Directions under Section 11 in the matter of S J Corporation Limited

1. On the basis of an internal alert, the Bombay Stock Exchange Limited (hereinafter referred to as BSE) conducted an investigation into the dealings in the shares of S J Corporation Limited (hereinafter referred to as SJCL) for the period between March 18, 2008 and July 16, 2009. As the shares of the company were illiquid in the past, the unusual price rise necessitated an examination by the Securities and Exchange Board of India (hereinafter referred to as SEBI). The period taken for examination by SEBI was between March 18, 2008 and October 1, 2009. During the said period, the share price moved up from Rs. 392.00 on March 18, 2008 to Rs. 3,464.60 on August 27, 2009. It was noticed that SJCL came out with a stock split in the ratio of 1:10 on August 28, 2009 (Friday). The number of shares of SJCL for March and June 2009 were 2,00,000 (at face value of Rs 10) and for September 2009, it was 20,00,000 (at face value of Re 1), post stock split. The share price opened at Rs. 363.75 on August 31, 2009, the next trading day, which went upto Rs.816/- on September 30, 2009 and the closing share price on October 1, 2009 was Rs. 778.10/-. The aforesaid price movement resulted in an overall price rise of 1981.63%. SJCL is listed only on BSE and was placed in ‘T’ (Trade-for-Trade) Group till February 2008. It was shifted to ‘B’ Group in February 2008 and was again shifted to ‘T’ Group with effect from October 6, 2009. From October 15, 2009, the price circuit filter was reduced to 2%. Subsequently, the price ranged from Rs. 702/- to Rs.

441/- (on November 19, 2009) and to Rs. 597/- (on December 14, 2009). The preliminary findings of the case are as under:

2. SJCL was incorporated as Grandpa Trading & Agencies Limited on September 15, 1981 and was promoted by Jayesh Textiles Private Limited, Divyesh Traders Private Limited, Hima Textiles Private Limited, Mr. Bhavin H. Parekh, Mr. Rajesh Mehta and Mr. Ketan Boda. The said company was engaged in the business of merchandise, produce on ready or forward basis on its own account. In 1999, the said company had decided to diversify its activities in the areas of information technology, software development, software packages, systems, programmes, internet and cyber space related applications, multimedia etc. Subsequently, the name of the said company was changed to Corcomp Infosystems Limited in the year 1999. Thereafter, Jayesh Textiles Private Limited, Divyesh Traders Private Limited, Hima Textiles Private Limited (promoters of said company) had sold 1,32,000 shares to Mr. Dayabhai G. Jivani (33,000 shares), Mr. Jagdishbhai H. Jivani (33,000 shares), Mr. Savjibhai D. Patel (33,000 shares) and Ms. Usha S. Patel (33,000 shares) for cash at a price of Rs 15/- each as per Share Purchase Agreement dated April 6, 2007. Thereafter, the said acquirers came out with a public announcement for an open offer on April 9, 2007 for 40,000 shares at an offer price of Rs. 142/- per share. Subsequently, the name of the company was changed to S J Corporation Limited and the same was listed under the category “Other Apparels and Accessories”. Further, Mr. Savjibhai D. Patel and Ms. Usha S. Patel (acquirers) along with Shyam Star Gems Limited (person acting in concert with them) had acquired 70,100 shares of SJCL from other promoters i.e. Mr. Jagdish H. Jivani and Mr. Dayabhai G. Jivani on July 31, 2008. Consequently, the aforesaid acquirers made a public announcement on August 4, 2008 in respect of 40,000 shares at Rs. 447/- per share. As a result, the holding of Mr. Savjibhai D. Patel and his wife, Ms. Usha S. Patel had increased to 1,48,000 shares constituting 74% of share capital of SJCL. Since then there has been no change in their shareholding. The details of the acquisitions in 2007-2008 and 2008-2009 are given below:

Sr. Date of acquisition No. of shares Percentage of Shares shares acquired as a No. acquired shares acquired acquired in percentage of total open offer shares 1. April 6, 2007 66,000 33.00% 8,200 4.10% 2. August 4, 2008 70,100 35.05% 7,800 3.90%

3. The monthly price and volume data in respect of SJCL for the period between January 2009 and October 2009 is given below: Month Open High Low Close No of Price(Rs.) Price(Rs.) Price(Rs.) price(Rs.) shares No of Total Turnover traded trades (Rs.) January 2009 570.15 517.15 570.15 13 517.15 3 6,854.00 February 2009 598.65 692.90 598.65 692.90 18 6 11,957.00 March 2009 727.50 928.40 727.50 928.40 36 8 29,611.00 April 2009 974.80 1,023.50 974.80 1,023.50 20 4 19,983.00 May 2009 1,074.65 1,243.95 1,074.65 1,243.95 210 5 232,442.00 June 2009 1,306.10 2,127.15 1,306.10 2,127.15 117 15 174,017.00 July 2009 2,233.50 2,850.45 2,233.50 2,850.45 6 6 15,189.00 August 2009 2,992.95 3,464.60 363.75 363.75 10 6 29,452.00 POST SPLIT September 2009 381.90 816.00 381.90 797.20 23220 860 16,877,616.00 October 2009 801.00 801.00 562.70 562.70 11748 741 8,097,562.00

4. The facts which alluded to the unusual nature of trading in SJCL are mentioned below: • The share price had continuously been rising from January 2009 onwards on extremely low volumes and number of trades. • Increase in volumes in September, 2009 and October, 2009 was after the stock split and indicates mounting interest of unsuspecting investors in the scrip after the said split. • There is an increase in number of shareholders from 28 to 129 from June 2009 to September 2009. Out of the said 28 shareholders, it was observed that twelve are promoter related/associated entities. • It is seen that prior to April 6, 2007, when the present promoters initially acquired 66,000 shares in SJCL, the scrip had traded on November 28, 2006 at Rs. 141/-. After April 6, 2007, the next trade in the scrip was registered only on October 24, 2007 at a price of Rs. 148/- i.e. two trades over eleven months. Thereafter, the scrip traded till December 5, 2007 when it closed at a price of Rs. 405/-. Thereafter, the next trade occurred only on March 18, 2008 (after three months) at a price of Rs. 386/-. Between March 18, 2008 (when the scrip traded at Rs. 386/-) to August 18, 2008 (when it was traded at Rs. 492/-), the shares were traded only on six days. • The announcement of second open offer was made on August 4, 2008. Pursuant to the trade on August 18, 2008, the shares were seen to have traded after a gap of almost five months on January 28, 2009 at a price of Rs. 517.15.

6. The shareholding pattern of SJCL for the quarters ended March 2009, June 2009 and September 2009 is mentioned below. a. Shares held by Promotors/Promotors Group. Sr. Name of Shareholder March 2009 June 2009 September 2009 No. No. of Shares Shares as % No. of Shares Shares as % No. of Shares Shares as % of Total No. of Total No. of Total No. of Shares of Shares of Shares 1. Savjibhai D. Patel 78,100 39.05 78,100 39.05 7,81,000 39.05 2. Usha S. Patel 69,900 34.95 69,900 34.95 6,99,000 34.95 Total 1,48,000 74.00 1,48,000 74.00 14,80,000 74.00 b. Persons holding more than 1% of shareholding: March 2009 June 2009 September 2009 Shares Shares as % of as % of Name of the No. of Total No. No. of Total No. No. of Shares as % of Total No. Sl. No. Shareholder Shares of Shares Shares of Shares Shares of Shares 1 Ketan Mugatlal Boda 3,000 1.50 3,000 1.50 - - 2 Ramesh Dhanjibhai Patel 7,255 3.63 7,955 3.98 97,995 4.90 3 Dharmishta Rameshbhai Patel 8,750 4.38 9,500 4.75 99,050 4.95 4 Reshma R Patel 6,000 3.00 9,500 4.75 98,500 4.93 5 Chanchpara Vasantben Laljibhai 9,100 4.55 9,100 4.55 21,000 1.05 6 Madhuben Manjibhai Chanchpara 2,500 1.25 - - - - 7 Shantibhai Manjibhai Chanchpara - - 2,000 1.00 - - 8 Laljibhai Chanchpara - - - - 20,000 1.00 9 Pritesh Laljibhai Chanchpara - - - - 30,000 1.50 10 Dhananjaya Sushilchandra Desai 3,100 1.55 - - - - 11 Anagram Stockbroking Ltd - - - - 32,581 1.63 Total 39,705 19.86 41,055 20.53 3,99,126 19.96 (Source: BSE Website) c. Persons holding less than 1% of shareholding. Sr. No of shareholders March 2009 June 2009 September 2009 No. No. of Shares Shares as % No. of Shares Shares as % No. of Shares Shares as % of Total No. of Total No. of Total No. of Shares of Shares of Shares 1 36 shareholders 12,295 6.14 - - - - 2. 28 shareholders - - 10,945 5.47 - - 3. 129 Shareholders - - - - 120,874 6.04

7. From above tables, following facts are noted: • There are only 36 and 28 shareholders with less than 1% holding for March and June 2009 quarters, respectively. • Total number of shares were only 2,00,000, of which the promoters held 1,48,000 shares. Out of the remaining 52,000 shares, 41,055 were held by persons with more than 1% holding. • Mr. Ramesh D. Patel, Ms. Dharmishtha Patel and Ms. Reshma Patel, in the category of ‘persons holding more than 1%’, are allegedly connected to each other and were also found to be related to the promoters. The aforesaid persons together held 26,955 shares (i.e, 13.48 % of total shares) and 2,95,545 shares (i.e.14.77 % of total shares) as per June 2009 and September 2009 quarters, respectively. • It is observed that at the end of September 2009 quarter, approximately 89% of shareholding in SJCL was directly or indirectly under the control of promoters i.e. 17,86,246 shares out of the total shareholding of 20,00,000 shares were held by the promoters or promoter related entities as enumerated in the Table at paragraph 19 of this Order.

Analysis of Financial Results of SJCL:

8. A preliminary analysis of the financials (details of which are given below) of SJCL which have a direct impact on its share price and information available with investors, prima facie casts a suspicion on its financial status. Review of Balance Sheet from March 2001 to March 2009: (Rs. In Crore) Year Mar Mar Mar Mar Mar Mar Mar Mar Mar 09 08 07 06 05 04 03 02 01 SOURCES OF FUNDS : Share Capital 0.20 0.20 0.20 0.20 0.20 0.20 0.20 0.20 0.20 Reserves Total 1.64 -1.88 -1.79 -2.06 -2.02 -1.66 -1.05 -0.52 -0.50 Total Shareholders Funds 1.84 -1.68 -1.59 -1.86 -1.82 -1.46 -0.85 -0.32 -0.30 Secured Loans NIL NIL NIL NIL NIL NIL NIL NIL 0.54

Unsecured Loans NIL 1.78 1.79 2.55 2.59 2.45 2.65 2.78 2.83 Total Debt NIL 1.78 1.79 2.55 2.59 2.45 2.65 2.78 3.37 Total Liabilities 1.84 0.10 0.20 0.69 0.77 0.99 1.80 2.46 3.07 APPLICATION OF FUNDS Gross Block 0.60 0.47 NIL 0.70 0.70 0.70 0.65 0.64 0.57 Less:Accumulated depreciation 0.03 NIL NIL 0.48 0.39 0.31 0.22 0.13 0.05 Net Block 0.57 0.47 NIL 0.22 0.31 0.39 0.43 0.51 0.52 Investments NIL NIL NIL NIL NIL NIL NIL NIL NIL Current Assets, Loans & Advances Inventories 3.14 NIL NIL 0.15 0.30 0.45 0.95 1.21 0.84 Sundry Debtors 19.47 NIL 0.17 0.40 0.35 0.62 0.55 0.93 0.44 Cash and Bank 0.41 0.09 0.01 NIL 0.03 0.02 0.22 0.08 1.43 Loans and Advances 0.02 0.02 0.02 0.03 0.05 0.15 0.34 0.25 0.23 Total Current Assets 23.04 0.11 0.20 0.58 0.73 1.24 2.06 2.47 2.94 Current Liabilities 21.75 0.48 NIL 0.11 0.27 0.65 0.75 0.63 0.50 Provisions 0.02 NIL NIL NIL NIL NIL NIL NIL NIL Total Current Liabilities 21.77 0.48 NIL 0.11 0.27 0.65 0.75 0.63 0.50 Net Current Assets 1.27 -0.37 0.20 0.47 0.46 0.59 1.31 1.84 2.44 Miscellaneous Expenses not NIL NIL NIL NIL NIL 0.01 0.06 0.11 0.11 written off Total Assets 1.84 0.10 0.20 0.69 0.77 0.99 1.80 2.46 3.07 Contingent Liabilities NIL NIL 0.01 0.01 0.02 0.01 NIL NIL NIL

9. On a perusal of the aforesaid details, the following emerge: • From the year 2001 onwards the financial position of SJCL was deteriorating and it had a negative net worth till March 2009. • During the year ended March 31, 2008, SJCL did not carry out any business activity and trading in the scrip was largely absent. • The profit for the year ended March 31, 2009 was Rs. 3.54 crore as compared to a loss of Rs. 0.10 crore for the year ended March 31, 2008 with a resultant transfer of Rs 1.64 crore to reserves compared to a negative Rs 1.88 crore of reserves for March 31, 2008. • On analyzing the Profit/Loss Account and Balance Sheet of SJCL for the financial year 2008-09, it was observed that SJCL made sale and purchase to the tune of Rs. 22.28 crore and 18.62 crore, respectively. The money receivable by SJCL from its debtors as on March 31, 2009 stood at Rs. 19.47 crore. Therefore, it appears that the total sale by SJCL was on credit and its working capital, if any, was totally blocked in debts. Similarly, the total purchases were to the tune of Rs. 18.62 crore and Rs. 21.73 crore stood payable by SJCL, prima facie appears improbable. The debtors and creditors appear to be balancing each other and therefore actual cash flows in the business seem doubtful. • More suspiciously, in the case of SJCL, all sales were only to two clients, both located in Hongkong. Apparently, SJCL had not paid the entire amount of purchase to its four suppliers, the major one was also located in Hongkong. SJCL had dealt only with 2 clients and 4 suppliers during the year ended March 31, 2009. • The financial statements appear to be mere book entries. However, further analysis of financial statements, is a subject matter of detailed investigation, which has been initiated. Further, the name appearing as authorized signatory in all sale invoices raised by M/s. Floral Impex (the major supplier in Hongkong) shared his last name, Chanchpara with a few of the shareholders holding more than 1% holding in SJCL. • The financials of SJCL may not support the rise in share price, since its total assets stood at only Rs. 10 lakh as on March 31, 2008.

10. The quarterly un-audited (ending March 2009, June 2009 and September 2009) and the annual audited results (2007-08 & 2008-09) of SJCL are given below: (Rs in million) Quarterly Annual Unaudited Type UnAudited Unaudited Audited Audited Date Begin 01/01/2009 01/04/2009 01/07/2009 01/04/2008 01/04/2007 Date End 31/03/2009 30/06/2009 31/09/2009 31/03/2009 31/03/2008 Net sales 32.25 29.50 137.58 220.80 - Other Income - 0.01 0.80 - - Total Income 32.25 29.51 138.38 222.80 - Net Profit 2.63 1.01 18.16 35.40 -0.94 Equity Capital 2.00 2.00 2.00 2.00 2.00 EPS 13.14 5.05 9.08 177.00 -4.71 29/05/2009 04/08/2009 14/10/2009 29/05/2009 30/05/2008 Declared on (Source: bseindia.com)

An analysis of the audited financial results of SJCL for the year ended March 31, 2009 indicates that the total income was Rs.222.80 million with a net profit of Rs.35.40 million as compared to net loss of Rs.0.94 millions for the year ended March 2008. Further, the results announced for the quarter July to September 2009 appears to be extremely positive.

Financials of SJCL vis-à-vis Shyam Star Gems Limited

It is observed that Mr. Savjibhai D. Patel and Ms. Usha S. Patel (the promoters of SJCL) are also the promoters of Shyam Star Gems Limited where Mr. Savjibhai

D. Patel is the Managing Director. It is noted that Shyam Star Gems Limited is listed on BSE under the category “Other Apparels and Accessories”.

11. Shyam Star Gems Limited is a Person acting in concert with Mr. Savjibhai D. Patel and Ms. Usha S. Patel, promoters of SJCL and the financial status of SJCL vis-à-vis Shyam Star Gems Limited is given below: [Rs. in crore]

Particulars SJCL Shyam Star Gems Limited March 2009 March 2008 March 2009 March 2008 Equity Paid Up 0.20 0.20 6.91 6.90 Networth 1.84 -1.68 47.75 30.76 Profit After Tax 3.54 -0.09 16.80 19.78 Book Value (per share) 92.00 -84.00 68.13 44.58 Market Value (per share) 928.40 386.00 6.32 80.30 Market Capitalisation 18.57 7.72 4.39 55.81 EPS (annualized per share) 177.00 0.00 24.21 28.46 Dividend (annualized %) 10.00 0.00 6.00 12.00 ROG-Capital Employed (%) 1,740.00 -50.00 54.81 260.02 ROG-Market Capitalisation (%) 140.54 0.00 -92.13 324.41 (Source: capitaline.com) (Note: Book Value, Market Value and EPS are per share in Rupees and not in Crore) 12. From the comparative figures of both the aforesaid companies which share the same promoters i.e Mr. Savjibhai D. Patel and Ms. Usha S. Patel, the following are noted: (a) As on March 31, 2008, the market price of the shares of Shyam Star Gems Limited was Rs. 80.30 per share, when its profit after tax (PAT) was Rs.19.78 crore, whereas in case of SJCL, its market share price was Rs. 386/- per share, when it had incurred a loss of 0.09 crore. It is surprising to note that the share price of a profit making entity is much lower than the share price of a loss making company, especially when both the entities are in the same area of business. (b) It is very interesting to note that during a period of only one year (2008- 2009), the market capitalization of SJCL had increased by 140.54%, whereas the market capitalization of Shyam Star Gems Limited had gone down by 92.13%. (c) Earning per share (EPS) of SJCL was Rs. 177/- as on March 31, 2009. It may be noted that the EPS of SJCL as on March 31, 2008 was NIL. In the case of Shyam Star Gems Limited, the EPS came down from Rs. 28.46 on March 31, 2008 to Rs. 24.21 as on March 31, 2009.

(d) During the year ended March 2009, the promoters of SJCL had announced a 10% dividend, whereas they reduced the dividend by 50% in Shyam Star Gems Limited. (e) The Return on Capital Employed (ROCE) in the case of SJCL moved from negative 50% in year ended March 2008 to a positive of 1,740 % in the year ended March 2009. In the case of Shyam Star Gems Limited, those figures were reducing.

Corporate Announcements by SJCL: 13. In the month of September 2009, the trading in the shares of SJCL increased substantially, which coincides with series of announcements made by SJCL to split shares and also the announcement of bonus shares. The chronology of announcements made is briefly stated as under: Sr. No. Date & Time of display on BSE website Announcement I. May 14, 2009 at 12:52:29 pm The company informed BSE that meeting of BOD of the company will be held on May 29, 2009 to approve subdivision of equity shares, consider issue of bonus shares and to recommend dividend. II. May 29, 2009 at 4:32:49 pm The company informed BSE that BOD of the company at its meeting held on May 29, 2009, inter alia, has recommended dividend of Re.1.00 per shares. III. August 01, 2009 at 4:14:30 pm The company informed BSE that AGM held on July 31, 2009 has declared dividend @ 10% and approved ordinary resolution for sub-division of shares. IV. August 04, 2009 at 4:07:51 pm Further company informed that members of the company at AGM held on July 30, 2009 have dropped the resolution pertaining to issue of bonus shares in the ratio 3:1 i.e. 3 new shares for every 1 share held. V. August 12, 2009 6:02:19 pm SJ Corporation Ltd has informed BSE that August 31, 2009 has been fixed as the Record Date for the purpose of Sub-division of Rs 10/- per share of the Company into the shares of Re 1/- each. VI. September 02, 2009 4:48:39 pm SJ Corporation Ltd has informed BSE that a meeting of the Board of Directors of the Company will be held on September 26, 2009, inter alia, to consider issue of bonus shares to the Members of the Company whose names appear in the Register of Members as on record date. VII. September 09, 2009 6:38:59 pm SJ Corporation has announced the resignation of Savji D. Patel from the post of directorship of the company with effect from 24 December 2008. The company has also appointed Sanjay Vallabhbhai Patel and Bhavik Prakash Patel as directors of the company with effect from 11 August 2009. VIII. September 29, 2009 1:43:08 pm SJCL has informed BSE that the Board of Directors of the Company at its meeting held on September 26, 2009, inter alia, has reconsidered & declared bonus shares in the ratio 3:1 [i.e. Three new shares for every One share held] to the Members of the Company whose names appear in the Register of Members as on record date.

14. It is very pertinent to note here that the promoters and their associates directly or indirectly hold around 89% of the shareholding in SJCL. Thus, the aforesaid announcements are only beneficial to the promoters especially, as SJCL is closely held. Thus, it is necessary to go into details to examine how the board of SJCL had decided the same, besides examining their source of funds and expenditure to see whether SJCL actually is in operation or is merely a paper company. Further, the announcement of the resignation of Mr. Savjibhai D. Patel from the directorship of the company with effect from 24 December 2008 was made only on September 9, 2009.

Price Volume Analysis:

15. The trading in the shares of SJCL was examined for the period March 18, 2008 to October 1, 2009. The price volume analysis for the above period is divided into three sub-periods as given below: (i) Period I: March 18, 2008 to January 27, 2009 It is observed that during the above period, trading took place only on six trading days between March and August 2008. The price rise during this period was not significant (as given below), but it is pertinent to note that most of the trades were undertaken by related clients. Particulars Price (Rs.) Date Open 392 March 18, 2008 High 493 August 18, 2008 Low 386 March 18, 2008 Close 493 August 18, 2008 Average Daily Volume : 29 shares Price Movement: 25.77% upwards Pursuant to the trade on August 18, 2008, the shares were seen to have traded after a gap of almost five months on January 28, 2009.

(ii) Period II: January 28, 2009 to August 27, 2009

16. As stated above, there was no trading from August 19, 2008 in the shares of SJCL till January 27, 2009. It was noted that after the aforesaid gap in trading, certain promoter related entities started trading in the scrip. The price was seen to have risen significantly on extremely low single digit volumes hitting price circuits on each trade day on one-share trades. The same can be observed from the following table: Particulars Price (Rs.) Date Open 517 January 28, 2009 High 3,465 August 27, 2009 Low 517 January 28, 2009 Close 3,465 August 27, 2009 Average Daily Volume : 3 shares Price Movement: 570.% upwards

III. Period III: August 28, 2009 to October 1, 2009 (period after stock split)

17. SJCL came up with stock split in the ratio of 1:10 (i.e. one share of face value of Rs. 10 was split into 10 shares of Re. 1 each). The price volume data after the stock split for the above period is as under: Particulars Price (Rs.) Date Open 363 August 28, 2009 High 816 September 30, 2009 Low 363 August 31, 2009 Close 778 October 01, 2009 Average Daily Volume : 1,133 shares Price Movement: 114.% upwards

Thus, it is observed that the share price had moved substantially even if the effect of stock split were to be discounted. A possible attempt to take the price up, create liquidity through a stock split and then attract greater volumes appears to be borne out by the data.

Relationships/connections among clients:

18. A perusal of the ‘Know Your Client’ (KYC) documents of the clients who had traded in the shares of SJCL during the period March 18, 2008 to October 1, 2009 revealed that most of the clients who had traded before the ‘stock split’

appeared to be related or connected. The said relationship as borne out from the aforesaid documents is given below:

Relationship amongst buy clients who traded in the scrip in Period I:

Sr. Name of Name of the Address as per the client Email id as Telephone Inter-se Relationship No. the client stock broker database provided by per the client No. relationship with BSE and NSDL database promoter/prom provided by oter related BSE and entities NSDL 1 Ms. Rasila HDFC 1307, Raj Madhur, 13th harshadlast@ 022 28774447 Mother of Appeared to be Patel Securities Ltd. Floor, Near Aquaria Club, yahoo.co.in Pragna Patel acquainted Devidas Lane, Borivili (W), and Bhavesh with the Mumbai - 400103 Patel promoters 2 Ms. Pragna HDFC 1307, Raj Madhur, 13th harshadlast@ 022 28485996 Sister of same as above Patel Securities Ltd. Floor, Near Aquaria Club, yahoo.co.in Bhavesh Patel Devidas Lane, Borivili (W), Mumbai - 400103 3 Mr. HDFC 1307, Raj Madhur, 13th harshadlast@ 022 28774447 Brother of same as above Bhavesh Securities Ltd. Floor, Near Aquaria Club, yahoo.co.in Pragna Patel Patel Devidas Lane, Borivili (W), Mumbai - 400103 4 Ms. Jagruti HDFC Flat No-701 A Wing, 7th harshadlast@ 022 28945476 Daughter of same as above Patel Securities Ltd. Floor, Ruchi Appts, yahoo.co.in Manjula Patel Devidas Lane, Borivali (W), Mumbai - 400103 5 Ms. HDFC Flat No-701 A Wing, 7th harshadlast@ 022 28945476 Mother of same as above Manjula Securities Ltd. Floor, Ruchi Appts, yahoo.co.in Hetal Patel Patel Devidas Lane, Borivali (W), Mumbai - 400103 6 Ms. Hetal HDFC Flat No-701 A Wing, 7th harshadlast@ 022 28945476 Daughter of same as above Patel Securities Ltd. Floor, Ruchi Appts, yahoo.co.in Manjula Patel Devidas Lane, Borivali (W), Mumbai - 400103

19. It may be noted that all the above clients have traded only during Period I and bought 2240 shares of SJCL. The said trades accounted for 36% of the total traded volumes. Further, they are dealing through the same stock broker and had provided the same email id as per the data from the stock exchange and depository. They shared the common addreeses, as stated above. All of them have their bank accounts with HDFC Bank, Anand Nagar, Dahisar (East) Branch, It also appeared that the buy side clients are family friends of the promoters of SJCL. On the sell side, Mr. Patel Harjibhai Purshottambhai and Mr. Gabani Bharat Harjibhai were seen to have been sharing common address and telephone number.

Relationship amongst buy clients who traded in the scrip in Period II: Sr. Name of the Name of the Address as per the Telephone Inter-se relationship Relationship with No. client broker client database No. promoter/promoter provided by BSE and related entities NSDL 1. Mr. Ramesh D. India E- 104, Panchvati, 022 28775954 Shares common address Brother in law of Patel Advantage Raheja Township, and Telephone no. with Promoter Securities Ltd. Malad (E), Mumbai- Mr. Ramesh D Patel HUF 400097 and Shamo Investments Pvt. Ltd. 2. Ramesh D. Patel India E- 104, Panchvati, 022 28775954 Shares common address Mr. Ramesh D Patel, HUF Advantage Raheja Township, and Telephone no. with (Brother in law of Securities Ltd. Malad (E), Mumbai- Mr. Ramesh D Patel and Promoter) is the 400097 Shamo Investments Pvt. Karta of Ramesh D Ltd. Patel HUF 3. Shamo India E- 104, Panchvati, 022 28775954 Shares common address Mr. Ramesh D Patel Investments Pvt. Advantage Raheja Township, and Telephone no. with and Ms. Dharmishta Ltd. Securities Ltd. Malad (E), Mumbai- Mr. Ramesh D Patel and Patel, wife of Mr. 400097 Ramesh D Patel HUF Ramesh D Patel are promoters of Shamo Investments Pvt. Ltd. 4. Mr. Jayesh India Emereland Sea, 022 28546259 Husband of Ms. Urvashi Mr. Ramesh D Patel Shamjibhai Patel Advantage Bunglow 1. Thakur Patel transferred Rs. Securities Ltd. Complex, Mumbai – 10,00,000 on 400101 November 14, 2007 vide HDFC Bank cheque no. 0257497 and Rs. 5,524 on March 28, 2008 vide HDFC Bank Cheque no. 0308640. 5. Ms. Urvashi India Emereland Sea, 022 28546259 Wife of Mr. Jayesh Mr. Ramesh D Patel Patel Advantage Bunglow 1. Thakur Shamjibhai Patel transferred Rs. Securities Ltd. Complex, Mumbai - 9,52,000 on March 400101 28, 2008 vide HDFC Bank Cheque no. 0308641. 6. Shyam Star Inventure 203 Prateek Archade, --- --- Promoter of S J Gems Ltd. Growth and Tata Road, Opera Corporation Ltd., Mr. (A BSE listed Securities Ltd. House, Mumbai 400004 Savjibhai D Patel is a Company) director of Shyam Star Gems Ltd.

The above buy-side entities who had traded during Period II were found to be connected with the promoters of SJCL. Their contribution to total trading volumes and price movement is brought out in the later part of this order.

Examination of trading:

20. The details of the trading in the shares of SJCL during the period from March 18, 2008 to October 1, 2009 are given below:

Period-I: From March 18, 2008 to January 27, 2009.

21. During this period, the promoters announced an open offer on August 4, 2008 at a price of Rs.447/- per share. The scrip was traded for only 6 days during the period between March 18, 2008 and January 27, 2009, the details of which are given below:

Total no. of No. of days of Total no. of No. of shares Value of shares traded (in Rs.) trading days trading in SJCL trades in SJCL traded 209 6 19 6,151 25,89,625

22. Some significant observations in respect of the trading during Period I are as under: • In 12 trades out of the 19 trades executed during the said period, the buyers were either associated with the promoters or promoter related entities. These entities had purchased 78% of the shares traded during Period I. • In the first 9 trades executed between March 18, 2008 and April 25, 2008, the buy clients were the entities listed in the Table at paragraph 18 of this Order. The trades of these clients have been executed from the same location “4006020024001007” and had contributed 2240 shares of the total 6,151 shares traded during this period. • One trade for 50 shares was executed by the promoter related entity, Shamo Investments Private Limited on June 18, 2009 with Mr. Gabani Bharat Harjibhai. • On July 30, 2008, Mr. Ramesh D. Patel bought 2,500 shares from two persons apparently related to each other i.e. Mr. Sushilchandra Dhananjaya Desai and Ms. Surbhi Dhananjaya Desai. It may be noted that on April 09, 2009, Mr. Sushilchandra Dhananjaya Desai and Ms. Surbhi Dhananjaya Desai had together transferred 4450 shares of SJCL through off market to Mrs. Dharmishta Patel, wife of Ramesh D Patel. Thus, it can be inferred that the purchase of 2,500 shares were from related entities. • On March 18, 2008, a total of 6 trades were executed. All these trades were among related entities viz. the entities listed in the Table at paragraph 18 of this Order on the buy side and Mr. Patel Harjibhai Purshottambhai and Mr. Gabani Bharat Harjibhai on the sell side. • It may be noted that Mr. Patel Harjibhai Purshottambhai and Mr. Gabani Bharat Harjibhai share common address and telephone number. • On August 13, 2008, in all the five trades that took place, Mr. Hirji Bhuralal Patel was the sell client. • After the second open offer, there was no trades after August 18, 2008. • The price increased to the maximum possible extent (of 5%) on five of the six days the scrip was traded. The share price had moved from Rs.392/- to Rs.493/-during the said period.

Therefore, it can be seen that most of the trades that took place out of the very few trades during Period I, were by connected/related entities. Period - II: From January 28, 2009 to August 27, 2009

23. The trading during the aforesaid period was infrequent and for low volumes which facilitated a detailed examination of every trade done during this period. The following is the trade summary for the period:

Total no. of No. of days Total no. No. of Value of trading days of trading in of trades shares shares traded SJCL in SJCL traded (in Rs.) Price Rise From To (Rs.) Percentage (Rs.) increase 144 40 52 429 5,19,157.95 517.15 3,464.60 569.94%

It is observed that from January 28, 2009, the clients [most of whom were promoter related entities (the group)], were seen to be trading in the scrip in such a manner so as to raise the price through every trade. They had placed their orders in the very first minute of market opening [between 9:55:01 to 9:56:00] at the rates at upper circuit filter i.e. 5% over the previous closing price. A summary of their trading activities in the scrip including their expired orders is given below:

Of which Orders Sr. No. of Orders entered between No. Name entered 9:55:01 to 9:56:00 Orders expired Actual Trades 1 Mr. Ramesh D. Patel 35 35 35 3 2 Ramesh D. Patel HUF 80 78 80 10 Shamo Investments 3 Private Limited 52 49 52 3 4 Ms. Dharmishta Patel 13 13 13 0 Mr. Jayesh Shamjibhai 5 Patel 56 55 55 13 6 Ms. Urvashi Patel 51 50 51 1 Shyam Star Gems 7 Limited 1 0 1 1 Total 288 280 287 31

From the above data, it is observed that: • Out of the total 288 orders placed by the aforesaid persons/entities, 280 orders were placed immediately when the market opened. [placed between 9:55:01 to 9:56:00] • Every buy order placed at the upper circuit filter prima facie gives rise to an inference that the same was done to move the price up to the maximum limit. It is also surprising to note the above pattern of placing orders in the light of the presumption that buyers normally purchase at the lowest possible price available in the market. • One of the entities in the group was found to be placing orders every day even though the scrip was traded only on 40 days out of the 144 trading days. • Out of the total 288 orders entered, there were rare cases of partial deletions but orders have been allowed to expire 287 times, indicating the intention of the above clients to create an impression of buying pressure in the scrip. • The promoter related entities traded on the buy side in 31 trades out of the total 52 trades during this period. • For one third of the trades executed with a group entity, no delivery was made by the selling clients, which further strengthens the prima facie view that the buyers and sellers did not intend in genuine transfer of ownership but were doing the same for creating false volumes to create investor interest in the shares of SJCL.

24. The month-wise summary of the buy orders entered by the related clients is given below to understand the nature of the buy orders entered by those clients: Months No. of No. of days Average Total Buy Buy % age of buy volume Trading on which no. of daily Volume Volume entered by related Days these orders entered entered by clients entities put entered by related buy orders the group clients

3 January, 2009 3 2 270 200 74.07 4 February, 2009 19 19 4,151 1,424 34.30 7 March, 2009 20 17 6,598 4,650 70.48 5 April, 2009 18 15 6,217 3,450 55.49 6 May, 2009 20 19 11,305 7,416 65.60 6 June, 2009 22 21 10,464 5,436 51.95 2 July, 2009 23 17 3,524 2,695 76.48 2 August, 2009 19 10 2,414 191 7.91

25. From the above, it is seen that in most of the months, the number of buy orders placed by these entities constituted more than 50% of the total buy orders placed from January 2009. The intention of the clients seems to be not to acquire shares but only to create an impression that the market was buying the shares of the said company. The purpose of such trading behavior by placing orders and executing trades in small quantities of shares at an increasing price every day, prima facie strengthens the view that they were indulging in fraudulent and unfair trade practices.

The trade logs for the Periods I and II are placed at ‘Annexure A’ to this Order.

Analysis of trades and orders of certain clients:

26. As already mentioned above, the clients were placing orders at higher price than the price of the previous orders. Some observations in this regard are as under:

Shyam Star Gems Limited:

a) The said entity is a company listed at the BSE. Its promoters are same as that of SJCL viz. Mr. Savjibhai Patel & Ms. Usha S. Patel. On January 28, 2009, Shyam Star Gems Limited had entered a buy order for 100 shares of SJCL, out of which trades in respect of only 10 shares were executed. It was also observed that the client, Ramesh D. Patel HUF was allegedly facilitating the promoters to establish a higher price, as he was the counter party to the said trade. With this initial trade at a higher price, the entities of the group indulged in placing buy orders at the 5% upper circuit level to take the price up. The order for the remaining 90 shares was automatically deleted from the order book at the closure of the market.

b) It is also noted that after January 28, 2009, Shyam Star Gems Limited did not put any buy or sell order and only the other promoter related entities were seen to be trading in the shares of SJCL.

Mr. Ramesh D. Patel and Ramesh D. Patel HUF

In respect of Mr. Ramesh D Patel and Ramesh D Patel HUF, the analysis of the order log has indicated the following:

a. On February 16 and 17, 2009, Mr. Ramesh D. Patel entered a buy order at 9:55 am for 50 shares at Rs.692.90/- per share. The buy order rate was at the upper circuit level at 5% more than the previous closing price. Due to non-execution of said order, the same got cancelled when the market had closed. b. On February 18, 2009, Mr. Ramesh D. Patel and Ramesh D. Patel HUF entered two buy orders for 50 shares each at the price of 692.90/- per share. As the said orders were executed with the corresponding orders of the sellers Mr. Kiritbhai Anghan and Mr. Dharnendra Ashok Mehta for 5 shares each at the said price, the price of 692.90/- was established in the market. The orders for remaining 90 shares had expired. c. From February 18, 2009 to March 05, 2009, it is observed that, Mr. Ramesh D. Patel along with Ramesh D. Patel HUF were placing orders at Rs.727.50/- per share which was again at the upper circuit filter level. Due to the non-execution of trades, the orders were automatically cancelled on the closing of the market. d. In another instance on June 4, 2009, Mr. Ramesh D. Patel along with Ramesh D. Patel HUF had entered a buy order for 190 shares at Rs.1371.40/- at around 9:55 am. The said order rate was also at the upper circuit filter level. It is also noted that Mr. Kiritbhai Anghan was observed to be on the sell side for only 1 share. e. In similar instances, observed on June 30, 2009, July 1 and 2, 2009 it is observed that Ramesh D. Patel HUF had entered bid order at 5% upper circuit filter to buy 66, 98 and 34 shares respectively. It is observed that Ms. Shilpaben Veghani sold only 1 share each on the aforesaid three days. Interestingly, it is noticed that she failed to deliver the shares for the trades mentioned above. A similar instance took place on August 11, 2009 as well when Ms. Shilpaben Veghani sold only one share to Mr. Ramesh D. Patel at the upper circuit filter and again failed to make the delivery and close out was effected at a higher price.

Shamo Investments Private Limited a. On February 04, 2009, Shamo Investments Private Limited had entered an order to buy 49 shares at a price of Rs.628.55/- which was at the upper circuit level at 5% more than the previous traded price of Rs.598.65/-. It is observed that one Savjibhai Anghan had sold 6 shares and orders for remaining 43 shares were automatically cancelled at the close of the market. In this manner, a higher price was established in the market for the shares of SJCL. b. On February 11, 2009, Shamo Investments Private Limited had entered an order to buy 50 shares at a price at the upper circuit filter level. However, only one share was sold by Mr. Paras Shah. Accordingly, they could establish a higher price. The order for remaining 49 shares was automatically deleted on closing of the market.

Ms. Dharmishtha Patel a. Ms. Darmishtha Patel, wife of Mr. Ramesh D. Patel, had placed buy orders at upper circuit filter levels but the orders could not be executed due to illiquidity in the scrip. b. During the period January 28, 2009 to August 27, 2009 (the pre-split period), she had entered the buy orders at opening of the market (around 9:55 am) and almost all the orders entered by her expired at the closing of the market. Her trading pattern gives an inference that her intention was to show buying pressure in the market.

Mr. Jayesh Shamjibhai Patel and Ms. Urvashi Patel a. It is observed that Mr. Jayesh Shamjibhai Patel and his wife Ms. Urvashi Patel entered the orders at the beginning of the market on alternative days. b. It was observed that on March 30, 2009, Mr. Jayesh Shamjibhai Patel had placed a buy order for 200 shares at a price of 884.20/- per share, which was at 5% above the previous closing price and at the upper circuit filter level. Interestingly, Ms. Shilpaben Veghani (the same client who had traded with Mr. Ramesh D. Patel and Ramesh D. Patel HUF as stated above in this Order) sold 10 shares and the remaining order for 190 shares was automatically cancelled at the closure of the market hours. As said earlier, Ms. Shilpaben Veghani had failed to fulfill her delivery obligations for those trades.

27. A perusal of the trade and order logs brings out the following significant observations in respect of the trading during the above period:

i. After a long gap of five months (after August 18, 2008), the first and the only trade on January 28, 2009 was between the connected parties i.e, Mr. Ramesh D. Patel and Shyam Star Gems Limited, at a price which hit the upper circuit filter. ii. It is pertinent to note that Mr. Ramesh D. Patel, his HUF and Shamo Investments Private Limited through 16 trades with a total volume for 45 shares were instrumental in increasing the share price by Rs.994.35/-. iii. Further, Ms. Urvashi Patel and Mr. Jayesh Shamjibhai Patel have together contributed to a price rise of Rs.460.20/- in 14 trades with a total volume of 151 shares. iv. Out of the total price rise of Rs.2947.45/- during the period from January 28, 2009 to August 27, 2009, Rs. 1430.50 or 48.53% of the total price rise was contributed by the promoter related group. v. All the orders entered by clients Ramesh D. Patel HUF, Shamo Investments Private Limited, Ms. Urvashi Patel and Mr. Jayesh Shamjibhai Patel have the same location ID “4000210007016001” which indicates that the orders were placed by the same stock broker and from the same terminal.

It strengthens the case that all the above clients who are related with each other had acted in concert to assist in the alleged manipulation of the share price. vi. Out of the 40 trading days, the first trade in 23 days was made by a promoter related entity, thereby establishing a new high price each time. Every first trade hit the maximum 5% price circuit.

28. Therefore, it can be said that out of the total 52 trades during period II, 31 trades were through the promoter related entities. The following is the summary of the number of shares bought by the aforesaid persons/entities: Sr. No. Name of the entity No. of shares bought 1. Shyam Star Gems Limited 10 2. Shamo Investments Private. 7 Limited 3. Mr. Ramesh D. Patel 11 4. Mr. Jayesh Shamjibhai Patel 146 5. Ms. Urvashi Patel 5 6. Ramesh D. Patel HUF 27 Total 206

29. Overall observations for the Periods I & II:

a. The clients on the sell side during Period I, Mr. Patel Harjibhai Purushottambhai, Mr. Gabani Bharat Harjibhai and Mr. Patel Umesh Harjibhai, the seller during Period II, shared the same address at 101, Parvati Apartments, Gausala Lane, Near Ramlila Maidan, Malad (E), Mumbai - 400097 and also the telephone number ‘022-28834704’. This address is in the same premises as that of the promoters viz. 304, Parvati Apartments, Gausala Lane, Malad (E), Mumbai- 400097.

b. Mr. Patel Umesh Harjibhai had placed orders on June 8 and 16, 2009 from the same location as that of Mr. Anghan Kirtibhai Babubhai and Mr. Soni Chandra Pradumman, also sellers in Period II. All the said five persons (Mr. Patel Umesh Harjibhai, Mr. Anghan Kirtibhai Babubhai, Soni Chandra Pradumman and Mr. Gabani Bharat Harjibhai & Mr. Patel Harjibhai

Purushottambhai) – two from period I and three from period II were found to be selling shares from the same terminal (no. ‘4000970356356090’) of the stock broker, Inventure Growth and Securities Limited. Therefore, it prima facie appears that the aforesaid five selling entities are related or known to each other and acting in concert. c. This group executed 11 out of 19 sell trades during Period-I and 22 out of total 52 sell trades during Period II. d. The relationship amongst the entities is summarized in the form of a pictorial diagram:

Common Address and phone number.

Mr. Gabani Bharat Mr. Patel Harjibhai Mr. Patel Umesh Mr. Anghan Kirtibhai Harjibhai Purushottambhai Harjibhai Babubhai

Same location Id Same location Id 4000970356356090 for 4000970058058190 for placing sell placing sell orders orders

Soni Chandra Pradumman e. The buy orders placed by Mr. Ramesh D. Patel, Ramesh D. Patel HUF, Shamo Investments Private Limited, Mr. Jayesh Shamjibhai Patel and Ms. Urvashi Patel have been placed from the same location Id (4000210007016000) of the stock broker, India Advantage Securities Limited. They have placed buy orders immediately at the market opening at the upper circuit level on each trading day. f. Further, On May 05, 2009 and May 13, 2009, Ms. Chanchpara Madhuben Manjibhai and Mr. Chanchpara Shantibhai Manjibhai, who share a common address as 151 Enterprise Apartments Forjett Hill Street Tardeo, Mumbai –

400036, were seen to be buying and selling between themselves. The location Id (4000040035001000) for their three buys and sell trades on these days is the same. Thus, it gives rise to an inference that their trades were structured trades. g. Further, Ms. Patel Hetalben Niteshbhai, Mr. Sutariya Nilesh Himatbhai and Ms. Rita Nilesh Sutaria have placed their sell orders from the same location Id (4000040035001000)of the stock broker Anagram Stock Broking Limited, as that of Ms. Chanchpara Madhuben Manjibhai and Mr. Chanchpara Shantibhai Manjibhai. h. On February11, 2009, Shamo Investments Private Limited and Mr. Paras V. Shah have traded between themselves for one share through the same trader of the stock broker India Advantage Securities Limited, establishing a higher price at the maximum level for the day. i. As already stated above, the shares of SJCL were illiquid. The trades executed at higher prices every day, were the only trades that took place during the period under examination. This indicates that the intention of the clients prima facie was to accumulate shares and increase the share price. There seems to be no logic or reasoning behind placing orders (buy) at the upper circuit levels at 5% higher than the previous days’ closing price. The orders were put in such a manner that the maximum increase in the price on a particular day was effected. The price increase over period I and II was 783.92%. During the said period, the promoter related entities bought 2756 shares and the promoter associated entities bought 2240 shares.

30. Non delivery of shares: It is observed that the following persons/entities who had sold the shares during Period II had failed to meet their delivery obligations: a. Mr. Niteshbhai Sutariya b. Ms. Rita Nilesh Sutariya c. Ms. Shilpaben Vaghani d. Ms. Hetalben Niteshbhai Patel e. Mr. Jignesh Chimanlal Shah

31. Further, Ms. Patel Hetalben Niteshbhai, Mr. Sutariya Nilesh Himatbhai and Ms. Rita Nilesh Sutaria were found to have placed their sell orders from the same location (ID). Mr. Niteshbhai Sutariya and Ms. Rita Nilesh Sutariya share the same telephone number 022-28108654. Since the counterparties to each trade of the above clients were none other than the promoter related entities, they probably did not bother to take delivery of the shares. The same may also appears to be part of their concerted action. As the scrip was illiquid, BSE could not obtain these shares from auction, which resulted in ‘close-out’ causing higher prices. Thus, it appears that the above clients assisted the buyers in getting their orders executed so as to artificially move the share price to a higher level. It may be noted that four out of the above five clients had a common stock broker in Anagram Stock Broking Limited. The trade pattern should have alerted the concerned stock broker who appears to have failed to exercise due care and caution in respect of the above transactions. The conduct of the said stock broker would also be examined in detail in the on-going investigation.

Period-III : From August 28, 2009 to October 1, 2009 (Post Stock-split)

32. As stated earlier, SJCL came with a stock split on August 28, 2009. A share of face value of Rs.10/- was split into 10 shares of face value of Re. 1. The analysis of the trading in the scrip during the period August 28, 2009 to October 1, 2009 revealed that the scrip started trading after the stock split on August 31, 2009 and opened at a price Rs.363.75/-. Thereafter, the share price started to rise steadily and reached a high of Rs.816/- on September 30, 2009. It is pertinent to note that the entities who had purchased the shares during Period I & II were seen to be selling during this period. It is seen that the otherwise illiquid scrip, which had few clients, most of which were associated or related to the promoters, witnessed more trading during this ‘post split’ period. The summary of the same is as under:

Total no. of No. of days on which Total no. of trades No. of shares Value of shares traded (in Rs.) trading days trading took place during the said traded period 23 19 1,014 26,070 1,90,91,964.55

33. An examination of trade log for the above period indicates that a significant number of new clients started trading in the scrip. The details of the top 20 buyers and sellers are provided in ‘Annexure ‘B’ to this Order. It is seen that once the share price was artificially increased, SJCL was able to come up with a stock split. A large number of new investors then started trading in the scrip. The details given in Annexure B are indicative of the tremendous interest in the scrip which reflects in the increased trading in the scrip observed after the stock split. The sellers are prima facie identified as persons who are related or associated with the promoters and are seen to be exiting at higher prices. It is seen that the earlier trades undertaken by the entities related to the promoters of SJCL not only raised the price of the scrip manifold but also created significant interest in the scrip. The decision of SJCL to come up with the stock split at this point in time corroborates the prima facie view that it was all the game plan of the promoters and the related entities to artificially raise the share price, increase their holdings in the scrip and later off-loading them in an artificially created market, apart illegally profiteering from the same. The sell trades by the promoter entities during Period III is provided in Annexure ‘C’ to this Order and the summary of the same is given below: Holdings as on August 27, 2009 after the shares bought No. of shares sold Holdings as on Sr. No. Name of the entity in period I and II (post split of 1:10) October 01, 2009 Promoter related entities: Shamo Investments Private 1 Limited. 3,560 459 3,101

2 Mr. Jayesh Shamjibhai Patel 3,660 160 3,500

3 Ms. Urvashi Patel 4,000 Nil 4,000

4 Shyam Star Gems Limited. 100 Nil 100

5 Mr. Ramesh D. Patel 98,000 5 97,995 6 Ramesh D. Patel HUF 25,480 180 4,600

Sub Total 'A' 1,09,320 804 1,08,696 Promoter associated entities:

1 Mr. Bhavesh Patel 3,100 600 2,500

2 Ms. Hetal Patel 2,700 400 2,300

3 Ms. Jagruti Patel 3,000 300 2,700

4 Ms. Manjula Patel 3,600 400 3,200

5 Ms. Pragna Patel 2,800 700 2,100

6 Ms. Rasila Patel 7,200 1,150 6,050 Sub Total 'B' 22,400 3,550 18,850 Total 'A' + 'B' 1,31,720 4,354 1,27,546 (Note: For the sake of easy understanding figures in pre split period are converted into equivalents of post split)

34. From the above data, it prima facie appears that in the ‘pre-split’ period the promoter related entities increased the share price through a strategy of bid orders and structures/pre-arranged trades. During the ‘post split’ period, when new investors entered the market, the promoter related entities started placing sell orders with nominal volume of shares. This trend demonstrates that their main intention was not to realize their gain at this stage, but to further maximize their wealth by raising the market capitalization of the holdings of the promoters. Perusal of the holdings of the above clients on August 27, 2009 and October 1, 2009 reveal that the holdings of all the clients have come down. It therefore follows that these clients have not been trading among themselves post split, but have been selling the shares to the other new unsuspecting clients. The same can borne out from the list of top 20 sellers [as provided in Annexure B], as they had not traded during the periods I & II. Further, it can be observed from the above table, that the promoter related entities had sold the shares of SJCL to the new clients who had entered the market post the stock split after being lured into trading in the shares of the company by the artificial market so created by the promoter related entities. It is to be noted that these entities have sold 4,354 shares out of the total 49,960 shares bought by the above entities put together. These entities are still holding a major share of the equity capital.

Calculation of realized gains:

35. The following is the summary of the gains made by the promoter related entities during the three periods till October 1, 2009:

Name of the Buy Average Value (4 = 2 x Sell Average Value (7 = 5 Actual cost Gain (9 = 7 - 8) entity (1) Quantity Buy 3) Quantity Sell Price x 6) of shares (2) Price* (3) (5) (6) sold (8 =5 x 3 ) (Rs.) (Rs.) (Rs.) (Rs.) Mr. Ramesh 25,110 44.814 11,25,279.54 5 592.1 2,960.50 224.07 2,736.43 D. Patel

Ramesh D. 270 199.25 53,797.50 280 4,559.48 12,76,654.4 55,790.00 12,20,864.40 Patel HUF Shamo 570 45.103 25,708.71 459 7,505.90 34,45,208.1 20,702.28 34,24,505.82 Investments Private Limited Mr. Jayesh 1,460 125.74 1,83,577.48 160 7,118.83 11,39,012.8 20,118.08 11,18,894.72 Shamjibhai Patel Total 57,67,001.37

* Average Buy Price is calculated by converting 448.14 (Face Value = Rs. 10/- each) into Rs. 44.81 (Face Value = Re. 1 each), to make the calculation of actual realized gains.

36. The realized gains are not large for the trading till October 1, 2009. Selling by the promoter related entities in a market that is witnessing increased liquidity because of a stock split and attracted investor interest, may lead to rich pickings in their account. This is strongly borne out as described in earlier paragraphs as the denouement of a possible pump and dump strategy, that is apparently being witnessed, may be imminently played out by its architects. It becomes imperative for SEBI to protect investors from such attempted manipulation by promoters of a company. On account of the above entities, there is a huge increase in the value of the current holding of the promoter and promoter related/associated entities as compared to the value of their holding as on March 31, 2009. The values of their holdings at the beginning of the period and at the end of the period works out as follows:

Sr. Name of the Holdings as Market Value Holdings Market Value Holdings as Market Value Increase in the Percent No entity on March of holding as as on of holding as on October of holding as value of holding age. 31, 2009* on March 31, August on August 27, 01, 2009 on October since March 31, increase 2009 @ 27, 2009 2009 @ 01, 2009 @ 2009 in 92.84** per after the 346.5*** per 778.10 per value(%) share shares share share bought in period I and II Promoter related entities: 1 Mr. Savjibhai D Patel 7,81,000 7,25,08,040 7,81,000 27,06,16,500 7,81,000 60,76,96,100 53,51,88,060 738.11 2 Ms. Usha S Patel 6,99,000 6,48,95,160 6,99,000 24,22,03,500 6,99,000 54,38,91,900 47,89,96,740 738.11 3 Shyam Star Gems Ltd. 100 9,284 100 34,650 100 77,810 68,526 738.11 4 Ramesh D Patel 72,550 67,35,542 98,000 33,95,7000 97,995 7,62,49,909 6,95,14,367 1,032.05 Ramesh D 5 Patel HUF 2,400 2,22,816 2,480 8,59,320 2,300 17,89,630 15,66,814 703.19 6 Mr. Jayesh Shamjibhai Patel 2,550 2,36,742 3,660 12,68,190 3,500 27,23,350 24,86,608 1,050.35 7 Ms. Urvashi J Patel 4,000 3,71,360 4,000 13,86,000 4,000 31,12,400 27,41,040 738.11 8 Shamo Investments Pvt. Ltd. 3,560 3,30,510 3,560 12,33,540 3,101 24,12,888 20,82,377 630.05 9 Ms, Dharmishta Rameshbhai Patel 87,500 81,23,500 99,050 3,43,20,825 99,050 7,70,70,805 6,89,47,305 848.74 10 Ms. Reshma R Patel 65,000 60,34,600 98,500 3,41,30,250 98,500 7,66,42,850 7,06,08,250 ------- Total (A) 17,17,660 15,94,67,554 17,89,350 62,00,09,775 1,788,546 1,391,667,643 1,23,22,00,088 ------- Promoter associated entities: 1 Mr. Bhavesh Patel 3,100 2,87,804 3,100 1,074,150 2,500 19,45,250 16,57,446 575.89 2 Ms. Hetal Patel 2,700 2,50,668 2,700 9,35,550 2,300 17,89,630 15,38,962 613.94 3 Ms. Jagruti Patel 3,000 2,78,520 3,000 10,39,500 2,700 21,00,870 18,22,350 654.30 4 Ms. Manjula Patel 3,600 3,34,224 3,600 12,47,400 3,200 24,89,920 21,55,696 644.99

5 Ms. Pragna Patel 2,800 2,59,952 2,800 9,70,200 2,100 16,34,010 13,74,058 528.58 6 Ms. Rasila Patel 7,200 6,68,448 7,200 24,94,800 6,050 47,07,505 40,39,057 604.24 Total (B) 22,400 20,79,616 22,400 77,61,600 18,850 1,46,67,185 1,25,87,569 ------- Grand Total (A+B) 17,40,060 1,61,54,7170 18,11,750 62,77,71,375 18,07,396 1,40,63,34,828 1,24,47,87,657 -------

*The no. of shares has been arrived at by multiplying the same by 10 to make them equivalent to the post split numbers. ** The price of the scrip has been divided by 10 to make it equivalent to the post split price.

37. From the above, it may be seen that the promoter related and promoter associated entities prima facie, bought shares with the intention of rigging the price prior to the stock split of SJCL and offloading shares in the post split period to unsuspecting investors. It can be seen from the table above that as on March 31, 2009 the holding of the promoter related as well as associated entities was 17,40,060 shares which increased to 18,11,750 shares before stock split. Post split, these entities sold shares as stated above, as a result of which the holding of the promoter related and promoter associated entities decreased to 18,07,396 shares. These dealings of the promoter related/associated entities have induced the general public to enter the market and buy the shares of SJCL, though not in large quantities. These dealings, if not restrained now, would induce more of such innocent investors to fall into the trap of the promoter related/associated entities.

38. The scrip SJCL was illiquid with only scattered trading prior to January 28, 2009. From January 28, 2009 the price of the scrip started to move up significantly. It is observed that after an open offer given by the promoters in August 2008, first trade took place after a gap of 5 months in the month of January, 2009. An examination in the trading in the scrip during this period revealed that promoter related entities viz. Mr. Ramesh D Patel, the brother-in-law of the promoter of SJCL, Ramesh D. Patel HUF and Shamo Investments Private Limited together with Ms. Urvashi Patel and Mr. Jayesh Shamji Patel contributed more than Rs.1454.55 to or 49% of the increase in the price. Interestingly, most of the trades were for one share each indicating that the purpose of the purchase of the shares was not accumulation of shares but only to increase the price. Further, from within this group buy orders were placed on a daily basis at the upper price circuit, and on 23 of 40 days the first trade was executed by them. The buy orders were allowed to stand till the end of the day to send misleading signals of a demand for the scrip of SJCL.

39. Preliminary examination of the matter revealed that the first trade happened between entities connected to promoters i.e. Mr. Ramesh D. Patel (brother-in-law of Mr. Savjibhai D. Patel) and Shyam Star Gems Limited (Mr. Savjibhai D. Patel is the managing Director of SJCL) at a price that caused the scrip to hit the five percent filter. Further, the holding of promoter related entities has gone up from 13.48 % as on June 30 2009 to 15. 31% as on October 01, 2009. As stated above in this order, SJCL came up with stock split on August 28, 2009 splitting one share of Rs. 10 each into 10 shares of Re. 1 each. After the split, the scrip opened at a price of Rs. 363.75 on August 31, 2009 and went up to a high of Rs. 816/- during the period from August 28, 2009 to October 1, 2009. It therefore appears that it was the game plan of the promoters and promoter related entities to first create an interest in the scrip by raising the price through structured and pre-planned trades and then announce a stock split to ultimately benefit themselves by increasing the worth of their holdings in the scrip or make supra-normal profits by selling to lay investors.

The net result of the above has been that the value of shareholding of the promoter and related entities has risen by Rs. 123 crore in a short span of seven months. Since the huge price rise witnessed by the scrip is prima facie not genuine, looking at the sudden entry of new investors and fresh liquidity in the scrip, post stock split, and taking into account the interest of investors and the integrity of the market, it is considered necessary to restrain promoters and promoter related entities from further trading in the scrip during the investigation. It is recognized that pre-emptive action by SEBI may prevent the denouement of a pump and dump strategy that is apparently being played out by the promoter and its related entities. By placing the buy or sell orders at higher price and by indulging in structured and apparently pre-arranged trades these entities have contributed to price rise and also to increase in the trading volume in the scrip. The trading activities of those entities connected to the promoters have not only resulted in artificial price rise but also created artificial volume in the scrip.

The preliminary findings of the investigation conducted so far, indicates that these entities prima facie have violated Regulations 3(c),4(2)(a),(b) and (g) of Securities and Exchange Board of India (Prohibition of Fraudulent and Unfair Trade Practices Relating to Securities Market) Regulations, 2003:

40. The role of trading members viz. India Advantage Securities Limited and Inventure Growth and Securities Limited who dealt on behalf of the promoter related entities needs to be examined in detail in the course of investigation in view of the trading activities of their clients, which prima facie appeared to be inconsistent with the interest of the investors in the securities market. Further, it may be noted that four out of the five clients, who had failed to fulfill their delivery obligations during the period from January 28, 2009 to August 27, 2009, had a common stock broker Anagram Stock Broking Limited. It appears that the said stock broker has failed to exercise due care in dealing in respect of those transactions and therefore, the role of the said stock broker would also be examined in the ongoing investigation by SEBI.

The trading of the promoter related entities has prima facie played a significant role in causing the price of the scrip to rise and also creating volume in the scrip in order to attract gullible investors to deal in the shares of SJCL. The trading by these entities prima facie appears to be carried out with an intention to artificially inflate the price and volume in the scrip thereby inducing lay investors to deal in the shares of SJCL. Detailed investigation has been initiated but in the meantime the connected entities continue to deal in shares of SJCL in a manner prima facie inconsistent with the interest of the investors and the securities laws. The absence of wide spread investor interest in the shares of SJCL in the year 2008-2009, the sudden increase in share price between January 2009 and August 2009, stock split on August 28, 2009 after the price of the scrip increased by more than 500% and an increased investor interest in the scrip post stock split, coupled with a flurry of corporate announcements including announcements on dividend and bonus issue, as stated above in this Order, indicates a careful designing and orchestration of a plan by the promoters to make personal gains at the expense of investors by enticing them to participate in the trading of the shares of SJCL. In the meantime, in view of the disconcerting developments as above impacting the market and to save the investors and the securities market from further acts of the concerned entities which brooks no delay, there is a need for an urgent and immediate action to prevent these entities from causing further damage or possible loss to investors.

41. In view of the foregoing, in order to protect the interest of investors and the integrity of the securities market, I, in exercise of the powers conferred upon me Under Sections 11,11(4) and 11B of Securities and Exchange Board of India Act, 1992 read with Section 19 thereof read with Regulation 11 of the Securities and Exchange Board of India (Prohibition of Fraudulent and Unfair Trade Practices Relating to Securities Market) Regulations, 2003, pending investigation and passing of further orders, by way of an ad interim ex-parte order, hereby restrain the following persons/entities from buying, selling or dealing in the shares of S J Corporation Limited, either directly or indirectly, in any manner, till further directions in this regard.

Sr. No. Name of the person/entity Permanent Account Number 1. Mr. Savjibhai D. Patel AAFPP8999Q 2. Ms. Usha S Patel AAFPP9000N 3. Shyam Star Gems Limited AADCS5179G 4. Mr. Ramesh D. Patel AGHPP0007B 5. Ramesh D. Patel HUF AAKHR0408M 6. Ms. Dharmishtha R Patel AAIPP5236F 7. Ms. Reshma Patel AWGPP7594J 8. Shamo Investments Private Limited AAACS6502Q 9. Mr. Jayesh Shamjibhai Patel AAFPP9585L 10. Ms. Urvashi Patel AAFPP3078E

11. Mr. Bhavesh Patel AJDPP6220F 12. Ms. Hetal Patel ARGPP0339J 13. Ms. Jagruti Patel APQPP0020C 14. Ms. Manjula Patel AJQPP1832J 15. Ms. Pragna Patel APQPP0022A 16. Ms. Rasila Patel AJPPP7275C

42. The above direction shall come into force with immediate effect.

43. The Depositories shall not give effect to any transactions in respect of the shares of S J Corporation Limited by the aforementioned persons/entities.

44. The aforesaid entities/persons against whom this Order is issued may file their objections, if any, to this Order within twenty one days from the date of receipt of this Order.

DR. K. M. ABRAHAM WHOLE TIME MEMBER SECURITIES AND EXCHANGE BOARD OF INDIA PLACE: MUMBAI DATE: FEBRUARY 5, 2010

Annexure ‘A’ Trade Log for Period-I: From March 18, 2008 to January 27, 2009:

S. % Buy Buy Sell N Change change Broker Client Broker Sell Client o Date Price in price in price Value Volume Name Name Name Name Location Id'[Buy] Location Id'[Sell] Inventur e Patel HDFC Growth Harjibhai Securitie Pragna & Sec. Purshottam 1 18/3/2008 392 ---- ----- 109,760 280 s Ltd. Patel Ltd. bhai 4006020024001000 4000970058058190 Inventur e Patel HDFC Growth Harjibhai Securitie Bhavesh & Sec. Purshottam 2 18/3/2008 390 -2 -0.51 120,900 310 s Ltd. Patel Ltd. bhai 4006020024001000 4000970058058190 Inventur e Patel HDFC Growth Harjibhai Securitie Jagruti & Sec. Purshottam 3 18/3/2008 387 -3 -0.77 116,100 300 s Ltd. Patel Ltd. bhai 4006020024001000 4000970058058190 Inventur e Patel HDFC Growth Harjibhai Securitie Patel & Sec. Purshottam 4 18/3/2008 386 -1 -0.26 42,460 110 s Ltd. Geeta P Ltd. bhai 4006020024001000 4000970058058190 Inventur e HDFC Growth Gabani Securitie Patel & Sec. Bharat 5 18/3/2008 386 0 0.00 185,280 480 s Ltd. Geeta P Ltd. Harjibhai 4006020024001000 4000970058058190 Inventur e HDFC Growth Gabani Securitie Hetal & Sec. Bharat 6 18/3/2008 386 0 0.00 104,220 270 s Ltd. Patel Ltd. Harjibhai 4006020024001000 4000970058058190 Inventur e Patel HDFC Growth Harjibhai Securitie Manjula & Sec. Purshottam 7 25/4/2008 405 19.3 5.00 145,908 360 s Ltd. Patel Ltd. bhai 4006020024001000 4000970356356090 Inventur e Patel HDFC Growth Harjibhai Securitie Rasila & Sec. Purshottam 8 25/4/2008 405 0 0.00 291,816 720 s Ltd. Patel Ltd. bhai 4006020024001000 4000970356356090 Sanghav Inventur i Fofani e Patel brothers Divya Growth Harjibhai brokerag Devendr & Sec. Purshottam 9 25/4/2008 405 0 0.00 145,908 360 e ltd. a Ltd. bhai 4000970026026090 4000970356356090 Inventur e Patel HDFC Growth Harjibhai Securitie Geeta P & Sec. Purshottam 10 25/4/2008 405 0 0.00 24,318 60 s Ltd. Patel Ltd. bhai 4006020024001000 4000970356356090

Shamo Inventur India Investm e Advanta ents Growth Gabani 21,277.5 ge Sec. Pvt. & Sec. Bharat 11 18/6/2008 426 20.3 5.00 0 50 Ltd Ltd. Ltd. Harjibhai 4000210007016000 4000970058058090 India Desai Advanta ICICI Dhananjaya ge Sec. Ramesh Securitie Sushilchan 12 30/7/2008 447 21.3 4.99 446,800 1,000 Ltd D.Patel s Ltd. dra 4000210007016000 1111111111111000 India Advanta ICICI Desai ge Sec. Ramesh Securitie Surbhi 13 30/7/2008 447 0 0.00 670,200 1,500 Ltd D.Patel s Ltd. Dhananjaya 4000210007016000 1111111111111000 Shah Patel Hirji investor Shah Angel Bhuralal s home Nayana Broking Hirji Bhura 14 13/8/2008 469 22.3 4.99 46,910 100 ltd. S Ltd. Patel 3800060216202000 4000860491491090 Shah Shah Patel Hirji investor Bharti Angel Bhuralal s home Somcha Broking Hirji Bhura 15 13/8/2008 469 0 0.00 46,910 100 ltd. nd Ltd. Patel 3800060216202000 4000860491491090 ASE Patel Hirji Capital Shah Angel Bhuralal 11,727.5 Markets Ajay Broking Hirji Bhura 16 13/8/2008 469 0 0.00 0 25 Ltd. Rasiklal Ltd. Patel 3800010098003000 4000860491491090

Monarc h research Sanghvi Patel Hirji & Mauli Angel Bhuralal 11,727.5 brokerag Chiragb Broking Hirji Bhura 17 13/8/2008 469 0 0.00 0 25 e pvt.ltd. hai Ltd. Patel 3800010008001000 4000860491491090 Prajapati Shah Natvarb Patel Hirji investor hai Angel Bhuralal s home Shivara broking Hirji Bhura 18 13/8/2008 469 0 0.00 46,910 100 ltd. m ltd. Patel 3823450037201000 4000860491491090

Dhiren ASE Angel Mahend capital Broking rakumar markets Shah Ajay 19 18/8/2008 493 23.5 5.00 492.55 1 Ltd. Shah ltd. Rasiklal 4000860491491090 3800010098003000

Trade Log for Period-II: From January 28, 2009 to August 27, 2009.

T ra S. % de Buy Buy Sell N Change change Value Volu I Broker Client Broker Sell Client o Date Price in price in price (Rs.) me D Name Name Name Name Location Id'[Buy] Location Id'[Sell]

Inventur e Shyam India Growth Star Advanta Patel D & Sec. Gems ge Sec. Ramesh 1 28/1/2009 517 24.6 4.99 5,171.50 10 1 Ltd. Ltd Ltd HUF 4000970031031090 4000210007016000 Inventur Arcadia e Chandra Share Growth Praddu and & Sec. man Stock Kalathiya 2 29/1/2009 543 25.9 5.00 543 1 1 Ltd. Soni Broking Rajendra 4000970356356090 3950030013002000 DSE Arcadia Financia Share l and Services Kundu Stock Kalathiya 3 30/1/2009 570 27.2 5.00 1,140.30 2 1 Ltd. Bidyut Broking Rajendra 1100880201004080 3950030013002000

Bagri Soni Uttam B Inventur Chandra BCB Bcb e Pradduman Brokera Finance Growth Chandra ge Private & Sec. Pradduman 4 2/2/2009 599 28.5 5.00 598.65 1 1 Pvt.Ltd. Limited Ltd. Soni 4000010006006090 4000970356356090 Shamo Inventur India Investm e Advanta ents Growth ge Sec. Pvt. & Sec. Anghan 5 4/2/2009 629 29.9 4.99 628.55 1 1 Ltd Ltd. Ltd. Savjibhai T 4000210007016000 4000970356356090 Shamo Inventur India Investm e Advanta ents Growth ge Sec. Pvt. & Sec. Anghan 6 4/2/2009 629 0 0.00 3,142.75 5 2 Ltd Ltd. Ltd. Savjibhai T 4000210007016000 4000970356356090 Shamo India Investm India Advanta ents Advanta ge Sec. Pvt. ge Sec. Shah Paras 7 11/2/2009 660 31.4 5.00 659.95 1 1 Ltd Ltd. Ltd V 4000210007016000 4000210007018000 Mehta Dharnendra India Magnu Ashok Advanta m equity Dharnendra ge Sec. Ramesh broking Ashok 8 18/2/2009 693 32.9 4.99 3,464.50 5 1 Ltd D.Patel ltd. Mehta 4000210007018000 4012090025001000 Inventur India e Advanta Growth Anghan ge Sec. Ramesh & Sec. Kiritbhai 9 18/2/2009 693 0 0.00 3,464.50 5 2 Ltd D.Patel Ltd. Babubhai 4000210007018000 4000970356356090

Arcadia P Shree Share Khambhadi bahubali and ya Sanjay internati Dugar Stock Khambhadi 10 13/3/2009 728 34.6 4.99 3,637.50 5 1 onal ltd. Vinod Broking ya Sanjay P 7111020140001000 3640010023001000 Anand India Jayesh rathi Raghavan Advanta Shamji financial Ranjit ge Sec. bhai services Vallyapurai 11 24/3/2009 764 36.4 5.00 3,819.25 5 1 Ltd Patel ltd. l 4000210007016000 4012090144003000 Inventur India Jayesh e Advanta Shamji Growth Anghan ge Sec. bhai & Sec. Kiritbhai 12 24/3/2009 764 0 0.00 3,819.25 5 2 Ltd Patel Ltd. Babubhai 4000210007016000 4000970356356090 India Jayesh Advanta Shamji Kalpana ge Sec. bhai A.Gund Tukrul 13 26/3/2009 802 38.2 4.99 4,010 5 1 Ltd Patel aria Sneha S 4000210007016000 4000010002002000

Bagri Uttam B Inventur Bcb e Bcb Finance Growth Patel brokerag Private & Sec. Umesh 14 27/3/2009 842 40.1 5.00 842.1 1 1 e pvt.ltd. Limited Ltd. Harjibhai 4000010007007090 4000970356356090

India Jayesh Dhameliya Advanta Shamji Jhaveri Haresh ge Sec. bhai securitie Haresh R 15 30/3/2009 884 42.1 5.00 4,421 5 1 Ltd Patel s ltd. Dhameliya 4000210007016000 3640030085001000 Inventur India Jayesh e Advanta Shamji Growth Anghan ge Sec. bhai & Sec. Kiritbhai 16 30/3/2009 884 0 0.00 4,421 5 2 Ltd Patel Ltd. Babubhai 4000210007016000 4000970356356090

Arcadia India Jayesh Share Advanta Shamji and Vaghani ge Sec. bhai Stock Shilpaben 17 31/3/2009 928 44.2 5.00 4,642 5 1 Ltd Patel Broking Bharatbhai 4000210007016000 3640010030001000

Arcadia India Jayesh Share Advanta Shamji and Vaghani ge Sec. bhai Stock Shilpaben 18 1/4/2009 975 46.4 5.00 4,874 5 1 Ltd Patel Broking Bharatbhai 4000210007016000 3640010030001000 Inventur India Jayesh e Advanta Shamji Growth Anghan ge Sec. bhai & Sec. Kiritbhai 19 1/4/2009 975 0 0.00 4,874 5 2 Ltd Patel Ltd. Babubhai 4000210007016000 4000970356356090 Arcadia India Jayesh Share Advanta Shamji and Vaghani 1023. ge Sec. bhai Stock Shilpaben 20 2/4/2009 5 48.7 5.00 5117.5 5 1 Ltd Patel Broking Bharatbhai 4000210007016000 3640010030001000 Inventur India Jayesh e Advanta Shamji Growth Anghan 1023. ge Sec. bhai & Sec. Kiritbhai 21 2/4/2009 5 0 0.00 5117.5 5 2 Ltd Patel Ltd. Babubhai 4000210007016000 4000970356356090 Chanchp ara Anagra Madhub Anagra m Stock en m Stock Chanchpara 53,732.5 Broking Manjibh Broking Shantibhai 22 5/5/2009 1,075 51.15 5.00 0 50 1 Ltd. ai Ltd. Manjibhai 4000040035001000 4000040035001000 Chanchp ara Anagra Madhub Anagra m Stock en m Stock Chanchpara 53,732.5 Broking Manjibh Broking Shantibhai 23 5/5/2009 1,075 0 0.00 0 50 2 Ltd. ai Ltd. Manjibhai 4000040035001000 4000040035001000 Chanchp ara Anagra Madhub Anagra m Stock en m Stock Chanchpara Broking Manjibh Broking Shantibhai 24 13/5/2009 1,128 53.7 5.00 112,835 100 1 Ltd. ai Ltd. Manjibhai 4000040035001000 4000040035001000 India Advanta Kalpana ge Sec. Urvashi A.Gund Tukrul 25 26/5/2009 1,185 56.4 5.00 5,923.75 5 1 Ltd Patel aria Sneha S 4000210007016000 4000010002002000

Emkay India global Advanta Ramesh financial Mahendra ge Sec. D.Patel services Jivraj 26 29/5/2009 1,244 59.2 5.00 6,219.75 5 1 Ltd HUF ltd. Mitliya 4000210007016000 4212010179001000 Mehta Urvi India Devdatt Advanta Ramesh Angel Urvi ge Sec. D.Patel broking Devdatt 27 1/6/2009 1,306 62.1 5.00 6,530.50 5 1 Ltd HUF ltd. Mehta 4000210007016000 4000900049094000 Inventur India e Advanta Growth Anghan ge Sec. Ramesh & Sec. Kiritbhai 28 4/6/2009 1,371 65.3 5.00 1,371.40 1 1 Ltd D.Patel Ltd. Babubhai 4000210007016000 4000970356356090 Inventur India Jayesh e Advanta Shamji Growth Anghan ge Sec. bhai & Sec. Kiritbhai 29 5/6/2009 1,440 68.6 5.00 1,439.95 1 1 Ltd Patel Ltd. Babubhai 4000210007016000 4000970356356090 Sanghav India Jayesh i Advanta Shamji brothers Fofani 135,355. ge Sec. bhai brokerag Divya 30 5/6/2009 1,440 0 0.00 30 94 2 Ltd Patel e ltd. Devendra 4000210007016000 4000970026026090

Bagri Uttam B Inventur BCB Bcb e Brokera Finance Growth Patel ge Private & Sec. Umesh 31 8/6/2009 1,512 72 5.00 1,511.90 1 1 Pvt.Ltd. Limited Ltd. Harjibhai 4000010056056090 4000970356356090 Savla prabhab bagri Uttam en r BCB B BCB Unique prabhab Brokera Finance stockbro en r. ge Private 32 9/6/2009 1,587 75.6 5.00 1,587.45 1 1 pvt.ltd. Savla Pvt.Ltd. Limited 4000140036036090 4000010001001000 India Jayesh Anagra Advanta Shamji m Stock Chanchpara ge Sec. bhai Broking Shantibhai 33 10/6/2009 1,667 79.3 5.00 1,666.80 1 1 Ltd Patel Ltd. Manjibhai 4000210007016000 4000040035001000

Madhani Bijal K J.G.A.S Kalpana hah Madhani Anagra Share Securitie m Stock Shah brokers s Pvt. Broking Jignesh 34 11/6/2009 1,750 83.3 5.00 1,750.10 1 1 pvt.ltd. Ltd. Ltd. Chimanlal 4000630018018090 4000040035001000

Madhani J.G.A.S bijal k India hah kalpana Advanta Ramesh Share madhani ge Sec. D.Patel Brokers securities 35 12/6/2009 1,838 87.5 5.00 1,837.60 1 1 Ltd HUF Pvt.Ltd. pvt. Ltd. 4000210007016000 4000010003003090 Sanghav India i Advanta Ramesh brothers Fofani 11,025.6 ge Sec. D.Patel brokerag Divya 36 12/6/2009 1,838 0 0.00 0 6 2 Ltd HUF e ltd. Devendra 4000210007016000 4000970047047090 India Anagra Advanta Ramesh m Stock Chanchpara ge Sec. D.Patel Broking Shantibhai 37 12/6/2009 1,838 0 0.00 1,837.60 1 3 Ltd HUF Ltd. Manjibhai 4000210007016000 4000040035001000

Bagri Uttam B BCB Bcb Anagra Brokera Finance m Stock Patel ge Private Broking Hetalben 38 15/6/2009 1,929 91.9 5.00 1,929.45 1 1 Pvt.Ltd. Limited Ltd. Niteshbhai 4000010070070090 4000040035001000 Savla prabhab en r Unique prabhab Kotak stockbro en r. securitie Veer Raju 39 16/6/2009 2,026 96.5 5.00 2,025.90 1 1 pvt.ltd. Savla s ltd. Muppana 4000140036036090 1111111111111080 Savla prabhab Inventur en r e Unique prabhab Growth Patel stockbro en r. & Sec. Umesh 40 16/6/2009 2,026 0 0.00 2,025.90 1 2 pvt.ltd. Savla Ltd. Harjibhai 4000140036036090 4000970356356090

Vaghani Arcadia Shilpaben India Share Bharatbhai Advanta Ramesh and Shilpaben ge Sec. D.Patel Stock Bharatbhai 41 30/6/2009 2,127 101 5.00 2,127.15 1 1 Ltd HUF Broking Vaghani 4000210007016000 3640010030001000

Vaghani Arcadia Shilpaben India Share Bharatbhai Advanta Ramesh and Shilpaben ge Sec. D.Patel Stock Bharatbhai 42 1/7/2009 2,234 106 5.00 2,233.50 1 1 Ltd HUF Broking Vaghani 4000210007016000 3640010030001000

Vaghani Arcadia Shilpaben India Share Bharatbhai Advanta Ramesh and Shilpaben ge Sec. D.Patel Stock Bharatbhai 43 2/7/2009 2,345 112 5.00 2,345.15 1 1 Ltd HUF Broking Vaghani 4000210007016000 3640010030001000 Rungta Dimensi Nitin Anagra onal Nitin m Stock Sutariya securitie Rungta Broking Nilesh 44 8/7/2009 2,462 117 5.00 2,462.40 1 1 s pvt.ltd. Huf Ltd. Himatbhai 7000010003003090 4000040035001000 Rungta Inventur Dimensi Nitin e onal Nitin Growth Patel securitie Rungta & Sec. Umesh 45 13/7/2009 2,586 123 5.00 2,585.50 1 1 s pvt.ltd. Huf Ltd. Harjibhai 7000010003003090 4000970098002000

Savla Vaghani prabhab Arcadia Shilpaben en r Share Bharatbhai Unique prabhab and Shilpaben stockbro en r. Stock Bharatbhai 46 14/7/2009 2,715 129 5.00 2,714.75 1 1 pvt.ltd. Savla Broking Vaghani 4000140036036090 3640010030001000 Rungta Dimensi Nitin Anagra onal Nitin m Stock securitie Rungta Broking Rita Nilesh 47 16/7/2009 2,850 136 5.00 2,850.45 1 1 s pvt.ltd. Huf Ltd. Sutariya 7000010001001000 4000040035001000

Bhajiwa la Rajesh Maganb hai Rajesh Sushil Maganb Muppana financial hai P C S Veerraju services Bhajiwa Securitie Veerraju 48 3/8/2009 2,993 143 5.00 2,992.95 1 1 pvt.ltd. la s Ltd. Muppana 3950010027003000 5330040001001000 Rungta Dimensi Nitin Muppana onal Nitin P C S Veerraju securitie Rungta Securitie Veerraju 49 3/8/2009 2,993 0 0.00 2,992.95 1 2 s pvt.ltd. Huf s Ltd. Muppana 7000010001001000 5330040001001000

Arcadia India Share Advanta Ramesh and Vaghani ge Sec. D.Patel Stock Shilpaben 50 11/8/2009 3,143 150 5.00 3,142.55 1 1 Ltd HUF Broking Bharatbhai 4000210007016000 3640010030001000

Indira India share & Vijit shares Advanta Ramesh stock and 16,498.2 ge Sec. D.Patel brokers commoditie 51 13/8/2009 3,300 157 5.00 5 5 1 Ltd HUF pvt.ltd. s pvt ltd 4000210007016000 4520180001019000 Bhajiwa la Rajesh Maganb hai Vaghani Rajesh Arcadia Shilpaben Sushil Maganb Share Bharatbhai financial hai and Shilpaben services Bhajiwa Stock Bharatbhai 52 27/8/2009 3,465 165 5.00 3,464.60 1 1 pvt.ltd. la Broking Vaghani 3950010027003000 3640010030001000

Annexure ‘B’ Period-III : From August 28, 2009 to October 01, 2009 – Top 20 buyers and sellers: Top 20 buyers:

Gross Gross Buy Sell Net Total Client Member Name Client Name Client Address Volume Volume Volume Volume Brahmbhatt Milan 9 Ashirwad Flat prankunj KIFS Securities Pravinbhai Society kankaria, B_3127_ARM142 Pvt.Ltd. HUF Ahmedabad, Gujarat, 380022 1,223 1,223 0 2,446 A/202, Adarsh Galaxy, Balance Equity Adarsh Vidyalay,Marve Road Broking (India) Mewada Malad, Mumbai, B_3003_2134 Pvt.Ltd. Bhavna Bhanu Maharashtra 400064 1,200 0 1,200 1,200

604/A Bhattad Toweropp Bp Equities Mehta Bhavin Kora Kendra Ground B_74_5103 Pvt.Ltd. Y Mumbai Maharashtra 400092 1,030 1,030 0 2,060 18 Kund Kund Nagar G S K Marg Daftary Road Malad Kamdar East Mumbai Maharashtra B_748_71459 Sharekhan Ltd. Aashita Sunil 400097 1,000 0 1,000 1,000

8 36 Elephanta Chs Ltd Motilal Oswal Wala Babubhai Gaushala Lane Malad East B_446_MLDB081 Securities Ltd. J Mumbai Maharashtra 400097 900 0 900 900 Brahmbhatt Indira Pravinbhai Indira 9, Prankunj Society KIFS Securities Pravinbhai Maninagar ahmedabad B_3127_ARI18 Pvt.Ltd. Brahmbhatt 380008 Ahmedabad Gujarat 750 750 0 1,500 910 Gandi Bhawan, 9TH Nirmal Bang Floor,Near Police Station Securities Lamington Road,Mumbai B_498_L1067 Pvt.Ltd. Dhola Dinesh C Maharashtra 400004 700 700 0 1,400 Brahmbhatt Ketal Milanbhai Ketal 9, Ashirwad Flatprankunj KIFS Securities Milanbhai Societykankaria Ahmedabad B_3127_ARK22 Pvt.Ltd. Brahmbhatt Gujarat 380028 538 538 0 1,076 Shiv Pooja CHS Ltd Rh1 Plot Patel No 100 Sector 29 Vashi1 Plot Narmadaben K No 100 Sector 29 Vashi1 Plot Narmadaben K No 100 Sector 29 Vashi Navi B_748_W536358 Sharekhan Ltd. Patel Mumbai Maharashtra 400703 502 0 502 502 Thakkar Hasmukh Manilal Fortune Equity Hasmukh House No 15/469 Goregaon Brokers (India) Manilal Nav Nirmata Chs Ltd Siddh B_176_1190073 Ltd. Thakkar Mumbai Maharashtra 400062 500 5 495 505

3, Chandra Thakkar Bhuvan,H.N.Compound,M.G. Saikripa Taraben Road,Goregaon (W) Mumbai B_481_6534 Securities Ltd. Dahyalal Maharashtra 400062 500 0 500 500 Sanghvi Sameer Champaklal Rehman Bldg 4 Th Floor 24 Dynamic Stock Dynamic Stock Veer Nariman Road Fort Broking (India) Broking India Mumbai MAHARASHTRA B_115_OWN Pvt.Ltd. Pvt Ltd 400023 500 500 0 1,000

A / 202, Adarsh Galaxi, Balance Equity Mewada Adarsh Dugdhalayamarve Broking (India) Bhanuchandra Road, Malad (West) B_3003_9343 Pvt.Ltd. Manilal Mumbai Maharashtra 400064 450 300 150 750

K.M.Jain Stock 401 Vaishali Apt 51st T.P.S Brokers Shah Paresh Roadborivali (West) Mumbai B_352_5454 Pvt.Ltd. Dhirajlal Maharashtra 400092 444 444 0 888 Gurukrupa,2 Maruti Patel Anita Nagar,Air Port Road Rajkot B_3022_A1758 ANS Pvt.Ltd. Jayesh Gujarat 360001 400 0 400 400 Jain Rajeev Kamal Kumar Fairdeal Infin 205, Kedia Chambers, ( Resi. Jalan Securities Services Pvt. Wing),S.V. Road, Malad (W), B_361_9000 Pvt.Ltd. Ltd. Mumbai Maharashtra 400064 400 400 0 800

D.P.Vora 21/B Khatau Biulg. Opp. Securities Vora Deepak Stock Exchange Fort B_153_OWN Pvt.Ltd. Popatlal Mumbai Maharastra 400021 330 230 100 560 Shah Vipul Navinchandra A-403,Devraj Tower,Jugdes ASE Capital Vipul N Shah Bumglow,Bodakdev B_293_004V014 Markets Ltd. HUF Ahmedabad Gujarat 380054 325 300 25 625 Mehta Nemish Jaykishor Mehta Nemish Caregrowth Jaykishor J K Complex Diwanpara Broking Mehta Nemish Durlabhji Virani Road B_3210_JS01N134 Pvt.Ltd. Jaykishor Rajkot Gujarat 360001 312 17 295 329

304 Sai Complex A Wing Motilal Oswal Parul Hiten Kanderpada Dahisar (West) B_446_MLDP003 Securities Ltd. Thaker Mumbai Maharashtra 400068 300 0 300 300

Top 20 sellers:

Client Member Name Client Name Client Address Gross Buy Gross Net Total Volume Sell Volume Volume Volume

B_27_14507002 Anagram Stock Chanchpara 151 Enterprise Apartment 0 2,418 -2,418 2,418 Broking Ltd. Shantibhai Forjett Hill Rd Tardeo, Manjibhai Mumbai

B_27_14507004 Anagram Stock Chanchpara 101 Regal Arcade Opp 0 2,400 -2,400 2,400 Broking Ltd. Manjibhai Shreeji Chambers Tata Gilabhai Road No 2 Opera House, Mumbai

B_27_14507053 Anagram Stock Chanchpara 151 Enterprise Apts Forjett 0 1,981 -1,981 1,981 Broking Ltd. Manjibhai Hill Street Tardeo, Gilabhai Mumbai B_3127_ARM142 KIFS Securities Brahmbhatt 9 Ashirwad Flatprankunj 1,223 1,223 0 2,446 Pvt.Ltd. Milan Society Kankaria, Pravinbhai Ahmedabad HUF B_393_553129 HDFC Securities Patel Rasila J 1307, Raj Madhur,13 th 0 1,150 -1,150 1,150 Ltd. Rasila J Patel Flr, Nr Aquaria Club,Devidas Lane,Borivali (West), Mumbai B_141_45F002 Sanghavi Fofani Divya G-2, Gokul, M.G. Road, 0 1,100 -1,100 1,100 Brothers Devendra Borivali (E), Mumbai Brokerage Ltd. B_74_5103 BP Equities Mehta Bhavin 604/A Bhattad Toweropp 1,030 1,030 0 2,060 Pvt.Ltd. Y Kora Kendra Ground, Mumbai

B_27_14507021 Anagram Stock Chanchpara 101 Regal Arcade Opp 0 1,000 -1,000 1,000 Broking Ltd. Laljibhai Shreeji Chambers Tata Road No 2 Opera House, Mumbai

B_275_J14863 Inventure Anghan 2-B 505, Shantivan Raheja 0 940 -940 940 Growth & Savjibhai T Township Malad East, Securities Ltd. Mumbai

B_3127_ARI18 KIFS Securities Brahmbhatt 9, Prankunj Society 750 750 0 1,500 Pvt.Ltd. Indira Maninagar, Ahmedabad Pravinbhai 380008 Indira Pravinbhai Brahmbhatt B_393_552467 HDFC Securities Patel Pragna 1307, Raj Madhur,13 TH 0 700 -700 700 Ltd. Jaisukhbhai Flr, Nr Aquaria Pragna Club,Devidas Jaisukhbhai Lane,Borivali (West), Patel Mumbai B_498_L1067 Nirmal Bang Dhola Dinesh 910 Gandi Bhawan, 9th 700 700 0 1,400 Securities C Floor,Near Police Station Pvt.Ltd. Lamington Road,Mumbai

B_393_581325 HDFC Securities Patel Bhavesh 1307, Raj Madhur,13 TH 0 600 -600 600 Ltd. J Bhavesh J Flr, Nr Aquaria Patel Club,Devidas Lane Borivali (W), Mumbai B_3127_ARK22 KIFS Securities Brahmbhatt 9, Ashirwad Flatprankunj 538 538 0 1,076 Pvt.Ltd. Ketal Societykankaria, Milanbhai Ahmedabad Ketal Milanbhai Brahmbhatt B_115_OWN Dynamic Stock Sanghvi Rehman Bldg 4 th Floor 24 500 500 0 1,000 Broking (India) Sameer Veer Nariman Road Fort, Pvt. Ltd. Champaklal Mumbai Dynamic Stock Broking India Pvt Ltd B_3036_28061 India Advantage Shamo E/104, Panchvati -1,Raheja 0 459 -459 459 Securities Ltd. Investments Township,Rani Sati Marg, Private Malad (East). Mumbai Limited Shamo Investments Private Limited

B_393_556997 HDFC Securities Patel Geeta P Shikharkunj 9th Floor Flat 0 450 -450 450 Ltd. Geeta P Patel No 902,Upper Govind Nagar,Malad East, Mumbai B_352_5454 K.M.Jain Stock Shah Paresh 401 Vaishali Apt 51st 444 444 0 888 Brokers Pvt.Ltd. Dhirajlal T.P.S Roadborivali (West), Mumbai

B_393_552605 HDFC Securities Patel Manjula Flat No 701 A Wing 7th 0 400 -400 400 Ltd. H Manjula H Floor,Ruchi Appartment Patel Devidas Lane,Borivali West, Mumbai

B_393_552447 HDFC Securities Patel Hetal H Flat No 701 A Wing 7th 0 400 -400 400 Ltd. Hetal H Patel Floor,Ruchi Appartment Devidas Lane,Borivali West, Mumbai

Annexure ‘C’ Summary of the sell trades by the promoter entities in period III: Date Time Volume Price Value Sell Client Name 3/9/2009 14:21:13 2 400.95 801.90 Mr. Jayesh Shamjibhai Patel 7/9/2009 12:20:14 2 420.95 841.90 Mr. Jayesh Shamjibhai Patel 9/9/2009 13:58:12 5 464 2,320.00 Shamo Investments Pvt. Ltd. 14/9/2009 13:27:23 165 511.55 84,405.75 Ms. Rasila Patel 14/9/2009 13:27:23 10 511.55 5,115.50 Ms. Rasila Patel 14/9/2009 13:27:23 20 511.55 10,231.00 Ms. Rasila Patel 14/9/2009 13:27:23 5 511.55 2,557.75 Ms. Rasila Patel 14/9/2009 13:27:23 2 511.55 1,023.10 Ms. Rasila Patel 14/9/2009 13:27:23 50 511.55 25,577.50 Ms. Rasila Patel 14/9/2009 13:27:23 20 511.55 10,231.00 Ms. Rasila Patel 14/9/2009 13:27:23 100 511.55 51,155.00 Ms. Rasila Patel 14/9/2009 13:27:23 28 511.55 14,323.40 Ms. Rasila Patel 14/9/2009 14:02:16 2 511.55 1,023.10 Ramesh D. Patel HUF 14/9/2009 14:02:16 3 511.55 1,534.65 Ramesh D. Patel HUF 17/9/2009 15:22:43 5 592.1 2,960.50 Mr. Ramesh D. Patel 18/9/2009 13:25:45 5 621.7 3.108.50 Ms. Manjula Patel 22/9/2009 15:05:26 9 652.75 5,874.75 Ms. Jagruti Patel 22/9/2009 15:05:26 50 652.75 32,637.50 Ms. Jagruti Patel 22/9/2009 15:05:26 41 652.75 26,762.75 Ms. Jagruti Patel 22/9/2009 15:06:01 54 652.75 35,248.50 Ms. Manjula Patel 22/9/2009 15:06:01 46 652.75 30,026.50 Ms. Manjula Patel 22/9/2009 15:06:32 100 652.75 65,275.00 Ms. Hetal Patel 23/9/2009 10:20:38 500 685.35 3,42,675.00 Mr. Bhavesh Patel 23/9/2009 10:25:31 5 685.35 3,426.75 Ms. Pragna Patel 23/9/2009 10:25:31 495 685.35 3,39,248.25 Ms. Pragna Patel 23/9/2009 11:25:35 200 685.35 1,37,070.00 Ms. Rasila Patel 23/9/2009 12:01:16 65 685.35 44,547.75 Ramesh D. Patel HUF 23/9/2009 12:01:16 25 685.35 17,133.75 Ramesh D. Patel HUF 23/9/2009 12:01:16 85 685.35 58,254.75 Ramesh D. Patel HUF 23/9/2009 12:02:39 115 685.35 78,815.25 Ms. Manjula Patel 23/9/2009 12:02:39 35 685.35 23,987.25 Ms. Manjula Patel 23/9/2009 12:03:12 15 685.35 10,280.25 Ms. Jagruti Patel 23/9/2009 12:03:12 15 685.35 10,280.25 Ms. Jagruti Patel 23/9/2009 12:03:12 15 685.35 10,280.25 Ms. Jagruti Patel 23/9/2009 12:03:12 1 685.35 685.35 Ms. Jagruti Patel 23/9/2009 12:03:12 15 685.35 10,280.25 Ms. Jagruti Patel 23/9/2009 12:03:12 25 685.35 17,133.75 Ms. Jagruti Patel 23/9/2009 12:03:12 14 685.35 9,594.90 Ms. Jagruti Patel 24/9/2009 10:07:19 123 719.6 88,510.80 Mr. Jayesh Shamjibhai Patel 24/9/2009 13:37:36 33 719.6 23,746.80 Mr. Jayesh Shamjibhai Patel 25/9/2009 11:34:20 1 755.55 755.55 Ms. Manjula Patel 25/9/2009 11:34:20 144 755.55 1,08,799.20 Ms. Manjula Patel 25/9/2009 11:59:08 250 755.55 1,88,887.50 Ms. Rasila Patel 25/9/2009 12:00:45 96 755.55 72,532.80 Ms. Jagruti Patel 25/9/2009 12:00:45 4 755.55 3,022.20 Ms. Jagruti Patel

25/9/2009 12:01:15 6 755.55 4,533.30 Mr. Bhavesh Patel 25/9/2009 12:01:15 10 755.55 7,555.50 Mr. Bhavesh Patel 25/9/2009 12:01:15 9 755.55 6,799.95 Mr. Bhavesh Patel 25/9/2009 12:01:15 10 755.55 7,555.50 Mr. Bhavesh Patel 25/9/2009 12:01:15 10 755.55 7,555.50 Mr. Bhavesh Patel 25/9/2009 12:01:15 10 755.55 7,555.50 Mr. Bhavesh Patel 25/9/2009 12:01:15 5 755.55 3,777.75 Mr. Bhavesh Patel 25/9/2009 12:01:15 1 755.55 755.55 Mr. Bhavesh Patel 25/9/2009 12:01:15 10 755.55 7,555.50 Mr. Bhavesh Patel 25/9/2009 12:01:15 29 755.55 21,910.95 Mr. Bhavesh Patel 25/9/2009 12:01:45 10 755.55 7,555.50 Ms. Pragna Patel 25/9/2009 12:01:45 10 755.55 7,555.50 Ms. Pragna Patel 25/9/2009 12:01:45 10 755.55 7,555.50 Ms. Pragna Patel 25/9/2009 12:01:45 2 755.55 1,511.10 Ms. Pragna Patel 25/9/2009 12:01:45 25 755.55 18,888.75 Ms. Pragna Patel 25/9/2009 12:01:45 43 755.55 32,488.65 Ms. Pragna Patel 25/9/2009 12:03:21 25 755.55 18,888.75 Ms. Hetal Patel 25/9/2009 12:04:27 1 755.55 755.55 Ms. Hetal Patel 25/9/2009 12:04:30 1 755.55 755.55 Ms. Hetal Patel 25/9/2009 12:05:30 10 755.55 7,555.5 Ms. Hetal Patel 25/9/2009 12:06:04 10 755.55 7,555.5 Ms. Hetal Patel 25/9/2009 12:07:58 53 755.55 40,044.15 Ms. Hetal Patel 25/9/2009 12:07:58 42 755.55 31,733.10 Ms. Pragna Patel 25/9/2009 12:08:34 5 755.55 3,777.75 Ms. Pragna Patel 25/9/2009 12:09:59 5 755.55 3,777.75 Ms. Pragna Patel 25/9/2009 12:10:07 48 755.55 36,266.40 Ms. Pragna Patel 25/9/2009 14:21:14 50 753.5 37,675.00 Shamo Investments Pvt. Ltd. 25/9/2009 14:21:19 1 753.5 753.5 Shamo Investments Pvt. Ltd. 25/9/2009 14:23:04 30 753.5 22,605.00 Shamo Investments Pvt. Ltd. 25/9/2009 14:23:10 5 753.5 3,767.50 Shamo Investments Pvt. Ltd. 25/9/2009 14:24:41 5 753.5 3,767.50 Shamo Investments Pvt. Ltd. 25/9/2009 14:25:52 10 753.5 7,535.00 Shamo Investments Pvt. Ltd. 25/9/2009 14:43:27 2 753.5 1,507.00 Shamo Investments Pvt. Ltd. 25/9/2009 14:52:43 3 753.5 2,260.50 Shamo Investments Pvt. Ltd. 25/9/2009 14:53:04 1 753.5 753.50 Shamo Investments Pvt. Ltd. 25/9/2009 14:55:07 5 753.5 3,767.50 Shamo Investments Pvt. Ltd. 25/9/2009 14:57:52 38 753.5 28,633.00 Shamo Investments Pvt. Ltd. 25/9/2009 14:57:52 52 753.8 39,197.60 Shamo Investments Pvt. Ltd. 25/9/2009 14:59:21 1 753.8 753.8 Shamo Investments Pvt. Ltd. 25/9/2009 15:17:41 5 753.8 3,769.00 Shamo Investments Pvt. Ltd. 25/9/2009 15:20:34 142 753.8 1,07,039.60 Shamo Investments Pvt. Ltd. 25/9/2009 15:20:34 53 754 39,962.00 Shamo Investments Pvt. Ltd. 25/9/2009 15:21:05 5 754 3,770.00 Shamo Investments Pvt. Ltd. 25/9/2009 15:21:19 27 754 20,358.00 Shamo Investments Pvt. Ltd. 25/9/2009 15:25:51 1 754 754 Shamo Investments Pvt. Ltd. 25/9/2009 15:25:57 18 754 13,572.00 Shamo Investments Pvt. Ltd. 30/9/2009 15:15:35 191 800.5 1,52,895.50 Ms. Hetal Patel 30/9/2009 15:16:21 3 800.5 2,401.50 Ms. Hetal Patel

30/9/2009 15:20:27 6 800 4,800.00 Ms. Hetal Patel 30/9/2009 15:20:27 294 800.5 2,35,347.00 Ms. Rasila Patel 30/9/2009 15:21:04 1 800.5 800.5 Ms. Rasila Patel 30/9/2009 15:21:43 1 800.5 800.5 Ms. Rasila Patel 30/9/2009 15:22:31 1 800.5 800.5 Ms. Rasila Patel 30/9/2009 15:24:29 3 800.5 2,401.5 Ms. Rasila Patel Total 4354 30,57,652.2