered into Synchronized trades with entities at sr. no.




Page 10 of 29 July 22, 2014

6,7,8,9.

6 Quantum Global Securities and leasing company Ltd.

Entered into Synchronized trades with entities at sr. no. 4, 5, 7, 10, and 12.

BSE: Buy-NIL Sell-NIL NSE:Buy-302095 Sell-286835

7 Ishita Finstock Ltd. (Vishvas securities Ltd.)

Entered into large no. of Synchronized trades with entities at sr. no. 1, 4, 5, 6, and 10.

BSE: Buy-NIL Sell-NIL NSE:Buy1953803 Sell-1569204

8 Praveen Poddar (TCP Stock Brokers Ltd)

Entered into large no. of Synchronized trades with entities at sr. no. 2, 4, 5, 9 and 10.

BSE:Buy-460990 Sell-460990 NSE:-Buy-NIL Sell-NIL

9 Sunita Gupta (Parasram Holdings)

Entered into large no. of Synchronized trades with entities at sr. no. 2, 4, 5, 8 and 10.

BSE:Buy-342246 Sell-342246 NSE:-Buy-NIL Sell-NIL

10 Mefcom Securities limited (Mefcom Securities limited)

Same address, same e-mail Id, same director (Vijay Mehta) as of Mefcom infrastructure project Limited. And director (vijay mehta) belongs to promoter group of Vishvas Projects Ltd. (Formerly Known as Mefcom agro Industries Ltd.)


11 Avisha Credit capital Ltd. (Shriram Insight Share Brokers Ltd.)

Holder of 25% stake in Vishvas Sec Ltd. (Unlisted Co.) 337380 Shares as on 30.09.2006.

Same address as Vishvas projects Ltd. (mefcom Agro Industries Ltd.) & Master Finlease Ltd.

Directors of Avisha Credit Capital Ltd.( Shubha Jhindal, Vijay Jhindal, & Rakesh Agarwal) are also directors in Master Finlease Ltd.

BSE: Buy-50000 Sell-NIL NSE:-Buy-NIL Sell-NIL

12 Vishvas Securities Ltd. (Vishvas Securities Ltd.)

Old Address of Mefcom Agro Industries Limited same as address of Vishvas Securities Ltd. i.e. “912, Kailash Building, Kasturba Gandhi Marg, New Delhi".

Off market transfer to Master Finlease Ltd., SIC Stock and Services Pvt. Ltd. (8/7/2006, 50000 shares) and Avisha Credit Capital Ltd.

BSE: Buy-NIL Sell-NIL NSE:Buy-134460 Sell-118661



Page 11 of 29 July 22, 2014

Avisha Credit capital Ltd. and Master Finlease Ltd. were the shareholders of Vishvas Securities Ltd. as on 30.9.2006.(Unlisted Co.)

Atul Joshi one of the director of Vishvas Securities Ltd. is also director in Mefcom Agro Industries Ltd.

13 Vishvas Projects limited (Formerly Known as Mefcom Agro Industries Ltd. (Mefcom Securities Ltd)

Same address as Avisha Credit Capital & Master Finlease.

BSE:Buy-100000 Sell-NIL NSE:-Buy-NIL Sell-NIL

14 SIC Stocks and Services Pvt. Ltd.

Received 50,000 shares from Vishvas Securities Ltd. through off market.

Holding 10.7% shares in Mefcom Agro Industries Ltd. (listed company) as on 20/9/2006.

Transfer of substantial amount to avisha credit capital Limited as per bank statements.

NIL Trading at BSE & NSE

From the above table I find the following:

The members of Vishvas Group namely, Purshottam, Ishita, Cosmo,

Praveen, Sunita, Master, Quantum, VPL, Avisha, Mefcom, ISF, VSL,

Anupama and SIC are connected to each other.

Noticee is a broker and traded in its proprietary account at NSE.

16. Traded quantity of Vishvas Group at BSE and NSE (During Investigation

Period)

Sr. No.

Members of Vishvas Group

Traded quantity (During Investigation Period)

BSE NSE

Buy Sell Buy Sell

1 Master 38000 18386 20500 111400

2 Purshottam 2927835 2882486 0 0

3 Anupama 0 0 0 0

4 Cosmo 445643 320630 401520 471184

5 ISF 389748 338795 453396 368574



Page 12 of 29 July 22, 2014

From the above table I find the following:

Nine members of Vishvas Group namely, Master, Purshottam,

Cosmo, ISF, Praveen, Sunita, Mefcom, Avisha and VPL had traded

in the scrip of Gangotri at BSE.

Seven members of Vishvas Group namely, Master, Cosmo, ISF,

Quantum, Ishita, Mefcom and VSL had traded in the scrip of

Gangotri at NSE.

Total buy and sell quantity of the members of Vishvas Group at BSE

is 51,98,404 shares and 47,11,903 shares respectively.

Total buy and sell quantity of the members of Vishvas Group at NSE

is 38,76,420 shares and 35,92,980 shares respectively.

Noticee had bought 3,02,095 shares of Gangotri and sold 2,86,835

shares of Gangotri in/from its proprietary account at NSE.

TRADE CONCENTRATION

AT NSE:

17. From the trade & order log and documents available on record, I find that

total traded volume of the scrip of Gangotri during investigation period was

68,16,750 shares. During the investigation period, the trading details of top

10 trading brokers were analyzed and found that they had contributed

72.8% (49,62,603 shares) and 69.4% (47,33,357 shares) of the gross buy

6 Quantum 0 0 302095 286835

7 Ishita 0 0 1953803 1569204

8 Praveen 460990 460990 0 0

9 Sunita 342246 342246 0 0

10 Mefcom 443942 348370 610646 667122

11 Avisha 50000 0 0 0

12 VSL 0 0 134460 118661

13 VPL 100000 0 0 0

14 SIC 0 0 0 0

Total 5198404 4711903 3876420 3592980



Page 13 of 29 July 22, 2014

and gross sell respectively. Further, it is observed that the Noticee

appeared in top 10 trading brokers by gross buy and gross sell. Noticee had

contributed 3,10,356 shares to gross buy and 2,94,506 shares to gross sell

of total market quantity.

18. During investigation period, the trading details of top 10 trading clients were

analyzed and found that they had contributed 67.42% (45,95,836 shares)

and 59.85% (40,80,121 shares) of the gross buy and gross sell

respectively. Further, it is observed that out of top 10 trading clients, six

members of Vishvas Group namely, Ishita, Mefcom, ISF, Cosmo, Quantum

and VSL were appeared in gross buy with total contribution of 56.56% (

38,55,920 shares) and six members of Vishvas Group namely, Ishita,

Mefcom, ISF, Cosmo, Quantum and VSL were appeared in gross sell with

total contribution of 51.07% (34,81,580 shares). Noticee had contributed

3,02,095 shares to gross buy and 2,86,835 shares to gross sales of total

market quantity.

19. During investigation period, the trading details of top 10 clients with net buy

and net sell position were also analyzed and found that 3 members of

Vishvas Group namely, Ishita, ISF and VSL appeared at net buy position

and 3 members of Vishvas Group namely, Master, Cosmo, Mefcom

appeared at net sell position. At the end of the investigation period the net

buy position of the Noticee was 15,260 shares.

SYNCHRONIZED TRADES

AT NSE

20. Upon perusal of data, trade & order log and documents available on record,

I find that during investigation period there were 21,451 trades for a traded

quantity of 68,16,750 shares at NSE. Out of these, there were 495 trades

for 14,48,679 shares (21.25% of the total traded quantity) were



Page 14 of 29 July 22, 2014

synchronized trades i.e. the difference between buy order time and sell

order time was less than 60 seconds and there was no difference between

buy order rate and sell order rate as well as there was no difference

between buy order quantity and sell order quantity.

21. It was observed that there were 30 trading days (out of total 37 trading days

during the investigation period) when synchronized trading was being done

at NSE, out of which Vishvas Group appeared in 24 trading days. Out of

these 24 days, on 23 days, the matching of synchronized trades of

members of Vishvas Group with total market synchronized trades was more

than 50% and on 15 days, the contribution of volumes through

synchronized trades by the members of Vishvas Group was more than 15%

to the total market volume. For e.g. on May 24, 2006 the total day traded

volume was 1,35,845 shares out of which 56,862 shares (41.86% shares)

were synchronized by Vishvas Group.

22. It is observed that the seven members of Vishvas Group namely, Ishita,

Cosmo, VSL, Quantum, Mefcom, ISF and Master, indulged in 312

synchronized trades for 12,01,751 shares (82.95% of total synchronized

quantity). The details of synchronized trade amongst the member of

Vishvas Group are as under: –

Particulars Seller Name

Buyer Name Ishita Quantum VSL Mefcom Cosmo ISF Master Total

Mefcom 122738 73820 5000 00 56927 53390 7000 318875

Ishita 00 73439 00 136008 42150 44444 00 296041

Cosmo 110657 4975 00 81341 00 32925 00 229898

Quantum 68063 00 27653 41787 29953 1000 00 168456

ISF 67724 18996 1992 35350 37300 00 00 161362

VSL 00 4975 00 16340 00 00 00 21315

Master 3804 00 00 00 00 2000 00 5804

Total 372986 176205 34645 310826 166330 133759 7000 1201751

From the above table, it is observed that:



Page 15 of 29 July 22, 2014

Out of total shares bought (3,02,095 shares) by the Noticee at NSE

during investigation period, 1,68,456 shares were synchronized with

the members of the Vishvas Group i.e. Ishita, VSL, Mefcom, Cosmo

and ISF.

Out of total shares sold (2,86,835 shares) by the Noticee at NSE

during investigation period, 1,76,205 shares were synchronized with

the member of the Vishvas Group i.e. Mefcom, Ishita, Cosmo, ISF

and VSL.

One of the instances of the synchronized trade and reversal trade by

the Noticee with other members of Vishvas Group is that on May 23,

2006, Noticee sold 10,000 shares of Gangotri @ ` 50.95 to Mefcom

at 10:10:04. The buy order was placed by Mefcom at 10:10:04 @

`50.95 for 10,000 shares and the sell order was placed by the

Noticee at 10:10:01 @ ` 50.95 for 10,000 shares. The order time

difference was 4 seconds. Noticee again bought 10,000 Gangotri

shares back from Mefcom @ ` 51.70 at 10:56:23, i.e. the trade was

reversed within 50 minutes. In the reverse trade the buy order was

placed by the Noticee at 10:56:22 @ ` 51.70 for 10,000 shares and

the sell order was placed by Mefcom at 10:56:23 @ ` 51.70 for

10,000 shares. The order time difference was 1 seconds. During

investigation period, similar trading patterns of synchronized trading

were also observed between Noticee and other members of Vishvas

Group.

23. Details of total number of synchronized buy and sell orders, trades and

trade quantity by Vishvas Group during investigation period are as under:

Client Name Buy Sell Total

Count of Buy Orders

Count of Buy Trades

Total Buy Qty

Count of Sell Orders

Count of Sell Trades

Total Sell Qty

Total Orders

Total Trades

Total Qty

Ishita 51 70 296041 65 92 372986 116 162 669027



Page 16 of 29 July 22, 2014

Mefcom 62 102 318875 58 68 310826 120 170 629701

ISF 32 42 161362 23 23 133759 55 65 295121

Quantum 33 51 168456 31 40 176205 64 91 344661

Cosmo 36 40 229898 31 68 166330 67 108 396228

VSL 4 4 21315 8 19 34645 12 23 55960

Master 3 3 5804 2 2 7000 5 5 12804

Total 221 312 1201751 218 312 1201751 439 624 2403502

From the above table, it is observed that out of total 439

synchronized trades (buy & sell) by Vishvas Group for 24,03,502

shares, Noticee was indulged in 64 synchronized trades for 3,44,661

shares.

CIRCULAR TRADES and REVERSAL TRADES

24. Upon analysis of trade log in NSE, it is observed that there were

substantial number of trades in which parties and counterparties to the

trade were same entities which belong to Vishvas Group. They were

creating an artificial volume in the market by trading among themselves i.e.

by circular trading and reversal trading. seven members of Vishvas Group

were doing circular trading and reversal trading in NSE.

At NSE

25. It is observed that seven members of Vishvas Group namely, Ishita,

Cosmo, VSL, Quantum, Mefcom, ISF and Master involved in circular trades

in 29 trading days out of 37 trading days during investigation period and

created artificial volume of 23,56,185 shares (34.56% of total market

volume) by buying and selling among themselves. These transactions took

place in 2419 trades. Out of the same, circular trades aggregating to

12,01,751 shares from 312 trades were synchronized.

26. It is also observed that members of Vishvas Group made large contribution

in circular and reversal trades as compared to the total market volume in

the scrip. The circular trades and reversal trades by seven members of



Page 17 of 29 July 22, 2014

Vishvas Group resulted in significant proportion of volume to the total

market volume in the scrip. Out of 29 trading days, On 10 days, the

percentage of circular trade volume of seven entites of Vishvas Group to

the total market volume was more than 40% and on 5 days it was more

than 60%.

27. The details of circular trades among the seven members of Vishvas Group

are as under:-

Circular Trades Sellers

Buyers ISF Mefcom VSL Cosmo Ishita Master Quantum

Grand Total

ISF 625 110961 6552 68158 157108 00 33458 376862

Mefcom 68254 550 5000 102992 231230 7040 100574 515640

VSL 26258 24142 497 100 5022 00 14980 70999

Cosmo 36925 123702 00 00 143512 00 27975 332114

Ishita 157329 188865 2570 183095 92185 29825 107776 761645

Master 2000 00 00 00 7841 00 00 9841

Quantum 2000 76917 48823 59751 101533 00 60 289084

Grand Total 293391 525137 63442 414096 738431 36865 284823 2356185

From the above table, it is observed that:

Out of total shares bought (3,02,095 shares) by the Noticee during

investigation period, 2,89,084 shares were involved in circular

trading with the member of the Vishvas Group i.e. Ishita, Mefcom,

Cosmo, ISF and VSL.

Out of total shares sold (2,86,835 shares) by the Noticee during

investigation period, 2,84,823 shares were involved in circular

trading with the other members of the Vishvas Group i.e. Ishita,

Mefcom, Cosmo, ISF and VSL.

28. During investigation period, circular trading among Vishvas Group were

observed from April 21, 2006 till May 31, 2006. Some of the instances of

circular trading are as follows



Page 18 of 29 July 22, 2014

Trade Quantity = 10000

Trade Time = 15:10:18

Trade Quantity = 10000 Trade Quantity = 10000

Trade Time = 15:13:08 Trade Time = 15:11:04

Circular pattern observed on May 18, 2006 among the group is as under:

SELF TRADES AT NSE

29. It is observed that Noticee had also indulged in self trades during

investigation period. The summary of its self trades done are as under -

Name of the entity Number of trades

Traded Qty

Quantum 1 60

It is observed that 1 trade of Noticee for 60 share was self trade

where buyers and sellers are same person.

PRICE MANIPULATION:

30. Last Traded Price (LTP) analysis:- It is observed that during investigation

period, the price of the scrip has decreased in patch I & III and increased in

patch II as discussed below:

Patch I (April 7, 2006 to April 20, 2006):

Mefcom

Quantum

VSL



Page 19 of 29 July 22, 2014

Exchange Opening price (April 07, 2006)

Closing price (April 20, 2006)

Trading days

% Change in price of the scrip

Average Daily Traded Volume

BSE 53.25 44.75 8 Days 15.96% (Decrease)

70713

NSE 56.00 44.40 8 Days 20.70% (Decrease)

68005

Patch II (April 21, 2006 to May 5, 2006):

Exchange Opening price (April 21, 2006)

Closing price (May 05, 2006)

Trading days



BSE 46.00 66.55 11 Days 44.70% (Increase)

338391

NSE 46.00 66.90 11 Days 45.40% (Increase)

213738

Patch III (May 8, 2006 to May 31, 2006):

Exchange Opening price (May 08, 2006)

Closing price (May 31, 2006)

Trading days



BSE 64.50 44.35 18 Days 31.20% (Decrease)

258554

NSE 63.55 45.40 18 Days 28.60% (Decrease)

217866

It is observed that, all the members Vishvas Group started trading on

or after April 21, 2006 i.e. they had traded only during patch II

(Period of price rise) and patch III (Period of price fall).

It is also observed that the day from when the members of Vishvas

Group start trading, the average trading volume of the scrip at NSE

had gone up significantly from 68,005 shares (during April 07, 2006

to April 20, 2006) to 2,13,738 shares (during April 21, 2006 to May

05, 2006) and 2,17,866 shares (during May 08, 2006 to May 31,

2006).

31. LTP contribution of Visvas Group entities at NSE: Total cumulative

positive and negative LTP contribution was Rs. 995.25 and Rs. 1007.25



Page 20 of 29 July 22, 2014

respectively during investigation period in NSE whereas, it is observed that

seven members of Vishvas Group namely, Ishita, Mefcom, VSL, Cosmo,

Quantum, ISF and Master had contributed Rs.489.05 and Rs.307.90

respectively. The details of contribution of seven members of Vishvas

Group to cumulative Positive and Negative LTP variation are as under –

Sr. No.

Client Name Sum of Positive LTP `

Sum of Negative LTP `

Total positive Cumulative LTP

1 Ishita 365.95 -229.2 136.75

2 Mefcom 56.55 -45 11.55

3 VSL 32.1 -18.5 13.6

4 Cosmo 14.5 -6.7 7.8

5 Quantum 10.55 -3.7 6.85

6 ISF 8.8 -4.6 4.2

7 Master 0.6 -0.2 0.4

Total 489.05 -307.90 181.15

Noticee had contributed ` 10.55 to total cumulative positive LTP and

` 3.7 to total cumulative negative LTP.

32. It is observed that the Noticee's contribution towards LTP was not much.

However, the role of the Noticee in executing the larger game plan of

creating manipulation in the scrip of Gangotri in concert with the other

members of Vishvas Group cannot be overlooked i.e. the Noticee had

mostly traded with Ishita, Mefcom, Cosmo, ISF and VSL, who are the major

contributors towards LTP variation. Further, most of the synchronized

trades and circular trades of the Noticee's were with Ishita, Mefcom,

Cosmo, ISF and VSL. It is not possible for a single entity to manipulate the

market and the role of the entire Vishvas group has to be considered in a

holistic manner to arrive at any conclusion. Thus, Noticee have also aided

and abetted the other members of Vishvas Group in manipulating the price

of the scrip of Gangotri.

33. I find that during the investigation period, the Noticee had bought 3,02,095

shares and sold 2,86,835 shares (total traded volume of the Noticee was

5,88,930 shares). Out of total trading volume of the Noticee, 3,44,661



Page 21 of 29 July 22, 2014

shares of the Noticee were synchronized and 5,73,907 shares were circular

with other members of Vishvas Group. I also find that Noticee was indulged

in 1 self trades for 60 shares.

34. I find that the patterns of circular trading among the Vishvas Group are in

the manner [A→B→C→D→A]. Almost same numbers of shares were

rotated in a circular manner among the Vishvas Group on daily basis and

the pattern depicts that the trades were planned with a manipulative intent.

Thus, the said circular trading was not just a co-incidence and the same

indicates their concerted effort and manipulative intent to increase the price

of the scrip by creating false and artificial volume in the scrip. Due to the

concerted effort of Vishvas Group the price of the scrip of Gangotri in NSE

had increased from ` 41.25 on April 19, 2006, touched the high to ` 71.05

on May 05, 2006 and then decreased to `45.40 on May 31, 2006 within a

period of one and half month. This gave an impression to other investors in

the market that the scrip of Gangotri was being actively traded at the

prevailing price but actually this was not the case.

35. The pattern of synchronized order placement, reversal trading and circular

trading clearly points out that the transactions were carried out with the

intention that the orders of particular entities should match and there was a

prior arrangement with respect to these transactions. These transactions

resulted in creation of artificial volume. The pattern of trading indicates

several instances where the time difference between buy and sell orders

was less than 20 seconds. No unknown person can trade continuously with

same set of persons by putting orders in such pattern contributing

significantly to total volume in the market. The Noticee along with the other

members of Vishvas Group have transacted amongst themselves in the

shares of Gangotri through circular, reversal and synchronized order

placement in a contrived pricing pattern and it led to creation of artificial

volumes in the scrip as the trades were reversed in a short time. The



Page 22 of 29 July 22, 2014

increase in the trading volume of Gangotri shares can be attributed to the

trades done by the Noticee in collusion with the other members of Vishvas

Group. Thus, these trades were fraudulent and manipulative in nature as

Noticee have misused the trading mechanism.

36. The fact is that had the trades of the members of Vishvas Group been

executed in the normal course of business, the possibility of such perfect

matching would not have been possible. The buy and sell prices of one

entity were close to the buy/sell rates of the other entity in all the

settlements, such that the trades of these entities were always matched.

Greater the number of synchronized trades, the larger is the chance of

trades not being genuine in nature, which is bound to affect the market

equilibrium. A trade can be executed on the screen and still be manipulative

in nature. Considering the number of such trades, it is clear that there has

been a gross mis-use of the screen based trading system. It is also to be

stated that “intention” is inherent in all cases of synchronized trading

involving large scale price manipulation and the same was also brought out

in the case of Nirmal Bang Securities (P) Ltd. vs SEBI by the Hon‟ble SAT

whereby it was observed that “Intention is reflected from the action of the

Appellant. Choosing selective time slots does not appear to be an involuntary

action.”

37. The trading pattern of the Noticee creates doubts about the genuineness of

its trades. I am of the view that the trades carried out were fraudulent and

manipulative in nature. However, in the present case, the records show that

most of the trading carried out by the Noticee was with a fixed set of entities

i.e. members of Vishvas Group namely, Ishita, Mefcom, Cosmo, ISF and

VSL.

38. Therefore, I am of the view that the trades of the members of Vishvas

Group were with the intention not to transfer the beneficial ownerships of



Page 23 of 29 July 22, 2014

the shares of Gangotri but with an intention to operate only as a device to

inflate, depress or cause fluctuations in the price of shares of Gangotri for

wrongful gains. Thus the Noticee through collusion with the other members

of the Vishvas Group has transacted in the shares of Gangotri in such a

manner that it led to creation of artificial volumes in the scrip and a false

market leading to price movement in the scrip which lacked presence of any

sort of fundamentals.

39. It is evident from the trading pattern of Noticee and other member of

Vishvas Group that through circular, reversal and synchronized trades, they

have manipulated the price of the scrip during the period under scrutiny. It

is also observed that there was no transfer of ownership of shares.

40. Hon‟ble Securities Appellate Tribunal (hereinafter referred as “SAT”), in

Ketan Parekh Vs. Securities & Exchange Board of India (Appeal No. 2 of

2004), observed that, “A synchronized transaction even on the trading screen

between genuine parties who intend to transfer beneficial interest in the trading

stock and who undertake the transaction only for that purpose and not for rigging

the market is not illegal and cannot violate the regulations. As already observed

„synchronisation‟ or a negotiated deal ipso facto is not illegal. A synchronised

transaction will, however, be illegal or violative of the Regulations if it is executed

with a view to manipulate the market or if it results in circular trading or is

dubious in nature and is executed with a view to avoid regulatory detection or does

not involve change of beneficial ownership or is executed to create false volumes

resulting in upsetting the market equilibrium. Any transaction executed with the

intention to defeat the market mechanism whether negotiated or not would be

illegal. Whether a transaction has been executed with the intention to manipulate

the market or defeat its mechanism will depend upon the intention of the parties

which could be inferred from the attending circumstances because direct evidence

in such cases may not be available. The nature of the transaction executed, the

frequency with which such transactions are undertaken, the value of the



Page 24 of 29 July 22, 2014

transactions, whether they involve circular trading and whether there is real

change of beneficial ownership, the conditions then prevailing in the market are

some of the factors which go to show the intention of the parties. This list of

factors, in the very nature of things, cannot be exhaustive. Any one factor may or

may not be decisive and it is from the cumulative effect of these that an inference

will have to be drawn.”

41. In my view, the Noticee through the said artificial trades interfered with the

market mechanism by manipulating the price and volume of the said scrip.

The trades executed by the Noticee and Vishvas Group were not real

trades as there was no intention to change the beneficial ownership. When

the trades were inherently non genuine, I do not feel that it is necessary to

prove that investors had, in fact got induced and bought and/ or sold on the

basis of these trades. Similar views were expressed by Hon‟ble SAT in its

order dated 14.7.2006 in Ketan Parekh Vs. SEBI wherein it had observed

that “When a person takes part in or enters into transactions in securities with the

intention to artificially raise or depress the price he thereby automatically induces

the innocent investors in the market to buy /sell their stocks. The buyer or the seller

is invariably influenced by the price of the stocks and if that is being manipulated

the person doing so is necessarily influencing the decision of the buyer / seller

thereby inducing him to buy or sell depending upon how the market has been

manipulated. We are therefore of the view that inducement to any person to buy or

sell securities is the necessary consequence of manipulation and flows therefrom.

In other words, if the factum of manipulation is established it will necessarily

follow that the investors in the market had been induced to buy or sell and that no

further proof in this regard is required. The market, as already observed, is so wide

spread that it may not be humanly possible for the Board to track the persons who

were actually induced to buy or sell securities as a result of manipulation and law

can never impose on the Board a burden which is impossible to be discharged.

This, in our view, clearly flows from the plain language of Regulation 4(a) of the

Regulations.”



Page 25 of 29 July 22, 2014

42. Keeping in mind the dicta of the SAT as reproduced above, I see no reason

to take a different view in the present case.

43. As per regulation 2 (1) (c) of PFUTP Regulations, "fraud" includes any act,

expression, omission or concealment committed whether in a deceitful manner or

not by a person or by any other person with his connivance or by his agent while

dealing in securities in order to induce another person or his agent to deal in

securities, whether or not there is any wrongful gain or avoidance of any loss….”

44. In terms of Clauses A1 to A5 of the Code of Conduct prescribed under the

provisions of Brokers Regulations, a stock broker is required to ensure that

it does not indulge in fraudulent or deceptive transactions with a view to

distort market equilibrium, or, shall not create false market singly or in

concert with others that leads to inference with fair and smooth functioning

of the market. A broker shall abide by all the provisions and statutory

requirements of the Act and rules. The Broker shall also maintain high

standards of integrity, promptitude and fairness and shall act with due skill,

care and diligence in the conduct of his business. Noticee through reversal,

circular, self and synchronized trades created a false & misleading

appearance of trading, created artificial volume in the shares of Gangotri

and manipulated the price of the scrip of Gangotri. It further shows that the

Noticee had failed to exercise due skill, care and diligence and not

maintained high standards of integrity, promptitude, fairness in the conduct

of business as a stock broker. Moreover, the transactions of the Noticee in

Gangotri were reversal, circular, self and synchronized and there does not

appear to be any genuine trading interest in the scrip.

45. I have noted the submissions of the Noticee, however, the same is not

convincing and thus, I do not find any merit in its submissions. Moreover the

Noticee has accepted the violations as mistakes on its part. Therefore, I



Page 26 of 29 July 22, 2014

hold that the charges leveled against the Noticee are proved and that the

allegation of violation of provisions of sections 12A(a), 12A(b), 12A(c) of

SEBI Act and Regulations 3(a), 3(b), 3(c), 3(d), 4(1), 4(2)(a), 4(2)(e) &

4(2)(g) of PFUTP Regulations and regulation 7 read with clause A(1), A(2),

A(3), A(4), A(5) of Code of Conduct for Stock Brokers specified under

schedule II of Broker Regulations by the Noticee stand established.

ISSUE 2: Whether the Noticee is liable for monetary penalty under

sections 15HA & 15HB of the SEBI Act ?

46. The aforesaid violations of SEBI Act, PFUTP Regulations and Broker

Regulations by the Noticee make it liable for penalty under Sections 15HA

and 15 HB of SEBI Act which reads as follows:

“Section 15HA. Penalty for fraudulent and unfair trade practices.

If any person indulges in fraudulent and unfair trade practices relating to

securities, he shall be liable to a penalty of twenty-five crore rupees or three times

the amount of profits made out of such practices, whichever is higher.”

“15HB.Penalty for contravention where no separate penalty has been provided.-

Whoever fails to comply with any provision of this Act, the rules or the regulations

made or directions issued by the Board thereunder for which no separate penalty

has been provided, shall be liable to a penalty which may extend to one crore

rupees.”

47. In the matter of SEBI vs. Shri Ram Mutual Fund [2006] 68 SCL 216 (SC),

the Hon‟ble Supreme Court of India has held that “In our considered opinion,

penalty is attracted as soon as the contravention of the statutory obligation as

contemplated by the Act and the regulation is established and hence the intention of

the parties committing such violation becomes wholly irrelevant”.



Page 27 of 29 July 22, 2014

48. As already observed that, Noticee have violated the provisions of sections

12A(a), 12A(b), 12A(c) of SEBI Act and Regulations 3(a), 3(b), 3(c), 3(d),

4(1), 4(2)(a), 4(2)(e) & 4(2)(g) of PFUTP Regulations and regulation 7 read

with clause A(1), A(2), A(3), A(4), A(5) of Code of Conduct for Stock

Brokers specified under schedule II of Broker Regulations. Therefore, I find

that the Noticee is liable for monetary penalty under Sections 15HA & 15HB

of the SEBI Act.

ISSUE 3: What quantum of monetary penalty should be imposed on

the Noticee taking into consideration the factors mentioned

in Section 15J of SEBI Act ?

49. While determining the quantum of penalty under Sections 15HA & 15HB of

SEBI Act, it is important to consider the factors stipulated in section 15J of

SEBI Act, which reads as under:-

“15J - Factors to be taken into account by the adjudicating officer

While adjudging quantum of penalty under section 15-I, the adjudicating officer

shall have due regard to the following factors, namely:-

(a) the amount of disproportionate gain or unfair advantage, wherever

quantifiable, made as a result of the default;

(b) the amount of loss caused to an investor or group of investors as a result of the

default;

(c) the repetitive nature of the default.”

50. I note that on the basis of data available on record, it is difficult, in cases of

such nature, to quantify exactly the disproportionate gain or unfair

advantage enjoyed by the Noticee and the consequent losses suffered by

the investors. Further the amount of loss to an investor or group of investors

also cannot be quantified on the basis of available facts and data. Even

though the monetary loss to the investors cannot be computed, any

manipulation in the volume or price of the stocks caused by vested interest



Page 28 of 29 July 22, 2014

always erodes investor confidence in the market so that investors find

themselves at the receiving end of market manipulators. Hence, anyone

could have been carried away by the unusual fluctuations in the

volume/price and been induced into investing in the said scrip. Besides, this

kind of activity seriously affects the normal price discovery mechanism of

the securities market. People who indulge in manipulative, fraudulent and

deceptive transactions, or abet the carrying out of such transactions which

are fraudulent and deceptive, should be suitably penalized for the said acts

of omissions and commissions. Considering the continuous effort of the

Noticee in this aspect where the trading was carried out over a period of

time, it can safely be surmised that the nature of default was also repetitive.

51. In the forgoing paragraphs, it is now established that the Noticee have

violated the provisions of sections 12A(a), 12A(b), 12A(c) of SEBI Act and

Regulations 3(a), 3(b), 3(c), 3(d), 4(1), 4(2)(a), 4(2)(e) & 4(2)(g) of PFUTP

Regulations and regulation 7 read with clause A(1), A(2), A(3), A(4), A(5) of

Code of Conduct for Stock Brokers specified under schedule II of Broker

Regulations. In view of the above and considering the facts and

circumstances of the case and factors under Section 15J of the SEBI Act

and the violation committed by the Noticee, I find that imposing a penalty of

` 60,00,000/- (Rupees Sixty Lakhs only) under section 15HA of SEBI Act

for the violations of provisions of SEBI Act & PFUTP Regulations and

`15,00,000/- (Rupees Fifteen Lakhs only) under section 15HB of SEBI Act

for the violations of provisions of Code of Conduct for Stock Brokers

specified under Broker Regulations on the Noticee, would be

commensurate with the violations committed by it.

ORDER

52. In exercise of the powers conferred under Section 15-I of the SEBI Act and

in terms of the provisions of Sections 15HA & 15HB of the SEBI Act & Rule

5(1) of the Rules, I hereby impose a total penalty of ` 75,00,000/- (Rupees



Page 29 of 29 July 22, 2014

Seventy Five Lakhs only) on M/s Quantum Global Securities and Leasing

Company Limited for violation of provisions of sections 12A(a), 12A(b),

12A(c) of SEBI Act and Regulations 3(a), 3(b), 3(c), 3(d), 4(1), 4(2)(a),

4(2)(e) & 4(2)(g) of PFUTP Regulations and regulation 7 read with clause

A(1), A(2), A(3), A(4), A(5) of Code of Conduct for Stock Brokers specified

under schedule II of Broker Regulations.

53. The Noticee shall pay the said amount of penalty by way of demand draft

drawn in favour of “SEBI – Penalties Remittable to Government of India”

payable at Mumbai within 45 days of receipt of this order. The said demand

draft shall be forwarded to the Division Chief, Investigation Department (IVD

– ID6), Securities and Exchange Board of India, Plot No. C4-A, „G‟ Block,

Bandra Kurla Complex, Bandra (E), Mumbai – 400051.

54. In terms of rule 6 of the Rules, copies of this order are sent to the Noticee

and also to SEBI.

Date: July 22, 2014 Jayanta Jash

Place: Mumbai Adjudicating Officer

Documents

BEFORE THE ADJUDICATING · PDF fileGangotri was traded in both NSE & BSE. Details of price volume data at BSE & NSE for the period April 07, 2006 to May 31, 2006 are as follows: