Confirmatory Order in the matter of Ritman Infra Limited[202/2018]

Under Sections 11, 11(4), 11A and 11B of the Securities and Exchange Board of India Act, 1992 in the matter of Ritman Infra Ltd.

1. Securities and Exchange Board of India (hereinafter referred to as “SEBI”), in the interest of investors, vide its letter dated August 7, 2017 took pre-emptive interim measures under section 11(1) of Securities and Exchange Board of India Act, 1992 (“SEBI Act”), in respect of certain listed companies identified as “shell companies” by the Ministry of Corporate Affairs including Ritman Infra Ltd. (hereinafter referred to as “RIL” / “Company”). SEBI placed trading restrictions, on the promoters/directors so that they do not exit the company at the cost of innocent shareholders. In view of the said objective, SEBI vide the said letter dated August 7, 2017 also placed the scrip of RIL in the trade to trade category with limitation on the frequency of trade and imposed a limitation on the buyers by way of 200% deposit on the trade value, so as to alert them trading in the scrip. The said measures were initiated by SEBI pending final determination after verification of credentials and fundamentals of the company by the exchanges, including by way of audit and forensic audit if necessary. The measures also envisaged, on the final determination, delisting of the company from the stock exchange, if warranted. By virtue of these measures, trading in the scrip was not suspended, but was allowed under strict monitoring so that investors could take informed investment decisions till SEBI and Stock Exchanges complete their detailed examination of such companies.

2. Aggrieved by the aforesaid letter dated August 7, 2017 issued by SEBI, RIL filed an appeal No. 238 of 2017 before the Hon’ble Securities Appellate Tribunal (hereinafter referred to as “SAT”). The Hon’ble SAT vide order dated September 11, 2017, allowed RIL to withdraw the appeal with liberty to file a representation to SEBI against the said letter dated August 7, 2017. Hon’ble SAT directed SEBI to dispose of the representation of RIL as expeditiously as possible and in any event within a period of four weeks from the date of receiving of the representation. Hon’ble SAT also held

Order in the matter of Ritman Infra Limited that passing of any order on the representation made by the appellant would not preclude SEBI from further investigating the matter and initiate appropriate proceedings if deemed fit

3. Pursuant to the decision of Hon’ble SAT that the communication of SEBI dated August 7, 2017 is in the nature of quasi-judicial order, in the interest of natural justice, an opportunity of personal hearing was granted to RIL on October 3, 2017. The authorized representative of RIL had appeared for the said hearing.

4. Thereafter, SEBI vide Interim Order dated October 13, 2017 (hereinafter referred to as “Interim Order”), had modified, subject to para 25 (iv) of the interim order, the actions envisaged in SEBI’s letter dated August 07, 2017 and the consequential actions taken by Stock Exchanges, against RIL as under:

i. The trading in securities of RIL shall be reverted to the status as it stood prior to issuance of letter dated August 7, 2017 by SEBI. ii. Stock Exchange shall appoint an independent forensic auditor, inter alia, to further verify: a) Misrepresentation including of financials and/or business of RIL and consolidating subsidiaries, if any; b) Misuse of the funds/books of accounts of RIL and consolidating subsidiaries, if any. iii. The promoters and directors in RIL are permitted only to buy the securities of RIL. The shares held by the promoters and directors in RIL shall not be allowed to be transferred for sale by depositories. iv. The other actions envisaged in SEBI’s letter dated August 07, 2017 in para 1 (d) as may be applicable, and the consequential action taken by Stock Exchanges shall continue to have effect against RIL.

5. The prima facie observations in the Interim Order are as under: “I. Observations from Annual Reports 2016-17, 2015-16 & 2014-15: i) The following are noted from the secretarial audit report for the financial year ended March 31, 2016: a. Out of 4 directors, only one independent director is present. b. The company could not have proper composition of Audit Committee and Nomination and Remuneration Committee as required under the provisions of the Companies Act, 2013. This has consequential impacts on all required decisions of the said Committees. c. The company had not appointed Company Secretary in the Audit Period i.e. 2015-16. d. As per the SEBI circular, on the uniform listing agreement, the Company has initiated the process of entering into the fresh listing agreement with the Calcutta Stock Exchange. However till the end of the audit period, the agreement was not executed. ii) From the independent auditors report for the year 2015-16, the auditor has emphasized regarding non-provisioning of liabilities arising out of performance obligation of Rs.3,62,59,530/- as in the opinion of management, no demand for the nonperformance would arise in future. iii) As per secretarial audit report for the financial year ended March 31, 2015, the Company has same violations as stated at point no. i (a to c) in the year 2014-15 and 2016-17 also. iv) From the independent auditors report for the year 2014-15, the auditor has emphasized regarding non provisioning of liabilities arising out of performance obligation of Rs.2,24,78,212/- as in the opinion of management, no demand for the nonperformance would arise in future and non-provision against investment and other loans and advances from the subsidiary Ritman Strata Chem Sdn Bhd amounting to Rs.64,17,300/- and Rs.31,00,058, respectively as in the opinion of management, that the non-receipt of the financial statement from the subsidiary is only temporary.

II. RIL has failed to file any response to the following queries that were asked from it during the hearing: • The consolidated financial statements for FY 2016-17 include one subsidiary whose financial statements are not audited and were considered for consolidation based on certification from company management. An explanation be furnished on the same. • Assets worth Rs.62.33 lakhs related to subsidiaries are reported in consolidated financial statements. Furnish the full list of assets along with the purchase order or backup documents. • Separate affidavits by Mr. Parag Majmudar and Ms. Falguni Majmudar mentioning “Whether at any point they know or had spoken to Mr. Mahendra Sethia, Mr. Arun Banerjee, Mr. Gautam Ghosh, Mr. Ravi

Shankar Pandey and Mr. Pachu Das; if yes, details of what it was regarding” • In FY 2016-17, the company has converted an amount of Rs.3.37 crore worth stock in trade into non-current investments. Furnish the full list, breakup along with supporting documents.

III. It is noted that in exercise of the powers conferred upon SEBI under Section 11 (1) & (2) (ia) of SEBI Act, 1992, SEBI had asked for certain specific information vide its letter dated September 26, 2017 (mentioned above). The said information was to be submitted by October 3, 2017, but till date, despite numerous reminders, RIL has failed to submit the complete information sought from it and has thereby violated Section 11 (1) & (2) (ia) of SEBI Act.

IV. During the hearing, the authorized representative of RIL had elucidated that RIL has recently ventured into Hospitality services in New York. The company was asked to provide specific details in this regard including the Articles/documents submitted with Exchange, respective clauses in MOA and AOA, etc. However, RIL in its reply has submitted that the aforesaid hospitality business does not concern RIL at this moment. However, it is noted that RIL on its website has announced its association with “Hotel Royal, Old City Hall, Binghampton, New York”. On the basis of this contradiction, it appears that RIL has misrepresented its business to the public.

V. As noted from the submissions of RIL, it has not appointed any company secretary as required under the Companies Act, 2013. Further, the board of directors of RIL does not have the requisite number of independent directors. These violations have been observed in RIL for three consecutive financial years.

VI. Mrs. Falguni Majmudar and Mr. Parag Majmudar were specifically asked to file separate affidavits mentioning “Whether at any point they know or had spoken to Mr. Mahendra Sethia, Mr. Arun Banerjee, Mr. Gautam Ghosh, Mr. Ravi Shankar Pandey and Mr. Pachu Das; if yes, details of what it was regarding”. However, instead of filing the affidavit, Mrs. Falguni Majmudar has submitted a mere statement stating that she is not aware of nor does she have any contact with the above named persons. Mr. Parag Majmudar did not even submit a statement to that effect.

VII. With regard to conversion of an amount of Rs.3.37 crore worth stock in trade into non-current investments in FY 2016-17, the company has failed to furnish the full list, breakup along with supporting documents.

VIII. The company has failed to provide supporting documents regarding inventories worth Rs.3.32 crore shown in FY 2016-17 and also with regard to advance against properties worth Rs. 9.94 crore. It has only provided a list of the same. Thus, the genuineness of the financials in respect of inventories and advances are suspect.

IX. With regard to trade receivables, it is noted that an amount of Rs.1.48 crore (97% of total Rs. 1.52 crore) is receivable from 3 entities namely Ritman Fullmark Inks Pvt. Ltd., Silkflex Trexim Pvt. Ltd. & Bengal Cynosure Development Pvt. Ltd., wherein Mr. Parag Majmudar and Ms. Falguni Majmudar are directors. Being a related party transaction, in order to verify whether the figures as to the receivables mentioned in the Annual Report are not misrepresented to the public, SEBI sought for the detailed back up documents. However, the company has failed to give back-up documents in this regard. The failure to provide the backup documents and relevant details, despite the fact that the Company was given several opportunities, leads to the prima facie conclusion that the company has made misrepresentation of the figures as to the trade receivables mentioned in the annual report of RIL. Further, as these transactions are related party transactions, there is a possibility that the funds receivable from the related parties carry low or zero interest rate or have been pending for several years.

X. Considering the fact that the company has represented in the Annual Report that it has received advances against property to the tune of Rs.9.94 Cr, SEBI in order to verify whether the company has made correct representation to the public on the figures of advances against property, sought for the supporting documents from the Company. However, the company despite getting several opportunities, failed to adduce supporting documents in order to prima facie prove that the said figures are correctly represented to the public. Despite seeking the entire details as to the advances, the company failed to provide even the minimum details as to the date of transaction and the counterparty. Further, despite SEBI’s request to provide specific details of the payment received by the company by way of identifying the same in its bank statement, the company failed to prima facie substantiate the factum of payment by identifying the same in its bank statement. In absence of counterparty details, advances given/received by the company cannot be identified from the bank statements given by the company (without highlighting the receipts/payments). Given this background, the failure of the company to provide the backup documents with regard to advances appearing in its annual report for 2016-17, leads to the prima facie conclusion that the Company has misrepresented the figures as to advances against property to the public in its annual report for 2016-17.

… In view of the above I observe that RIL has been in non-compliance with the provisions of Companies Act regarding appointment of company secretary and independent directors. Also, there is lack of documents to substantiate the figures disclosed in the financials of the company and to establish their genuineness. Further, despite several reminders, both the directors of the company, who were asked to submit the affidavits, have failed to do so. Also, the company/its directors have failed to submit the information along with documentary proof sought by SEBI at the time of hearing and the information sought vide earlier letter. Thus, there is prima facie evidence of misrepresentation of business and financials by the company and a strong suspicion regarding the misuse of books of accounts/funds by the company.”

6. Vide said interim order, SEBI had advised RIL to file its reply/objections to the said interim order within 30 days from the date of receipt of the said interim order and also indicate in its reply whether it desires to avail an opportunity of personal hearing on a date and time to be fixed on a specific request made in that regard.

7. Vide email dated October 13, 2017, a copy of interim order was forwarded to RIL. Vide a letter dated October 16, 2017, a physical copy of interim order was also sent to RIL at ‘Ritman Infra Limited, Ritman House 14, Syed Amir Ali Avenue, Kolkata, West Bengal - 700017” through Speed Post and the same was delivered.

8. RIL vide letter dated October 25, 2017 submitted its reply/objections to the interim order. The response of RIL in respect of the observations made in the interim order are as under:

a) Observation of the interim order: The consolidated financial statements for FY 2016-17 include one subsidiary whose financial statements are not audited and considered for consolidation based on certification from company management.

RIL’s response: “Since Indus Ind Bank didn’t allow us to remit money and thus the Malaysian Persons didn’t work as no one is expected to work without remuneration. We approached Reserve bank of India also, but they did not help. Then we filed a Writ Petition number 26891(W) of 2014 which is still pending before the Honorable Calcutta High Court”.

b) Observation of the interim order: Assets worth Rs.62.33 lakhs (CWIP) related to subsidiaries are reported in consolidated financial statements. Furnish the full list of assets along with the purchase order or backup documents.

RIL’s response:

The information submitted by RIL in this regard is summarized in the table below:

Company reply Payment Made/Invoices raised Particulars US $ INR Incorporation exp paid to MJT Management 1,695.00 Towards Operational expenses banked to MJT 3,134.00 Mgmt. – transfer back to Ritman HLB account Export of Machinery from Ritman Infra Ltd. to 91,275.00 Ritman Strata Chem Sdn. Bhd. Deposit in Stratechem Bank A/c on 07/10/2012 7,000.00 Import Clearances – bill Reimbursement to 4,372.00 CCL & Seajaan Deposit in Stratechem Bank A/c on 14/12/2012 9,353.00 Total Investments – Invested in RM 375,000 1,16,829.00 64,17,30 shares 0.00 Note: RM2 Shares paid in Cash

As noted in the above table, the company had transferred machinery worth USD 91,275 to its Malaysian subsidiary. Further the details provided/incurred for incorporation & operational expenses, deposits in bank accounts do not form part of fixed assets.

c) Observation of the interim order: Separate affidavits by Mr. Parag Majmudar and Ms. Falguni Majmudar mentioning “Whether at any point they knew or had spoken to Mr. Mahendra Sethia, Mr. Arun Banerjee, Mr. Gautam Ghosh, Mr. Ravi Shankar Pandey and Mr. Pachu Das; if yes, details of what it was regarding.

RIL’s response: “It is pertinent to mention that we had asked for details and other particulars of the above persons on same date i.e. 03.10.2017 and the reply with details was received on 09.10.2017. Affidavit of Ms. Falguni Majmudar was already submitted on October 11th 2017. Since we had informed you that Mr. Parag Majmudar was travelling out of India and it was possible to provide his affidavit on October 14th 2017. But the interim order was passed on October 13th 2017 and was sent via email at around 11:05 PM. Hence, attaching the affidavit of Mr. Parag Majmudar marked…”

d) Observation of the interim order: In FY 2016-17, the company converted an amount of Rs.3.37 crore worth stock in trade into non-current investments.

RIL’s response: “Two floors of Ritman House were given on rent, hence the value of stock i.e.3.37 crore of these two floors were taken into investments as the management decided not to sell but to earn from it’s rental”.

e) Observation in the interim order: During the hearing, the authorized representative of RIL had elucidated that RIL has recently ventured into Hospitality services in New York. The company was asked to provide specific details in this regard including the Articles/documents submitted with Exchange, respective clauses in MOA and AOA, etc. However, RIL in its reply has submitted that the aforesaid hospitality business does not concern RIL at this moment. However, it is noted that RIL on its website has announced its association with “Hotel Royal, Old City Hall, Binghampton, New York”. On the basis of this contradiction, it appears that RIL has misrepresented its business to the public.

RIL’s response: The details mentioned in their website with regards to association with Hotel Royal, New York, does not misrepresent to the public RIL submitted that “it does not concern Ritman Infra Limited at the moment”.

9. Vide interim order, RIL was advised to indicate in its reply whether it desires to avail an opportunity of personal hearing, if any. RIL vide its reply dated October 25, 2017, did not communicate its intention to avail an opportunity of personal hearing. Thereafter, SEBI vide email dated November 20, 2017 advised RIL to confirm whether it wants to avail an opportunity of personal hearing or not. RIL vide email dated November 20, 2017 informed that it wants to avail the opportunity of personal hearing. Acceding to the said request, an opportunity of personal hearing was given to RIL on December 14, 2017. The same was communicated to RIL on November 23, 2017. However, RIL vide its email dated November 23, 2017, made a request for adjournment which was acceded to and the hearing in the matter was adjourned to January 11, 2018.

10. On the said date of hearing i.e. January 11, 2018, the authorized representatives (ARs) of RIL appeared and made, inter alia, the following submissions: i) It appears that the interim order has not taken into consideration all the documents submitted by the company. ii) The company is ready to file further documents along with supporting documents to show that the conclusions drawn in the interim order are not correct. iii) The entire Ritman Group has a common website. The news relating to the New York hospitality business appearing on the group website relates to another company of the Ritman Group i.e. Ritman Concrete Ltd. iv) Regarding their dispute with IndusInd Bank, they have filed a writ petition before High Court which is currently pending. v) The company is in the process of setting up a unit in Malaysia and the company had shipped the machines to Malaysia. It was further submitted that if required, a confirmation in that regard from the Malaysian Authorities would be required by the company.

The company sought one week’s time to file its submissions along with the supporting documents and the affidavit by Mr. Parag Majmudar, which was granted. The company also sought 30 days’ time to file a confirmation from the Malaysian Authorities regarding the delivery of machines to Malaysia.

11. RIL vide its mail dated January 16, 2018 provided a part-reply. Further, RIL vide its letter dated January 18, 2018 submitted documents running into total 48 pages but did not specifically correlate these documents with the specific observations of the interim order. Thus, to the extent possible, attempt was made by SEBI to correlate the documents with the interim order observations.

12. The documents/information provided by RIL vide letter dated January 18, 2018 is as under: a) Affidavits dated January 12, 2018 by Mr. Parag Majmudar and Mrs. Falguni Majmudar stating that they are not aware nor have any contact with Mr. Mahendra Sethia, Mr. Arun Banerjee, Mr. Gautam Ghosh, Mr. Ravi Shankar Pandey & Mr. Pachu Das. b) Photocopy of invoices for purchase of machinery/parts/material from various suppliers, ledger account of suppliers and relevant bank account statement highlighting the payment (entries) to suppliers. The particulars are as follows:

Supplier Invoi Data of Particulars Amount Third party verifiable Name ce Invoice in INR documents provided No. Amar 0800 27/12/2 Lab Autoclave- 4,06,709 Copy of invoice Equipments 010 Stirred 5 L provided. The invoice Pvt. Ltd. was in the name of erstwhile company name i.e. Lancing Investment Ltd. (LIL) Ritman Infra Ltd. has taken over the LIL. The relevant Bank statement was not provided. Amar 1111 22/03/2 Autoclave - 32,20,577 Ledger account of Equipments 012 Fabricated supplier, statement of Pvt. Ltd. 1000 L IndusInd Bank (relevant) highlighting the payments (entries) to vendor. As highlighted, the payments were made on 20/07/2011, 20/10/2011, 30/01/2012 & 24/04/2012. Parag R-89 14/07/2 Model No: HL - 93,250 Purchase order dated Engineering 012 2000- I I Parag 13-07-2012, delivery Make Oil note dated 14-07-2012 Sealed Rotary & statement of IndusInd High Vacuum Bank (relevant) Pump with highlighting the payment NRV + (entry) to supplier on Regulator + 05/07/2012. RIL has Vacuum Gauge also provided invoice With 5 HP 3 no.R-157 dated 11-10-phase electric 2012 for Rs.95,115. Motor Energypack EX-12 26/07/2 Diesel Oil Fired 4,88,766 Letter dated 27/07/2012 Boilers Pvt. 012 400 Kgs/HR of Energypack Boilers Ltd. Steam Boiler Pvt. Ltd., Consignment note dated 26/07/2012, L/R No. 93639 issued by Goods India Carriers, ledger account of supplier and, statement of IndusInd Bank (relevant) highlighting the payments (entries) to vendor.

As highlighted, the payments were made on 27/01/2012 & 03/05/2012. 42,09,302 c) Copy of invoice no. RIL/MECH/001/12-13 dated 24/08/2012 issued by Ritman Infra Ltd. to Ritman Strata Chem. SDN BHD for USD 91,275, & packing list of machinery, bill of lading no. INSAMYPKG1022 for shipping of 4812 KGS of Machinery by K R Container Lines Pvt. Ltd. (shipped on board date 14/09/2012), copy of invoice no. CCL/M/1822 dated 03/10/2012 of Care Container Lines for Rs.2,36,250/- & receipt no. CCL/082 dated 03/10/2012 of Care Container Lines for Rs.2,36,250/-, copy of invoice no. CCL/M/1662 dated 17/09/2012 of care container lines for Rs.3,44,742/- & receipt no. CCL/026 dated 18/09/2012 of care container lines for Rs. 3,44,742/- and copy of receipt no.1001 dated 17/10/2012 for Rs.1,00,000/- issued by Seajaan Logistics Pvt. Ltd. d) Mail communications dated 02/10/2012 between RIL and Malaysian Industrial Development Authority (MIDA). e) Statement showing outstanding as on 31/03/2017 of Malaysian Ringgit (RM) 56,851.06 (expenses incurred for Ritman Strata Chem SDN. BHD.) & mail communication dated 24 & 26 April, 2017 for settlement of outstanding. f) Statement showing total investment in Ritman Strata Chem SDN.

BHD. of US $ 1,16,829

Particulars In US $ Third party verifiable documents provided Company Incorporation 1,695 Statement of IndusInd Bank, A/c. Expenses paid to MJT no. 0015-614795-060 highlighting Management Service the entry on 11/06/2012 for USD Sdh. Bhd. 1695 (converted into Rs.96,729) Towards Operational 3,134 Statement of IndusInd Bank, A/c. Expenses paid to MJT no. 0015-614795-060 highlighting Management Service the entry on 09/07/2012 for USD Sdh. Bhd. 3134 (converted into Rs.1,79,653) Export of Machinery from 91,275 Copy of invoice no. Ritman Infra Ltd., India RIL/MECH/001/12-13 dated 24/08/2012 issued by Ritman Infra Ltd. to Ritman Strata Chem. SDN BHD Deposit in Strata Chem 7,000 Statement of IndusInd Bank, A/c. Bank A/c. on 07/10/2012 no. 0015-614795-060 highlighting the entry on 03/10/2012 for USD 7000 (converted into Rs.3,74,096)

Machinery Import 4,372 Nil Clearance Expenses Deposit in Strata Chem 9,353 Statement of IndusInd Bank, A/c. Bank A/c. on 14/12/2012 no. 0015-614795-060 highlighting the entry on 14/12/2012 for USD 9353 (converted into Rs.5,19,662) Total 1,16,829

The RIL has also provided form of Annual Return of Ritman Strata Chem SDN. BHD. (6 pages) made up to 30th day of September 2013. In the form, it is mentioned that Ritman Strata Chem SDN.BHD. was inactive during said financial period. g) Copy of rent invoices issued by Ritman Infra Ltd. in the name of Hotel Platinum viz. RIL/RENT/03/17-18, dt.01-May-2017 for Rs.1,43,750/-, RIL/RENT/05/17-18, dt.01-Jun-2017 for Rs.1,43,750/-, RIL/RENT/07/17-18, dt.01-Aug-2017 for Rs.1,47,500/-, RIL/RENT/09/17-18, dt.02-Aug-2017 for Rs.1,47,500/-, RIL/RENT/013/17-18, dt.01-Sep-2017 for Rs.1,47,500/-, RIL/RENT/019/17-18, dt.03-Oct-2017 for Rs.1,47,500/-, RIL/RENT/021/17-18, dt.01-Nov-2017 for Rs.1,47,500/-.

13. Considering the above mentioned response of RIL to the Interim order, I observe the following:

a. During the hearing the company was asked to furnish an explanation for consolidation of unaudited financials of one subsidiary on the basis of certification from company management. However, the company has failed to provide a satisfactory explanation along with supporting documents in this regard. b. The submissions of RIL relating to Capital Work in Progress have not been supported with third party verifiable documents. In fact, the ‘total’ provided in the submissions does not match with the figure in the balance sheet for the year 2016-17. Further, the documents that have been filed by RIL vide letter dated January 18, 2018 remotely correlate and could be verified with IndusInd Bank only to the extent of Rs.42 lakhs out of a total of Rs. 62.33 lakhs shown towards CWIP in its annual report for 2016-17. The company has provided particulars for only one class of asset i.e. machinery.

c. With respect to USD 4,372 incurred for Machinery Import Clearance, the company has not provided the bank account statement. d. With respect to conversion of an amount of Rs.3.37 crore worth stock in trade into non-current investment in FY 2016-17, the company has enclosed only rental bills raised in the name of Hotel Platinum. It may be noted that all the rental invoices are pertaining to FY 2017-18. The Company was advised to provide the third party verifiable supporting documents like bank statement, agreement, resolution/minute(s) supporting the decision of management for conversion, basis of valuation etc. However, RIL has failed to provide the same. e. Further, the company has failed to reply on the following major observations stated in the interim order: i) Supporting documents for inventories worth Rs.3.32 crore. (Interim Order Para no. 19 VIII) ii) Advance against properties of Rs.9.94 crore, explain what this relates to, underlying contracts/documents (Interim Order Para no. 19 X). iii) Short term loans and advances of Rs.5.60 crore (as per standalone financial statements) (includes Rs.4.75 crore as an advance against properties), -backup documents and also bank statement highlighting the receipts/payments. iv) Backup documents (such as sales agreement, etc.) for trade receivables of Rs.1.52 crore. (Interim Order Para no. 19 IX). f. Further, RIL has also failed to reply against Interim Order observations at paragraph 19 I (relating to Observations from Annual Reports 2016-17, 2015- 16 & 2014-15), 19 III (relating to non-submission of specific information sought by SEBI vide its letter dated September 26, 2017) and 19 V (relating to non-appointment of company secretary and the required number of independent directors).

14. I note that RIL, at this stage, has failed to submit any third party/banks documentary evidence in support of its claims and has also failed to give a plausible reason/explanation alongwith suitable documentary evidences in respect of many of the allegations / prima facie findings made in the interim order.

15. In view of the above, I find that the facts and circumstances of the case as brought out in the interim order, have not changed adequately, so as to justify the dis-continuation/ modification/ revocation of the directions passed in the interim order.

16. Thus, I, in exercise of the power conferred upon me under sections 11, 11(4), 11A and 11B read with section 19 of the Securities and Exchange Board of India Act, 1992 hereby confirm the directions issued against RIL and other entities vide interim order dated October 13, 2017.

17. Copy of this Order shall be forwarded to the recognized stock exchanges for information and necessary action.

18. A copy of this Order shall also be forwarded to the Ministry of Corporate Affairs and Serious Fraud Investigation Office for their information.

Sd/-

DATE: April 25, 2018 MADHABI PURI BUCH PLACE: MUMBAI WHOLE TIME MEMBER SECURITIES AND EXCHANGE BOARD OF INDIA