Ad Interim Ex-parte order in the matter of Blue Chip Corporation Pvt. Ltd.

WTM/RKA/MIRSD/145/ 2015 SECURITIES AND EXCHANGE BOARD OF INDIA ORDER DIRECTIONS UNDER SECTIONS 11(1), 11(4), 11B AND 11D OF THE SECURITIES AND EXCHANGE BOARD OF INDIA ACT, 1992 AGAINST BLUE CHIP CORPORATION PVT. LTD., ITS DIRECTORS MR. NITIN RAJARAM NARKE AND MR. PRAVIN B. DARAWADE AND OTHERS.

1. Blue Chip Corporation Pvt. Ltd. (hereinafter referred to as "BCCPL") is registered with Securities and Exchange Board of India (SEBI) as a stock broker in cash and equity derivative segments of National Stock Exchange of India Limited (NSE) (Registration No. INB/INF231446536) with effect from August 24, 2011. Mr. Nitin Rajaram Narke has 90% of the shareholding in BCCPL while Mr. Pravin B. Darawade has the remaining 10%. Mr. Nitin Rajaram Narke and Mr. Pravin B. Darawade are also directors of BCCPL. 2. SEBI received complaints from Hadapsar Parisar Investors Association, Pune (HPIA) stating inter alia that: (a) Mr. Nitin Rajaram Narke had solicited and raised money from public through M/s Milestone Investment, M/s Nitin Narke Investment, M/s Blue Chip Investment and had promised them a return of 100% in 10 months and 200% in 20 months. (b) In this manner, Mr. Nitin Rajaram Narke, through 15 agents, collected an amount of `1,200 crores from public. (c) Mr. Nitin Rajaram Narke had represented to the investors that he is a SEBI registered stock broker of NSE and a trading member of Multi Commodity Exchange of India (MCX). He also showed the certificate of registrations in respect of these exchanges and told that trading in shares through BCCPL and Blue Chip Commodities Broking Pvt. Ltd. (BCCBPL) is legal. (d) In the advertisement, dated November 27, 2011, published in the newspaper “Dainik Bhaskar” Mr. Nitin Rajaram Narke promised that money will be immediately returned to an investor on demand who would invest through him. (e) When investors sought refund of their money, BCCPL shifted their office unlawfully and did not refund the money to the investors. The board of directors of BCCPL are absconding since last two years. The refund cheques issued by BCCPL have also bounced. During this time, the office of BCCPL also used to be closed most of the time. (f) BCCPL again issued advertisements in newspaper that its office would open from Order in the matter of Blue Chip Corporation Pvt. Ltd.

February 2014, but the office was never opened. (g) Mr. Nitin Rajaram Narke has, thus, cheated the investors for `1,200 crores. Mr. Nitin Rajaram Narke was arrested by Pune police for one month. However, after his release on a personal bond of `1 lakh, Mr. Nitin Rajaram Narke has been threatening the investors who had lodged complaint against him. 3. Vide its letter dated November 24, 2014, HPIA also forwarded certain documents viz. copies of complaints lodged with NSE against BCCPL, copy of letter issued by NSE, copy of letter issued by BCCPL, copies of bank pass books of the investors, copies of post dated cheques issued by M/s Milestone Investment, M/s Nitin Narke Investment, M/s Blue Cheap Investment and M/s Blue Chip Investment, pertaining to various investors in support of their complaints. 4. In view of the above complaints, vide letter dated July 08, 2015, SEBI advised BCCPL to provide its comments. However, SEBI letter sent to BCCPL at its registered address through Registered Post (Acknowledgement due) returned undelivered with the comments “addressee left”. Emails sent to BCCPL at its email address also returned undelivered.

BCCPL could not be contacted even at the telephone numbers which were provided by it at the time of registration. Thus, BCCPL was not traceable and comments could not be obtained from it. It is the duty of a stock broker to intimate the place where the books of account, records and documents are maintained, even in case, when there is a change in address. 5. SEBI also sought information/data from NSE, MCX, National Commodity & Derivatives Exchange Limited (NCDEX), Axis Bank, ICICI Bank, HDFC Bank, IDBI Bank, Cosmos Cooperative Bank Ltd., Saraswat Bank, the Royal Bank of Scotland N.V and IndusInd Bank and Police Department, Pune. 6. NSE has, inter alia, informed the following in respect of BCCPL: (a) NSE had levied a monetary penalty of `1,20,000/- for non-compliance of various statutory requirements, such as non-implementation of adequate systems to monitor transactions and generate alerts based on set parameters as per the guidelines issued under the Prevention of Money Laundering Act, 2002 incorrect reporting of CTCL terminals to the exchange, non-settlement of funds and securities of clients as per their preference and non-intimation or Principal Officer appointment to Financial Intelligence Unit.

(b) NSE and National Securities Clearing Corporation Ltd. (NSCCL) have disabled the terminal of BCCPL in cash segment with effect from March 18, 2014 for shortfall in the Interest Free Security Deposit. (c) NSE had disabled the terminal of BCCPL in F&O segment with effect from December 11, 2013 due to initial margin violation and shortfall in the Interest Free Security Deposit. (d) Three investor complaints had been filed against BCCPL and Investor Grievances Resolution Panel of NSE had ruled in favour of the complainants. (e) The stock broker’s office was closed and the stock broker could not be contacted telephonically as well. (f) BCCPL has not submitted net worth certificate, annual report, internal audit report during 2013-14 to till date and quarterly compliance certificate was submitted in 2013 with a delay of 37 days and 20 days for quarters June 2013 and September 2013 respectively. (g) Penalty of `9,000 was levied on BCCPL for non-submission of internal audit report for the half year September 2013. (h) The Disciplinary Action Committee of NSE in its meeting held on January 16, 2015 decided that the membership of BCCPL be suspended from all segments of the stock exchange.

(i) Mr. Nitin Rajaram Narke and Mr. Pravin B. Darawade are clients of BMA Wealth Creators Ltd. (a SEBI registered stock broker). (j) As regards the investor complaints against BCCPL which were forwarded by HPIA, NSE intimated to the complainants that the payments were neither made to BCCPL nor its sub broker and therefore the matter was closed in the records of the stock exchange. 7. MCX has informed SEBI that, with effect from February 18, 2015, BCCBPL had been declared as defaulter in terms of directives of Forward Markets Commission (FMC) and the provisions of Rules, Bye Laws and Business Rules of MCX for its failure to honour arbitral awards. NCDEX has also informed SEBI that, with effect from March 25, 2015, BCCBPL has been declared as a defaulter in terms of directives of FMC and the provisions of Rules, Bye Laws and Regulations of NCDEX, as the said member was declared a defaulter by MCX. 8. As per the information provided by banks, Ms. Bhavana Chadha and Mr. Nitin Rajaram Narke are partners of M/s Milestone Investment, in the manner 51% and 49% respectively and M/s Blue Chip Investment is constituted as a sole proprietorship by Mr. Nitin Rajaram Narke.

However, no information was available in respect of M/s Nitin Narke Investment, M/s Blue Cheap Investment and its directors/partners. Axis Bank, ICICI Bank and HDFC Bank have provided also account statements pertaining to M/s Blue Chip Investment, M/s Blue Cheap Investment, M/s Nitin Narke Investment, Mr. Nitin Rajaram Narke, Mr. Narke Nitin Rajaram and M/s Milestone Investment. 9. Vide letter dated September 23, 2015, the office of Superintendent of Police, Pune (Rural)

inter alia informed the following: (a) Mr. Nitin Rajaram Narke and 17 other accused formed M/s Nitin Narke Investment, M/s Milestone Investment, M/s Blue Chip Investment, BCCPL and collected funds from public by assuring 8 to 10 percent returns per month and did not return. Total amount involved in such fraudulent schemes was amounting to `15,30,32,400/-. (b) In the name of BCCPL, accused Mr. Nitin Rajaram Narke had taken membership of NSE vide registration No. INB231446536 and deposited `1,19,20,810/- towards membership. (c) Further, in the name of BCCPL, taken membership of MCX vide Member ID 46185 and deposited `10,50,000/- in his membership account. (d) Mr. Nitin Rajaram Narke made a fix deposit of `25,00,000/- with ICICI Bank, Fatima Nagar, Pune and kept the same, with NSE towards his membership. (e) In the Pune District Police (Rural) there are 7 cases relating to cheating of investors have been filed against the accused Mr. Nitin Rajaram Narke out of which he had obtained anticipatory bail in 3 cases. Mr. Nitin Rajaram Narke is in judicial custody at Yarawada Jail for the remaining 4 cases.

10. From perusal of the documents forwarded by HPIA and the information received from the stock exchanges, commodities derivatives exchanges, banks and police it is, inter alia, observed that: (a) BCCPL is a member of NSE and BCCBPL is a member of MCX and NCDEX. (b) BCCPL and BCCBPL are having same promoters/directors, i.e., Mr. Nitin Rajaram Narke and Mr. Pravin B. Darawade. (c) Mr. Nitin Rajaram Narke had solicited and collected money from public by assuring high returns to them. Payments were made by the investors in the name of M/s Milestone Investment, M/s Nitin Narke Investment, M/s Blue Cheap Investment, M/s Blue Chip Investment which are not registered with SEBI. (d) Ms. Bhavana Chadha and Mr. Nitin Rajaram Narke are partners in the firm M/s Milestone Investment, in the manner 51% and 49% respectively and M/s Blue Chip Investment is constituted as a sole proprietorship by Mr. Nitin Rajaram Narke. (e) Even trading/demat accounts which are required for investment in the stock market were not opened for the investors. (f) Mr. Nitin Rajaram Narke and other entities M/s Milestone Investment, M/s Nitin Narke Investment, M/s Bluechip Investment had issued post dated cheques to the investors which were subsequently dishonored by them.

(g) Amongst others, the claim `4,17,34,647/- remains unpaid in respect of 95 investors who had deposited around `2,65,68,000/- and on whose behalf complaints have been filed by HPIA. (h) Investors had lodged police complaint against Mr. Nitin Rajaram Narke pursuant to which Mr. Nitin Rajaram Narke was in police custody for seven days. (i) Large investments had been made by Mr. Nitin Rajaram Narke in his own name from the money received from the investors; (j) During the course of investigation and police custody of Mr. Nitin Rajaram Narke it was revealed that he had purchased various properties at Rupawali in Kokan as well as at Nandur, Pune, row houses at Vimannagar as well as other properties and various luxurious cars such as Audi, BMW, Land Cruiser. (k) Details of bank accounts as available on the said post dated cheques are given below:

Sr. No. Account in the name of Name of Bank Bank account No. 1 Blue Chip Investment Axis Bank Ltd, Pune 910020033025119 2 Blue Cheap Investment ICICI Bank, Pune 147505500007 3 Milestone Investment ICICI Bank, Pune 147505500021 4 Nitin Narke Investment ICICI Bank, Pune 147505500100 5 Nitin Rajaram Narke ICICI Bank, Pune 147505500096 6 Nitin Rajaram Narke ICICI Bank, Pune 147501500483 7 Blue Cheap Investment HDFC Bank Ltd., Pune 08378620000057 8 Milestone Investment HDFC Bank Ltd., Pune 08372560000909 9 Narke Nitin Rajaram HDFC Bank Ltd., Pune 15781930000665 10 Narke Nitin Rajaram HDFC Bank Ltd., Pune 09622020000379 11 Blue Cheap Investment IDBI Bank, Pune 0651102000005098 12 Blue Cheap Investment Cosmos Co-operative Bank Ltd., Pune 09310010426 13 Blue Cheap Investment Saraswat Bank, Pune 370100100000024 14 Blue Cheap Investment The Royal Bank of Scotland N.V., Pune 1659086 15 Blue Cheap Investment Indusind Bank, Pune 0002518201050 16 Nitin Rajaram Narke Saraswat Bank 370218100000001 (l) The information in respect of above bank accounts was called for from the concerned banks. Till now information has been received from the concerned banks in respect of only 10 bank accounts (Sr. No. 1 to 10 above). The transactions, on a sample basis, as noticed in some of the above bank accounts are given below in a tabular format: Table 1: Bank account in the name of M/s Blue Chip Investment Account Details (sample transactions above `5 Name: Blue Chip Investment lacs only) No. 910020033025119 Name of Bank: Axis Bank, Pune Period : 01/04/2011 to 30/06/2012 Tran Cheque Particulars Debit (`) Credit (`) Date No. 06/04/2011 By Cash 5,00,000 07/04/2011 By Cash 7,00,000

08/04/2011 By Cash 5,00,000 09/04/2011 By Cash 9,50,000 11/04/2011 By Cash 5,00,000 13/04/2011 By Cash 5,00,000 15/04/2011 By Cash 9,50,000 18/04/2011 By Cash 9,50,000 19/04/2011 By Cash 9,50,000 20/04/2011 By Cash 8,00,000 23/04/2011 By Cash 9,50,000 25/04/2011 By Cash 9,00,000 26/04/2011 By Cash 9,00,000 27/04/2011 By Cash 9,50,000 28/04/2011 By Cash 9,50,000 29/04/2011 By Cash 9,50,000 30/04/2011 By Cash 9,50,000 02/05/2011 By Cash 5,00,000 04/05/2011 By Cash 9,50,000 05/05/2011 By Cash 9,50,000 06/05/2011 By Cash 9,00,000 07/05/2011 By Cash 9,50,000 09/05/2011 By Cash 9,50,000 10/05/2011 By Cash 5,00,000 11/05/2011 By Cash 8,00,000 12/05/2011 By Cash 6,00,000 13/05/2011 By Cash 5,00,000 16/05/2011 By Cash 5,00,000 20/05/2011 By Cash 7,00,000 21/05/2011 By Cash 7,00,000 23/05/2011 By Cash 9,50,000 24/05/2011 By Cash 9,50,000 25/05/2011 By Cash 9,50,000 27/05/2011 By Cash 5,00,000 28/05/2011 By Cash 7,00,000 30/05/2011 By Cash 9,50,000 01/06/2011 By Cash 8,00,000 03/06/2011 By Cash 9,50,000 06/06/2011 By Cash 5,00,000 07/06/2011 By Cash 9,00,000 09/06/2011 By Cash 5,00,000 10/06/2011 By Cash 8,00,000 13/06/2011 By Cash 9,50,000 14/06/2011 By Cash 9,00,000 15/06/2011 By Cash 9,50,000 18/06/2011 By Cash 9,50,000 24/06/2011 By Cash 9,50,000

27/06/2011 By Cash 5,00,000 28/06/2011 By Cash 5,00,000 29/06/2011 By Cash 5,00,000 30/06/2011 By Cash 5,00,000 01/07/2011 By Cash 5,00,000 05/07/2011 By Cash 9,50,000 06/07/2011 By Cash 5,00,000 07/07/2011 By Cash 5,00,000 11/07/2011 By Cash 6,00,000 12/07/2011 By Cash 8,00,000 13/07/2011 By Cash 5,00,000 14/07/2011 By Cash 7,00,000 15/07/2011 By Cash 5,00,000 16/07/2011 By Cash 9,50,000 18/07/2011 By Cash 9,50,000 19/07/2011 By Cash 9,50,000 20/07/2011 By Cash 9,50,000 21/07/2011 By Cash 6,00,000 23/07/2011 By Cash 6,00,000 25/07/2011 By Cash 9,00,000 26/07/2011 By Cash 8,00,000 28/07/2011 By Cash 5,00,000 29/07/2011 By Cash 5,00,000 02/08/2011 By Cash 7,00,000 03/08/2011 By Cash 9,50,000 12/08/2011 By Cash 5,00,000 16/08/2011 By Cash 5,00,000 17/08/2011 By Cash 9,50,000 29/08/2011 By Cash 5,00,000 30/08/2011 By Cash 8,00,000 02/09/2011 By Cash 6,00,000 06/09/2011 By Cash 9,50,000 07/09/2011 By Cash 8,00,000 08/09/2011 By Cash 9,00,000 09/09/2011 By Cash 9,50,000 10/09/2011 By Cash 9,00,000 12/09/2011 By Cash 5,00,000 17/09/2011 By Cash 5,00,000 20/09/2011 By Cash 5,00,000 22/09/2011 By Cash 7,00,000 24/09/2011 By Cash 5,00,000 26/09/2011 By Cash 16,00,000 07/10/2011 By Cash 9,00,000 08/10/2011 By Cash 9,00,000 14/10/2011 By Cash 9,00,000

15/10/2011 By Cash 9,00,000 18/10/2011 By Cash 5,00,000 19/10/2011 By Cash 5,00,000 29/10/2011 579916 To self 20,00,000 02/11/2011 579920 Blue Chip Investment 20,00,000 05/11/2011 By Cash 8,00,000 11/11/2011 By Cash 9,00,000 12/11/2011 By Cash 6,00,000 14/11/2011 581527 To self 20,00,000 15/11/2011 581531 To self 20,00,000 16/11/2011 579955 Nitin Narke Investment 50,00,000 23/11/2011 581536 To self 20,00,000 24/11/2011 579963 To self 30,00,000 28/11/2011 579346 To Cash/Self 5,50,000 30/11/2011 581548 To self 9,50,000 25/11/2011 579344 To self 9,00,000 10/12/2011 581557 To self 9,00,000 14/12/2011 579359 To self 5,00,000 19/12/2011 579364 To self 11,00,000 21/12/2011 581599 To self 25,00,000 27/12/2011 581600 To self 5,00,000 28/12/2011 579387 To Cash/Self 3,00,000 29/12/2011 578192 To Self 3,00,000 30/01/2012 80916 To Cash/Self 2,80,000 01/02/2012 35667 To Cash/Self 2,60,000 08/02/2012 35670 To Cash/Self 8,00,000 08/02/2012 35669 To Cash/Self 5,00,000 Table 2: Bank account in the name of M/s Blue Cheap Investment

Account Details (sample Name: Blue Cheap Investment transactions above `10 lacs only) No. 147505500007 Name of Bank: ICICI Bank, Fatima Nagar, Pune Period : 01/04/2011 to 23/04/2012 Date Particulars Cheque Withdrawals (`) Deposits (`) No. 03/05/2011 Blue Cheap Investment 10,00,000 09/06/2011 Trfr to: BCCPL 8116 20,00,000 20/06/2011 Trfr from: Nitin R Narke 10,00,000 20/06/2011 -do- 15,00,000 23/06/2011 Trfr to: Blue Chip Commodities 4905 40,00,000 Broking Pvt Ltd 30/06/2011 Trfr to: Yourself DD 4979 17,40,000 01/07/2011 Trfr to: Yourself DD 4973 11,60,000 04/07/2011 Trfr to: Yourself DD 4991 32,00,000

06/07/2011 Trfr from: Blue Chip 13,00,000 Commodities Broking Pvt Ltd 08/07/2011 Trfr to: BCCPL 907443 90,00,000 11/07/2011 Trfr to: Nitin Narke 7932 20,00,000 15/07/2011 Trfr to: Blue Chip Commodities 7984 15,00,000 Broking Pvt Ltd 21/07/2015 -do- 6373 10,00,000 21/07/2015 Trfr to: BCCPL 6374 40,00,000 27/07/2011 Trfr from: Blue Chip 55,00,000 Corporation 01/08/2011 Trfr to: BCCPL 8944 55,00,000 04/08/2011 Blue Chip Corp 9000 10,00,000 10/08/2011 Trfr from: Blue Chip 50,00,000 Corporation 10/08/2011 Blue Cheap Investment 30,00,000 10/08/2011 Blue Cheap Investment 48,00,000 11/08/2011 Trfr to: BCCPL 9025 15,00,000 12/08/2011 Blue Chip Investment 9024 30,00,000 18/08/2011 Trfr to: Nitin Narke 10411 20,00,000 18/08/2011 Blue Cheap Corporation 10412 50,00,000 20/08/2011 Cash paid self 7521 75,00,000 20/08/2011 Trfr from: Blue Chip 1,00,00,000 Corporation 20/08/2011 Trfr from: Blue Chip 50,00,000 Corporation 22/08/2011 Trfr from: Blue Chip 40,00,000 Corporation 22/08/2011 Blue Cheap Investment 40,00,000 25/08/2011 Trfr from: Blue Chip 10,00,000 Corporation 02/09/2011 Trfr to: BCCPL 8171 10,00,000 03/09/2011 Trfr from: Nitin R Narke 20,00,000 03/09/2011 Trfr to: BCCPL 11451 20,00,000 05/09/2011 Nitin R Narke 11577 10,00,000 05/09/2011 Trfr to: BCCPL 8880 10,00,000 06/09/2011 -do- 11617 10,00,000 07/09/2011 -do- 11405 10,00,000 07/09/2011 -do- 11618 10,00,000 08/09/2011 -do- 11620 10,00,000 09/09/2011 -do- 8883 10,00,000 12/09/2011 -do- 11507 20,00,000 16/09/2011 -do- 12052 10,00,000 19/09/2011 -do- 11630 10,00,000 19/09/2011 Trfr from: Nitin R Narke 15,00,000

27/09/2011 Trfr from: Blue Chip 13,00,000 Corporation 28/09/2011 Trfr to: Blue Cheap Corporation 10,00,000 03/10/2011 -do- 14,00,000 10/10//011 Trfr to: BCCPL 12851 20,00,000 12/10/2011 -do- 12260 11,00,000 13/10/2011 -do- 13002 15,00,000 17/10/2011 -do- 12096 27,00,000 19/10/2011 -do- 12864 1,14,00,000 19/10/2011 Trfr to: Nitin R Narke 12262 10,00,000 20/10/2011 Trfr to: Nitin Narke Investment 12871 10,00,000 24/10/2011 Trfr to: Nitin Narke Investment 13005 25,00,000 24/10/2011 Trfr from: BCCPL 50,00,000 25/10/2011 -do- 50,00,000 25/10/2011 Trfr from: Nitin R Narke 10,00,000 25/10/2011 Trfr to: Nitin Narke Investment 12155 25,00,000 31/10/2011 Trfr to: Blue Chip Commodities 11490 20,00,000 Broking Pvt. Ltd. 01/11/2011 Trfr to: BCCPL 8907 10,00,000 03/11/2011 Trfr from: Milestone Inv 20,17,846 03/11/2011 Trfr to: BCCPL 11443 23,26,669 03/11/2011 Trfr from: Nitin Narke Inv 29,48,137 03/11/2011 Trfr from: Nitin R Narke 16,84,614 04/11/2011 Trfr from: Nitin R Narke 18,09,345 08/11/2011 Trfr from: Nitin Narke 66,36,560 08/11/2011 Trfr from: Nitin Narke 38,19,238 Investment 08/11/2011 Trfr from: Nitin Narke 24,33,382 08/11/2011 Trfr to: BCCPL 12199 1,00,00,000 09/11/2011 Trfr from: Nitin Narke 57,62,392 09/11/2011 Trfr from: Blue Chip 20,00,000 Corporation Pvt Ltd 09/11/2011 Trfr to: BCCPL 11446 57,00,000 14/11/2011 Trfr to: Yourself for DD 13030 12,00,000 14/11/2011 Trfr from: Nitin R Narke 1,50,00,000 14/11/2011 Trfr to: BCCPL 13094 1,50,00,000 14/11/2011 Trfr from: Nitin R Narke 1,50,00,000 15/11/2011 Nitin R Narke 8912 18,00,000 16/11/2011 Trfr from: Nitin R Narke 11,27,992 16/11/2011 Trfr to: BCCPL 12958 1,00,00,000 16/11/2011 Trfr to: BCCPL 15477 19,00,000 17/11/2011 Trfr from: Nitin R Narke 50,00,000 Investment 17/11/2011 Trfr to: BCCPL 13040 50,00,000 17/11/2011 Trfr from: BCCPL 25,00,000

18/11/2011 Trfr to: Nitin Narke 15408 10,00,000 18/11/2011 Trfr from: BCCPL 50,00,000 19/11/2011 Trfr from: BCCPL 10,00,000 21/11/2011 Trfr to: BCCPL 14190 22,00,000 22/11/2011 Trfr to: Nitin R Narke 11534 30,00,000 22/11/2011 Trfr from: BCCPL 55,00,000 22/11/2011 -do- 20,00,000 23/11/2011 Trfr to: BCCPL 11648 12,00,000 23/11/2011 Trfr from: Nitin R Narke 12,00,000 Investment 25/11/2011 Trfr to: BCCPL 15426 15,00,000 28/11/2011 Trfr to: BCCPL 15543 18,00,000 28/11/2011 Trfr to: BCCPL 15545 11,00,000 29/11/2011 Trfr from: BCCPL 10,00,000 29/11/2011 Blue Chip Investment 14205 10,00,000 10/12/2011 Trfr from: BCCPL 60,00,000 12/12/2011 Trfr from: Blue Chip 40,00,000 12/12/2011 Trfr from: Nitin R Narke 11,32,000 13/12/2012 Trfr from: Nitin R Narke 21,00,000 14/12/2011 Trfr from: BCCPL 10,00,000 14/12/2011 -do- 10,00,000 11/01/2012 Trfr to: BCCPL 11536 17,00,000 18/01/2012 Cash paid self 11546 11,00,000

Table 3: Bank account in the name of M/s Blue Cheap Investment

Account Details (sample Name: Blue Cheap Investment transactions above `5 lacs only) No. 147505500007 Name of Bank: ICICI Bank, Fatima Nagar, Pune Period : 01/04/2011 to 13/02/2012 Date Particulars Cheque Withdrawals (`) Deposits (`) No. 21/06/2011 Trfr to: Blue Cheap Inv 8751 9,00,000 11/07/2011 Trfr to: Nitin Narke 7119 10,00,000 04/10/2011 Cash paid self 10259 10,00,000 19/10/2011 Trfr from: Blue Cheap 13485 9,00,000 31/10/2011 Trfr from: Blue Cheap 14551 9,00,000 03/11/2011 Trfr to: Blue Cheap Inv 13486 20,17,846 14/11/2011 Trfr from: Blue Cheap Inv 10,00,000 15/11/2011 Cash paid self 15799 8,00,000 16/11/2011 Cash paid self 14463 8,00,000 17/11/2011 Cash paid self 15676 25,00,000 17/11/2011 Trfr from: Blue Cheap 25,00,000 18/11/2011 Trfr from: Blue Cheap 80,00,000 18/11/2011 Trfr to: Blue Cheap 14599 72,00,000

18/11/2011 Cash paid self 14598 8,00,000 19/11/2011 Cash paid self 15826 30,00,000 10/12/2011 Blue Cheap Investment 30,00,000 10/12/2011 Cash paid self 17045 30,00,000 10/01/2012 Cash paid self 18676 13,00,000 18/01/2012 Trfr to: Nitin Rajaram Narke 19745 24,00,000 20/01/2012 Trfr to: Nitin Rajaram Narke 19761 22,00,000 21/01/2012 Trfr to: Nitin Rajaram Narke 15673 25,00,000 06/02/2012 Cash paid self 20826 25,00,000

Table 4: Bank account in the name of M/s Milestone Investment

Account Details (above `5 Lacs) Name: Milestone Investment No. 147505500021 Name of Bank: ICICI Bank, Fatima Nagar, Pune Period : 01/04/2011 to 13/02/2011 Date Particulars Cheque Withdrawals (`) Deposits (`) No. 21/06/2011 By cash 9,00,000 21/06/2011 Trfr to Blue Cheap Inv. 8751 9,00,000 29/06/2011 By cash 9,50,000 11/07/2011 BMA Wealth Creato 50,00,000 11/07/2011 Trfr to Nitin Narke 7119 10,00,000 17/09/2011 By cash 9,50,000 04/10/2011 Cash paid self 10259 10,00,000 14/10/2011 By cash 9,50,000 18/10/2011 By cash 9,00,000 19/10/2011 Trfr to Blue Cheap 13485 9,00,000 31/10/2011 By cash 9,00,000 31/10/2011 Trfr to Blue Cheap 14551 9,00,000 03/11/2011 Trfr to Blue Cheap Inv 13486 20,17,846 17/11/2011 Trfr from Blue Cheap 25,00,000 17/11/2011 Cash paid self 15676 25,00,000 18/11/2011 Trfr from Blue Cheap 80,00,000 18/11/2011 Trfr to Blue Cheap 14599 72,00,000 18/11/2011 Cash paid self 14598 8,00,000 19/11/2011 Cash paid self 15826 30,00,000 10/12/2011 Trfr from Blue Cheap Inv. 30,00,000 10/12/2011 Cash paid self 17045 30,00,000 10/01/2012 Cash paid self 18676 13,00,000 17/01/2012 Trfr from BMA Wealth Creators 25,00,000 Ltd 18/01/2012 Trfr to Nitin Rajaram Narke 19745 24,00,000 19/01/2012 BMA Wealth Creators 25,00,000 20/01/2012 Trfr to Nitin Rajaram Narke 19761 22,00,000

20/01/2012 Trfr from BMA Wealth Creators 25,00,000 21/01/2012 Trfr to Nitin Rajaram Narke 15673 25,00,000 06/02/2012 BMA Wealth Creators 25,00,000 06/02/2012 Cash paid self 20826 25,00,000

Table 5: Bank account in the name of Mr. Nitin Rajaram Narke

Account Details (sample Name: Nitin Rajaram Narke transactions above Rs 4.0 lacs only) No. 147505500096 Name of Bank: ICICI Bank, Fatima Nagar, Pune Period : 01/04/2011 to 13/02/2011 Date Particulars Cheque Withdrawals (`) Deposits (`) No. 26/05/2011 Trfr from Blue Cheap 5,00,000 26/05/2011 Cash paid self 8284 5,00,000 21/06/2011 By cash 9,00,000 21/06/2011 Trfr to Blue Cheap Inv. 6626 9,00,000 23/08/2011 Trfr to Blue Chip Corp 11152 4,75,000 05/09/2011 By cash 9,00,000 14/10/2011 By cash 9,00,000 03/11/2011 Trfr to Blue Cheap Inv. 14897 16,84,614 04/11/2011 Trfr to Blue Cheap 14899 18,09,345 08/11/2011 Trfr to Blue Cheap Inv. 16075 66,36,560 09/11/2011 Trfr to Blue Cheap 14874 57,62,392 18/11/2011 Trfr from Blue Cheap 10,00,000 18/11/2011 Cash paid self 16376 10,00,000 19/11/2011 Cash paid self 16377 30,00,000 21/11/2011 Trfr to Blue Cheap Inv. 16476 7,00,000 22/11/2011 Trfr from Blue Cheap 30,00,000 22/11/2011 Cash paid self 16526 30,00,000 13/12/2011 Trfr to Blue Cheap Inv. 17245 21,00,000 14/12/2011 Trfr to Blue Cheap 17349 5,00,000 27/12/2011 Cash paid self 18116 6,00,000 10/01/2012 Cash paid self 19077 8,00,000 11/01/2012 Trfr to Nitin Narke 19189 20,00,000 11/01/2012 Trfr to Blue Cheap Inv. 19188 5,00,000 11/01/2012 Cash paid self 19185 20,00,000

Table: 6 Bank account in the name of M/s Nitin Narke Investment

Account Details (sample Name: Nitin Narke Investment transactions above `4 lacs only) No. 147505500100 Name of Bank: ICICI Bank, Fatima Nagar, Pune Period : 01/04/2011 to 27/02/2012 Date Particulars Cheque Withdrawals (`) Deposits (`) No.

21/06/2011 By cash 9,00,000 21/06/2011 Trfr to Blue Cheap Inv. 8827 9,00,000 11/07/2011 Trfr to Nitin Narke 9477 10,00,000 19/07/2011 Globe Capital 20,36,253.66 06/08/2011 Trfr to Globe Capital 8499 10,00,000 23/08/2011 Trfr to Blue Chip Corp 11302 4,15,000 05/09/2011 By cash 9,00,000 14/10/2011 By cash 9,00,000 15/10/2011 Globe Capital Market 28,34,901 17/10/2011 By cash 9,00,000 20/10/2011 Trfr from Blue Cheap Inv 10,00,000 21/10/2011 Trfr from Blue Cheap Inv 10,00,000 24/10/2011 Trfr from Blue Cheap Inv 25,00,000 24/10/2011 Cash paid self 14966 25,00,000 25/10/2011 Trfr from Blue Cheap Inv 25,00,000 25/10/2011 Cash paid self 14968 25,00,000 31/10/2011 By cash 9,00,000 31/10/2011 Trfr to Blue Cheap 13975 9,00,000 03/11/2011 Trfr to Blue Cheap Inv 15023 29,48,137 04/11/2011 Trfr from Blue Cheap 7,00,000 04/11/2011 Cash paid self 16133 8,00,000 08/11/2011 Trfr to Blue Cheap Inv 14950 38,19,238 16/11/2011 Blue Chip Investment 50,00,000 17/11/2011 Trfr to Blue Cheap 13925 50,00,000 10/01/2012 Globe Capital 14,00,000 10/01/2012 Trfr from Amol Atre 20,66,526 10/01/2012 Cash paid self 19426 20,00,000 11/01/2012 Trfr to Blue Cheap 19377 12,00,000 11/01/2012 Self 19352 5,00,000 18/01/2012 Trfr from Nitin Rajaram Narke 10,00,000 18/01/2012 Cash paid self 20277 7,00,000 25/02/2012 Globe Capital Market 6,00,000

Table:7 Bank account in the name of M/s Blue Cheap Investment Account Details Name: Blue Cheap Investment No. 08378620000057 Name of Bank: HDFC Bank, Fatima Nagar, Pune Period : 01/04/2011 to 01/05/2013 Date Particulars Cheque Withdrawals (`) Deposits (`) No. 09/04/2011 Funds transfer – Wanowrie* 5,00,000 09/04/2011 Funds transfer – Wanowrie 5,00,000 15/04/2011 Chq paid – Wanowrie / Pune 208270 8,00,000 20/04/2011 Chq paid – Wanowrie / Pune 211901 8,00,000 15/05/2011 Blue Chip Corporation Pvt Ltd 208685 1,00,000

01/06/2011 Funds transfer – Wanowrie 4,00,000 13/06/2011 Funds transfer – Wanowrie 5,00,000 16/06/2011 Funds transfer – Wanowrie 9,50,000 17/06/2011 Chq paid – Wanowrie / Pune 217676 5,00,000 18/06/2011 Chq paid – Wanowrie / Pune 215651 5,00,000 20/06/2011 Chq paid – Wanowrie / Pune 210804 6,00,000 12/07/2011 Funds transfer – Wanowrie 10,00,000 12/07/2011 Funds transfer – Wanowrie 10,00,000 12/07/2011 Funds transfer – Wanowrie 5,00,000 12/07/2011 Funds transfer – Wanowrie 5,00,000 12/07/2011 Funds transfer – Wanowrie 5,00,000 12/07/2011 Pravin B Darawade 215652 20,00,000 18/07/2011 Funds transfer – Wanowrie 10,00,000 30/07/2011 Blue Chip Commodities 211778 1,00,000 10/08/2011 Chq paid – Blue Cheap Invest 218715 48,00,000 27/08/2011 Chq paid – Wanowrie / Pune 227036 24,00,000 04/10/2011 Chq paid – Wanowrie / Pune 211793 10,00,000 13/10/2011 Chq paid – Wanowrie / Pune 222897 30,00,000 14/10/2011 Chq paid – Wanowrie / Pune 227046 15,00,000 21/10/2011 Chq paid – Wanowrie / Pune 230652 12,00,000 31/10/2011 Blue Chip Corporation Pvt Ltd 222899 3,00,000 18/11/2011 Chq paid – Wanowrie / Pune 234080 25,00,000 22/11/2011 Chq paid – Wanowrie / Pune 230654 10,00,000 27/11/2011 Blue Chip Corporation Pvt Ltd 203405 1,00,000 28/11/2011 Funds transfer – Wanowrie 10,00,000 08/12/2011 BCCPL 230665 1,00,000 08/12/2011 Blue Chip Commodities 230666 50,000 10/01/2012 BCCPL 235303 1,00,000 10/01/2012 Blue Chip Commodities 235304 50,000 11/01/2012 Blue Chip Commodities 230674 1,00,000 20/01/2012 BCCPL 235313 1,00,000 30/01/2012 BCCPL 234099 3,00,000 31/01/2012 BCCPL 234100 50,000 14/02/2012 Narke Nitin Rajaram 244784 30,000 18/02/2012 Narke Nitin Rajaram 249064 2,00,000 06/03/2012 Narke Nitin Rajaram 244793 15,00,000 *Wanowrie may be a branch of HDFC, where Nitin Rajaram Narke may have accounts in the name of Blue Cheap Investment, Milestone Investment etc.

(m) From the above tables, the following is observed:

(i) Large number of cash deposits were made in the bank accounts of M/s Blue Chip Investment, M/s Blue Cheap Investment, M/s Milestone Investment, Mr. Nitin Rajaram Narke. In the bank account of M/s Blue Chip Investment, out of total deposit of `18,60,82,019/- cash deposit was to the tune of `8,58,55,000/-.

(ii) Frequent movement of funds were noticed in the bank accounts held by Mr. Nitin Rajaram Narke, M/s Milestone Investment, BCCPL, M/s Blue Chip Investment, M/s Blue Cheap Investment, BCCBPL, by way of withdrawal as well as deposits. (iii) In almost all the bank accounts, money was withdrawn, mostly by way of self cash withdrawal/cash paid self, fund transfer to the personal bank account of Mr. Nitin Rajaram Narke and again withdrawing cash from that bank account or by way of yourself demand draft. (iv) Apart from the above, it was also observed that money was transferred from the above bank accounts to BCCPL, BCCBPL, BMA Wealth Creators Ltd. (stock broker) and Globe Capital Markets Ltd. (stock broker) suggesting that money of the investors was utilised in the securities markets including commodities. (v) The bank statements also show that small amounts in cheque/cash was being credited into the accounts suggesting collection of money from investors and there were also debits of small amount by way of cheque/cash/funds transfer, suggesting repayment of the amount so collected. (vi) Type of transactions in all the said bank accounts are similar, i.e., deposits by way of cash, cheques, inter se fund transfers from one account to another account and payments also were made to either of the said accounts and mostly amounts withdrawn by Mr. Nitin Rajaram Narke.

11. While being a registered stock broker in the name of BCCPL (Registration No. INB/INF231446536), Mr. Nitin Rajaram Narke and Mr. Praveen B. Darawade deceived the clients by portraying to them that their investments are legitimate and the monies collected from them are for the purpose of investing in the stock market. For the same bank accounts in the name of M/s Blue Cheap Investment and M/s Blue Chip Investment were opened. The names “Blue Cheap” and "Blue Chip" are misleading to suggest that cheques are being given towards the stock broker BCCPL. Further, accounts were also opened in the name of firms, having name of the director, i.e., M/s Nitin Rajaram Narke Investments, M/s Nitin Narke Investments, etc. and money was collected from investors depicting to them that it was a legitimate transaction since it was being given in the name of a director of a registered stock broker.

12. I find that the scheme by Mr. Nitin Rajaram Narke and Mr. Praveen B. Darawade had sufficient material so as to give an impression to the investors that the money collected from them were getting invested in the securities market through BCCPL and that they were managing their investments properly. A company being a legal person having separate and independent existence than its shareholders acts through its board of directors who individually and collectively hold the position of trust and have fiduciary duties towards the company, the shareholders and other stakeholders. It is settled position that while alleging vicarious liabilities on the directors, the company should also be proceeded with for its defaults In the instant case, BCCPL has only two promoters/directors who amongst themselves own BCCPL fully. Further, Mr. Nitin Rajaram Narke (90% shareholding in BCCPL) floated several firms, including sole proprietorship firm and partnership firm with Ms. Bhavana Chadha and solicited money from general investors to make investment in the securities market on their behalf and promising them high returns.

13. The facts brought out above prima facie indicate that: (a) Mr. Nitin Rajaram Narke, Mr. Praveen B. Darawade and Ms. Bhavana Chadha solicited and collected funds/deposits from investors to make investments on their behalf and to that effect these schemes were in the nature of portfolio management schemes without obtaining registration as a portfolio management services as required in terms of section 12(1) of the SEBI Act, 1992 read with regulation 3 of the SEBI (Portfolio Managers) Regulations, 1993 (the Portfolio Managers Regulations); (b) BCCPL and its promoters/directors were carrying out fund based activities through multitude of firms and thus indulged in fund based activities involving personal financial liability, which BCCPL, being a member of a recognised stock exchange and SEBI registered stock broker, cannot undertake and as such BCCPL has contravened rule 8(3)(f) of the Securities Contracts (Regulation) Rules, 1957 (the SCRR). (c) Office of BCCPL is closed or shifted and all other modes of communication viz., email and telephone non-functional and as such BCCPL has failed to intimate to SEBI its new communication details and as the place where the books of account, records and documents are maintained.

14. In view of the aforementioned facts, I, prima facie, find that BCCPL has contravened conditions of registration, general obligations and responsibilities as specified under regulation 9(f) and 17(2) of the SEBI (Stock Brokers and Sub Brokers) Regulations, 1992 (hereinafter referred as “Stock Brokers Regulations”) respectively, read with clauses A(1) and A(5) of Schedule II of the Regulations. The relevant provisions of the SEBI Act, 1992, the Stock Brokers Regulations, the Portfolio Managers Regulation and the SCRR are reproduced as following:

Section 12(1) of the SEBI Act, 1992 Registration of stock brokers, sub-brokers, share transfer agents, etc 12. (1) No stock broker, sub-broker, share transfer agent, banker to an issue, trustee of trust deed, registrar to an issue, merchant banker, underwriter, portfolio manager, investment adviser and such other intermediary who may be associated with securities market shall buy, sell or deal in securities except under, and in accordance with, the conditions of a certificate of registration obtained from the Board in accordance with the regulations made under this Act:

SEBI (Portfolio Managers) Regulations, 1993 Regulation 3 – "No person shall act as portfolio manager unless he holds a certificate granted by the Board under these regulations: ………………."

The SEBI (Stock Brokers and Sub-Brokers) Regulations, 1992 “Conditions of registration. 9. Any registration granted by the Board under regulation 6 shall be subject to the following conditions, namely,- (f) he shall at all times abide by the Code of Conduct as specified in Schedule II; and ..........................................”

General Obligations and Responsibilities To maintain proper books of account, records etc. 17.(2) Every stock broker shall intimate to the Board the place where the books of account, records and documents are maintained.

SCHEDULE II Code of Conduct for Stock Brokers "A. GENERAL (1) Integrity: A stock/broker, shall maintain high standards of integrity, promptitude and fairness in the conduct of all his business. (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.

The Securities Contracts (Regulation) Rules, 1957 “Qualifications for membership of a recognised stock exchange. 8. The rules relating to admission of members of a stock exchange seeking recognition shall inter alia provide that: (3) No person who is a member at the time of application for recognition or subsequently admitted as a member shall continue as such if – (f) he engages either as principal or employee in any business other than that of securities or commodity derivatives except as a broker or agent not involving any personal financial liability, ....” 15. By their acts and omissions, BCCPL, its promoters/directors Mr. Nitin Rajaram Narke and Mr. Praveen B. Darawade, the various firms floated by Mr. Nitin Rajaram Narke in partnership with Ms. Bhavana Chadha, viz. M/s Blue Chip Investment, M/s Blue Cheap Investment, M/s Milestone Investment, M/s Nitin Narke Investment solicited, enticed and induced their clients and other investors to deal in securities and have also collected funds and deposits from their clients and other general investors through misrepresentation and allurement of high returns through various schemes to such clients and investors. They also solicited investments from investors claiming to give high returns even when the firms through which fund was directly solicited, viz. M/s Blue Chip

Investment, M/s Blue Cheap Investment, M/s Milestone Investment, M/s Nitin Narke Investment were not a SEBI registered intermediary. This prima facie appears to be a representation made in a reckless and careless manner. In my view the modus operandi of BCCPL, Mr. Nitin Rajaram Narke, Mr. Praveen B. Darawade and Ms. Bhavana Chadha indicate a scheme, plan, device or artifice or contrivance that is, besides being in contraventions of the SEBI Act, 1992, the SCRR and the Regulations as discussed above, is 'fraudulent' as defined in regulation 2(1)(c) of the SEBI (Prohibition of Fraudulent and Unfair Trade Practices relating to Securities Market) Regulations, 2003 (hereinafter referred to as "the PFUTP Regulations") which reads as under:-

Definition of “fraud” – Regulation 2(1)(c). (c)“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, and shall also include— (1) a knowing misrepresentation of the truth or concealment of material fact in order that another person may act to his detriment; (2) a suggestion as to a fact which is not true by one who does not believe it to be true; (3) an active concealment of a fact by a person having knowledge or belief of the fact; (4) a promise made without any intention of performing it; (5) a representation made in a reckless and careless manner whether it be true or false; (6) any such act or omission as any other law specifically declares to be fraudulent; (7) deceptive behaviour by a person depriving another of informed consent or full participation; (8) a false statement made without reasonable ground for believing it to be true; (9) the act of an issuer of securities giving out misinformation that affects the market price of the security, resulting in investors being effectively misled even though they did not rely on the statement itself or anything derived from it other than the market price.

And “fraudulent” shall be construed accordingly; ………………………………………………………………………………….”

16. In the light of the aforesaid observations, I, prima facie, find that BCCPL, M/s Blue Chip Investment, M/s Blue Cheap Investment, M/s Milestone Investment, M/s Nitin Narke, Investment, Mr. Nitin Rajaram Narke, Mr. Praveen B. Darawade and Ms. Bhavana Chadha not only contravened the provisions of the SEBI Act, the Stock Brokers Regulations and the Portfolio Managers Regulations but have also acted in fraudulent and deceitful manner which attracts prohibitions enshrined in section 12A (a) (b) and (c) of the SEBI Act and regulation 3 (b), (c) and (d) and regulation 4(1) and 4(2) (k) of the PFUTP Regulations which read as following:-

Section 12A of the SEBI Act- "Prohibition of manipulative and deceptive devices, insider trading and substantial acquisition of securities or control. 12A. No person shall directly or indirectly - (a) use or employ, in connection with 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 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;"

Regulation 3 of the PFUTP Regulations - "3. Prohibition of certain dealings in securities No person shall directly or indirectly— (a)………………………………………………………………………………… (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 there under; (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 there under."

"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:— ………………………………………………………………………………… (k) an advertisement that is misleading or that contains information in a distorted manner and which may influence the decision of the investors; …………………………………………………………………"

17. A person acting as a securities market intermediary is expected to protect the interest of investors in the securities market in which he operates and it ill-behoves him to become a party to any market misconduct. Such a person is required to maintain high standards of integrity, promptitude and fairness in the conduct of his business dealings, and not be motivated purely by prospects of financial gain. As a regulator of the securities market, SEBI has the duty to safeguard the interest of investors and protect the integrity of the securities market. Since the conduct of BCCPL and its directors is not in the interest of investors in the securities market, necessary action, including impounding and retaining the assets of BCCPL by way of an interim measure has to be taken against them immediately, else it may lead to further harm to the investors and loss of investors’ trust in the securities market.

18. In view of the foregoing, in order to protect the interest of investors and the integrity of securities market, I, in exercise of the powers conferred upon me by virtue of section 19 read with sections 11(1), 11(4), 11B and 11D of the SEBI Act, 1992, by way of this order, hereby issue the following directions:

(a) The financial assets of Blue Chip Corporation Pvt. Ltd. (PAN: AAECB5060A), Mr. Nitin Rajaram Narke (PAN: AECPN7019L), Mr. Pravin B. Darawade (PAN: ATUPD8449F), Ms. Bhavana Chadha (PAN: AFNPC9292G), M/s Milestone Investment, M/s Nitin Narke Investment, M/s Blue Cheap Investment and M/s Blue Chip Investment are hereby impounded till further directions. They are further directed not to dispose off or alienate any of their assets, whether movable or immovable, or any interest or investment or charge in any of such assets except for the purpose provided herein.

(b) The banks and depositories are directed that no debits shall be made in their bank accounts/demat accounts, held jointly or severally, except after confirmation from the concerned stock exchange in this regard.

(c) The concerned stock exchanges, depositories and the banks are directed to ensure that all the above directions are strictly enforced.

(d) The aforesaid entities are directed to provide the complete details of amounts collected from investors and amount due to each of them.

(e) The aforesaid entities are directed to provide a full inventory of all their assets whether movable or immovable, or any interest or investment or charge in any of such assets, including details of their all their bank and demat accounts immediately but not later than 7 working days from the date of receipt of these directions.

(f) The aforesaid entities are restrained from accessing the securities market and are further prohibited from buying, selling or otherwise dealing in securities, either directly or indirectly, or being associated with the securities market in any manner whatsoever, with immediate effect, till further directions.

(g) The aforesaid entities shall cease and desist from undertaking any activity in the securities market, directly or indirectly, in any manner whatsoever till further directions.

(h) Blue Chip Corporation Pvt. Ltd., Mr. Nitin Rajaram Narke, Mr. Pravin B. Darawade, Ms. Bhavana Chadha M/s Milestone Investment, M/s Nitin Narke Investment, M/s Blue Cheap Investment and M/s Blue Chip Investment are prohibited from mobilizing funds in any manner or pooling funds from public and from offering any unregistered service, in whatever form.

(i) Mr. Nitin Rajaram Narke, Mr. Pravin B. Darawade, Ms. Bhavana Chadha, Blue Chip Corporation Pvt. Ltd., M/s Milestone Investment, M/s Nitin Narke Investment, M/s Blue Cheap Investment and M/s Blue Chip Investment are directed to immediately withdraw and remove all advertisements, representations, literatures, brochures, materials, publications, documents, websites, etc. and any unregistered activity in the securities market.

(j) Blue Chip Corporation Pvt. Ltd., Mr. Nitin Rajaram Narke, Mr. Pravin B. Darawade, Ms. Bhavana Chadha, M/s Milestone Investment, M/s Nitin Narke Investment, M/s Blue Cheap Investment and M/s Bluechip Investment are prohibited from transferring the funds/deposits from their bank account, which were mobilised from the clients or other investors or from disposing of or alienating any asset that has been created from the funds/deposits received from their clients or other investors for purposes other than refund as directed hereinabove.

19. The above directions are without prejudice to the right of SEBI to take any other action that may be initiated against Blue Chip Corporation Pvt. Ltd., Mr. Nitin Rajaram Narke, Mr. Pravin B. Darawade, Ms. Bhavana Chadha, M/s Milestone Investment, M/s Nitin Narke Investment, M/s Blue Cheap Investment, M/s Blue Chip Investment and in accordance with law including the action in accordance with section 12 of the SEBI Act, 1992 and the provisions of the Securities and Exchange Board of India Act, 1992, the regulations framed thereunder and Securities Contracts (Regulation) Rules, 1957. (.

20. This order shall come into force with immediate effect. The stock exchanges and the depositories are directed to ensure that the above directions are strictly enforced.

21. A copy of the order shall also be forwarded to the Enforcement Department, Financial

Intelligence Unit, Economic Offences Wing and Income Tax Department for taking further necessary action at their end, if any.

22. The entities/persons against whom this Order is being passed may file their objections, if any, within twenty one (21) days from the date of this Order and, if they so desire, may avail themselves or through their authorised representatives an opportunity of personal hearing before the Securities and Exchange Board of India at its Head Office at SEBI Bhavan, Plot No. C4/A, G Block, Bandra Kurla Complex, Bandra (East), Mumbai - 400051 on a date and time to be fixed on a specific request in writing, to be received in this behalf from the entities/persons.

Sd/-

DATE: NOVEMBER 9th, 2015 RAJEEV KUMAR AGARWAL PLACE: MUMBAI WHOLE TIME MEMBER SECURITIES AND EXCHANGE BOARD OF INDIA