Interim Ex Parte Order in the matter of Debock Industries Limited

WTM/AB/CFID/CFID-SEC4/30708/2024-25 SECURITIES AND EXCHANGE BOARD OF INDIA INTERIM EX - PARTE ORDER Under Sections 11(1), 11(4) and 11B of the Securities and Exchange Board of India Act, 1992 In respect of:

Name of the Noticee Debock Industries Limited AACCD9561G Mukesh Manveer Singh AMHPM1429Q Sunil Kalot BLHPK0027J Priyanka Sharma AZQPS4804F (The aforesaid entities are hereinafter individually referred to by their respective names/Noticee No. and collectively as “Noticees” unless the context specifies otherwise).

In the matter of Debock Industries Limited 1. Debock Industries Limited (Debock/DIL/Company) is a company listed on the National Stock Exchange of India Limited (NSE) having its registered office at 51, Lohiya Colony, 200 ft Bypass, Vaishali Nagar, Jaipur. As per the Annual Report of the Company for FY23, Debock is primarily engaged in trading agricultural equipment, hospitality services and mining. The Company was initially listed on the Innovators Growth Platform on June 05, 2018. Subsequently, it migrated to the main board of NSE on March 31, 2022. 2. An examination by NSE indicated that there was a significant increase in revenue and purchases recorded in the books of the Company in FY22 and FY23. The period during which the Company recorded higher revenues matched with the period the Company migrated to the main board of NSE. It was also noted that during this period the Company came out with two preferential issues, one rights

Interim Ex Parte Order in the matter of Debock Industries Limited issue and one bonus issue. The details of the same are discussed in subsequent paragraphs. 3. The revenue and purchases recorded in the financial statements of the Company for the period FY21 to FY23 are given in the Table below: (Amt. in Rs. Cr.) Particulars FY21 FY22 FY23 Total Revenue 30.78 97.37 146.4 Total Purchases 24.69 92.79 117.08

4. On examining the information submitted by the Company, NSE noted that around 75% of the sales and 95% of the purchases recorded in FY22 and FY23 consisted of transactions undertaken with related or linked entities (connected entities). Based on the findings of the examination, NSE submitted a report to SEBI. The major findings in the report related to: i. Transactions with connected entities that constituted a significant percentage of sales and purchases recorded by DIL in FY22 and FY23; ii. Funds for sales made to connected entities were round-tripped and recorded as payments for purchases from other connected entities. 5. On receipt of the report from NSE, considering the gravity of the findings, SEBI initiated a preliminary examination into the matter. To understand the nature of transactions entered with connected entities, the books of accounts and other records including ledgers maintained by the Company were called for and examined. It was noted that sales recorded with connected entities accounted for 72% and 77.88% of the total sales recorded in FY22 and FY23 respectively. Similarly, purchases from connected entities represented approximately 94% of the total purchases recorded in the respective years. The details of the same are given in the Table below:

(Amt. in Rs. Cr.) Particulars FY22 FY23 Comments Sales Wadwa Agro Seeds 19.66 63.61 linked entity DSML 9.11 50.41 linked entity Eagle Sales 20.92 - related party Arvind Trading Undisclosed 20.41 - Company related party Total Sales from above 70.10 114.02 -parties Total Sales 97.37 146.4 % of Revenue from disclosed/ undisclosed / linked / 72% 77.88% -related parties Purchases Impex Prime 36.83 51.72 related party Engineering Works Semi Engineering 50.71 58.37 linked entity Total purchases from 87.54 110.09 -above parties Total Purchases 92.79 117.08 % of Purchases from 94.34% 94.03% -related / linked parties

6. The nature of the relationship of the Company with connected entities is depicted below:

7. Wadwa Agro Seeds and DSML are sole proprietorships owned by Mohak Wadhwa and Harish Sharma respectively, who are directors in Debock Seeds Multi Producer Company Ltd. (Debock Seeds), a Debock Group Company. Mukesh Manveer Singh, the CMD of DIL is a shareholder of Debock Seeds. 8. Arvind Trading Company and Eagle Sales are sole proprietorship concerns of Arvind Rao, an Independent Director of the Company and Mukesh Manveer Singh respectively. They are, therefore, Related Parties of DIL. However, the Company only disclosed Eagles Sales as a Related Party. 9. Impex Prime (Impex) is a proprietorship of Sunil Kalot who is disclosed as a promoter of DIL and is also a shareholder in Debock Seeds.

Analysis of ledgers and corresponding bank transactions 10. During the examination of the ledgers of connected entities in the books of Debock for the period April 01, 2021 to March 31, 2023, it was noted that funds received for sales to connected entities were recorded as payments for purchases from certain other connected entities on the same or next day. As an illustration, the transactions entered by the Company with connected entities in the month of April 2022 are given in the Table below for reference: (Amt. in Rs.) Sr. Customer/ Date Party Name Receipt Payment No. Supplier 4-Apr-22 DSML Sales 6,500,000 - 1 5-Apr-22 Semi Engineering Purchase - 6,500,000 Wadwa Agro 8-Apr-22 Sales 9,900,000 - Seeds 2 8-Apr-22 Impex Prime Purchase - 5,000,000 8-Apr-22 Semi Engineering Purchase - 6,500,000 Wadwa Agro 10-Apr-22 Sales 9,500,000 - Seeds 3 10-Apr-22 Semi Engineering Purchase - 5,000,000 11-Apr-22 Impex Prime Purchase - 5,000,000 13-Apr-22 DSML Sales 9,500,000 - 4 13-Apr-22 Impex Prime Purchase - 5,000,000 Wadwa Agro 16-Apr-22 Sales 5,342,043 - 5 Seeds 16-Apr-22 Impex Prime Purchase - 5,000,000 6 17-Apr-22 DSML Sales 6,500,000 -

Sr. Customer/ Date Party Name Receipt Payment No. Supplier 17-Apr-22 DSML Sales 9,500,000 - 17-Apr-22 Semi Engineering Purchase - 5,000,000 17-Apr-22 Semi Engineering Purchase - 5,000,000 Wadwa Agro 23-Apr-22 Sales 5,000,000 - 7 Seeds 23-Apr-22 Semi Engineering Purchase - 5,000,000 26-Apr-22 DSML Sales 6,500,000 - 26-Apr-22 DSML Sales 9,500,000 - 8 26-Apr-22 Impex Prime Purchase - 5,000,000 26-Apr-22 Semi Engineering Purchase - 5,000,000 Wadwa Agro 29-Apr-22 Sales 5,500,000 - 9 Seeds 29-Apr-22 Impex Prime Purchase - 5,000,000

11. It is evident from the above Table that on most dates, sales to connected entities matched purchases from other connected entities. As per ledgers of the Company, majority of the payments and receipts in respect of these transactions with connected entities were recorded in A/c bearing No.200000806982 maintained with Equitas Small Finance Bank and A/c bearing No.046014100l000560 maintained with Adarsh Co-operative Bank Limited. 12. The details of the receipts and payments recorded, as per the ledger, in Equitas Small Finance Bank bearing A/c No. 200000806982 are given in the Table below: (Amt. in Rs. Cr.) FY22 FY23 % of Receipts/ Receipts/ receipts % of receipts Particulars Amount of payment payments Transa payments payments s from ction from transaction from from Equitas Equitas Amount Equitas Equitas Bank Bank Bank Bank Sales Wadwa Agro 19.66 19.66 100% 63.61 43.74 68.76% Seeds DSML 9.11 7.65 83.97% 50.41 43.74 86.77% Eagle Sales 20.92 22.63 108.17% 0 0 0% Arvind Trading 20.41 18.17 89.02% 0 0 0% Company Total sales to 70.1 68.11 97.16% 114.02 87.48 76.72% linked entities Total Sales 97.37 146.4

% of Total 72% 77.88% Sales to linked entities Purchases Impex Prime 36.83 38.04 103.29% 51.72 51.72 100% Semi 50.71 50.19 98.97% 58.37 55.36 94.84% Engineering Total 87.54 88.23 100.79% 110.09 107.08 97.27% purchases from linked entities Total 92.79 117.08 purchases % of total 94.34% 94.03% purchases from linked entities * bank account closed on November 2020

13. In order to trace the movement of funds related to these transactions, the details of the bank accounts used for these transactions were called for from the Company. Debock vide email dated June 18, 2024, submitted copy of bank statement of the account maintained at Equitas Small Finance Bank for the period April 01,2022 to July 28,2022. Physical copies of the bank statements and other related documents certified by the director of the Company were submitted by the Company vide letter dated June 14, 2024, which was received by SEBI on June 26, 2024. 14. In order to independently verify the trail of funds for the abovementioned transactions, statement of the account was sought from Equitas Small Finance Bank vide email dated June 16, 2024. The analysis of the bank statement obtained from the Bank revealed that the account in question was closed on November 09, 2020 and the closure proceeds (Rs. 497.50) were credited to IT Indiabull Private Limited (subsequently renamed as Naturo Indiabull Limited). 15. On comparing the bank statement provided by the Company with the statements obtained from Equitas Small Finance Bank, it was noted that the bank account statement submitted by the Company was fabricated as the account was closed on November 09, 2020. The transactions undertaken in FY23 could not have been recorded in a bank account which was closed in 2020. 16. It was, therefore, prima facie noted that in FY22, 72% of the sales and 94.34 % of purchases were from linked entities, out of which 97.16% of the sales and 100 % of purchases were recorded in a nonexistent bank account. Similarly, in FY23, where 77.88% of the sales and 94.03 % of purchases consisted of transactions undertaken with connected entities, 76.72 % of sales and payment for 97.27% of purchases made to connected entities were recorded in books of the Company against a nonexistent bank account. 17. The Company had recorded the majority of its sales and purchases from linked entities in a bank account which was closed before recording these transactions. Thus, it appears that approx. 70-80 % of the sales and purchases of Debock for FY 2021-22 and FY 2022-23 were bogus. Qualified opinion by statutory auditor 18. It is noted from the audit report for the quarter ended March 2024 that the statutory auditor, Mittal & Associates, has written in Emphasis of Matter that:

“Revenue from Operations aggregating to Rs. 9807.84 Lakhs and Purchases of Stock-in-trading aggregating to Rs. 8215.72 Lakhs for the year ended March 31, 2024 wherein we observed the following: - a. Based on the generally accepted auditing practices in case of sale of goods and purchases of goods, we could not find the evidence for the movement of the goods like delivery challans, transport charges, purchase orders, Goods Receipt Notes (GRN) and proof of delivery etc. However, we have received few E way bills for the samples selected by us, but the volume of sales and purchases, nature of stock items, and repetitiveness of vehicle numbers in E way bills gives us doubt on physical movement of goods supplied. Also, in the samples selected by us we observed that the GST at the prevailing rates were not levied on the products purchased or sold during the year and the same has been categorised as exempt goods. b. Furthermore, the Sales Transactions on which TCS was collected by the Company as per section 206C(1H) of Income Tax Act, 1961 but not paid by the Company and applicable periodic returns for TCS were not filed. Based on the party wise sales volume, we could not find the supporting third party evidence to confirm the deduction of TDS U/s 194Q of Income Tax Act, 1961 on purchases made by the customers of the Company. Therefore, we state that the reporting of sales transactions as above have not been done either by seller or by purchaser. c. Furthermore, the TDS on purchase of goods u/s 194Q was not paid nor the return was filed for the year ended March 31, 2024 and hence the party-wise details of purchases were not reported to the respective departments.

d. Further, in cases of receipts from sale of goods, we observed that the amount realised from the sales were not retained in the bank accounts and the same were immediately transferred to the other parties. As a result of these observations, we were unable to obtain sufficient appropriate audit evidence regarding the movement of the goods during the year and also unable to comment on the taxability of the goods purchased and sold during the year.”

19. It is noted that the statutory auditor had qualified financial statements by stating that the sales and purchases were without any underlying movement of goods. Further, the statutory auditor has also stated that GST at the prevailing rates was not levied on the products purchased or sold during the year and the same was categorized as exempt goods. The Company did not file returns with respect to TCS collected on sales of goods as per section 206C(1H) of the Income-tax Act, 1961 and TDS on purchase of goods under section 194Q. This supports the suspicion regarding genuineness of sales and purchases of the Company.

Analysis of share price and changes in promoter shareholding 20. The price of the DIL scrip showed a sharp spike during the period the Company started reporting inflated sales and purchases. The share price of DIL for the period March 2021 to March 2024 is given in the chart below:

200 Rs 156.3 150 Rs. 128 100 50 Rs.18 Rs. 7.2 0 111111111222222222222333333333333444 222222222222222222222222222222222222 -r p A -0 3 -y a M -1 3 -n u J-0 3 -lu J-1 3 -g u A -1 3 -p e S -0 3 -tc O -1 3 -v o N -0 3 -c e D -1 3 -n a J-1 3 -b e F -8 2 -r a M -1 3 -r p A -0 3 -y a M -1 3 -n u J-0 3 -lu J-1 3 -g u A -1 3 -p e S -0 3 -tc O -1 3 -v o N -0 3 -c e D -1 3 -n a J-1 3 -b e F -8 2 -r a M -1 3 -r p A -0 3 -y a M -1 3 -n u J-0 3 -lu J-1 3 -g u A -1 3 -p e S -0 3 -tc O -1 3 -v o N -0 3 -c e D -1 3 -n a J-1 3 -b e F -9 2 -r a M -1 3

21. As per the above chart, the share price of DIL started moving up from May/June 2021. There was a significant spike in share price during the period from September 2021 to December 2021. The scrip witnessed an increase in retail investor participation during this price rise period. Resultantly, public shareholding in the Company increased during this period to 90.56% (from a mere 171 to 53,389 shareholders) whereas the promoter shareholding saw a steady decline to 9.41% from 64.79% as depicted in the chart below:

Promoter v/s Public shareholding 90.56% 100.00% 80.00%64.79% 60.00% 35.21% 40.00% 9.41% 20.00% 0.00%

Promoters Public

22. It is evident from the charts above that there was a steady decline in the promoter shareholding starting from FY22 with a concomitant increase in the public shareholding. Therefore, corporate actions undertaken by the Company during this period were examined. Major corporate Actions by the Company from FY 2021-22 to FY 2023-24 23. The major corporate actions undertaken by the Company during the period FY22 to FY24 are given in the Table below: Sr. Date Corporate Action Particulars Amount (Rs. No. Crores) 1. 13/09/2021 Preferential issue 3.00 crore 37.50 10/02/2022 warrants and conversion warrants 25/04/2022 2. 01/11/2022 Bonus issue 1:1 Bonus -- Issue 3. 04/07/2023 Rights Issue -- 49.50 4. 31/10/2023 Preferential. Issue 5.35 crore 74.90 07/02/2024 warrants and conversion warrants

Preferential allotment (1) – (2021) 24. As already noted in this Order, Debock migrated to the main board of NSE on March 31, 2022. Prior to this, the Company made a preferential issue of 3,00,00,000 convertible warrants at a price of Rs.12.50 per warrant on September 13, 2021, which were converted to equity in 2 tranches:

i. Tranche 1- 10/02/2022 - 1,50,00,000 warrants; ii. Tranche 2- 25/04/2022 - 1,50,00,000 warrants. 25. The details of the allottees, the number of warrants/shares allotted and the consideration received from the allottees are given in the Table below: Sr. Name of Category No. of Amount 1st 2nd Amount No. the warrants receivable on Conversion conversion receivable on Allottee allotted Conversion 10/02/2022 25/04/2022 Conversion (13/09/2021) (25% of total (no. of (no. of (75% of total consideration) shares) shares) consideration) 1. Mr. Promoter 1,05,00,000 3,28,12,500 44,92,000 60,08,000 9,84,37,500 Mukesh Manveer Singh 2. Mr. Raju Promoter 35,00,000 1,09,37,500 21,26,000 13,74,000 3,28,12,500 Ajmera 3. Mr. Non- 40,00,000 1,25,00,000 24,30,000 15,70,000 3,75,00,000 Abhishek promoter Khandelwal 4. Ms. Najiya Non- 37,00,000 1,15,62,500 22,47,000 14,53,000 3,46,87,500 Bano promoter 5. Mr. Bharu Non- 37,00,000 1,15,62,500 22,43,000 14,57,000 3,46,87,500 Ram promoter 6. Mr. Rahul Non- 14,50,000 45,31,250 4,80,000 9,70,000 1,35,93,750 Khurana promoter 7. Ms. Non- 14,50,000 45,31,250 4,82,000 9,68,000 1,35,93,750 Sheetal promoter Jain 8. Mr. Ajay Non- 17,00,000 53,12,500 5,00,000 12,00,000 1,59,37,500 Dahiya promoter Total 3,00,00,000 9,37,50,000 1,50,00,000 1,50,00,000 28,12,50,000 Grand Total 37,50,00,000

26. It was found during the examination that the allottees under the non-promoter category appeared to be linked to the Company. The details of their connection to Debock are given below:

The connection between Debock and the allottees is as follows :

Note: The role of Naturo Indiabull Ltd is discussed later in the Order.

27. As many of the preferential allottees appeared to be ‘connected’ to the Company, the details of the bank account where the proceeds from the allotment were credited were sought from the Company. DIL in its reply submitted that the application money for the preferential allotment (25% of total consideration for allotment of warrants) was received in its Axis Bank bearing A/c No. 21020030160622 on September 08, 2021. The Company also submitted a copy of the bank statement of the said account in support. Upon verification of the bank statements obtained from Axis Bank, it was found that bank statements submitted by the Company were fabricated. The funds transferred by the preferential allottees were not reflected in the bank statement obtained from Axis Bank. 28. However, upon examining the A/c bearing No.046014100000560 maintained by the Company with Adarsh Co-operative Bank, it was noted that the said account reflected payments received from the preferential allottees. On examination of the trail of payments, it was, prima facie, found that fund transfers to the account were made in a circuitous manner.

29. To illustrate, in respect of the payment received from Mukesh Manveer Singh for the allotment of warrants (Rs.3.28 crore was payable by the Noticee at the time of allotment of warrants), it was found that Rs.30 lakh was initially transferred from Priyanka Sharma to Debock a day prior to the transfer of funds by the allottees (September 06, 2021). These funds were subsequently transferred by Debock to Sunil Kalot (promoter) on the next day (September 07, 2021). Sunil Kalot transferred the funds to Mukesh Manveer Singh (allottee) who paid the amount to Debock as consideration for the allotment of warrants. This completed the initial round of payment of Rs.30 lakh towards application money. 30. The same amount was circulated repeatedly between the Company, Sunil Kalot and Mukesh Manveer Singh to show the payment of a total consideration of Rs.3.28 crore without the actual availability of funds with the preferential allottee. Thus, it is seen that Rs.30 lakh received from Priyanka Sharma by the Company was round tripped ten times in quick succession and Rs.28 lakh remitted finally to create an impression of payment of Rs.3.28 crore towards 25% application money, while no such amount actually existed.

The credit balance in the account of both Sunil Kumar Kalot and Mukesh Manveer Singh with Adarsh Co-operative Bank was a mere Rs.1000/-. Obviously, DIL did not receive any proceeds from Mukesh Manveer Singh for the preferential allotment.

31. The trail of funds is depicted below :

The details of these transactions have been placed as Annexure A.

32. The screenshot of bank statements depicting the said transactions are as follows:

a. Transfer from Priyanka Sharma to Debock and from Debock to Sunil Kalot b. Transfer from Debock to Sunil Kalot and from Sunil Kalot to Mukesh Manveer Singh c. Transfer from Sunil Kalot to Mukesh Manveer Singh and from Mukesh Manveer Singh to Debock

33. Further, the process of such circuitous transactions was repeated for other allottees wherein funds transferred from Debock to Sunil Kalot were used to fictitiously create an impression of payment of application money by the allottees. The details are summarised below:

Name of the Total Amount No. of circuitous applicant circulated (Rs. transactions crore) involving Company and Sunil Kalot Mukesh 3.28 11 Manveer Singh Abhishek 1.25 5 Khandelwal Najiya Bano 1.16 5 Bharu Ram 1.16 5 Sheetal Jain 0.46 2 Rahul Khurana 0.46 2 Ajay Dahiya 0.53 3 Total money Rs. 8.28 crore* circulated at the time of issuance of warrants *Raju Ajmera did not pay his share of Rs.1,09,37,500/- 34. The trail of funds and the details of the circuitous bank transfers made by the other allottees is placed as Annexure B. It was also noted that no funds were received from Raju Ajmera who was allotted 35,00,000 warrants. 35. Thus, the Company gave a false appearance of receipt of allotment money of Rs.8.28 crore by circulation of a single sum of Rs.30 lakh multiple times through Sunil Kalot as a conduit. Further, the amount of Rs.30 lakh initially received by the Company from Priyanka Sharma was returned by DIL on September 13, 2021.

Allotment of equity shares in two tranches pursuant to the conversion of warrants: 36. The Company vide email dated June 14, 2024 submitted the details of the subsequent conversion of warrants to equity shares. As per the submissions, the 1st conversion of 1.5 crore warrants and second conversion of 1.5 crore warrants to equity shares were on February 10, 2022 and April 25, 2022 respectively against the receipt of a total of Rs.28.20 crore in the bank account (No. 921020030160622) of the Company maintained with Axis Bank. The Company also provided certified copies of the bank statement indicating these payments. 37. However, the analysis of the bank statement obtained from Axis Bank did not show these receipts. Thus, it was observed that the Company submitted fabricated bank account statement to substantiate its claim of the receipt of the conversion money and its utilisation. 38. The Company also mentioned the bank accounts from which it received funds for conversion of the warrants to equity. When the statement of the account provided in respect of Mukesh Manveer Singh was obtained from the Bank and examined, it was observed that no such transactions/credits existed in the said bank account. Thus, it was, prima facie, found that the conversion of warrants/allotment of equity shares (both tranches) was done without DIL having actually received the conversion money. 39. In terms of regulation 169(5) of the SEBI (Issue of Capital and Disclosure Requirements) Regulations, 2018, the issuer has to submit a certificate from the statutory auditor certifying that the cash consideration payable by the preferential allottees had been received in the designated bank account of the Company. It is noted that this certificate was issued by Mittal & Associates, Chartered Accountants, who were the statutory auditor of the Company. Mittal & Associates certified that “The company has realised 25% upfront money amounting to Rs.9,37,50,000 on September 8, 2021 against the allotment of 3,00,00,000 warrants made on September 13, 2021”. However, when information was called from the statutory auditor seeking clarification regarding the basis on which the certificate was provided, vide email dated June 29, 2024 the statutory auditor submitted the fabricated Axis Bank account statements (which was earlier submitted by the Company to SEBI) as the basis of its certification.

Use of Proceeds from Preferential Issue-I 40. The Company, in its reply dated June 14, 2024, submitted that the funds from the preferential allotment was used for making payments to Debock Builders Pvt. Ltd. (Rs. 90 lakh) and Azimuddin Abbasi (Rs.36 crore) for purchasing land. In support of this, the Company submitted a copy of bank statements of Axis Bank bearing A/c No.921020030160622 (which as already noted above were forged) to substantiate that these transactions were undertaken in September and October 2021. The analysis of the Bank Statement of the account maintained with Adarsh Co-operative Bank indicated, as already stated earlier, that the Company repeatedly engaged in transactions where funds that were received were promptly returned/rotated in a circuitous manner. 41. Given the same, it is, prima facie, noted that no money was effectively received by the Company from the preferential issue and, therefore, the contentions of the Company regarding its utilisation are not tenable. Resultantly, it can be stated that financial statements of the Company for the relevant period have been misstated.

Qualified opinion by statutory auditor 42. In the auditor report for FY 2023-24, the statutory auditor, Mittal & Associates, had written an Emphasis of Matter that: “Capital advances aggregating to Rs. 4845.26 lakhs as on March 31, 2024 disclosed under the head “Other Non-current assets”. Out of this, an amount of Rs. 1185.25 Lakh were given to the related party whose name were struck off as per the Ministry of Corporate Affairs (MCA) records. Further, as per the explanation and information available to us, these advances were given for the purchase of Lands however as on March 31, 2024, neither the lands have been purchased nor any confirmations were received from the parties. Further, no impairment assessments have been conducted in regards to these advances.”

43. The audit qualifications/Emphasis of Matter as noted above, further substantiate the prima facie finding recorded in this Order that submissions made by the Company that the proceeds from the issue were utilised for making payments towards the purchase of lands is false. Further, the bank statements submitted by the Company were forged. 44. Given the foregoing, I am of the considered view that it prima facie appears that the preferential issue was done in a fraudulent manner and shares were allotted to entities without receiving any consideration. Fictitious preferential issue facilitated the Company to meet eligibility for Migration from Innovators Growth Platform to Main Board 45. As stated earlier, Debock migrated to the main board of NSE in March 2022. As per the migration policy of NSE Innovators Growth Platform to NSE Main Board1,

1 NSE/SME/47077 Cir no 01/2021 dated January 21,2021 one of the eligibility criteria that needs to be complied with by companies moving to the main board is given below: “The paid-up equity capital of the applicant shall not be less than 10 crores and the capitalisation of the applicant's equity shall not be less than 25 crores” 46. It is noted from the financials of the Company that the equity share capital of Debock increased from Rs. 8.22 crore in FY21 to Rs. 23.22 crore in FY22. This increase was on account of the issue of 3,00,00,000 warrants and their subsequent conversion into equity shares as mentioned above. The conversion of 1,50,00,000 warrants to equity in February 2022 increased the paid-up equity capital to Rs.23.22 crore. This increase in paid-up equity share capital allowed the Company to be eligible for migration from the Innovators Growth Platform to the main board of NSE. 47. In view of the above, it appears that the fictitious issue of warrants and the subsequent conversion to equity shares facilitated the Company’s migration to the main board as Debock would have failed to satisfy the minimum paid-up capital criteria without the said issue.

Rights issue and Diversion of Proceeds to promoters/ entities associated with the directors: 48. Subsequent to the migration of the Company to the main Board of NSE, Debock vide draft letter of offer dated February 13, 2023, filed with NSE, proposed a rights issue of equity shares, The issue, which was completed in July 2023, raised Rs.49.50 crore. As per the objects of the issue, mentioned at page 50 of the draft letter of offer, the net proceeds from the issue were proposed to be utilised for: i. Meeting incremental working capital requirements; ii. General corporate purposes. 49. During the examination, the Company was asked to provide details of the utilization of proceeds from the rights issue. In response, the Company provided a copy of the ICICI bank statement highlighting payments made to Impex Agrotech Pvt. Ltd. (Impex Agro), as well as a copy of the Memorandum of Understanding (MOU) between Debock and Impex Agro. The MoU provided that: “Purpose: The purpose of this Memorandum of Understanding MOU is to establish a clear and mutually agreed framework under which Debock Industries Limited the “First Party” will provide financial assistance to Impex Agrotech Limited the “Second Party”.

Agreement to Extent Financial Assistance - The First Party agree to extend financial assistance to the Second Party in the amount of INR 40,36,53,000 India Rupees forty cores Thirty six lakh fifty three thousand only hereinafter referred to as the “Funds”. This financial assistance is provided to support the second Party’s operational, expansion, and financial stabilization activities.”

50. It is noted that Impex Agro is a related party of the Company and as per the related party disclosure to the exchange for the period April 01, 2023 to September 30, 2023, it was disclosed that the Company had loaned an amount of Rs. 49 crore to Impex Agro. Connection of Impex Agro with Debock 51. Impex Agro was incorporated on October 21, 2021 with its registered address at Yudhishtir Marg, Jaipur, Rajasthan. Impex Agro’s directors include Jyoti Choudhary (who served as an independent director of Debock until February 2020), Mukesh Manveer Singh as well as Gaurav Jain and Deepika Trivedi, who are directors in other Debock group companies. Mukesh Manveer Singh and Jyoti Choudhary held 50% each of the share capital of Impex Agro. Analysis of the fund trail of the amount transferred to Impex Agro 52. Debock had transferred an amount of Rs. 49.09 crore from its Rights issue allotment account with ICICI Bank bearing A/c No.405142297 to its ICICI Bank A/c bearing No.777705956180 on July 21, 2023. On July 24, 2023, within a span of 3 days, Debock transferred almost the entire rights issue proceeds (Rs. 49.00 crore) to Impex Agro. On analysis of Impex Agro’s the bank account statement with ICICI Bank bearing A/c No. 675905500964, it was observed that Impex Agro transferred the amount to entities depicted below after the Rs.49 crore was credited to its account:

The details of bank transactions are placed as Annexure C.

53. The connections between Mukesh Manveer Singh and Gaurav Jain is depicted below:

54. As illustrated above, out of the funds transferred by the Company to Impex Agro, Rs. 25.07 crore was transferred to Naturo Indiabull Limited and Rs.14 crore was credited to account of Priyanka Sharma (wife of Mukesh Manveer Singh). Additionally, Mukesh Manveer Singh and Gaurav Jain received Rs. 0.90 crore and Rs. 0.72 crore respectively. Jyoti Choudhary, a former independent director, also received Rs. 0.30 crore in this process. 55. The connection between Debock and the ultimate beneficiaries of the proceeds of the rights issue is depicted below

Qualification by statutory auditor 56. The statutory auditor in the limited review report for the quarter ended December 31, 2023 stated that the Company failed to provide details of the utilisation of funds from the rights issue and had not disclosed the same in financial statements. 57. From the foregoing, it prima facie appears that the issue proceeds were siphoned off to the promoters or entities associated with promoters, the present or past directors of group companies and it was not utilized as provided in the draft offer letter.

Preferential allotment (2) – (2023) 58. Following the rights issue, the Company undertook another issue of convertible warrants on November 30, 2023 totalling 5,35,71,428 warrants, at a price of Rs. 14 per warrant. These warrants were subsequently converted into 5,35,71,428 equity shares on February 7, 2024, bringing in another Rs.74.99 crore into the Company. 59. The details of the allottees and the number of warrants/shares allotted along with the amount involved in these transactions are as follows: Sr. Name of Category No. of Conversion Amount No. the warrants 07/02/2024 (Rs.) Allottee allotted (No. of (30/11/2023) shares) 1. Harish Non - 73,23,125 73,23,125 10,25,23,750 Kumar Promoter Sharma 2. Rajesh Non - 73,23,125 73,23,125 10,25,23,750 Kumar Promoter Vishwas 3. Chetna Non - 73,23,125 73,23,125 10,25,23,750 Promoter 4. Kadir Kha Non - 1,13,91,528 1,13,91,528 15,94,81,392 Promoter 5. Mahaveer Non - 97,64,166 97,64,166 13,66,98,324 Prasad Promoter Panchal 6. B Pavan Non - 71,91,637 71,91,637 10,06,82,918 Kumar Promoter Sharma 7. Avance Non - 32,54,722 32,54,722 4,55,66,108 Ventures Promoter Private Limited TOTAL 5,35,71,428 5,35,71,428 74,99,99,992

60. During examination, the Company was asked to provide details of the bank account where the proceeds from the allotment were credited and also details of end-use of these funds. The Company stated that the application money from the preferential allotment (25% of the total consideration) and the amount from the conversion of warrants (75% of the total consideration) were deposited on November 2, 2023 and November 30, 2023 respectively into its ICICI Bank bearing A/c No. 21020030160622. The Company also provided a copy of the bank statement to support these claims. 61. However, given past conduct of the Company, SEBI independently obtained the bank statements from ICICI Bank. Upon examining information submitted by ICICI Bank, it was found that the supposed transactions showing receipt of funds from the allottees in the second preferential allotment were non-existant, confirming that DIL had once again resorted to submitting forged documents to SEBI. 62. In the limited review report for the quarter ended December 31, 2023, the statutory auditor of the Company, Mittal & Associates, noted that even though Debock reported receipt of Rs. 75.04 crore from the issuance of warrants, it had failed to provide details in respect of receipt or the utilization of the said funds. 63. Given the above, it appears that no funds were actually received by the Company from the preferential issue. Therefore, the Company’s claims regarding the utilization of these funds were untrue and the financial statements for the relevant period appear to have been misstated.

Summary of Mis-statement in Financials on account of above mentioned corporate actions 64. The details of the mis-statements noted in the financial statements of the Company on account of the prima facie finding recorded in this Order are discussed in the Table below: (Amt. in Rs. Cr.) Date Corporate No. of Increase Increase Utilisation/ Action shares in share in comments capital securities Premium (30/09/2021 Preferential 3.00 30.00 7.5 Rs. 36.60 Crore to allotment (fictitious advances (3 *10) (3 * 2.5) 25/04/2022) (1) given for land purchase, no land purchased). The Company submitted forged bank statements to show receipt of funds as application money and utilization of issue proceeds in the preferential issue, indicating the transactions are fictitious. 01/11/2022 Bonus 3.82 38.22 NA The bonus shares Issue were issued from reserves generated out of inflated profit generated out of fictitious sales and purchases. Share Premium generated fictitiously in the first preferential issue. 04/07/2023 Rights 3.27 32.7 16.35 Rs. 49.05 crore (Loan Issue given to related party, (3.27 *10) (3.27 *5) which was partly diverted to promoter /connected entities and Naturo Indiabulls Limited) (30/11/2023 Preferential 5.35 53.5 21.4 Rs. 75.03 (shown as to allotment (5.35 *10) (5.35 *4) loans given to related 07/02/2024) (2) parties/connected entities). The Company submitted forged bank statements to show receipt of funds as application money in the preferential issue.

65. The prima facie findings recorded in this Order holds that the Company and its Managing director (Mukesh Manveer Singh) and promoter (Sunil Kalot), and the allottees have violated the provisions of section 12A(a), (b) and (c) of the SEBI Act, 1992 and regulations 3(a), (b), (c) (d), 4(1) and 4(2)(f) of the SEBI (Prohibition of Fraudulent and Unfair Trade Practices) Regulations, 2003 and regulations 4(1) and 33 of SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015 read with section 27 of the SEBI Act, 1992.

Calculation of gains to promoters on reduction of promoter shareholding Share capital history of the Company Particulars Date Shares Shares issued held by by DIL Promoters No. of shares as on 30/09/2021 53,25,424 82,20,000 Add- Preferential issue allotments 1st Tranche 10/02/2022 66,18,000 1,50,00,000 Add-Preferential issue allotments 2nd Tranche 25/04/2022 73,82,000 1,50,00,000 Add-Bonus Issue 01/11/2022 1,40,12,600 3,82,20,000 Add-Rights Issue 04/07/2023 0 3,27,24,687 Up to Jan 2,48,48,000 Add-Promoter purchases 2024 * - Up to Jan 4,28,73,024 Less-Promoter sales 2024 * - Add-Preferential Issue 5.34 crore warrants -conversion 07/02/2024 0 5,35,71,428 March 31, Total No. of shares 2024 1,53,13,000 16,27,36,115 * includes inter-se off-market transfers between promoters (from Raju Ajmera to Sunil Kalot) of 7,48,000 shares.

Change in promoter shareholding from September 2021 to March 2024. 66. As already noted in this Order, the promoter shareholding in the Company reduced from 64.79% in September 2021 to 9.41 % in March 2024. It was, however, found that even during this period Sunil Kalot was accumulating shares through off-market transactions from allottees of Preferential Allotment-I without payment of consideration. The details of such purchases are given in the Table below: Date Purchasing Seller Type of No. of shares promoter seller received Off market 01/05/2023 Sunil Kalot Sheetal Jain Preferential 4,64,000 04/05/2023 Sunil Kalot Ajay Dahiya allottee, who 10,00,000 04/05/2023 Sunil Kalot Rahul Khurana received 9,60,000 shares 25/05/2023 Sunil Kalot Sheetal Jain 18,64,000 without 25/05/2023 Sunil Kalot Sheetal Jain 72,000 consideration 25/05/2023 Sunil Kalot Ajay Dahiya 24,00,000 25/05/2023 Sunil Kalot Rahul Khurana 19,40,000

12/06/2023 Sunil Kalot Raju Ajmera 7,48,000 (promoter) 16/06/2023 Sunil Kalot Najiya Bano 74,00,000 16/06/2023 Sunil Kalot Abhishek 40,00,000 Khandelwal 17/06/2023 Sunil Kalot Abhishek 40,00,000 Khandelwal Total No. of 2,48,48,000 Shares Market sale by the promoters: 67. It was found from the data obtained from the stock exchange, depositories and respective stock brokers that Sunil Kalot and Mukesh Manveer Singh had sold 3,73,99,300 shares of Debock from October 2021 to January 2024. The sale of shares by promoters (on market) and their credit to respective bank accounts is summarized below: Promoter Quantity Sale Value Amount Credited to sold (Rs.) Bank account (Rs.) Sunil Kalot 2,53,35,200 38,97,96,580 38,82,55,833 Mukesh Manveer Singh 1,20,64,100 12,75,61,825 12,67,59,052 Total 3,73,99,300 51,73,58,405 51,50,14,885

The details of the market transactions undertaken by the Promoters is placed as Annexure D. 68. The aforesaid promoters of the Company sold ~3.74 crore shares in the market at a total sale value of ~Rs. 51.73 crore (based on the transaction value in the trade log). Of this amount, at least Rs.51.50 crore was ultimately credited to the respective bank accounts of the promoters.

Off-market transfers by promoters 69. It is seen that the promoters had also transferred shares through off-market transactions during the period September 30, 2021 to March 31, 2024. The details are as follows:

Selling Date Nature of Buyer Quantity Closing Sale Value Promoter transaction market (Rs.) # price (Rs.) Mukesh Manveer 23/04/2 Off Market Gaurav 10,00,000 127 12,70,00,000 Singh 022 Transfer Jain Mukesh Manveer 23/04/2 Off Market Gaurav 10,00,000 127 12,70,00,000 Singh 022 Transfer Jain Mukesh Manveer 23/09/2 Confiscation Gaurav 27,48,024 31.6 8,68,37,558 Singh 022 Jain Mukesh Manveer Singh TOTAL 47,48,024 34,08,37,558

Raju Ajmera 12/06/2 Off Market Sunil 7,48,000 16.75 1,25,29,000 023 Transfer Kalot # For the purpose of calculating sale value, the closing market price on the day of off market sale by promoter is considered.

Calculation of gains on sale of shares by promoters 70. The prospectus filed at the time of the Initial Public Offer (IPO) by Debock stated that Mukesh Manveer Singh held 48,07,624 shares in the Company, acquired at an average price of Rs.26.93. This translates to a total investment of Rs.12.94 crore. Further, as noted earlier, he was allotted shares vide preferential allotments undertaken by the Company at NIL value through the circuitous transactions. The acquisition cost of the shares held by Mukesh Manveer Singh is given in the Table below: Particulars No. of Average Price- Total Value (Amt. shares cost (Amt. in Rs.) in Rs.) No of shares held at the 48,07624 26.93 12,94,69,314 time of IPO Allotment of Shares – 1st 44,92,000 0 0 pref. Allotment of shares – 2nd 39,07,900 0 0 pref. Bonus Shares 1,05,00,000 0 0 Total shares 2,37,07,524 0 0 Average cost of shares 5.4611 (12,94,69,314 / 2,37,07,524)

71. The cost of shares sold by Mukesh Manveer Singh: Particulars No. of shares Cost per share Total Cost (Rs.) On market 1,20,64,100 6,58,83,257 Off market and 47,48,024 5.4611 2,59,29,434 Confiscation Total shares 1,68,12,124 9,18,12,690 sold

72. The total cost of acquisition of 1,68,12,124 shares sold (off-market and on-market) by Mukesh Manveer Singh is worked out to Rs. 9,18,12,690/-. Calculation of gains made by Mr. Mukesh Manveer Singh Particulars No. of shares Total Value (Rs.) On market(A) 1,20,64,100 12,67,59,052 Off market and Confiscation (B) 47,48,024 34,08,37,558 # Total 1,68,12,124 46,75,96,610 Cost of shares sold (C) 9,18,12,690 Total Gains of Mr. Mukesh 37,57,83,920 Manveer Singh (A+B-C) # For the purpose of calculating sale value, the closing market price on the day of off market sale by promoter is considered, as the off market as well as pledge, confiscation are with Gaurav Jain, who is connected to the promoter as shown in chart above. The average purchase price and value of shares held by Sunil Kalot is as follows: Particulars No. of Average Price-cost Total Value shares (Amt. in Rs.) (Rs.) No of shares held at the time of 4,88,025 26.93 1,31,42,513 IPO Allotment of Shares – 1st pref. 0 0 0 Allotment of shares – 2nd pref. 0 0 0 Bonus Shares 825 0 0 Purchased from off-market 2,48,48,000 0 0 Total shares 2,53,36,850 Average cost of shares 0.5187 (1,31,42,513/2,53,36,850) Calculation of gains made by Sunil Kalot Particulars No. of shares Total (Rs.) Total shares sold - On market sale of shares (A) 2,53,35,200 38,97,96,580 Cost of shares sold (B) 1,31,41,368 (2,53,35,200*0.5187) Total Gains of Mr. Sunil Kalot (B-A) 37,66,55,212

Summary of Gains made by the promoters Name of Off market Market sale Total Sale Cost Price Profit the sale value value Value (Amt. (Amt. in Rs) (Amt. in Rs) promoter in Rs) Mukesh Manveer 34,08,37,558 12,67,59,052 46,75,96,610 9,18,12,690 37,57,83,920 Singh Sunil Kalot - 38,97,96,580 38,97,96,580 1,31,41,368 37,66,55,212 TOTAL 34,08,37,558 51,77,58,932 85,85,96,490 10,53,94,731 75,32,01,759

Need for Interim Ex-Parte Directions 73. The prima facie findings recorded in this Order reveal a disturbing pattern of financial misrepresentation, misutilization of funds and the Company resorting to forgery to cover up its actions. As many of these practises are still ongoing, there is an urgent need for regulatory intervention. Prima facie findings in this respect are summarized below: (a) Migration to the Main Board through Fictitious Preferential Issues: The Company appears to have met the eligibility criteria for migration to the main board through fictitious issue of warrants and their subsequent conversion to equity. This was achieved without the actual receipt of consideration as evidenced by the rotation of Rs. 30 lakh in a circuitous manner to falsely reflect receipt of Rs.8.28 crore in application money in September 2021. Additionally, even the allotment of shares pursuant to conversion of these warrants was made without receipt of consideration which amounted to Rs.28.12 crore. This led to the artificial inflation of share capital and capital advances for purchase of assets on the balance sheet of DIL for FY22 and FY23, a misrepresentation that continues as on date. (b) Inflation of Sales and Purchases: The Company appears to have inflated its sales by approximately 72% in FY22 and 77% in FY23, alongside inflating its purchases by approximately 94% during both these financial years. These actions were carried out through circuitous transactions to present a positive picture relating to activities in the Company to investors. It is, prima facie, found that this practice that appears to be ongoing as per the transactions reflected in the recent bank statements of the Company.

(c) Submission of False Bank Statements: The Company submitted fabricated bank statements to SEBI to conceal the fictitious preferential issues and the inflated sales and purchases. (d) Diversion of Rights Issue Proceeds: Following its migration to the main board of NSE, the Company raised Rs.49.50 crore through a rights issue in June 2023. These funds appear to have been diverted to the promoters and related entities rather than being used for legitimate business purposes. (e) Auditor's Qualifications on Subsequent Preferential Issues: The audit qualifications regarding the subsequent preferential issue of warrants on November 30, 2023 and their conversion on February 7, 2024, raise serious concerns that Company is repeatedly engaging in fraudulent practises. 74. The promoters have not only resorted to offloading their holding to unsuspecting investors in the open market but also appear to have siphoned off the proceeds of the rights issue. Out of the rights issue proceeds, Rs. 14 crore was transferred to the accounts of Priyanka Sharma, the wife of Mukesh Manveer Singh. The remaining amount was transferred to other connected entities as brought out in this Order. It is, therefore, necessary to direct the Company and Mukesh Manveer Singh to take steps to bring back this amount. 75. Direction also need to be issued to impound the proceeds of prima facie unlawful gains made by the Noticees. The unlawful gains prima facie noted to have been made by the individual Noticees is given in the Table below:

Sl. No. Noticee Name Amount (Rs.) Mukesh Manveer Singh 1. 37,57,83,920 Sunil Kalot 2. 37,66,55,212

3. Priyanka Sharma 14,00,00,000

Total 89,24,39,132

76. It is further noted the Board of Directors of Company at its meeting held on June 28, 2024 had approved a scheme to amalgamate Debock Ventures Limited with Debock Industries Limited, leading to further increase in the share capital of the Company. This potentially presents further opportunities for the promoters to offload shares to unsuspecting investors in the open market. Given the same, there is an urgent need to intervene in the matter pending completion of the investigation initiated by SEBI.

Conclusion 77. The actions of the Company, prima facie, reveal a brazen and calculated effort to defraud investors and deceive regulatory authorities. The case, based on material placed before me, does not appear to be a run of the mill case. The promoters have clearly indulged in siphoning of funds from the Company. It also appears that the very purpose behind listing this Company was to defraud investors and make huge gains for personal benefit. 78. The preferential allotment, which was used to justify the Company’s migration to the main board, stands exposed as nothing more than a hollow pretence. Once allotted, the shares were quietly transferred off-market to the promoters, who then offloaded them onto unsuspecting shareholders. As noted earlier in this Order, during the period FY21 to FY24, the promoter shareholding came down from 64.79% to 9.41% whereas the public shareholding went up from 35.21% to 90.56%. The Company, which only had 171 public shareholders as of March 31, 2021, had 53,389 shareholders by March 31, 2024. 79. Even more alarming is the fact that once the Company migrated to the main board of NSE, it came out with a rights issue where the promoters did not participate and the entire proceeds from the rights issue — funds that should have been used for legitimate business purposes — have been siphoned off by the promoters and their associates.

This rights issue was followed by another preferential allotment. The Company appears to have not received the proceeds of this issue also. A repeated pattern can, therefore, be observed where the Company was coming out with back-to-back issuances, which cumulatively should have raised close to Rs. 162 crore, all of which, at this stage appear, to have vanished. It is further noted that the Board of the Company has now granted approval for amalgamation of Debock Ventures Limited with Debock Industries Limited and the timing of this event could not have been more serendipitous. 80. To top it all, majority of the Company's reported sales and purchases are fictitious. Many of these transactions were mere book entries, which had been conjured up to inflate the balance sheet. The financials of the Company, I am constrained to note, is a work of fiction. 81. The entire edifice, the whole enterprise and every action of this Company appear to have been geared towards defrauding investors. The submission of forged bank statements to SEBI underscores a level of audacity that is as shocking as it is unacceptable.

The Company has not only flouted the law but has done so with the apparent belief that it could operate above it. 82. This blatant masquerade of potential deception and fraud casts a shadow on the reputation of every honest Company that strives to uphold the principles of integrity and transparency in our markets. Such apparent brazen manipulation is nothing short of a betrayal of investor trust—a situation that demands swift and uncompromising action. 83. At the same time, retail investors need to exercise certain level of due diligence while investing in such companies and not be swayed by seemingly attractive returns that may quickly come their way. In other words, investors need to be realistic and responsible about their return expectations. Order: 84. Keeping in view the foregoing, I, in exercise of the powers conferred upon me under sections 11, 11(4) and 11B (1) read with section 19 of the SEBI Act, 1992, hereby issue by way of this interim order the following directions, which shall be in force until further orders: - a) Noticee 2 is restrained from holding the position of a director or a Key Managerial Personnel in any listed company, other than Debock, or any SEBI registered intermediary until further orders. b) Noticees 1 to 4 are restrained from buying, selling or dealing in securities, or accessing capital market either directly or indirectly, in any manner whatsoever until further orders.

If the said Noticees have any open position in any exchange-traded derivative contracts, as on the date of the order, they can close out /square off such open positions within 3 months from the date of order or at the expiry of such contracts, whichever is earlier. The said Noticees are permitted to settle the pay-in and pay-out obligations in respect of transactions, if any, which have taken place before the close of trading on the date of this order. c) An amount of Rs. 89,24,39,132 being the alleged total unlawful gain earned from the alleged fraudulent activities carried out by the Noticees 2, 3 and 4 is impounded. The individual liabilities of the respective Noticees is provided in the Table at paragraph 75. d) Noticees 2, 3 and 4 are directed to credit/deposit amount of unlawful gains as mentioned in the Table provided at paragraph 75 to an interest bearing Escrow Account created specifically for the purpose in a Nationalized Bank within 15 days from the date of service of this order. The above Noticees shall create Escrow Account(s) with Lien in favour of SEBI and the amount kept therein shall not be released without permission from SEBI. e) Noticee 1 and 2 are directed to bring back the complete rights issue funds, other than the amount directed to be impounded by Noticee 4 vide this Order, to the Company. f) Banks where the Noticees 2, 3 and 4 are holding bank accounts, including joint accounts, are directed that no debits shall be made without permission of SEBI except for the purposes of transfer of funds to the Escrow Account.

Further, the Depositories are also directed that no debit shall be made, without permission of SEBI, in respect of the demat accounts held by the aforesaid persons. However, credits, if any, into the accounts maybe allowed. Banks and the Depositories are directed to ensure that all the aforesaid directions are strictly enforced. Further, debits in the bank accounts may be allowed for amounts available in the account in excess of the amount to be impounded. Banks are allowed to debit the accounts for the purpose of complying with this Order. g) Noticees 2, 3 and 4 are directed not to dispose of or alienate any of their assets/properties/securities, till such time the amount of unlawful gain is credited to an Escrow Account except with the prior permission of SEBI.

h) Noticees 2, 3 and 4 are further directed to provide a full inventory of all their assets whether movable or immovable, or any interest or investment or charge in any of such assets, including property, details of all their bank accounts, demat accounts, holdings of shares/securities if held in physical form and mutual fund investments and details of companies in which they hold substantial or controlling interest immediately but not later than 15 working days from the date of service of this order. 85. NSE is directed to not grant approval for the scheme to amalgamation between Debock Ventures Limited with Debock Industries Limited till further orders. 86. SEBI is directed to initiate prosecution proceedings against Noticees 1, 2 and 3, as may be provided under law. 87. The Depositories are directed to ensure that till further directions, no credits or debits are made in the demat accounts of Noticees, held individually or jointly. 88. The Registrar and Transfer Agents are also directed to ensure that till further directions, the securities/mutual funds units held in the name of the Noticees 2, 3 and 4, individually or jointly, are not transferred/redeemed. 89. The foregoing prima facie observations contained in this Order are made on the basis of the material available on record. The concerned Noticees may, within 21 days from the date of receipt of this Order, file their reply/objections, if any, to this Order and may also indicate whether they desire to avail an opportunity of personal hearing on a date and time to be fixed in that regard. 90. The above directions shall take effect immediately and shall be in force until further orders. 91. A copy of this order shall be served upon the Noticees, Stock Exchanges, Registrar and Transfer Agents and Depositories for necessary action and compliance with the above directions.

DATE: AUGUST 23, 2024 ASHWANI BHATIA PLACE: MUMBAI WHOLE TIME MEMBER SECURITIES AND EXCHANGE BOARD OF INDIA

Annexure A Date From From From To To To Am entity Bank Bank entit Bank Bank oun accou y accou t nt No nt No (Rs. In Cr) 07/09/ DEBOC Adarsh 46014 SUNI Adarsh 46010 0.30 2021 K Co- 10000 L Co- 10000 SALES operativ 0560 KUM operativ 1794 AND e Bank AR e Bank MARKE Ltd KAL Ltd TING OT LIMITE D 07/09/ DEBOC Adarsh 46014 SUNI Adarsh 46010 0.30 2021 K Co- 10000 L Co- 10000 SALES operativ 0560 KUM operativ 1794 AND e Bank AR e Bank MARKE Ltd KAL Ltd TING OT LIMITE D 07/09/ DEBOC Adarsh 46014 SUNI Adarsh 46010 0.30 2021 K Co- 10000 L Co- 10000 SALES operativ 0560 KUM operativ 1794 AND e Bank AR e Bank MARKE Ltd KAL Ltd TING OT LIMITE D 07/09/ DEBOC Adarsh 46014 SUNI Adarsh 46010 0.30 2021 K Co- 10000 L Co- 10000 SALES operativ 0560 KUM operativ 1794 AND e Bank AR e Bank MARKE Ltd KAL Ltd TING OT LIMITE D 07/09/ DEBOC Adarsh 46014 SUNI Adarsh 46010 0.30 2021 K Co- 10000 L Co- 10000 SALES operativ 0560 KUM operativ 1794 AND e Bank AR e Bank MARKE Ltd KAL Ltd TING OT

Date From From From To To To Am entity Bank Bank entit Bank Bank oun accou y accou t nt No nt No (Rs. In Cr) LIMITE D 07/09/ DEBOC Adarsh 46014 SUNI Adarsh 46010 0.30 2021 K Co- 10000 L Co- 10000 SALES operativ 0560 KUM operativ 1794 AND e Bank AR e Bank MARKE Ltd KAL Ltd TING OT LIMITE D 07/09/ DEBOC Adarsh 46014 SUNI Adarsh 46010 0.30 2021 K Co- 10000 L Co- 10000 SALES operativ 0560 KUM operativ 1794 AND e Bank AR e Bank MARKE Ltd KAL Ltd TING OT LIMITE D 07/09/ DEBOC Adarsh 46014 SUNI Adarsh 46010 0.30 2021 K Co- 10000 L Co- 10000 SALES operativ 0560 KUM operativ 1794 AND e Bank AR e Bank MARKE Ltd KAL Ltd TING OT LIMITE D 07/09/ DEBOC Adarsh 46014 SUNI Adarsh 46010 0.30 2021 K Co- 10000 L Co- 10000 SALES operativ 0560 KUM operativ 1794 AND e Bank AR e Bank MARKE Ltd KAL Ltd TING OT LIMITE D 07/09/ DEBOC Adarsh 46014 SUNI Adarsh 46010 0.30 2021 K Co- 10000 L Co- 10000 SALES operativ 0560 KUM operativ 1794 AND e Bank AR e Bank MARKE Ltd KAL Ltd TING OT

Date From From From To To To Am entity Bank Bank entit Bank Bank oun accou y accou t nt No nt No (Rs. In Cr) LIMITE D 07/09/ DEBOC Adarsh 46014 SUNI Adarsh 46010 0.28 2021 K Co- 10000 L Co- 10000 SALES operativ 0560 KUM operativ 1794 AND e Bank AR e Bank MARKE Ltd KAL Ltd TING OT LIMITE D 07/09/ SUNIL Adarsh 46010 MUK Adarsh 46010 0.30 2021 KUMAR Co- 10000 ESH Co- 10000 KALOT operativ 1794 MAN operativ 1799 e Bank VEE e Bank Ltd R Ltd SING H 07/09/ SUNIL Adarsh 46010 MUK Adarsh 46010 0.30 2021 KUMAR Co- 10000 ESH Co- 10000 KALOT operativ 1794 MAN operativ 1799 e Bank VEE e Bank Ltd R Ltd SING H 07/09/ SUNIL Adarsh 46010 MUK Adarsh 46010 0.30 2021 KUMAR Co- 10000 ESH Co- 10000 KALOT operativ 1794 MAN operativ 1799 e Bank VEE e Bank Ltd R Ltd SING H 07/09/ SUNIL Adarsh 46010 MUK Adarsh 46010 0.30 2021 KUMAR Co- 10000 ESH Co- 10000 KALOT operativ 1794 MAN operativ 1799 e Bank VEE e Bank Ltd R Ltd SING H

Date From From From To To To Am entity Bank Bank entit Bank Bank oun accou y accou t nt No nt No (Rs. In Cr) 07/09/ SUNIL Adarsh 46010 MUK Adarsh 46010 0.30 2021 KUMAR Co- 10000 ESH Co- 10000 KALOT operativ 1794 MAN operativ 1799 e Bank VEE e Bank Ltd R Ltd SING H 07/09/ SUNIL Adarsh 46010 MUK Adarsh 46010 0.30 2021 KUMAR Co- 10000 ESH Co- 10000 KALOT operativ 1794 MAN operativ 1799 e Bank VEE e Bank Ltd R Ltd SING H 07/09/ SUNIL Adarsh 46010 MUK Adarsh 46010 0.30 2021 KUMAR Co- 10000 ESH Co- 10000 KALOT operativ 1794 MAN operativ 1799 e Bank VEE e Bank Ltd R Ltd SING H 07/09/ SUNIL Adarsh 46010 MUK Adarsh 46010 0.30 2021 KUMAR Co- 10000 ESH Co- 10000 KALOT operativ 1794 MAN operativ 1799 e Bank VEE e Bank Ltd R Ltd SING H 07/09/ SUNIL Adarsh 46010 MUK Adarsh 46010 0.30 2021 KUMAR Co- 10000 ESH Co- 10000 KALOT operativ 1794 MAN operativ 1799 e Bank VEE e Bank Ltd R Ltd SING H 07/09/ SUNIL Adarsh 46010 MUK Adarsh 46010 0.30 2021 KUMAR Co- 10000 ESH Co- 10000 KALOT operativ 1794 MAN operativ 1799 e Bank VEE e Bank Ltd R Ltd

Date From From From To To To Am entity Bank Bank entit Bank Bank oun accou y accou t nt No nt No (Rs. In Cr) SING H 07/09/ SUNIL Adarsh 46010 MUK Adarsh 46010 0.30 2021 KUMAR Co- 10000 ESH Co- 10000 KALOT operativ 1794 MAN operativ 1799 e Bank VEE e Bank Ltd R Ltd SING H 07/09/ MUKES Adarsh 46010 DEB Adarsh 46014 0.30 2021 H Co- 10000 OCK Co- 10000 MANVE operativ 1799 SALE operativ 0560 ER e Bank S e Bank SINGH Ltd AND Ltd MAR KETI NG LIMIT ED 07/09/ MUKES Adarsh 46010 DEB Adarsh 46014 0.30 2021 H Co- 10000 OCK Co- 10000 MANVE operativ 1799 SALE operativ 0560 ER e Bank S e Bank SINGH Ltd AND Ltd MAR KETI NG LIMIT ED 07/09/ MUKES Adarsh 46010 DEB Adarsh 46014 0.30 2021 H Co- 10000 OCK Co- 10000 MANVE operativ 1799 SALE operativ 0560 ER e Bank S e Bank SINGH Ltd AND Ltd MAR KETI NG LIMIT ED

Date From From From To To To Am entity Bank Bank entit Bank Bank oun accou y accou t nt No nt No (Rs. In Cr) 07/09/ MUKES Adarsh 46010 DEB Adarsh 46014 0.30 2021 H Co- 10000 OCK Co- 10000 MANVE operativ 1799 SALE operativ 0560 ER e Bank S e Bank SINGH Ltd AND Ltd MAR KETI NG LIMIT ED 07/09/ MUKES Adarsh 46010 DEB Adarsh 46014 0.30 2021 H Co- 10000 OCK Co- 10000 MANVE operativ 1799 SALE operativ 0560 ER e Bank S e Bank SINGH Ltd AND Ltd MAR KETI NG LIMIT ED 07/09/ MUKES Adarsh 46010 DEB Adarsh 46014 0.30 2021 H Co- 10000 OCK Co- 10000 MANVE operativ 1799 SALE operativ 0560 ER e Bank S e Bank SINGH Ltd AND Ltd MAR KETI NG LIMIT ED 07/09/ MUKES Adarsh 46010 DEB Adarsh 46014 0.30 2021 H Co- 10000 OCK Co- 10000 MANVE operativ 1799 SALE operativ 0560 ER e Bank S e Bank SINGH Ltd AND Ltd MAR KETI NG LIMIT ED

Date From From From To To To Am entity Bank Bank entit Bank Bank oun accou y accou t nt No nt No (Rs. In Cr) 07/09/ MUKES Adarsh 46010 DEB Adarsh 46014 0.30 2021 H Co- 10000 OCK Co- 10000 MANVE operativ 1799 SALE operativ 0560 ER e Bank S e Bank SINGH Ltd AND Ltd MAR KETI NG LIMIT ED 07/09/ MUKES Adarsh 46010 DEB Adarsh 46014 0.30 2021 H Co- 10000 OCK Co- 10000 MANVE operativ 1799 SALE operativ 0560 ER e Bank S e Bank SINGH Ltd AND Ltd MAR KETI NG LIMIT ED 07/09/ MUKES Adarsh 46010 DEB Adarsh 46014 0.30 2021 H Co- 10000 OCK Co- 10000 MANVE operativ 1799 SALE operativ 0560 ER e Bank S e Bank SINGH Ltd AND Ltd MAR KETI NG LIMIT ED 07/09/ MUKES Adarsh 46010 DEB Adarsh 46014 0.30 2021 H Co- 10000 OCK Co- 10000 MANVE operativ 1799 SALE operativ 0560 ER e Bank S e Bank SINGH Ltd AND Ltd MAR KETI NG LIMIT ED

Annexure B Circuitous payment of application money by Abhishek Khandelwal is diagrammatically shown below:

The details of bank transactions Date From From From To To To Amount entity Bank Bank entity Bank Bank (Rs. In acco accou Cr.) unt nt No No 07/09 DEBOC Adarsh 4601 SUNIL Adarsh 46010 0.28 /2021 K Co- 4100 KUMA Co- 10000 SALES operativ 0005 R operativ 1794 AND e Bank 60 KALO e Bank MARKE Ltd T Ltd TING LIMITE D 07/09 DEBOC Adarsh 4601 SUNIL Adarsh 46010 0.29 /2021 K Co- 4100 KUMA Co- 10000 SALES operativ 0005 R operativ 1794 AND e Bank 60 KALO e Bank MARKE Ltd T Ltd TING LIMITE D

Date From From From To To To Amount entity Bank Bank entity Bank Bank (Rs. In acco accou Cr.) unt nt No No 07/09 DEBOC Adarsh 4601 SUNIL Adarsh 46010 0.25 /2021 K Co- 4100 KUMA Co- 10000 SALES operativ 0005 R operativ 1794 AND e Bank 60 KALO e Bank MARKE Ltd T Ltd TING LIMITE D 07/09 DEBOC Adarsh 4601 SUNIL Adarsh 46010 0.27 /2021 K Co- 4100 KUMA Co- 10000 SALES operativ 0005 R operativ 1794 AND e Bank 60 KALO e Bank MARKE Ltd T Ltd TING LIMITE D 07/09 DEBOC Adarsh 4601 SUNIL Adarsh 46010 0.16 /2021 K Co- 4100 KUMA Co- 10000 SALES operativ 0005 R operativ 1794 AND e Bank 60 KALO e Bank MARKE Ltd T Ltd TING LIMITE D 07/09 SUNIL Adarsh 4601 ABHIS Adarsh 46010 0.28 /2021 KUMAR Co- 0100 HEK Co- 10000 KALOT operativ 0017 KHAN operativ 1800 e Bank 94 DELW e Bank Ltd AL Ltd 07/09 SUNIL Adarsh 4601 ABHIS Adarsh 46010 0.29 /2021 KUMAR Co- 0100 HEK Co- 10000 KALOT operativ 0017 KHAN operativ 1800 e Bank 94 DELW e Bank Ltd AL Ltd 07/09 SUNIL Adarsh 4601 ABHIS Adarsh 46010 0.25 /2021 KUMAR Co- 0100 HEK Co- 10000 KALOT operativ 0017 KHAN operativ 1800 e Bank 94 DELW e Bank Ltd AL Ltd

Date From From From To To To Amount entity Bank Bank entity Bank Bank (Rs. In acco accou Cr.) unt nt No No 07/09 SUNIL Adarsh 4601 ABHIS Adarsh 46010 0.27 /2021 KUMAR Co- 0100 HEK Co- 10000 KALOT operativ 0017 KHAN operativ 1800 e Bank 94 DELW e Bank Ltd AL Ltd 07/09 SUNIL Adarsh 4601 ABHIS Adarsh 46010 0.16 /2021 KUMAR Co- 0100 HEK Co- 10000 KALOT operativ 0017 KHAN operativ 1800 e Bank 94 DELW e Bank Ltd AL Ltd 07/09 ABHISH Adarsh 4601 DEBO Adarsh 46014 0.28 /2021 EK Co- 0100 CK Co- 10000 KHAND operativ 0018 SALES operativ 0560 ELWAL e Bank 00 AND e Bank Ltd MARK Ltd ETING LIMITE D 07/09 ABHISH Adarsh 4601 DEBO Adarsh 46014 0.29 /2021 EK Co- 0100 CK Co- 10000 KHAND operativ 0018 SALES operativ 0560 ELWAL e Bank 00 AND e Bank Ltd MARK Ltd ETING LIMITE D 07/09 ABHISH Adarsh 4601 DEBO Adarsh 46014 0.25 /2021 EK Co- 0100 CK Co- 10000 KHAND operativ 0018 SALES operativ 0560 ELWAL e Bank 00 AND e Bank Ltd MARK Ltd ETING LIMITE D 07/09 ABHISH Adarsh 4601 DEBO Adarsh 46014 0.27 /2021 EK Co- 0100 CK Co- 10000 KHAND operativ 0018 SALES operativ 0560 ELWAL e Bank 00 AND e Bank Ltd MARK Ltd ETING

Date From From From To To To Amount entity Bank Bank entity Bank Bank (Rs. In acco accou Cr.) unt nt No No LIMITE D 07/09 ABHISH Adarsh 4601 DEBO Adarsh 46014 0.16 /2021 EK Co- 0100 CK Co- 10000 KHAND operativ 0018 SALES operativ 0560 ELWAL e Bank 00 AND e Bank Ltd MARK Ltd ETING LIMITE D

Circuitous payment of application money by Najiya Bano is diagrammatically shown below:

The details of bank transactions Dat From From From To entity To To Am e entity Bank Bank Bank Bank oun acco accou t unt nt No (Am No t in Rs.) 07/0 DEBOCK Adarsh 4601 SUNIL Adarsh 46010 0.29 9/20 SALES Co- 4100 KUMAR Co- 10000 21 AND operati KALOT operativ 1794

Dat From From From To entity To To Am e entity Bank Bank Bank Bank oun acco accou t unt nt No (Am No t in Rs.) MARKET ve 0005 e Bank ING Bank 60 Ltd LIMITED Ltd 07/0 DEBOCK Adarsh 4601 SUNIL Adarsh 46010 0.28 9/20 SALES Co- 4100 KUMAR Co- 10000 21 AND operati 0005 KALOT operativ 1794 MARKET ve 60 e Bank ING Bank Ltd LIMITED Ltd 07/0 DEBOCK Adarsh 4601 SUNIL Adarsh 46010 0.27 9/20 SALES Co- 4100 KUMAR Co- 10000 21 AND operati 0005 KALOT operativ 1794 MARKET ve 60 e Bank ING Bank Ltd LIMITED Ltd 07/0 DEBOCK Adarsh 4601 SUNIL Adarsh 46010 0.25 9/20 SALES Co- 4100 KUMAR Co- 10000 21 AND operati 0005 KALOT operativ 1794 MARKET ve 60 e Bank ING Bank Ltd LIMITED Ltd 07/0 DEBOCK Adarsh 4601 SUNIL Adarsh 46010 0.06 9/20 SALES Co- 4100 KUMAR Co- 10000 21 AND operati 0005 KALOT operativ 1794 MARKET ve 60 e Bank ING Bank Ltd LIMITED Ltd 07/0 SUNIL Adarsh 4601 NAJIYA Adarsh 46010 0.29 9/20 KUMAR Co- 0100 BANO Co- 10000 21 KALOT operati 0017 operativ 1798 ve 94 e Bank Bank Ltd Ltd 07/0 SUNIL Adarsh 4601 NAJIYA Adarsh 46010 0.28 9/20 KUMAR Co- 0100 BANO Co- 10000 21 KALOT operati 0017 operativ 1798 ve 94 e Bank Bank Ltd Ltd

Dat From From From To entity To To Am e entity Bank Bank Bank Bank oun acco accou t unt nt No (Am No t in Rs.) 07/0 SUNIL Adarsh 4601 NAJIYA Adarsh 46010 0.27 9/20 KUMAR Co- 0100 BANO Co- 10000 21 KALOT operati 0017 operativ 1798 ve 94 e Bank Bank Ltd Ltd 07/0 SUNIL Adarsh 4601 NAJIYA Adarsh 46010 0.25 9/20 KUMAR Co- 0100 BANO Co- 10000 21 KALOT operati 0017 operativ 1798 ve 94 e Bank Bank Ltd Ltd 07/0 SUNIL Adarsh 4601 NAJIYA Adarsh 46010 0.06 9/20 KUMAR Co- 0100 BANO Co- 10000 21 KALOT operati 0017 operativ 1798 ve 94 e Bank Bank Ltd Ltd 07/0 NAJIYA Adarsh 4601 DEBOCK Adarsh 46014 0.29 9/20 BANO Co- 0100 SALES Co- 10000 21 operati 0017 AND operativ 0560 ve 98 MARKET e Bank Bank ING Ltd Ltd LIMITED 07/0 NAJIYA Adarsh 4601 DEBOCK Adarsh 46014 0.28 9/20 BANO Co- 0100 SALES Co- 10000 21 operati 0017 AND operativ 0560 ve 98 MARKET e Bank Bank ING Ltd Ltd LIMITED 07/0 NAJIYA Adarsh 4601 DEBOCK Adarsh 46014 0.27 9/20 BANO Co- 0100 SALES Co- 10000 21 operati 0017 AND operativ 0560 ve 98 MARKET e Bank Bank ING Ltd Ltd LIMITED 07/0 NAJIYA Adarsh 4601 DEBOCK Adarsh 46014 0.25 9/20 BANO Co- 0100 SALES Co- 10000 21 operati 0017 AND operativ 0560 ve 98 MARKET

Dat From From From To entity To To Am e entity Bank Bank Bank Bank oun acco accou t unt nt No (Am No t in Rs.) Bank ING e Bank Ltd LIMITED Ltd 07/0 NAJIYA Adarsh 4601 DEBOCK Adarsh 46014 0.06 9/20 BANO Co- 0100 SALES Co- 10000 21 operati 0017 AND operativ 0560 ve 98 MARKET e Bank Bank ING Ltd Ltd LIMITED

Circuitous payment of application money by Bharu Ram is diagrammatically shown below:

The details of bank transactions

Date From From From To To To Amo entity Bank Bank entity Bank Bank unt accoun accou (Amt t No nt No in Rs.) 07/09 DEBOCK Adarsh 460141 SUNIL Adarsh 46010 0.24 /2021 SALES Co- 000005 KUMA Co- 10000 AND operative 60 R operativ 1794 MARKET Bank Ltd KALO e Bank T Ltd

ING LIMITED 07/09 DEBOCK Adarsh 460141 SUNIL Adarsh 46010 0.25 /2021 SALES Co- 000005 KUMA Co- 10000 AND operative 60 R operativ 1794 MARKET Bank Ltd KALO e Bank ING T Ltd LIMITED 07/09 DEBOCK Adarsh 460141 SUNIL Adarsh 46010 0.23 /2021 SALES Co- 000005 KUMA Co- 10000 AND operative 60 R operativ 1794 MARKET Bank Ltd KALO e Bank ING T Ltd LIMITED 07/09 DEBOCK Adarsh 460141 SUNIL Adarsh 46010 0.29 /2021 SALES Co- 000005 KUMA Co- 10000 AND operative 60 R operativ 1794 MARKET Bank Ltd KALO e Bank ING T Ltd LIMITED 07/09 DEBOCK Adarsh 460141 SUNIL Adarsh 46010 0.14 /2021 SALES Co- 000005 KUMA Co- 10000 AND operative 60 R operativ 1794 MARKET Bank Ltd KALO e Bank ING T Ltd LIMITED 07/09 SUNIL Adarsh 460101 Bharu Adarsh 46010 0.24 /2021 KUMAR Co- 000017 Ram Co- 10000 KALOT operative 94 operativ 1795 Bank Ltd e Bank Ltd 07/09 SUNIL Adarsh 460101 Bharu Adarsh 46010 0.25 /2021 KUMAR Co- 000017 Ram Co- 10000 KALOT operative 94 operativ 1795 Bank Ltd e Bank Ltd 07/09 SUNIL Adarsh 460101 Bharu Adarsh 46010 0.23 /2021 KUMAR Co- 000017 Ram Co- 10000 KALOT operative 94 operativ 1795 Bank Ltd e Bank Ltd 07/09 SUNIL Adarsh 460101 Bharu Adarsh 46010 0.29 /2021 KUMAR Co- 000017 Ram Co- 10000 KALOT operative 94 operativ 1795 Bank Ltd e Bank Ltd

07/09 SUNIL Adarsh 460101 Bharu Adarsh 46010 0.14 /2021 KUMAR Co- 000017 Ram Co- 10000 KALOT operative 94 operativ 1795 Bank Ltd e Bank Ltd 07/09 Bharu Adarsh 460101 DEBO Adarsh 46014 0.24 /2021 Ram Co- 000017 CK Co- 10000 operative 95 SALES operativ 0560 Bank Ltd AND e Bank MARK Ltd ETING LIMITE D 07/09 Bharu Adarsh 460101 DEBO Adarsh 46014 0.25 /2021 Ram Co- 000017 CK Co- 10000 operative 95 SALES operativ 0560 Bank Ltd AND e Bank MARK Ltd ETING LIMITE D 07/09 Bharu Adarsh 460101 DEBO Adarsh 46014 0.23 /2021 Ram Co- 000017 CK Co- 10000 operative 95 SALES operativ 0560 Bank Ltd AND e Bank MARK Ltd ETING LIMITE D 07/09 Bharu Adarsh 460101 DEBO Adarsh 46014 0.29 /2021 Ram Co- 000017 CK Co- 10000 operative 95 SALES operativ 0560 Bank Ltd AND e Bank MARK Ltd ETING LIMITE D 07/09 Bharu Adarsh 460101 DEBO Adarsh 46014 0.14 /2021 Ram Co- 000017 CK Co- 10000 operative 95 SALES operativ 0560 Bank Ltd AND e Bank MARK Ltd ETING LIMITE D

Circuitous payment of application money by Sheetal Jain is diagrammatically shown below:

The details of bank transactions Date From From From To To To Amo entity Bank Bank entity Bank Bank unt accoun accou (Amt t No nt No in Rs.) 07/09 DEBOCK Adarsh 460141 SUNIL Adarsh 46010 0.28 /2021 SALES Co- 000005 KUMAR Co- 10000 AND operative 60 KALOT operativ 1794 MARKET Bank Ltd e Bank ING Ltd LIMITED 07/09 DEBOCK Adarsh 460141 SUNIL Adarsh 46010 0.17 /2021 SALES Co- 000005 KUMAR Co- 10000 AND operative 60 KALOT operativ 1794 MARKET Bank Ltd e Bank ING Ltd LIMITED 07/09 SUNIL Adarsh 460101 SHEET Adarsh 46010 0.28 /2021 KUMAR Co- 000017 AL JAIN Co- 10000 KALOT operative 94 operativ 1796 Bank Ltd e Bank Ltd 07/09 SUNIL Adarsh 460101 SHEET Adarsh 46010 0.17 /2021 KUMAR Co- 000017 AL JAIN Co- 10000 KALOT operative 94 operativ 1796 Bank Ltd e Bank Ltd

07/09 SHEETA Adarsh 460101 DEBOC Adarsh 46014 0.28 /2021 L JAIN Co- 000017 K Co- 10000 operative 96 SALES operativ 0560 Bank Ltd AND e Bank MARKE Ltd TING LIMITE D 07/09 SHEETA Adarsh 460101 DEBOC Adarsh 46014 0.17 /2021 L JAIN Co- 000017 K Co- 10000 operative 96 SALES operativ 0560 Bank Ltd AND e Bank MARKE Ltd TING LIMITE D

Circuitous payment of application money by Rahul Khurana is diagrammatically shown below:

The details of bank transactions

Date From From From To To To Amo entity Bank Bank entity Bank Bank unt accoun accou (Amt t No nt No in Rs.)

07/09/20 DEBOCK Adarsh 460141 SUNIL Adarsh 46010 0.29 21 SALES Co- 000005 KUMAR Co- 10000 AND operati 60 KALOT operativ 1794 MARKETI ve e Bank NG Bank Ltd LIMITED Ltd 07/09/20 DEBOCK Adarsh 460141 SUNIL Adarsh 46010 0.16 21 SALES Co- 000005 KUMAR Co- 10000 AND operati 60 KALOT operativ 1794 MARKETI ve e Bank NG Bank Ltd LIMITED Ltd 07/09/20 SUNIL Adarsh 460101 RAHUL Adarsh 46010 0.29 21 KUMAR Co- 000017 KHURA Co- 10000 KALOT operati 94 NA operativ 1797 ve e Bank Bank Ltd Ltd 07/09/20 SUNIL Adarsh 460101 RAHUL Adarsh 46010 0.16 21 KUMAR Co- 000017 KHURA Co- 10000 KALOT operati 94 NA operativ 1797 ve e Bank Bank Ltd Ltd 07/09/20 RAHUL Adarsh 460101 DEBOC Adarsh 46014 0.29 21 KHURANA Co- 000017 K Co- 10000 operati 97 SALES operativ 0560 ve AND e Bank Bank MARKE Ltd Ltd TING LIMITE D 07/09/20 RAHUL Adarsh 460101 DEBOC Adarsh 46014 0.16 21 KHURANA Co- 000017 K Co- 10000 operati 97 SALES operativ 0560 ve AND e Bank Bank MARKE Ltd Ltd TING LIMITE D

Circuitous payment of application money by Ajay Dahiya is diagrammatically shown below:

The details of bank transactions

Date From From From To To To Amo entity Bank Bank entity Bank Bank unt accou accou (Amt nt No nt No in Rs.) 07/09/ DEBOCK Adarsh 46014 SUNIL Adarsh 46010 0.26 2021 SALES Co- 10000 KUMA Co- 10000 AND operative 0560 R operativ 1794 MARKET Bank Ltd KALO e Bank ING T Ltd LIMITED 07/09/ DEBOCK Adarsh 46014 SUNIL Adarsh 46010 0.23 2021 SALES Co- 10000 KUMA Co- 10000 AND operative 0560 R operativ 1794 MARKET Bank Ltd KALO e Bank ING T Ltd LIMITED 07/09/ DEBOCK Adarsh 46014 SUNIL Adarsh 46010 0.04 2021 SALES Co- 10000 KUMA Co- 10000 AND operative 0560 R operativ 1794 MARKET Bank Ltd KALO e Bank ING T Ltd LIMITED

07/09/ SUNIL Adarsh 46010 AJAY Adarsh 46010 0.26 2021 KUMAR Co- 10000 DAHIY Co- 10000 KALOT operative 1794 A operativ 1793 Bank Ltd e Bank Ltd 07/09/ SUNIL Adarsh 46010 AJAY Adarsh 46010 0.23 2021 KUMAR Co- 10000 DAHIY Co- 10000 KALOT operative 1794 A operativ 1793 Bank Ltd e Bank Ltd 07/09/ SUNIL Adarsh 46010 AJAY Adarsh 46010 0.04 2021 KUMAR Co- 10000 DAHIY Co- 10000 KALOT operative 1794 A operativ 1793 Bank Ltd e Bank Ltd 07/09/ AJAY Adarsh 46010 DEBO Adarsh 46014 0.26 2021 DAHIYA Co- 10000 CK Co- 10000 operative 1793 SALES operativ 0560 Bank Ltd AND e Bank MARK Ltd ETING LIMITE D 07/09/ AJAY Adarsh 46010 DEBO Adarsh 46014 0.23 2021 DAHIYA Co- 10000 CK Co- 10000 operative 1793 SALES operativ 0560 Bank Ltd AND e Bank MARK Ltd ETING LIMITE D 07/09/ AJAY Adarsh 46010 DEBO Adarsh 46014 0.04 2021 DAHIYA Co- 10000 CK Co- 10000 operative 1793 SALES operativ 0560 Bank Ltd AND e Bank MARK Ltd ETING LIMITE D

Annexure C Date From Entity From From To entity To To Bank Amou Bank Bank Bank account nt (Rs. accoun No In Cr) t No 21- DEBOCK ICICI 405142 DEBOCK ICICI 7777059 49.09 07- INDUSTRIES Bank 297 INDUSTRI Bank 56180 2023 LIMITED- ES RIGHTS ISSUE LIMITED ALLOTMENT ACCOUNT 24/07 DEBOCK ICICI 777705 IMPEX ICICI 6759055 49.00 /2023 INDUSTRIES Bank 956180 AGROTEC Bank 00964 LIMITED H PRIVATE LIMITED 24/07 IMPEX ICICI 675905 NATURO ICICI 3616050 24.00 /2023 AGROTECH Bank 500964 INDIABUL Bank 00762 PRIVATE L LIMITED LIMITED 26/07 IMPEX ICICI 675905 PRIYANK ICICI 6759017 14.00 /2023 AGROTECH Bank 500964 A Bank 02447 PRIVATE SHARMA LIMITED 24/07 IMPEX ICICI 675905 DEBOCK ICICI 7777059 2.75 /2023 AGROTECH Bank 500964 INDUSTRI Bank 56180 PRIVATE ES LIMITED LIMITED 28/07 IMPEX ICICI 675905 NATURO ICICI 3616050 1.00 /2023 AGROTECH Bank 500964 INDIABUL Bank 00762 PRIVATE L LIMITED LIMITED 28/07 IMPEX ICICI 675905 MUKESH ICICI 3616015 0.50 /2023 AGROTECH Bank 500964 MANVEER Bank 03611 PRIVATE SINGH LIMITED 14/08 IMPEX ICICI 675905 DEBOCK ICICI 7777059 0.50 /2023 AGROTECH Bank 500964 INDUSTRI Bank 56180 PRIVATE ES LIMITED LIMITED 24/07 IMPEX ICICI 675905 GAURAV ICICI 3616015 0.46 /2023 AGROTECH Bank 500964 JAIN Bank 03352 PRIVATE LIMITED

24/07 IMPEX ICICI 675905 DEBOCK ICICI 7777059 0.40 /2023 AGROTECH Bank 500964 INDUSTRI Bank 56180 PRIVATE ES LIMITED LIMITED 08/08 IMPEX ICICI 675905 MUKESH ICICI 3616015 0.40 /2023 AGROTECH Bank 500964 MANVEER Bank 03611 PRIVATE SINGH LIMITED 24/07 IMPEX ICICI 675905 JYOTI ICICI 3616015 0.30 /2023 AGROTECH Bank 500964 CHOUDH Bank 03634 PRIVATE ARY LIMITED 24/07 IMPEX ICICI 675905 BIG BOY ICICI 7430374 0.25 /2023 AGROTECH Bank 500964 TOYZ LTD Bank 919 PRIVATE LIMITED 03/08 IMPEX ICICI 675905 GAURAV ICICI 3616015 0.22 /2023 AGROTECH Bank 500964 JAIN Bank 03352 PRIVATE LIMITED 27/07 IMPEX ICICI 675905 DEBOCK ICICI 7777059 0.15 /2023 AGROTECH Bank 500964 INDUSTRI Bank 56180 PRIVATE ES LIMITED LIMITED 28/07 IMPEX ICICI 675905 DEBOCK ICICI 7777059 0.10 /2023 AGROTECH Bank 500964 INDUSTRI Bank 56180 PRIVATE ES LIMITED LIMITED 11/08 IMPEX ICICI 675905 DEBOCK ICICI 7777059 0.10 /2023 AGROTECH Bank 500964 INDUSTRI Bank 56180 PRIVATE ES LIMITED LIMITED 02/08 IMPEX ICICI 675905 DEBOCK ICICI 7777059 0.05 /2023 AGROTECH Bank 500964 INDUSTRI Bank 56180 PRIVATE ES LIMITED LIMITED 04/08 IMPEX ICICI 675905 DEBOCK ICICI 7777059 0.05 /2023 AGROTECH Bank 500964 INDUSTRI Bank 56180 PRIVATE ES LIMITED LIMITED 04/08 IMPEX ICICI 675905 NATURO ICICI 3616050 0.05 /2023 AGROTECH Bank 500964 INDIABUL Bank 00762 PRIVATE L LIMITED LIMITED 14/08 IMPEX ICICI 675905 GAURAV ICICI 3616015 0.02 /2023 AGROTECH Bank 500964 JAIN Bank 03352

PRIVATE LIMITED 01/08 IMPEX ICICI 675905 NATURO ICICI 3616050 0.02 /2023 AGROTECH Bank 500964 INDIABUL Bank 00762 PRIVATE L LIMITED LIMITED 01/08 IMPEX ICICI 675905 GAURAV ICICI 3616015 0.02 /2023 AGROTECH Bank 500964 JAIN Bank 03352 PRIVATE LIMITED

Annexure D Clien Date Broke Avg Proceeds Sell Sell Value Amount t r Sell credited Quantity credited Nam Name Price to bank to bank e SUNI 04- CHOI 46.85 Adarsh 1,02,000 47,78,700 47,44,865 L Oct- CE Co- KAL 2021 EQUIT opearative OT Y Bank 07- BROK 54.15 Adarsh 48,000 25,99,200 39,50,000 Oct- ING Co- 2021 PRIVA opearative TE Bank 08- LIMIT 56.85 Adarsh 24,000 13,64,400 combined Oct- ED Co-with 07- 2021 opearative 10-2024 Bank 21- 81.25 Adarsh 36,000 29,25,000 29,00,000 Oct- Co- 2021 opearative Bank 26- 80.75 Adarsh 24,000 19,38,000 19,00,000 Oct- Co- 2021 opearative Bank 09- 71.45 Adarsh 60,000 42,87,000 43,00,000 Nov- Co- 2021 opearative Bank 21- 136.9 Adarsh 1,02,000 1,39,63,80 1,38,99,81 Dec- 0 Co- 0 0 2021 opearative Bank 17- 143.0 Adarsh 50,400 72,07,200 1,00,00,00 Mar- 0 Co- 0 2022 opearative Bank 21- 145.0 Adarsh 40,800 59,16,000 30,63,000 Mar- 0 Co- 2022 opearative Bank 05- RUDR 15.32 Adarsh 24,24,00 3,71,34,53 3,69,63,00 May- A Co- 0 0 0 2023 SHAR opearative ES & Bank

Clien Date Broke Avg Proceeds Sell Sell Value Amount t r Sell credited Quantity credited Nam Name Price to bank to bank e 01- STOC 17.00 Adarsh 25,00,00 4,25,00,00 4,22,55,60 Jun- K Co- 0 0 4 2023 BROK opearative ERS Bank 20- LIMIT 16.00 ICICI 3,50,000 56,00,623 55,00,000 Jun- ED Bank 2023 21- BAJAJ 16.00 Adarsh 1,00,000 16,00,000 combined Jun- FINAN Co-with 22 2023 CIAL opearative june 2023 SECU Bank 22- RITIE 16.00 Adarsh 51,26,64 8,20,31,24 8,34,44,69 Jun- S Co- 0 0 6 2023 LTD. opearative Bank 26- 16.00 ICICI 43,47,87 6,95,65,93 6,94,11,30 Jun- Bank 1 6 7 2023 04- 10.96 ICICI 36,03,50 3,95,00,63 3,94,12,75 Jan- Bank 4 5 4 2024 05- 10.41 ICICI 3,21,985 33,51,259 33,43,723 Jan- Bank 2024 08- RUDR 10.63 ICICI 40,73,66 4,33,06,49 4,30,57,04 Jan- A Bank 3 8 2 2024 SHAR 09- ES & 10.11 ICICI 20,00,33 2,02,26,55 2,01,10,03 Jan- STOC Bank 7 9 2 2024 K BROK ERS LIMIT ED SUNIL KALOT Total 2,53,35,2 38,97,96,5 38,82,55,8 00 80 33 MUK 12- CHOI 128.0 Adarsh 100 12,800 Combined ESH Apr- CE 0 Co-with 21 MAN 2022 EQUIT opearative April 2022 VEE Y Bank

Clien Date Broke Avg Proceeds Sell Sell Value Amount t r Sell credited Quantity credited Nam Name Price to bank to bank e R 21- BROK 124.9 Adarsh 1,00,000 1,24,90,00 1,23,84,44 SING Apr- ING 0 Co- 0 8 H 2022 PRIVA opearative TE Bank LIMIT ED 10- RUDR 9.62 Yes Bank 1,19,64,0 11,50,59,0 11,43,74,6 Jan- A 00 25 04 2024 SHAR ES & STOC K BROK ERS LIMIT ED MUKESH MANVEER SINGH Total 1,20,64,1 12,75,61,8 12,67,59,0 00 25 52 AMIT 18- MOTIL 66.85 IDBI Bank 18,000 12,03,300 11,97,784 AGA Nov- AL RWA 2021 OSWA L L FINAN CIAL SERVI CES LIMIT ED Grand Total 3,74,17,5 51,85,63,5 51,62,12,6 00 95 69