Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling Ropeway Company Ltd., GBL Industries Ltd. and Vishal Fabrics Ltd.Corrigendum to the Interim Order dated June 19, 2023 in the matter of Mauria Udyog Ltd and other scrips

WTM/ SM/ IVD/ ID9/ 27532/2023-24 SECURITIES AND EXCHANGE BOARD OF INDIA ORDER UNDER SECTIONS 11(1), 11(4) 11(4A), 11B (1) AND 11B (2) OF THE SECURITIES AND EXCHANGE BOARD OF INDIA ACT, 1992

In respect of: Sl. No. Name of the Entity PAN 1. Hanif Shekh CBEPS9710A 2. Kasambhai Shekh AGRPS7734C 3. Hasina Kasambhai Shekh BFHPS4813N 4. Robert Resources Ltd AAACR2073D 5. Econo Trade India Ltd AAACE5451C 6. Econo Broking (Erstwhile Bansal Finstock) AADCB8817A 7. Sai Metaltech Llp ADXFS9004L 8. Navneet Kumar Sureka ANWPS5531K 9. Deepa Sureka ANTPS8310F 10. Mauria Udyog Ltd AABCM9522F 11. Vee Em Infocenter Ltd AACCV0425D 12. Jagdish Chahar ANNPC0228J 13. Amit Kumar AJCPK6114G 14. Jagdish Singh ARGPS3874H 15. Mithun Singh BVZPS9152G 16. Santosh Raut AZBPR5416K 17. Raja Ram CCIPR2093C 18. Govind Ojha AATPO0326J 19. Rakesh Goel AHQPG6997D 20. Shiv Pal AUGPP5794G 21. Ramajor Ramajor ATZPR1408H 22. Mahavir Prasad AKQPP6836M

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling Ropeway Company Ltd., GBL Industries Ltd. and Vishal Fabrics Ltd.

Sl. No. Name of the Entity PAN 23. Haribansh Gupta BDFPG5772A 24. Sunil Kumar Verma ARGPV5585N 25. Govind Singh DHXPS0249Q 26. Sukanta Kumar Pala ABRPP1855G 27. Madhu EAAPS2972B 28. Ravita Devi BIGPD0615R 29. Sukhilal Meena BKZPM0621H 30. Hare Ram AEYPR6338C 31. Arvind Kumar AEHPK9032M 32. Meera Devi BIGPD0616N 33. Roshan Kumar Jaiswal AWMPJ9308E 34. Kavita Devi BASPD6735J 35. Jeet Bahadur AHVPB6604R 36. Madan Prasad BUZPP4215J 37. Krishan Murari Sharma BNJPS2163K 38. Pappu Kumar Ram BZQPR7716A 39. Nand Lal Sharma AXAPS1944E 40. Leelu Singh DCNPS6356F 41. Amarjeet AIEPA6834G 42. Anand Bansal AHYPB4902B 43. Arun Kumar CJCPK8525R 44. Bhurey Singh BFIPS7754D 45. Binod Kumar Jha AKWPJ0656R 46. Dashrath Yadav AEOPY5916K 47. Devi Singh BFVPS5988C 48. Dharamwati Chauhan AXZPC6279R 49. Hariom Rathore ALQPR2239F 50. Hoshiyar Saini BXEPS7837P 51. Indranand Singh FIIPS3787P 52. Jitender Nagar ANPPN2462B

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling

Sl. No. Name of the Entity PAN 53. Kailash Chouhan ADCPC4008R 54. Kesh Ram AGMPR1636B 55. Kuldeep Singh BFIPS7755C 56. Laxman Yadav ABBPY2796D 57. Mahender Singh AWJPS8491E 58. Mangal Singh BRPPS6874R 59. Mukesh Pandey CXPPP6254H 60. Narender ADVPN2232P 61. Parmanand ALBPP6249E 62. Pramod Ram AYUPR9406M 63. Prem Chand AGSPC0271B 64. Rajendra Kumar BWHPK5104R 65. Rajesh Giri AXGPG5852K 66. Rajesh Kumar BPUPK5369G 67. Raju Devi CAQPD3563B 68. Ratindra Nath AMCPN9622R 69. Saroj Yadav AFPPY4880A 70. Seeta Ram AGMPR7725F 71. Shiv Shanker COKPS1441D 72. Sunil Nagar AMCPN9604P 73. Susheel Kumar Arora AISPA5466E 74. Davinder Kumar Gupta AONPG0703M 75. Deepak Kumar Garg AIDPG7889A 76. Linkwise Marketing Private Limited AABCL8513H 77. Durgeshwari Pradipbhai Chiripal AHWPC2289G 78. Manuj Ashokkumar Chiripal AUCPC1621M 79. Rushp Trading Llp AAMFR3523K 80. Satrama Trading Llp ABUFS0540C 81. Shivhari Trading Llp ACSFS3095B 82. Trisha Vikash Bajaj AEGPA7779E

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling

Sl. No. Name of the Entity PAN 83. Bajaj Sonali Ateet APCPC1264M 84. Ravi Kannadasan Adidravid AVSPA1063A 85. Pritiben Popatbhai Parmar AXGPP6927Q 86. Manishkumar Rajput CGPPR9641K 87. Shahrukhkhan Pathan DOJPP7089N 88. Sahilkumar Amrutbhai Vaghela ATLPV1359B 89. Lilaben Popatbhai Parmar DBYPP5174G 90. Popatbhai Ramjibhai Parmar DGFPP6706L 91. Dipika Popatbhai Parmar DKMPP5973A 92. Fuldeep Popatbhai Sehgal GIOPS7160B 93. Keval Savant HYAPS6005L 94. Chiragkumar Makwana CTXPM2544K 95. Makwana Madhuben CUHPM8134L 96. Krusha Birjukumar Sanghvi FXCPS0434J 97. Karan Birjubhai Sanghvi ESJPS8192E 98. Hina Barot DGUPB9477B 99. Prakash Kantilal Vaghela AGEPV6889L 100. Highgrowth Vincom Private Limited AACCH1789A 101. Sumit Laha AXJPL4908J 102. Dibakar Laha AJVPL4026B 103. Glorious Vincom Pvt. Ltd. AADCG3846Q 104. Arpan Das CEZPD7390K 105. Sanjay Dey BWHPD4063L 106. Linkup Financial Consultants Private Limited AACCL0347G 107. Suprabhat Laha APXPL1814M 108. Ujjal Laha ATSPL2483R 109. Buddhadeb Laha AQBPL5563C 110. Sourav Das CEJPD9809M 111. Minu Mallick DGTPM2047B 112. Arun Dutta AIYPD5217E

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling

Sl. No. Name of the Entity PAN 113. Debashish Dutta CVMPD9641P 114. Uma Dutta COXPD8400E 115. Subrata Laha APWPL5386H 116. Priyankar Laha AKLPL2832L 117. Tapas Laha ANCPL7138F 118. Arun Laha APWPL5441F 119. Tejal Amitkumar Khatri ERFPK5538F 120. Nitesh P Pavskar BJQPP0910G 121. Chintukumar Vasudevbhai Pandya BBGPP8915H 122. Naginbhai Jeshingbhai Maheriya AZRPM0004E 123. Chandrikaben Maheshbhai Chauhan BWSPC8594A 124. Kamleshkumar G Solanki BFLPS7554C 125. Vijay Rajeshbhai Vasita AXQPV0383G 126. Jitendra Harjivanbhai Gohil AJMPG6403E 127. Govindbhai Natvarlal Chauhan BFMPC4964H 128. Natvarbhai Patlia DDYPP0586C 129. Ravindra Nanalal Raval AETPR3110B 130. Dixit Nareshbhai Borisa BNDPB5397L 131. Sushma Jasmin Barot CEYPB7305B 132. Manoharprasad Ghanshyambhai Vaishnav AKDPV8381N 133. Maheshkumar Nareshkumar Purabia APJPP8572N 134. Piyush Agarwal APBPA7314M 135. Juscorp Enterprises Private Limited AADCJ9182A 136. A1 Solutions- Prop-Ajju Kumar EJKPK0864F 137. Corredor Services Private Limited AAGCC9495E 138. Sapan Kumar Agarwal BBHPK0862R 139. Vepar Solutions Private Limited AAFCV8797B 140. Shyam Kumar Singh BLVPS0924A 141. Kamal Gupta HUF AALHK4127K 142. Chinnu BGQPC3096K

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling

Sl. No. Name of the Entity PAN 143. Gyanendra Gharti Chhetri AVBPC2116P 144. Aayush Tanwar ATPPT4346L 145. Goenka Business Finance Limited AAACG9648P 146. Kalpesh Dantani CRCPD9488E 147. Shivam Kumar HQAPK6082B 148. Sanjaybhai Babubhai Solanki DYOPS5202R 149. Chetanbhai Mahendrabhai Dantani FQGPD8779G 150. Suresh Deshaljibhai Vaghela AATPV7474Q 151. Amrutji Gokaji Thakor AZIPT0131G 152. Malay Bhow AEJPB9509C 153. Aakash Dilip Doshi AILPD8283D 154. Rajvi Naresh Shah BJAPS6060A 155. Ramnaresh Dashadeen Nirmal ADGPN1274J 156. Arvind Shantilal Shah AAPPS5253A 157. Yash Manish Mehta CGGPM6543Q 158. Rupal Bhavin Shah AUWPS1058E 159. Bharati Arvind Shah ANDPS3927Q 160. Dhavani Jayantkumar Shah AIWPS7376P 161. Kruti Kevin Kapadia BCRPK1909C 162. Shashikant C Kapadia AARPK2091E 163. Ankur Suresh Mehta AJGPM2288K 164. Bhashit Deepak Shah BLOPS8366M 165. Mehul Hasmukh Shah AKMPS7735C 166. Vidhi Mehul Shah APFPS2795N 167. Himanshu Shah ACSPS6353A 168. Shalini Sushil Jain AFOPJ1106R 169. Devarshi J Shah AYKPS9042E 170. Sayar S Bhandari AKLPB9574B 171. Vimala Anandraj Ostwal Bhandari AAIPV1564A 172. Rekha Ravi Bhandari AAHPR8129A

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling

Sl. No. Name of the Entity PAN 173. Shrenik Jitendrabhai Gohil BRCPG1140D 174. Amit Bechu Yadav AJYPY3967H 175. Hardik Parmar DJFPP1628L 176. Akshay Jitendrakumar Brahambhatt CDXPB7730C 177. Dakshaben Maheshkumar Purabiya DGQPP3613D 178. Neeta Ganpatbhai Dabhi BTLPD3342P 179. Binal Naginbhai Patel CTQPP5758M 180. Prabhavatiben Natvarbhai Patliya DBRPP5531G 181. Maunesh Hargovinddas Devara AVSPD3674L 182. Ramu Jomdar Jsoneya AWJPJ7193E 183. Patiram Ramkishan CCEPK8853M 184. Rahul Rameshbhai Mehta ARCPM5961D 185. Harishkumar Sakariya AXFPS3805D 186. Preyash Sathvara BWPPS8357E 187. Mukeshkumar Mavjibhai DMKPP1977E 188. Praveen Kumar DRRPK7321D 189. Ankit Jagdishbhai Pithava BXVPP0489B 190. Dipak Ganpatbhai Sakariya DYXPS5815K 191. Rekhaben Harishbhai DZEPS8946B 192. Naresh Mavjibhai Parmar DMKPP1979L 193. Sushila Ashokbhai Chiripal AHWPC2333D 194. Anil Dhanuka AAPPD9931Q 195. Chirpal Suryansh Hari BHWPC6616A 196. Vedprakash Devkinandan Chiripal AAHPC2102Q 197. Yash R Bajaj AJCPB9461D 198. Raaj Ravindrakumar Bajaj AVYPB4290Q 199. Yogeshkumar Anandpal Goyal ABKPG1172A 200. Savitridevi V Chiripal AAQPA0515Q 201. Bhavin Shah AAKPS2177G 202. Kevin Kapadia AGIPK9817H

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling

Sl. No. Name of the Entity PAN 203. Manish Shah (Proprietor of Aneel A & Co) BFOPS3849R 204. Vishal Jitendrakumar Barot (Proprietor of Samukh Trade) BHLPB2441M 205. Amrish Nagindas Shah (Proprietor of Shakti Enterprise) BFOPS4241B 206. Sharad Enterprise APOPP1463R 207. Amitkumar Govindbhai Parmar (Proprietor of Ambika Traders) BIGPP7877P 208. Midpoint Commodeal AAICM0631L 209. Dk Jain Properties AACCD3821F 210. Mr Merchants Pvt Ltd AAICM3686R 211. Armeva Dealers Pvt Ltd AAQCA6476M 212. Amuly Suppliers AAKCA3466B 213. Frexon Supppliers Pvt Ltd AADCF4723H 214. Rightview Dealers Pvt Ltd AAICR7968M 215. Mackny Trexim Pvt Ltd AALCM9241K 216. Urki Sales Pvt Ltd AACCU2118C 217. Nxstar Dealcom Pvt Ltd AAGCN1597E 218. Impalio Distributors Pvt Ltd AAECI9546E 219. Cradon Traders Pvt Ltd AAHCC6973A 220. Nilratan Suppliers Private Limited AADCN5209L 221. Briya Enterprise Ltd AABCA7879D 222. Kanungo Financiers Ltd AABCK1251B 223. Purple Entertainment Ltd AAACH5273P 224. Lagan Barter Pvt Ltd AABCL5159M 225. Jignesh Sudhirbhai Shah BBNPS1083E 226. Chandraprakash Valchand Parekh (Proprietor of Sambhavanath ASAPP9100C Traders) In the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling Ropeway Company Ltd., GBL Industries Ltd. and Vishal Fabrics Ltd. Background 1. Securities and Exchange Board of India (hereinafter referred to as "SEBI") investigated into the trading in respect of five (5) scrips viz: Mauria Udyog Ltd., 7NR

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling

Retail Ltd., Darjeeling Ropeway Company Ltd. and GBL Industries Ltd. listed on the Bombay Stock Exchange Limited (hereinafter referred to as "BSE") and also in the trading in the scrip of Vishal Fabrics Ltd. listed on both the Stock Exchanges i.e., BSE and National Stock Exchange of India Ltd. (hereinafter referred to as "NSE”) based on the abnormally sharp rise witnessed in the prices and volumes in the aforesaid five scrips. It was observed during the investigation that there were certain strong commonalities in the trading pattern followed by various entities in these scrips. One such common feature was that ‘buy recommendations’ for all the above mentioned five scrips were widely circulated through circulation of SMSs and additionally, certain websites were also used for recommending buying in four out of the above noted five aforesaid scrips (except Vishal Fabrics Limited). It was further noted that the period of such SMS circulation with respect to the aforenamed five scrips, coincided with an astronomical rise in the prices and volumes in all the above mentioned five scrips except for the fact, that in case of Darjeeling Ropeway Company Ltd. only volume had increased and price rise remained under control apparently because of specific surveillance actions that were imposed on this scrip by the Stock Exchange during the period of SMS circulation of such ‘buy recommendations’ with respect to this scrip.

2. In this backdrop, SEBI conducted an investigation into the trading activities witnessed in the aforenamed five scrips to ascertain the reasons behind such historic and abnormal rise registered in the prices and volumes, in the aforesaid scrips and further to identify as to whether the said unusual rise in the price and/or volume had happened in the normal course of dealing in these securities on the Stock Exchange platforms or there were any entities / persons who have masterminded and caused large scale circulation of the ‘buy recommendations’ in these scrips through SMS and websites so as to artificially cause rapid price and volume increase in these scrips. The investigation also aimed further to find out as to whether such entities who were behind the said SMS circulation, were having connection with the Promoters of the companies and / or with any the other entities who were dealing in the said five scrips during the period under investigation. The investigation also had set out its objective

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling to ascertain the identities of the Ultimate Beneficiaries of wrongful gains, if any, that have been derived by way of dealing in the aforesaid five scrips, in a fraudulent manner or otherwise. Further, the focus of the investigation was also to determine as to whether the acts of such entities involved in dealing in the said five scrips were in consonance with the provisions of Securities and Exchange Board of India Act, 1992 (hereinafter referred to as “SEBI Act”) and SEBI (Prohibition of Fraudulent and Unfair Trade Practices relating to Securities Market) Regulations, 2003 (hereinafter referred to as “PFUTP Regulations”) during the period under investigation. SEBI’s Investigation 3. The investigation conducted by SEBI has successfully identified certain suspected entities who were prima facie found to be involved in various fraudulent acts that had led to the abnormal rise in the volumes and prices of the above named five scrips during the investigation period. These suspected entities who have been prima facie found to be indulged in fraudulent trade practices in the above named five scrips have been listed out in the first page of this interim order-cum-show cause notice, based on the following fact findings: 3.1. A very discernible unusual pattern of dealing was noted at the time of investigation from the way the entities have dealt in the said five scrips which hinged upon the circulation of bulk SMS with buy recommendations and use of certain websites for recommending to public to buy the said five scrips. It was found that there were two distinct but connected phases of dealing in the said scrips; one was pre-SMS circulation phase during which the scrips which did not have backing of any significant corporate announcements or did not have very sound fundamentals, have witnessed substantial movement in their prices. It has further been noticed that these scrips did not have any noteworthy liquidity and yet witnessed a sustained and substantial increase in prices and volumes compared to their past performances. The second phase kicked in with post circulation of bulk SMS with buy recommendations (SMS circulation phase) during which the trade volumes and prices of the scrips further rose

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling prima facie as a consequence to the SMS circulations and certain other entities who were either enjoying connection with each other and / or with the company through its Promoters/Directors taking advantage of the price rise have exited from these scrips after pocketing a substantial profit. 3.2. It was noted during the investigation that, broadly there were three set of entities involved in the entire matter: the first set of entities were those who are seen to be instrumental in artificially influencing price and volume in the scrips during the pre-SMS period. These entities are nomenclated as “PV Influencers”. These PV influencers were the entities who are found to be connected with each other and / or with the company and who had, in concert by trading as a coherent group in the respective scrips during the pre-SMS period in an unusual manner, had increased the price and volume in the said five scrips. The second set of entities were the “Off loaders” who were also the entities connected with each other and / or with the Company and who had made substantial profits by their dealing in the scrip by way of dumping the shares of these companies on the Stock Exchange platforms (previously acquired by them), by taking advantage of the rapid abnormal price rise in these scrips particularly, during post-SMS circulation. Lastly the ‘kingpin’, who was the mastermind behind the successful implementation/execution of the entire fraudulent operation, was the “SMS Sender”, who has been identified as Mr. Hanif Shekh who, apart from being instrumental in orchestrating the entire scheme along with his connected entities, had also sent the bulk SMS with the buy recommendations in the said five scrips and additionally had also made use of certain websites for making buying recommendation in four out of five aforesaid scrips (except Vishal Fabrics Limited) which triggered influencing and luring other investors / general public to trade in the said five scrips. 3.3. The price and volume manipulation in the afore-stated five scrips as noted during the time of the investigation is summarised in the table below:

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling

Table No. 1 Volume Manipulation Price Manipulation Scrip Name Buy Quantity %Buy to Sell %Sell to Net Net Total_ %contri by connected total Quantity total Buy_LTP Sell_LTP LTP bution entities Market by Market by by to net Buy connecte Sell connected connected price Volume d entities Volume entities entities rise

Mauria Udyog 2004898 39.9% 1769584 35.22% 832.4 343.44 1175.88 479.46 Ltd- Group 1 % (27.01.2017 to 20.09.2019)

Mauria Udyog 2531309 23.08% 2491027 22.71% - - - - Ltd- Group 2 (19.07.2019 to 27.12.2019)

7NR Retail Ltd 3085303 44.83% 2939480 42.72% 62.77 124.34 187.36 120.62 (10.01.2019 to % 08.11.2019) Darjeeling 3541302 32.00% 3972753 35.90% 124.36 -24.26 100.1 111.83 Ropeway % Company Ltd (02.04.2018 to 22.12.2019) GBL Industries 1829089 20.10% 1808699 19.88% 43.4 23.85 67.25 108.12 Ltd % 02.07.2018 To 14.01.2019) Vishal Fabrics 594348 56.12% 413421 39.04% 5.30 71.05 76.35 55.33% Ltd – BSE (25.03.2020 to 04.09.2020) Vishal Fabrics 223282 18.17% 392354 31.93% 47.90 -17.70 30.20 23.59% Ltd – NSE (25.03.2020 to 04.09.2020)

3.4. It was also observed that the entire operation which was being prima facie run by the kingpin (Mr. Hanif Shekh) with best of care to deceitfully hoodwink

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling and delude the normal eyes, as a consequence of which Mr. Hanif Shekh along with his connected entities and promoters of some of these companies (scrips) had generated wrongful gains to the tune of approximately INR 143.79 crore by way of dealing in the aforesaid five scrips. 3.5. The investigation also prima facie reveals that a large number of entities connected to Mr. Hanif Shekh and / or Promoter of some of the Companies who were constituents of either PV Influencers or Collaborators or Off Loaders that took part in the prima facie scheme apparently master minded by Mr. Hanif Shekh alongwith Promoters of some of the Companies, were front entities / mule entities / name lenders. These front entities / mule entities / name lenders were prima facie observed to be operated as conduits of Mr. Hanif Shekh and / or of Promoters of some of the Companies. During the investigation, summons was issued to approximately 150 entities, out of which approximately 90 summons did not elicit any response from the respective entities. The same also strengthens the aforesaid prima facie observation that front entities / mule entities / name lenders were employed to successfully execute the prima facie scheme. 3.6. Before delving into the dealing in detail about the prima facie scheme that is observed to be employed for fraudulently dealing in the above noted five scrips so as to generate huge sums of wrongful gains that were transferred by the entities participating in the scheme to the ultimate beneficiaries through various layers of conduits, a diagrammatic indicative representation of the scheme that was prima facie unearthed during the investigation is presented below:

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling

Figure No. 1

Consideration and Prima Facie Findings 4. I have carefully perused and considered the above narrated findings of SEBI’s investigation and have also considered various materials and evidence available on record. On a perusal of the same, I find that essentially, the issue that prima facie requires to be addressed in the present matter is whether one Mr. Hanif Shekh, pursuant to a scheme designed by him, with the assistance of other connected entities

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling in the matter, has first manipulated the price and volume in the aforesaid five scrips which till then had not seen any sustained trading activities. Further, it needs to be ascertained as to whether, once the desired level was reached in the said scrips in terms of price and volumes, it was Mr. Hanif Shekh who ensured that bulk SMSs are sent out to public with buy recommendations in respect of the afore noted five scrips including using certain websites to recommend buying in four out of five aforesaid scrips (except Vishal Fabrics Limited), which became instrumental in further inducing the investors to deal in the aforesaid five scrips causing further rise in volumes and prices of those scrips, thereby giving an opportunity to certain entities who were either connected with Mr. Hanif Shekh and / or the company concerned, to offload the shares in the market they had previously acquired, and in the said process they were successful in making a substantial profit. 5. It will be relevant here to note that although there are five scrips which were taken up under investigation for examining the role of various connected entities and individuals who were suspected to be engaged in fraudulent trade practices in those scrips, most of these connected entities were however not commonly spread across all the said five scrips, as each scrip had also its separate set of inter-linked entities involved in its trading, apart from sharing some common entities who were seen to be involved in dealing with all or many of those in the five scrips. However, there is one common thread that strongly runs through the dealings in all of the said five scrips, which is that of wide circulation of bulk SMSs with buy recommendations with respect to the said five scrips and use of certain websites to recommend buying in favour of four out of five aforesaid scrips (except Vishal Fabrics Limited). Therefore, at the outset, it becomes essential to identify the identity of the ‘SMS Sender’ that apparently accentuated inducement to buy these scrips, before proceeding further in the matter. SMS Sender- Mr. Hanif Shekh 6. It is noted that buy recommendations in the scrip of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling Ropeway Company Ltd., GBL Industries Ltd. and Vishal Fabrics Ltd.

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling were circulated through SMSs and certain websites were also used to recommend buying four out of five aforesaid scrips (except Vishal Fabrics Limited), as detailed below: Table No. 2

Sl. No. Scrip SMS circulation period SMS ID and website involved*

1 Mauria Udyog Ltd. 21.09.2019 to 27.12.2019 www.midcapgains.in and SMS 2 7NR Retail Ltd. 11.11.2019 to 27.12.2019 headers viz. BT-ZROHDA, BZ- 3 Darjeeling Ropeway 23.12.2019 to 27.12.2019 MGAINS, BT-ICISEC and BH- Company Ltd. MGAINS 4 GBL Industries Ltd. 15.01.2019 to 31.01.2019 www.mbstocks.in and SMS headers MB-STOCK and MD- MULTIB 5 Vishal Fabrics Ltd. 07.09.2020 to 20.10.2020 QP-BGAINS

* It is clarified that SMS were sent not only from the aforesaid SMS IDs but also from other SMS IDs and aforenamed websites may not be the only one used for recommending buying the scrips. Identity of SMS Sender –IDs- BT-ZROHDA, BT-MGAINS, BH-MGAINS, BT-ICISEC, MB- STOCK, MD-MULTIB, QP-BGAINS 7. Bharat Sanchar Nigam Limited (hereinafter referred to as “BSNL”) was Telecom Service Provider (hereinafter referred to as “TSP”) of sender IDs BT-ZROHDA, BT- MGAINS, BH-MGAINS and BT-ICISEC and MTNL was TSP of MB- STOCK and MD- MULTIB. As per the submissions made by BSNL, the aggregators and resellers during the investigation, it is observed that Awadh Info Pvt. Ltd. (hereinafter referred to as “Awadh Info”), Spark TG Pvt. Ltd. (hereinafter referred to as “Spark TG”) and Newrise Technosys Pvt. Ltd. (hereinafter referred to as “Newrise”) were the resellers who dealt with the clients on behalf of TSP for sending SMS from these IDs. HFCL Infotel was TSP for QP-BGAINS. As per submissions of HFCL Infotel and telemarketers, it was seen that Popular Softtech was the reseller who had dealt with the client. 8. For convenience and better appreciation, details of information submitted by BSNL, aggregators and resellers are summarized in the table below:

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling

Table No. 3 Details As submitted by As submitted by As submitted by As submitted by Awadh Info Spark TG Newrise Popular SoftTech

Certificate Multibagger Multibagger Multibagger Multibagger user Securities Securities Securities Securities Client Name Hanif Khan Vishal Vishal/Hanif Vishal Shah Kasambhai Shekh Contact E-hkshekh@yahoo.co midcapgains@gmail dgfinindia@gmail. midcapgains@gmail mail .in .com com .com Contact No. 9157787756 9537570268 8511591152 / 9537570268 used for 9067584982 9157787756 9067584982 9157787756 communicat 9537570268 ion 8511591152 Payment Money deposited Money deposited Money deposited Money deposited details through cash through cash through cash through cash Period September 2019 to October 2019 to January 2019 September 2020 to December 2019 December 2019 October 2020

In order to ascertain the person who was running the operations of the Certificate User viz: Multibagger Securities, focus was laid upon the mobile numbers which were found to have been given to all the Resellers by the said Certificate Users. The table below identifies the commonality amongst the contact mobile numbers of the Certified Users as shared by the resellers with SEBI and the person owning the said mobile numbers: Table No. 4 Mobile Owner of the Evidence Number Mobile Number 9067584982 Hanif Shekh 1. In UCC details of PAN - CBEPS9710A (Hanif Shekh) maintained with BSE and NSE, mobile number and email id is mentioned as ‘9067584982’ and ‘hkshekh@yahoo.co.in’ respectively. 2. Hanif Shekh in his electronic or otherwise correspondences with SEBI uses - hkshekh@yahoo.co.in as his email address. He accepted that mobile number 9067584982 and e-mail id -hkshekh@yahoo.co.in’ is used by him. 3. Hanif Shekh has e-mailed from hkshekh@yahoo.co.in to Awadh Info on January 29, 2014 for bulk SMS services.

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling

Mobile Owner of the Evidence Number Mobile Number 4. For most of the times tower location of 9067584982, 9537570268 and 8511591152 was found to be the same which is similar to the 2 address of Hanif Shekh. 5. As per the submission of Interglobe Aviation Limited (“Indigo Airlines”), traveler with name Hanif Shekh has made bookings with E-mail id – hkshekh@yahoo.co.in, dgfinindia@gmail.com, smartfno@gmail.com and mobile numbers – 9067584982, 9537570268 and 8511591152. 6. As per submission of Yahoo, smartfno@gmail.com is recovery e-mail of hkshekh@yahoo.co.in. 9537570268 Hanif Shekh 7. In the account opening form of Sai Metaltech LLP with Oriental Bank of Commerce (now merged with PNB), mobile number – 9537570268 is provided which has signature of Hanif Shekh, who is one of the partners of Sai Metaltech LLP. 11. 9537570268 have same IMEI number as that of 8511591152 (another number of Hanif Shekh) for some period. 12. For most of the times tower location of 9067584982, 9537570268 and 8511591152 was found to be is the same which is similar to the 2 address of Hanif Shekh. 13. As per information and documents provided by Makemytrip Pvt. Ltd., mobile numbers – 9537570268, 8511591152 and email-id - hkshekh@yahoo.co.in/smartfno@gmail.com were used by customer named Hanif Shekh for booking hotels during the period September 2019 to March 2022. 14. As per submission of Interglobe Aviation Limited (“Indigo Airlines”), traveller with name Hanif Shekh has made bookings with E-mail id – hkshekh@yahoo.co.in, dgfinindia@gmail.com, smartfno@gmail.com, Hanif@bansalonline.com and mobile numbers – 9067584982, 9537570268 and 8511591152. During his statement recording in SEBI, Mr Hanif Shekh has accepted Hanif@bansalonline.com as his email ID. 15. As per submission of Swiggy, 9537570268 is registered with Name- Hanif with delivery address – Crescent Area, Bhavnagar, Gujarat – 364001 with Landmark as Near Gujarat Travels, Sir Pattani Road. According to CDR of 9537570268, user of said number has similar location for majority of the times. 8511591152 Hanif Shekh 16. 9537570268 and 8511591152 have same IMEI number for some period indicating that user of the two numbers have used same handset for some point of time.

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling

Mobile Owner of the Evidence Number Mobile Number 17. Forgot password of e-mail id - dgfinindia@gmail.com is linked with mobile number - 8511591152. 18. 8511591152 shares same tower location as 9537570268 and 9067584982 as per their CDRs. 19. As per submission of Interglobe Aviation Limited (“Indigo Airlines”), traveller with name Hanif Shekh has made bookings with E-mail id – hkshekh@yahoo.co.in, dgfinindia@gmail.com, smartfno@gmail.com and mobile numbers – 9067584982, 9537570268 and 8511591152. 20. As per information and documents provided by Makemytrip Pvt Ltd, mobile numbers – 9537570268, 8511591152 and email-id - hkshekh@yahoo.co.in were used by a customer, named Hanif Shekh for booking of hotels during the period from September 2019 to March 2022. 9157787756 Hanif Shekh 21. In the account opening form of Sai Metaltech LLP with SBI, mobile number – 9157787756 is provided and Mr Hanif Kasambhai Shekh, one of the partner of Sai Metaltech LLP, has signed on the very page wherein the mobile number- 9157787756 is appearing two times. 22. Zomato has submitted that a user registered as ‘Hanif’ holding mobile number- 9157787756 had placed multiple orders on its platform during the Nov-2020 to January-2021.

In majority of these orders, delivery address was ‘Near gujarat travels, sir pattani road, Bhavnagar’ (which is similar to the address provided by Mr Hanif Shekh during the statement recording). 23. Also on January 30, 2021 one of the orders placed by the user holding mobile number- 9157787756 was delivered to Double Tree Hotel having (Latitude: 23.0284391, Longitude: 72.50159863). Accordingly, the aforesaid hotel was requested to confirm whether any guest by the name Hanif Shekh/ Hanif Kasambhai Shekh stayed in the Double Tree Hotel, Ambli Rd, Vikram Nagar, Ahmedabad, and Gujarat 380058 on January 30, 2021. Hotel Double Tree by Hilton-vide email dated February 03, 2023 has inter alia informed that Hanif K Shekh and Yasminabanu S Pathan had checked into the aforesaid hotel on January 30, 2021 and checked out on January 31, 2021. Other details submitted by Hanif K Shekh and Yasminabanu S Pathan to Double Tree Hotel are - Mobile Number: 9067584982, Email id of Guest: SMARTFNO@GMAIL.COM, Identity Proof: Driving License. 24. During his statement recording, Mr Hanif Shekh has accepted 9067584982 as his mobile number.

Moreover, driving license (GJ04 200800338898) submitted by Double Tree

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling

Mobile Owner of the Evidence Number Mobile Number Hotel is matching with the driving license provided by Mr Hanif Shekh during statement recording. 9. The details as provided in the above table unequivocally highlight the strong commonalities that exist amongst the mobile numbers 9067584982, 9537570268, 8511591152 and 9157787756 in terms of location of the mobile numbers, common IMEI number, common email ids, and similar digital footprints (Indigo, Swiggy, Zomato, Makemytrip) etc. All the aforesaid factual details that are irrefutable, prima facie show that the owner of the aforesaid four mobile numbers, is none other than Mr. Hanif Shekh. To sum up the aforesaid factual evidences, the following figure succinctly captures the various parameters/factors based on which the identity of Mr. Hanif Shekh can be prima facie ascertained without any doubt: Figure No. 2

Digital footprints-Flight bookings (Indigo), Food delivery (Swiggy/Zomato), Hotel Stay(MMT), Gmail (Recovery-E-mail), Yahoo (Forgot password)

UCC and KYC details –Number CDR –Location, Common IMEI provided while opening Brokerage Hanif Number, Call record with resellers account and Bank account. Shekh and other accomplice. Signature in KYC

10. With respect to the websites i.e. www.midcapgains.in and www.mbstocks.in, the following is noted: www.midcapgains.in (Active: - October 2019 to September 2020) 10.1. The aforesaid website was registered in the name of First Economy Pvt. Ltd. (hereinafter referred to as the “FEPL”). FEPL in its replies has submitted that it is a digital marketing agency specializing in media planning and buying,

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling website and mobile app development. One person, named Mr. Rohit Jain approached them for the aforesaid website development and for advertisement of the said website on Moneycontrol website. No KYC or agreement was entered into by FEPL with the person named Mr. Rohit Jain. 10.2. It is noted from the submissions of FEPL that the website was advertised on the Money control website and through which customers would land on the customer registration page of the website, www.midcapgains.in. Once the customer registers himself on the website, he would start getting recommendations to buy the aforesaid scrips, except GBL Industries Ltd. 10.3. The records reflect that the website owner was using the mobile number 9537570268 and the email id, midcapgains@gmail.com for communication with FEPL. www.mbstocks.in 10.4. As per information submitted by GoDaddy, the website (www.mbstocks.in) was created on December 29, 2018. The contact details of the registrant (Shopper-ID:193051104) for the website, www.mbstocks.in was, dgfinindia@gmail.com and the same email id was used for communication purpose by the website owner. 10.5. It is also noted that the email id dgfinindia@gmail.com is linked with mobile number 8511591152. 10.6. The records reflect that the website was used for sending buy recommendations in the scrip of GBL Industries Ltd. 11. It has already been prima facie observed in the preceding paragraphs that mobile numbers 9537570268 and 8511591152 are owned by Mr. Hanif Shekh. Further, the email id, dgfinindia@gmail.com as noted above has been used by Mr. Hanif Shekh for his transaction with Indigo Airlines and also was provided to the reseller i.e., Newrise while the other email id, i.e. midcapgains@gmail.com was provided by him to the resellers, viz: Spark TG and Popular SoftTech while transacting with them. Therefore,

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling it can be prima facie observed that Mr. Hanif Shekh is the owner and was closely connected with the management of two websites viz: www.midcapgains.in and www.mbstocks.in. Further, it is observed from the findings of the investigation that payment with respect to the website creation and development of www.midcapgains.in was received by FEPL from one proprietary firm, Sambhavanath Traders having HDFC Bank Account No. 50200027909681. As in any kind of commercial transaction, the consideration for owning any kind of property comes from the owner and / or his connected entity. Thus, as noted above prima facie Mr. Hanif Shekh is the owner of the aforesaid two websites and since the payment for the creation and operation of the said websites has come from Sambhavanath Traders, it can be prima facie inferred that both Mr. Hanif Shekh and Sambhavanath Traders (Proprietor – Mr. Chandraprakash Valchand Parekh) are connected with each other. In other words, by making the payment to operationalise the website, www.midcapgains.in, which was used to send buy recommendations in the scrips except GBL Industries Ltd., Sambhavanath Traders has played a decisive role in the prima facie scheme employed in the said scrips (as discussed in subsequent paragraphs) by Mr. Hanif Shekh and / or Promoters of the Companies, wherever applicable. 12. Once the identity of the person who was dealing with the resellers and who was the owner of the aforesaid two websites has been prima facie determined to be Mr. Hanif Shekh, the following circumstances / documentary evidence prima facie lead me to the finding that it was Mr. Hanif Shekh who was actively involved in sending the bulk SMSs and operating the aforesaid two websites: 12.1. Call Data Records (hereinafter referred to as “CDRs”) in respect of mobile number 9537570268 confirms calls exchanged between Mr. Hanif Shekh and Awadh Info (9838585569 and 7311111641) and Spark TG (97179397366) during the relevant period. 12.2. Screenshot of WhatsApp Chat between person having mobile number 9537570268 (Mr. Hanif Shekh) and Awadh Info, regarding Sender-IDs, content

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling of message related to Mauria Udyog Ltd., were found to be similar to those messages received by the complainants who have produced those messages in their complaints. 12.3. From the screenshot of WhatsApp chats/calls between the representative of Popular Softtech (9930447726) and mobile number- 9537570268, it is observed that Mr. Hanif Shekh is asking for credit of 3 lakh SMSs in his account and there are multiple WhatsApp calls between these above two mobile numbers on September 22, 2020 and October 07, 2020. 12.4. Documents provided by Spark TG regarding chats with mobile number 9537570268 (Mr. Hanif Shekh) asking for missed call service and SMS content was also similar to those received by complainants. 12.5. Screenshot of WhatsApp Chats between person having mobile number 8511591152 (Mr. Hanif Shekh) and Awadh Info regarding advertisement of midcapgains.in on Moneycontrol website, stating that their advertisements were directly running on Moneycontrol as well. The same has also been submitted by FEPL, who created the website of www.midcapgains.in and ran advertisement of www.midcapgains.in on Moneycontrol. 12.6. Link of the website, www.midcapgains.in was sent both through SMS and through advertisement on Moneycontrol website, prima facie showing that both the SMS sender and website owner are connected with each other. 13. In the light of the aforesaid factual revelations, it can be prima facie inferred that Mr. Hanif Shekh was not only involved from the very beginning of creation of multiple SMS sender IDs as well creation of websites but was also involved in actively managing the operation of sending bulk SMSs and also managing those websites. In other words, Mr. Hanif Shekh is prima facie the person found to be responsible for the creation, development and management of websites, www.midcapgains.in and www.mbstocks.in and is also responsible for circulation of SMSs from the sender-IDs such as - BT-ZROHDA, BZ-MGAINS, BH- MGAINS, BT-ICISEC, MB-STOCK, MD-MULTIB and QP-BGAINS etc. from which Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling

SMSs with buy recommendations were sent out in favour of the scrips of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling Ropeway Company Ltd., GBL Industries Ltd. and Vishal Fabrics Ltd. Therefore, in the present matter, it is prima facie observed that Mr. Hanif Shekh is the “SMS Sender” and the websites owner. Further, it is observed from the aforementioned multiple SMSs sender IDs that were prima facie owned and used by Mr. Hanif Shekh, that some of these ID names mimic the names of certain reputed stock brokers such as Zerodha Broking Ltd., ICICI Securities, etc. The aforesaid act of imitating and surreptitiously misusing the names of reputed brokerage houses to create similar sounding sender IDs cannot be a coincidence and prima facie has to be by design as Mr. Hanif Shekh apparently has no connection with the afore-stated brokerage houses. Therefore, the sole purpose of using the said nomenclatures to create such sender IDs was prima facie to bring more credibility to the buy recommendations that were prima facie circulated by him considering the stature and huge number of retail investors associated with these brokerage houses.

At the outset, such a cunning move by the SMS Sender reveals how well thought of the scheme was that was prima facie employed by Mr. Hanif Shekh wherein, he alongwith his connected entities have not only tried to prima facie manipulate the volumes and prices in the scrips (discussed in subsequent paragraphs of this Order) but have also by impersonating the reputed brokerage houses, deliberately attempted to trick the investors to believe in the growth potential and investment opportunities in the scrips, by sending such bulk SMSs from such mimicked sender IDs, therein giving ‘buy recommendations’ in favour of such scrips. PV Influencers, Collaborators and Off Loaders 14. Moving on to the next crucial step to unravel the prima facie scheme, the roles enacted by entities who have, played the role of the PV Influencers, certain entities who also have acted as Collaborators and the Off Loaders of shares, in the prima facie fraudulent trades that were witnessed in the aforementioned five scrips need to be discussed and prima facie determined. For the sake of clarity, the roles played by these Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling separate categories of players who have discharged their respective parts as assigned to them under the prima facie scheme, have been examined scrip wise, in the following sections of this Order.

Mauria Udyog Ltd. 15. Mauria Udyog Ltd. (hereinafter referred to as “MUL / Company”) is the company which is involved in the manufacturing and export of LPG cylinders, valves, regulators and related accessories. MUL got listed on BSE on July 14, 2015. It is noted from the Price volume data available on the BSE website, the first trade that was executed in the scrip was on January 27, 2017. Thereafter, there was a sustained increase in the price and volume of the scrip till September 20, 2019. During the period of January 27, 2017 to September 20, 2019, the scrip opened at INR 10.20 reached a high of INR 300 and closed at INR 255.45 with an average volume of 9,423 shares. The relevant Price – Volume chart in the scrip is depicted below: Figure No. 3

16. As can be seen from the above that price of the scrip increased by 25 times by September 20, 2019 from the price level noticed in January 27, 2017. Further, as can be seen from the aforesaid Price – Volume chart that during the period September 2019 to December 2019, there was a marked increase in the price and volume of the scrip with a high of INR 412.10/- and an average volume of 1,63,738 shares. During the entire period i.e., January 27, 2017 to December 27, 2019 (hereinafter referred to as “Investigation Period - MUL”), it is also noted that there were hardly any major

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling corporate announcements made by the Company or any major change in Company’s earnings (rather net loss of INR 12.65 crore was shown in the quarter ended September 2019) or revenue increase (rather revenue decreased by 35% in September 2019 quarter compared to previous quarter). Therefore, in the absence of any fundamental change in the operations or financials of the Company, the sustained rise in the price and volume of the scrip as noted above, certainly raised bonafide suspicion for conducting an investigation. 17. The aforesaid suspicion was further strengthened from the fact that bulk SMSs with buy recommendations were sent in the scrip and the website, www.midcapgains.in was used to send buy recommendations in the scrip which, as discussed in subsequent paragraphs, prima facie had a substantial impact on the price and volume of the scrip. The SMSs had started circulating in the scrip from September 21, 2019 onwards. Considering that the circulation of bulk SMSs and the use of the aforesaid website was the central focal point to the prima facie scheme employed in influencing the trading in the scrip, the trades in the scrip was examined for both, during the pre-SMS period (January 27, 2017 to September 20, 2019) as well as during the SMS period (September 21, 2019 to December 27, 2019). PV Influencers Group 1 18. It was noted that the following group (collectively referred to as “Group 1”) of connected entities was frequently trading in the scrip of MUL during the period January 27, 2017 to September 20, 2019 i.e., during the pre- SMS period: Table No. 5 Sl. No Entity Name Connection amongst different entities of the group based on following facts 1. Piyush 1. Piyush Agarwal and Sapan Kumar Agarwal are partners of a CA firm Agarwal MKSKA & CO. 2. Juscorp 2. Juscorp Enterprises Pvt Ltd (“Juscorp”) and Vepar Solutions Pvt Ltd Enterprises (“Vepar”) have same address as that of MKSKA & CO – “207, D.R.

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling

Sl. No Entity Name Connection amongst different entities of the group based on following facts Private Chambers, D.B. Gupta Road, Karol Bagh, New Delhi – 110005”. Vepar is a Limited company of Piyush Agarwal and Juscorp is a company of Sapan Kumar Agarwal. 3. A1 Solutions- Prop-Ajju 3. E-mail id of Sapan Kumar Agarwal (agarwal.sapan@ymail.com) is given Kumar for Juscorp on MCA and wife of Sapan Kumar Agarwal- Supriya Agarwal is one of the directors of Juscorp. 4. Corredor Services 4. Shyam Kumar Singh has multiple bank transactions with Sapan Kumar Private Agarwal and MKSKA & Co. He has an account in the same branch of PNB Limited as Sapan Kumar Agarwal. Shyam Kumar Singh is the authorised signatory of Corporate First (proprietorship) which has the same address as that of 5. Sapan Kumar MKSKA & CO and Juscorp. Agarwal 5. Common Mobile Number (9540649579) is provided in the UCC of 6. Vepar Shyam Kumar Singh and Orion Ventures Pvt Ltd where Supriya Agarwal, Solutions wife of Sapan Agarwal has 50% shareholding. Private Limited 6. Corredor Services Pvt Ltd has Shyam Kumar Singh (DIN 07752726) as one of the Directors. Corredor Services Pvt Ltd has multiple bank 7. Shyam Kumar transactions with Juscorp and MKSKA & CO. Singh 7. Multiple fund transfer between A1 solutions and Piyush Agarwal, Corredor Services Pvt Ltd, Juscorp Enterprises Ltd, Shyam Kumar Singh, MKSKA&CO. 8. MKSKA & CO, Corredor, Juscorp and Vepar have transactions with entity K.M. Enterprise. Proprietor of KM Enterprise is also a friend of one of these entities (Piyush Agarwal- Partners of MKSKA & Co). KM Enterprises has financial transaction with Forex companies (Sub-group 6) Hanif entity- Samukh Trade (Sub-group 2.A). (discussed in subsequent paragraphs). 9. There is an e-mail communication between DK Gupta and Deepak Kumar Garg – staff of Mauria Udyog Ltd to which an excel file is attached (Contractor Shares-1.xlsx) regarding shares sold by the Mauria employees and payment to be made to the two entities, namely Piyush and Malay during the same period when SMS were being circulated. 8. Kamal Gupta 11. Sl Nos. 8,9,10 and 11 have bank transactions with each other and Huf MKSKA & Co and entities at Sl No. 3 and Sl No.7. 9. Chinnu 12. Kamal Gupta and Piyush Agarwal are friend as per their submissions.

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling

Sl. No Entity Name Connection amongst different entities of the group based on following facts 10. Gyanendra Gharti Chhetri 11. Aayush Tanwar

19. It is noted from the above table that the aforesaid 11 entities are inter alia connected with each other either by way of common directorship or having common address or having multiple fund transactions amongst themselves. For instance, Juscorp and Vepar share common address i.e. “207, D.R. Chambers, D.B. Gupta Road, Karol Bagh, New Delhi – 110005”. Further, multiple fund transfers have been observed between A1 solutions (IndusInd Bank Account No. and ICICI Bank Account No.), Mr. Piyush Agarwal (SBI Bank Account No. 55151455822), Corredor Services Pvt. Ltd. (ICICI Bank Account No. 678205600410), Juscorp (ICICI Bank Account No. 629105046965), Mr. Shyam Kumar Singh (PNB Bank Account No. 0619000100190252). The afore-noted factual findings prima facie show the strength of their inter se connections and when the above noted close connections are seen and examined in the backdrop of the peculiar pattern of trading followed by these entities in the scrip of MUL where, these entities have been observed to be trading in a concerted manner and have further been seen to be posing as counterparties to each other’s trades in the scrip of MUL during the period from January 27, 2017 to September 20, 2019, they would prima facie demonstrate that the very fact of these connected entities coming together in the securities market to deal in the scrip of MUL in unison and in a concerted manner was not a mere happenstance. 20. As per the findings of the investigation, contribution of aforesaid 11 group members to the price and volume rise in the scrip of MUL during the period January 27, 2017 to September 20, 2019 was, as shown in the table below:

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling

Table No. 6 Sl. No Entity Name Buy Qty % Buy Sell Qty % Sell Net Buy Net Sell Total LTP % to total to total LTP LTP Contributio Market Market n to Net Buy Sell Price Rise Volume Volume 1. A1 Solutions 483761 9.63% 435017 8.66% 121.74 -32.62 89.12 36.34% Prop. Ajju Kumar 2. Piyush 400631 7.98% 339724 6.76% 57.65 -173.35 -115.7 -47.18% Agarwal 3. Shyam Kumar 251808 5.01% 208327 4.15% 509.3 54.01 563.31 229.69% Singh 4. Chinnu 173103 3.45% 160797 3.20% 234.65 -23.15 211.5 86.24% 5. Corredor 152015 3.03% 147410 2.93% 37.55 -28.35 9.2 3.75% Services Private 6. Sapan Kumar 142565 2.84% 116947 2.33% -273.85 0.3 -273.55 -111.54% Limited Agarwal

7. Kamal Gupta 119066 2.37% 108290 2.16% 37.8 -44.65 -6.85 -2.79% Huf 8. Aayush 102155 2.03% 102155 2.03% 35.95 477.9 513.85 209.52% Tanwar 9. Vepar 91211 1.82% 78100 1.55% 12.6 8.65 21.25 8.66% Solutions Private 10. Juscorp 51212 1.02% 36397 0.72% -141.95 16.3 -125.65 -51.23% Limited Enterprises Private 11. Gyanendra 37371 0.74% 36420 0.73% 201 88.4 289.4 118.00% Limited Gharti Chhetri Total 2004898 39.92% 1769584 35.22% 832.4 343.44 1175.88 479.46% Trading directly 872744 17.38% 872744 17.38% 906.45 906.45 369.60% among the group Market Total 5022692 100% 5022692 100% 245.25 245.25 245.25

21. As can be seen from the above table, these 11 connected entities while acting as a group have prima facie contributed 39.92% to the market buy volume and 35.22% to the market sell volume and also have contributed 17.38% of the total market traded volume, by trading with each other as a group in the scrip of MUL. The trades of the aforesaid connected entities were also further analysed to determine as to how the Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling said connected entities were trying to influence the volume and price in the scrip so as to create artificial exuberance in the market thereby projecting the scrip of MUL a potentially attractive proposition for the investors in the securities market. Some illustrations to that effect are as follows: 21.1. On June 3, 2019, Mr. Sapan Kumar Agarwal had placed 25 different buy orders (order numbers from 1559532600002658026 to 1559532600002658050) for 10 shares each in the scrip of MUL at the price of INR 205/- per share (when LTP was INR 255.8/-). All such orders were placed on the stock exchange system at 9:15:00 hours.

Subsequently, Mr. Aayush Tanwar who is part of the connected group, had placed a sell order (order number 1559532600002658051) for 250 shares in the scrip of MUL for INR 254.8/- per share at 9:17:36 hours (when LTP was INR 255.8/-). In order to match the aforesaid sell order, the 25 buy orders earlier placed, were modified by Mr. Sapan Kumar Agarwal after 1 second of the aforesaid sell order was placed i.e. at 9:17:37 hours, so as to match the price of the sell order i.e. INR 254.8/-. The aforesaid actions on the part of Mr. Sapan Kumar Agarwal led to matching of 1 sell order of 250 shares with 25 different buy orders for 10 shares each at similar price of INR 254.8/- per share. Thus, by trading in such a manner the entities effected change of hands of 250 shares from Mr. Aayush Tanwar to Mr. Sapan Kumar Agarwal, which could have been otherwise done in a single trade as well had Mr. Sapan Kumar Agarwal initially placed a single buy order for 250 shares at one go instead of placing 25 separate buy orders for 10 shares each. However, by executing a trade for 250 shares of MUL through 25 trades the said two entities have consciously and artificially created a volume through first 25 trades in the scrip on that particular day.

It is noted that during the period when the above trades were being executed the average daily trading volume in the scrip was around 9,400 shares which shows that the liquidity in the scrip was relatively less. In this scenario, placing a buy order of 250 shares which is around 2.5% of the average daily trading volume, at a price (INR 254.8/-) which was far away from the LTP (INR 255.8/-) by at least

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling

24%, not only prima facie shows a non-genuine trading behaviour but also prima facie shows that the entities were trying to artificially influence the liquidity / volume in the scrip. The aforesaid acts of the two connected entities when seen along with the fact that the buying entity immediately changed (within few seconds of placement of sale order) his buying price upwards by approximately INR 50/-, only to match the sell order placed by his connected entity and further, the act of the seller entity who is supposed to act prudently on the principle of trying to get the highest price possible for his shares offering his shares to sell even below the LTP prima facie shows that these connected entities were basically trying to artificially create a positive momentum in the scrip. It is further noted that Mr. Aayush Tanwar who was thus seen to be a seller in the first 25 trades of the day, again accessed the securities market on the same day i.e. on June 3, 2019 by placing one buy order (order number 1559532600002658107) for 250 shares in the scrip of MUL at the price of INR 250.8/- per share at 10:29:25 hours (when LTP was INR 252.4/-), which were again, matched by 25 different sell orders (order numbers from 1559532600002658073 to 1559532600002658097) for 10 shares each placed by another connected group entity viz. Mr. Shyam Kumar Singh at the price of INR 250.8/- per share ignoring the fact that the LTP in the scrip was INR 252.4.

It is important to note here that initially 25 sell orders were placed by Mr. Shyam Kumar Singh at a price of INR 300/- per share between 10:09:36 hours to 10:10:54 hours (when LTP was INR 252.4/-). However, as soon as a buy order for 250 shares was placed by Mr. Aayush Tanwar at 10:29:25 hours, the 25 sell orders were modified by Mr. Shyam Kumar Singh at the same time at 10:29:25 hours by modifying earlier sell price of INR 300/- per share downwards to INR 250.08/-, in order to match the buy order of Mr. Aayush Tanwar. This resulted in execution of another 25 trades on that particular day. From the above illustration it can be seen that, similar to the first illustration, buy / sell orders were first placed by the connected entities at prices away from the LTP and such orders were modified when a counter order was placed by the Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling connected entity, only in order to match the price of the counter party order, and to execute the said order into a trade. 22. I note from the order log and trade log that the aforesaid instances are not the only instances when the PV Influencers have traded in such unusual pattern as illustrated above.

There are multiple such instances of trades during the period from January 27, 2017 to September 20, 2019 through which the said connected entities have prima facie influenced the volume in the scrip. It is however observed that the aforesaid method is not the only modus operandi employed by the connected entities to prima facie create artificial trading volume in the scrip though this was the most frequently used method. A pre-determined plan of the PV Influencers to create artificial volume in the scrip of MUL becomes prima facie evident when the trades executed by these connected entities are juxtaposed with the total trades executed in the scrip during the pre-SMS period. As per the available records, it is noted that the PV Influencers have prima facie created artificial volume of 35.22% out of which 17.38% has been created by directly trading by the group members amongst each other and the remaining 17.84% volume has been created when at least one of the aforesaid connected entities was on either side of a trade. Upon further examination of the trading activities of the said connected entities, it was further observed that although the connected entities had created substantial volume in the scrip during the aforesaid period, in effect only 4.7% (39.92% - 35.22%) of their traded volume during the said period had actually resulted in change of beneficial ownership while the remaining 35.22% of traded volume was created deliberately, just to create a prima facie artificial volume with no change in effective beneficial ownership i.e., the ownership of the shares stayed within the group.

23. It is further noted from the available records that the PV Influencers have not only prima facie created artificial volume in the scrip of MUL but were also prima facie instrumental in creating artificial price in the said scrip. During the pre-SMS period i.e., from January 27, 2017 to September 20, 2019 the said connected entities while acting as a group have contributed INR 906.45/- to the net positive LTP in the scrip of MUL by trading amongst each other in 11,511 trades with a total volume of 8,72,944

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling shares (17.38% of total market volume). Further, out of the above mentioned 11,511 trades, in 8,643 trades (75.08% of total group trades) it is observed that the time difference between placing of buy orders and sell orders was equal to or less than 60 seconds and such trades have resulted in contribution of INR 842.70/- to the net positive LTP involving 6,34,096 shares (12.62% of total market volume) that were traded by these 11 entities. Upon further scrutiny of the trading activities of the PV Influencers, it was noted that in 7,543 trades (65.52% of total group trades), the time difference between buy orders and sell orders was equal to or less than 10 seconds and such trades have resulted in contribution of net LTP of INR 721.85/- involving 4,91,717 shares (9.78% of total market volume) that were traded by these 11 entities. A few illustrations showing prima facie synchronised trades in the scrip by the said connected entities are also shown herein below: 23.1. On July 2, 2019, Mr. Shyam Kumar Singh had placed a buy order (order number 1562038200002072025) for 400 shares of MUL at 09:31:56 hours at a price of INR 150/- (previous day’s LTP was INR 180/-) and Mr. Aayush Tanwar had placed a sell order (order number 1562038200002072027) for 50 shares at 09:35:04 hours at INR 194/-.

Within next 3 seconds of the afore-stated sell order placed by Mr. Aayush Tanwar, i.e. at 09:35:07 hours, the buy order placed by Mr. Shyam Kumar Singh was modified and the modified price was INR 194/- and the modified quantity was 50 shares. Consequently, the buy and the sell orders matched resulting in creation of positive LTP of INR 14/- (7.78% higher than the previous LTP). Interestingly, this was the 1st trade of the day. 23.2. On July 04, 2019, Mr. Sapan Kumar Agarwal had placed a buy order (order number 1562211000002044029) for 20 shares of MUL at 09:15:24 hours at a price of INR 163/- (previous day’s LTP was INR 190/-) and Mr. Aayush Tanwar had placed a sell order (order number 1562211000002044031) for 100 shares at 09:16:22 at INR 209/-. Within next 5 seconds of the afore-stated sell order placed by Mr. Aayush Tanwar, i.e. at 09:16:27 hours, the buy order placed by Mr. Sapan Kumar Agarwal was modified and the modified price was INR 209/-. Consequently, the buy and the sell orders matched resulting in creation of Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling positive LTP of INR 19 (10% higher than the previous LTP).

Interestingly also, this was the 1st trade of the day. The aforesaid illustration when seen in the light of the fact that approximately 65% of the trades (7,543 trades) executed within the said group, were executed within 10 seconds, which not only resulted in net LTP of INR 721.85/- but also represented approximately 10% of the market volume, which demonstrates not only the repeated nature of the transaction that was prima facie synchronised in nature but also strongly points to prior meeting of minds amongst the said entities to conduct their trades in such unusual manner. It is also observed from the details of the trades executed by the said group that despite there being an anonymous trading system on the exchange platforms, matching of such large number of trades between the same connected parties on the said trading system could not have fructified, unless the trading system was being shrewdly abused. It is further pertinent to note that prima facie such types of abnormal trading pattern lead to unwarranted price fluctuation and creates a false appearance of trading in the securities market and thereby tending to mislead the investors.

In other words, the execution of buy and sell orders within the group, the volume created therefrom and the proximity of time between the buy orders and sell orders as noted above prima facie show the deceptive behaviour of the PV Influencers to play the market in a pre-ordained unscrupulous manner only for the purpose of increasing the price and the volume and thereby to create an artificial picture of large scale dealings in the scrip of MUL. SMS Period 24. Once a momentum was generated in the scrip by dealing in the scrip of MUL in the aforesaid unusual manner as illustrated above, so as to maintain the price and volume in the scrip at a sustainable level, the next leg of the prima facie scheme that is discernible from the investigation comes into play by way of sending out bulk SMSs in favour of the scrip with buy recommendations to the public at large including using the website to give buy recommendation in the scrip. In the SMS headers related to scrip of MUL, it was observed that the SMS from the header BH-MGAINS were sent to Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling

61,960 unique mobile numbers and from the header BT-MGAINS SMS were sent to 752 unique mobile numbers during the period of September 21, 2019 to December 27, 2019 i.e., SMS Period. A few sample SMS texts that were circulated in respect of the said scrip and its prima facie impact on volume and price in the scrip of MUL, are indicated in the table below: Table No. 7 Sl. SMS Sample SMS Text Date of % volume % price increase No. Header SMS increase from from previous circulation previous trading trading day day 1. BT- Multi- Bagger Buy October 29, 1,37,648 shares Weighted Average MGAINS MAURIA UDYOG 2019 traded on October price on 27-Oct-2019 LTD 29, 2019 from was INR 296.64/- and (B.S.E. Code 31,219 shares the scrip touched the 539219) For traded on October high of INR 301.05/- -INTRA-DAY Target 27, 2019 i.e. on 29-Oct-2019 i.e. 301+ increase of the scrip witnessed a -This Week Target 340.91%. movement of approx. 310++ 1.5% in its price. FINAL Target 1000+ 2. BH- BUY/ADD More December 6,05,036 shares Weighted Average MGAINS MAURIA UDYOG 19, 2019 traded on 19-Dec-price on 18-Dec-2019 (539219) 2019 from was INR 388.43/- and -NEXT WEEK Target 5,39,963 shares the scrip touched the 425+ traded on 18-Dec-high of INR 395.05/- -INTRA-DAY Target 2019 i.e. an on 19-Dec-2019 i.e. 395+ increase of the scrip witnessed a -FINAL Target 12.05%. movement of 1.7% in 1000+ its price. N.S.E. LISTING in 12 DAYS-BUY MAXIMUM QUANTITY RIGHT NOW Thus, from the aforesaid table it can be seen that there has been a marked increase in the volume of the scrip noticed immediately on the next day of sending of the SMS including an upward movement in the price of the scrip. It is further observed from the records that there has been 1638% increase in the volume of the scrip during the SMS period vis-à-vis pre-SMS period. The price in the scrip also touched a high of INR

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling

412.10/- during the SMS period as compared to the closing price of the pre-SMS period which was INR 255.45/- i.e., there was a 61.32% spike in the price of the scrip. The aforesaid figures prima facie accentuates the role played by the bulk SMSs in luring the investors to deal in the scrip. The records reflect that the circulation of bulk SMSs and the use of the website to give buy recommendations was not a solitary instance and was frequently used during the SMS period by using different sender IDs. The same had a noticeable impact on the price and volume movement in the scrip. Apart from sending scrip specific recommendation in scrip of MUL, automatic messages were also received from calling on missed call service number. Sample of SMS text received from calling missed call service number (926667330) is shown below: “Thank You For Joining Us For MULTI-BAGGER Stock 2019. Our Executive Will Call You Soon. Please Check Our 100% Successful PAST PERFORMANCE on www.MidcapGains.in” Collaborators Group -2 25. It is noted from the records that around the time when the bulk SMSs in the scrip had started circulating (September 21, 2019 to December 27, 2019), another group of connected entities (hereinafter referred to as “Collaborators”), as shown below were observed to be frequently trading in the scrip of MUL:

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling

Table No. 8 Sl Entity Name Connection with each other as a group No 1. G oenka Business 1. There are fund transfers between Kalpesh Dantani, Shivam Kumar, Finance Limited Sanjaybhai Solanki, Amrutji Gokaji Thakor, Goenka Business and Finance Ltd and Director of Goenka Business and Finance Ltd, Yasin 2. K alpesh Dantani Abdul Sattar Ghori. There are multiple fund transfers between Sanjaybhai Solanki, Suresh Vaghela and Goenka Business and Finance 3. S hivam Kumar Ltd. There are multiple fund transfers between Suresh Vaghela and 4. S anjaybhai Babubhai Amrutji Thakor, Sanjaybhai Solanki. Solanki 2. Goenka Business and Finance Ltd and Kalpesh Dantani shared 5. C hetanbhai same mobile number – 7622002502 in their UCC details. Mahendrabhai Dantani 3. Kalpesh Dantani and Chetanbhai Dantani shared same mobile 6. S uresh Deshaljibhai number -8487887844 in their UCC details. Vaghela 4. Goenka Business and Finance Ltd and Sanjaybhai Babubhai Solanki traded with Sunflower broking as member. 7. A mrutji Gokaji Thakor 5. Malay Bhow of Sunflower broking and his wife Viral Bhow have had frequent bank transactions with Goenka Business and Finance Ltd. 6. Malay Bhow (Mob No. 9924920206) has frequent communications (call) with Hanif Shekh (Mob No. 9537570268). 7. There is fund transfer from Kailash Chouhan Contractor and Susheel Kumar Contractor of INR 7.41 lakh and INR 7.27 lakh, respectively to Kalpesh Dantani on 8/8/2019. Kailash Chouhan and Susheel Kumar are named in the list of employees (both permanent and contractual) as provided by MUL 8. There is e-mail communication between DK Gupta and Deepak Kumar Garg – employees of MUL where an excel file is attached (Contractor Shares-1.xlsx) regarding shares sold by the employees of MUL and payment to be made to two entities namely Piyush and Malay during the same period when SMS were being circulated. The above referred excel list also has details of payment made to Kalpesh Dantani.

26. For ease of reference, the connections that are found amongst the Collaborators are depicted diagrammatically as below:

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling

Figure No. 4

27. It is noted from the above table and the figure that the aforesaid 7 entities are inter alia connected with each other either by way of having multiple fund transactions amongst themselves or through common phone numbers or through common stock broker. For instance, Mr. Suresh Deshaljibhai Vaghela had received INR 5,00,000/- on February 18, 2019 and INR 1,00,000/- on July 26, 2019 from Mr. Amrutji Gokaji Thakor. Mr. Suresh Deshaljibhai Vaghela had also received INR 5,00,000/- on October 4, 2019 and INR 2,22,000/- on December 30, 2019 from Mr. Sanjaybhai Babubhai Solanki. Similarly, as per UCC details, Goenka Business and Finance Ltd. and Mr. Kalpesh Dantani have same mobile number viz. ‘7622002502’. It is further noted that in addition to the connection that existed amongst each other, some of these 7 entities are also connected to one more entity namely Mr. Malay Bhow, who is directly connected with Mr. Hanif Shekh (through phone calls as well as through his own admission during statement recording). Mr. Malay Bhow is closely connected with Goenka Business and Finance Ltd. For instance, Goenka Business and Finance Ltd. has frequent fund transfers with Mr. Malay Bhow and his wife, Ms. Viral Bhow. Further,

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling

Goenka Business and Finance Ltd. and Mr. Sanjaybhai Babubhai Solanki executed their trades in the scrip of MUL through Sunflower Broking wherein Mr. Malay Bhow is one of the Directors. It is further noticed that one of the aforementioned group of 7 entities, namely Mr. Kalpesh Dantani has fund transactions with employees of MUL and his name also appears in the excel sheet unearthed at the time of investigation from email id of Mr. Davinder Kumar Gupta (employee of MUL), which shows his connection with the employees of MUL. The aforesaid facts prima facie suggest the strength of their inter se connections and when these connections are seen along with the timing of their dealings in the scrip of MUL and the way the Collaborators (7 entities) have traded in a concerted manner inter alia by being counterparties to each other’s trades in the scrip of MUL during the SMS period (discussed in subsequent paragraphs), would prima facie demonstrate that the act coming in unison to trade together in the securities market in the scrip of MUL by these connected entities, was not a mere coincidence.

28. The trades executed by the Collaborators were examined during the SMS circulation period (September 21, 2019 to December 27, 2019). The summary of the trades executed by the aforesaid Collaborators group is shown below: Table No. 9 Sl. No % Buy to total % Sell to total Market Buy Sell Market Sell Entity Name Buy Quantity Volume Quantity Volume 1. Goenka Business Finance 806768 7.35% 806768 7.35% Limited 2. Kalpesh Dantani 452245 4.12% 454400 4.14% 3. Chetanbhai Mahendrabhai 294835 2.69% 299135 2.73% Dantani 4. Shivam Kumar 293773 2.68% 290323 2.65% 5. Sanjaybhai Babubhai 291075 2.65% 291075 2.65% Solanki

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling

Sl. No % Buy to total % Sell to total Market Buy Sell Market Sell Entity Name Buy Quantity Volume Quantity Volume 6. Suresh Deshaljibhai 207268 1.89% 164580 1.50% Vaghela 7. Amrutji Gokaji Thakor 185345 1.69% 184746 1.68% Total 2531309 23.08% 2491027 22.71% Trading directly among the Group 159197 1.45% 159197 1.45%

Market Total 10969187 100.00% 10969187 100.00% 29. As can be seen from the above table, the Collaborators while acting as a group have prima facie contributed 23.08% to the market buy volume and 22.71% to the market sell volume and 1.45% to the total market traded volume by trading amongst each other as group members in the scrip of MUL. The trades of the Collaborators were analysed and the prima facie pattern that had emerged therefrom showed that the said group of entities, by trading in the scrip were trying to artificially influence the volume in the scrip so as to maintain and carry forward the momentum of trading in the scrip that was already previously created by the PV Influencers as explained in earlier paragraphs, thereby presenting the scrip as an attractive proposition for the investors in the securities market. Few illustrations to support the aforesaid observation are as follows: 29.1. I note from the trade logs that the aforesaid 7 connected entities were trading in a peculiar manner where, at any given point of time during the first 1.5 months of the SMS period i.e., during September 24, 2019 to November 11, 2019, at least 2 entities from the group were accessing the market. Thus, it is observed that the Collaborators were forming small units of two entities at a given point of time and were taking turns one after another on different trading days during first 1.5 months of the SMS circulation period to deal in the scrip of MUL so as to ensure that there is a sustained trading activity in the scrip when the SMS had initially started circulating in the scrip, so as to prima facie ensure that the momentum that was previously created by the PV Influencers during pre-SMS

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling period continued unabatedly in the scrip. The aforesaid peculiar trading pattern followed by the collaborators is further highlighted below: Table No. 10 Date Goenka Kalpesh Shivam Sanjaybhai Chetanbhai Suresh Amrutji Business Dantani Kumar Babubhai Mahendrabh Deshaljibhai Gokaji Finance Solanki ai Dantani Vaghela Thakor Limited 24/9/2019 √ √ 25/9/2019 √ √ 26/9/2019 √ √ 27/9/2019 √ √ 30/09/2019 √ √ 1/10/2019 √ 3/10/2019 √ 4/10/2019 √ √ √ 7/10/2019 √ 9/10/2019 √ 10/10/2019 √ 11/10/2019 √ √ 14/10/2019 √ 15/10/2019 √ √ √ 16/10/2019 √ √ √ √ 17/10/2019 √ 18/10/2019 √ 22/10/2019 √ 23/10/2019 √ 24/10/2019 √ √ 25/10/2019 √ √ 27/10/2019 √ √ 29/10/2019 √ √

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling

Date Goenka Kalpesh Shivam Sanjaybhai Chetanbhai Suresh Amrutji Business Dantani Kumar Babubhai Mahendrabh Deshaljibhai Gokaji Finance Solanki ai Dantani Vaghela Thakor Limited 30/10/2019 √ √ 31/10/2019 √ √ 1/11/2019 √ √ 4/11/2019 √ √ 5/11/2019 √ √ 6/11/2019 √ √ 7/11/2019 √ √ 8/11/2019 √ √ 11/11/2019 √ √

In the light of the trading pattern as depicted in the above table and upon further analysis of the trade logs of the Collaborators, it is also noted that out of 64 trading days that the group has traded in the scrip of MUL during the SMS period, on 11 trading days, only 1 of the 7 entities has continuously traded in the scrip of MUL. Similarly, on 21 trading days, only 2 of the 7 entities have traded in the scrip of MUL. There was not a single trading day out of the aforementioned 64 trading days, when at least one of the members of the Collaborators has not traded in the scrip. The aforesaid trading behaviour adopted by the Collaborators prima facie exposes a premediated scheme employed by the Collaborators to deal in the scrip of MUL to serve an ulterior motive. 29.2. It is further noticed that the Collaborators mostly executed intra day trades in the scrip of MUL. It is further observed that on a majority of the occasions, similar amount of shares was sold and bought on the said trading day by such entities. It is noted from the records that the Company had weak fundamentals coupled with poor financials and there was absence of any major corporate announcement from the end of the Company during the relevant period.

In the aforesaid scenario, executing intra day trades of considerable volumes on a Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling regular basis in spite of continuously suffering losses, does not appear to be either a prudent or a genuine dealing in the scrip. In the instant matter, given the nature of the prima facie scheme appears to have been employed by these entities in the scrip, the act of the Collaborators / Group 2 entities to execute frequent intra day trades in the scrip irrespective of the outcome of such trades, was prima facie found to be intended to increase the number of trades in the scrip of MUL with an ulterior motive to demonstrate liquidity and high trading volumes in the scrip so as to induce the innocent investors to deal in the said scrip. Few of the instances where the aforesaid 7 entities have repeatedly executed intra day trades and have suffered losses during the SMS period are cited below: 29.2.1. For instance, on November 26, 2019, Mr. Kalpesh Dantani purchased 12,290 shares of MUL and sold a similar number of shares of MUL on the same trading day and incurred a loss of INR 10,751.9/-.

Further, he had purchased and sold similar quantity of shares on various trading days such as on November 21-22, December 2-3, 5, 9-13, 16-20 and 23, 2019 and in each of the aforementioned trading days, he had incurred losses in the range of INR 3,687/- to INR 59,497/-. 29.2.2. Similarly, Mr. Shivam Kumar had purchased 11,066 shares of MUL on December 2, 2019 and had sold similar number of shares of MUL on the same trading day. In the said process he had incurred a loss of INR 15,002.4/-. Further, he had purchased and sold similar quantities of shares on various trading days such as on November 14, 18, 19, 21, 25-29, December 2, 4-6, 10–13, 19-20 and 23-24, 2019 and in all the aforementioned trading days, he had incurred losses in the range of INR 973/- to INR 24,148/-. I note that the same trading pattern of buying and selling of similar number of shares on a particular trading day and incurring losses has been exhibited by other entities of the group as well and cumulatively, the Collaborators have

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling incurred losses to the tune of INR 52.17 lakh by trading in the scrip of MUL during the SMS period. 29.3. From a closer examination from the order / trade logs in the scrip of MUL during the SMS period, it is noted that these 7 entities, while dealing in the scrip of MUL, either as a buyer or a seller, have quite apparently and deliberately, placed orders for few shares. The said trading behaviour was followed prima facie to artificially create and show to the public continuous trading activities in the scrip as well as to demonstrate artificial liquidity in the scrip to induce the innocent investors to deal in the scrip. It is noted that out of 19,559 trades executed by 7 entities on buy side, in 3,809 trades (19.47% of total number of trades executed by 7 entities on buy side) the traded quantity was 10 shares or less than 10 shares. Similarly, out of 19,559 trades executed by 7 entities on buy side, in 5,232 trades (26.74% of total number of trades executed by 7 entities on buy side) the traded quantity was 20 shares or less than 20 shares.

Similarly, while acting as sellers in the scrip of MUL during the SMS period, it is noted that these 7 entities have cumulatively executed 20,933 sell trades and out of these 20,933 sell trades, in 6,758 trades (32.28%) the traded quantity was 10 shares or less than 10 shares. Similarly, out of 20,933 trades executed by 7 entities on sell side, in 8,753 trades (41.81%) the traded quantity was 20 shares or less than 20 shares. 30. In view of the aforesaid discussion and factual findings on the peculiar trading pattern adopted by the Collaborators, it is prima facie observed that such an abnormal trading pattern as noted in the trades executed by the Collaborators wherein they have frequently executed intra day trades in spite of incurring losses on a regular basis, coupled with the fact that the said entities during the first half of the SMS period, were dealing in the scrip of MUL by forming small sub groups on a rotational basis, when seen in conjunction with the timing of their dealing in the scrip along with their connections with Mr. Hanif Shekh, one comes to a prima facie conclusion that the afore described manipulative trading behaviour displayed by the Collaborators was mischievously intended to artificially inflate the trading volumes in the scrip of MUL

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling hence, such trading transactions of these entities do not inspire any confidence to suggest that their trades were ever executed in the normal and ordinary course of dealing in the scrip. 31. It is also observed that the aforesaid methods are not the only methods employed to prima facie create artificial volume in the scrip though this was the most frequently used strategy followed by the Collaborators. The pre-determined plan of the Collaborators to create artificial volume in the scrip becomes prima facie more evident when the trades executed by them are juxtaposed with the total number trades executed in the scrip during the SMS period. As per the available records, it is noted that the aforesaid connected entities have prima facie created an artificial volume of 23.08% on the buy side and 22.71% of trading volumes on the sell side. Upon further examination of the trading activities of the said connected entities, the extent of their dishonest intent behind executing those trades becomes more apparent. For example, though the connected entities had created substantial volumes in the scrip during the aforesaid period, however, in effect only 0.37% (23.08% - 22.71%) of their traded volumes during the said period resulted in actual change of beneficial ownership while the remaining 22.71% of trade volumes created by them was used just to create prima facie artificial volume without any intent to change/transfer the effective beneficial ownership i.e., the ownership of the shares always stayed within the group. It is further pertinent to note that prima facie such type of unusual trading pattern leads to creation of false appearance of trading in the securities market thereby tending to mislead the investors. In other words, the net effect of the overall buy and sell orders executed by the group as noted above and the trade volumes artificially created therefrom prima facie expose the true intention of the group to influence / play the market for the purpose of creating an artificial picture of large scale dealings in the scrip of MUL to entice other genuine investors to deal in the said scrip.

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling

Off Loaders 32. Once the bulk SMSs were sent out with buy recommendations in favour of the scrip and the website, www.midcapgains.in was also used to give buy recommendations in the scrip, by the SMS Sender who has been prima facie identified as Mr. Hanif Shekh in the earlier part of this Order, thereby prima facie luring the other gullible investors who by witnessing the meteoritic rise in the price and volume of the scrip during the SMS period (September 21, 2019 to December 27, 2019) a large part of which was also contributed and sustained by the dealings of the Collaborators in the scrip, apparently got attracted to invest/deal in the said scrip triggering a bullish run of the scrip. Taking advantage of this opportunity, it is observed that the entities who were connected either with the Company or with the SMS Sender, successfully exited the scrip by offloading their shares prima facie on those innocent investors who were induced to deal in the said scrip due to the sustained artificial trades carried out by the PV influencers and Collaborators during pre-SMS as well as during SMS period as have been discussed in detail earlier in this order. As noted in the preceding paragraphs, the average daily volume in the scrip during the SMS period vis-a-vis pre- SMS period increased by 1638%, while the price in the scrip opened at INR 256/- and reached a high of INR 412.10/-, an approximate increase of 61% during the SMS period. Such entities who exited the scrip taking advantage of the afore noted price & volume rise in the scrip are herein after referred to as Off Loaders. 33. The connection amongst the Off Loaders who exited the scrip of MUL during the SMS period as discovered during the investigation, are indicated in the table below: Table No. 11 Sl. Entity Name PAN Connection with sub-group members No. Mauria Connected entities (hereinafter referred to as “Sub-group 1”) 1. Jagdish Chahar ANNPC0228J Connection as an Employee of Mauria Udyog Ltd. 2. Amit Kumar AJCPK6114G 3. Jagdish Singh ARGPS3874H 1. Many of the Entities at Sl. No. 1 to 62 are employees (either 4. Mithun Singh BVZPS9152G permanent or contractual) of Mauria Udyog Ltd. as per data 5. Santosh Raut AZBPR5416K submitted by the Company. 6. Raja Ram CCIPR2093C

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling

Sl. Entity Name PAN Connection with sub-group members No. 7. Govind Ojha AATPO0326J 2. Name of the Entities at Sl No. 1 to 62 appears in the excel sheet 8. Rakesh Goel AHQPG6997D attached to the email dated May 13, 2020, sent by Mr. Deepak Garg to 9. Shiv Pal AUGPP5794G Mr. Davinder Gupta. All the details of trades done by the Entities at Sl 10. Ramajor ATZPR1408H No. 1 to 62, such as no. of shares bought/sold, dates of trade, pay out Ramajor date etc. are mentioned along with details of beneficiaries to whom 11. Mahavir Prasad AKQPP6836M these 62 entities have transferred their sale proceeds with bank 12. Haribansh BDFPG5772A account no., UTR no, date of transfer, amount transferred etc. Gupta Connection w.r.t address of entities 13. Sunil Kumar ARGPV5585N Verma 3. 37 entities in their bank accounts have furnished their postal 14. Govind Singh DHXPS0249Q correspondence address as ‘C/O Mauria Udyog Ltd., Sector 25, Sohna 15. Sukanta Kumar ABRPP1855G Road, Faridabad,121004’ which is same as that of the Company – Pala Mauria Udyog Ltd. 16. Madhu EAAPS2972B 4. As per UCC data received from NSDL, 22 entities have furnished their 17. Ravita Devi BIGPD0615R postal address as ‘C/O Mauria Udyog Ltd, Sector 25, Sohna Road, 18. Sukhilal Meena BKZPM0621H Faridabad,121004’ which is same as that of the company – Mauria 19. Hare Ram AEYPR6338C Udyog Ltd. Connection w.r.t Bank Accounts opened 20. Arvind Kumar AEHPK9032M 5. Out of 62 entities, 32 entities had their bank accounts in same branch 21. Meera Devi BIGPD0616N of Karnataka Bank - Faridabad Branch.

22. Roshan Kumar AWMPJ9308E 6. For most of the entities, the correspondence address of Mauria Udyog Jaiswal Ltd. Has been provided in Bank opening form with Karnataka Bank, 23. Kavita Devi BASPD6735J Faridabad Branch. For the aforesaid entities Mauria Udyog Ltd. gave 24. Jeet Bahadur AHVPB6604R recommendation letter to open bank accounts. 25. Madan Prasad BUZPP4215J 7. Another 9 entities had their account in Union Bank (erstwhile Andhra 26. Krishan Murari BNJPS2163K bank and Corporation Bank) and had provided address as that of Sharma Mauria Udyog Ltd. as their correspondence address. 27. Pappu Kumar BZQPR7716A 8. During 2 years (January 2019 to December 2020) there was virtually Ram no transaction in the bank statements of these 29 entities except for 28. Nand Lal AXAPS1944E the brief period of SMS circulation i.e. from September 2019 to Sharma December 2019. Majority of the transactions are related to fund 29. Leelu Singh DCNPS6356F transfers either with the Promoter Companies or Forex Companies 30. Amarjeet AIEPA6834G or Hanif related entities, as elaborated in subsequent paragraphs 31. Anand Bansal AHYPB4902B 9. All the aforesaid entities have transferred funds to almost similar set 32. Arun Kumar CJCPK8525R of entities during the SMS period.

Further, they have negligible bank 33. Bhurey Singh BFIPS7754D transactions before and after the SMS period. 34. Binod Kumar AKWPJ0656R Connection w.r.t Income Tax Return Filings Jha 10. For 21 entities address is given as that of Mauria Udyog Ltd in 35. Dashrath AEOPY5916K ITR filing. Yadav 11. For the aforesaid entities, a common email id has been 36. Devi Singh AGMPR1636B furnished in their ITR forms, viz: 37. Dharamwati AXZPC6279R dkgupta1087@gmail.com/sensons2@gmail.com. Chauhan 12. Common mobile number – 8800772803 is the common contact 38. Hariom ALQPR2239F number given in all the above noted 21 ITR filings. According to a Rathore reply of Mauria Udyog Ltd., the said mobile number belongs to CFO 39. Hoshiyar Saini BFIPS7755C of Mauria Udyog Ltd. – Mr. D. K. Gupta. 40. Indranand FIIPS3787P Singh Connection w.r.t gmail ids 41. Jitender Nagar ANPPN2462B

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling

Sl. Entity Name PAN Connection with sub-group members No. 42. Kailash ADCPC4008R 13. For entities at Sl. No. 2,4,6,14,24 recovery e-mail is the same i.e. Chouhan lmgupta@mauria.com. 43. Kesh Ram ABBPY2796D 14. lmgupta@mauria.com is email id used on behalf of Mr. Deepak 44. Kuldeep Singh BRPPS6874R Kumar Garg who is a secretarial staff. Mobile number of Mr. Deepak 45. Laxman Yadav ADVPN2232P Kumar Garg- 9911546552 is also provided as UCC details for opening 46. Mahender AWJPS8491E of broker accounts of many employees of Mauria Udyog Ltd. Singh 15. E-mail id – lmgupta@mauria.com is also associated with Ms. 47. Mangal Singh ALBPP6249E Deepa Sureka- Promoter of Mauria Udyog Ltd. and Mr. Akhil Kumar 48. Mukesh CXPPP6254H Sureka – family members of Mr. Navneet Kumar Sureka as per the Pandey UCC details available with broker/exchanges. 49. Narender BFVPS5988C 16. Promoter related companies like Linkwise Marketing Private 50. Parmanand ALBPP6249E Limited and Vee-Em Infocentre Pvt Ltd, while opening their Gmail 51. Pramod Ram AYUPR9406M accounts have provided the same recovery e-mail viz: 52. Prem Chand AGSPC0271B lmgupta@mauria.com.

53. Rajendra BWHPK5104R 17. Mr. Deepak Kumar Garg signed as a witness on the rent agreement Kumar of Linkwise Marketing Pvt Ltd that was signed on March 02, 2016. 54. Rajesh Giri AXGPG5852K 18. Mr. Raja Ram (Sl No. 6) and Linkwise Marketing Pvt. Ltd. have a 55. Rajesh Kumar BPUPK5369G common mobile number -- 9911546552 linked with their Gmail 56. Raju Devi CAQPD3563B account. 57. Ratindra Nath AMCPN9622R 19. Ms. Leelu Singh (Sl No. 29) and Mr. Sukhilal Meena (Sl No. 18) have 58. Saroj Yadav AFPPY4880A common recovery mobile number – 9990928213 as per the data 59. Seeta Ram AGMPR7725F provided by Google. 60. Shiv Shanker COKPS1441D 61. Sunil Nagar AMCPN9604P Connection w.r.t IP address 62. Susheel Kumar AISPA5466E 20. Mr. Amit Kumar (Sl no.2), Mr. Govind Singh (Sl. No. 14), Mr. Jeet Arora Bahadur (Sl No. 24), Mr. Mithun Singh (Sl. No.4), Mr. Raja Ram (Sl No. 6) had similar/common IP address (103.79.114.72/103.79.114.74/ 103.79.114.75) while opening their Gmail account. 21. Ms. Leelu Singh (Sl No. 29) and Mr. Sukhilal Meena (Sl No. 18) had common IP address (2402:3a80:93b:66ff:3477:d7f:65ce:a6fc) while opening their Gmail account.

Connection w.r.t UCC data 22. Mr. Santosh Raut (Sl No. 5), Mr. Govind Ojha (Sl No. 7), Mr. Ramajor (Sl No. 10), Mr. Prem Chand (Sl No. 52), Mr. Devi Singh (Sl No. 36), Mr. Rajendra Kumar (Sl No. 53) and Mr. Rathindra Nath (Sl No. 57) and Mr. Madan Prasad (Sl No. 25) share a common mobile no- 9268823695. 23. Mr. Raja Ram (Sl No. 6) shares same address viz. 8 Bougan Villa Avenue, Westend Green Fram Rajokari, South West New Delhi- 110038’ with the Director of the Company viz. Navneet Kumar Sureka. 24. Mr. Mithun Singh (Sl No. 4), Mr. Sukhilal Meena (Sl No. 18), Mr. Leelu Singh (Sl No. 29), Mr. Arvind Kumar (Sl No. 20), Mr. Krishan Murari Sharma (Sl No. 26), Mr. Binod Kumar Jha (Sl No. 34), Mr. Hoshiyar Saini (Sl No. 39), Mr. Mahender Singh (Sl No. 46), Mr. Narender (Sl No. 49), Mr. Jeet Bahadur (S. No 24), Mr. Hare Ram (Sl

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling

Sl. Entity Name PAN Connection with sub-group members No. No 19) and Mr. Roshan Kumar Jaiswal (Sl No. 22) shared common mobile no- 9268823641. Mobile number - 9268823641 and 9911546552 belonged to Mr. Deepak Kumar Garg. Mr. Deepak Kumar Garg is a secretarial staff of Mauria Udyog Ltd. In UCC details of Mr. Charu Garg (DMLPG7693K), the e-mail id of Mr. Deepak Kumar Garg i.e.– garg.deepak55@gmail.com is mentioned against mobile number - 9268823641. 25. As per UCC data received from NSDL, 22 entities have common address at ‘C/O Mauria Udyog Ltd, Sector 25, Sohna Road, Faridabad,121004’ which is the same as that of the Company’s postal address. Ahmedabad Based entities (hereinafter referred to as “Sub-Group 2”) 63. Ravi AVSPA1063A Connection w.r.t bank statements Kannadasan Adidravid 26. All these entities have frequent transactions with either each other 64. Pritiben AXGPP6927Q or with another set of companies related to Mr. Hanif Shekh (Sub- Popatbhai Group 2.A. which has been discussed later in this Order). Parmar 65. Manishkumar CGPPR9641K 27. Majority of the entities have bank accounts in Canara Bank at Rajput Sabarmati Branch. 66. Shahrukhkhan DOJPP7089N Pathan Connection w.r.t Income Tax Return filing 67. Sahilkumar ATLPV1359B Amrutbhai 28. Entities at Sl No. 63-72 have common/similar e-mail id in ITR viz:- Vaghela birju2it@gmail.com/ birju1it@gmail.com. 68. Lilaben DBYPP5174G Popatbhai 29. Sl Nos. 66, 73, 74 and 75 have common mobile numbers in their ITR Parmar form i.e.- 9428735408. 69. Popatbhai DGFPP6706L Ramjibhai Connection w.r.t UCC details Parmar 70. Dipika DKMPP5973A 30. Mr. Karan Sanghvi (Sl No. 76) has the same address and e-mail id Popatbhai with Ms. Krusha Sanghvi (Sl No. 75)- K6SANGHVI@GMAIL.COM Parmar 71. Fuldeep GIOPS7160B 31. E-mail address of Ms. Hina Barot (Sl No. 77) is Popatbhai vishal.ideabdo@gmail.com which is same as that of the Proprietor Sehgal of Samukh Trade- Mr. Vishal Jitendrakumar Barot, who has funded 72. Keval Savant HYAPS6005L these entities. 73. Chiragkumar CTXPM2544K Makwana Connection w.r.t trading pattern 74. Makwana CUHPM8134L 32. Trading by these entities in other companies was done where either Madhuben SMS has been circulated. 75. Krusha FXCPS0434J Birjukumar Sanghvi

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling

Sl. Entity Name PAN Connection with sub-group members No. 76. Karan ESJPS8192E Birjubhai Sanghvi 77. Hina Barot DGUPB9477B 78. Prakash AGEPV6889L Kantilal Vaghela Kolkata Based entities (hereinafter referred to as “Sub-Group 3”) 79. Highgrowth AACCH1789A Connection w.r.t UCC details Vincom Private 33. All entities except for Highgrowth Vincom (Sl No. 79), Glorious Limited Vincom (Sl No. 82), Linkup Financial (Sl No. 85), Ms. Minu Mallick (Sl No. 90) have a common address i.e.– Vill- Ramchandra Nagar, Madhya Shibpur, South 24 Parganas, West Bengal India 743372. 80. Sumit Laha AXJPL4908J 81. Dibakar Laha AJVPL4026B 34. Glorious Vincom Pvt. Ltd. shared a common address and common 82. Glorious AADCG3846Q Director (Mr. Umesh Rajak, Mr. Sumon Mondal, Mr. Somnath Vincom Pvt. Halder) with Highgrowth Vincom Pvt. Ltd. Ltd. 83. Arpan Das CEZPD7390K Connections w.r.t Bank: 84. Sanjay Dey BWHPD4063L 85. Linkup AACCL0347G Financial 35. All the entities have entered into frequent bank transactions with Consultants Hanif connected entities namely Amuly Suppliers, DK Jain Private Limited Properties, MR Merchants Pvt Ltd, Midpoint Commodeal Pvt. Ltd 86. Suprabhat Laha APXPL1814M 87. Ujjal Laha ATSPL2483R 88. Buddhadeb AQBPL5563C 36. DK Jain Properties Ltd. has shown its address as 9/12, Lal Bazar Laha Street 3rd Floor Block-B Room No 17 Kolkata 700001 which is 89. Sourav Das CEJPD9809M similar to the address of Econo Trade India Ltd. is located viz: - 9/12 Lal Bazaar Street, 3rd Floor, Block - B, Room No. 3103 Kolkata 90. Minu Mallick DGTPM2047B 700001. Parents of Hanif Shekh are major shareholders in Econo 91. Arun Dutta AIYPD5217E Trade India Ltd. 92. Debashish CVMPD9641P Dutta 37. Linkup Financial Consultants Ltd. Has shown its address as 9/12, 93. Uma Dutta COXPD8400E Lal Bazar Street, 1st Floor, Block - B, Kolkata 700001 which is 94. Subrata Laha APWPL5386H similar to the address of Econo Trade India Ltd. is located viz: - 9/12 Lal Bazaar Street, 3rd Floor, Block - B, Room No. 3103 Kolkata 95. Priyankar Laha AKLPL2832L 700001. 96. Tapas Laha ANCPL7138F 97. Arun Laha APWPL5441F 38. Highgrowth Vincom Private Limited and Linkup Financial Consultants have multiple fund transfers with Lagan Barter Pvt Ltd. The Directors of Lagan Barter Pvt Ltd. viz. Mr. Ramesh Laha and Mr. Kamal Das have shown their address as - “Madhya Shibpur, Ramchandranagar South 24 Parganas, Magrahat II, Howrah 743372”.

39. Mr. Sumit Laha, Mr. Buddhadeb Laha, Mr. Arpan Das, Mr. Dibakar Laha, Mr. Priyankar Laha and Mr. Suprabhat Laha had common IP address, viz: - [2401:4900:1c00:385c:3944:f716:fbae:38b9] while

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling

Sl. Entity Name PAN Connection with sub-group members No.

accessing their respective IDBI Bank accounts on 06-12-2022 around 10:00 AM. 40. Ms. Uma Dutta, Ms. Aruna Laha and Mr. Subrata Laha had common IP address -223.182.93.217 while accessing their respective Bandhan Bank account on 02-03-2022 around 02:15 -02:56 PM. 41. Mr. Ujjal Laha, Mr. Sanjay Dey and Mr. Debashish Dutta had common IP address - 110.227.77.235 while accessing their respective Kotak Mahindra Bank account on 12-31-2020 around 09:15 AM.

Connection w.r.t Broker Data 42. As per broker data, Mr. Arun Laha (Sl No. 97), Mr. Subrata Laha (Sl No. 94), Mr. Tapas Laha (Sl No. 96), Mr. Arun Dutta (Sl No. 91), Mr. Debashish Dutta (Sl No. 92), Mr. Buddhadeb Laha (Sl No. 88), Mr. Priyankar Laha (Sl No. 95), Mr. Dibakar Laha (Sl No. 81), Mr. Arpan Das (Sl No. 83) and Ms. Uma Dutta (Sl No. 93) had common IP addresses (116.206.200.17/48/*) while trading from their respective online accounts. 43. As per broker data, Mr. Arun Laha, Mr. Subrata Laha, Mr. Tapas Laha, Mr. Arun Dutta, Mr. Debashish Dutta had common Mac-ID (device id - E0:D5:5E:41:F9:3F) while accessing to their respective trading accounts. 44. As per broker data, Mr. Arpan Das and Ms. Uma Dutta had common Mac-ID (device id - 40-A5-EF-D6-52-D7, 6C-4B-90-83-46-27 and 78-32-1B-AC-A5-FA) while using their respective trading accounts. 45. As per broker data, Mr. Dibakar Laha and Mr. Debashish Dutta had common Mac-ID (device id - 6C:4B:90:83:45:4C and F4:93:9F:F6:D4:2C) while using their respective trading accounts. Connection w.r.t Gmail data: 46. Highgrowth Vincom Pvt. Ltd. and Linkup Financial Consultants Pvt. Ltd. had same IP address - 121.247.228.231 while opening Gmail account on 26/04/2012. Connection w.r.t Shareholding Pattern: 47. Mr. Arpan Das, Mr. Arun Laha, Ms. Minu Mallick, Mr. Sanjay Dey, Mr. Sumit Laha, Mr. Ujjal Laha, Ms. Uma Dutta, Highgrowth Vincom Pvt. Ltd. appear as >1% shareholder in Econo Trade India Ltd. where parents of Mr. Hanif Shekh hold majority of shares apart from being its Promoters. 48. Mr. Arpan Das, Mr. Priyankar Laha, Mr. Arun Dutta, Highgrowth Vincom Pvt. Ltd. and Linkup Financial Consultants Pvt. Ltd. appear

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling

Sl. Entity Name PAN Connection with sub-group members No.

as >1% shareholders in Kanungo Financiers Ltd. which is part of Hanif group of companies. Connection w.r.t trading pattern 49. Trading by these entities in the scrips of other companies where either SMS has been circulated giving buy recommendations in favour of those companies.

34. It is noted from the above table that the Mauria Connected entities / Sub Group 1 listed out therein are inter alia connected with MUL through employer - employee relationship, common addresses, common email ids., UCC data, common IP addresses, etc. For instance, it is noted from the data provided by MUL at the time of investigation that many of the aforestated 62 entities are employees (either permanent or contractual) of MUL. It is also noted that 37 entities in their bank accounts have disclosed their correspondence address as “C/O Mauria Udyog Ltd, Sector 25, Sohna Road, Faridabad,121004” which is the same address as that of MUL. Further, as per UCC data, it is noted that 22 entities have shown their address as “C/O Mauria Udyog Ltd, Sector 25, Sohna Road, Faridabad,121004” which is the same address as that of MUL. Further, from the ITRs of 21 entities, it is noted that they have shared a common email id and mobile number viz., dkgupta1087@gmail.com/sensons2@gmail.com and 8800772803 respectively, which belongs to Mr. D. K. Gupta (CFO of MUL). Now coming to their inter se connections, it is noted that these entities are connected with each other through common mobile numbers, common IP addresses used while opening their gmail accounts, etc. For instance, as per UCC data, entities namely Mr. Santosh Raut, Mr. Govind Ojha, Mr. Ramajor, Mr. Madan Prasad, Mr. Prem Chand, Mr. Devi Singh, Mr. Rajendra Kumar and Mr. Rathindra Nath, share common mobile no. “9268823695”. It is also noted that Mr. Amit Kumar, Mr. Govind Singh, Mr. Jeet Bahadur, Mr. Mithun Singh, Mr. Raja Ram have similar/common IP address (103.79.114.72/103.79.114.74/ 103.79.114.75) while opening their gmail accounts. Keeping in view the afore noted undisputed factual findings and my observations thereon, it can be seen that not only there is a common identity thread which runs

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling through all the aforesaid entities i.e. almost all of them were employees of MUL but also these entities shared many other things in common amongst them, such as mobile number, email id, IP address etc. When the various commonalities shared by the aforesaid 62 entities are juxtaposed or examined in combination with their unusual trading pattern (heavy selling) in the scrip of MUL during the SMS period, coupled with their timing of accessing the market and also the fact that the said entities did not even have the financial capacity to deal in such huge volumes in the said scrip (discussed in subsequent paragraph), it can be prima facie firmly inferred that their act of coming together to offload their shares of MUL in the market as a group during SMS period, was pursuant to a prima facie pre-conceived scheme and was by design. 35. It is also noted from the above table that the Ahmedabad Based entities / Sub Group 2 entities are inter alia connected with each other by way of common email ids, common phone numbers, having multiple fund transactions amongst themselves, etc. For instance, it is noted from the ITR forms of Mr. Shahrukhkhan Pathan, Mr. Chiragkumar Makwana, Mr. Makwana Madhuben and Ms. Krusha Birjukumar Sanghvi that they have disclosed in their Income Tax Returns, a common mobile number i.e. 9428735408. Similarly, entities namely Mr. Ravi Kannadasan Adidravid, Ms. Pritiben Popatbhai Parmar, Mr. Manishkumar Rajput, Mr. Shahrukhkhan Pathan, Mr. Sahilkumar Amrutbhai Vaghela, Ms. Lilaben Popatbhai Parmar, Mr. Popatbhai Ramjibhai Parmar, Ms. Dipika Popatbhai Parmar, Mr. Fuldeep Popatbhai Sehgal and Mr. Keval Savant have disclosed common/similar e-mail ids viz. birju2it@gmail.com/ birju1it@gmail.com in their ITRs.

It is also noted that as per UCC details, Mr. Karan Sanghvi and Ms. Krusha Sanghvi shared a common e-mail id (K6SANGHVI@GMAIL.COM) and common address viz. “227, Varsodas Chawl, Opp Jayesh Hard Ware, Sabarmati, Ahmedabad, Gujarat, India 380005”. Various funds transfers have also been observed amongst the Sub Group 2 entities. For instance, Mr. Sahilkumar Amrutbhai Vaghela had received INR 5 lakh in his account number 1414101054772 in Canara Bank from Ms. Madhuben Jayantibhai Makwana from bank account number 1414101055111 held with Canara Bank on May 12, 2020.

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling

Similarly, on July 3, 2020, Ms. Krusha Birjukumar Sanghvi had transferred an amount of INR 5 lakh from her Canara Bank Account bearing number 1414101053100 to Mr. Prakash Kantilal Vaghela into his account bearing no. 1414201012372 held with Canara Bank. In the light of the aforesaid facts and prima facie evidence which demonstrate that the said 16 entities are connected with each other on multiple parameters. These findings about their inter se close connections not only prima facie show the strength of the connection enjoyed by them with each other as a group, but also when the said inter se connection is seen along with the way the said entities have traded in an unusual but concerted manner in the scrip including the unusual timing of their dealing in the scrip, and moreover, keeping the fact in view that these entities were funded by some other set of entities (discussed in subsequent paragraphs), it leads to a prima facie compelling inference that their act of coming together in the securities market to deal in the scrip of MUL was part of a premediated scheme and was pursuant to a prima facie scheme employed in the scrip. 36. It is observed from the above table that the Kolkata based entities / Sub Group 3 are also inter alia connected with each other by way of common addresses, common IP addresses, common email ids, having common phone numbers, having multiple fund transactions amongst themselves, etc. For instance, all the entities (except Highgrowth Vincom, Glorious Vincom, Linkup Financial and Ms. Minu Mallick) have shown a common address at “Vill- Ramchandra Nagar, Madhya Shibpur, South 24 Parganas, West Bengal India 743372”. Further, entities namely Mr. Arun Laha, Mr. Subrata Laha, Mr. Tapas Laha, Mr. Arun Dutta, Mr. Debashish Dutta, Mr. Buddhadeb Laha, Mr. Priyankar Laha, Mr. Dibakar Laha, Mr. Arpan Das and Ms. Uma Dutta have shared a common IP addresses (116.206.200.17/48/*) while trading from their respective online accounts through multiple stock brokers. It is also noted that these entities are connected with Mr. Hanif Sheikh. For instance, Mr. Arpan Das, Mr. Priyankar Laha, Mr. Arun Dutta, Highgrowth Vincom Pvt Ltd and Linkup Financial Consultants Pvt Ltd appear as >1% shareholders in Kanungo Financiers Ltd. which is part of Hanif group of companies. Similarly, Mr. Arpan Das, Mr. Arun Laha, Ms. Minu

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling

Mallick, Mr. Sanjay Dey, Mr. Sumit Laha, Mr. Ujjal Laha, Ms. Uma Dutta and Highgrowth Vincom Pvt Ltd appear as >1% shareholder in Econo Trade India Ltd where the parents of Mr. Hanif Shekh are Promoters. Further, DK Jain properties Ltd has shown its address as “9/12, Lal Bazar Street 3rd Floor Block-B Room No 17 Kolkata 700001” which is located in the same premises/address where Econo Trade India Ltd is located of which the parents of Mr. Hanif Shekh are the Promoters. From the aforesaid factual revelations, it is noted that not only the aforesaid 18 entities are connected with each other on various parameters but are also connected with Mr. Hanif Shekh who, as noted in preceding paragraphs, is not only the prima facie the kingpin of the scheme but is also the SMS Sender in the scrip. The aforesaid facts when seen along with their unusual trading pattern (heavy selling) in the scrip of the MUL including the timing of their dealing in the said scrip and also keeping in view the fact that they were also funded by the entities who are connected with Mr. Hanif Shekh, it can be prima facie inferred that the very act of coming together of the aforesaid entities/off loaders to the market to offload their shares of MUL at a profit was in accordance with the prima facie pre-designed scheme employed to indulge in fraudulent trades in the scrip. 37. The profits made by the Off Loaders by dumping their shares of MUL during the SMS period are indicated in the table below. Interestingly, the investigation reveals that the PV Influencers who had prima facie artificially inflated the price and volume in the scrip prior to the circulation of SMSs on this scrip, had also prima facie made unlawful gains while perpetrating their prima facie fraudulent trade practices in the scrip. Table No. 12 Profit made by Mauria connected entities-Off loaders (Sub-group 1) Sl Entity Buy Qty Buy Value Sell Qty Sell Value Shares #Acquisi Total Net Profit No. Name during during IP during during IP alread tion Buy (INR) IP IP y held price of Value (A) (B) before shares C-G (C) (D) IP already (G) = (E) = held B+F C-A (F) 1. Jag dish 37706 14701851 205086 50988111 167380 1707276 1640912 34578984 Chahar 7

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling

Sl Entity Buy Qty Buy Value Sell Qty Sell Value Shares #Acquisi Total Net Profit No. Name during during IP during during IP alread tion Buy (INR) IP IP y held price of Value (A) (B) before shares C-G (C) (D) IP already (G) = (E) = held B+F C-A (F) 2. Am it 0 0 72450 29753195 72450 738990 738990 29014205 Kumar 3. Jag dish 2784 793226 82000 29494355 79216 808003 1601229 27893126 Singh 4. Mi thun 5000 1950000 71000 27691916 66000 673200 2623200 25068716 Singh 5. Ra ja 42923 17168262 108023 40698073 65100 664020 1783228 22865791 Ram 2 6. Sa ntosh 41553 16724964 94553 38190557 53000 540600 1726556 20924993 Raut 4 7. Go vind 10235 4020465 71800 25404326 61565 627963 4648428 20755898 Ojha 8. Ra kesh 27214 10426359 93214 31719665 66000 673200 1109955 20620106 Goel 9 9. Sh iv Pal 1714 488886 64444 19872398 62730 639846 1128732 18743666 10. Ra major 35400 14091726 92700 31793464 57300 584460 1467618 17117278 Ramajor 6 11. Ma havir 25571 10128127 75058 26117547 49487 504767 1063289 15484653 Prasad 5 12. Ha riban 0 0 28400 11102010 28400 289680 289680 10812330 sh Gupta 13. Go vind 0 0 28000 10841142 28000 285600 285600 10555542 Singh 14. Su nil 1658 644947 30158 11490181 28500 290700 935647 10554534 Kumar Verma 15. Ar vind 0 0 27500 10522260 27500 280500 280500 10241760 Kumar 16. Su kanta 4000 1600000 30350 12038450 26350 268770 1868770 10169680 Kumar Pala 17. Ma dhu 0 0 27655 10299492 27655 282081 282081 10017411 18. Ra vita 0 0 28130 10264165 28130 286926 286926 9977239 Devi 19. Su khilal 0 0 26600 10089380 26600 271320 271320 9818060 Meena 20. Ha re 16010 5499674 44000 15576290 27990 285498 5785172 9791118 Ram 21. Me era 0 0 26000 9918314 26000 265200 265200 9653114 Devi 22. Na nd Lal 0 0 29350 9933760 29350 299370 299370 9634390 Sharma 23. Jee t 4844 1882387 30859 11701432 26015 265353 2147740 9553691 Bahadur 24. Ro shan 0 0 28500 9843481 28500 290700 290700 9552781 Kumar Jaiswal

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling

Sl Entity Buy Qty Buy Value Sell Qty Sell Value Shares #Acquisi Total Net Profit No. Name during during IP during during IP alread tion Buy (INR) IP IP y held price of Value (A) (B) before shares C-G (C) (D) IP already (G) = (E) = held B+F C-A (F) 25. Ka vita 0 0 28500 9825461 28500 290700 290700 9534761 Devi 26. Ma dan 0 0 28000 9723400 28000 285600 285600 9437800 Prasad 27. Ha riom 39500 14343421 80095 23939505 40595 414069 1475749 9182015 Rathore 0 28. Kr ishan 27425 10387578 50374 19707386 22949 234080 1062165 9085729 Murari 7 Sharma 29. Le elu 4950 1654538 33450 10937537 28500 290700 1945238 8992299 Singh 30. Sh iv 0 0 88225 9856512 88225 899895 899895 8956617 Shanker 31. Ka ilash 4705 1881765 30910 11019334 26205 267291 2149056 8870278 Chouhan 32. Pa ppu 0 0 28010 8897818 28010 285702 285702 8612116 Kumar Ram 33. Se eta 0 0 21700 8391630 21700 221340 221340 8170290 Ram 34. Su sheel 9500 2982050 34610 10456185 25110 256122 3238172 7218013 Kumar Arora 35. Jit ender 0 0 28000 7304825 28000 285600 285600 7019225 Nagar 36. In drana 0 0 28010 6504888 28010 285702 285702 6219186 nd Singh 37. Ke sh 4000 1599995 22500 7987890 18500 188700 1788695 6199195 Ram 38. Dh armw 0 0 28500 6478461 28500 290700 290700 6187761 ati Chauhan 39. Mu kesh 10000 3933823 28220 10304026 18220 185844 4119667 6184359 Pandey 40. Pr em 30218 11507794 45800 17767265 15582 158936 1166673 6100534 Chand 1 41. De vi 0 0 19700 5813545 19700 200940 200940 5612605 Singh 42. Su nil 0 0 14150 5543832 14150 144330 144330 5399502 Nagar 43. Ra jesh 0 0 14450 5444570 14450 147390 147390 5297180 Kumar 44. Pr amod 0 0 14450 5442415 14450 147390 147390 5295025 Ram 45. Pa rman 42000 16590000 67330 22107991 25330 258366 1684836 5259625 and 6

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling

Sl Entity Buy Qty Buy Value Sell Qty Sell Value Shares #Acquisi Total Net Profit No. Name during during IP during during IP alread tion Buy (INR) IP IP y held price of Value (A) (B) before shares C-G (C) (D) IP already (G) = (E) = held B+F C-A (F) Parman and 46. Ra jesh 0 0 14450 5039302 14450 147390 147390 4891912 Giri 47. Na rende 4000 873000 17000 5759097 13000 132600 1005600 4753497 r Narende r 48. Ku ldeep 0 0 14500 4853735 14500 147900 147900 4705835 Singh 49. Ma ngal 59000 23806668 74230 28018939 15230 155346 2396201 4056926 Singh 4 50. Ra thindr 0 0 14315 4036515 14315 146013 146013 3890502 a Nath 51. Ho shiya 0 0 12000 3712535 12000 122400 122400 3590135 r Saini 52. An and 0 0 72060 3883055 72060 735012 735012 3148043 Bansal 53. Bh urey 0 0 10100 2914808 10100 103020 103020 2811788 Singh 54. Ra jendr 0 0 7900 2743130 7900 80580 80580 2662550 a Kumar 55. Am arjee 13800 4881450 21500 7283014 7700 78540 4959990 2323024 t 56. Sa roj 0 0 9865 1785160 9865 100623 100623 1684537 Yadav 57. La xman 0 0 4000 1585873 4000 40800 40800 1545073 Yadav 58. Da shrat 0 0 71680 2090700 71680 731136 731136 1359564 h Yadav 59. Ra ju 0 0 2550 977460 2550 26010 26010 951450 Devi 60. Ma hend 0 0 300 83625 300 3060 3060 80565 er Singh 61. *B*i nod 38300 14185958 34800 13512188 -3500 622596 Kumar Jha 62. *A run 4221 1663567 2221 885460 -2000 10127 Kumar Total 548231 210412481 2534285 807963038 579321306

#Note: For the shares bought before Investigation Period (IP), opening day price – INR 10.2 has been taken to calculate the acquisition price of these extra shares. For entities at Sl Nos. 61 and 62, shares sold during IP is less than shares sold. To calculate the profit, for the shares sold, profit made per share is calculated and is multiplies by no of shares sold. Profit/shares is calculated by (Total Sale Value/Total Sell Qty – Total Buy Value/Total Buy Qty).

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling

Table No. 13

Profit made by Ahmedabad based connected entities-Off loaders (Sub-group 2)

Sl Entity Buy Buy Sell Sell Value Shares #Acquisitio Total Buy Net Profit No. Name Qty Value Qty during IP already n price of Value (INR) duri during during held shares ng IP IP IP (D) before IP already (G) = B+F C-G (A) (E) = C-A held (B) (C) (F) 1. Sa hilkumar 0 0 8000 2418850 8000 1583000 1583000 835850 Amrutbhai Vaghela 2. Va ghela 0 0 6400 1945971.35 6400 1370266 1370266 575705 Prakash Kantilal 3. Ra vi 0 0 3700 1126645 3700 691125 691125 435520 Kannadasan Adidravid 4. Ke val 0 0 3450 1051128.5 3450 650375 650375 400753 Savant 5. Di pika 0 0 5000 1500500 5000 1117000 1117000 383500 Popatbhai Parmar 6. M anishkum 0 0 3500 1051250 3500 709000 709000 342250 ar Rajput 7. Ch iragkuma 0 0 2700 822973.9 2700 520500 520500 302473 r Makwana 8. Kr usha 0 0 3000 905979.05 3000 628000 628000 277979 Birjukumar Sanghvi 9. Ka ran 0 0 2000 608456.1 2000 379000 379000 229456 Birjubhai Sanghvi 10. Fu ldeep 0 0 2000 601450 2000 379000 379000 222450 Popatbhai Sehgal 11. M akwana 0 0 1700 518455.4 1700 315000 315000 203455 Madhuben 12. Po patbhai 0 0 3000 899700 3000 697000 697000 202700 Ramjibhai Parmar 13. Hi na Barot 0 0 3000 899250 3000 697000 697000 202250 14. Li laben 0 0 2900 868910 2900 677500 677500 191410 Popatbhai Parmar 15. Pr itiben 0 0 2000 599100 2000 444000 444000 155100 Popatbhai Parmar

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling

Sl Entity Buy Buy Sell Sell Value Shares #Acquisitio Total Buy Net Profit No. Name Qty Value Qty during IP already n price of Value (INR) duri during during held shares ng IP IP IP (D) before IP already (G) = B+F C-G (A) (E) = C-A held (B) (C) (F) 16. Sh ahrukhkh 0 0 1000 299500 1000 195000 195000 104500 an Pathan Total 0 0 53350 16118119 53350 11052766 11052766 5065353

#Note: For calculation in column ‘F’ (buy value for shares bought before SMS circulation period), if shares are bought during IP period, average buy price of shares during Pre-SMS period (within IP) is considered for calculating buy value of shares, otherwise if shares are bought before IP period, opening price on the first day of IP is considered as acquisition price for calculating value of those shares.

Table No. 14 Profit made by Kolkata based connected entities-Off loaders (Sub-group 3) Sl Entity Buy Qty Buy Sell Qty Sell Value Shares #Acquisit Total Buy Net Profit No. Name during Value during during IP already ion price Value (INR) IP during IP held of shares (A) IP (D) before already (G) = B+F C-G (C) IP held (B) (E) = C- (F) A 1. Ar pan Das 52713 1803410 72313 24213861 19600 3757475 21791578 2422283 3 2. Su mit 23694 8089974 30194 11066861 6500 1195500 9285474 1781387 Laha 3. Su prabhat 71470 2193090 88430 26862563 16960 3320268 25251170 1611393 Laha 2 4. Sa njay 25727 8088741 34377 10606549 8650 1563690 9652431 954118 Dey 5. Di bakar 34772 1120523 41672 13364445 6900 1341500 12546734 817711 Laha 4 6. De bashish 8286 2404439 19346 5472451 11060 2295600 4700039 772412 Dutta 7. Bu ddhade 1962 515901 9512 2559494 7550 1440100 1956001 603493 b Laha 8. Um a Dutta 0 0 7950 2156895 7950 1568100 1568100 588795 9. Su brata 29693 8469761 36093 10251539 6400 1296400 9766161 485378 Laha 10. Li nkup 9337 2523644 18852 5201733 9515 2194960 4718604 483129 Financial Consultan ts Private Limited 11. M inu 13900 4689530 16700 5604180 2800 498400 5187930 416250 Mallick 12. Uj jal Laha 0 0 6350 1650216 6350 1245500 1245500 404716

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling

Sl Entity Buy Qty Buy Sell Qty Sell Value Shares #Acquisit Total Buy Net Profit No. Name during Value during during IP already ion price Value (INR) IP during IP held of shares (A) IP (D) before already (G) = B+F C-G (C) IP held (B) (E) = C- (F) A 13. Hi ghgrowt 0 0 7460 2105601 7460 1829760 1829760 275841 h Vincom Private Limited 14. Ar un Laha 8095 2396691 11195 3337285 3100 682000 3078691 258594 15. Pr iyankar 200 52250 3200 844365 3000 548400 600650 243715 Laha 16. Ta pas 0 0 3200 865574 3200 704000 704000 161574 Laha 17. Ar un 0 0 1000 286573 1000 180409 180409 106164 Dutta 18. Gl orious 40000 1520000 40000 15200000 0 0 15200000 0 Vincom 0 Private Limited Total 319849 1036011 447844 141650183. 127995 25662062 129263232 12386951 70 3 #Note: For calculation in column ‘F’ (buy value for shares bought before SMS circulation period), if shares are bought during IP period, average buy price of shares during Pre-SMS period (within IP) is considered for calculating buy value of shares, otherwise if shares are bought before IP period, opening price on the first day of IP is considered as acquisition price for calculating value of those shares.

Table No. 15 Profit made by the PV Influencers

Sl No. Entity name Buy Qty Buy Value Sell Qty Sell Value Net Profit (INR) (A) (B) (A) - (B)

1. A1 Solutions Prop. 506784 82861242 486784 95818045 12956803 Ajju Kumar 2. Piyush Agarwal 413392 89483158 413392 99476360 9993202 3. Shyam Kumar 251808 39451766 221808 57189105 17737339 Singh 4. Chinnu 175203 30710801 175203 35633500 4922700 5. Corredor Services 164608 36864706 179608 40307841 3443135 Private Limited 6. Sapan Kumar 147090 27454481 147090 33956376 6501896 Agarwal 7. Kamal Gupta Huf 130113 17370234 128490 23190299 5820065

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling

Sl No. Entity name Buy Qty Buy Value Sell Qty Sell Value Net Profit (INR) (A) (B) (A) - (B)

8. Juscorp 107580 31424973 127952 40164120 8739147 Enterprises Private Limited 9. Vepar Solutions 103417 23381627 108417 27038549 3656922 Private Limited 10. Aayush Tanwar 102155 22447403 102155 22476354 28952 11. Gyanendra Gharti 37371 8147262 37371 8181639 34377 Chhetri Total 2139521 409597655 2128270 483432190 73834535

The Ultimate Beneficiaries 38. It is prima facie noted from the records that though the Off Loaders were the entities who had exited the scrip by making a substantial profit, however, they were just a façade to hide the Ultimate Beneficiaries. The rationale behind the aforesaid prima facie finding is as follows: 38.1. The trading activities of the above listed three groups of Off Loaders were not commensurate with their respective declared annual income. It has already been brought on records in the preceding paragraphs that the Mauria Group of entities are connected with each other as well as with the Company inter alia in terms of their employment, operation of bank accounts and their trading accounts (which were active only during the SMS period and had nil/negligible transactions, a year before and after the SMS period), common recovery email addresses, common email ids for filing of ITR etc. Similarly, Ahmedabad based entities and Kolkata based entities are connected with each other inter alia in terms of frequent funds transactions with Mr. Hanif Shekh connected entities, common email ids for filing of ITR, common MAC address and IP address, common shareholding etc. In the table below, the total exposures taken by some of the Mauria Group of entities, Ahmedabad based entities and Kolkata based entities to the scrip of MUL - the Off Loaders in the scrip of MUL vis-à-vis their respective total annual income are depicted:

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling

Table No. 16

Sl No. Entity Name Total exposure in the market which is prima facie not commensurate with declared income Mauria connected entities Annual Income as Buy Value during Sell value during the SMS period per ITR SMS period 1. Jagdish Chahar 306991 3,26,99,321 Shares already 2. Amit Kumar 563275 held before start 2,97,53,195 3. Jagdish Singh 512884 of SMS circulation 2,87,01,130 4. Rakesh Goel 239768 1,63,75,751 5. Shiv Pal 250950 1,62,18,262 6. Ramajor 364494 1,34,54,600 7. Mahavir Prasad 384475 1,27,66,410 8. Haribansh Gupta #NA 1,11,02,009 9. Sunil Kumar Verma 463065 1,08,45,234 10. Govind Singh 419893 1,08,41,142 11. Sukanta Kumar Pala 553023 1,04,38,450 12. Madhu 282164 1,02,99,492 13. Ravita Devi 464253 1,02,64,165 14. Sukhilal Meena #N/A 1,00,89,380 15. Hare Ram 191028 1,00,76,616 16. Arvind Kumar 209789.5 1,00,69,760 17. Meera Devi 449402.5 99,18,314 18. Roshan Kumar Jaiswal 248160.5 98,43,481 19. Kavita Devi 430095.5 98,25,461 20. Jeet Bahadur 432144 98,19,044 21. Madan Prasad 374883 97,23,400 22. Krishan Murari Sharma 503173 93,14,034 23. Pappu Kumar Ram 290660.5 88,97,818 24. Nand Lal Sharma 484699 86,78,760 25. Leelu Singh 426329 86,60,499 Ahmedabad based entities Total exposure in the market is incommensurate with declared income Annual Income as Avg buy value Avg sell value during the period per ITR during the period June 01, 2019 to December 31, June 01, 2019 to 2019 December 31, 2019 26. Ravi Kannadasan 4,27,129 1,32,55,601 9,76,163 Adidravid 27. Pritiben Popatbhai 4,27,327 62,82,533 13,42,864 Parmar 28. Manishkumar Rajput 4,95,000 22,42,825 8,27,797 29. Shahrukhkhan Pathan 4,02,520 28,38,125 17,46,031

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling

Sl No. Entity Name Total exposure in the market which is prima facie not commensurate with declared income 30. Sahilkumar Amrutbhai 4,32,962 3,48,58,921 38,13,077 Vaghela 31. Lilaben Popatbhai 4,34,468 70,66,579 27,51,460 Parmar 32. Popatbhai Ramjibhai 4,60,784 59,62,698 25,22,185 Parmar 33. Dipika Popatbhai 4,29,112 73,65,499 16,63,850 Parmar 34. Fuldeep Popatbhai 4,02,804 30,68,170 11,30,044 Sehgal 35. Keval Savant 4,45,423 1,26,05,819 11,92,354 36. Chiragkumar Makwana 3,81,882 1,20,74,068 13,48,828 37. Makwana Madhuben 3,73,587 1,11,17,241 14,38,597 38. Krusha Birjukumar 4,28,781 22,22,405 5,46,452 Sanghvi 39. Karan Birjubhai Sanghvi 4,00,652 13,19,156 10,81,905 40. Hina Barot 4,96,500 64,03,156 17,86,626 41. Prakash Kantilal 3,80,900 1,53,37,411 7,80,034 Vaghela Kolkata based entities Total exposure in the market is incommensurate with declared income Annual Income as Avg buy value Avg sell value during the period per ITR during the period June 01, 2019 to December 31, June 01, 2019 to 2019 December 31, 2019 42. Arpan Das 7,54,537 8,33,15,677 9,52,52,557 43. Suprabhat Laha 6,27,933 7,10,90,813 7,84,60,781 44. Debashish Dutta 3,78,562 1,27,98,646 1,38,12,156 45. Sumit Laha 20,33,907 6,52,21,180 9,11,39,146 46. Sanjay Dey 18,59,997 3,13,93,056 4,99,69,756 47. Dibakar Laha 18,85,021 14,75,02,020 16,11,32,996 48. Uma Dutta 4,24,750 72,59,120 87,99,756 49. Buddhadeb Laha 16,46,845 46,65,859 64,39,214 50. Subrata Laha 2,09,797 1,71,41,540 1,84,16,062 51. Ujjal Laha 8,22,076 1,53,16,402 2,72,83,081 52. Arun Laha 5,02,099 1,01,65,418 1,23,47,255 53. Tapas Laha 3,14,854 48,91,005 66,29,232 54. Priyankar Laha 3,88,977 35,75,388 46,00,427 55. Minu Mallick 8,48,976 2,60,21,480 3,35,12,638 56. Arun Dutta 9,42,422 81,49,237 95,18,674 57. Highgrowth Vincom 5,63,154 1,71,86,299 4,35,33,171 Private Limited 58. Linkup Financial 1,30,108 5,18,33,591 5,21,85,903 Consultants Private Limited

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling

From the above table, it is observed that on a comparison of the declared income with either the average buy value or average sell value of the trades executed by each of the aforesaid entities in the scrip of MUL, one can easily ascertain the glaring disproportionate trading activities undertaken in the trading accounts of the said entities as compared to their declared annual income. For instance, the declared annual income of Mr. Sahilkumar Amrutbhai Vaghela (Sl. No. 30) is approximately INR 4.32 lakh while his average buy value in the scrip is approximately INR 3.48 crore which is at an astronomical variance of approximately 7950% from his declared income. Similarly, the declared income of Mr. Subrata Laha (Sl. No. 50) is approximately INR 2.09 lakh while his average buy value in the scrip is approximately INR 1.71 crore which is at an astronomical variance of approximately 8070% from his declared income. The aforesaid instances prima facie demonstrate how, by taking such huge buying exposures in the scrip the said entities were displaying their unfettered confidence about their capability, albeit without any credible substance, to take delivery of those shares bought by them that were worth much more than their annual income. In other words, their risk appetite in the scrip was very high which necessarily was not the outcome of their own net worth/income level or even the fundamentals of the Company but was due to certain inexplicable extraneous circumstances. 38.2. Ownership of shares – It is noted from the records that except a few entities, the above discussed Off Loaders connected to the Company, did not buy any shares on-market from the very start of the trading in the scrip of MUL i.e. January 27, 2017 till the start of circulation of SMS i.e. September 21, 2019 onwards (a few entities had bought some shares after starting of SMS circulation). Before listing of the scrip, most of these entities had received their shares of the Company, majorly through off-market transactions. Since, before listing of the Company the shares of the Company are mainly held by the Promoters of the Company, the probability of the aforesaid entities of receiving the shares of the Company through off-market mode from the Promoters of the Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling

Company, is high. Further, there are no records which could be unearthed at the time of investigation, which would show that any consideration was ever paid by the Off Loaders to the persons from whom they had received the shares in off market mode. The said fact coupled with the fact that the Off Loaders had transferred funds (out of the sale proceeds) post their off-loading of the shares of MUL inter alia to the Promoter related companies (discussed in subsequent paragraphs) and the fact that most of these Off Loaders were also the employees of the Company, lead me to a compelling inference, on a preponderance of probability basis, that the Off Loaders/ beneficial owners of the shares who off-loaded the shares on the Exchange platform by booking substantial profits, were not the genuine owners of those shares which they had acquired from off-market sources during pre-listing days of the Company, but in all likelihood were prima facie the front entities for the Promoters of the Company. Similarly, the other two sets of Off Loaders i.e., Ahmedabad based entities (Sub Group 2) and Kolkata based entities (Sub Group 3) who on paper were the owners of the shares of the Company which they sold at a high profit, but the records with SEBI reflect that they were funded by certain other entities who are collectively referred to as Sub Group 2.A and Sub Group 3.A, respectively, who in turn were connected with Mr. Hanif Shekh and apparently by using such funds these entities, i.e. Sub Groups 2 and 3, had acquired those shares of the Company. A few instances where the buy trades of the Sub Groups 2 and 3 were prima facie found to have been funded by the Sub Groups 2.A and 3.A, respectively, are presented below. However, prior to that it will be appropriate to identify the entities who belonged to the Sub Groups 2.A and 3.A which provided funds to Sub Groups 2 and 3 for acquiring shares of MUL. The said entities are as follows: Table No. 17

Sl No. Entity Name Connection with each other Sub-group 2.A - Entities involved in funding of trade of Sub-group 2 and transferring funds to Sub-Group 3.A 1. Aneel A & Co

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling

2. Samukh Trade a. Sub-group 2.A has frequent two-ways 3. Shakti Enterprise transactions with each other and with Sub-group 2. 4. Sharad Enterprise b. Sub-group 2.A has frequent transactions with 5. Ambika Traders Sub-group 3.A. Sub-Group 3.A - Entities inc.v olAvlel dha ivne f oupnedniendg tohfe tirra adceco oufn Stus bin- Gsaromuep b 3ra nch of Canara Bank. 6. Midpoint Commodeal a. Sub-group 3.A has had frequent two-ways transactions with each other and Sub-group 3. 7. Dk Jain Properties b. Midpoint Commodeal, D K Jain Properties, MR 8. Mr Merchants Pvt Ltd Merchants, Amuly Supplier had shareholdings in Escort Agencies-an unlisted entity. 9. Armeva Dealers Pvt Ltd c. Amuly suppliers and Midpoint Commodeal 10. Amuly Suppliers have same android id (device id- 11. Frexon Supppliers Pvt Ltd 3dec7ed5640fa5fe) while accessing their 12. Rightview Dealers Pvt Ltd respective e-mail ids. 13. Mackny Trexim Pvt Ltd d. DK Jain Properties Private Ltd., Amuly Suppliers Private Ltd., MR Merchants Private 14. Urki Sales Pvt Ltd Ltd. and Midpoint Commodeal Private Ltd. all 15. Nxstar Dealcom Pvt Ltd had a common director, Mr. Nandu Shaw (DIN 16. Impalio Distributors Pvt Ltd 06403637). 17. Cradon traders Pvt Ltd

It is noted from the aforesaid table and material available on record that the said 17 entities (5 entities from Sub Group 2.A and 12 entities from Sub Group 3.A) are not only inter se connected with each other but were also connected with Mr. Hanif Shekh, and / or Hanif Entities (Sub Group 5 - identified subsequently in the Order). Few of such connections are indicated below:  Sub Group 2.A had frequent transaction with Sub Group 3.A. For instance, an entity from Sub Group 2.A namely, Aneel A & Co had transferred INR 12 lakh to an entity from Sub Group 3.A namely, Armeva Dealers Pvt. Ltd. on December 7, 2018. Again on December 12, 2018, Aneel A & Co had transferred INR 19 lakh to Armeva Dealers Pvt. Ltd.  An entity from Sub Group 3.A namely, DK Jain properties Ltd has its address as “9/12, Lal Bazar Street 3rd Floor Block-B Room No 17 Kolkata 700001” which is located in the same premises and address where Econo

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling

Trade India Ltd (Sub Group 5) is located. Further, parents of Mr. Hanif Shekh are Promoters of Econo Trade India Ltd as well.

A few instances where the buy trades of the Sub Groups 2 and 3 were seen to be funded by Sub Groups 2.A and 3.A, respectively, are shown below: Table No. 18

Sub-group 2.A Sub-group 2 Entity Entity Samukh Trade Sahilkumar Vaghela Competent Finman Pvt Ltd Used for (Broker) trading Date Amount Date Amount 12/07/19 5,00,000 12/07/19 5,00,000 Sahilkumar Vaghela Competent Finman Pvt Ltd (Broker) Aneel A &Co Date Amount Date Amount 21/08/18 4,00,000 21/08/18 4,00,000

20/08/19 9,16,000 20/08/19 9,16,000 Sharad Kevalrao Savant Berkley Securities Ltd Enterprise (Broker) Date Amount Date Amount 23/08/19 4,00,000 23/08/19 4,00,000 Shakti Manish Kumar Rajput MNM Stock Broking Pvt Ltd Enterprise (Broker) Date Amount Date Amount 16/08/19 2,00,000 16/08/19 2,00,000

Table No. 19

Sub-group 3.A Sub-group 3 Entity Entity Midpoint Sanjay Dey Ashika Stock Broking (Broker) Used for Commodeal Pvt Date Amount Date Amount trading Ltd 07/08/19 3,00,000 07/08/19 3,01,700 D K Jain Suprabhat Laha SMC Global Securities (Broker) Properties Pvt Date Amount Date Amount Ltd 26/08/19 14,00,000 27/08/19 13,97,500 D K Jain Buddhadeb Laha Edelweiss Broking Ltd Properties Pvt (Broker) Ltd Date Amount Date Amount 28/08/19 6,50,000 29/08/19 6,28,574 Midpoint Arpan Das Giriraj Stock Broking Pvt Ltd Commodeal (Broker)

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling

Date Amount Date Amount 17/08/19 10,00,000 19/08/19 10,00,000 Similar to the conduct of Mauria Group of connected entities (Sub Group 1) post their exit from the scrip of MUL with substantial profits, the Off Loaders of Sub Groups 2 and 3 also, post their exit from the scrip, had transferred funds (prima facie out of the sales proceeds of the shares) inter alia to Sub Groups 2.A and 3.A (discussed in subsequent paragraphs). Additionally, considering the undeniable fact that all the sub groups i.e., 2, 2.A, 3 and 3.A are connected with each other as well as with Mr. Hanif Shekh, I am now persuaded, on a preponderance of probability basis that, the aforesaid beneficial owners of the shares, viz: the entities of Sub groups 2 and 3 were not the genuine owners but were prima facie the front entities holding the shares of MUL on behalf of the entities pertaining to Sub Groups 2.A and 3.A (who had provided funds) and who in turn, were prima facie the front entities for some other entities (discussed in subsequent paragraphs) who were the Ultimate Beneficiaries of the entire scheme deployed in the trading of the scrip. Thus, prima facie form the aforesaid factual exposition and my prima facie observations pertaining to the apparent role played by the various groups of connected entities, a discernible pattern emerges wherein it can be seen that as per the master plan of the purported scheme, it was pre-determined that there would be one set of entities who would be shown as the owners of the shares on the books of the Company while there would be another set of entities who would fund the transactions of the so called owners of shares to procure the shares and then post the dealing in the scrip by the Off Loaders i.e., the first set of entities who were the on-paper owners of the shares, would transfer the sales proceeds with the profits so earned to the ultimate and the real beneficiaries by using the financiers (the second set of entities referred to above who had funded the first set of entities) as conduits, wherever applicable and in other cases via layered transactions using other connected entities as conduits. In short, prima facie the scheme was perpetrated in such a way so as to hide the real identities of the Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling

Ultimate Beneficiaries by putting enough distance / layers between them and the initial dealings in the scrip by their connected front entities. 38.3. Transfer of trade proceeds – In a genuine sell transaction on the securities market, post selling of shares, the proceeds of the shares sold in the securities market, goes to the bank account of the seller on T+2 day (where T is the trading day). However, in the instant case the sellers in the scrip of MUL i.e., the Off Loaders, be it the Mauria Connected entities, or the Sub Group 2 or Sub Group 3 entities, all of them have without fail, transferred the proceeds either to the Promoter related companies of MUL or to Mr. Hanif Shekh (the SMS sender) related companies or to certain Forex companies which was later on converted into cash. These post sales suspicious behaviour of the selling entities viz: the entities of sub-groups no.1, 2 and 3 who, after off-loading the shares never held the proceeds with themselves and instead transferred them to the aforesaid destinations, belies and betrays the genuineness of the dealings in the scrip by the Off Loaders. Further, once the funds trail is traced out and the ultimate recipients of the sales proceeds are identified, it becomes crystal clear that the Ultimate Beneficiaries of the prima facie scheme that was deployed in the trading in the scrip of MUL included none other than the kingpin and the mastermind behind the bulk SMSs that were sent to public by him/at his behest namely, Mr. Hanif Shekh and also the Promoters of the Company. Before proceeding to illustrate a few instances of transfer of money by the Off Loaders to the Ultimate Beneficiaries, it will be appropriate to first identify a certain set of entities which can be named as Hanif entities, Hanif connected entities, and also the entities which were used to transfer money to Forex companies and to the entities connected to the Promoters of the Company. Table No. 20 Hanif Entities – Sub-group 5 Sl No Entity Name Relation/Connection

1. Hanif Shekh a. SMS sender

Interim Orde r-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling

2. Kasambhai Shekh b. Father of Hanif Shekh. 3. Hasina Kasambhai c. Mother of Hanif Shekh. Shekh 4. Robert Resources d. Hanif Shekh is the Managing Director since April 2016. His Ltd mother is the Director since March 2017. 5. Econo Trade India e. Hasina Kasambhai Shekh, Kasambhai Umarbhai and Robert Ltd Resources Limited are Promoters and have 26.19% shareholding of the company. f. Hasina Kasambhai Shekh is Executive Director in the said company. g. Kasambhai Umarbhai Shekh was Director from July 21, 2018 to July 31, 2020. h. Sanjay Vishnudas Kotak was Director from August 14, 2018 to April 15, 2019 and was also Director in Econobroking Pvt Ltd from May 23, 2014 to March 04, 2022. 6. Econo Broking i. Frequent bank transactions with Econ-trade, Sai Metaltech (Erstwhile Bansal LLP. Finstock) j. Since April 2021, Hasina Kasambhai Shekh holds 55% shareholding. k. Sanjay Kotak erstwhile Director of Econo Trade India Ltd is CEO of Econobroking Pvt Ltd. l. One of the e-mail addresses of Hanif Shekh is hanif@bansalonline.com. which shows his association/connection with Econobroking (Erstwhile Bansal Finstock). 7. Sai Metaltech LLP m. Hanif Shekh was Partner along with his father, Kasambhai Shekh till July 2020 and thereafter he became Partner with his mother, Shekh Hasina Kasambhai. n. E-mail address of Hanif Shekh is hanif@bansalonline.com which has been furnished with MCA for the company.

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling

Table No. 21 Sl. No Entity Name Connection with each other Sub-group 5.A – Hanif Connected Entities 1. Nilratan Suppliers Pvt. a. Briya Enterprise, Kanungo Financiers and Purple Ltd. Entertainment had same android id (device id- 37cf22489924fd2f) while accessing their respective e-mail ids. b. Nilratan Suppliers Pvt Ltd and Kanungo Financiers had same 2. Briya Enterprise Ltd. android id (device id- 3d266d7692779548) while accessing 3. Kanungo Financiers their respective e-mail ids. Ltd. c. Lagan Barter Pvt Ltd had frequent transactions with Kolkata 4. Purple Entertainment entities and Econo Broking Pvt Ltd, Econo Trade India Ltd, Ltd. Nilratan Suppliers Pvt Ltd and Briya Enterprise. d. Lagan Barter Pvt Ltd and Nilratan Suppliers Pvt Ltd trade 5. Lagan Barter Pvt. Ltd. frequently with broking firm of Hanif Shekh- Econo Broking Pvt Ltd.

6. Jignesh Sudhirbhai e. Frequent bank transaction between Jignesh Sudhirbhai Shah Shah and abovementioned entities. Hanif Shekh has frequent call record with Jignesh Sudhirbhai Shah.

Table No. 22 Sub-group 6 – Companies involved in routing fund to Forex conversion in Cash S No Name Relation/Connection 1. Amba Enterprise a. Entities at S No 1 to 21 are companies acting as 2. Sai Enterprise conduits to transfer money to Forex dealers – Entities at S No 22 to 25 (“FFMC – Full Fledged 3. Yash Enterprise Money Converters”) who in turn converted the 4. Njp Ntrade International money received from entities at S No 1 to 21 into Forex cash and have not maintained bills for the 5. Garvi Trading said transactions/conversions as per their 6. C Square Trading submission. 7. Vikas Sales 8. Shree Mahakal Enterprises b. Net Sellers in the scrip of Mauria Udyog Ltd, 7NR Retail Ltd, GBL industries Ltd and Price-volume manipulators in Mauria Udyog Ltd –Group-01 9. Jagannath International (through K M Enterprise) and Sub-group 2.A and Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling

10. Hoffman Trade Enterprise 3.A have transferred funds to same set of companies i.e. Entities at S No. 1 to 21. 11. Navkar Enterprise c. Entities at S No 1 to 21 have financial 12. Infinity Trading transactions with sub-groups identified during investigation and are connected/related to Hanif 13. Nilkant Sales Corporation Shekh. They have also provided funds to Sub- 14. Nandan Trading Co group 3.A who in turn provided to Sub-group 3 for trading as can be seen from their respective 15. Skyline Trading bank statement. 16. Adventure India 17. Attractive Choice d. Donum Forex, Gemmy Forex and Velox Forex 18. Jay Enterprises have same contact number – 93269831777 in 19. Aj Enterprise ITR form. 20. Metro Corporation e. Velox Forex and Malacca Forex have common e- 21. Flying Enterprise mail id in ITR form – 22. Gemmy Forex Pvt Ltd pratikshadesai@gmail.com. 23. Donum Forex Pvt Ltd f. All the Forex companies (S No. 22 to 25 are related/connected to each other. 24. Malacca Forex Pvt Ltd 25. Velocity Forex Pvt Ltd

Table No. 23 Sl. No Entity Name Connection with each other Entities connected to the Promoters of Mauria Udyog Ltd. 1. Linkwise Marketing Pvt. Ltd.

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling

2. Vee-Em Infocentre Pvt a. Both while opening Gmail account, had same recovery e-mail Ltd as lmgupta@mauria.com which is also mentioned in the UCC details of broker/exchanges of Deepa Sureka- Promoter of Mauria Udyog Ltd. and Akhil Kumar Sureka – family member of Navneet Kumar Sureka. b. Both had same service IP address i.e. 27.251.171.132 on 09/07/2014 and 23/06/2014 while opening Gmail account. c. Deepak Kumar Garg (employee of MUL) signed as witness on the rent agreement of Linkwise Marketing Pvt Ltd signed on March 02, 2016 d. Sureka group has significant holding in Vee-Em Infocenter Pvt. Ltd. e. In a corporate filing with BSE, Mauria Udyog Ltd has mentioned Vee-Em Infocenter Pvt. Ltd. in its related party transactions (Group Company). Now that the relevant recipient entities (of sales proceeds of shares of MUL) have been identified, a few instances are shown below to demonstrate as to how the sale proceeds were transferred by the Off Loaders to the Ultimate Beneficiaries.

A few instances where the sales proceeds were transferred by Mauria Connected entities to the Company/Promoter connected entities, are shown below:

Table No. 24

Broker Entity Company/sister concern of MUL Mauria connected entities sales proceeds Choice Jagdish Chahar Linkwise Marketing Vee EM Infocentre Mauria Udyog Ltd. Equity (Group company of Mauria Udyog Ltd) Date Amount Date Amount Date Amount Date Amount 29/11/19 17,08,000 29/11/19 17,08,000 29/11/19 15,00,000 30/11/19 15,00,000 Edelweiss Jagdish Singh Mauria Udyog Ltd. Date Amount Date Amount 30/10/19 14,70,000 31/10/19 14,70,000 Edelweiss Jagdish Singh Sai Enterprise Date Amount Date Amount 27/12/19 60,68,100 27/12/19 19,50,000 Linkwise Marketing Date Amount 27/12/19 22,22,500 Choice Ramajor Linkwise Marketing Vee EM Infocentre Mauria Udyog Ltd. Equity (Includes amount received from other sellers) Date Amount Date Amount Date Amount Date Amount 26/12/19 27,60,000 26/12/19 27,60,000 30/12/19 2,76,00,000 30/12/19 90,00,000 31/12/19 1,90,00,000

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling

A few instances where the sales proceeds were transferred by Mauria Connected entities to Hanif connected entities are shown below: Table No. 25 Broker Choice Equity Jagdish Chahar Frexon Suppliers Ltd (Sub-group Further 3.A transfer to Date Amount Date Amount Hanif Shekh 30/08/19 9,41,500 30/08/19 9,41,500 Entities (Sub- Edelweiss Jagdish Singh Samukh Trade (Sub-group 2.A) group 5.A) Date Amount Date Amount 30/10/19 14,70,000 31/10/19 14,70,000 Pantomath Ramajor Armeva Dealers (Sub-group 3.A Date Amount Date Amount 20/08/19 9,16,000 20/08/19 9,16,000 Comfort Mahavir Parshad Rightview Dealers Pvt Ltd (Sub-group 3.A Date Amount Date Amount 19/08/19 9,18,816 20/08/19 9,19,047 Mahavir Parshad Armeva Dealers Pvt Ltd (Sub-group 3.A Date Amount Date Amount 22/08/19 9,70,454 26/08/19 9,71,047 A few instances where sales proceeds were transferred by Mauria Connected entities to the companies acting as conduits for conversion of sales proceeds into foreign exchange are shown below:

Table No. 26

Broker to Choice Jagdish Chahar NJP Ntrade C Square Trading After Equity International multiple routing, Date Amount Date Amount Date Amount funds 16/12/19 21,67,000 16/12/19 21,67,000 17/12/19 24,50,000 were Choice Jagdish Chahar Amba Enterprise Infinity Trading Co converted Equity to Forex Date Amount Date Amount Date Amount cash 06/01/20 20,00,000 06/01/20 20,00,000 07/01/20 15,00,000 Choice Ramajor Amba Enterprise MH Corporation Equity Date Amount Date Amount Date Amount 20/12/19 52,25,000 20/12/19 52,25,000 20/12/19 1,18,00,000

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling

A few instances where the sales proceeds were transferred by Ahmedabad based entities (Sub Group 2) to Sub Group 2.A entities are shown below:

Table No. 27

Broker MNM Stock Manish Kumar Rajput Aneel A &CO Aneel A & CO, Broking Ambika Traders and Date Amount Date Amount Samukh Trade 30/10/19 25,00,000 01/11/19 25,00,000 are part of Sub Competent Finman Sahilkumar Vaghela Ambika Traders Group 2.A Pvt Ltd entities who Date Amount Date Amount are connected 17/10/19 18,00,000 23/10/19 18,00,000 to Hanif Shekh Arihant Capital Fuldeep Popatbhai Samukh Trade (discussed later Markets* Sehgal in the Order). Date Amount Date Amount 09/09/20 22,59,330 09/09/20 22,59,330 *Outside IP – To illustrate repetitive pattern and relation/connection between the Entities.

A few instances where the sales proceeds were transferred by Kolkata based entities (Sub Group 3) to Sub Group 3.A entities are shown below:

Table No. 28

Ashika Stock Broking Sanjay Dey Midpoint Commodeal Midpoint Date Amount Date Amount Commodeal Pvt Ltd, D K Jain 23/12/19 37,48,796 23/12/19 30,00,000 Properties Pvt Amuly Suppliers Ltd and Amuly Date Amount Suppliers are 23/12/19 575,675 part of Sub SMC Global Suprabhat Laha D K Jain Properties Pvt Ltd Group 3.A Securities* Entities who Date Amount Date Amount are connected 19/10/20 25,43,573 19/10/20 19,02,169 to Hanif Shekh Prabhudas Liladhar Arpan Das Midpoint Commodeal Pvt Ltd (discussed later Pvt Ltd Date Amount Date Amount in the Order). 20/12/19 80,00,000 23/12/19 7,50,000 27/12/19 25,95,000 15/01/20 70,00,000 D K Jain Properties Pvt Ltd Date Amount 15/01/20 21,65,765 *Outside IP – To illustrate repetitive pattern and relation/connection between the entities.

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling

38.4. Attempt to conceal the identity – As noted in the preceding paragraphs, each and every leg of the prima facie scheme is designed in such a way so as to hide the identity of the real perpetrators of the said scheme. Right from the first leg were the PV Influencers were trying to prima facie artificially inflate the price and volume in the scrip to the Collaborators who continued to manipulate the trading volumes and prices of the scrip during the SMS period till the transfer of the sales proceeds by the Off Loaders post their exit from the scrip, to the Ultimate Beneficiaries, every attempt was made to conceal the identity of the real and ultimate beneficiaries of the prima facie fraudulent scheme, including the attempt that was made to hide the identity of the SMS Sender by giving incorrect name, multiple mobile numbers, by making cash payment etc. At every step, effort was made to mask the connection of the entities who were on paper dealing in the scrip during pre and post SMS period, with the Promoters of the Company or with Mr. Hanif Shekh, the SMS Sender. However, as one scrutinizes and looks through the maze of multiple layers of the prima facie scheme, the concerted effort which was put in the said scheme by the kingpin, Mr Hanif Shekh to maintain his anonymity and to avoid the regulatory detection, falls apart. 39. The cumulative effects of the afore-discussed deceitful acts that have been committed by different sets of entities through layers of transactions, coupled with the relationship / connections as brought out succinctly in the preceding paragraphs that existed amongst the connected entities based on a preponderance of probabilities, prima facie lead to an imposing inference that the prima facie scheme which was employed to deal in the scrip of MUL was prima facie conceived and implemented to benefit Mr. Hanif Shekh and his connected entities namely, Mr. Kasambhai Shekh, Ms. Hasina Kasambhai Shekh, Robert Resources Ltd, Econo Trade India Ltd, Econo Broking Pvt Ltd and Sai Metal tech LLP and also the Promoters of Mauria Udyog Ltd. namely Mr. Navneet Sureka and Ms. Deepa Sureka and their connected companies viz., Mauria Udyog Ltd. and Vee-Em Infocenter Pvt. Ltd.

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling

Profits 40. As may be observed from the foregoing factual analyses, the prima facie scheme that was hatched by the kingpin, Mr. Hanif Shekh along with the Promoters of the Company for their fraudulent dealings in the scrip of MUL has prima facie resulted in earnings of profits at various levels. The first and the foremost entities who made profits by their fraudulent dealings in the scrip are the PV influencers as noted at Table No. 15 above in this Order, who had entered the scrip at the initial stages of implementation of the prima facie scheme. As already discussed in the early part of this Order, these entities had collectively by their manipulative trades in the scrip during pre and post SMS period (majorly during pre-SMS period), have prima facie made a profit of INR 7,38,34,535/-. The next set of entities who made profit by their dealings in the scrip, pursuant to the prima facie scheme are the Off Loaders. The first group of Off Loaders i.e., Mauria Connected entities (Sub Group 1) post their exit from the scrip had transferred the profits to Mr. Hanif Shekh and his connected entities and also to the entities connected to the Promoters of the Company. A summary of such profit earned by the Mauria Connected entities that were transferred through layers of conduits to Mr. Hanif Shekh and his connected entities and also to the entities connected to the Promoters of the Company is tabulated below:

Table No. 29 Sl Entity Name Profit Earned Forex Mauria related Hanif No (in INR) Companies entities/Mauria Related (in INR) Promoter entities (in companies (in INR) INR) 1. Jagdish Chahar 34578984 12307000 15024000 941500 2. Amit Kumar 29014205 0 29645000 0 3. Jagdish Singh 27893126 16018200 11046500 657700 4. Mithun Singh 25068716 13140000 12500000 0 5. Raja Ram 22865791 5768000 10863000 917000

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling

Sl Entity Name Profit Earned Forex Mauria related Hanif No (in INR) Companies entities/Mauria Related (in INR) Promoter entities (in companies (in INR) INR) 6. Govind Ojha 20924993 15170000 3880000 920000 7. Santosh Raut 20755898 1347000 14959000 0 8. Rakesh Goel 20620106 12179000 2351000 2832500 9. Shiv Pal 18743666 8833500 6695500 1635500 10. Ramajor 17117278 9695000 4119500 1886500 Ramajor 11. Mahavir Prasad 15484653 7446000 2543500 1890000 12. Haribansh Gupta 10812330 9581000 1479300 0 13. Govind Singh 10555542 8756500 2044000 0 14. Sunil Kumar 10554534 10223600 0 0 Verma 15. Arvind Kumar 10241760 1400000 5429000 0 16. Sukanta Kumar 10169680 4300000 1200000 0 Pala 17. Madhu 10017411 10261000 35400 0 18. Ravita Devi 9977239 9339500 857100 0 19. Sukhilal Meena 9818060 10003500 0 0 20. Hare Ram 9791118 3460000 5752000 0 21. Meera Devi 9653114 9881500 0 0 22. Roshan Kumar 9634390 8695400 1111000 0 Jaiswal 23. Jeet Bahadur 9553691 7302000 1893300 0 24. Madan Prasad 9552781 7905000 1751000 0

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling

Sl Entity Name Profit Earned Forex Mauria related Hanif No (in INR) Companies entities/Mauria Related (in INR) Promoter entities (in companies (in INR) INR) 25. Krishan Murari 9534761 215000 9025000 0 Sharma 26. Nand Lal Sharma 9437800 3482000 3264900 842300 27. Hariom Rathore 9182015 0 3103300 2466625 28. Shiv Shanker 9085729 8285000 0 0 29. Leelu Singh 8992299 5317400 1994020 0 30. Kailash Chouhan 8956617 6816900 0 0 31. Pappu Kumar 8870278 5501000 3466700 0 Ram 32. Seeta Ram 8612116 3612500 4658100 0 33. Susheel Kumar 8170290 3795000 1405800 876500 Arora 34. Kavita Devi 7218013 6275000 1157500 0 35. Jitender Nagar 7019225 0 672000 0 36. Indranand Singh 6219186 0 0 2813500 37. Dharamwati 6199195 0 1323400 1635500 Chauhan 38. Kesh Ram 6187761 3973000 1930000 0 39. Mukesh Pandey 6184359 4770000 360000 630500 40. Prem Chand 6100534 1975000 4050000 0 41. Devi Singh 5612605 0 4728475 0 42. Sunil Nagar 5399502 5491000 0 0 43. Parmanand 5297180 480000 1318000 973000

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling

Sl Entity Name Profit Earned Forex Mauria related Hanif No (in INR) Companies entities/Mauria Related (in INR) Promoter entities (in companies (in INR) INR) 44. Rajesh Kumar 5295025 5423500 0 0 45. Pramod Ram 5259625 5421500 0 0 46. Rajesh Giri 4891912 4449000 0 0 47. Narender 4753497 2895000 2000000 0 48. Binod Kumar Jha 4705835 1800000 0 0 49. Mangal Singh 4056926 1425000 850000 869500 50. Ratindra Nath 3890502 0 1613520 0 51. Arun Kumar 3590135 1260000 0 876500 52. Hoshiyar Saini 3148043 0 0 0 53. Anand Bansal 2811788 0 3210000 0 54. Bhurey Singh 2662550 450000 500000 0 55. Rajendra Kumar 2323024 2311000 421000 0 56. Kuldeep Singh 1684537 1354000 1000000 0 57. Amarjeet 1545073 1000000 0 500000 58. Saroj Yadav 1359564 0 0 0 59. Laxman Yadav 951450 0 14848666 0 60. Dashrath Yadav 80565 0 0 1427500 61. Raju Devi 622596 969900 0 0 62. Mahender Singh 10127 0 83300 0 Total 57,93,21,306 29,17,60,400 20,21,62,781 2,55,92,125

41. It has been noted in the preceding paragraphs that the forex companies viz., Gemmy Forex Pvt. Ltd., Donum Forex Pvt. Ltd., Malacca Forex Pvt. Ltd. and Velocity Forex Pvt.

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling

Ltd., etc. were receiving funds from certain companies as mentioned at Sl. Nos. 1-21 at Table No. 22 which were acting as conduits and in turn, the Forex companies were converting the funds so received by them into forex cash. The aforesaid conduit companies which were transferring funds to the Forex companies were receiving funds from the Sub Group 1 (Mauria Connected entities) and from the entities of Sub Group 2.A as well as Sub Group 3.A. It may be noted that entities of Sub Group 2.A were having banking transactions with Ahmedabad based entities [Sub Group 2] and the entities of Sub Group 3.A were having banking transactions with Kolkata based entities [Sub Group 3]. It is noted from the records that similar to the action of Off Loaders like Sub Group 1 in the case of MUL, in case of certain other scrips covered in this matter as well viz., 7NR Retail Ltd. and GBL Industries Ltd., the Off Loaders were seen to be transferring the funds (sales proceeds) to the conduit companies and the only common denominator involved across all these scrips where prima facie, similar fraudulent schemes were deployed, is Mr. Hanif Shekh (discussed in subsequent paragraphs).

Thus, a pattern can be seen across all such scrips wherein post the exit of the respective Off Loaders from the scrip especially during the SMS period, certain portion of the profits were also transferred to the conduit companies only to be onward transferred to the forex companies. Thus, on a preponderance of probability basis it can be inferred that Mr. Hanif Shekh who is the only constant key element across different scrips where similar scheme was found to be deployed as in the case of the scrip of MUL, and considering the fact that the same set of conduit companies and Forex companies have been used across all these scrips covered in the present proceedings, one is prima facie led to a factual conclusion that the conversion of sales proceeds of the shares by the Off Loaders to forex cash was done only on behalf of and for the benefit of Mr. Hanif Shekh. The said inference further gets reinforced from the fact that the Sub Groups 2.A and 3.A which have transferred funds to the conduit companies are in turn connected with Mr. Hanif Shekh, thereby showing proximity of Mr. Hanif Shekh with respect to the said conduit companies, rather than with multiple Off Loaders across the scrips.

In other words, there can be no other contrary inference made other than the aforesaid prima facie conclusion, which can plausibly explain as Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling to why not one or two but a majority of the Off Loaders across the scrips, whether or not Promoters of the companies are involved, decided to transfer the sales proceeds of their dealing in that scrip, to the conduit companies for onward transfer of those funds to Mr. Hanif Shekh and his related entities or to the entities related to the Promoters of the company and in most such instances like in the scrip of MUL, the Off Loaders (not necessarily all the Off Loaders) did not have even the requisite financial capacity to deal in the scrip and also were seen to be funded by some other entities. 42. In view of the aforesaid discussion, it can be prima facie inferred that the profits made by Mr. Hanif Shekh and his connected entities including Sub Groups 2 and 3 by their dealing in the scrip of MUL aggregate to INR 33,48,04,829/- while the Promoters of MUL along with their connected companies have prima facie made a profit of INR 26,19,68,781/-.

43. Before proceeding further to determine the prima facie violations of the entities who were involved in the dealings in the scrip of MUL in a fraudulent manner, based on the detailed discussions in preceding paragraphs, I would like to briefly reiterate the broad modus operandi of the prima facie scheme employed in the scrip of MUL. The same is as follows: 43.1. A certain group of entities (PV Influencers) who are connected to the Company started dealing in the scrip of MUL inter alia either by trading amongst themselves or by executing synchronised trades or by accessing the market at regular interval and placing multiple orders on the same day with the primary goal of gradually increasing the price and volume in the scrip. 43.2. In the meantime, Mr. Hanif Shekh obtained multiple sender IDs from the resellers of TSPs which can be used to send bulk SMSs and also created website (www.midcapgains.in) which can be used to give buy recommendation in favour of the scrip once a desired level of price and volume is reached largely with the support of the fraudulent trades of the PV influencers.

43.3. Post the wide circulation of SMSs in which recommendations for buying the scrip was given, a few entities (Collaborators) connected with the SMS Sender,

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling collectively as a group tried to maintain the momentum so far created by the PV Influencers in the scrip inter alia either by taking turns to deal in the scrip on separate occasions or by executing intra day trades even at the cost of making losses in the process, just to ensure that the liquidity can be continuously maintained in the scrip, consequently, increasing the probability of the Off Loaders to exit the scrip with a profit. 43.4. Multiple groups of connected entities (Off Loaders), majority of whom did not have even the financial capacity or were funded by other set of entities, were set up as front entities by the Ultimate Beneficiaries, and such front entities dealt in the scrip by executing both buy and sell trades during the SMS period. 43.5. Due to the concerted effort of the SMS Sender and the Collaborators, the Off Loaders were able to exit the scrip by pocketing a substantial profit after dumping around 30 lakh shares of MUL-, a scrip which, post its listing did not witness any trades for two years and subsequently in spite of the sustained efforts of the PV Influencers, the average volume during pre SMS period remained at 9,423 shares. 43.6. Once the Off Loaders had exited the scrip, the profits were transferred from their accounts to the accounts of the Ultimate Beneficiaries who were none other than the SMS Sender and his connected entities and also the Promoters of the Company and their connected entities and such funds transfers were undertaken via several conduits and layers so as to maintain the anonymity of the Ultimate Beneficiaries and also to avoid regulatory detection. 44. Here, it will be relevant to reproduce the text of Sections 12A (a), (b) and (c) of SEBI Act and regulations 3 (a), 3 (b), 3 (c), 3(d), 4(1) and 4(2)(a), (b), (e), (g), (k), (n) and (r) of PFUTP Regulations for ready reference. The same reads as follows: SEBI Act Prohibition of manipulative and deceptive devices, insider trading and substantial acquisition of securities or control.

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling

12A. No person shall directly or indirectly— (a) use or employ, in connection with the issue, purchase or sale of any securities listed or proposed to be listed on a recognized stock exchange, any manipulative or deceptive device or contrivance in contravention of the provisions of this Act or the rules or the regulations made thereunder; (b) employ any device, scheme or artifice to defraud in connection with issue or dealing in securities which are listed or proposed to be listed on a recognised stock exchange; (c) engage in any act, practice, course of business which operates or would operate as fraud or deceit upon any person, in connection with the issue, dealing in securities which are listed or proposed to be listed on a recognised stock exchange, in contravention of the provisions of this Act or the rules or the regulations made thereunder; PFUTP Regulations 3. Prohibition of certain dealings in securities No person shall directly or indirectly— (a) buy, sell or otherwise deal in securities in a fraudulent manner; (b) use or employ, in connection with issue, purchase or sale of any security listed or proposed to be listed in a recognized stock exchange, any manipulative or deceptive device or contrivance in contravention of the provisions of the Act or the rules or the regulations made there under; (c) employ any device, scheme or artifice to defraud in connection with dealing in or issue of securities which are listed or proposed to be listed on a recognized stock exchange; (d) engage in any act, practice, course of business which operates or would operate as fraud or deceit upon any person in connection with any dealing in or issue of securities which are listed or proposed to be listed on a recognized stock exchange

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling in contravention of the provisions of the Act or the rules and the regulations made there under. 4. Prohibition of manipulative, fraudulent and unfair trade practices (1) Without prejudice to the provisions of regulation 3, no person shall indulge in a manipulative, fraudulent or an unfair trade practice in securities markets. 4 (2) Dealing in securities shall be deemed to be manipulative, fraudulent or an unfair trade practice if it involves any of the following: — (a) knowingly indulging in an act which creates false or misleading appearance of trading in the securities market; (b) dealing in a security not intended to effect transfer of beneficial ownership but intended to operate only as a device to inflate, depress or cause fluctuations in the price of such security for wrongful gain or avoidance of loss; …. (e) any act or omission amounting to manipulation of the price of a security including, influencing or manipulating the reference price or bench mark price of any securities; … (g) Entering into a transaction in securities without intention of performing it or without intention of change of ownership of such security; … (k) disseminating information or advice through any media, whether physical or digital, which the disseminator knows to be false or misleading in a reckless or careless manner and which is designed to, or likely to influence the decision of investors dealing in securities; … (n) circular transactions in respect of a security entered into between persons including intermediaries to artificially provide a false appearance of trading in such security or to inflate, depress or cause fluctuations in the price of such security;

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling

… (r) knowingly planting false or misleading news which may induce sale or purchase of securities; 45. From the aforesaid provisions of law, it may be appreciated that the determination of the prima facie violations by the entities has two linked but separate parts to it: 45.1. The first is determination of prima facie violation of provisions of SEBI Act and PFUTP Regulations and who all are liable for the same. 45.2. The second is to determine the persons who are prima facie liable for the proceeds generated by executing the trades that were executed in the scrip prima facie in violation of provisions of SEBI Act and PFUTP Regulations. 46. I now proceed to address the first issue. In the instant matter, pursuant to the employment of the prima facie scheme, the entities belonging to the category of PV Influencers by way of their manipulative trades have prima facie interfered with the market forces of supply and demand in the scrip of MUL by artificially influencing the price and volume of the scrip and have thus, prima facie distorted the price discovery mechanism of the Stock Exchange. The said entities have, by frequently trading amongst themselves above the LTP during the pre-SMS period have contributed significantly to the LTP of the scrip and also have executed numerous synchronised trades above LTP amongst themselves wherein, in majority of the trades the time difference between buy orders and sell orders was equal to or less than 10 seconds. Further, the said entities, by trading amongst themselves have created substantial trading volumes in the scrip so as to enhance the liquidity in the scrip which was illicitly achieved by executing multiple trades for a particular order (for example, matching of 1 big buy or sell order with multiple small buy / sell orders) to artificially show market depth in the scrip. It is also noted from the records that the aforesaid entities, by engaging in such manipulative trades in the scrip of the company during the SMS period had also made substantial profits. As noted in preceding paragraphs, matching of a large number of trades between a selected set of persons over a considerable period of time in an illiquid scrip cannot be a matter of market

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling coincidence especially when the fundamentals and financials of the Company are weak. Furthermore, there were several red flags already available in public domain which could have alerted a genuine investor in the scrip viz., at the peak (December 26, 2019), the Company showed a PE ratio of 121.56 in contrast to PE ratio of its peers, Ador Fontech Ltd- 6.90, W.H. Brandy & CO- 4.71. Further, during similar periods the broader market Nifty 50 moved by 30.07 % while the scrip price of MUL moved by 2204%. Therefore, it has to be prima facie inferred that the PV Influencers have acted in collusion with the Promoters of the Company and have created artificial volumes in the market inter alia by trading amongst themselves and have also influenced price of the scrip by placing and executing a large number of orders at a price higher than the last traded price including executing synchronised trades, thereby indulging in unfair trade practices so as to induce/attract the gullible investors to deal in the scrip.

Thus, the aforesaid actions of the PV Influencers i.e., Mr. Piyush Agarwal, Juscorp Enterprises Private Limited, A1 Solutions- Prop- Mr. Ajju Kumar, Corredor Services Private Limited, Mr. Sapan Kumar Agarwal, Vepar Solutions Private Limited, Mr. Shyam Kumar Singh, Kamal Gupta HUF, Ms. Chinnu, Mr. Gyanendra Gharti Chhetri and Mr. Aayush Tanwar along with the Promoters of the Company, Mr. Navneet Kumar Sureka and Ms. Deepa Sureka with whom the PV Influencers are connected (and prima facie for whom they have undertaken those manipulative trades as PV Influencers), have prima facie led to the violation of Sections 12A (a), (b) and (c) of SEBI Act and regulations 3 (a), 3 (b), 3 (c), 3(d), 4(1) and 4(2)(a), (b), (e) and (g) of PFUTP Regulations. 47. Next comes the examination of the role played by Mr. Hanif Shekh as SMS Sender and owner of the website, www.midcapgains.in. I note that the examination of the definition of fraud under the PFUTP Regulations envisages, among other things, fraud by way of an “act” so as to have an “effect of inducement” on another person for dealing in securities.

The Regulation prohibits employing any device, scheme or artifice in connection with dealing with or issuance of securities. It also prohibits engaging in any acts or course of business which operates as fraud or deceit upon any one in connection with dealing in or issuance of the securities. It is noted from the Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling records that Mr. Hanif Shekh was prima facie instrumental in the creation of sender IDs which were used to send bulk SMSs and website which was used to give buy recommendation to the public at large to buy the scrip. Further, the impact of the said bulk SMSs was also noted on the scrip as pursuant to the circulation of those SMSs, there were significant increase in the volume of shares and marked increase in the price of the scrip that were traded the next day of circulation of such SMSs. Not only the SMS was disseminating misleading information by giving random target price in the scrip but was also spreading false news such as “N.S.E. LISTING IN 12 DAYS- BUY”. Moreover, as noted earlier, after exiting the scrip with profits, the Off Loaders, transferred the proceeds to the Promoter related companies and also to certain conduits so that the said funds can be eventually transferred to Mr. Hanif Shekh.

The said acts and conduct involving transfer of funds out of sales proceeds earned by the Off Loaders prima facie shows the complicity of the Promoters of the Company with Mr. Hanif Shekh. The said involvement of the Promoters of the Company when seen along with the fact that when such bulk SMSs were circulating in the market for a considerable period of time, disseminating misleading and false information, no action or clarification was forthcoming from them who were also in charge of the affairs of the Company, thereby further strengthening the prima facie inference of their collusion with Mr. Hanif Shekh in sending the bulk SMSs. The aforesaid actions of Mr. Hanif Shekh and the Promoters of the Company, Mr. Navneet Kumar Sureka and Ms. Deepa Sureka have prima facie led to the violation of Sections 12A (a), (b) and (c) of SEBI Act and regulations 3 (a), 3 (b), 3 (c), 3(d), 4(1) and 4(2)(k) and (r) of PFUTP Regulations. Further, as noted in preceding paragraphs, Sambhavanath Traders (Proprietor – Mr. Chandraprakash Valchand Parekh) has prima facie played a decisive role in operationalising the website, www.midcapgains.in without which the prima facie scheme would not have been able to be implemented at its full vigour.

Therefore, the actions of Sambhavanath Traders (Proprietor – Mr. Chandraprakash Valchand Parekh) has prima facie led to the violation of Sections 12A (a), (b) and (c) of SEBI Act and regulations 3 (a), 3 (b), 3 (c), 3(d), 4(1) and 4(2)(k) and (r) of PFUTP Regulations.

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling

48. Moving on to the Collaborators who as a group were taking turns to deal in the scrip and were executing intra day trades even at the expense of continuous losses just to maintain the positive momentum in the scrip which was created by the PV Influencers, so that the same momentum can be sustained post sending of the SMS, have prima facie indulged in a deceitful behavior and unfair trade practices. Their premediated way of accessing the securities market in small units to execute trades in the scrip and also intentionally incurring losses, prima facie do not show a genuine trading behavior. Trading is always done with the aim to make profits. But if one party consistently and prima facie deliberately, makes losses and the same behavior is repeated across the group members, the same prima facie constitutes an unfair trade practice as nobody intentionally trades only for incurring loss. Any intentional trading for incurring losses per se, is not a genuine dealing in securities. Moreover, as noted earlier, the trading activities of the Collaborators were undertaken by following a peculiar and unusual pattern that was prima facie suggestive of the fact that such trades executed by the Collaborators were undertaken as part of a scheme wherein they had to maintain the liquidity in the scrip over a period so that the next leg of the scheme could be implement wherein the Off Loaders could dump their shares and exit the scrip by making considerable profit.

Therefore, when the actions of the Collaborators are seen conjointly in the context of giving effect to the prima facie scheme, it is unequivocal that the Collaborators were not trading in the normal and ordinary course. Consequently, it can be prima facie inferred that their dealing in the scrip has clearly restricted the free and fair operation of market forces in the scrip and has upset the market equilibrium. Any transaction executed to defeat the market mechanism is illegal and amounts to compromising the integrity of the market. Therefore, the actions of the Collaborators namely, Goenka Business Finance Limited, Mr. Kalpesh Dantani, Mr. Shivam Kumar, Mr. Sanjaybhai Babubhai Solanki, Mr. Chetanbhai Mahendrabhai Dantani, Mr. Suresh Deshaljibhai Vaghela and Mr. Amrutji Gokaji Thakor along with the kingpin of the prima facie scheme Mr. Hanif Shekh and the Promoters of the Company, Mr. Navneet Kumar Sureka and Ms. Deepa Sureka, have prima facie led to the violation of Sections 12A (a), (b) and (c) of SEBI Act and Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling regulations 3 (a), 3 (b), 3 (c), 3(d), 4(1) and 4(2)(a), (b) and (e) of PFUTP Regulations.

Additionally, as observed in the preceding paragraphs that the Collaborators have prima facie played their role as part of the prima facie scheme hatched by Mr. Hanif Shekh along with the Promoters of the Company. Considering the timing of their dealing in the scrip, it would be too much of a coincidence to believe that they dealt in the scrip right at the opportune time when the liquidity in the scrip had to be maintained. Therefore, the coming together of the Collaborators and Mr. Hanif Shekh without the aid of Mr. Malay Bhow prima facie cannot be ruled out. Thus, Mr. Malay Bhow is also prima facie instrumental in facilitating the execution of the prima facie scheme. The said action of Mr. Malay Bhow has led to the prima facie violation of Sections 12A (a), (b) and (c) of SEBI Act and regulations 3 (a), 3 (b), 3 (c), 3(d) and 4(1) of PFUTP Regulations. 49. Similarly, the Off Loaders were also not prima facie genuine traders in the scrip as not only the majority of them did not have the financial capacity to deal in huge volumes in the scrip and some of them were also funded by other entities, their only prima facie purpose to trade in the scrip was to take undue benefit of the liquidity and the high price created in the scrip by the previous players of the prima facie scheme as part of a pre-meditated plan employed in the scrip.

Thus, the trades executed by the Off Loaders were prima facie not in the normal and ordinary course and were non-genuine trades as they were executed pursuant to the prima facie scheme. Therefore, the actions of the Off Loaders were prima facie a deliberate unwarranted interference in the operation of ordinary market forces of supply and demand in the scrip and consequently it has not only undermined the integrity and efficiency of the market but has also prima facie portrayed a misleading appearance of trading in the scrip thereby inducing the other investors to deal in the scrip. The aforesaid actions of the Off Loaders as highlighted in the Table No. 11 along with the actions of the kingpin of the prima facie scheme Mr. Hanif Shekh and the Promoters of the Company, Mr. Navneet Kumar Sureka and Ms. Deepa Sureka, have prima facie led to the violation of Sections 12A (a), (b) and (c) of SEBI Act and regulations 3 (a), 3 (b), 3 (c), 3(d), 4(1) and 4(2)(a) of PFUTP Regulations. Additionally, as noted in the preceding paragraphs,

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling the Off Loaders post their exit from the scrip had transferred funds via multiple layers to the Promoters of the Company and its connected entities namely, Mauria Udyog Ltd. and Vee Em Infocenter Ltd. The same had enabled Promoters of the Company to become the Ultimate Beneficiary of the prima facie scheme employed in the scrip. Thus, the actions of Mauria Udyog Ltd. and Vee Em Infocenter Ltd. have prima facie led to the violation of Sections 12A (a), (b) and (c) of SEBI Act and regulations 3 (a), 3 (b), 3 (c), 3(d) and 4(1) of PFUTP Regulations. 50. It is noted from records that entities connected to Mr. Hanif Shekh namely Mr. Kasambhai Shekh, Ms. Hasina Kasambhai Shekh, Robert Resources Ltd., Econo Trade India Ltd., Econo Broking (Erstwhile Bansal Finstock) and Sai Metaltech LLP, entities mentioned at Table 21 and entities mentioned at Table No. 17 have prima facie enabled him to encash the benefit of the scheme employed by him along with the Promoters of the Company in the scrip as they had facilitated in transferring of funds which were received by them from the other connected entities of Mr. Hanif Shekh namely Sub-groups 2.A, 3 and 3.A who had dealt in the scrip pursuant to the prima facie scheme employed in the matter.

Thus, the aforesaid actions of the connected entities of Mr. Hanif Shekh have prima facie led to the violation of Sections 12A (a), (b) and (c) of SEBI Act and regulations 3 (a), 3 (b), 3 (c), 3(d) and 4(1) of PFUTP Regulations. 51. With respect to Mr. Deepak Kumar Garg and Mr. Davinder Kumar Gupta, it is observed that Mr. Deepak Kumar Garg had maintained an Excel Sheet wherein all the details of the activities of Off Loaders who were employees of the Company viz., details of trades done by them such as number of shares bought/sold, date of trade, pay out date etc. was mentioned along with details of beneficiaries to whom the said entities had transferred their sale proceeds with bank account no., UTR no, date of transfer, amount transferred etc. The said Excel Sheet was sent by him to Mr. Davinder Kumar Gupta. Not only that, the entrenchment of both the aforesaid two entities in the prima facie scheme is further borne out from the fact that in the ITR filing of 21 entities (Off Loaders who were employees of the Company) as mentioned at Table No. 11, Mr. Davinder Kumar Gupta’s email id (dkgupta1087@gmail.com) and mobile number

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling (8800772803) has been provided. Moreover, the mobile number of Mr. Deepak Kumar Garg, 9268823641 was common with various Off Loaders (Mithun Singh, Jeet Bahadur, Hare Ram, Roshan Kumar Jaiswal, Sukhilal Meena, Leelu Singh, Arvind Kumar, Krishan Murari Sharma, Binod Kumar Jha, Hoshiyar Saini, Mahender Singh and Narender) and 5 of the Off Loaders recovery email id was same as that of him, lmgupta@mauria.com, as noted from the UCC details. It has already been noted in preceding paragraphs that the Off Loaders who were connected with the Company were as per the prima facie scheme were the front entities who were dealing in the scrip on behalf of the Promoters of the Company. Consequently, it can also be prima facie inferred that Mr. Deepak Kumar Garg and Mr. Davinder Kumar Gupta were instrumental in managing the dealing of the Off Loaders who were connected with the Company in the scrip and maintaining the records thereof. Thus, the actions of Mr. Deepak Kumar Garg and Mr. Davinder Kumar Gupta which prima facie enabled the Promoters of the Company to execute the scheme has led to the violation of Sections 12A (a), (b) and (c) of SEBI Act and regulations 3 (a), 3 (b), 3 (c), 3(d) and 4(1) of PFUTP Regulations.

52. Furthermore, as observed in the preceding paragraphs with respect to flow of funds by entities who have dealt in the scrip pursuant to the prima facie scheme that post dealing in the scrip they have transferred funds to entities connected to the Promoters of the Company through multiple layers and one such entity was Linkwise Marketing Pvt. Ltd. Thus, Linkwise Marketing Pvt. Ltd. has prima facie enabled Promoters of the Company to encash the benefit of the scheme employed by them along with Mr. Hanif Shekh in the scrip, as it had facilitated in transferring of funds which were received by it from the other connected entities of Promoters of the Company who had dealt in the scrip pursuant to the prima facie scheme. The said action of Linkwise Marketing Pvt. Ltd. has prima facie led to the violation of Sections 12A (a), (b) and (c) of SEBI Act and regulations 3 (a), 3 (b), 3 (c), 3(d) and 4(1) of PFUTP Regulations. 53. The issue which now merits discussion is who amongst the aforesaid entities, would be prima facie liable for the proceeds generated by the employment of the prima facie scheme in the scrip.

From the above discussion, I note that the kingpin, Mr. Hanif

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling

Shekh and the Promoters of the Company, Mr. Navneet Kumar Sureka and Ms. Deepa Sureka have prima facie masterminded and implemented the scheme at its various stages. Not only were they the Ultimate Beneficiaries of the prima facie scheme even though they have tried their best to obfuscate the funds trail by executing the funds transactions through multiple layers. Therefore, based on the available records, it is prima facie inferred that Mr. Hanif Shekh and his connected entities namely Mr. Kasambhai Shekh, Ms. Hasina Kasambhai Shekh, Robert Resources Ltd., Econo Trade India Ltd., Econo Broking (Erstwhile Bansal Finstock) and Sai Metaltech LLP including Sub Groups 2 and 3 and Promoters of MUL, Mr. Navneet Kumar Sureka and Ms. Deepa Sureka are jointly and severally liable for the wrongful gains generated in the scrip by the employment of the prima facie scheme as discussed in preceding paragraphs, to the tune of INR 33,48,04,829/- while the Promoters of MUL, Mr. Navneet Kumar Sureka and Ms. Deepa Sureka along with their connected companies namely, Mauria Udyog Ltd., Vee Em Infocenter Ltd. and Mr. Hanif Shekh and his connected entities namely Mr. Kasambhai Shekh, Ms. Hasina Kasambhai Shekh, Robert Resources Ltd., Econo Trade India Ltd., Econo Broking (Erstwhile Bansal Finstock) and Sai Metaltech LLP are jointly and severally liable for the wrongful gains generated in the scrip by the employment of the prima facie scheme as discussed in preceding paragraphs, to the tune of INR 26,19,68,781/-. Furthermore, the PV Influencers (entities at Table No. 6) who have also exited the scrip by making wrongful gains to the tune of INR 7,38,34,535/- are jointly and severally liable for the said wrongful gains generated in the scrip by them. Vishal Fabrics Ltd. 54. Vishal Fabrics Ltd. (hereinafter referred to as “VFL / Company”) was incorporated in 1985 and is involved in dyeing, printing and processing of denim, and other wide range of fabrics. VFL got listed on BSE on August 20, 2014. Based on the price and volume movement in the scrip, the trading in the scrip was examined for the period of March 25, 2020 to October 20, 2010 (hereinafter referred to as “Investigation Period - VFL”). It is noted that during the period of March 25, 2020 to September 4, 2020 (pre-SMS period), the scrip had opened on BSE at INR 134/- and closed at INR

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling

272/- with a high of INR 291.80/-, with an average daily volume of 10,382 shares, while during the period of September 7, 2020 to October 20, 2020 (during SMS period), the scrip had opened on BSE at INR 274.10/- and closed at INR 369.25/- with a high of INR 369.35/-, with an average daily volume of 91,217 shares. At NSE, during the period of March 25, 2020 to September 4, 2020 (pre- SMS period), the scrip had opened at INR 144.10/- and closed at INR 272/- with a high of INR 299/-, with an average daily volume of 11,701 shares, while during the period of September 7, 2020 to October 20, 2020 (during SMS period), the scrip had opened on NSE at INR 274.10/-and closed at INR 369.20/- with a high of INR 369.40/-, with an average daily volume of 6,63,124 shares. The aforesaid figures show that not only the price in the scrip increased by more than 2.5 times within a brief span of 7 months but there was a massive spurt in the volume of the scrip as well. The Price – Volume chart in the scrip during the aforesaid period is depicted below: Figure No. 5 BSE PV Chart - VFL 400 160000 350 140000 300 120000 250 100000 200 80000 150 60000 100 40000 50 20000 0 0 25-Mar-20 25-Apr-20 25-May-20 25-Jun-20 25-Jul-20 25-Aug-20 25-Sep-20 No.of Shares Close Price

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling

Figure No. 6 NSE PV Chart - VFL 400 1400000 350 1200000 300 1000000 250 800000 200 600000 150 400000 100 50 200000 0 27-Mar-20 27-Apr-20 27-May-20 27-Jun-20 27-Jul-20 27-Aug-20 27-Sep-20 Total Traded Quantity Close Price 55. The aforesaid Price – Volume charts show that from March 2020 onwards till August 2020, there has been a gradual increase in the price and volume of the scrip but in the next two months i.e., during September - October 2020, there has been a noteworthy increase in both price and volume of the scrip. During the investigation period it is noted that there were hardly any major corporate announcements made by VFL. The absence of major corporate announcements by the Company has to be seen in conjunction with the bulk SMSs which had started circulating in the scrip with buy recommendations from September 7, 2020 onwards. As noted in the preceding paragraphs, circulation of bulk SMSs is prima facie the epicentre of the scheme that was employed in the scrip. The aforesaid factors were compelling enough to examine the dealings in the scrip during the investigation period. Accordingly, the trading in the scrip of VFL has been examined in two phases, one during pre-SMS period (March 25, 2020 to September 4, 2020) and the other during SMS period (September 7, 2020 to October 20, 2020).

PV Influencers 56. It is noted from the records that during pre-SMS period (March 25, 2020 to September 4, 2020), the price in the scrip on both the Stock Exchanges has increased gradually

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling but steadily month on month onwards. The month wise break-up of the increase in the price during this period is indicated below: Table No. 30 Price Volume BSE Month Closing % change from Month Average Volume Price (INR) closing price on March 24, 2020 Mar-20 158.50 17.84% Apr-20 218.05 62.12% May-20 251.45 86.95% Jun-20 258.00 91.82% Pre-SMS period 10,382 Jul-20 273.10 103.05% Aug-20 274.50 104.09% NSE Mar-20 158.75 10.24% Apr-20 218.50 51.74% Pre-SMS period May-20 251.40 74.58% 11,701 Jun-20 258.00 79.17% Jul-20 273.10 89.65% Aug-20 274.50 90.63%

Chiripal Group 57. It will be relevant here to note that the following entities are part of the Promoter / Promoter Group of VFL: Mr. Brijmohan Chiripal Devkinandan, Chiripal Industries Limited, Mr. Deepak J Chiripal, Mr. Jaiprakash D Chiripal, Mr. Jyotiprasad D Chiripal, Ms. Nitika Deepak Chiripal, Ms. Priyanka Brijmohan Chiripal, Mr. Ravindrakumar Bajranglal Bajaj, Mr. Ronak B Agarwal, Ms. Savitridevi V Chiripal, Shanti Exports Pvt Ltd, Tripoli Management Private Limited and Mr. Vedprakash Devkinandan Chiripal. It is noted from the material available on record that the following group (collectively referred to as “Chiripal Group”) of connected entities who were prima facie directly and / or indirectly connected with the Promoter / Promoter Group of VFL, were frequently trading in the scrip of VFL during the pre-SMS period:

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling

Table No. 31 Sl. No. Name of the Entity Basis of Connection As per UCC details, it is observed that  Entities at Sr. No 1 and 4 have common contact no. “528518708”. As per KYC documents provided by Banks based in UAE (Habib Bank AG Zurich), it is observed that 1 Anil Dhanuka  Entities at Sr. No 1 and 4 are Partners/Directors in Golden Multitrade (FZC). As per submission of Entity at Sr. No. 4, it is observed that  Entity at Sr. No. 1 is a business partner of Entity at Sr No. 4 in UAE. As per UCC details, it is observed that Chiripal Suryansh  Entities at Sr No 2 and 9 have common email Id- 2 Hari sidhsales@gmail.com. As per UCC details, it is observed that  Entity at Sr. No. 3 has a common Mobile No- “9974089611” with Deepak J Chiripal, Jaiprakash D Chiripal and Priyanka Brijmohan Chiripal.  Entities at Sr. No. 3, 7 and Tripoli Management Private Limited have common email id maheshadhyaru@chiripalgroup.com.  Brijmohan Chiripal Devkinandan, Entity at Sr. No. 3, Jaiprakash D Chiripal, Jyotiprasad D Chiripal, Nitika Deepak Chiripal, Shanti Exports Pvt Ltd and Entity at Sr. No. 11 have Durgeshwari common email id monil@chiripalgroup.com. 3 Pradipbhai Chiripal  Deepak J Chiripal, Entity at Sr. No. 3, Jaiprakash D Chiripal, Ronak B Agarwal, Entity at Sr. No. 8 and Shanti Exports Pvt Ltd have common email id nareshagrawal@chiripalgroup.com. As per bank statement, it is observed that  Entity at Sr No 3 had multiple bank transactions with Entity at Sr No 6. As per submission of Entity at Sr No 3, it is observed that Entity at Sr No 3 had business transactions with Entities at Sr. No. 7, 8, 9, Jyotiprasad D Chiripal, Nitika Deepak Chiripal and Tripoli Management Private Limited. As per UCC details, it is observed that  Entities at Sr. No 1 and 4 have common contact no. “528518708”. Manuj Ashokkumar  Entities at Sr. No 4 and 11 have a common address – “A 14 4 Chiripal Shivam Apartment, Opp Inductotherm, Bopal, Ahmedabad – 380058”. As per KYC documents provided by Banks based in UAE, it is observed that Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling

Sl. No. Name of the Entity Basis of Connection  Entities at Sr. No 1 and 4 are Partners/Directors in Golden Multitrade (FZC). As per KYC documents provided by Bank, it is observed that  Entity at Sr No 4 is the son of Entity at Sr No 11. As per submission of Entity No 3, it is observed that  Entity at Sr No. 1 is a business partner of Entity at Sr No. 4 in UAE.  Entity at Sr No 11 is the mother of Entity at Sr No 4.  Golden Multitrade (FZC) had banking transactions with VFL.  Brijmohan Chiripal Devkinandan is the uncle of entity at Sr. No 4.  Entity at Sr. No. 3 is aunt of entity at Sr. No 4. As per the submission of Entities at Sr. No. 10 and 12, it is observed that  Entities at Sr No. 5, 10, 12, 14 and Brijmohan Chiripal Raaj Ravindrakumar 5 Devkinandan are relatives. Bajaj As per bank statement, it is observed that  Entities at Sr No 5 and 6 had banking transactions. As per UCC details, it is observed that  Entities at Sr. No. 6 and 11 have common mobile no. “9925010586” with Jaiprakash D Chiripal and Jyotiprasad D Chiripal.  Entities at Sr. No. 6, 7 and 9 have common mobile no. “9727768088” and common email id-purvee@chiripalgroup.com.  Entities at Sr. No. 6 and 7 have common address- “283 New Cloth Market Ahmedabad”. As per bank statement, it is observed that  Entity at Sr No. 6 had multiple banking transactions with Entities at Sr. No. 3, 5, 9, 11, 14, Brijmohan Chiripal Devkinandan and Chiripal Industries Limited. 6 Rushp Trading LLP As per MCA data, it is observed that  Entity at Sr No. 11 is a Designated Partner of Entity at Sr No. 6.  Mr Pawankumar Rambilas Agarwal, Designated Partner of Entity at Sr No 6 is a Director in Chiripal Lifestyle Limited along with Brijmohan Chiripal Devkinandan, Jaiprakash D Chiripal and Jyotiprasad D Chiripal.  Entities at Sr. No. 6 and 7 have a common Designated Partner namely Ms Rukmanidevi Agarwal. As per the submission of Entity at Sr No 6, it is observed that  Entity at Sr No 6 has business transactions with Chiripal Industries Limited, Entity at Sr No 3, Jaiprakash D Chiripal, Nitika Deepak Chiripal, Priyanka Brijmohan Chiripal, Ronak

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling

Sl. No. Name of the Entity Basis of Connection B Agarwal, Entity at Sr No Entity at Sr No 8, Shanti Exports Pvt Ltd, Entity at Sr No 11, Tripoli Management Private Limited and Entity at Sr No 14. As per UCC details, it is observed that  Entities at Sr. No. 6, 7 and 9 have common mobile no. “9727768088” and common email id-purvee@chiripalgroup.com.  Entities at Sr. No. 7, 11 and Tripoli Management Private Limited have common contact no. “9727768083”.  Entities at Sr. No. 3, 7 and Tripoli Management Private Limited have common email id maheshadhyaru@chiripalgroup.com. As per bank statement, it is observed that  Entity at Sr No 7 had multiple banking transactions with Satrama Trading 7 Chiripal Industries Limited, Entities at Sr No 9 and 15. LLP As per MCA data, it is observed that  Ms Ramdulari Sidhkishor Agarawal is a Designated Partner in Entities at Sr. No. 7 and 9. As per the submission of Entity at Sr No 7, it is observed that  Entity at Sr No 7 had business transactions with Entities at Sr. No. Brijmohan Chiripal Devkinandan, Chiripal Industries Limited, Deepak J Chiripal, Entity at Sr No 3, Jaiprakash D Chiripal, Jyotiprasad D Chiripal, Ronak B Agarwal, Entity at Sr No 8, Shanti Exports Pvt Ltd, Entity at Sr No 11, Tripoli Management Private Limited and Entity at Sr No 14. As per UCC details, it is observed that  Ankit Naresh Agarwal, Chiripal Industries Limited, Deepak J Chiripal, Jyotiprasad D Chiripal, Nitika Deepak Chiripal, Ronak B Agarwal, Entity at Sr No 8, Shanti Exports Pvt Ltd and Tripoli Management Private Limited have common Mobile No. “9879105115”.  Deepak J Chiripal, Entity at Sr. No. 3, Jaiprakash D Chiripal, Ronak B Agarwal, Entity at Sr. No. 8 and Shanti Exports Pvt Savitridevi V Ltd. have common email id 8 Chiripal nareshagrawal@chiripalgroup.com. As per off-market transactions data, it is observed that  Entity at Sr. No. 8 had off-market transaction with Entity at Sr. No. 3 on 18/02/2020 in the scrip of VFL. As per the submission of Vishal Fabrics Limited, it is observed that  Entity at Sr. No. 8 and Entity at Sr. No. 13 are Promoter/Promoter Group/Director of VFL. Shivhari Trading As per UCC details, it is observed that 9 LLP

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling

Sl. No. Name of the Entity Basis of Connection  Entities at Sr. No. 6, 7 and 9 shared a common mobile no. “9727768088” and a common email id-purvee@chiripalgroup.com.  Entities at Sr. No. 5 and 9 have common email id-sidhsales@gmail.com. As per bank statement, it is observed that  Entity at Sr No 9 had multiple banking transactions with Chiripal Industries Limited, Tripoli Management Private Limited, Entities at Sr No 6, 7 and 15. As per MCA data, it is observed that  Ms Rukmanidevi Agarwal is a Designated Partner in Entities at Sr. No. 6 and 9.  Ms Ramdulari Sidhkishor Agarawal is a Designated Partner in Entities at Sr. No. 7 and 9. As per the submission of Entity at Sr No. 9, it is observed that  Entity at Sr No. 9 had business transactions with Brijmohan Chiripal Devkinandan, Chiripal Industries Limited, Entity at Sr No. 2, Deepak J Chiripal, Entity at Sr No. 3, Jaiprakash D Chiripal, Jyotiprasad D Chiripal, Nitika Deepak Chiripal, Priyanka Brijmohan Chiripal, Ronak B Agarwal, Entity at Sr No. 7, Entity at Sr No. 8, Shanti Exports Pvt Ltd, Entity at Sr No. 11, and Tripoli Management Private Limited. As per the submission of Entities at Sr. No. 10 and 12, it is observed that 10 Sonali Ateet Bajaj  Entities at Sr No. 5, 10, 12, 14 and Ravindrakumar Bajranglal Bajaj are relatives. As per UCC details, it is observed that  Entities at Sr. No. 6 and 11 have common mobile no. “9925010586” with Jaiprakash D Chiripal and Jyotiprasad D Chiripal.  Brijmohan Chiripal Devkinandan, Entity at Sr No. 3, Jaiprakash D Chiripal, Jyotiprasad D Chiripal, Nitika Deepak Chiripal, Shanti Exports Pvt Ltd and Entity at Sr No. 11 have common email id monil@chiripalgroup.com.  Entities at Sr. No 4 and 11 have common address – “A 14 Sushila Ashokbhai 11 Shivam Apartment, Opp Inductotherm, Bopal, Ahmedabad – Chiripal 380058”.  Entities at Sr. No. 7 and 11 have common contact no. “9727768083”. As per submission of 4, it is observed that  Entity at Sr No 11 is the mother of Entity at Sr No 4. As per MCA data, it is observed that  Entity at Sr No. 11 is a Designated Partner in Entity at Sr No. 6.

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling

Sl. No. Name of the Entity Basis of Connection As per the submission of Entities at Sr. No. 10 and 12, it is observed that 12 Trisha Vikas Bajaj  Entities at Sr No. 5, 10, 12, 14 and Ravindrakumar Bajranglal Bajaj are relatives. As per the submission of Vishal Fabrics Limited, it is Vedprakash observed that 13 Devkinandan  Part of Promoter/Promoter Group/Director of VFL. Chiripal As per UCC details, it is observed that  Entities at Sr. No. 5 and 14 have common contact no. “9825604515” and email id-yashrbajaj@gmail.com. As per the submission of Entities at Sr. No. 10 and 12, it is observed that 14 Yash Ravi Bajaj  Entities at Sr No. 5, 10, 12, 14 and Ravindrakumar Bajranglal Bajaj are relatives. As per the submission of Entity at Sr No 6, it is observed that  Entity at Sr No 6 had business transactions with Entity at Sr. No. 14. As per bank statement, it is observed that Yogeshkumar 15  Entity at Sr No 15 had banking transactions with Entities at Anandpal Goyal Sr No 7 and 9. 58. It is noted from the factual points presented in the above table that the aforesaid 15 entities are not only connected with the Company but are also inter alia connected with each other either by way of common mobile no. or having common email id or are relatives of each other or having multiple fund transactions or business transactions amongst themselves.

For instance, as per UCC details, Mr. Anil Dhanuka and Mr. Manuj Ashokkumar Chiripal shared a common mobile number viz. “1528518708”. Similarly, Rushp Trading LLP, Satrama Trading LLP and Shivhari Trading LLP shared a common mobile number viz. “9727768088” and common email id i.e. “purvee@chiripalgroup.com:. Further, Mr. Yash Ravi Bajaj, Ms. Trisha Vikas Bajaj, Ms. Sonali Ateet Bajaj and Raaj Ravindrakumar Bajaj are relatives. Various fund transfers have been observed amongst Rushp Trading LLP and Ms. Durgeshwari Pradipbhai Chiripal, Mr. Raaj Ravindrakumar Bajaj, Shivhari Trading LLP, Ms. Sushila Ashokbhai Chiripal and Mr. Yash Ravi Bajaj. The aforesaid factual findings prima facie show that these entities enjoyed a strong inter se connection amongst themselves and when such connection is seen along with the way the said entities have traded in a Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling concerted manner and also seen to have traded posing as counterparties to each other’s trades in the scrip of VFL during the pre-SMS period (March 25, 2020 to September 7, 2020), it would prima facie demonstrate that their dealings in the scrip of VFL was not genuine trades executed in normal course of trading in securities market but instead were undertaken as part of a premediated plan or scheme to perpetrate fraudulent trades in the scrip of VFL.

The aforesaid inference is further buttressed from the fact that during the pre-SMS period, it was observed that the Chiripal Group, Ahmedabad based entities (Sub-group 2) and Kolkata based entities (Sub-group 3) were found to be frequently trading amongst themselves in the scrip of VFL. As noted in preceding paragraphs, the Ahmedabad based entities and Kolkata based entities are prima facie connected with Mr. Hanif Shekh who is also the prima facie the SMS Sender in the scrip of VFL. Thus, the very act of the aforesaid three motley group of entities coming together to deal in the scrip of VFL during the pre- SMS period has to be by design and not by mere coincidence and in all probability, given the preponderance of facts and circumstances, these entities have dealt with the scrip of VFL only pursuant to a prima facie fraudulent scheme employed by them for trading in the scrip. 59. Contribution of aforesaid 3 groups i.e., Chiripal Group, Ahmedabad based entities and Kolkata based entities to the price and volume rise in the scrip of VFL during the period March 25, 2020 to September 4, 2020, is shown below: Table No. 32

% % Buy to % Sell to contrib total total Net Net Entity Type of Buy Sell Total ution to Market Market Buy Sell Name entity Qty Qty LTP net Buy Sell LTP LTP price Volume Volume rise BSE Rushp Chiripal 112014 10.58% 0 0.00% -6.95 - -6.95 -5.04% Trading LLP Group Chiripal Satrama Group 101138 9.55% 0 0.00% 1.00 - 1.00 0.72% Trading LLP Chiripal Bajaj Sonali Group 34300 3.24% 0 0.00% 1.10 - 1.10 0.80% Ateet

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling

% % Buy to % Sell to contrib total total Net Net Entity Type of Buy Sell Total ution to Market Market Buy Sell Name entity Qty Qty LTP net Buy Sell LTP LTP price Volume Volume rise Chiripal Shivhari Group 34025 3.21% 5151 0.49% -2.00 3.75 1.75 1.27% Trading LLP Manuj Chiripal Ashokkuma Group 31726 3.00% 205759 19.43% -2.90 -7.90 -10.80 -7.83% r Chiripal Chiripal Trisha Group 22000 2.08% 0 0.00% -2.30 - -2.30 -1.67% Vikash Bajaj Vedprakash Chiripal Devkinanda Group 18115 1.71% 0 0.00% 0.00 - 0.00 0.00% n Chiripal Chiripal Yash R Bajaj Group 7300 0.69% 0 0.00% 3.00 - 3.00 2.17% Raaj Chiripal Ravindraku Group 7300 0.69% 0 0.00% 0.00 - 0.00 0.00% mar Bajaj Sushila Chiripal Ashokbhai Group 100 0.01% 4000 0.38% 4.00 24.40 28.40 20.58% Chiripal Chiripal Anil Group 0 0.00% 159121 15.03% - 11.60 11.60 8.41% Dhanuka Yogeshkum Chiripal ar Anandpal Group 0 0.00% 18346 1.73% - 0.00 0.00 0.00% Goyal Chiripal Savitridevi Group 0 0.00% 18115 1.71% - 0.00 0.00 0.00% V Chiripal Durgeshwar Chiripal i Pradipbhai Group 0 0.00% 2000 0.19% - 27.70 27.70 20.07% Chiripal Prakash Ahmeda Kantilal bad 4351 0.41% 20 0.00% 7.90 -2.00 5.90 4.28% Vaghela Group Sahilkumar Ahmeda Amrutbhai bad 2701 0.26% 0 0.00% 7.90 - 7.90 5.72% Vaghela Group Ahmeda Shahrukhkh bad 2200 0.21% 93 0.01% 0.10 7.50 7.60 5.51% an Pathan Group Lilaben Ahmeda Popatbhai bad 1950 0.18% 0 0.00% 0.00 - 0.00 0.00% Parmar Group Popatbhai Ahmeda Ramjibhai bad 1900 0.18% 0 0.00% -26.25 - -26.25 -19.02% Parmar Group

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling

% % Buy to % Sell to contrib total total Net Net Entity Type of Buy Sell Total ution to Market Market Buy Sell Name entity Qty Qty LTP net Buy Sell LTP LTP price Volume Volume rise Ahmeda Chiragkuma bad 1501 0.14% 202 0.02% 0.00 0.00 0.00 0.00% r Makwana Group Ahmeda Keval bad 1501 0.14% 0 0.00% 0.20 - 0.20 0.14% Savant Group Ahmeda Hina Barot bad 1350 0.13% 100 0.01% 8.75 2.50 11.25 8.15% Group Ravi Ahmeda Kannadasan bad 1251 0.12% 202 0.02% 0.00 2.50 2.50 1.81% Adidravid Group Dipika Ahmeda Popatbhai bad 1250 0.12% 110 0.01% 0.00 1.00 1.00 0.72% Parmar Group Pritiben Ahmeda Popatbhai bad 1100 0.10% 100 0.01% 8.85 0.00 8.85 6.41% Parmar Group Ahmeda Makwana bad 401 0.04% 102 0.01% 0.00 0.00 0.00 0.00% Madhuben Group Kolkata Sourav Das 30295 2.86% 0 0.00% -3.00 - -3.00 -2.17% Group Highgrowth Vincom Kolkata 28100 2.65% 0 0.00% 0.00 - 0.00 0.00% Private Group Limited Kolkata Uma Dutta 20000 1.89% 0 0.00% 0.00 - 0.00 0.00% Group Kolkata Ujjal Laha 17950 1.69% 0 0.00% -0.05 - -0.05 -0.04% Group Linkup Financial Kolkata Consultants 16500 1.56% 0 0.00% -6.00 - -6.00 -4.35% Group Private Limited Kolkata Arun Dutta 15890 1.50% 0 0.00% -1.00 - -1.00 -0.72% Group Debashish Kolkata 14900 1.41% 0 0.00% -0.05 - -0.05 -0.04% Dutta Group Kolkata Sanjay Dey 12800 1.21% 0 0.00% 1.00 - 1.00 0.72% Group Subrata Kolkata 12700 1.20% 0 0.00% 20.00 - 20.00 14.49% Laha Group Kolkata Arun Laha 12000 1.13% 0 0.00% -5.00 - -5.00 -3.62% Group Kolkata Tapas Laha 9000 0.85% 0 0.00% 5.00 - 5.00 3.62% Group

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling

% % Buy to % Sell to contrib total total Net Net Entity Type of Buy Sell Total ution to Market Market Buy Sell Name entity Qty Qty LTP net Buy Sell LTP LTP price Volume Volume rise Buddhadeb Kolkata 7050 0.67% 0 0.00% 0.00 - 0.00 0.00% Laha Group Kolkata Sumit Laha 6000 0.57% 0 0.00% 0.00 - 0.00 0.00% Group Minu Kolkata 739 0.07% 0 0.00% 0.00 - 0.00 0.00% Mallick Group Priyankar Kolkata 550 0.05% 0 0.00% 0.00 - 0.00 0.00% Laha Group Suprabhat Kolkata 400 0.04% 0 0.00% -8.00 - -8.00 -5.80% Laha Group Total 594348 56.12% 413421 39.04% 5.30 71.05 76.35 55.33% Trading as a group 307405 29.03% 307405 29.03% 25.80 25.80 18.70% 105900 138.0 138.0 138.0 100.00 Market Total 1059004 100.00% 100.00% 4 0 0 0 % NSE Chiripal Shivhari Group 24033 1.96% 1095 0.09% 1.35 -3.00 -1.65 -1.29% Trading LLP Sushila Chiripal Ashokbhai Group 100 0.01% 0 0.00% 0.00 - 0.00 0.00% Chiripal Chiripal Bajaj Sonali Group 9820 0.80% 0 0.00% -0.10 - -0.10 -0.08% Ateet Chiripal Chiripal Suryansh Group 6000 0.49% 0 0.00% -0.90 - -0.90 -0.70% Hari Chiripal Rushp Group 50449 4.11% 0 0.00% -4.00 - -4.00 -3.13% Trading LLP Chiripal Satrama Group 38652 3.15% 1 0.00% -5.45 -0.30 -5.75 -4.49% Trading LLP Chiripal Trisha Group 31700 2.58% 0 0.00% -19.30 - -19.30 -15.08% Vikash Bajaj Chiripal Anil Group 0 0.00% 151295 12.31% - -26.15 -26.15 -20.43% Dhanuka Chiripal Chiripal Manuj Group 0 0.00% 206086 16.77% - -38.15 -38.15 -29.80% Ashokkuma r Chiripal Durgeshwar Group 0 0.00% 1314 0.11% - 0.00 0.00 0.00% i P Chiripal

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling

% % Buy to % Sell to contrib total total Net Net Entity Type of Buy Sell Total ution to Market Market Buy Sell Name entity Qty Qty LTP net Buy Sell LTP LTP price Volume Volume rise Prakash Ahmeda Kantilal bad 5931 0.48% 182 0.01% 33.10 0.00 33.10 25.86% Vaghela Group Ahmeda Chiragkuma bad 5600 0.46% 0 0.00% 7.50 - 7.50 5.86% r Makwana Group Sahilkumar Ahmeda Amrutbhai bad 5519 0.45% 8220 0.67% 0.00 3.75 3.75 2.93% Vaghela Group Ahmeda Makwana bad 4262 0.35% 4 0.00% -0.70 -0.60 -1.30 -1.02% Madhuben Group Dipika Ahmeda Popatbhai bad 3400 0.28% 4540 0.37% 14.90 39.50 54.40 42.50% Parmar Group Lilaben Ahmeda Popatbhai bad 1800 0.15% 3750 0.31% 1.00 -2.20 -1.20 -0.94% Parmar Group Pritiben Ahmeda Popatbhai bad 1799 0.15% 2799 0.23% 8.75 -5.00 3.75 2.93% Parmar Group Popatbhai Ahmeda Ramjibhai bad 1600 0.13% 3500 0.28% -13.95 2.95 -11.00 -8.59% Parmar Group Ahmeda Hina Barot bad 1550 0.13% 100 0.01% 0.00 2.50 2.50 1.95% Group Ravi Ahmeda Kannadasan bad 1351 0.11% 2400 0.20% 0.00 -5.00 -5.00 -3.91% Adidravid Group Ahmeda Shahrukhkh bad 900 0.07% 3007 0.24% 0.00 11.90 11.90 9.30% an Pathan Group Ahmeda Keval bad 5 0.00% 1506 0.12% 0.00 0.00 0.00 0.00% Savant Group Dibakar Kolkata 9080 0.74% 0 0.00% 12.10 - 12.10 9.45% Laha Group Priyankar Kolkata 4324 0.35% 555 0.05% 0.00 0.10 0.10 0.08% Laha Group Kolkata Ujjal Laha 4010 0.33% 2000 0.16% 0.00 2.00 2.00 1.56% Group Kolkata Sanjay Dey 3510 0.29% 0 0.00% 0.00 - 0.00 0.00% Group Kolkata Sourav Das 2094 0.17% 0 0.00% 0.00 - 0.00 0.00% Group Kolkata Uma Dutta 2000 0.16% 0 0.00% 0.00 - 0.00 0.00% Group

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling

% % Buy to % Sell to contrib total total Net Net Entity Type of Buy Sell Total ution to Market Market Buy Sell Name entity Qty Qty LTP net Buy Sell LTP LTP price Volume Volume rise Subrata Kolkata 1300 0.11% 0 0.00% 0.00 - 0.00 0.00% Laha Group Buddhadeb Kolkata 1011 0.08% 0 0.00% 0.00 - 0.00 0.00% Laha Group Kolkata Sumit Laha 1000 0.08% 0 0.00% 0.00 - 0.00 0.00% Group Minu Kolkata 446 0.04% 0 0.00% 0.00 - 0.00 0.00% Mallick Group Kolkata Tapas Laha 31 0.00% 0 0.00% 13.00 - 13.00 10.16% Group Debashish Kolkata 5 0.00% 0 0.00% 0.60 - 0.60 0.47% Dutta Group Total 223282 18.17% 392354 31.93% 47.90 -17.70 30.20 23.59% Trading as a group 84122 6.85% 84122 6.85% 38.20 38.20 29.84% Market Total 1228645 100.00% 1228645 100.00% 128.00 128.00 128.00 100.00%

60. As can be seen from the above table, the Chiripal Group along with Ahmedabad based entities (Sub-group 2) and Kolkata based entities (Sub-group 3) collectively have prima facie contributed 56.12% to the market buy volume and 39.04% to the market sell volume during the pre-SMS period through their trades on BSE. Further, by trading amongst each other as one seamless group in the scrip of VFL, these entities have contributed 29.03% to the total market traded volume during the pre-SMS period. It is also noticed that on BSE, the aforesaid connected entities have contributed to the tune of INR 76.35/- (55.33%) to the net price rise in the scrip during the pre-SMS period. The trades of the said connected entities were analysed to determine as to how the said connected entities were trying to influence the volume and price in the scrip during the pre-SMS period so as to present the scrip as an attractive proposition for the investors in the securities market. Some illustrations to that effect as noticed from their trades on BSE are as follows: 60.1. On March 25, 2020, Mr. Manuj Ashokkumar Chiripal had placed 1 buy order for 18,353 shares of VFL on BSE at 14:32:58 hours at a price of INR 134/- per share. Subsequently, Mr. Yogeshkumar Anandpal Goyal who is also part of the Chiripal Group, had placed 11 different sell orders cumulatively for 18,346

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling shares in the scrip of VFL for INR 134/- per share between 14:33:30 hours to 14:37:26 hours, i.e. within few minutes of placement of the aforesaid single buy order and to be very precise, the time range within which these 11 sell orders were placed was between 30 seconds to 4 minutes and 28 seconds. The aforesaid efforts on the part of the entities to place orders in such a manner led to the matching of 1 buy order of 18,353 shares with 11 different sell orders for different quantities of shares (cumulatively 18,346 shares) at the same price of INR 134/- per share. The aforestated manner of dealing in the scrip apparently resulted into changing hands of 18,346 shares from Mr. Yogeshkumar Anandpal Goyal to Mr. Manuj Ashokkumar Chiripal. These two persons as noted above, belonged to the Chiripal Group and by their act of splitting a single transaction into multiple sub-transactions executed through multiple trades which could have been done in a single trade as well, these entities have prima facie exposed their spurious intention while dealing in the scrip of VFL.

It is also pertinent to note that the aforesaid action on the part of the said two entities has resulted in execution of the first 11 trades in the scrip on that particular day. It is also pertinent to note here that apart from the afore discussed 11 trades, there was no other trade in the scrip of VFL on BSE on that particular trading day. 60.2. On July 3, 2020, Mr. Manuj Ashokkumar Chiripal (part of Chiripal Group) had placed 1 sell order for 20,000 shares of VFL on BSE at 14:49:50 hours at a price of INR 255.5/- per share having order number as 1593747000000018022. Subsequently, one of the connected entities namely, Linkup Financial Consultants Private Limited from the Sub-group 3, had placed 1 buy order for 3,000 shares in the scrip of VFL for INR 255.5/- at 14:52:51 hours (just 3 minutes after the sell order was placed by Mr. Manuj Chiripal). The said sell order got executed and a trade for 3,000 shares at INR 255.5/- was executed in the scrip. No sooner the aforesaid trade was executed, Linkup Financial Consultants Private Limited immediately after 14 seconds i.e. at 14:53:05 hours, placed another buy order for 3,000 shares at INR 255.5 per share which also matched with the pending sell order of Mr. Manuj Ashokkumar Chiripal.

Similar pattern

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling was followed two more times by Linkup Financial Consultants Private Limited i.e. it placed two separate buy orders (3rd and 4th orders) one after the other for 3,000 shares and 2,500 shares at 14:53:18 hours (13 seconds after his 2nd order) and at 14:53:40 hours (22 seconds after his 3rd order) respectively, which also got matched with the sell order of Mr. Manuj Ashokkumar Chiripal, already pending in the system, thereby matching more than 57% (11,500 shares out of 20,000 shares) of the sell order placed by Mr. Manuj Ashokkumar Chiripal. Then, in order to execute the remaining sell orders placed by Mr. Manuj Ashokkumar Chiripal, another connected entity from the Sub-group 3, namely Mr. Sourav Das, placed a buy order for 3,000 shares of scrip of VFL at INR 255.5/- per share (similar to price offered by Mr. Manuj Ashokkumar Chiripal for his sell order) at 15:09:14 hours, which immediately got executed. Straightaway, Mr. Sourav Das placed his 2nd and 3rd buy orders for 3,000 shares and 2,500 shares respectively at price of INR 255.5/- per share at 15:09:20 hours (5 seconds after his 1st order) and 15:09:25 hours (5 seconds after his 2nd order) in order to match the remaining quantity of the pending sell order of Mr. Manuj Ashokkumar Chiripal.

Interestingly, by looking at the market momentum and activities in the scrip and prima facie getting enticed by these artificially created volumes, another market participant placed an order and purchased 790 shares from Mr. Manuj Ashokkumar Chiripal and therefore, Mr. Sourav Das could get only 1,710 shares out of 2,500 shares that he planned to buy. The aforesaid actions on the part of the entities led to matching of 1 single sell order for 20,000 shares with 7 different buy orders for different quantities of shares at the same price of INR 255.5/- per share as placed by the seller. The aforestated trades apparently have resulted into changing hands of 19,210 shares from Mr. Manuj Ashokkumar Chiripal to Linkup Financial Consultants Private Limited and to Mr. Sourav Das and considering that all the three entities are directly / indirectly connected with each other, it can be said that the said sell order could have been matched by the buyer by placing either one or two buy orders as well. It is also important to note that all the aforesaid 8 orders viz. (1 sell and 7 buy orders) placed by these Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling connected entities, were placed consecutively, in sequence (one after another) ranging from order number 1593747000000018022 to 1593747000000018029 resulting in 7 continuous trades in the scrip from trade numbers 11 to 17, which prima facie demonstrates that the aforesaid connected entities have dealt in the scrip in a pre-planned manner only to generate trading activities around the scrip in a concocted manner.

60.3. I note that the aforesaid instance is not a solitary instance since similar pattern of dealing in the scrip wherein one buy / sell order is matched with multiple buy / sell orders has been executed on numerous occasions by the aforesaid Groups in the scrip during the pre-SMS period. For instance, on July 2, 2020, Shivhari Trading LLP (part of Chiripal Group) had placed one buy order for 4,000 shares of VFL at BSE for INR 255/- per share at 11:19:35 hours bearing order number 1593660600000021010, which remained unexecuted for almost 40 minutes till a sell order was placed by Mr. Anil Dhanuka (part of Chiripal Group) for 6,000 shares at INR 255/- per share at 11:58:13 hours (order number 1593660600000021011), which resulted in a trade of 4,000 shares in the scrip of VFL. Immediately, within 5 minutes, i.e. at 12:03:43 hours, another buy order (order number 1593660600000021012) for 2,000 shares (to match with the pending sell order of Mr. Anil Dhanuka) was placed by Shivhari Trading LLP at a price of INR 255/-, which resulted in another trade for 2,000 shares. It is pertinent to mention here that these 2 trades were the 1st two trades in the scrip of VFL on that day, which started the momentum for the trading in the scrip for the rest of the day.

61. The aforesaid illustrations of the trades executed by the PV Influencers (Chiripal Group, Ahmedabad based entities and Kolkata based entities) in the scrip demonstrates the trading pattern of the PV Influencers wherein the buyers and the sellers across the various groups have traded in close proximity of time inter se amongst them which means, the orders were being placed on the anonymous exchange trading system in a manner that they matched with each other and was confined to the connected entities of the aforesaid group. The buy and sell orders were Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling placed within a short time interval and the trades which could have been executed in one or two transactions were broken down into several smaller transactions. By the said act, the entities have not only prima facie made an attempt to artificially inflate the number of trades executed in the scrip on a particular trading day thereby trying to artificially create more number of trades but have also deliberately try to set a positive momentum for the trading in the scrip.

Further, considering the fact that the counter parties to the trades were mostly connected with each other resulting in the beneficial ownership of the shares so traded, staying within the group, it prima facie shows how the PV Influencers were attempting to create artificial volume in the scrip by indulging in such trades. The aforesaid act of the PV Influencers to influence the volume in the scrip becomes further glaring from the fact that the entities were placing orders within few minutes of each other’s orders and their orders were almost identical in terms of quantity and price. Thus, the PV Influencers have prima facie tried to influence the volume in the scrip by executing their trades in a structured manner wherein the orders were being placed in tandem with each other’s orders so as to ensure that the orders placed by the connected entities matched with each other thereby contributing to the trade volumes and price of the scrip in a pre-designed manner. Needless to observe here that the aforesaid trading pattern repeatedly followed by the PV Influencers could not have occurred by accident or by coincidence and rather such an unusual and artificial manner of trade in the scrip of VFL lead me to a prima facie inference that there was a prior meeting of minds with a pre-determined plan.

Therefore, the aforesaid trades executed in the scrip by PV Influencers to create artificial volume in the scrip were prima facie non-genuine trades and were executed in pursuance of a scheme employed in the scrip. 62. It is also observed that the aforesaid method is not the only method employed by the aforesaid connected entities to prima facie create an artificial volume in the scrip but was the most frequently used strategy. The pre-determined plan of the PV Influencers to create an artificial volume in the scrip becomes prima facie evident, when the trades executed by them are juxtaposed with the total trades executed in the scrip during the pre-SMS period. As per the available records, it is noted that during the Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling pre-SMS period, a total number of 2,245 trades were executed in the scrip of VFL on BSE which resulted in trading of 10,59,004 shares of VFL. Out of the said 10,59,004 shares of VFL that were traded during the pre-SMS period, the connected entities (PV Influencers) while acting as buyers, have cumulatively traded for 5,94,348 (56.12%) shares of VFL in just 339 trades (14.87% of total trades executed in the scrip during the period).

Similarly, for contributing 39.04% of the total volume as sellers, these connected entities have traded in 496 trades (22.09% of the total trades in the scrip). Further, while trading within the group, it is observed that these entities have contributed to trading in 3,07,405 shares (29.02% of total trading volume) in only 176 trades (7.83% of total trades executed in the scrip during the period). Though the connected entities have prima facie created substantial volume in the scrip during the pre-SMS period, however, in effect only 17.08% (56.12% - 39.04%) of their traded volume during the said period has resulted in actual change in beneficial ownership while the remaining 39.04% shares were used just to create a prima facie artificial volume in the scrip with no change in effective beneficial ownership i.e., the ownership of the shares stayed within the group. 63. It is noted from the material available on record that the PV Influencers have cumulatively contributed to a price rise of INR 76.35/- (55.33%) of the net price rise of INR 138/- seen in the scrip of VFL at BSE during the pre-SMS period.

Further, these connected entities, by trading amongst each other, have contributed INR 25.80/- (18.70%) to the net price rise of INR 138/- in the scrip of VFL at BSE during the pre- SMS period. Upon examination of the trade log of the PV Influencers, it was noted that various methods were employed by these entities to prima facie influence the price in the scrip viz., structured trades by as pointed out earlier and manipulating the closing price and opening price etc. Few illustrations to that effect are presented below: 63.1. On March 27, 2020, one of the connected entities namely Mr. Sahilkumar Amrutbhai Vaghela (part of Sub – group 2), had placed a buy order at BSE for 200 shares of VFL at INR 144.9/- (at that time the LTP was INR 137) and after 9 minutes, another connected group entity namely Mr. Durgeshwari Pradipbhai Chiripal (part of Chiripal Group) placed a sell order for 200 shares, exactly at the Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling price of INR 144.9/- to match the pending buy order of the connected group entity which resulted in creating a positive LTP of INR 7.9/- (5.77% increase from previous LTP of INR 137).

It is important to note that it was the 6th and the last trade of the particular day which was a structured trade and apart from getting the scrip closed at around 4.34% higher than the previous day closing price, the LTP created by this trade also set the positive momentum for the next trading day due to which the scrip opened on a positive note of INR 145/- on the next day. 63.2. On March 26, 2020, the closing price of the scrip of VFL on BSE was INR 138/-. On March 27, 2020 (next trading day), Ms. Durgeshwari Pradipbhai Chiripal (part of Chiripal Group) placed a sell order (order number 1585279802392020000) for 100 shares of VFL at 12:34:23 hours at a price of INR 144/- and after 38 seconds of the aforesaid sell order i.e. at 12:34:23 hours, Ms. Sushila Ashokbhai Chiripal (part of Chiripal Group) placed a buy order (order number 1585279802392020001) for 100 shares at INR 131.1/-. However, due to difference between the offer and ask price, both of these orders remained unexecuted till the buying price and the selling price were modified to INR 142/-by Ms. Sushila Ashokbhai Chiripal and Ms. Durgeshwari Pradipbhai Chiripal respectively.

Interestingly, the difference between the time while the aforesaid buy and sell orders were modified was 1 second i.e. the buy order was modified by Ms. Sushila Ashokbhai Chiripal at 12:35:10 hours and the sell order was modified Ms. Durgeshwari Pradipbhai Chiripal at 12:35:11 hours. It is also pertinent to note that the aforesaid trade was executed at INR 4/- (2.9%) higher than the previous closing price and interestingly this was also the 1st trade of the said trading day. 63.3. It is also noted that on the aforesaid trading day (March 27, 2020) only 6 trades were executed and till the execution of 5th trade, the LTP was INR 137/-which was executed at 14:49:12 hours. However, in order to set the LTP further high for the next trading day, these entities again accessed the market. Mr. Sahilkumar Amrutbhai Vaghela (part of Ahmedabad Group) placed a buy order

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling (order number 1585279802392020008) for 200 shares of VFL at 15:09:54 hours at price INR 144.9/- (INR 7.9/- higher than the LTP of INR 137/-) and then Ms. Durgeshwari Pradipbhai Chiripal (part of Chiripal Group) placed a sell order (order number 1585279802392020009) for 200 shares at 15:19:15 hours at INR 144.9/-, which led to matching with the pending buy order of Mr. Sahilkumar Amrutbhai Vaghela and resulted in creation of a positive LTP of INR 7.9/-. Since this was the last trade of the trading day and as no other trade happened during the last 30 minutes of the trading, price of INR 144.9/- became the closing price of VFL on BSE on (March 27, 2020). 63.4. It is also noted that apart from the aforesaid trade on March 27, 2020, various occasions have been noticed when these entities have manipulated the opening price in the scrip of VFL by executing the 1st trade on respective trading days. For instance, on July 8, 2020, sell order placed by one of the Chiripal Group entity namely Mr. Anil Dhanuka at a price of INR 258/- was matched by a buy order placed by another Chiripal Group entity namely Rushp Trading LLP which resulted in creating LTP at INR 258/- (INR 2/- higher than closing price on previous trading day).

Such instances by trading at a price higher than the previous trading day’s closing price and creating positive LTP through 1st trades by these connected entities were also observed on other trading days including July 8, 2020, July 9, 2020 and July 10, 2020. 64. The trades of the PV Influencers in the scrip were also examined on NSE. As can be seen from the above table, Chiripal Group along with Ahmedabad based entities (Sub-group 2) and Kolkata based entities (Sub-group 3) collectively as a group have prima facie contributed 18.17% of the total market buy volume and 31.93% of the total market sell volume. Further, by trading with each other as group members in the scrip of VFL, these entities have contributed 6.85% of the total market traded volume. It is also noticed that on NSE, the aforesaid connected entities contributed to the tune of INR 30.20/- (23.59%) to the net price rise in the scrip. Similarly, by trading amongst each other, these entities have contributed INR 38.230/- (29.84%) to the net price rise in the scrip of VFL. The trades of the said connected entities were further analysed

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling to determine as to how the said connected entities were trying to influence the volume and price in the scrip on NSE so as to present the scrip as an attractive proposition for the investors in the securities market. Some illustrations to that effect are as follows: 64.1. On April 30, 2020, one of the Sub-group 2 entity, namely Mr. Parmar Popatbhai had placed a sell order (Order number 1300000007525715) for 250 shares of VFL at NSE at 12:11:49 hours at a price of INR 218.5/- (+ve LTP of INR 0.70/-). It is noted that various connected entities from Sub-groups 2 and 3, placed buy orders in miniscule quantities but at the same price one after the other (within a time difference of few seconds to few minutes) so as to enable execution of multiple trades in the scrip. Details of such entities and their respective trades are tabulated below: Table No. 33

Trade Buyer Seller Buy Sell Trade Trade Buy Sell Trade Date Name Name Order Order Time Price Order Oder Qty Last Last Last Last Modifie Modifie Mod Mod d Time d Time Qty Qty 30/04/2020 Sourav Das Parmar 12:14:14 12:11:49 12:14:14 218.5 4 250 4 Popatbhai 30/04/2020 Dibakar Parmar 12:15:04 12:11:49 12:15:04 218.5 5 250 5 Laha Popatbhai 30/04/2020 Sahilkumar Parmar 12:15:32 12:11:49 12:15:32 218.5 1 250 1 Amrutbhai Popatbhai Vaghela 30/04/2020 Priyankar Parmar 12:15:51 12:11:49 12:15:51 218.5 5 250 5 Laha Popatbhai 30/04/2020 Vaghela Parmar 12:16:46 12:11:49 12:16:46 218.5 1 250 1 Prakash Popatbhai Kantilal 30/04/2020 Ravi Parmar 12:16:53 12:11:49 12:16:53 218.5 1 250 1 Kannadasan Popatbhai Adidravid 30/04/2020 Keval Parmar 12:16:55 12:11:49 12:16:55 218.5 5 250 5 Savant Popatbhai 30/04/2020 Chiragkuma Parmar 12:16:58 12:11:49 12:16:58 218.5 1 250 1 r Makwana Popatbhai 30/04/2020 Makwana Parmar 12:17:01 12:11:49 12:17:01 218.5 5 250 5 Madhuben Popatbhai 30/04/2020 Debashish Parmar 12:18:14 12:11:49 12:18:14 218.5 5 250 5 Dutta Popatbhai 30/04/2020 Buddhadeb Parmar 12:22:25 12:11:49 12:22:25 218.5 5 250 5 Laha Popatbhai

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling

Trade Buyer Seller Buy Sell Trade Trade Buy Sell Trade Date Name Name Order Order Time Price Order Oder Qty Last Last Last Last Modifie Modifie Mod Mod d Time d Time Qty Qty 30/04/2020 Buddhadeb Parmar 12:22:31 12:11:49 12:22:31 218.5 1 250 1 Laha Popatbhai 30/04/2020 Minu Parmar 12:24:46 12:11:49 12:24:46 218.5 15 250 15 Mallick Popatbhai 30/04/2020 Priyankar Parmar 12:25:39 12:11:49 12:25:39 218.5 20 250 20 Laha Popatbhai 30/04/2020 Dibakar Parmar 12:28:38 12:11:49 12:28:38 218.5 20 250 20 Laha Popatbhai 30/04/2020 Sanjay Dey Parmar 12:30:55 12:11:49 12:30:55 218.5 10 250 10 Popatbhai 30/04/2020 Ujjal Laha Parmar 12:31:13 12:11:49 12:31:13 218.5 10 250 10 Popatbhai 30/04/2020 Buddhadeb Parmar 12:35:07 12:11:49 12:35:07 218.5 5 250 5 Laha Popatbhai

64.2. Another similar instance of continuous trading in the scrip on August 10, 2020 with miniscule quantity and within a short time interval executed by Sub-group 2 entities namely, Mr. Vaghela Prakash Kantilal (VPK), Mr. Chirag Kumar Makwana (CM) and Mr. Makwana Madhuben (MM) acting as buyers and Ms. Parmar Dipika (DP), Ms. Priti Parmar (PP), Ms. Parmar Lilaben Popatbhai (PLP) and Mr. Parmar Popatbhai (PP1) acting as sellers, is shown herein below:

Table No. 34

Buyer Seller Trade Buy Sell Time Traded Buy Sell Order Time Order Order difference in Qty Order Qty Time Time Buy and Sell Qty Order Time VPK DP 13:00:21 13:00:21 13:00:19 00:00:02 20 20 20 CM PP 13:01:31 13:01:31 13:01:29 00:00:02 20 20 20 MM PLP 13:01:43 13:01:43 13:01:42 00:00:01 20 20 20 VPK DP 13:02:22 13:02:22 13:01:57 00:00:25 20 20 20 CM PLP 13:03:00 13:03:00 13:02:59 00:00:01 20 20 20 MM DP 13:03:10 13:03:10 13:03:08 00:00:02 20 20 20 VPK PP1 13:03:25 13:03:25 13:03:23 00:00:02 20 20 20 CM PP1 13:03:45 13:03:45 13:03:38 00:00:07 20 20 20 MM PP 13:04:01 13:04:01 13:03:57 00:00:04 20 20 20 VPK PLP 13:04:12 13:04:12 13:04:11 00:00:01 20 20 20

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling

Buyer Seller Trade Buy Sell Time Traded Buy Sell Order Time Order Order difference in Qty Order Qty Time Time Buy and Sell Qty Order Time CM PP1 13:04:35 13:04:35 13:04:31 00:00:04 20 20 20 MM PP 13:04:42 13:04:42 13:04:40 00:00:02 20 20 20 CM PLP 13:04:51 13:04:51 13:04:50 00:00:01 20 20 20 MM DP 13:05:00 13:05:00 13:04:58 00:00:02 20 20 20 VPK PP1 13:05:08 13:05:08 13:05:07 00:00:01 20 20 20 VPK DP 13:05:49 13:05:49 13:05:47 00:00:02 25 25 25 CM PP1 13:06:05 13:06:05 13:06:05 00:00:00 25 25 25 MM PP 13:06:15 13:06:15 13:06:14 00:00:01 25 25 25 VPK PLP 13:06:30 13:06:30 13:06:28 00:00:02 25 25 25 VPK DP 13:07:13 13:07:13 13:07:12 00:00:01 25 25 25 CM PP 13:07:29 13:07:29 13:07:28 00:00:01 25 25 25 MM PLP 13:07:38 13:07:38 13:07:37 00:00:01 25 25 25 VPK DP 13:07:45 13:07:45 13:07:44 00:00:01 25 280 25 VPK PP1 13:07:52 13:07:45 13:07:52 00:00:07 25 280 25 VPK PP 13:08:04 13:07:45 13:08:04 00:00:19 25 280 25 VPK PLP 13:08:49 13:08:49 13:08:37 00:00:12 25 25 25 CM PP1 13:09:09 13:09:09 13:09:08 00:00:01 25 25 25 MM PP 13:09:20 13:09:20 13:09:18 00:00:02 25 25 25 VPK PLP 13:09:30 13:09:30 13:09:26 00:00:04 25 25 25 CM PP1 13:09:44 13:09:44 13:09:42 00:00:02 25 25 25 MM PP 13:09:53 13:09:53 13:09:51 00:00:02 25 25 25 VPK PLP 13:10:02 13:10:02 13:09:59 00:00:03 25 25 25 CM PP1 13:10:16 13:10:16 13:10:15 00:00:01 25 25 25 MM PP 13:10:25 13:10:25 13:10:23 00:00:02 25 25 25 VPK PLP 13:10:33 13:10:33 13:10:31 00:00:02 25 25 25 CM PP1 13:10:49 13:10:49 13:10:48 00:00:01 25 25 25 MM PP 13:10:57 13:10:57 13:10:55 00:00:02 25 25 25 VPK PP 13:11:09 13:11:09 13:11:07 00:00:02 25 25 25 CM DP 13:11:27 13:11:27 13:11:25 00:00:02 25 25 25 MM PP1 13:11:35 13:11:35 13:11:34 00:00:01 25 25 25 VPK PP 13:11:44 13:11:44 13:11:42 00:00:02 25 25 25 CM DP 13:12:01 13:12:01 13:12:00 00:00:01 25 25 25 MM PP1 13:12:11 13:12:11 13:12:09 00:00:02 25 25 25 VPK PP 13:12:44 13:12:44 13:12:18 00:00:26 25 25 25 CM PLP 13:12:51 13:12:51 13:12:48 00:00:03 25 25 25 CM DP 13:15:57 13:15:57 13:15:56 00:00:01 9 9 9 VPK DP 14:09:08 14:09:08 14:09:07 00:00:01 20 20 20

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling

Buyer Seller Trade Buy Sell Time Traded Buy Sell Order Time Order Order difference in Qty Order Qty Time Time Buy and Sell Qty Order Time CM PP 14:09:29 14:09:29 14:09:29 00:00:00 20 20 20 MM PLP 14:09:36 14:09:36 14:09:36 00:00:00 20 20 20 CM DP 14:09:46 14:09:46 14:09:45 00:00:01 20 20 20 VPK PP1 14:09:51 14:09:51 14:09:50 00:00:01 20 20 20 MM PLP 14:10:04 14:10:04 14:10:03 00:00:01 20 20 20 VPK DP 14:10:09 14:10:09 14:10:08 00:00:01 20 20 20 CM PP1 14:10:16 14:10:16 14:10:12 00:00:04 20 20 20 CM PP 14:10:24 14:10:24 14:10:18 00:00:06 20 20 20 MM PLP 14:10:29 14:10:29 14:10:23 00:00:06 20 20 20 VPK DP 14:10:33 14:10:33 14:10:32 00:00:01 20 20 20 MM PP 14:10:46 14:10:46 14:10:45 00:00:01 20 20 20 CM PLP 14:10:51 14:10:51 14:10:51 00:00:00 20 20 20 VPK PP1 14:11:01 14:11:01 14:11:00 00:00:01 20 20 20 VPK PP 14:11:13 14:11:13 14:11:07 00:00:06 20 20 20 CM PLP 14:11:20 14:11:20 14:11:18 00:00:02 20 280 20 CM DP 14:11:24 14:11:20 14:11:24 00:00:04 25 280 25 VPK PP1 14:11:38 14:11:38 14:11:37 00:00:01 25 25 25 CM PLP 14:11:54 14:11:54 14:11:53 00:00:01 25 25 25 MM DP 14:11:59 14:11:59 14:11:58 00:00:01 25 25 25 CM PP1 14:12:04 14:12:04 14:12:02 00:00:02 25 25 25 VPK PLP 14:12:24 14:12:24 14:12:23 00:00:01 25 25 25 MM DP 14:12:29 14:12:29 14:12:28 00:00:01 25 25 25 VPK PP1 14:12:37 14:12:37 14:12:36 00:00:01 25 25 25 CM PLP 14:12:57 14:12:57 14:12:55 00:00:02 25 25 25 MM PP1 14:13:04 14:13:04 14:13:04 00:00:00 25 280 25 MM DP 14:13:04 14:13:04 14:13:00 00:00:04 25 280 25 VPK PP 14:13:14 14:13:14 14:13:11 00:00:03 25 25 25 CM DP 14:13:27 14:13:27 14:13:23 00:00:04 25 25 25 MM PP1 14:13:32 14:13:32 14:13:28 00:00:04 25 25 25 VPK PLP 14:13:46 14:13:46 14:13:38 00:00:08 25 25 25 CM DP 14:13:51 14:13:51 14:13:42 00:00:09 25 25 25 MM PP1 14:13:59 14:13:59 14:13:47 00:00:12 25 25 25 VPK PP 14:14:02 14:14:02 14:13:52 00:00:10 25 25 25 CM DP 14:14:07 14:14:07 14:14:01 00:00:06 25 25 25 MM PP1 14:14:09 14:14:09 14:14:06 00:00:03 25 25 25 VPK PP 14:14:13 14:14:13 14:14:11 00:00:02 25 25 25 CM DP 14:14:26 14:14:26 14:14:21 00:00:05 25 25 25

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling

Buyer Seller Trade Buy Sell Time Traded Buy Sell Order Time Order Order difference in Qty Order Qty Time Time Buy and Sell Qty Order Time CM PP1 14:14:34 14:14:34 14:14:27 00:00:07 25 25 25 MM PP 14:14:37 14:14:37 14:14:33 00:00:04 25 25 25 VPK PLP 14:15:59 14:15:59 14:14:39 00:01:20 25 25 25 CM PP1 14:16:37 14:16:37 14:16:34 00:00:03 25 25 25 CM PP 14:16:58 14:16:58 14:16:56 00:00:02 25 25 25 MM PLP 14:17:06 14:17:06 14:17:05 00:00:01 25 25 25 VPK PP1 14:17:13 14:17:13 14:17:12 00:00:01 25 25 25 CM PP1 14:18:34 14:18:34 14:18:06 00:00:28 10 70 10 CM DP 14:18:34 14:18:34 14:18:00 00:00:34 10 70 10 CM PLP 14:18:34 14:18:34 14:17:38 00:00:56 25 70 25 CM PP1 14:18:34 14:18:34 14:17:33 00:01:01 25 70 25

It is pertinent to note from the aforesaid table that the PV Influencers while collectively acting as a group have executed 95 trades at INR 280/- (at LTP) per share in the scrip wherein the time difference between the buy orders and sell orders time was in the range of 0 seconds to 1 minute 20 seconds. Further in 84 trades out of the above illustrated 95 trades, buy quantities placed by the buyers were exactly similar to the sell quantities offered by the sellers. The aforesaid two illustrations clearly demonstrate the pre-dominant method employed by the PV Influencers wherein the group entities were placing continuous trades within a short span of time, to influence the volume in the scrip. The trading pattern followed by them could be either matching of one single buy / sell order with numerous counterparty orders at one go or it could be matching of miniscule quantity of buy / sell orders with similar size of counterparty order within a matter of few minutes. Thus, execution of miniscule quantities of trades by way of placement of buy orders and sell orders at close proximity to each other on a regular basis, in a scrip which was not highly liquid, that too by the entities that are connected with each other, prima facie leads to an inference that the Stock Exchange platform was abused by these connected entities to execute the said structured trades. Such prima facie non-genuine trades not only creates

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling misleading appearance of trading in the scrip but also creates artificial volume in the scrip thereby painting a misleading picture about the liquidity in the scrip. 64.3. The above narrated structured trades executed by the connected entities not only lead to a prima facie inference that the PV Influencers have artificially manipulated the trade volumes in the scrip during the pre-SMS period but also it shows that by placing buy and sell orders for such miniscule quantities for prices per share either above LTP or at LTP, they are either trying to inflate the price or at least are trying to maintain the price in the scrip at a certain level, which is nothing but a prima facie an attempt to manipulate the price in the scrip. However, the aforesaid method is not the only method adopted by the PV Influencers to prima facie manipulate the price of the scrip. Upon examination of the trades executed by the said entities, it is noted that out of 522 trades executed amongst these connected entities in the scrip of VFL on NSE during the pre-SMS period, in 452 trades, the time difference between placing of buy and sell orders by these connected entities was less than 60 seconds i.e., prima facie the trades were synchronised.

It is also noted that in the aforementioned 452 trades, these entities have contributed INR 25.45/- to the net LTP (i.e.18.51% of net LTP) in the scrip of VFL during the period. Further, in 364 trades out of the said 452 trades executed amongst each other, the time difference between placing of buy and sell orders by these connected entities was between 0 seconds to 10 seconds and the net LTP contributed through those 364 prima facie synchronised trades was INR 32.55/- (i.e. 23.58% of net LTP in the scrip of VFL during the period). Few illustrations of such prima facie synchronised trades noticed during the investigation are as follows: 64.3.1. On August 12, 2020, Ms. Dipika Popatbhai Parmar (part of Sub-group 2) placed a sell order (order number 1300000007239079) for 20 shares of VFL at 11:46:07 hours at a price of INR 270/- (INR 6.8/- higher than the LTP of INR 263.2/-) and then Mr. Vaghela Prakash Kantilal (part of Sub-group 2) placed a buy order (order number 1300000007239834) for 20 shares at 11:46:09 hours (2 seconds after the aforestated sell order) at a price of INR

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling

270/-, which led to matching with the pending sell order of Ms. Dipika Popatbhai Parmar and resulted in creation of positive LTP of INR 6.8 /- (2.52% higher than the previous LTP). Interestingly, this was the 2nd trade of the day and in the 1st trade of the day, the scrip had traded at INR 263.2/- (INR 9.3/- less than the closing price on the previous trading day i.e. on August 11, 2020). 64.3.2. On August 21, 2020, Mr. Pathan Shahrukhkhan (part of Sub-group 2) placed a sell order (order number 1300000006476544) for 20 shares of VFL at 11:41:34 hours at a price of INR 280/- (INR 7/- higher than the LTP of INR 273/-) and then Mr. Vaghela Prakash Kantilal (part of Sub-group 2) placed a buy order (order number 1300000006476761) for 20 shares at 11:41:35 hours (within a second after the aforestated sell order) at a price of INR 280/-, which matched with the pending sell order of Mr. Pathan Shahrukhkhan and resulted in creation of a positive LTP of INR 7/- (2.5% higher than the previous LTP). Interestingly, this was the 2nd trade of the day and in the 1st trade of the day, the scrip had traded at INR 273/- (INR 7/- less than the closing price on the previous trading day i.e. on August 20, 2020). 64.4. The aforesaid trading pattern demonstrates not only the repeated nature of the transactions which is prima facie synchronised in nature but also prima facie exposes a prior meeting of minds amongst the said entities. It is observed from the details of the trades executed by the said group and having regard to the anonymised trading system of the Stock Exchanges, matching of such large number of trades between the same parties could not have taken place on such trading platforms, unless the trading system was itself being abused in a manner that the orders placed by the connected entities end up matching with each other. It is further pertinent to note that prima facie such trading patterns lead to unnecessary price fluctuations and create false appearance of trading in the securities market and thereby tending to mislead the investors. In other words, the frequency of matching of trades, the proximity of time between the placement of buy orders and sell orders and the inter connectedness between the buyers and the sellers, all conjointly read together prima facie show the ill-

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling conceived intention of the PV Influencers to influence / play the market for the purpose of increasing the price and volumes in the scrip and thereby creating an artificial picture of dealing in the scrip of VFL. 65. It is noted from the records that there was one more entity namely, Goenka Business Finance Limited (hereinafter referred to as “GBFL”) which was prima facie found to be manipulating the price of the scrip during the pre-SMS period. The aforesaid entity was trading with Sunflower Broking Pvt. Ltd. whose owner Mr. Malay Bhow was in frequent communication with Mr. Hanif Shekh during the relevant period and as noted in the preceding paragraphs, Mr. Hanif Shekh is the prima facie SMS Sender in the scrip. The trades executed by GBFL was examined during the pre-SMS period (March 25, 2020 to September 7, 2020). The summary of the trades executed by the aforesaid entity is shown below: Table No. 35 % Buy to % Sell to % total total contribu Net Buy Net Sell Total Entity Name Buy Qty Market Sell Qty Market tion to LTP LTP LTP Buy Sell net price Volume Volume rise BSE Goenka Business 19886 1.88% 6382 0.60% 19.95 32.55 52.50 38.04% Finance Limited Market 1059004 100.00% 1059004 100.00% 138.00 138.00 138.00 100.00% Total NSE Goenka Business 48958 3.98% 18310 1.49% 41.50 -22.75 18.75 14.65% Finance Limited Market 1228645 100.00% 1228645 100.00% 128.00 128.00 128.00 100.00% Total 66. As can be seen from the above table, GBFL has prima facie during the period of March 25, 2020 to September 4, 2020, contributed 38.04% of net market LTP (INR 52.50/-of the actual rise of INR 138/-) through his trades on BSE, and on NSE, its contribution was 14.65% of net market LTP (INR 18.75/- of the actual rise of INR 128/-).

The trades of the said entity were analysed to determine as to how this entity which is prima facie connected with the SMS Sender was trying to manipulate the price in the Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling scrip so as to present the scrip as an attractive proposition before the innocent investors in the securities market. 67. Upon examination of the trade log of GBFL for the trades executed on BSE, it is noted that though the contribution to the net LTP in the scrip of VFL by GBFL during the pre- SMS period is INR 19.95/- out of the total rise in LTP in the scrip by INR 138/- during the aforesaid period, it is noted that the total positive contribution by GBFL (on gross basis) through its buy trades was INR 114.8/-. In other words, sans other buy trades executed in the scrip, only GBFL’s buy trades if seen on a standalone basis has contributed INR 114.8/- to the rise in the price of the scrip. The same shows that though the prevailing market forces in the scrip were acting contrary to the view taken by the entity, still GBFL through its buy trades placing orders at prices higher than LTPs was able to withstand the headwinds and was able to contribute a net amount of INR 19.95/- to the increase in the price of the scrip.

During the pre- SMS period, GBFL had executed 160 buy trades as buyer in the scrip of VFL, but it is pertinent to note that the aforesaid gross contribution of INR 114.8/- to positive LTP was done only through 28 buy trades executed by GBFL in the said scrip. If the aforesaid figures are further scrutinised, it would show that in a scrip such as VFL which was not highly liquid and financially the Company was not achieving any significant milestones, GBFL as a buyer was making a considerable effort to acquire the shares to the extent that it was willing to pay on an average of INR 4/- over the LTP in 17.5% of its buy trades. The buy trades of GBFL, when seen in terms of number of shares would show that out of 19,986 shares bought by the entity during the said period, 3,381 shares led to the gross total positive LTP contribution of INR 114.8/-. Thus, the prima facie concerted effort and exuberance that was shown by GBFL to acquire the shares of VFL leads to two scenarios; either GBFL was in possession of some material information or foresaw some growth potential which other investors were not able to foresee or there was some other driving force which was motivating GBFL to deal in the scrip in a manner that it was consistently contributing to the positive LTP in the scrip through its repetitive buy trades.

In the given facts and circumstances of the case, the latter scenario is highly probable as artificially

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling increasing the price of the scrip was one of the primary leg of the prima facie scheme that was observed to be employed in the scrip as discussed in detail in the subsequent paragraphs of this order. 68. I also note that out of the 28 buy trades of GBFL wherein positive LTP was contributed, in 9 such trades the counterparties (Mr. Chetanbhai Mahendrabhai Dantani, Mr. Shivam Kumar Patel and Mr. Suresh Deshaljibhai Vaghela) were connected to GBFL (as already recorded in Table No. 8 of this Order) and such 9 trades resulted in contribution of INR 22/- to the positive LTP in the scrip of VFL. Further, out of 28 such positive LTP creating buy trades, 13 buy trades executed by GBFL were the 1st trades of the respective trading days. A few instances of such trades are placed below: 68.1. On July 29, 2020, Mr. Shivam Kumar Patel (an entity connected to GBFL) had placed a sell order for 25 shares at a price of INR 272/- (INR 2/- higher than the LTP on July 28, 2020) in the scrip of VFL at BSE at 10:26:39 hours. After 23 seconds of the aforesaid sell order, i.e. at 10:27:02 hours, a buy order for 10 shares at a price of INR 272/- was placed by GBFL which resulted in execution of the 1st trade in the scrip of VFL on July 29, 2020 and creation of LTP of INR 272/- (0.74% higher than previous LTP). 68.2. On August 20, 2020, Mr. Shivam Kumar Patel (an entity connected to GBFL) had placed a sell order for 50 shares at price of INR 273/- (INR 2.65/- higher than the LTP on previous trading day) in the scrip of VFL at BSE at 15:13:34 hours. After 14 seconds of the aforesaid sell order, i.e. at 15:13:48 hours, a buy order for 50 shares at price of INR 273/- was placed by GBFL which resulted in execution of the 1st trade in the scrip of VFL on August 20, 2020 and creation of LTP of INR 273/- (0.98% higher than previous LTP). 69. The aforesaid illustrations show that GBFL was not only prima facie executing synchronised trades with its connected entities above the LTP but also was executing 1st trades in the scrip in order to set the momentum in the trading in the scrip. Upon examination of GBFL’s trade log, it was noted that apart from the aforestated strategies adopted by GBFL to prima facie impact the price in the scrip, it had also

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling employed another strategy of executing multiple small quantities of trades to match one big counter party order within a short span of time. A sample of the said strategy is given below: 69.1. On June 15, 2020, the closing price in the scrip of VFL at BSE was INR 250/. On June 16, 2020, Ms. Durgeshwari Pradipbhai Chiripal (part of Chiripal Group) had placed a sell order (order number 1592278200003021000) for 2,500 shares of VFL at 09:46:27 hours at a price of INR 250/-. After 14 seconds of the aforesaid sell order i.e. 09:46:41 hours, a buy order (order number 1592278200003021001) for only 5 shares was placed by GBFL at a price of INR 250/-, which matched with the sell order of Ms. Durgeshwari Pradipbhai Chiripal and resulted in execution of the 1st trade of the day in scrip of VFL at BSE. It is pertinent to mention here that the sell order of Ms. Durgeshwari Pradipbhai Chiripal remained partly unexecuted and was lying in the stock exchange’s system as a passive order. Subsequently, it is noted that the next trade in the scrip (2nd trade) was executed at a price of INR 234.2/- (INR 15.8/- less than the LTP) and the 3rd trade was also executed in the scrip at price of INR 234.2/-. Interestingly, the aforementioned 2nd and 3rd trades were executed at 14:58:52 hours and 14:59:53 hours respectively and were executed by other market participants (other than the entities mentioned in this Order). It is worthwhile to mention here that the sell order for the 2nd and 3rd trades were lying pending in the Stock Exchange system since 14:03:58 hours and it got matched only at 14:58:52 hours, when the buy orders for a matching price at INR 234.2/- were placed by the buyer of 2nd and 3rd trades. However, in order to prima facie inflate the price of the scrip and in order to ensure that the closing price of the scrip of VFL is higher than INR 234.2/-, so as to not only influence the closing price of the scrip but also to have a positive impact on the next day’s opening price, GBFL started placing buy orders in smaller quantities just to match the pending sell order of Ms. Durgeshwari Pradipbhai Chiripal at a price of INR 250/-. Details of such orders and trades executed in the scrip of VFL are tabulated below:

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling

Table No. 36 Trade Trade Buy Sell Order Traded Buy Sell Order Number Time Order Time Quantity Order Quantity Time Quantity 4 15:02:58 15:02:58 09:46:27 250 250 2500 5 15:03:33 15:03:33 09:46:27 250 250 2500 6 15:03:50 15:03:50 09:46:27 245 245 2500 7 15:08:10 15:08:10 09:46:27 250 250 2500 8 15:10:28 15:10:28 09:46:27 10 10 2500 9 15:10:30 15:10:30 09:46:27 25 25 2500 10 15:10:31 15:10:31 09:46:27 35 35 2500 11 15:10:32 15:10:32 09:46:27 44 44 2500 12 15:10:35 15:10:35 09:46:27 22 22 2500 13 15:10:37 15:10:37 09:46:27 89 89 2500 14 15:10:39 15:10:39 09:46:27 125 125 2500 15 15:10:41 15:10:41 09:46:27 133 133 2500 16 15:10:43 15:10:43 09:46:27 148 148 2500 17 15:14:53 15:14:53 09:46:27 69 69 2500

The aforesaid acts of GBFL have resulted in execution of continuous trades (4th trade to 17th trade) at a price of INR 250/-, which was INR 15.8/- (6.75%) higher than the LTP. It is noted from the trade data that only 17 trades were executed in the scrip of VFL at BSE on that particular trading day (June 16, 2020) and the closing price of the scrip was INR 250/-. The aforesaid trading behaviour on the part of GBFL while acting as buyer, prima facie does not inspire confidence, as a buyer would always like to buy shares at a lower price than the LTP. In the present case, despite the fact that the sell orders that resulted in the 2nd and 3rd trades were lying pending in the stock exchange system at an offer price of INR 234.2/- for almost 55 minutes (placed at 14:03:58 hours and executed as trade at 14:58:52 hours), however, no interest was shown by GBFL to buy the shares of VFL at a lower price but within 3 minutes of execution of the aforesaid sell

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling orders at INR 234.2/- which resulted in the 2nd and 3rd trades, GBFL promptly accessed the market to buy shares at INR 250/-. Further, despite there being a pending sell order for 2,495 shares (2,500 shares minus 5 shares which were executed as the 1st trade of the day), GBFL chose to buy shares in small quantities only at a price of INR 250/-. Under these facts and circumstances as exhibited above, the act of GBFL was prima facie while dealing in the shares of the Company, can be said to have been done only to manipulate the price in the scrip of VFL and ostensibly to portray to the market that there are willing buyers of the scrip at a price of INR 250/-. As expected, it is noted that the 1st trade which was executed the next trading day (June 17, 2020) in the scrip was done at price of INR 255/-. 70. Similar kind of strategy was also adopted by GBFL on the selling side in the scrip on BSE. It is noted from the available records that though the contribution to the net LTP in the scrip of VFL by GBFL during the pre- SMS period is INR 32.55/- out of the total rise in LTP in the scrip of INR 138/- during the aforesaid period, it is noted that the total positive contribution by GBFL (on gross basis) through its sell trades was INR 85.05/-.

During the pre- SMS period, GBFL had executed 36 sell trades as seller in the scrip of VFL, but it is pertinent to note that the aforesaid contribution of INR 85.05/-to positive LTP was done only through 14 sell trades executed by GBFL in the scrip. Out of the 14 sell trades of GBFL wherein positive LTP was contributed, in 8 such trades the counterparties (Mr. Chetanbhai Mahendrabhai Dantani and Mr. Shivam Kumar Patel) were connected to GBFL (as already recorded in Table No. 8 of this Order) and such 8 trades have resulted in contribution of INR 36.9/- to the positive LTP in the scrip of VFL. A few instances of such trades are placed below: 70.1. On April 22, 2020, GBFL had placed a sell order for 50 shares at a price of INR 210/- (INR 2 higher than the LTP on previous trading day) in the scrip of VFL at BSE at 15:05:17 hours. Interestingly, no trade was executed in the scrip on the aforestated trading day till a buy order was placed at 15:07:25 hours (2 minutes and 8 seconds after the aforesaid sell order of GBFL) for 50 shares at a price of INR 210/- by Mr. Chetanbhai Mahendrabhai Dantani (an entity

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling connected to GBFL) which resulted in the execution of 1st trade in the scrip of VFL on April 22, 2020 and creation of LTP of INR 210/- (2.44% higher than previous LTP). 70.2. On August 10, 2020, Mr. Shivam Kumar Patel (an entity connected to GBFL) placed a buy order for 50 shares at a price of INR 272/- (INR 12/- higher than the LTP) in the scrip of VFL at BSE at 15:21:08 hours. After 63 seconds of the aforesaid sell order, i.e. at 15:22:11 hours, a sell order for 50 shares at a price of INR 272/- was placed by GBFL which resulted in execution of the 5th and the last trade in the scrip of VFL on August 10, 2020 and a creation of LTP of INR 272/- (4.62% higher than previous LTP). Again on the next trading day i.e. on August 11, 2020, the 2nd and last trade of the day was executed between GBFL (as buyer) and Mr. Shivam Kumar Patel (as seller) for 50 shares with a time difference of 32 seconds between buy and sell order which resulted in increasing the LTP to INR 272.5/- (INR 0.5/- higher than the LTP).

The aforesaid pattern wherein GBFL sells 50 shares of VFL to one of its connected entities at INR 272/- (INR 12/- higher than the LTP) on August 10, 2020 in a prima facie structured trade and again buys the same quantity of 50 shares of VFL from the same connected entity at INR 272.5/- (INR 0.5/- higher than the LTP) the very next day, through another prima facie structured trade, by no stretch of imagination can be said to be a genuine transaction, as the beneficial ownership of the 50 shares of VFL has not been changed, and rather the aforesaid transactions can be cited as a prime example of a reverse trade which was entered into between the connected entities just to inflate the price of the scrip. 71. In the light of the aforesaid discussions, it can be prima facie inferred that the sole purpose of GBFL to deal in the scrip of VFL during pre-SMS period was not that it had inherent belief in the growth prospect of the Company but was to manipulate the price of the scrip. To that extent, it had employed various strategies viz., executing the first trades in the scrip higher than the LTP, trading with connected entities above the LTP, and executing continuous trades above LTP etc. Whether, it was the buy side or the Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling sell side, GBFL has always dealt in the scrip on a regular basis in a manner so as to artificially maintain the price in the scrip at a desired level which can be easily deduced from the fact that its gross contribution to the price on the buy side was INR 114.8/- and on the sell side the same was INR 85.05/-.

The aforesaid observation about the real intent of GBFL to deal in the scrip of VFL is further strengthened from the fact that similar kind of trading activities by GBFL have also been observed on the platform of NSE. 72. Upon examination of the trade log of GBFL for the trades executed by it on NSE, it is noted that though the contribution to the net LTP in the scrip of VFL by GBFL as a buyer during the pre- SMS period is INR 41.50/- out of the total rise in LTP in the scrip of INR 128/- during the aforesaid period, it is noted that the total positive contribution by GBFL (on gross basis) through its buy trades in the scrip of the Company was INR 145.35/-. In other words, sans other buy trades executed in the scrip, if GBFL’s buy trades are to be seen on a standalone basis, they will be seen to have contributed INR 145.35/- to the rise in the price of the scrip. This factual revelation shows that though the prevailing market forces in the scrip were acting contrary to the view taken by the entity, still GBFL through its buy trades was able to withstand the opposing market forces and was able to effectively contribute INR 41.50/- to the increase in the price of the scrip.

During the pre- SMS period, GBFL had executed 193 buy trades as a buyer in the scrip of VFL, but it is pertinent to note that the aforesaid contribution of INR 145.35/- to positive LTP was done only through 37 buy trades executed by GBFL in the scrip. If the aforesaid figures are further scrutinised, it would show that in a scrip such as VFL which is not highly liquid and financially the Company was not doing well at all, GBFL as a buyer was making a considerable effort and showing excessive enthusiasm to acquire the shares to the extent that it was willing to pay on an average of INR 3.9/- over and above the LTP in 19.17% of its buy trades. The buy trades of GBFL when seen in terms of number of shares would show that out of 48,958 shares bought by the entity during the said period, purchase of 1,366 shares led to the gross total positive LTP of INR 145.35/-. Thus, the prima facie concerted exuberance shown by GBFL to acquire the shares of VFL leads to two scenarios; either GBFL was in Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling possession of some material information or saw some future growth potential which other investors were not able to fathom or there was some other illicit motive behind GBFL to deal in the scrip in the peculiar manner as explained above.

In the given facts and circumstances of the case, the latter scenario is highly probable since, artificially increasing the price of the scrip was the first crucial step to implement the prima facie scheme that was employed in the scrip which is discussed further in the subsequent paragraphs. 73. I also note that out of the 37 buy trades of GBFL wherein positive LTP was contributed, in 4 such trades the counterparties (Mr. Chetanbhai Mahendrabhai Dantani and Mr. Shivam Kumar Patel) were connected to GBFL (as already recorded in Table No. 8 of this Order) and such 4 trades have resulted in contribution of INR 10.15/- to the positive LTP in the scrip of VFL. Further, out of 37 such positive LTP creating buy trades, 9 buy trades executed by GBFL were the 1st trades of the respective trading days. A few instances of such trades are placed below: 73.1. On April 01, 2020, GBFL sold 100 shares of VFL on NSE at a price of INR 166/-. This was the 2nd and last trade in the scrip on the aforesaid trading day. On the next trading day i.e. on April 03, 2020, GBFL placed a buy order for 700 shares in the scrip of VFL on NSE at a price of INR 174/- (INR 8 more than the previous LTP of INR 166) at 12:07:27 hours.

The aforesaid buy order remained pending in the NSE’ s system for more than 3 hours, till it was matched with the sell order placed by Mr. Chetanbhai Mahendrabhai Dantani (an entity connected to GBFL) for 25 shares at a price of INR 174/- at 15:21:59 hours, which resulted in execution of 1st and the only trade of that trading day (April 03, 200) at a price of INR 174/- (4.6% higher than previous LTP of INR 166/-). It is not clear as to why GBFL, which had sold 100 shares of VFL at a price of INR 166/- on April 01, 2020, again showed interest in buying 700 shares of the same scrip on very next trading day and that too at 4.6% higher price (INR174). Further, the fact that the aforesaid buy order of GBFL for 700 shares at 4.6% higher than LTP was lying unexecuted for more than 3 hours, demonstrates that there was not much liquidity in the scrip of VFL.

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling

73.2. On August 29, 2020, Mr. Shivam Kumar Patel (an entity connected to GBFL) placed a sell order for 25 shares at a price of INR 272/- (INR 2/- higher than the LTP on the previous trading day) in the scrip of VFL on NSE at 10:26:27 hours. After 30 seconds of the aforesaid sell order, i.e. at 10:26:57 hours, a buy order for 10 shares at a price of INR 272/- was placed by GBFL which resulted in execution of the 1st trade in the scrip of VFL on August 29, 2020 and creation of LTP of INR 272/- (0.74% higher than previous LTP). 74. The aforesaid illustrations show that GBFL was not only prima facie executing synchronised / structured trades with its connected entities above the LTP but also was executing 1st trades in the scrip in order to artificially set the momentum in the trading of the scrip. Upon examination of GBFL’s trade log, it was noted that apart from the aforestated strategies adopted by GBFL to prima facie impact the price in the scrip, it had also employed one more strategy of executing multiple small quantities of trades by way of matching with one big counter party order within a short span of time. A sample of the said strategy is explained below: 74.1. On June 15, 2020, the closing price in the scrip of VFL at BSE was INR 250/. On June 16, 2020, Ms. Durgeshwari Pradipbhai Chiripal (part of Chiripal Group) had placed a sell order (order number 1592278200003021000) for 2,500 shares of VFL at 09:45:49 hours at price of INR 250/-. After 48 seconds of the aforesaid sell order was placed i.e. 09:46:37 hours, a buy order (order number 1300000002383239) for only 5 shares was placed by GBFL at a price of INR 250/-, which matched with the sell order of Ms. Durgeshwari Pradipbhai Chiripal and resulted in execution of the 1st trade of the day in the scrip of VFL at BSE. It is pertinent to mention here that the sell order of Ms. Durgeshwari Pradipbhai Chiripal remained partly unexecuted and was lying in the Stock Exchange’s system as a passive order. However, GBFL again accessed the NSE platform by placing buy orders in smaller quantities just to match the pending sell order of Ms. Durgeshwari Pradipbhai Chiripal at a price of INR 250/-. Details of such orders and trades executed in the scrip of VFL are tabulated below:

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling

Table No. 37 Trade Time Buy Sell Order Traded Buy Order Sell Order Qty Order Time Qty Qty Time 15:19:21 15:19:21 09:45:49 50 50 2500 15:19:23 15:19:23 09:45:49 50 50 2500 15:19:24 15:19:24 09:45:49 50 50 2500 15:19:30 15:19:30 09:45:49 50 50 2500 15:19:32 15:19:32 09:45:49 45 45 2500 15:19:36 15:19:36 09:45:49 50 50 2500 15:19:37 15:19:37 09:45:49 50 50 2500 15:19:39 15:19:39 09:45:49 50 50 2500 15:19:40 15:19:40 09:45:49 50 50 2500 15:19:46 15:19:46 09:45:49 50 50 2500

The aforesaid trade practice of GBFL resulted in execution of 10 trades (within 25 seconds) at a price of INR 250/-. Such a pattern of trading behaviour on the part of GBFL while acting as a buyer, prima facie does not inspire confidence as because, a buyer would always like to buy shares at a lower price than the LTP. In the present case however, despite the fact that there was a pending sell order lying in the system for 2,495 shares (2,500 shares minus 5 shares which were executed as the 1st trade of the day), GBFL chose to buy the shares in small quantities at a price of INR 250/-. This act of GBFL was prima facie done to ostensibly present to the outside world that there were willing buyers who were ready to buy the scrip at a price of INR 250/-. It is noted that the 1st trade which was executed the next trading day (June 17, 2020) in the scrip was at INR 255/- (INR 5/- higher than the LTP) and the buyer in this trade was Mr. Shivam Kumar Patel, a connected entity of GBFL.

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling

75. In the view of the aforesaid factual analyses and unearthing of such unusual trading practices being followed by GBFL and other connected entities a prima facie pattern that emerges in the way GBFL has dealt in the scrip of VFL on both the Exchanges is that in order to sustain the momentum in the price of the scrip GBFL was inter alia either executing prima facie synchronised / structured trades with its connected entities above the LTP or was executing 1st trades above the LTP or was executing multiple small trades to match a big order. Executing the aforesaid kind of trades on a frequent basis on both the Exchanges and to be part of such trades executed in the scrip either as a buyer or a seller throughout the pre-SMS period in a scrip which was highly illiquid with the Company lacking in any strong fundamentals, prima facie shows that there was a pre-meditated and a concerted effort by GBFL to artificially impact the price movement in the scrip of VFL. By engaging in such kind of deceptive trading behaviour which has not only prima facie abused the trading system but has also misled the investors to deal in the scrip of VFL. SMS Period 76. Once a positive momentum was generated in the scrip by sustained dealing in the scrip of VFL so as to maintain the price and volume in the scrip at a desired high level, the next leg of the prima facie scheme that was employed in the scrip came into play with the sending of bulk SMSs in the scrip. Out of the several SMS headers used to send SMSs related to scrip of VFL, it was observed that from the SMS header ID- BGAINS, as many as 5,80,241 SMSs were sent to 38,073 mobile numbers during the period from September 7, 2020 to October 20, 2020 (hereinafter referred to as “SMS Period”). A few sample of such SMS texts that were circulated in the said scrip and its prima facie impact on volume and price in the scrip of VFL, are shown in the table below:

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling

Table No. 38 Sl. No. SMS Sample SMS Text Date of SMS % volume % price Header circulation increase from increase from previous trading previous trading day day 1. QP-BGAINS Alert:- Look SENSEX September 21, 1,07,752 shares Weighted Down -600 Points But 2020 traded on Average price on Our MULTI-BAGGER September 21, 18-Sep-2019 was VISHAL FABRICS Flying 2020 on BSE from INR 304.32/- and High 309++ 65,698 shares the scrip touched - We Clearly Told You traded on the high of INR That If Market Go Down September 18, 309.35/- on 21- Then Also Our MULTI- 2020 i.e. an Sep-2019 i.e. the BAGGER Stock Will NOT increase of 64.01%. scrip witnessed a Go Down - IT WILL GO movement of UP UP UP ONLY 1.65% in its price. - BUY MORE FOR TOMORROW TARGET 311++ - THIS WEEK TARGET 320++ - FINAL TARGET 700++ 2. QP-BGAINS Sure Shot BUY / ADD October 21, 3,55,082 shares Weighted More VISHAL FABRICS 2020 traded on October Average price on - INTRA-DAY Target 21, 2020 on BSE 20-Oct-2019 was 369+ from 1,42,412 INR 368.42/- and - THIS WEEK Target shares traded on the scrip touched 377+ October 20, 2020 the high of INR - FINAL Target 700+ i.e. an increase of 372.15/- on 21- BONUS Coming on 149.33 %.

Oct-2019 i.e. the THURSDAY - BUY scrip witnessed a MAXIMUM QUANTITY movement of NOW 1.01% in its price. Thus, from the aforesaid table it can be seen that there was a marked increase in the volume of the scrip immediately on the next day of sending of the SMS including an upward movement in the price of the scrip. It is further observed from the records that there has been 779% increase on BSE and 627% increase on NSE in the volume of the scrip during the SMS period vis-à-vis pre SMS period. The price in the scrip also touched a high of INR 369.35/- during the SMS period as compared to the closing price of the pre-SMS period which was INR 272/- i.e., there was a 35 % spike in the price of Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling the scrip on BSE. The aforesaid figures prima facie accentuates the role played by the bulk SMSs in luring the investors to deal in the scrip. The records reflect that the circulation of bulk SMSs to give buy recommendations was not a solitary instance and was frequently used during the SMS period by using different sender IDs.

The same had a noticeable impact on the price and volume movement in the scrip. Off Loaders 77. Once the bulk SMSs were sent in the scrip by the SMS Sender who has been prima facie identified as Mr. Hanif Shekh in the earlier part of this Order, it gave an opportunity to the entities who were connected either with the Company or with the SMS Sender, to exit the scrip by dumping the shares on the investors who were prima facie lured in by the SMSs and by seeing the meteoritic rise in the price and volume of the scrip during the SMS period (September 7, 2020 to October 20, 2020). As noted in preceding paragraphs, the average daily volume in the scrip during the SMS period vis-a-vis pre-SMS period increased by 779% on BSE and 627% on NSE while the price in the scrip opened at INR 274.10/- and reached a high of INR 369.40/- during SMS period, registering an increase of 34.76% in 1.5 months only (approximately). Such entities who exited the scrip with a profit by taking advantage of the high trading volume and high price of the scrip apparently accentuated by the bulk SMSs, are herein after referred to as Off Loaders.

78. The findings of the investigation prima facie show that there are three sets of entities who are Off Loaders in the scrip of VFL during the SMS period, namely entities belonging to Chiripal Group, Sub-group 2 and Sub-group 3. The connection that existed amongst the various entities belonging to the aforesaid respective groups on multiple parameters, have been noted in the preceding paragraphs. Further, as noted from the trade logs and as already highlighted above, there have been frequent trades between the entities across the said 3 groups which were prima facie executed to manipulate price and volume in the scrip during pre- SMS period. Mr. Hanif Shekh who is prima facie the SMS sender in the scrip has already been noted to be connected with Sub-groups 2 and 3. The inter connections that existed amongst the entities as Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling already exhibited earlier in this order when seen jointly with the unusual trading pattern (heavy selling) in the scrip of the VFL by the Off Loaders including the timing of their dealing in the scrip, coupled with the fact that some of them were also prima facie involved in artificially raising the price and volume in the scrip, it can be prima facie inferred that the very act of coming together by the aforesaid entities (Off Loaders) and selling their shares during the same period, was nothing but an act that was performed in accordance with a pre-conceived scheme employed in the scrip.

79. The profits made by the Off Loaders by selling their shares of the VFL, are indicated in the table below: Table No. 39 Profit made by Company connected entities (Chiripal Group) S.No. Entity name BSE Net NSE Net Sell Total Net BSE Profit NSE Profit Total profit Sell Value Value Sell Value (INR) (INR) (INR) 1 Durgeshwari 3525928 0 3525928 2120000 0 2120000 Pradipbhai Chiripal 2 Manuj 19137889 296240064.8 315377954 12018227 183334613 195352840 Ashokkumar Chiripal 3 Rushp 13019297 68802675.4 81821972 2119911 34256177 36376088 Trading LLP 4 Satrama 13362064 19891401.43 33253465 2791546 6868484 9660030 Trading LLP 5 Shivhari 104509568 - 52881536 58397900 0 58397900 Trading LLP 51628032.05 6 Trisha 0 18342500 18342500 0 4399750 4399750 Vikash Bajaj 7 Bajaj Sonali 0 14740144 14740144 0 3294258 3294258 Ateet Total 301578340 153554746 366388753 519943500 232153282 309600866 #Wherever, the net sell quantity during SMS period is less than or equal to quantity bought during the Pre- SMS Period, the buy value is calculated by multiplying Net Sell quantity with Average buy price during Pre-SMS Period.

In cases, where the net sell quantity during SMS period is more than the quantity bought during the Pre-SMS Period, the buy value is calculated in two steps: 1. by multiplying Net Sell quantity (equals to the net buy quantity during the Pre-SMS Period) with Average buy price during Pre-SMS Period 2. by multiplying Balance Net Sell quantity with opening price on March 25, 2020 i.e. first day of the investigation period. In case of entity at Sl. Nos. 6 and 7, the Net sold quantity during SMS period is equal to the total quantity bought during the Pre-SMS Period across both the exchanges. Hence, profit is calculated considering trading on both the Exchanges.

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling

Table No. 40 Profit made by Sub-group 2 (Ahmedabad based entities) S.No. Entity Name BSE Net NSE Net Total Net BSE NSE Total Sell Sell Value Sell Value Profit Profit Profit Value (INR) (INR) (INR) 1 Chiragkumar 0 1858681 1858681 0 203894 203894 Makwana

2 Makwana 0 1241892 1241892 0 116051 116051 Madhuben 3 Hina Barot 0 683985 683985 0 119840 119840 4 Prakash Kantilal 0 2670060 2670060 0 346746 346746 Vaghela

Total 0 6454618 6454618 0 786531 786531 In case of entities from Sl. Nos. 1 to 4, the Net sold quantity during SMS period is equal to the total quantity bought during the pre-SMS Period across both the exchanges. Hence, profit is calculated considering trading on both the Exchanges.

Table No. 41 Profit made by Sub-group 3 (Kolkata based entities)

S.No. Entity BSE Net NSE Net Total Net BSE NSE Profit Total Profit Name Sell Value Sell Value Sell Value Profit (INR) (INR) (INR) 1. Linkup 5016737 0 5016737 828487 0 828487 Financial Consultants Private Limited 2. Highgrowth 0 7025000 7025000 0 1486224 1486224 Vincom Private Limited 3. Sumit Laha 0 1800000 1800000 0 229511 229511 4. Sanjay Dey 0 4226485 4226485 0 469039 469039 5. Suprabhat 0 100000 100000 0 22780 22780 Laha 6. Ujjal Laha 0 5252718 5252718 0 1308049 1308049 7. Buddhadeb 0 2176404 2176404 0 474282 474282 Laha 8. Sourav Das 0 8581724 8581724 0 1820173 1820173 9. Minu 0 303478 303478 0 60288 60288 Mallick

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling

S.No. Entity BSE Net NSE Net Total Net BSE NSE Profit Total Profit Name Sell Value Sell Value Sell Value Profit (INR) (INR) (INR) 10. Arun Dutta 0 4186000 4186000 0 954922 954922 11. Debashish 0 3921986 3921986 0 1132300 1132300 Dutta 12. Uma Dutta 0 5803000 5803000 0 1349364 1349364 13. Subrata 0 3737000 3737000 0 999319 999319 Laha 14. Priyankar 0 1159850 1159850 0 179577 179577 Laha 15. Tapas Laha 0 2445370 2445370 0 280631 280631 16. Arun Laha 0 3163500 3163500 0 618810 618810 17. Dibakar 1480000 1374760 2854760 161792 305694 467486 Laha Total 6496737 55257275 61754012 990279 11690963 12681242

The Ultimate Beneficiaries 80. As noted in the preceding paragraphs, one of the prima facie PV Influencers groups, namely the Chiripal Group, where entities were directly and / or indirectly connected with the Promoter / Promoter Group of VFL were not only seen to be dealing in the scrip of the Company amongst themselves but were also found to be executing prima facie manipulative trades (as discussed in preceding paragraphs) with the entities who are connected with Mr. Hanif Shekh, namely, the entities belonging to Sub-groups 2 and 3. The other entity which was also prima facie involved in artificially impacting the price of the scrip was found to be GBFL which was also connected with Mr. Hanif Shekh. Moreover, Mr. Hanif Shekh is prima facie the person who was sending bulk SMSs in the matter with buy recommendations to the public in favour of the said scrip which was traded in a manipulative manner by the PV Influencers groups as well as by GBFL to artificially inflate the volumes and price of the scrip. Thus, a picture now emerges which shows that prior to circulation of bulk SMSs in the scrip, certain entities connected to Promoters and Mr. Hanif Shekh have prima facie artificially influenced the price and volume in the scrip and thereafter coinciding with the circulation of bulk SMSs in the scrip which was done by Mr. Hanif Shekh, various entities which are directly and / or indirectly connected with the Promoter /

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling

Promoter Group of VFL and connected with Mr. Hanif Shekh, exited the scrip riding on the inflated volumes and price of the scrip, after making a substantial profit. In other words, a prima facie scheme was employed while dealing in the scrip wherein in each leg of the said scheme, entities related to either Promoters or Mr. Hanif Shekh have played a significant role to successfully execute the scheme. To elaborate further, in the first leg of the scheme, Chiripal Group, Sub-groups 2 and 3 and GBFL have dealt in the scrip so as to maintain the price and volume in the scrip at an elevated level which would be adequate enough to attract investors to deal in the scrip. In the next leg, bulk SMSs were circulated to prima facie attract the attention of the investors to the sustained rise in the price and volume in the scrip so that they may decide to invest in the scrip in large numbers and finally, taking advantage of the inflated levels of trading volumes and price of the scrip caused by the trading activities PV Influencers and other connected entities including GBFL as well as triggered by the circulation of bulk SMSs, the entities belonging to Chiripal Group and Sub-groups 2 and 3 have off-loaded their shares to exit the scrip after making significant profit.

81. As one scrutinizes the multiple layers of the aforesaid prima facie scheme, one can look through these layers to unravel the real reason as to why the entire scheme was hatched which was nothing but with an illicit intent to prima facie benefit the entities belonging to the Promoter / Promoter Group of VFL and to Mr. Hanif Shekh. The same also prima facie shows the complicity of the Promoters of the Company with Mr. Hanif Shekh. The involvement of entities connected with the Promoter/ Promoter Group of the Company in prima facie manipulating the price and volume of the scrip inter alia by trading with entities connected to Mr. Hanif Shekh when seen along with the fact that when bulk SMSs were circulating in the market for a considerable period of time, disseminating misleading and false information to the public, no action or clarification was ever forthcoming from them who were also at the helms of affairs of the Company. Such inaction and non-responsive attitude on the part of the Company or its Promoters further reinforces the prima facie inference of the collusion between the Promoter/ Promoter Group of the Company (Chiripal Group) and Mr. Hanif Shekh in the entire scheme including in the act of sending of the bulk SMSs to entice the public

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling to invest in the scrip. Keeping the aforesaid in view, the prima facie Ultimate Beneficiaries in the scrip can be identified as follows: 81.1. Entities connected to Promoter/ Promoter Group of the Company who not only have prima facie acted as PV Influencers but were also Off Loaders namely, Ms. Durgeshwari Pradipbhai Chiripal, Mr. Manuj Ashokkumar Chiripal, Rushp Trading LLP, Satrama Trading LLP, Shivhari Trading LLP, Ms. Trisha Vikash Bajaj and Mr. Bajaj Sonali Ateet. 81.2. Mr. Hanif Shekh – It has already been discussed in preceding paragraphs while considering the dealing in the scrip of MUL that entities pertaining to Sub-groups 2 and 3 were funded by Sub-groups 2.A and 3.A, respectively and in turn Sub-groups 2 and 3 were transferring funds back to Sub-groups 2.A and 3.A. Subsequently, Sub-groups 2.A and 3.A through multiple layers of transactions have been found to have transferred money to Mr. Hanif Shekh. Similarly, in the scrip of VFL also, the entities pertaining to Sub-groups 2 and 3 who prima facie not only performed the role of PV Influencers but also as Off Loaders, are found to be nothing but prima facie front entities of Mr. Hanif Shekh. Therefore, though the entities pertaining to Sub-groups 2 and 3 made substantial profit in the scrip as noted at Table Nos. 40 and 41, the Ultimate Beneficiary was none other than Mr. Hanif Shekh. 82. Now moving on to the determination of the prima facie violations by the entities involved in the scrip of VFL. Considering the fact that the prima facie scheme employed in the scrip of VFL is similar to the scheme employed in the scrip of MUL wherein the modus operandi is similar and the role of entities as PV Influencers, SMS Sender and Ultimate Beneficiaries, is also similar. Consequently, the rationale for holding each entity liable for the role played by them in the prima facie scheme would also be similar. Therefore, for the sake of brevity, the rationale for their prima facie violation is not repeated once again. 83. The entities who have played the prima facie role of PV Influencers in the scrip and have been mentioned at Table No. 32 are therefore prima facie guilty of violation of Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling

Sections 12A (a), (b) and (c) of SEBI Act and regulations 3 (a), 3 (b), 3 (c), 3(d), 4(1) and 4(2)(a), (b), (e) and (g) of PFUTP Regulations. Further, the entity who has played the prima facie role of PV Influencer in the scrip and has been mentioned at Table No. 35 is therefore prima facie guilty of violation of Sections 12A (a), (b) and (c) of SEBI Act and regulations 3 (a), 3 (b), 3 (c), 3(d), 4(1) and 4(2) (a), (b) and (e) of PFUTP Regulations. 84. Next comes, the SMS Sender, Mr. Hanif Shekh. As noted in preceding paragraphs, Chiripal Group was also prima facie complicit in sending of bulk SMSs along with Mr. Hanif Shekh. Therefore, for the said action of Mr. Hanif Shekh and Chiripal Group, they have prima facie violated Sections 12A (a), (b) and (c) of SEBI Act and regulations 3 (a), 3 (b), 3 (c), 3(d), 4(1) and 4(2)(k) and (r) of PFUTP Regulations. 85. Moving on to the prima facie violations of the Off Loaders, it can be stated with conviction that the action of the Off Loaders was nothing but giving final effect to the consequences of the previous legs of the prima facie scheme. In other words, their action was the fruition of the scheme employed in the scrip and would not have been possible without the efforts / actions of the Chiripal Group and the kingpin of the prima facie scheme, Mr. Hanif Shekh. Therefore, the Off Loaders as mentioned at Table Nos. 39-41 along with the Chiripal Group and Mr. Hanif Shekh have prima facie violated Sections 12A (a), (b) and (c) of SEBI Act and regulations 3 (a), 3 (b), 3 (c), 3(d), 4(1) and 4(2)(a) of PFUTP Regulations. 86. It is noted from records that the entities connected to Mr. Hanif Shekh namely, Mr. Kasambhai Shekh, Ms. Hasina Kasambhai Shekh, Robert Resources Ltd., Econo Trade India Ltd., Econo Broking (Erstwhile Bansal Finstock) and Sai Metaltech LLP, also entities mentioned at Table No. 21 and entities mentioned at Table No. 17 have prima facie enabled Mr. Hanif Shekh to encash the benefit of the scheme employed by him along with the Promoters of the Company in the scrip, since the Promoters of the Company are seen to have facilitated in transferring of funds which were received by them from the other connected entities of Mr. Hanif Shekh namely, the Sub-groups 2.A, 3 and 3.A who had dealt in the scrip pursuant to the prima facie scheme employed

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling in the matter. Thus, the aforesaid actions of the connected entities of Mr. Hanif Shekh have prima facie led to the violation of Sections 12A (a), (b) and (c) of SEBI Act and regulations 3 (a), 3 (b), 3 (c), 3(d) and 4(1) of PFUTP Regulations. 87. The issue which now merits discussion is who amongst the aforesaid entities, would be prima facie liable for the proceeds generated by the employment of the prima facie scheme in the scrip. From the above discussion, I note that the kingpin, Mr. Hanif Shekh and Chiripal Group entities who were connected with the Promoters of the Company, were prima facie controlling and implementing the scheme at its various stages. Not only that, they were also the Ultimate Beneficiaries of the prima facie scheme. Therefore, based on the available records, it is prima facie inferred that Mr. Hanif Shekh and his connected entities namely Mr. Kasambhai Shekh, Ms. Hasina Kasambhai Shekh, Robert Resources Ltd., Econo Trade India Ltd., Econo Broking (Erstwhile Bansal Finstock) and Sai Metaltech LLP including entities of Sub Groups 2 and 3 as mentioned at Table Nos. 40 and 41 and members of Chiripal Group as mentioned at Table No. 39, are jointly and severally liable for the wrongful gain generated in the scrip of VFL by employment of the prima facie scheme, to the tune of INR 1,34,67,773/- while the Chiripal Group as mentioned at Table No. 39 and entities mentioned at Table No. 20 are jointly and severally liable for the wrongful gains generated in the scrip by the employment of the prima facie scheme, to the tune of INR 30,96,00,866/-. 7NR Retail Limited 88. 7NR Retail Limited (hereinafter referred to as “7NR / Company”) is the company engaged in the business of trading of textiles and mainly deals in the business of branding and selling readymade garments, suiting-shirting, fabrics and other textile products. 7NR got listed on BSE on July 18, 2017. Based on the price and volume movement in the scrip, the trading in the scrip was examined for the period January 10, 2019 to December 27, 2019 (hereinafter referred to as “Investigation Period – 7NR”). It is noted that during the period January 10, 2019 to November 8, 2019, the scrip opened on BSE at INR 16.80/- and closed at INR 169/- with a high of INR 173/,

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling with an average daily volume of 47,458 shares, while during the period November 11, 2019 to December 27, 2019, the scrip opened on BSE at INR 169/- and closed at INR 193.05/- with a high of INR 239.50/-, with an average daily volume of 5,05,847 shares. The aforesaid figures show that not only the price in the scrip increased by almost 11.5 times within a span of less than 12 months but also there was a huge spurt in the volume of the scrip. The Price – Volume chart in the scrip for that period is depicted below: Figure No. 7 PV Chart - 7NR 300 1200000 250 1000000 200 800000 150 600000 100 400000 50 200000 0 0

No.of Shares Close Price

89. The aforesaid Price – Volume charts show that from January 10 2019 onwards till October, 2019, there has been a gradual increase in the price and volume of the scrip but in the next two months i.e., during November – December 2019, there has been a significant increase in both price and volume of the scrip. During the Investigation Period, it is noted that there were hardly any major corporate announcements or any major change in Company’s earnings (rather earnings decreased from INR 0.48 crore in quarter ending September 2019 to INR 0.12 crore in quarter ending December 2019). The absence of any fundamental change in the operations of the Company has to be seen in conjunction with the bulk SMSs which had started circulating in favour of the scrip with buy recommendations to the recipients of such SMSs from November 11, 2019 onwards. As noted in the preceding paragraphs in connection with Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling discussions about other scrips such as MUL and VFL, circulation of bulk SMSs is prima facie the core strategy of the scheme employed in the scrip of 7NR. The aforesaid factors were compelling enough to examine the dealings in the scrip during the Investigation Period. Thus, the trading in the scrip of 7NR has been examined in two phases, one during pre-SMS period (January 10 2019 to November 08, 2019) and the other during SMS period (November 11, 2019 to December 27, 2019). PV Influencers 90. It is noted from the records that during pre-SMS period (January 10 2019 to November 08, 2019), the price and volume in the scrip on BSE has increased significantly. Same is self-evident from the table below: Table No. 42 Price Volume Date Closing Price % change Daily traded % change volume 10-Jan-19 12.86 - 36000 - 08-Nov-19 168.55 1211% 82105 128%

Gohil Group and Sub-group 3 (Kolkata based entities) 91. It was noted that the following group (collectively referred to as “Gohil Group”) of connected entities were frequently trading in the scrip of 7NR during the pre-SMS period: Table No. 43

S No Name Basis of Connection Entities Shalini Sushil Jain & Devarshi J Shah are Directors of Mehai 1 Shalini Sushil Jain Technology Limited. On analyzing the bank statement of the entity Hardik Parmar held with Bandhan Bank having Account No-10180005606277, it was observed 2 Devarshi J Shah that Hardik Parmar had transferred funds to entity Devarshi J Shah who is director in the company, Mehai Technology Ltd.

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling

S No Name Basis of Connection On analyzing the bank statement of entity Sayar S Bhandari held with Bandhan Bank bearing Account No-50160003208331, it was observed that the entity had transferred & also received funds from the entity Vimala Ostwal. Sayar S Bhandari also transferred funds to the entity Rekha Bhandari. 3 Sayar S Bhandari Sayar S Bhandari had received funds and had also transferred funds frequently to the entity Novex Commercial in which, Jitendra H Gohil & Shilpaben Solanki are Directors. As per UCC details, Vimala Anandraj Ostwal Bhandari shared common Vimala Anandraj 4 address viz. ‘66 Secretariat Colony 2nd Street, Kilpauk, Chennai 600010’ Ostwal Bhandari with Sudhir Ostwal & Shalini Jain who are Directors of Mehai Technology Ltd. 5 Rekha Ravi Bhandari As per UCC details, Rekha Bhandari shared a common phone viz. ‘9726077352’ number with entity Vimala Ostwal. Jitendra H Gohil is the father of Shrenik Gohil and both shared a common address viz.'T-1 Jaysurya Flat Vejalpur Ahmedabad 380051'. 6 Jitendra H Gohil On analyzing the bank statement of the entity Jitendra H Gohil (who is also observed as Director of Novex Commercial) held with Central Bank of India account no-3321848728, it was observed that said Jitendra H Shrenik Jitendrabhai Gohil had made multiple fund transfers to entities Vijay Vasita, Nitesh 7 Gohil Pavskar, Dixit Borisa, Mahesh Purabia, Naginbhai Jeshingbhai Maheriya and also received funds from the entities Akshay Brahmabhatt, Kamleshbhai Solanki & ManoharPrasad Ghanshyambhai Vaishnav.

On analyzing the Bank statement of Shrenik Jitendrabhai Gohil held with Central Bank of India bearing account no-3480690617, it was observed that Shrenik Jitendrabhai Gohil had made multiple fund transfers to entities viz. Akshay Brahmabhatt, Vijay Vasita, Naginbhai Jeshingbhai Maheriya, Amit Bechu Yadav, Kamleshbhai Solanki, Hardik Parmar, 8 Amit Bechu Yadav Kapilaben Raval, Maunesh H Devara & Mahesh Purabia & received funds from the entities viz. Neeta Dabhi, Prabhavatiben Patliya, Govindbhai Natvarlal Chauhan. Further it was also observed that the said entity has received funds from the entity Novex Commercial (Jitendra H Gohil is Director) & has transferred funds to entities of Sub-Group 3.A viz. Cradon Traders, Frexon Suppliers, Migent commodeal, Rightview Dealers & Armeva Dealers. On analyzing the bank statement of entity Hardik Parmar held with Bandhan Bank Account No-10180005606277, it was observed that the said entity had transferred funds to entity Devarshi J Shah & Dakshaben 9 Hardik Parmar Purabiya. Further, Hardik Parmar received funds from entity Shrenik Gohil.

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling

S No Name Basis of Connection On analyzing the Bank statement of the entity Vijay Vasita held with Vijay Rajeshbhai Central Bank of India (A/C No: 3958462182) it was observed that the 10 Vasita entity had received funds from Novex Commercial (Jitendra H Gohil is Director) and transferred funds to Migent commodeal, Armeva Dealers, Cradon Traders, Sushma J Barot, Chintukumar Pandya, ManoharPrasad Vaishnav, Shrenik JitendraBhai Gohil, Nitesh Pavskar. Also, Vijay Rajeshbhai Vasita had received funds multiple times from Chintukumar 11 entities Akshya Jitendrakumar Brahmabhatt, Mahesh Purabia, Vasudevbhai Pandya Naginbhai Jeshingbhai Maheriya, ManoharPrasad Vaishnav, Prabhavatiben Patliya, Govindbhai Natvarlal Chauhan & Chandrikaben Maheshbhai Chauhan. On analyzing the Bank Statement of entity Nitesh P Pavskar held with Central Bank of India (A/C No: 3488168900), it was observed that he had received funds from entity Novex Commercial. Nitesh P Pavskar had transferred funds to entity Neeta Ganpatbhai Dabhi. Nitesh P Pavskar had also transferred funds to entities Dixit 12 Nitesh P Pavskar Borisa, Kapilaben Raval, Maheshbhai Purabia, Vijay Vasita, Maheshbhai Purabia, Jitendra Gohil, Akshay Brahmbhatt & Naginbhai Maheriya.

Further, Nitesh P Pavskar had received funds from entity Chandrikaben Maheshbhai Chauhan. Akshay As per the UCC details, Akshay Jitendrakumar Brahambhatt & Sushma 13 Jitendrakumar Jasmin Barot shared common Address Viz. ‘444 Karnavati Nagar, Brahambhatt Amraiwadi Ahmedabad 380026’ & contact no. viz.’ 9974630757'. On analyzing the bank statement of the entity Sushma Jasmin Barot held with Bandhan Bank Account no-10180005606457, it was observed that she has received funds from entities Mahesh Purabia, and Vijay Vasita, On analyzing the bank statement of the entity Akshay Jitendrakumar 14 Sushma Jasmin Barot Brahambhatt held with Central Bank of India bearing Account No 3501322597, it was observed that he has transferred funds multiple times to entities ManoharPrasad Vaishnav, Vijay Vasita, Nitesh Pavskar, Dixit Borisa, Jitendra Gohil, Mahesh Purabia & Prabhavatiben Natvarbhai Patliya. Maheshbhai N As per UCC details, Maheshbhai N Purabia & Dakshaben Maheshkumar 15 Purabia Purabiya shared a common address viz.'1431 7 Ganeshs Dahelu Mojdibajar New Madhupura Ahmedabad 380004'. Also, Neeta Dakshaben Ganpatbhai Dabhi and Maheshbhai N Purabia shared a common mobile 16 Maheshkumar no i.e. 9714714141. Purabiya

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling

S No Name Basis of Connection On analyzing the bank statement of the entity Mahesh Purabia held with Central Bank of India account no 3958457058, it was observed that the entity had transferred funds multiple times to entities Vijay Vasita, Chintukumar Pandya, Sushma J Barot, Nitesh Pavskar, Manoharprasad Vaishnav, Dixit Borisa, Jitendra Gohil, Akshay Brahmabhatt & Chandrikaben Maheshbhai Chauhan & further received funds from the entities Govindbhai Natvarlal Chauhan, Prabhavatiben Natvarbhai Patliya. Neeta Ganpatbhai Further, it was also observed that Neeta Ganpatbhai Dabhi had received 17 Dabhi funds from the entity Novex Commercial (Jitendra H Gohil is Director) & has transferred funds to the entities Armeva Dealers, Rightview Dealers On analyzing the bank statement of entity Neeta Dabhi held with Central Bank of India account no 3536728881, it was observed that she has transferred funds multiple times to entities viz. Prabhavatiben Natvarbhai Patliya, Shrenik Gohil, Dixit Borisa & Nitesh Pavskar. Further, she has received funds from the entity Novex Commercial (Jitendra H Gohil is Director).

Naginbhai As per KYC details, Naginbhai Maheriya & Binal Naginbhai Patel shared 18 Jeshingbhai a common address at 'F 5 Jaysurya Apts Vejalpur Ahmedabad 380051’. Maheriya On analyzing the bank statement of the entity Naginbhai Jeshingbhai Maheriya held with Central Bank of India’ (A/C No: 3537330299), it was 19 Binal Naginbhai Patel observed that Naginbhai Jeshingbhai Maheriya had received funds from Novex Commercial. Prabhavatiben 20 Natvarbhai Patliya Naginbhai Jeshingbhai Maheriya had transferred funds to Dixit Borisa, Vijay Vasita, Jitendra Gohil, Maheshbhai N Purabia & Akshay Brahmbhatt. On analyzing the bank statement of entity Binal Naginbhai Patel held with Bandhan Bank bearing account no-10180005606247, it was observed that Binal Naginbhai Patel had received funds from 21 Natvarbhai Patlia Prabhavatiben Natvarbhai Patliya and transferred funds to the entity Jitendra H Gohil. As per UCC database, the entities Prabhavatiben Natvarbhai Patliya & Natvarbhai Patlia shared a Common Contact No. 9879348947’. Kamleshkumar G On analyzing the bank statement of entity Kamleshkumar G Solanki held 22 Solanki with Bandhan Bank bearing account no-10190004038623 and held with Central Bank of India bearing account no – 3537330404, it was observed Maunesh that the entity (Kamleshkumar G Solanki) had transferred funds to 23 Hargovinddas Jitendra H Gohil, Maunesh Devara, Vijay Vasita & Nitesh Pavskar.

Devara On analyzing the bank statement of the entity Maunesh H Devera held with State Bank of India bearing account no-30201996995, it was Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling

S No Name Basis of Connection observed that the entity (Maunesh H Devera) had received funds from entities Nitesh Pavskar, Shrenik Gohil, Vijay Vasita, Akshay Jitendrakumar Brahmabhatt & Kamleshkumar G Solanki. On analyzing the bank statement of the entity Manoharprasad Ghanshyambhai Vaishnav held with Central Bank of India account no- 3538644738, it was observed that the entity (Manoharprasad Manoharprasad Ghanshyambhai Vaishnav) had received funds from the entity Novex 24 Ghanshyambhai Commercial (Jitendra H Gohil is director), Chandrikaben Maheshbhai Vaishnav Chauhan & Govindbhai Natvarlal Chauhan & has transferred funds to entities Amit Bechu Yadav, Armeva Dealers, Vijay Vasita, Jitendra H Gohil, Nitesh Pavskar, Mahesh Purabia & Akshay Brahmabhatt. On analyzing bank statement of the entity Dixit Nareshbhai Borisa held with Central Bank of India’ (A/C No: 3491131055), it was observed that Dixit Nareshbhai Borisa had received funds from the entity Neeta Dixit Nareshbhai Ganpatbhai Dabhi. 25 Borisa Further the Dixit Nareshbhai Borisa had transferred funds to entities Jitendra Gohil, Vijay Vasita, Nitesh P Pavskar & Akshay Brahmbhatt. On analyzing the bank statement of entity Tejal Amitkumar Khatri held Tejal Amitkumar with Central Bank of India’ (A/C No: 3211141339), it was observed that 26 Khatri Tejal Amitkumar Khatri had transferred funds to the entity Govindbhai Natvarlal Chauhan& Ravindra Raval. Chauhan As per UCC database, Chandrikaben Chauhan & Govindbhai Chauhan 27 Chandrikaben shared a common address viz, '2281 Khadayata Ni Khadki Oppcentral Maheshbhai Bank Near Raipur Chklaraipur Ahmedabad 380001'. On analyzing the bank statement of the entity Govindbhai Chauhan held with central Bank of India, it was observed that Govindbhai Chauhan had transferred funds to the entities Tejal Kumar Khatri, Mahesh Purabia, Vijay Vasita, Manoharprasad Vaishnav & Shrenik Gohil. Chauhan Govindbhai 28 On analyzing the bank statement of the entity Chandrikaben Chauhan Natvarlal held with Central bank of India bearing account no 3713055846, it was observed that Chandrikaben Chauhan had transferred funds multiple times to entities Manoharprasad Vaishnav, Nitesh Pavskar, Vijay Vasita, Prabhavatiben Patlia, Mahesh Purabia, Govind Natvarlal Chauhan & Jitendra Gohil.

Ravindra Nanalal As per UCC database, it was observed that the entities Ravindra & 29 Raval Kapilaben Raval shared a common address viz. 'S 5 Jaysurya Apts Opp Vastrapur Rel Station Vejalpur Jivraj Park Ahmedabad 380051'. Kapilaben Ravibhai 30 Raval

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling

S No Name Basis of Connection On analyzing the bank statement of Ravindra Raval held with Bandhan Bank bearing account no-10190002818580, it was observed that Ravindra Raval had received funds from the entity Tejal Kumar Khatri. On analyzing the bank statement of Kapilaben Raval held with Bandhan Bank account no-10190002818620, it was observed that Kapilaben Raval had received funds from the entities Nitesh Pavskar & Shrenik Gohil.

92. It is noted from the contents of the above table that the aforesaid 30 entities (Gohil Group) are well connected with each other either by way of common mobile numbers or common addresses or common directorship or are part of the same family or having multiple fund transactions amongst themselves. For instance, Ms. Shalini Sushil Jain and Mr. Devarshi J Shah are Directors in Mehai Technology Limited. Mr. Jitendra H Gohil is the father of Mr. Shrenik Gohil and both of these entities shared a common address viz.'T-1 Jaysurya Flat Vejalpur Ahmedabad 380051'. Similarly, Mr. Maheshbhai N Purabia & Ms. Dakshaben Maheshkumar Purabiya shared common address viz. '1431 7 Ganeshs Dahelu Mojdibajar New Madhupura Ahmedabad 380004’. Also, bank transactions have been observed between Mr. Shrenik Jitendrabhai Gohil (Central Bank of India account no-3480690617) with Mr. Akshay Brahmabhatt, Mr. Vijay Vasita, Mr. Naginbhai Jeshingbhai Maheriya, Mr. Amit Bechu Yadav, Mr. Kamleshbhai Solanki, Mr. Hardik Parmar, Ms. Kapilaben Raval, Mr. Maunesh H Devara & Mr. Mahesh Purabia, Ms. Neeta Dabhi, Ms. Prabhavatiben Patliya, Mr. Govindbhai Natvarlal Chauhan, etc. Further, Ms. Neeta Ganpatbhai Dabhi and Mr. Maheshbhai N Purabia shared a common mobile no i.e. ‘9714714141’.

The aforesaid factual findings prima facie reveal the close proximity and close connection enjoyed by these entities and when such close connection is examined along with the way the said entities have traded in a concerted manner and also are seen to have traded posing as counterparties to each other’s trades in the scrip of 7NR during the pre-SMS period (January 10 2019 to November 08, 2019), it prima facie leads me to observe with a lot of conviction that the manner of their dealing in the scrip of 7NR was part of a premediated plan. The aforesaid prima facie observation is further strengthened by the fact that the Gohil Group entities have not only traded amongst themselves to Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling prima facie influence the price and volume of the scrip during the pre-SMS period (discussed in subsequent paragraphs) but have also traded in a similar manner with the other set of PV Influencers as well viz: with the entities of Sub-group 3 (Kolkata based entities) who as noted in preceding paragraphs of this order, are prima facie connected with Mr. Hanif Shekh, the SMS Sender in the scrip of 7NR.

It is further noted from the material available on record that not only the Gohil group entities have traded with the entities connected with Mr. Hanif Shekh but have also had funds transactions with the entities connected with Mr. Hanif Shekh, and / or Hanif Entities. For, instance, funds transfers have been observed between the Gohil Group entities viz. Mr. Shrenik Gohil, Mr. Vijay Vasita, Ms. Neeta Dabhi and Mr. Nitesh Pavskar with Hanif entities namely, Frexon Suppliers, Migent Commodeal, Rightview Dealers, Armeva Dealers, Shakti Enterprise, Samukh Trades, Aneel & Co, etc. Thus, the very act of these entities of the aforesaid two motley groups coming together to deal in the scrip of 7NR in a concerted manner during the pre-SMS period signifies that such concerted manner of trading in the scrip of 7NR wherein the connected entities have themselves posed as counterparties to each other’s trades, was prima facie instigated by a pre-planned design and pursuant to a prima facie scheme employed to deal in the scrip. 93. Contribution of the aforesaid 2 groups i.e., Gohil Group and Kolkata based entities to the price and volume rise in the scrip of 7NR during the period from January 10 2019 to November 08, 2019, is shown below: Table No. 44

%Buy % to %Sell to contrib total total Net Net Sell Total ution to Sl No Entity Name Buy Qty Marke Sell Qty Market Buy LTP LTP net t Buy Sell LTP price Volum Volume rise e Gohil group 1 Akshay 84002 1.22 189395 2.75 2.32 35.55 37.87 24.39 Jitendrakumar Brahambhatt

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling

%Buy % to %Sell to contrib total total Net Net Sell Total ution to Sl No Entity Name Buy Qty Marke Sell Qty Market Buy LTP LTP net t Buy Sell LTP price Volum Volume rise e 2 Shrenikbhai J 74792 1.09 113939 1.66 10.20 18.10 28.30 18.23 Gohil 3 Tejal 203702 2.96 45700 0.66 10.95 10.75 21.70 13.98 Amitkumar Khatri 4 Kamleshkumar 45220 0.66 70877 1.03 -3.95 16.15 12.20 7.86 G Solanki 5 Amit Bechu 186000 2.70 0 0.00 11.20 0.00 11.20 7.21 Yadav 6 Vijay 100621 1.46 273333 3.97 4.40 6.57 10.97 7.07 Rajeshbhai Vasita 7 Maheshbhai N 12001 0.17 104917 1.52 2.60 7.85 10.45 6.73 Purabia 8 Jitendra H 3990 0.06 83904 1.22 0.00 9.55 9.55 6.15 Gohil 9 Chintukumar 166740 2.42 9810 0.14 9.05 -0.90 8.15 5.25 Vasudevbhai Pandya 10 Vimala 84000 1.22 504000 7.32 0.00 7.85 7.85 5.06 Anandraj Ostwal 11 Natvarbhai 55050 0.80 1060 0.02 8.45 -1.05 7.40 4.77 Patlia 12 Nitesh P 31099 0.45 198879 2.89 -2.65 8.80 6.15 3.96 Pavskar 13 Naginbhai 54000 0.78 106479 1.55 0.00 6.05 6.05 3.90 Jeshingbhai Maheriya 14 Sushma Jasmin 51664 0.75 4100 0.06 3.50 0.05 3.55 2.29 Barot 15 Rekha Ravi 306000 4.45 306000 4.45 -1.15 4.42 3.27 2.11 Bhandari 16 Binal 54900 0.80 200 0.00 3.00 0.15 3.15 2.03 Naginbhai Patel 17 Govindbhai 114000 1.66 61 0.00 3.90 -1.05 2.85 1.84 Natvarlal Chauhan 18 Dixit 0 0.00 69020 1.00 0.00 2.70 2.70 1.74 Nareshbhai Borisa 19 Devarshi 32700 0.48 1000 0.01 2.70 -0.15 2.55 1.64 Jayrajbhai Shah 20 Ravindra 57264 0.83 3250 0.05 2.45 -0.05 2.40 1.55 Nanalal Raval

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling

%Buy % to %Sell to contrib total total Net Net Sell Total ution to Sl No Entity Name Buy Qty Marke Sell Qty Market Buy LTP LTP net t Buy Sell LTP price Volum Volume rise e 21 Maunesh 9700 0.14 0 0.00 1.15 0.00 1.15 0.74 Hargovinddas Devara 22 Hardik 22900 0.33 0 0.00 0.20 0.00 0.20 0.13 Ramanbhai Parmar 23 Chandrikaben 168000 2.44 75 0.00 0.00 0.00 0.00 0.00 Maheshbhai Chauhan 24 Dakshaben 28751 0.42 4201 0.06 1.10 -1.10 0.00 0.00 Maheshkumar Purabiya 25 650 0.01 650 0.01 0.00 0.00 0.00 0.00 Shalini Jain 26 Sayar S 84000 1.22 468000 6.80 -4.05 3.95 -0.10 -0.06 Bhandari 27 Kapilaben 39800 0.58 0 0.00 -1.80 0.00 -1.80 -1.16 Ravibhai Raval 28 Manoharprasa 24000 0.35 57910 0.84 -1.85 -1.40 -3.25 -2.09 d Ghanshyambha i Vaishnav 29 Neeta 0 0.00 180000 2.62 0.00 -5.45 -5.45 -3.51 Ganpatbhai Dabhi 30 Prabhavatiben 18000 0.26 119420 1.74 -4.20 -2.25 -6.45 -4.15 Natvarbhai Patliya Total (A) 2113546 30.71 2916180 42.38 57.52 125.09 182.61 117.62 Kolkata Group Highgrowth 138000 2.01 0 0.00 0.00 0.00 0.00 0 Vincom Private 31. Limited Sumit Laha 129000 1.87 0 0.00 -4.45 0.00 -4.45 -3 32. Dibakar Laha 128600 1.87 0 0.00 -0.25 0.00 -0.25 0 33. Sanjay Dey 97800 1.42 0 0.00 -0.75 0.00 -0.75 0 34. Arpan Das 74500 1.08 0 0.00 2.30 0.00 2.30 1 35. Suprabhat Laha 66550 0.97 5300 0.08 0.25 -0.75 -0.50 0 36. Ujjal Laha 61100 0.89 0 0.00 -0.05 0.00 -0.05 0 37. Glorious 48000 0.70 6000 0.09 1.50 0.00 1.50 1 Vincom Private 38. Limited Sourav Das 42000 0.61 0 0.00 1.00 0.00 1.00 1 39.

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling

%Buy % to %Sell to contrib total total Net Net Sell Total ution to Sl No Entity Name Buy Qty Marke Sell Qty Market Buy LTP LTP net t Buy Sell LTP price Volum Volume rise e Minu Mallick 37400 0.54 0 0.00 0.45 0.00 0.45 0 40. Uma Dutta 25457 0.37 11500 0.17 0.20 0.00 0.20 0 41. Linkup 25000 0.36 0 0.00 3.25 0.00 3.25 2 Financial Consultants 42. Private Limited Arun Dutta 23500 0.34 0 0.00 0.10 0.00 0.10 0 43. Buddhadeb 18000 0.26 0 0.00 0.05 0.00 0.05 0 44. Laha Debashish 13900 0.20 0 0.00 1.65 0.00 1.65 1 45. Dutta Priyankar Laha 12500 0.1 0 0.00 0.00 0.00 0.00 0 46. Tapas Laha 11950 0.17 0 0.00 0.00 0.00 0.00 0 47. Subrata Laha 10000 0.15 0 0.00 0.00 0.00 0.00 0 48. Arun Laha 8500 0.12 500 0.01 0.00 0.00 0.00 0 49. TOTAL(B) 971757 14.12 23300 0.34% 5.25 -0.75 4.75 3% % Total (A+B) 3085303 44.83 2939480 42.72% 62.77 124.34 187.36 120.62% % Total (Trading 1418418 20.61 1418418 20.61% 18.3 11.79% within group) % Market Total 6881421 100% 6881421 100% 155.25 155.25 155.25

94. As can be seen from the above table, the Gohil Group along with the Kolkata based entities (Sub-group 3) have collectively prima facie contributed 44.83% of the market-buy volume and 42.72% of the market-sell volume during the pre-SMS period. Further, by trading amongst each other in unison prima facie as part of a group strategy in the scrip of 7NR, these entities have contributed 20.61% of the total market traded volume during the pre-SMS period. It is also noticed that the aforesaid connected entities have contributed to the tune of INR 187.36/- (120.62%) to the net price rise in the scrip that was witnessed during the pre-SMS period. The trades of the said connected entities were further analysed to determine as to how the said connected entities were trying to influence the volume and price in the scrip during the pre-SMS period, so as to present the scrip as an attractive investment proposition

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling for the investors in the securities market. Some illustrations to that effect are presented as follows: 94.1. On April 23, 2019, Mr. Sourav Das (part of Kolkata based entities) placed 2 different buy orders (order numbers 1555991100005067005 and 1555991100005067006) for 6,000 shares each (total quantity 12,000 shares) at the price of INR 57/- at 13:27:25 hours and 13:27:30 hours, respectively. On the same trading day, Mr. Sumit Laha (part of Kolkata based entities) placed 3 different buy orders (order numbers 1555991100005067007, 1555991100005067008 and 1555991100005067009) for 12,000 shares each (total quantity 36,000 shares) at the price of INR 57/- at 13:30:02 hours, 13:30:29 hours and 13:30:50 hours, respectively. It is pertinent to note that till this time, all the aforesaid 5 buy orders (with cumulative quantity of 48,000 shares) were lying pending / unmatched in the Stock Exchange system. However, at 13:31:39 hours, (after 49 seconds of placement of the 5th order of the aforesaid 5 buy orders), Ms. Vimala Anandraj Ostwal (part of Gohil Group) placed a sell order (order number 1555991100005067010) for 48,000 shares (exactly the same quantity placed for purchases by the entities from Sub-group 3) at the price of INR 57/-, which resulted in matching with the 5 separate pending buy orders and consequently 5 different trades were executed in the scrip of 7NR at a price of INR 57/-. It is also pertinent to mention here that all these 5 trades were the first 5 trades on that particular trading day in the scrip. Interestingly, the 1st trade also resulted in increase of LTP of INR 1/- (1.79%) from the previous closing day LTP of INR 56/-. 94.2. After executing the first five trades on April 23, 2019, entities from Sub-group 3 and Gohil group again accessed the market, wherein an entity from Sub-group 3 namely Mr. Sanjay Dey placed a buy order (order number 555991100005067011) for 24,000 shares at price of INR 57/- at 13:32:10 hours, which was followed by a buy order (order number 555991100005067012) from Mr. Ujjal Laha (part of Sub-group 3) for 6,000 shares at a price of INR 57/- at 13:32:29 hours, which was further followed by a buy order (order number

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling

555991100005067013) from Mr. Sanjay Dey (another entity from Sub-group 3) for 12,000 shares at a price of INR 57/- at 13:33:21 hours. It is pertinent to note that till this time, all the aforesaid 3 buy orders having cumulative buy quantity of 42,000 shares, were lying pending / unmatched in the Stock Exchange system till 13:34:21 hours (i.e. 60 seconds from the placement the 3rd order of the aforesaid 3 buy orders), when an entity from Gohil group namely Mr. Sayar S Bhandari placed a sell order (order number 1555991100005067014) for 42,000 shares (exactly the same amount of shares placed under the 3 pending buy orders) at the price of INR 57/-, which resulted in matching with the 3 pending buy orders and 3 different trades were executed in the scrip of 7NR at the price of INR 57/-. It is worthwhile to mention here that the all the aforesaid 4 orders (3 buy orders and 1 sell order) were placed in a consecutive manner i.e. no other orders were placed on the exchange in the scrip of 7NR in between these 4 orders. It is also noteworthy here that all these 3 trades were the next 3 trades i.e. trade numbers starting from 6, 7 and 8 (executed after the first 5 trades referred to earlier) on the particular trading day in the scrip. 94.3. Subsequent to the execution of the 8th trade of the day (April 23, 2019), certain entities from the aforesaid 2 Groups again accessed the market, wherein 3 different entities from Sub-group 3 namely, Mr. Arpan Das, Mr. Dibakar Laha and Mr. Ujjal Laha placed 3 different buy orders (order numbers 555991100005067015, 555991100005067016 and 555991100005067017 respectively) for 6,000 shares, 24,000 shares and 12, 000 shares, respectively at a price of INR 57/-. Interestingly, these 3 buy orders were placed in close proximity of each other i.e. 13:41:03 hours (Mr. Arpan Das), 13:41:42 hours (Mr. Dibakar Laha) and 13:43:29 hours (Mr. Ujjal Laha). Subsequently, all these 3 buy orders were matched with a single sell order placed by Ms. Vimala Anandraj Ostwal (part of Gohil group)) for 42,000 shares (order number 1555991100005067018 and exactly the same quantity of buy orders that were placed by the entities from Sub-group 3) at the price of INR 57/- at 13:47:02

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling hours. It is also pertinent to mention here that these 3 trades were trade numbers 9 to 11 on that particular trading day in the scrip. From the aforesaid facts, it can be seen that all the above narrated 11 trades were structured trades (some of which were above LTP of the previous trading day) that were executed in the scrip of 7NR on April 23, 2019 by the entities of these connected groups of entities in a pre-determined or pre-planned manner, which prima facie demonstrate that the aforesaid connected entities have dealt in the scrip in such pre-planned manner only to impact the price and volume of the scrip. 94.4. The aforesaid trading pattern followed by the connected entities by taking turns as buyers and sellers thereby increasing the trading volume and contributing to the positive LTP in the scrip has been observed on various other trading days as well. For instance, on May 02, 2019, only 3 trades were executed in the scrip of 7NR and in all the 3 trades, entities from Sub-group 3 viz. Mr. Arpan Das and Highgrowth Vincom Private Limited have acted as buyers while another entity from Gohil group viz. Mr. Sayar S Bhandari has acted as the counterparty seller.

All these 3 trades (cumulative quantity of 39,000 shares) were executed at a price of INR 63/- and the 1st trade out of the aforesaid 3 trades itself has resulted in contributing to the positive LTP of INR 2/- (3.28% from previous LTP). Similarly, on May 06, 2019, only 9 trades were executed in the scrip and in all such 9 trades, entities from Sub-group 3 have acted as buyers and entities from Gohil group have acted as sellers. Further, all these 9 trades have resulted in trading of 96,000 shares and were executed at a price of INR 64/- while the 1st trade out of the aforesaid 9 trades resulted in contributing to positive LTP of INR 0.5/- (0.79% from previous LTP). 95. The aforesaid illustrations of the trades executed by the PV Influencers (Gohil Group and Kolkata based entities) in the scrip of 7NR demonstrate the trading pattern of the PV Influencers wherein both of the groups viz., Gohil group and Sub-group 3 (Kolkata based entities) were regularly trading with each other apparently by following a Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling strategy under which one set of entities was acting as buyer while the other set of entities was acting as the counterparty seller so as to prima facie artificially influence the price and volume in the scrip.

Further, the trades which could have been executed in one or two transactions were prima facie deliberately, broken down into several smaller transactions. By the said act, the entities have not only prima facie made an attempt to artificially inflate the number of trades executed in the scrip on a particular trading day thereby trying to artificially set the momentum for the trading in the scrip but also considering the fact that the counter parties to the said trades were connected with each other, such trades did not practically result in any actual change of ownership of shares so traded inter se, by the connected entities amongst themselves as the beneficial ownership of these traded shares stayed within the group which further goes on to show the unlawful attempt on the part of the PV Influencers to create artificial volumes in the scrip. The act of the PV Influencers to influence the volume and price in the scrip becomes further glaring from the fact that the orders placed by the entities on the sell side were identical in terms of quantity and price placed in the buy side orders.

Thus, the PV Influencers have prima facie tried to influence the volume and price in the scrip by executing trades amongst each other in a structured manner which were similar to but falling short of being called synchronized trades. The said trading pattern of the PV Influencers cannot occur by accident or by coincidence on an anonymous trading platform of the Stock Exchanges unless the parties to such trades decide to abuse the trading system. Therefore, by indulging in such deceitful trading patterns, the PV influencers in this scrip have made it obvious that there was a prior meeting of minds of these connected entities with a pre-determined plan to deal in the scrip of 7NR. Therefore, the trades executed in the scrip by the PV Influencers to create artificial volume and to inflate the price in the scrip are considered to be prima facie non-genuine trades that were executed in pursuance of a scheme employed in the scrip. 96. It is also noted that while trading amongst each other, these entities (Gohil Group and Kolkata based entities) have traded in close proximity of time inter se between them.

It is noted from the trade logs that out of 531 trades executed amongst each other by Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling these 49 entities, (i.e. Gohil Group along with Kolkata based entities), in 54 trades, the time difference between placing of buy order and sell order was 60 seconds or less than 60 seconds. It is worthwhile to mention here that these entities have contributed to trading volume of 3,69,319 shares (5.36% of the total trading volume during the pre-SMS period) in the aforementioned 54 trades which are also prima facie found to be synchronised trades. 97. It is clarified that the aforesaid methods are not the only methods employed by these connected entities to prima facie create artificial volume in the scrip but was the most frequently used method. A pre-determined plan to create artificial volume in the scrip becomes prima facie evident when the trades executed by the PV Influencers are juxtaposed with all the trades executed in the scrip on the Stock Exchange platforms during the pre-SMS period. As per the available records, it is noted that during the pre-SMS period, a total number of 62,575 trades were executed in the scrip of 7NR which resulted in trading of 68,81,421 shares of 7NR.

Out of the 68,81,421 shares of 7NR that were traded during the pre-SMS period, the connected entities (PV Influencers) while acting as buyers, cumulatively traded for 30,85,303 (44.83%) shares of 7NR in just 1,039 trades (1.66% of total trades executed in the scrip during the period). Similarly, for contributing 42.72% (29,39,480 shares) of the total volume as sellers, these connected entities traded in 3,287 trades (5.25% of the total trades in the scrip). Further, while trading within the group, it is observed that these entities traded in 14,18,418 shares (20.61% of trading volume) in only 531 trades (0.84% of the total trades executed in the scrip during the period). Though the connected entities have prima facie created substantial volumes in the scrip during the pre-SMS period, however, in effect only 2.11% (44.83% - 42.72%) of their traded volumes during the said period resulted in actual change of beneficial ownership while the remaining 42.72% shares were used just to create prima facie artificial volumes in the scrip with no change in effective beneficial ownership i.e., the ownership of the shares stayed within the group.

98. It is noted from the materials available on record that the PV Influencers have cumulatively contributed to the price rise by INR 187.36/- (120.62%) of the net price

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling rise of INR 155.25/- in the scrip of 7NR during the pre-SMS period. In other words, though the impact of the trades of the PV Influencers on the price of the scrip was INR 187.36/- (net basis) but some of the impact of the trades of PV Influencers was absorbed by the presence of other investors in the securities market, resulting in an overall impact of INR 155.25/- to the price of the scrip of 7NR during the pre-SMS period. Further, these connected entities, by trading amongst each other, have contributed INR 18.30/- (11.79%) to the net price rise of INR 155.25/- in the scrip of 7NR during the pre-SMS period. Upon examination of the trade log of the PV Influencers, it was noted that various methods were employed by these entities to prima facie influence the price in the scrip viz., by engaging in structured trades through matching of each other’s orders placed in quick succession by the connected entities, indulging in synchronised trades, manipulating the closing price and opening price etc. Few illustrations of these trades are cited below: 98.1.

On April 09, 2019, the 1st trade was executed in the scrip at 09:32:35 hours at a price of INR 50.5/- (which was INR 1.75/- less than the LTP on April 08, 2019). Then one of the connected entities namely, Mr. Amit Bechu Yadav (part of Sub – group 3), placed a buy order at 09:37:08 hours for 30,0000 shares of 7NR at INR 54.85/- (at that time the LTP was INR 50.5/-) and within less than 2 minutes, another connected group entity namely Ms. Vimala Anandraj Ostwal (part of Gohil Group) placed a sell order for 30,000 shares at 09:38:57 hours exactly at the price of INR 54.85/- to match the pending buy order of the aforesaid connected group entity, which resulted in creating a positive LTP of INR 4.35/- (8.61% increase from previous LTP of INR 50.5/-). It is important to note that it was the 2nd trade of that particular day which was executed in a structured manner and what is important is that apart from getting the scrip traded at a higher price (8.61%) than the LTP, the new LTP created by this trade also tried to portray a positive movement in the price of the scrip. It is pertinent to note that for next more than 5 hours, no other trade (after 2nd trade) was executed in the scrip of 7NR on April 09, 2019. Then, another set of entities from Sub-group 3 and Sub-group 4 approached the market, wherein one of the Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling connected entities Mr. Chintukumar Vasudevbhai Pandya (part of Sub-group 3) placed a buy order for 24,0000 shares at 14:53:18 hours (last modified time of order) at a price of INR 54.85/- (already set by the 2nd trade) and the entity namely, Mr. Sayar S Bhandari (part of Gohil Group) matched the aforesaid buy order within 6 seconds i.e. at 14:53:24 hours.

The aforesaid acts of the entities trading in a synchronised manner resulted in execution of 3rd and the last trade of the particular day (April 09, 2019) and ensured that the closing price of the day remains at INR 54.85/-. The said closing price set the momentum for the opening price of the scrip of 7NR for the next trading day (April 10, 2019) as well. 98.2. On April 10, 2019, one of the connected entities namely, Mr. Amit Bechu Yadav (part of Sub–group 3), placed a buy order (order number 1554867900022070003) at 10:17:43 hours for 36,0000 shares of 7NR at INR 56.50/- (at that time the LTP previous day was INR 54.85/-) and since no sellers were there on the platform at the said price and quantity, the aforesaid buy order was lying pending in the Stock Exchange system. After 3 minutes of the aforesaid buy order, Mr. Chintukumar Vasudevbhai Pandya (part of Sub-group 3) placed a buy order (order number 1554867900022070004) for 12,000 shares at INR 56.50/- per share. Within less than 2 minutes of the aforesaid 2nd buy order, another connected group entity namely Ms. Vimala Anandraj Ostwal (part of Gohil Group) placed a sell order (order number 1554867900022070005) for 60,000 shares at 10:22:39 hours exactly at the price of INR 56.50/- to match the pending buy orders of the connected group entities which resulted in creating a positive LTP of INR 1.65/- (3.01% increase from previous LTP of INR 54.85/-).

It is important to note that these two trades were 1st two trades of the particular day which were structured trades and apart from getting the scrip traded at higher price (3.01%) than LTP, the new LTP created by this trade also tries to portray a positive movement in the price of the scrip. Then, Ms. Binal Naginbhai Patel (part of part of Gohil Group) placed a buy order for 12,0000 shares at 11:45:11 hours (last modified time of order) at a price of INR 56.50/- (already set by the 1st and 2nd trades) and an entity namely Ms. Sayar S Bhandari (part of Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling

Gohil Group) matched the aforesaid buy order within 12 minutes i.e. at 11:57:26 hours which resulted in execution of the 3rd trade of the day. It is pertinent to note that the next 2 trades (trade nos. 4 and 5) were also structured trades, wherein these Gohil Group entities i.e. Ms. Binal Naginbhai Patel was acting as buyer and Ms. Sayar S Bhandari was acting as seller. Interestingly, only 5 trades were executed in the scrip on April 10, 2019 and all these trades were executed by the connected entities. The aforesaid acts of the entities trading in a structured manner, apart from ensuring that 72,000 shares are traded in the scrip on April 10, 2019, also ensured that the closing price of the day remained INR 56.50/- (higher than the previous days’ LTP). The said closing price set a momentum for the opening price of the scrip of 7NR for the next trading day (April 11, 2019). Infact, this is evident from the fact that the 1st trade on April 11, 2019 was executed at INR 58/- (INR 1.5/- higher than previous day’s LTP). 99. It is also noted that the entities belonging to these 2 groups (Sub-group 3 [Kolkata based entities] and Gohil group) while trading amongst each other, have cumulatively contributed to the net positive LTP of INR 18.3/-.

However, it is noted that while trading amongst each other, on 19 occasions these entities have executed the 1st trade of the particular trading day and such 19 trades have together resulted in creating net positive LTP of INR 15.2/- (83.06% of net LTP creating while trading amongst each other). 100. The aforesaid illustrations / data show that the connected entities belonging to these 2 groups (Sub-group 3 [Kolkata based entities] and Gohil group) were not only prima facie executing synchronised / structured trades with other entities of these groups above the LTP, but also were executing the 1st trades in the scrip in order to set the momentum in the trading of the scrip. The said pattern of trade adopted by these entities was not seen in an isolated case but was observed to be followed by them in a consistent manner. Matching of trades within the same set of entities especially in a scrip which is not highly liquid (there are instances as noted above where only the connected entities were available on a particular day to execute trades in the scrip) cannot be prima facie termed as normal trading activity.

Therefore, the Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling acts of these entities while trading in the scrip of 7NR prima facie do not appear to be genuine acts of trading with a bonafide intention and rather such a trading behaviour repeatedly observed from the way these entities have dealt in the scrip glaringly indicate that these trades were merely undertaken to prima facie cause artificial upward price movement in the scrip of 7NR in pursuance of a scheme employed in the scrip. SMS Period 101. Once a momentum was generated in the scrip by sustained dealing in the scrip of 7NR so as to maintain the price and volume in the scrip at a desired level, the next leg of the prima facie scheme commenced with the sending of bulk SMSs in the scrip including using the website www.midcapgains.in to give buy recommendations in the scrip. Out of the several SMS headers used to send SMSs related to the scrip of 7NR, it was observed that from the SMS header ID- MGAINS, SMSs were sent to 61,960 mobile numbers during the November 11, 2019 to December 27, 2019 (hereinafter referred to as “SMS Period”).

A few sample SMS texts that were circulated in the said scrip and its prima facie impact on volume and price in the scrip of 7NR, are shown in the table below: Table No. 45 Sl. SMS Sample SMS Text Date of % volume increase from % price increase No. Header SMS previous trading day from previous circulation trading day 1. BT- BUY/ADD More December 5,99,139 shares traded on Weighted Average MGAINS 7NR RETAIL 13, 2019 December 13, 2019 from price on 12-Dec- (540615) For 4,90,076 shares traded on 2019 was INR -INTRA-DAY December 12, 2019 i.e. an 217.55/- and the Target 220+ increase of 22.25 %. scrip touched the -Next Week Target high of INR 220/- 230++ on 13-Dec-2019 i.e. STOCK IS GOING the scrip witnessed UP SAFELY SO BUY a movement of MAXIMUM 1.12% in its price. QUANTITY NOW

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling

FOR FINAL TARGET 500++ 2. BH- BUY/ADD More December 5,73,274 shares traded on Weighted Average MGAINS 7NR RETAIL 23, 2019 December 23, 2019 from price on 20-Dec- (540615) For 4,09,996 shares traded on 2019 was INR -INTRA-DAY December 20, 2019 i.e. an 229.73/- and the Target 234+ increase of 39.82 %. scrip touched the -This Week Target high of INR 250++ 234.25/- on 23- Dec-2019 i.e. the BIG BULL RUN scrip witnessed a STARTED – NON movement of 1.96% STOP TARGET in its price. 500++ COMING SOON SO BUY MAXIMUM

Thus, from the aforesaid table it can be seen that there was a marked increase in the volume of the scrip of 7NR immediately on the next day of sending of the SMS. It is further observed from the records that there has been 966% increase in the volume of the scrip during the SMS period vis-à-vis pre SMS period. The price in the scrip also touched a high of INR 238.5/- during the SMS period as compared to the closing price of the pre-SMS period which was INR 168.55/- i.e., there was a 41.5% spike in the price of the scrip on BSE. The aforesaid figures prima facie accentuates the role played by the bulk SMSs in luring the investors to deal in the scrip. The records reflect that the circulation of bulk SMSs to give buy recommendations was not a solitary instance and was frequently used during the SMS period by using different sender IDs. The same had a noticeable impact on the price and volume movement in the scrip. Apart from sending scrip specific recommendation in favour of the scrip of 7NR, automatic messages were also received from calling on missed call service number. A sample of such SMS text received from calling missed call service number (926667330) is shown below: “Thank You For Joining Us For MULTI-BAGGER Stock 2019. Our Executive Will Call You Soon. Please Check Our 100% Successful PAST PERFORMANCE on www.MidcapGains.in”.

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling

Off Loaders 102. Once the bulk SMSs were sent with buy recommendations in the scrip by the SMS Sender who has been prima facie identified as Mr. Hanif Shekh in the earlier part of this Order, it gave an opportunity to the entities who were connected with the SMS Sender, to exit the scrip by dumping their shares on the investors who were prima facie lured in by the SMSs as well as by seeing the meteoritic rise in the price and volume of the scrip during the SMS period (November 11, 2019 to December 27, 2019). As noted in preceding paragraphs, the average daily volume in the scrip during the SMS period vis-a-vis pre-SMS period increased by 966% on BSE while the price in the scrip opened at INR 169/- and reached a high of INR 239.50/- during SMS period, thereby registering an increase of 41.71% in 1.5 months only (approximately). Such entities who exited the scrip are hereinafter referred to as Off Loaders. 103. The findings of the investigation prima facie show that there are two sets of entities who were the Off Loaders in the scrip of 7NR during the SMS period, namely, the entities belonging to Sub-group 3 and the Gohil Group.

The connection amongst the various entities belonging to the aforesaid respective groups on multiple parameters have already been highlighted in the preceding paragraphs. Further, the findings from analyses of the trade logs as highlighted and illustrated earlier, there have been trades amongst the entities across the said 2 groups which were prima facie executed to manipulate the price and volume in the scrip during pre- SMS period. Mr. Hanif Shekh who is prima facie the SMS sender in the scrip has already been noted to be connected with Sub-group 3 and Gohil group. The maze of inter connections that exist amongst the entities which have been explained in detail through tabular presentations earlier, when considered along with the unusual trading pattern (heavy selling) in the scrip of the 7NR by the Off Loaders including the timing chosen by them to offload their shares, coupled with the fact that some of these Off Loaders were also prima facie involved in artificially raising the price and volume in the scrip it can be prima facie very well inferred that the very act of coming together by the aforesaid entities (Off Loaders) to the market at the same time to sell their shares was in accordance with a pre-conceived scheme employed in the scrip.

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling

104. The profits earned by the Off Loaders by dumping their shares of 7NR as explained above are indicated in the table below: Table No. 46 Profit made by Gohil Group entities Sl Entity Buy Qty Buy Value Sell Qty Sell Value Shares #Acquisi Total Buy Net Profit No Name during IP during IP during IP during IP already tion Value (INR) (A) held Price of (C) before IP Shares (B) (D) (E)= C-A already held (G)=B+F C-G (F) 1. Tejal 107356 23791018 265358 58349100 158002 7470912 31261930 27087170 Amitkumar Khatri 2. Ch andrikab 341484 66704077 509409 99774002 167925 6702307 73406383 26367618 en Maheshbha i Chauhan 3. N itesh P 40647 8954200 166867 36999458 126220 3552615 12506814 24492644 Pavskar 4. N aginbhai 14727 3398951 116827 25871989 102100 2842680 6241631 19630358 Jeshingbhai Maheriya 5. Ch intukum 92980 21330098 194891 44695330 101911 5327163 26657261 18038069 ar Vasudevbh ai Pandya 6. Go vindbhai 312393 60591696 426332 82699516 113939 4728169 65319864 17379651 Natvarlal Chauhan 7. Vijay 35000 7851487 129000 27965938 94000 4586847 12438334 15527604 Rajeshbhai Vasita 8. Ka mleshku 1000 205900 85164 19115442 84164 3724548 3930448 15184994 mar G Solanki 9. Jitendra 1642 347044 52759 11925654 51117 1290484 1637527 10288127 Harjivanbh ai Gohil 10. R avindra 239302 52485288 293316 63375807 54014 4096052 56581340 6794467 Nanalal Raval 11. Dixit 15209 3331341 47504 10458952 32295 542556 3873897 6585055 Nareshbhai Borisa 12. N atvarbhai 38736 8057806 92726 19095094 53990 4740896 12798701 6296392 Patlia 13. Sushma 92165 19355126 139729 29009167 47564 4862377 24217503 4791664 Jasmin Barot 14. M anoharpr 0 0 24105 5195421 24105 947964 947964 4247457 asad Ghanshyam

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling

Sl Entity Buy Qty Buy Value Sell Qty Sell Value Shares #Acquisi Total Buy Net Profit No Name during IP during IP during IP during IP already tion Value (INR) (A) held Price of (C) before IP Shares (B) (D) (E)= C-A already held (G)=B+F C-G (F) bhai Vaishnav 15. M aheshku 5726 1248733 24726 5518738 19000 817583 2066317 3452422 mar Nareshkum ar Purabia Total 1338367 277652765 2568713 540049608 1230346 56233153 333885914 206163692 #Note: For calculation of F (Buy value for shares bought before SMS circulation period), if shares are bought during IP period, average buy price of shares during Pre-SMS period (within IP) is considered for calculating buy value of shares, otherwise if shares are bought before IP period, opening price on the first day of IP is considered as acquisition price for calculating value of those shares. Table No. 47 Profit made by Sub-group 3 (Kolkata based entities) S Entity Buy Qty Buy Value Sell Qty Sell Value Shares #Acquisiti Total Buy Net Profit No Name during IP during IP during IP during IP already on Price of Value (INR) (A) held Shares (C) before already (B) (D) IP (E)= held C-A (F) (G)=B+F C-G 1. Hi ghgro 41963 7984189 179963 35822270 138000 8309250 16293439 19528831 wth Vincom Private Limited 2. S umit 269163 52291607 398163 76787391 129000 9402900 61694507 15092884 Laha 3. Di bakar 581915 117880019 710515 142214211 128600 13904687 131784706 10429505 Laha 4. U jjal 55787 10997178 116887 23102211 61100 4528724 15525902 7576309 Laha 5. Sa njay 112796 21286770 210596 39211707 97800 5825700 27112470 12099238 Dey 6. Su prab 173144 34092486 234394 45803528 61250 10879534 44972020 831508 hat Laha 7. A rpan 277157 54862526 351657 68721701 74500 6852200 61714726 7006975 Das 8. So urav 115504 22703334 157504 30996605 42000 2613000 25316334 5680271 Das 9. Gl oriou 217235 46889315 259235 55127834 42000 7903780 54793095 334739 s

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling

S Entity Buy Qty Buy Value Sell Qty Sell Value Shares #Acquisiti Total Buy Net Profit No Name during IP during IP during IP during IP already on Price of Value (INR) (A) held Shares (C) before already (B) (D) IP (E)= held C-A (F) (G)=B+F C-G Vincom Private Limited 10. M inu 91288 17644268 128688 24855564 37400 3580395 21224663 3630901 Mallick 11. Li nkup 95251 20458681 120251 25124010 25000 2096900 22555581 2568429 Financi al Consult ants Private Limited 12. A run 12050 2164783 35550 6346652 23500 3278245 5443028 903624 Dutta 13. Bu ddha 3500 628775 21500 3879720 18000 1812600 2441375 1438345 deb Laha 14. Pr iyank 3137 577208 15637 2870972 12500 1685850 2263058 607915 ar Laha 15. U ma 255 52109 14212 2586286 13957 1733400 1785509 800777 Dutta 16. T apas 10000 2043000 21950 4231545 11950 1544005 3587005 644540 Laha 17. Su brata 26726 5323584 36726 7171203 10000 1230000 6553584 617619 Laha 18. De bashi 0 0 13900 2408905 13900 2318141 2318141 90764 sh Dutta Total 2086871 417879830 3027328 597262315 940457 89499311 507379141 89883174 #Note: For calculation of F (Buy value for shares bought before SMS circulation period), if shares are bought during IP period, average buy price of shares during Pre-SMS period (within IP) is considered for calculating buy value of shares, otherwise if shares are bought before IP period, opening price on the first day of IP is considered as acquisition price for calculating value of those shares. The Ultimate Beneficiary 105. As noted in the preceding paragraphs of this Order, the prima facie PV Influencers namely, the Gohil Group and Sub-group 3 (Kolkata based entities), who are connected with Mr. Hanif Shekh, were executing prima facie manipulative trades (as discussed in preceding paragraphs) with each other as part of their modus operandi to impact the price and volume in the scrip. Moreover, it has already been factually unearthed that Mr. Hanif Shekh is prima facie the person who was sending bulk SMSs with buy

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling recommendations in favour of the scrip of 7NR and was also managing the website www.midcapgains.in which was used for giving buy recommendations in the scrip. Given the afore-discussed facts and circumstances in the matter, a picture that clearly emerges now is that, prior to the circulation of bulk SMSs in the scrip, entities connected to Mr. Hanif Shekh have prima facie artificially influenced the price and volume in the scrip and thereafter, coinciding with the circulation of bulk SMSs in the scrip which was done by Mr. Hanif Shekh, entities who are directly and / or indirectly connected with Mr. Hanif Shekh, sold their shares and exited the scrip after making substantial profits. In other words, a prima facie scheme was employed while dealing in the scrip wherein, at each leg of the said scheme, entities related to Mr. Hanif Shekh have played a significant role. To elaborate further, in the first leg of the scheme, Gohil Group and Sub-group 3 (Kolkata based entities) dealt in the scrip in a manner to maintain the price and volume in the scrip at a level which would be adequate enough to attract investors to deal in the scrip.

In the next leg, bulk SMSs were circulated to prima facie attract the investors to invest in the scrip which had already been witnessing a sustained rise in the price and volume (due to the trading activities of the PV influencers) and finally, the entities belonging to Gohil Group and Sub-group 3 (Kolkata based entities) taking undue advantage of the rising prices and volumes that was further accelerated by the bulk SMSs, exited the scrip after making a significant amounts of profits. Subsequently, it is noted from the records that the funds (prima facie generated out of sales proceeds by the Off Loaders) were transferred by the aforesaid two groups to Mr. Hanif Shekh connected entities via multiple layers of funds transfers, with a view to camouflage the identity of the SMS sender, Mr. Hanif Shekh and also to avoid the regulatory detection. 106. It may be reiterated here that during the execution of the last leg of the prima facie scheme wherein the funds were transferred by Off Loaders to Mr. Hanif Shekh connected entities, I have already pointed out with various instances in the preceding paragraphs of this Order while considering the dealing in the scrip of MUL, that the entities pertaining to Sub-group 3 were funded by Sub-group 3.A to trade in the scrip and the Sub-group 3 have in turn, transferred funds back to Sub-group 3.A.

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling

Subsequently, Sub-group 3.A through multiple layers of funds transfers, were observed to be transferring funds to Mr. Hanif Shekh. Following the same strategy as adopted in the case of the scrip of MUL, in the scrip of 7NR also, the entities belonging to Sub-group 3 have transferred funds to Mr. Hanif Shekh and / or his connected entities in the same manner through layers of intermediate funds transfers. Thus, it can be prima facie inferred that though the Sub-group 3 entities were dealing in the scrip of 7NR and have off-loaded shares of 7NR during the SMS-period, but in reality, these entities were just a façade put up by Mr. Hanif Shekh to transact in the scrip to his own benefit and therefore, Mr Hanif Sheikh through his connected entities in the Sub-group 3.A was funding the trades of Sub-group 3 entities. Consequently, post exit from the scrip by the Sub-group 3 entities, the funds realised by them from the sales proceeds were transferred by them to Mr. Hanif Shekh or to his connected entities albeit, through multiple layers. In the given facts and circumstances of the matter, prima facie there cannot be any other plausible explanation for the peculiar way in the which the funds have moved back and forth, between Mr. Hanif Shekh connected entities and Sub-group 3 entities (Off Loaders as well as front entities of Mr. Hanif Sheikh).

On the other hand, all the Off Loaders belonging to Gohil Group have without fail, transferred the sales proceeds realised by them post their exit from the scrip, to Mr. Hanif Shekh and / or his connected entities and such transfer of proceeds was found to be not limited to this scrip only, but has taken place in respect of off-loading of another scrip namely, GBL Industries Ltd. (discussed in subsequent paragraphs). The transfer of proceeds by the Off Loaders belonging to Gohil Group post exit from both the above noted scrips, viz: 7NR and GBL Industries Ltd. to Mr. Hanif Shekh and / or his connected entities was through Forex companies. It may be recalled that the details of transfers made by certain entities to Mr. Hanif Shekh and / or his connected entities through Forex companies have been discussed in earlier paragraphs of this Order while discussing the dealings in the scrip of MUL. It is no one’s guess that a genuine investor who trades in the securities market in normal course of dealing in securities, trades to benefit himself. It is rather strange to note here that it is not one, but all the entities belonging to the Gohil group who have exited the scrip, have

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling invariably transferred funds (out of sales proceeds) through multiple layers and mostly using the same set of companies as conduits for such transfers (Sub-group 6) before such funds ultimately reached Mr. Hanif Shekh and / or his connected entities. Under the circumstances, such dubious and illogical conduct as displayed by the Gohil group by transferring their sales proceeds to Mr. Hanif Shekh and / or his connected entities soon after exiting the scrip during the SMS period, prima facie leads to a compelling inference that the Gohil group of entities were mere front entities of Mr. Hanif Shekh. The details of the funds transferred by the Gohil group entities to the Forex companies from their net sales proceeds (for onward transfer to Mr. Hanif Shekh and / or his connected entities) are indicated below: Table No. 48 Sl Net sell Value (in Forex Companies No Entity Name INR) (in INR) 1 Jitendra H Gohil 1,15,78,610 61,36,000 2 Vijay Rajeshbhai Vasita 2,01,14,451 1,27,10,000 3 Chintukumar Vasudevbhai Pandya 2,33,65,232 1,04,80,000 4 Nitesh P Pavskar 2,80,45,258 2,44,80,000 5 Naginbhai Jeshingbhai Maheriya 2,24,73,038 1,67,80,000 6 Natvarbhai Patlia 1,10,37,288 49,00,000 7 Kamleshkumar G Solanki 1,89,09,542 1,28,58,744 8 Tejal Amitkumar Khatri 3,45,58,082 2,61,50,000 9 Chauhan Chandrikaben Maheshbhai 3,30,69,925 91,90,000 10 Chauhan Govindbhai Natvarlal 2,21,07,820 68,45,000 11 Ravindra Nanalal Raval 1,08,90,519 55,00,000 12 Dixit Nareshbhai Borisa 71,27,611 58,98,000 Manoharprasad Ghanshyambhai 51,95,420 13 Vaishnav 15,00,000 14 Maheshkumar Nareshkumar Purabia 42,70,005 35,05,000 15 Sushma Jasmin Barot 96,54,041 41,50,000 Total 26,23,96,842 15,10,82,744 107. In the light of the aforesaid discussion, it is noted that the only common denominator between the Sub-group 3 and the Gohil group is none other than Mr. Hanif Shekh.

Right from the beginning, records show that both the groups are connected with Mr. Hanif Shekh and both the groups have acted as PV Influencers in Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling the scrip. Further, as discussed earlier, Sub-group 3 was funded by Mr. Hanif Shekh, and both Sub-group 3 and the Gohil group have off-loaded their shares in the securities market during the SMS period and post exiting from the scrip, have adopted the same method of transferring of funds (from their sales proceeds) to Mr. Hanif Shekh and / or its connected entities namely, by using Forex companies as intermediate channels and layers so as to obfuscate the funds trail that ultimately led up to Mr Hanif Shekh and his connected entities. Moreover, the very timing of the offloading the shares of the scrips by the said two groups just around the circulation of bulk SMSs whose prima facie sender was none other than Mr. Hanif Shekh, further strengthens the inference that it was Mr. Hanif Shekh who was the mastermind of the scheme and was pulling the strings from behind the scene.

108. To sum up, as one traverses through the multiple layers of funds transfers noted above and the roles played by different groups of connected entities in the aforesaid prima facie scheme, it becomes abundantly clear that the entire scheme was hatched to prima facie benefit the entities belonging to / connected to Mr. Hanif Shekh. Thus, though the entities comprising the Sub-group 3 and Gohil group have on the face of it made substantial profits by exiting from in the scrip as noted at Table Nos. 46 and 47, the Ultimate Beneficiary of such profits was none other than Mr. Hanif Shekh. 109. Now, moving on to the determination of the prima facie violations committed by the entities involved in dealing in the scrip of 7NR as discussed aforesaid, one can appreciate the fact that the prima facie scheme employed in the scrip of 7NR is very similar to the cases of MUL and VFL as the modus operandi followed by the entities is similar and the role played by various entities as PV Influencers, SMS Sender and Ultimate Beneficiary etc. in the scrip of 7NR, is also similar to the facts and circumstances of MUL and VFL.

Consequently, the rationale for holding each entity liable for its role in the prima facie scheme would also be similar. Therefore, for the sake of brevity, the rationale for holding the entities liable for their prima facie violation is not repeated again.

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling

110. The entities who have played the prima facie role of PV Influencers in the scrip and have been mentioned at Table No. 44 have by their apparent actions committed violation of Sections 12A (a), (b) and (c) of SEBI Act and regulations 3 (a), 3 (b), 3 (c), 3(d), 4(1) and 4(2)(a), (b), (e) and (g) of PFUTP Regulations. 111. Next comes, the SMS Sender, Mr. Hanif Shekh who was responsible for sending of bulk SMSs in the scrip of 7NR to mislead and wrongfully entice the gullible to invest in the scrip of 7NR including using the website www.midcapgains.in to give buy recommendations in the scrip. Therefore, for the said prima facie fraudulent action, Mr. Hanif Shekh has violated Sections 12A (a), (b) and (c) of SEBI Act and regulations 3 (a), 3 (b), 3 (c), 3(d), 4(1) and 4(2)(k) and (r) of PFUTP Regulations. Further, as noted in preceding paragraphs, Sambhavanath Traders (Proprietor – Mr. Chandraprakash Valchand Parekh) has prima facie played a decisive role in operationalising the website, www.midcapgains.in without which the prima facie scheme would not have been able to be implemented at its full vigour.

Therefore, the actions of Sambhavanath Traders (Proprietor – Mr. Chandraprakash Valchand Parekh) has prima facie led to the violation of Sections 12A (a), (b) and (c) of SEBI Act and regulations 3 (a), 3 (b), 3 (c), 3(d), 4(1) and 4(2)(k) and (r) of PFUTP Regulations. 112. Moving on to the prima facie violations of the Off Loaders, one can observe that the actions committed by them was to fulfil the objectives of the scheme employed in the scrip and the same would not have been possible without the deceitful efforts / actions of the kingpin of the prima facie scheme, Mr. Hanif Shekh. Therefore, the Off Loaders as mentioned at Table Nos. 46 and 47 along with Mr. Hanif Shekh have prima facie violated Sections 12A (a), (b) and (c) of SEBI Act and regulations 3 (a), 3 (b), 3 (c), 3(d), 4(1) and 4(2)(a) of PFUTP Regulations. 113. It is noted from records that the entities connected to Mr. Hanif Shekh namely, Mr. Kasambhai Shekh, Ms. Hasina Kasambhai Shekh, Robert Resources Ltd., Econo Trade India Ltd., Econo Broking (Erstwhile Bansal Finstock) and Sai Metaltech LLP, the entities mentioned at Table No. 21 and the entities mentioned at Table No. 17 have all prima facie enabled him to encash the benefit of the scheme employed by him in the Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling scrip by facilitating in transferring of funds which were received by them from the other connected entities of Mr. Hanif Shekh namely Sub-groups 2.A, 3 and 3.A who had fraudulently dealt in the scrip pursuant to the prima facie scheme employed in the matter.

Thus, the aforesaid actions of the connected entities of Mr. Hanif Shekh have prima facie led to the violation of Sections 12A (a), (b) and (c) of SEBI Act and regulations 3 (a), 3 (b), 3 (c), 3(d) and 4(1) of PFUTP Regulations. 114. The issue which now merits discussion is who amongst the aforesaid entities, would be prima facie liable for the proceeds generated by the employment of the above discussed scheme in the scrip. From the foregoing discussions, I note that the kingpin, Mr. Hanif Shekh was prima facie controlling and implementing the scheme at its various stages. Not only that, as the facts of the matter suggest, he was also the Ultimate Beneficiary of the prima facie scheme. Therefore, based on the available records, it can be prima facie inferred that Mr. Hanif Shekh and his connected entities namely, Mr. Kasambhai Shekh, Ms. Hasina Kasambhai Shekh, Robert Resources Ltd., Econo Trade India Ltd., Econo Broking (Erstwhile Bansal Finstock) and Sai Metaltech LLP including the relevant entities of Gohil group and those of the Sub-group 3 as mentioned at Table Nos. 46 and 47, are jointly and severally liable for the wrongful gains generated in the scrip by the employment of the prima facie scheme, to the tune of INR 29,60,46,866/-.

GBL Industries Ltd 115. GBL Industries Limited (hereinafter referred to as “GBL/ Company”) is the company operating in the infrastructure sector. GBL got listed on BSE on March 16, 2015. Based on the price and volume movement in the scrip, the trading in the scrip was examined for the period from July 02, 2018 to January 31, 2019 (hereinafter referred to as “Investigation Period – GBL”). It is noted that during the period July 02, 2018 to January 14, 2019, the scrip had opened on BSE at INR 22/- and closed at INR 84.15/- with a high of INR 89.9/-, with an average daily volume of 68,937 shares, while during the period of January 15, 2019 to January 31, 2019, the scrip had opened on BSE at INR 84.15/- and closed at INR 100.25/- with a high of INR 101/-, with an Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling average volume of 6,66,854 shares. The aforesaid figures show that not only the price in the scrip increased by almost 4 times within a span of around 7 months but also there was a massive spurt in the trading volumes of the scrip.

The Price – Volume chart in the scrip for the aforesaid period is depicted below: Figure No. 8

120 1200000

100 1000000

80 800000

60 600000

40 400000

20 200000

0 0 02-Jul-18 02-Aug-18 02-Sep-18 02-Oct-18 02-Nov-18 02-Dec-18 02-Jan-19 TOTAL TRADED QTY CLOSE PRICE

116. The aforesaid Price – Volume chart shows that from July 02, 2018 onwards till the first half of January, 2019, there has been a consistent and gradual increase in both, price and volume of the scrip. However, from the second half of January 2019 till the end of January 2019 there was a huge spike in the price and volume of the scrip. During the Investigation Period pertaining to the scrip of GBL, it is noted that there were hardly any major corporate announcements or any major change in Company’s profit (rather the net profit decreased from INR 0.32 crore in the quarter ending September 2018 to INR 0.13 crore in the quarter ending December 2018) or earnings

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling and instead, the revenue of the Company had decreased from INR 13.96 crore in quarter ending September 2018 to INR 1.97 crore in quarter ending December 2018. The absence of any fundamental change in the operations or financials of the Company has to be seen in conjunction with the bulk SMSs which had started circulating in the scrip with buy recommendations from January 15, 2019 onwards. As noted in the previous discussions in this Order, circulation of bulk SMSs is prima facie the core issue to the scheme that was prima facie employed in the scrip along with the use of the website www.mbstocks.in to give buy recommendations in the scrip. The aforesaid factors were compelling enough to examine the dealings in the scrip during the Investigation Period. Accordingly, for better understanding, the trading in the scrip of GBL has been examined in two phases, one during pre-SMS period (July 02, 2018 to January 14, 2019) and the other during SMS period (January 15, 2019 to January 31, 2019).

PV Influencers 117. It is noted from the records that during pre-SMS period (July 02, 2018 to January 14, 2019), the price and volume in the scrip on BSE had increased significantly, which can be observed from the table below: Table No. 49 Price Volume Date Clos ing % change Date Average % Price Volume change July 02, 2018 21.8 - Pre- SMS Period since 68937 listing (July 02, 2018 - January 14, 2019 ) January 14, 84.15 286.01% SMS Period (January 666854 867.34% 2019 15, 2019 - January 31, 2019)

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling

The 11 Entities Group and Gohil Group 118. It was noted that the following group (collectively referred to as “11 Entities Group”) of connected entities were frequently trading in the scrip of GBL during the pre-SMS period: Table No. 50 Sl. No. Name Connections amongst them 1. Ramu Jomdar Jsoneya Sr. No. 1 to 7 had a common phone number 8511341363. Sr. No. 1, 4 to 2. Patiram Ramkishan 6 and 8 to 10 had a common phone number 8511362441. Sr. No. 1 and 3. Rahul Rameshbhai Mehta 11 had a common phone number 4. Harishkumar Sakariya 8140772210. 5. Preyash Sathvara 6. Mukeshkumar Mavjibhai 7. Praveen Kumar 8 Ankit Jagdishbhai Pithava 9 Dipak Ganpatbhai Sakariya 10 Rekhaben Harishbhai 11 Naresh Mavjibhai Parmar

119. It is noted from the above table that the aforesaid 11 entities (11 Entities Group) are connected with each other which is evident from their sharing of common mobile numbers. For instance, Mr. Ramu Jomdar Jsoneya and Mr. Naresh Mavjibhai Parmar shared common mobile number viz. “8140772210”. Similarly, entities namely Mr. Ramu Jomdar Jsoneya, Mr. Patiram Ramkishan, Mr. Rahul Rameshbhai Mehta, Mr. Harishkumar Sakariya, Mr. Preyash Sathvara, Mr. Mukeshkumar Mavjibhai and Mr. Praveen Kumar shared a common mobile number viz. “8511341363”. It is also observed during investigation that the other set of PV Influencers in the scrip namely, Gohil Group entities are also found to be connected to the afore-listed 11 Entities

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling

Group, through funds transfers. For instance, there was fund transfer between Mr. Ramu Jomdar Jsoneya (part of 11 Entities Group) and Mr. Chintukumar Vasudevbhai Pandya (part of Gohil group) for INR 64 lakh on January 02, 2020. Further, both Mr. Ramu Jomdar Jsoneya and the Gohil group entities have transferred funds to the same set of Forex companies (discussed in subsequent paragraphs). The above noted factual findings prima facie show the strength of their inter se connections and when these findings are seen conjointly with the way the said entities have traded in a concerted manner who are also seen to have traded posing as counterparties to each other’s trades in the said scrip during the said pre-SMS period pertaining to the scrip of GBL (July 02, 2018 to January 14, 2019), it would prima facie demonstrate that the pattern of dealings followed by these entities in the scrip of GBL was part of a premediated plan by virtue of which they were prima facie trading in that peculiar manner. The aforesaid inference is prima facie substantiated by the fact that during the pre-SMS period, it was observed that these 22 connected entities (11 Entities Group and eleven Gohil Group entities) were found to be trading amongst themselves. As already noted in the preceding paragraphs, Gohil Group entities are prima facie connected with Mr. Hanif Shekh who is prima facie the SMS Sender in the scrip of GBL and was also prima facie connected with the 11 Entities’ Group. Thus, the very act of coming together by the aforesaid two motley group of entities to deal in the scrip of GBL during the pre-SMS period in a concerted manner and also by trading amongst each other thereby abusing the trading system of the Stock Exchanges, has to be viewed as an act committed by design and pursuant to a prima facie pre-planned scheme employed in the scrip.

120. Contributions of aforesaid 2 groups i.e., the 11 Entities’ Group and Gohil Group to the price and volume rise in the scrip of GBL during the period of July 02, 2018 to January 14, 2019, are shown below:

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling

Table No. 51 Sl Net Net Net N LTP LTP %contrib Buy % Buy Sell % Sell Total_L o Contri Contri ution to Name Traded Traded Traded Traded TP bution bution net price Qty Qty Qty Qty Contrib as a as a rise ution Buyer Seller 1. Akshay 164594 1.81% 180587 1.98% 0.7 -1.3 -0.6 -0.96% Jitendrakumar Brahambhatt 2. Ankit 93804 1.03% 93804 1.03% 13.15 -3.55 9.6 15.43% Jagdishbhai Pithava 3. Dipak 35531 0.39% 35531 0.39% 1.05 -0.25 0.8 1.29% Ganpatbhai Sakariya 4. Dixit 60700 0.67% 98571 1.08% 2.25 3.15 5.4 8.68% Nareshbhai Borisa 5. Harishkumar 56624 0.62% 56624 0.62% 0.35 -0.45 -0.1 -0.16% Sakariya 6. Jitendra 18150 0.20% 32500 0.36% -0.3 0.45 0.15 0.24% Harjivanbhai Gohil 7. Kamleshkumar 42838 0.47% 57509 0.63% 2.55 0.35 2.9 4.66% G Solanki 8. Kushvah 86311 0.95% 86311 0.95% 2.45 4.3 6.75 10.85% Patiram Ramkishan 9. Maheshkumar 32382 0.36% 36088 0.40% 3.15 2.05 5.2 8.36% Nareshkumar Purabia 10. Manoharprasa 16089 0.18% 83089 0.91% -1.9 6 4.1 6.59% d Ghanshyambha i Vaishnav 11. Mukeshkumar 47489 0.52% 47489 0.52% -9.7 13.2 3.5 5.63% Mavjibhai Parmar 12. Naginbhai 44694 0.49% 25975 0.29% 1.75 0.65 2.4 3.86% Jeshingbhai Maheriya 13. Naresh 165535 1.82% 165535 1.82% -10.9 -17.65 -28.55 -45.90% Mavjibhai Parmar 14. Nitesh P 67080 0.74% 16318 0.18% -1.6 1.5 -0.1 -0.16% Pavskar 15. Prabhavatiben 16370 0.18% 51590 0.57% -0.7 1.2 0.5 0.80% Natvarbhai Patliya 16. Praveen Kumar 65475 0.72% 65475 0.72% 4.85 2.2 7.05 11.33%

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling

Sl Net Net Net N LTP LTP %contrib Buy % Buy Sell % Sell Total_L o Contri Contri ution to Name Traded Traded Traded Traded TP bution bution net price Qty Qty Qty Qty Contrib as a as a rise ution Buyer Seller 17. Preyash 119557 1.31% 119557 1.31% 6.3 -4.95 1.35 2.17% Sathvara 18. Rahul 190132 2.09% 0 0.00% 6.2 0 6.2 9.97% Rameshbhai Mehta 19. Ramu Jomdar 201691 2.22% 201691 2.22% 15.55 -7.5 8.05 12.94% Jsoneya 20. Rekhaben 134990 1.48% 134990 1.48% 0.25 7.15 7.4 11.90% Harishbhai Sakariya 21. Shrenikbhai J 75808 0.83% 78795 0.87% -3.2 -0.2 -3.4 -5.47% Gohil 22. Vijay 93245 1.02% 140670 1.55% 11.15 17.5 28.65 46.06% Rajeshbhai Vasita Total 1829089 20.10% 1808699 19.88% 43.4 23.85 67.25 108.12% Total(within 746393 8.20% 746393 8.20% 28.3 45.50% group) Market total 9099696 100.00% 9099696 100.00% 62.2 62.2 62.2 100.00% 121. As can be seen from the above table, the 11 Entities’ Group alongwith with certain Gohil Group entities have prima facie collectively contributed 20.10% of the market buy volumes and 19.88% of the market sell volumes during the pre-SMS period. Further, by trading amongst each other in unison as one single group in the scrip of GBL, these entities have contributed 8.20% of the total market traded volume during the pre-SMS period. It is also noticed that, the aforesaid connected entities have contributed to the tune of INR 67.25/- (108.12%) to the net price rise in the scrip during the pre-SMS period. The trades of the said connected entities were analysed to determine as to how the said connected entities were actually trying to influence the volume and price in the scrip during the pre-SMS period so as to present the scrip as an attractive investment proposition before the investors in the securities market. Some illustrations in this regard are cited as follows:

121.1. On December 27, 2018, Mr. Preyash Sathvara (part of 11 Entities Group) had placed a sell order (order number 1545881400001811772) for 750 shares of GBL at 13:27:54 hours at INR 74.65/- per share and at the same time i.e. at Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling

13:27:54 hours, Mr. Harishkumar Sakariya (part of 11 Entities Group) placed a buy order (order number 1545881400001811773) for 750 shares at INR 74.65/- per share which resulted in execution of a trade of 750 shares at a price of INR 74.65/- per share. This was the 1586th trade in the scrip of GBL on December 27, 2018. It is noteworthy that the next 3 trades i.e. trades number 1587 to 1589 were executed by these connected entities in a synchronised manner wherein orders containing matching quantities with similar prices were placed in buy and sell sides by the connected entities in quick succession as the difference in time between the placement of respective buy and sell orders was less than 1 second. Details of some such orders are tabulated below:

Table No. 52

Trade Buyer Seller Name Buy Sell Trade Buy Sell Trade Number Name Order Order Time Order Order Qty Time Time Qty Qty Preyash Harishkumar 13:28:02 13:28:02 13:28:02 750 750 750 1587 Sathvara Sakariya Ramu Harishkumar 13:28:17 13:28:17 13:28:17 750 750 750 1588 Jomdar Sakariya Jsoneya Harishku Ramu Jomdar 13:28:24 13:28:24 13:28:24 750 750 750 1589 mar Jsoneya Sakariya

121.2. In a similar manner to the above illustration, on various instances, the connected entities have traded in a synchronised manner wherein matching quantities with similar prices were placed in buy and sell orders by the connected entities and again, the difference in time between the respective buy and sell orders was less than 1 second. Details of some of such instances are tabulated below:

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling

Table No. 53

Trade Date Buyer Name Seller Name Buy Sell Trade Buy Sell Trade Order Order Time Order Order Qty Time Time Qty Qty 09/01/2019 Jsoneya Patiram 13:51:58 13:51:57 13:51:58 1500 1500 1500 Ramu Ramkishan Jomdar Kushvah 09/01/2019 Patiram Preyash 13:52:14 13:52:14 13:52:14 1500 1500 1500 Ramkishan Sathvara Kushvah 27/08/2018 Kushvah Ankit 14:45:01 14:45:01 14:45:01 1250 1250 1250 Patiram Jagdishbhai Ramkishan Pithava 28/08/2018 Ramu Rekhaben 14:33:57 14:33:57 14:33:57 1250 1250 1250 Jomdar Harishbhai Jsoneya Sakariya 29/11/2018 Preyash Ramu 09:29:31 09:29:31 09:29:31 899 899 899 Sathvara Jomdar Jsoneya 17/12/2018 Harishkumar Preyash 13:41:59 13:41:59 13:41:59 1250 1250 1250 Sakariya Sathvara

122. I note from the trade log of the scrip that the aforesaid instances are not the only instances when the PV Influencers have traded in a peculiar pattern as illustrated above. There are multiple such instances during the pre-SMS period when the said connected entities are found to have prima facie influenced the volumes in the scrip by trading in this fashion. It is clarified that the aforesaid method is not the only method employed in the scrip to prima facie create artificial volume in the scrip. Upon examination of the trade log, it was noted that apart from the aforestated strategies adopted by these 22 entities to prima facie impact the volume in the scrip, they have also employed another strategy such as executing only 1 share per trade so as to match one big counter party order within a short span of time. A sample of the said strategy is demonstrated below: 122.1. On December 26, 2018, Mr. Patiram Ramkishan (part of 11 Entities Group) had placed a sell order (order number 1545795000001305118) for 1,500 shares

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling of GBL at 11:27:37 hours at INR 72.75/- per share. Within next 3-15 seconds of the placement of the aforesaid sell order, i.e. between 11:27:40 hours to 11:27:52 hours, Mr. Ramu Jomdar Jsoneya (part of 11 Entities Group) placed 1,500 different buy orders for 1 share each at INR 72.75/- per share which resulted in execution of 1,500 trades (trade number 47 to 1546) in the scrip of GBL within a period of 15 seconds which in normal course of trading could have been executed by placing only one buy order for 1,500 shares. 122.2. On January 09, 2019, Mr. Patiram Ramkishan (part of 11 Entities Group) placed a buy order (order number 1547004600001016103) for 1,000 shares of GBL at 10:12:38 hours at INR 81.15/- per share. Within next 1-4 seconds of the placement of the aforesaid buy order, i.e. between 10:12:39 hours to 10:12:42 hours, Mr. Ramu Jomdar Jsoneya (part of 11 Entities Group) placed 1,000 different sell orders for 1 share each at INR 81.15/- which resulted in execution of 1,000 trades (trade number 30 to 1029) in the scrip of GBL within a period of 4 seconds which in ordinary course of trading could have been executed by placing only one sell order for 1,000 shares. 122.3. Again, on January 09, 2019, Mr. Patiram Ramkishan (part of 11 Entities Group) had placed a buy order (order number 1547004600001819047) for 2,000 shares of GBL at 13:47:46 hours at INR 81.05/-. Within next 2-9 seconds of the aforesaid buy order, i.e. between 13:47:48 hours to 13:47:55 hours, Mr. Ramu Jomdar Jsoneya (part of 11 Entities Group) placed 2,000 different sell orders for 1 share each at INR 81.05/- which resulted in execution of 2,000 trades (trade number 1128 to 3127) in the scrip of GBL within a period of 9 seconds which could have been executed by placing only one sell order of 2,000 shares to match the pending buy order. 123. The aforesaid illustrations of the trades executed by the PV Influencers (Gohil Group and 11 Entities Group) in the scrip of GBL demonstrate the unusual trading pattern followed by the PV Influencers wherein both of the groups viz., Gohil group and 11 Entities Group were regularly trading with each other in a manner that showed

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling that while one set of entities was acting as buyers, the other set of entities was acting as the sellers so as to prima facie artificially influence the price and volume in the scrip. Further, the trades which could have been executed in one or two transactions were broken down into several smaller transactions. By the said act, the entities have not only prima facie made an attempt to artificially inflate the number of trades executed in the scrip on a particular trading day thereby trying to set a false and misleading momentum for enticing the public to trade in the scrip but also, considering the fact that the counter parties to the trades were connected with each other, the beneficial ownership of the shares that were transacted between the connected counterparties belonging to these two groups, always stayed within the group, which again prima facie shows the concerted attempt being made of the PV Influencers during the pre-SMS period to create artificial volume in the scrip. The afore discussed acts of the PV Influencers to artificially influence the volumes and price in the scrip becomes further evident from the fact that out of 9,788 trades executed amongst each other in the scrip of GBL during pre-SMS period, in as many as 7,288 trades (74.45% of the total trades executed amongst the group), these connected entities have dealt in single share in each such trade.

Further, these single share trades were prima facie executed in a synchronised manner which is evident from the fact that out of above noted 7,288 trades, in respect of 6,858 trades, the time difference between placement of buy order and sell order was between 0 to 10 seconds. The very act of placing thousands of single buy / sell orders within a time gap of 0 to 10 seconds, when opposite orders with significant quantities were already available in the system, prima facie establishes the manipulative nature of such trades. Thus, it becomes glaring that the PV Influencers have prima facie tried to influence the volumes in the scrip by sometimes executing structured trades amongst themselves that closely resembled synchronized trades while at other times by executing trades with miniscule quantities of shares and sometimes even by executing purely synchronised trades. The aforesaid abnormal trading pattern repeatedly followed by the PV Influencers cannot simply occur by accident or by coincidence. Hence, I am compelled to make a prima facie observation that there was a prima facie prior

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling meeting of minds amongst the connected entities of the aforesaid two groups to trade in the scrip as per a pre-determined fraudulent plan. Therefore, the trades executed in the scrip by PV Influencers to create artificial volume in the scrip can be said to be prima facie non-genuine trades and were executed on a frequent basis in pursuance of a scheme employed in the scrip. 124. As per the available records, it is noted that the PV Influencers have prima facie created artificial volume to the extent of 19.88% of the total trading volume seen in the scrip during the pre-SMS period out of which 8.20% of such trading volume was created by the trades that were executed by the aforesaid group members amongst each other while the remaining 11.68% of the trading volumes was generated by those trades where at least one of the aforesaid entities was on either side of a trade. Upon further examination of the trading activities of the said connected entities, the extent of their inimical trading behaviour was prima facie examined.

It was observed that although the connected entities had created substantial volumes in the scrip during the aforesaid period, in effect only 0.22% (20.10% - 19.88%) of their traded volume during the said period had resulted in change of beneficial ownership while the remaining 19.88% of their trades was used just to create the prima facie artificial volumes with no change in effective beneficial ownership i.e., the ownership of the shares stayed within the group. 125. It is further noted from the available records that the PV Influencers have not only prima facie created artificial volume in the scrip of GBL but were also prima facie instrumental in creating artificial inflated price in the said scrip. The said connected entities while acting as a group, have contributed INR 28.3/- to the net positive LTP in the scrip of GBL by trading amongst each other in 9,788 trades with a total trading volume of 7,46,393 shares (8.20% of total market volume). Further, out of the aforesaid 9,788 trades, in 9,609 trades (98.17% of total group trades), it is observed that the time difference between placing of buy orders and sell orders was in the range of 0 to 60 seconds only and such trades have resulted in contribution of INR 26.30/- (42.28% of net LTP) to the net positive LTP covering 6,89,061 shares (7.57% of total market volume) that were traded by these 22 entities.

Upon further scrutiny of the Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling trading activities of the PV Influencers, it was noted that out of the above mentioned 9,788 trades, in 8,758 trades (89.47% of total group trades) the time difference between placing of buy orders and sell orders was between 0 to 10 seconds and such trades have resulted in contribution of INR 25.25/- (40.59% of net LTP) to the net positive LTP involving 5,74,570 shares (6.31% of total market volume) that were traded by these 22 entities. Few illustrations showing prima facie synchronised trades in the scrip by the said connected entities are shown herein below: 125.1. On July 02, 2018, Mr. Nitesh P Pavskar (part of Gohil Group) had placed a sell order (order number 1530502200001063082) for 300 shares of GBL at 13:57:40 hours at INR 22.20/- per share (at that time LTP was INR 21.20/-). Subsequent to the aforesaid sell order, at 13:58:17 hours (after 36 seconds of the sell order), Mr. Akshay Jitendrakumar Brahambhatt (part of Gohil Group) had placed a buy order (order number 1530502200001063084) for 5 shares at INR 22.20/- per share which resulted in execution of a trade of 5 shares at a price of INR 22.20/- which was INR 1/- (4.72%) higher than the previous LTP.

125.2. On August 24, 2018, Mr. Ankit Jagdishbhai Pithava (part of 11 Entities Group) had placed a sell order (order number 1535081400001038050) for 777 shares of GBL at 10:22:51 hours at INR 33.50/- (at that time LTP was INR 31.10/). Within the next 2 seconds of the aforesaid sell order, i.e. at 10:22:53 hours, Mr. Ramu Jomdar Jsoneya (part of 11 Entities Group) had placed a buy order (order number 1535081400001038051) for 50 shares at INR 33.50/-which had resulted in execution of trade of 50 shares at a price of INR 33.50/-per share which was INR 2.40/- (7.72%) higher than the previous LTP. 125.3. On August 24, 2018, Mr. Ankit Jagdishbhai Pithava (part of 11 Entities Group) had placed a sell order (order number 1535081400001038120) for 613 shares of GBL at 12:47:28 hours at INR 33.50/- per share (at that time LTP was INR 31.05/). Within next 2 seconds of the aforesaid sell order, i.e. at 12:47:30 hours, Mr. Ramu Jomdar Jsoneya (part of 11 Entities Group) had placed a buy order (order number 1535081400001038121) for 900 shares at INR 33.50/-

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling which resulted in execution of trade of 900 shares at a price of INR 33.50/- per share which was INR 2.45/- (7.89%) higher than the previous LTP. 125.4. On August 27, 2018, 2018, Mr. Patiram Ramkishan (part of 11 Entities Group) had placed a sell order (order number 1535340600001038167) for 999 shares of GBL at 15:11:27 hours at INR 34.95/- per share (at that time LTP was INR 32.30/). Within few microseconds of the aforesaid sell order, i.e. at 15:11:27 hours, Mr. Ankit Jagdishbhai Pithava (part of 11 Entities Group) had placed a buy order (order number 1535340600001038168) for 600 shares at INR 34.95/- per share which resulted in execution of trade of 600 shares at a price of INR 34.95/-which was INR 2.65/- (8.2%) higher than the previous LTP. 126. The aforesaid illustrations, when examined in the light of the fact that approximately 90% of the trades (8,638 trades) within the said group was executed within 10 seconds of placing of buy and sell orders which has not only resulted in net LTP of INR 25.45/- but also constituted approximately 6-7% of the market volume, demonstrate the repeated nature of the transactions that were prima facie synchronised in nature apart from indicating a prior meeting of minds amongst the said entities for executing trades in such patterns prima facie pursuant to a pre-planned scheme employed in the said scrip.

It is observed from the details of the trades executed by the said group that in spite of there being an anonymous electronic trading system on the Stock Exchange platforms the act of matching of such large number of trades between the same connected parties could not have taken place, unless the trading system was being abused by these PV influencers. It is further, pertinent to appreciate that prima facie indulgence in such trading patterns leads to price fluctuations that creates false appearance of trading in the securities market and thereby it tends to mislead the investors. In other words, the dubious act of repeated execution of buy and sell orders within the group, the artificial volume generated therefrom and the proximity of time between the placement of buy orders and sell orders, prima facie smacks of the deceptive behaviour of the PV Influencers to play foul with the market forces for the purpose of increasing the price and the volume and Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling thereby creating an artificial picture of dealing in the scrip of GBL in pursuance of the scheme that was prima facie, employed in the scrip.

127. In addition to the above, it is noted that the members of the 11 Entities Group have also carried out circular trading amongst themselves which have resulted in trading of 6,74,410 shares (7.41% of the total market volume by circular trading). It is pertinent to note that the aforesaid volumes generated by the circular trades constituted 66.97% of the total volumes (10,07,007 shares) traded by these 11 Entities Group as sellers in the scrip of GBL, during the pre-SMS period. The materials available on record show that a large number of circular trades were executed by the members of the 11 Entities Group wherein the shares of GBL were traded amongst themselves and the trades were not allowed to go out of the circle. A circular trade does not result in transfer of beneficial ownership in the scrip and since the said circular trades have been executed on the trading screen of the Stock Exchange, it prima facie shows that such trades could only be executed successfully only after prior meeting of minds and a pre-mediated effort on the part of those connected entities to bypass the anonymous trading system.

It can be therefore prima facie inferred that the members of the 11 Entities Group had executed the aforesaid fictitious circular trades to primarily create a false and misleading appearance of trading in the scrip of GBL thereby to lure the lay investors to jump into the fray. A few of such instances of circular trades executed by the members of the 11 Entities Group are cited below: 127.1. On September 12, 2018, Mr. Ramu Jomdar Jsoneya sold 3,334 shares of GBL to Ms. Rekhaben Harishbhai Sakariya. Then, on the same day, Ms. Rekhaben Harishbhai Sakariya sold 3,334 shares of GBL to Mr. Ankit Jagdishbhai Pithava. Subsequently, on September 12, 2018, Mr. Ankit Jagdishbhai Pithava sold 3,334 shares to Mr. Ramu Jomdar Jsoneya. A diagrammatic representation of the aforesaid illustration is given below:

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling

Figure No. 9

Ramu Jomdar Jsonea

Ankit Rekhaben Jagdishbhai Harishbhai Pithava Sakariya

127.2. On September 27, 2018, Mr. Ramu Jomdar Jsoneya sold 1,275 shares of GBL to Ms. Rekhaben Harishbhai Sakariya, who in turn sold 1,275 shares of GBL to Mr. Ankit Jagdishbhai Pithava. Subsequently, Mr. Ankit Jagdishbhai Pithava sold 1,275 shares of GBL to Mr. Ramu Jomdar Jsoneya. A diagrammatic representation of the aforesaid illustration is presented below:

Figure No. 10

Ramu Jomdar Jsoneya

Ankit Rekhaben Jagdishbhai Harishbhai Pithava Sakariya

SMS Period 128. Once a momentum was generated in the scrip by sustained dealing in the scrip of GBL by adopting various illicit methods/strategies as discussed above including by indulging in synchronised trading as well as circular trades as illustrated above so as to maintain the price and volume in the scrip at a desired level as per the pre-planned

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling scheme, the next move in the prima facie scheme was made with the sending of bulk SMSs in respect of the scrip including using the website www.mbstocks.in to give buy recommendations in the scrip. In the SMS headers related to scrip of GBL, it was observed that approximately about 2.10 crore SMSs were sent from the header MD- MULTIB during the period January 05, 2019 to January 31, 2019 i.e., SMS Period. A sample of such SMS texts circulated in favour of the said scrip and its prima facie impact on volume and price in the scrip of GBL, are shown in the table below: Table No. 54 Sl. SMS Sample SMS Text Date of SMS % volume % price increase No. Header circulation increase from from previous previous trading trading day day 1. MD- Buy GBL IND January 23, 8,04,314 shares Weighted Average MULTIB (539009) intraday 2019 traded on January price on 22-Jan-2019 target 101++. This is 23, 2019 from was INR 90.3/- and 100% safe stock in 5,57,889 shares the scrip touched the this volatile market traded on January high of INR 93/- on so BUY & HOLD for 22, 2019 i.e. 23-Jan-2019 i.e. the mega gains- Final 44.17% increase. scrip witnessed a TGT 200+ coming movement of approx. soon. 3% in its price. Thus, from the aforesaid table it can be seen that there was a marked increase in the volumes of the scrip of GBL immediately on the next day of sending of the SMS. It is further noticed from the records that there has been 867% increase in the volume of the scrip during the SMS period vis-à-vis pre-SMS period. The price in the scrip also touched a high of INR 101/- during the SMS period as compared to the closing price of the pre-SMS period which was INR 84.15/- i.e., there was a 20% spike in the price of the scrip. The aforesaid figures prima facie accentuates the role played by the bulk SMSs in luring the investors to deal in the scrip. The records reflect that the circulation of bulk SMSs and the use of the website to give buy recommendations was not a solitary instance and was frequently used during the SMS period by using different sender IDs. The same had a noticeable impact on the price and volume movement in the scrip.

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling

Off Loaders 129. Once the bulk SMSs were sent in the scrip by the SMS Sender and the aforenamed website was used to give buy recommendations in the scrip by Mr. Hanif Shekh, as already identified in the earlier part of this Order, it gave an opportunity to the entities who were connected with the SMS Sender, to exit the scrip by off-loading their shares on the investors who were prima facie lured in by the SMSs and after witnessing a steady rise in the price and volume of the scrip during the pre-SMS period which got a further boost during the SMS period (January 15, 2019 to January 31, 2019). As noted in preceding paragraphs, the average daily traded volume in the scrip during the SMS period vis-a-vis pre-SMS period increased by 867% while the price in the scrip opened at INR 84.15/- and reached a high of INR 101/-, an approximate increase of 20% during the SMS period. Such entities who exited the scrip are herein after referred to as Off Loaders. 130. The findings of the investigation prima facie indicate that there are two sets of entities who acted as Off Loaders in the scrip of GBL during the SMS period, namely, the entities belonging to Kolkata based Group (Sub-group 3) and Gohil Group. The connection that existed amongst the various entities belonging to the aforesaid two groups on multiple parameters have already been highlighted in the preceding paragraphs of this Order. Mr. Hanif Shekh who is prima facie the SMS sender in the scrip has already been noted to be connected with Sub-group 3 and the Gohil group. The aforesaid maze of overlapping inter se connections amongst the entities which have been noted earlier in this Order, when seen along with the unusual trading pattern (heavy selling) in the scrip of the GBL by the Off Loaders including the timing selected by them to off-load the shares during a common period, coupled with the fact that some of these Off Loaders were also prima facie involved in artificially raising the price and volume in the scrip, it can be prima facie inferred that the sheer act of these entities by coming together to off-load their shares so as to take exit from the scrip with substantial profits was in accordance with a pre-designed prima facie scheme that was employed while dealing in the scrip by the entities.

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling

131. The profits so made by the Off Loaders as discussed above, are indicated in the table below: Table No. 55 Profit made by Kolkata based entities (Sub-group 3) Sl Entity Name Buy Qty Buy Value Sell Qty Sell Value Quantiti #Buy Total_Buy Net Profit N during during SMS during during SMS es value Value (INR) o SMS period SMS period Bought Before period period Before SMS (A) SMS period (B) (C) (D) Period (E)= C-A (F) (G)=B+F C-G 1. Hig hgrowth 169444 16017388 412587 37973502 243143 17963826 33981214 3992288 Vincom Private Limited 2. G lorious 553814 54093743 725814 69957486 172000 350000 54443743 15513742 Vincom Private Limited 3. Ar pan Das 79585 7443650 157385 14258810 77800 5274764 12718413 1540396 4. San jay Dey 0 0 38000 3258000 38000 2487800 2487800 770200 5. L inkup 66736 6357890 211736 19391581 145000 3510450 9868340 9523241 Financial Consultants Private Limited 6. Uj jal Laha 23000 2017100 90000 6484967 67000 4517500 6534600 -49633 7. Bu ddhadeb 263283 24706751 404783 37559203 141500 9246610 33953361 3605842 Laha 8. Aru n Dutta 86125 7890367 195625 17865734 109500 7287500 15177867 2687867 9. Pr iyankar 5000 456605 5000 458250 0 0 456605 1645 Laha Total 1246987 118983494 2240930 207207533 993943 50638450 169621943 37585588 #Note: For calculation of F (Buy value for shares bought before SMS circulation period), if shares are bought during IP period, average buy price of shares during Pre-SMS period (within IP) is considered for calculating buy value of shares, otherwise if shares are bought before IP period, opening price on the first day of IP is considered as acquisition price for calculating value of those shares.

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling

Table No. 56 Profit made by Gohil Group entities (Sub-group 4) Sl Entity Name Buy Buy Sell Qty Sell Value Quantiti #Buy value Total_Buy Net Profit Qty Value during during es Before SMS Value (INR) N during during SMS SMS Bought period o SMS SMS period period Before period period SMS (F) (A) (C) Period (D) (E)= C-A (G)=B+F C-G (B) 1. Shrenikbhai J 0 0 16094 1512274 16094 473133 473133 1039141 Gohil 2. Vijay 0 0 16355 1521808 16355 599009 599009 922799 Rajeshbhai Vasita 3. Nitesh P 0 0 9164 880302 9164 230314 230314 649989 Pavskar 4. Akshay 0 0 9289 887499 9289 343103 343103 544396 Jitendrakumar Brahambhatt 5. Maheshkumar 0 0 8955 858489 8955 328601 328601 529888 Nareshkumar Purabia 6. Naginbhai 0 0 13664 1293382 13664 403624 403624 889758 Jeshingbhai Maheriya 7. Kamleshkumar 0 0 10448 990461 10448 319968 319968 670493 G Solanki 8. Manoharprasa 0 0 9234 884867 9234 359227 359227 525640 d Ghanshyambha i Vaishnav 9. Dixit 0 0 9800 935920 9800 356527 356527 579393 Nareshbhai Borisa Total 0 0 103003 9765002 103003 3413506 3413506 6351497 #Note: For calculation of F (Buy value for shares bought before SMS circulation period), if shares are bought during IP period, average buy price of shares during Pre-SMS period (within IP) is considered for calculating buy value of shares, otherwise if shares are bought before IP period, opening price on the first day of IP is considered as acquisition price for calculating value of those shares. The Ultimate Beneficiary

132. As noted in the preceding paragraphs, prima facie PV Influencers namely, the 11 Entities Group and the Gohil Group (connected with Mr. Hanif Shekh were seen to be executing prima facie manipulative trades (as discussed in preceding paragraphs). It Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling cannot be a mere matter of coincidence that 22 connected entities belonging to the aforesaid two groups were engaged in trading in the scrip of GBL on a regular basis, which was not a highly liquid scrip and by displaying apparent prior meeting of minds, these entities were found to be prima facie adopting the same kinds of strategies to manipulate the price and volume in the scrip. Thus, the very act of these entities coming together to deal in the scrip on the Stock Exchange system, when seen along with their timing of placing orders both on buy and sell sides so as to match trades with each other, also the timing of off-loading of shares in the scrip by the Off Loaders, including, the fact that not only there have been funds transfers between the aforesaid two groups but also both the groups are seen to have transferred money to the same set of Forex companies via which the funds have prima facie ultimately reached Mr. Hanif Shekh and / or his connected entities, all these prima facie unassailable facts cannot be brushed aside as a mere coincidence of events and have to be viewed prima facie as acts that were performed by these entities pursuant to a pre-determined scheme drawn up by the said two groups to deal in the scrip in a coordinated manner to achieve their ill-intentioned objectives.

Moreover, as per facts on records, Mr. Hanif Shekh is undoubtedly prima facie the person who was sending bulk SMSs in the matter and was also the person who was managing the website www.mbstocks.in which was used to give buy recommendations in the scrip. Thus, the picture that emerges from the conspectus of facts, strongly points that prior to circulation of bulk SMSs in the scrip of GBL including buy recommendation in the scrip, the entities connected to Mr. Hanif Shekh have prima facie artificially influenced the price and volume in the scrip and thereafter as soon as the circulation of bulk SMSs containing texts with buy recommendations in favour of the scrip was started by Mr. Hanif Shekh, taking advantage of rising volumes and price movements in the scrip, the entities who are directly and / or indirectly connected with Mr. Hanif Shekh, exited the scrip after making substantial profits. In other words, a prima facie scheme was employed apparently by Mr. Hanif Shekh in collusion with the other participating entities as have been identified to be belonging to different connected groups while dealing in the scrip wherein, in each leg and at each stage of the said scheme, entities related to Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling

Mr. Hanif Shekh have played a significant role. To elaborate further in the first leg of the scheme, the members of the 11 Entities Group and the Gohil Group dealt in the scrip so as to artificially raise and maintain the price and volume in the scrip at a level which would be adequate enough to pose a credible attraction to the investors to deal in the scrip. In the next leg, bulk SMSs were circulated to prima facie further entice the investors to invest in the scrip on the face of the sustained rise in the price and volume in the scrip and finally, taking advantage of the conducive price and volumes that was made possible by the manipulative trades executed on a regular basis by the PV Influencers in the scrip which was further triggered by the bulk SMSs circulated by Mr. Hanif Shekh, the entities belonging to Gohil Group and Sub-group 3 (Kolkata based entities) exited the scrip after making significant profits. 133. To elaborate further on the last leg of the prima facie scheme wherein the funds were transferred by Off Loaders to Mr. Hanif Shekh connected entities, I have already noted in the preceding paragraphs of this Order, while discussing the modus operandi followed in the dealings in the scrip of MUL, that the trading activities of entities belonging to Sub-group 3 were being funded by the entities of Sub-group 3.A and in turn, the entities of Sub-group 3 were transferring funds back to the entities of Sub-group 3.A.

Subsequently, Sub-group 3.A, through multiple layers of conduits, were transferring money to Mr. Hanif Shekh. Similarly, in the scrip of GBL also, I note that the entities comprising the 3.A and few entities of Sub-group 3 have transferred funds to Hanif Shekh and / or his connected entities. Thus, it can be prima facie inferred that though the Sub-group 3 entities were dealing in the scrip of GBL but in reality they were just the front entities of Mr. Hanif Shekh used for the purpose of transacting in the scrip. It is prima facie for this reason that Mr Hanif Shekh was funding their trades prima facie through the entities of Sub-group 3.A. Consequently, post exit from the scrip by the Sub-group 3 entities, funds from the net sales proceeds realised by them were transferred by them to Mr. Hanif Shekh or to his connected entities albeit through multiple layers. In the given facts and circumstances of the matter, prima facie there cannot be any other plausible explanation for the peculiar way in the which funds have been transferred by Sub-group 3 entities to Mr. Hanif Shekh or his

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling connected entities other than to suggest that Mr. Hanif Shekh was using the other group entities as his front for dealing in the scrip of GBL eventually to benefit and enrich himself. I find that all the Off Loaders belonging to the Gohil Group have also without fail, transferred proceeds post their exit from the scrip to Mr. Hanif Shekh and / or his connected entities and such transfer of proceeds is not limited to this scrip of GBL only but has also taken place in another scrip namely 7NR (already discussed in preceding paragraphs). I note that the transfer of proceeds by the Off Loaders belonging to Gohil Group post their respective exit from both the scrips, 7NR and GBL to Mr. Hanif Shekh and / or his connected entities, was through different Forex companies (the details of transfer through Forex companies have been discussed in the preceding paragraphs of this Order while dealing the scrip of MUL). It is also observed that all the entities belonging to Gohil group who have exited the scrip, have transferred funds through multiple layers and using the same set of companies (Sub-group 6) so that those funds ultimately reach Mr. Hanif Shekh and / or his connected entities. Such an abnormal behaviour on the part of the Gohil group entities who have sold their shares of GBL during the SMS period with profits and yet have transferred their sales proceeds to Mr Hanif Shekh and his connected entities prima facie leads to an inescapable inference that they were merely serving as front entities of Mr. Hanif Shekh for dealing in the scrip as part of the scheme that was employed in the said scrip.

134. To sum up, as one deeply looks through the multiple layers of transactions and funds transfers that were entered into before the funds ultimately reached Mr. Hanif Shekh and/or his connected entities as part of the aforesaid prima facie scheme, it becomes more clear as to why the entire scheme was hatched, which as the facts of the case strongly point out, was nothing but to prima facie benefit the entities belonging to / connected to Mr. Hanif Shekh. Thus, though the entities belonging to the Sub-group 3 and Gohil group have made substantial profit in the scrip as noted at Table Nos. 51 and 56, the Ultimate Beneficiary was prima facie, none other than Mr. Hanif Shekh.

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling

135. Now moving on to the determination of the prima facie violations committed by the entities involved in the scrip of GBL, the facts of the matter suggest that the prima facie scheme employed in the scrip of GBL is similar to the schemes employed in the scrips of MUL, VFL and 7NR, the modus operandi followed by the entities who are parties to the said scheme is similar in all the above noted scrips and the roles played by different entities as PV Influencers, SMS Sender and Ultimate Beneficiary, are also similar in all the afore-noted scrips. Consequently, the rationale behind holding each entity liable for their role in the prima facie scheme would also be similar. Therefore, for the sake of brevity, the rationale for holding different entities liable for their prima facie violations is not repeated once again.

136. Keeping the aforesaid facts and deliberations in view, the entities who have played the prima facie role of PV Influencers in the scrip and have been listed out at Table No. 51 have by their actions prima facie committed the violation of Sections 12A (a), (b) and (c) of SEBI Act and regulations 3 (a), 3 (b), 3 (c), 3(d), 4(1) and 4(2)(a), (b), (e) and (g) of PFUTP Regulations. Further, the entities mentioned at Table No. 50 who have executed the circular trades in the scrip as pointed out above in this Order, have also violated regulation 4(2) (n) of PFUTP Regulations.

137. Next comes, the SMS Sender, Mr. Hanif Shekh who was responsible for sending those false and misleading bulk SMSs inducing the investors to deal in the scrip of GBL including using the website www.mbstocks.in to give buy recommendations in the scrip. Therefore, for the said fraudulent acts on his part Mr. Hanif Shekh has prima facie violated Sections 12A (a), (b) and (c) of SEBI Act and regulations 3 (a), 3 (b), 3 (c), 3(d), 4(1) and 4(2)(k) and (r) of PFUTP Regulations.

138. Moving on to the prima facie violations committed by the Off Loaders, I find the action of the Off Loaders was nothing but encashing the benefits caused by the consequence of the previous legs of the prima facie scheme. In other words, the action of the Off Loaders represents the fruition of the scheme employed in the scrip and the same would not have been possible without the efforts / actions of the kingpin of the prima facie scheme, Mr. Hanif Shekh who has also been identified as the Ultimate

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling

Beneficiary of the entire scheme. Therefore, the Off Loaders as mentioned at Table Nos. 55 and 56 along with Mr. Hanif Shekh have prima facie violated Sections 12A (a), (b) and (c) of SEBI Act and regulations 3 (a), 3 (b), 3 (c), 3(d), 4(1) and 4(2)(a) of PFUTP Regulations.

139. It is noted from the records that the entities connected to Mr. Hanif Shekh namely, Mr. Kasambhai Shekh, Ms. Hasina Kasambhai Shekh, Robert Resources Ltd., Econo Trade India Ltd., Econo Broking (Erstwhile Bansal Finstock) and Sai Metaltech LLP, the entities mentioned at Table No. 21 and also the entities mentioned at Table No. 17 have prima facie enabled him to encash the benefit of the scheme employed by him in the scrip and have facilitated in transferring of funds which were received by them from the other connected entities of Mr. Hanif Shekh namely Sub-groups 2.A, 3 and 3.A, who had dealt in the scrip pursuant to the prima facie scheme employed in the matter. Thus, the aforesaid actions on the part of the connected entities of Mr. Hanif Shekh have prima facie led to the violation of Sections 12A (a), (b) and (c) of SEBI Act and regulations 3 (a), 3 (b), 3 (c), 3(d) and 4(1) of PFUTP Regulations.

140. The issue which now merits discussion is who amongst the aforesaid entities, would be prima facie be liable for the proceeds unlawfully generated by the employment of the prima facie scheme in the scrip. From the above discussion, I note that the kingpin, Mr. Hanif Shekh had prima facie masterminded and implemented the scheme at various stages and in every leg of implementation. Not only that, he was also found to be the Ultimate Beneficiary of the prima facie scheme. Therefore, based on the available records, it is prima facie inferred that Mr. Hanif Shekh and his connected entities namely Mr. Kasambhai Shekh, Ms. Hasina Kasambhai Shekh, Robert Resources Ltd., Econo Trade India Ltd., Econo Broking (Erstwhile Bansal Finstock) and Sai Metaltech LLP including the relevant entities of Sub-group 3 and Gohil group as mentioned at Table Nos. 55 and 56, are jointly and severally liable for the wrongful gains generated in the scrip by the employment of the prima facie scheme, to the tune of INR 4,39,37,085/-.

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling

Darjeeling Ropeway Company Ltd.

141. Darjeeling Ropeway Company Limited (hereinafter referred to as “Darjeeling/ Company”) is engaged in construction, purchase, leasing and repairs of ropeways, tramways and other forms of electrical transport projects. Darjeeling got listed on BSE on March 28, 2016. Based on the price and volume movement in the scrip, the trading in the scrip was examined for the period of April 02, 2018 to December 27, 2019 (hereinafter referred to as “Investigation Period – Darjeeling”). It is noted that during the period of April 02, 2018 to December 22, 2019, the scrip had opened on BSE at INR 11.9/- and closed at INR 103/- with a high of INR 112.40/-, with an average volume of 26,098 shares, while during the period of December 23, 2019 to December 27, 2019, the scrip had opened on BSE at INR 102.10/- and closed at INR 64.65/- with a high of INR 103.50/-, with an average daily volume of 3,68,210 shares. The aforesaid figures show that not only the price in the scrip increased by almost 8.5 times but also there was a vast spurt in the volume of the scrip during the investigation period pertaining to Darjeeling. The Price – Volume chart in the scrip as noticed during the aforesaid period is depicted below: Figure No. 10

Darjeeliing Ropeway Company Ltd 120 2500000 100 2000000 80 1500000 60 1000000 40 20 500000 0 0

No.of Shares Close Price

142. During the investigation period of Darjeeling, it is noted that there were hardly any major corporate announcements or any major change in Company’s profit (net profit marginally increased by INR 0.02 crore in quarter ending September 2019 as Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling compared to quarter ending June 2019) or earnings (revenues marginally increased by INR 0.4 crore quarter ending September 2019 as compared to quarter ending June 2019). The absence of any fundamental change in the operations or financials of the Company has to be seen in association with the bulk SMSs which had started circulating pertaining to the scrip with buy recommendations from December 23, 2019 onwards including the buy recommendations which was given in the scrip using the website, www.midcapgains.in. As noted, while discussing matters pertaining to the other scrips in the foregoing sections of this Order, circulation of bulk SMSs was prima facie the central issue to the scheme that was prima facie employed in the scrip during the investigation period. The aforesaid preliminary observations were compelling enough to examine the dealings in the scrip in detail, during the investigation period of Darjeeling. Accordingly, the trading in the scrip has been examined in two phases, one during pre-SMS period (April 02, 2018 to December 22, 2019) and the other during the SMS period (December 23, 2019 to December 27, 2019). PV Influencers 143. It is noted from the records that during pre-SMS period (April 02, 2018 to December 22, 2019), the price and volume in the scrip had increased significantly. The same is tabulated below:

Table No. 57 Price Volume Month Closing % change from Daily trading volume % change Price closing price on listing day 02-April- - 31 - 18 13 22-Dec-19 103 692% 136955 441690%

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling

Darjeeling Group

144. It was noted that the following group (collectively referred to as “Darjeeling Group”) of 15 connected entities were frequently trading in the scrip of Darjeeling during the pre-SMS period:

Table No. 58 Sl No Name Connection between the Entities 1. Aakash Dilip Doshi 1. Son of CFO of the Company – Dilip Doshi. According to submission of Aakash Doshi his father has diamond business 2. Rajvi Naresh Shah and knew the MD and Promoter of the Company, Himanshu Shah through religious congregation. 2. S No. 2 is wife of S No.1. According to her statement, her account is operated by Aakash Doshi. 3. Ramnaresh 3. S No. 4 to 7 are part of same family. According to submission Dashadeen Nirmal of Bhavin Shah, he operates all trading and bank accounts of his father – Arvind Shah, mother- Bharati Shah and wife 4. Arvind Shantilal Shah Rupal Shah. 5. Yash Manish Mehta 4. S No. 5 is nephew of Bhavin Shah and grand-son of S No. 4 and S No. 7. 6. Rupal Bhavin Shah 5. There are multiple funds transactions between S No. 3 and S 7. Bharati Arvind Shah No. 1,4,5,6. Also, there are multiple e-mail communications between S No. 3 and S No. 4,6. 8. Dhavani Jayantkumar 5. Received funds from Entity at S No. 6. Shah 9. Kruti Kevin Kapadia 6. Ms. Kruti Kevin Kapadia received funds from Entity at S No. 6. 10. Shashikant C Kapadia 7. Entity No. 9 and 10 have the same address i.e. “A3 8 Amrapali Tower, Nava Sharda Mandir Road, Paldi, Ahmedabad, Gujarat – 380007” and are family members i.e. Kruti Kevin Kapadia is Daughter-in-law of Shashikant Kapadia. According to submission of Aakash Dilip Doshi, his payment to Shashikant Kapadia was done actually to his friend Kevin Kapadia. Kevin Kapadia is husband of Kruti Kapadia and son of Shashikant Kapadia. In response to the summons issued for statement

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling

Sl No Name Connection between the Entities recording, Kruti Kapadia requested to advance the date as her husband Kevin Kapadia was not available. It points to the fact that Kevin Kapadia was acting in concert/on behalf of Kruti Kapadia and Shashikant Kapadia. 11. Ankur Suresh Mehta 8. Received funds from Entity No. 10. 9. Off-market transfers /Loan agreement with Entity at S No. 9 12. Bhashit Deepak Shah 10. Received funds from Entity No. 10. 13. Mehul Hasmukh Shah 11. Entity at S No. 13 and S No. 14 have common address. 14. Vidhi Mehul Shah 12. Entity at S No. 13 and S No. 14 received funds from Entity at S No. 10. 15. Himanshu Shah 13. Promoter and MD of the company Darjeeling Ropeway Company Ltd.

145. It is noted from the above table that the aforesaid 15 entities (Darjeeling Group) are connected with each other either by way of common addresses or having multiple fund transactions amongst themselves or through email communications or are part of the same family or off market transfers or being related to Darjeeling. For instance, Mr. Aakash Dilip Doshi is the son of CFO of Darjeeling i.e. Mr. Dilip Doshi and as per his (Mr. Aakash Dilip Doshi) deposition made before SEBI on March 01, 2023, Mr. Dilip Doshi knows Mr. Himanshu Shah (Promoter and MD of Darjeeling). Further, Ms. Rajvi Naresh Shah is the wife of Mr. Aakash Dilip Doshi. Similarly, Mr. Arvind Shantilal Shah and Ms. Bharati Arvind Shah are parents of Mr. Bhavin Shah. It is also noted that Ms. Rupal Bhavin Shah is the wife of Mr. Bhavin Shah. Regarding funds transactions, it is observed that Mr. Ankur Suresh Mehta, Mr. Bhashit Deepak Shah, Mr. Mehul Hasmukh Shah and Ms. Vidhi Mehul Shah have received funds from Mr. Shashikant Chinubhai Kapadia. It is further noted that Mr. Mehul Hasmukh Shah and Ms. Vidhi Mehul Shah are husband and wife and both have received funds from Mr. Shashikant Chinubhai Kapadia. Similarly, Ms. Kruti Kevin Kapadia and Mr. Shashikant Chinubhai Kapadia shared relationship of daughter-in-law and father-in-law respectively. The aforesaid illustrations prima facie shows the closeness of their inter se connections and when

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling these connections are seen along with the peculiar and abnormal manner in which the said entities have traded in a concerted manner and are also seen to have traded posing as counterparties to each other’s trades in the scrip of Darjeeling during the pre-SMS period (April 02, 2018 to December 22, 2019), the same would prima facie indicate that their dealings in the scrip of Darjeeling was not in ordinary course of dealings in securities but was done as part of a premediated plan. Under the circumstances, the very act of these connected entities coming together to deal in the scrip of Darjeeling during the pre-SMS period in a concerted manner has to be viewed as an act that was performed under a pre conceived design and pursuant to a prima facie scheme employed in the scrip, then by any genuine objective to trade in the scrip in normal course of trading in the securities market. 146. The contribution by the members of the aforesaid group i.e., Darjeeling group entities to the price and volume rise in the scrip of Darjeeling by way of their trading during the period from April 02, 2018 to December 22, 2019 along with Sub-groups 2 and 3 (prima facie Mr. Hanif Shekh connected entities), is shown below: Table No. 59 Entity Name Buy % Buy to Sell %Sell to Net Buy Net Total %contrib Quantity total Quantity total LTP Sell Net ution to Market Market LTP LTP net price Buy Sell rise Volume Volume Arvind 450481 4.07% 607699 5.49% -19.8 -15.6 -35.4 -39.55% Shantilal Shah Shashikant C 815533 7.37% 846568 7.65% 229.71 - 202.37 226.09% Kapadia 27.34 Himanshu 10925 0.10% 744723 6.73% -3.6 - -23.25 -25.97% Shah 19.65 Ramnaresh 237112 2.14% 193385 1.75% -62.4 27.25 -35.15 -39.27% Dashadeen Nirmal Aakash Dilip 73206 0.66% 271202 2.45% 9.9 -4.12 5.78 6.46% Doshi Dhavani 126192 1.14% 69036 0.62% -1.9 1.55 -0.35 -0.39% Jayantkumar Shah Ankur Suresh 55863 0.50% 92443 0.84% 26.2 -11.2 15 16.76% Mehta

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling

Entity Name Buy % Buy to Sell %Sell to Net Buy Net Total %contrib Quantity total Quantity total LTP Sell Net ution to Market Market LTP LTP net price Buy Sell rise Volume Volume Mehul 195590 1.77% 102864 0.93% -41.55 14.9 -26.65 -29.77% Hasmukh Shah Bharati 233085 2.11% 220473 1.99% -15.2 21 5.8 6.48% Arvind Shah Vidhi Mehul 25000 0.23% 0 0.00% -0.25 0 -0.25 -0.28% Shah Rupal Bhavin 17932 0.16% 9721 0.09% -0.45 0.65 0.2 0.22% Shah Kruti Kevin 617834 5.58% 516069 4.66% 50.75 -21.9 28.85 32.23% Kapadia Rajvi Naresh 9000 0.08% 9500 0.09% 0.9 -0.75 0.15 0.17% Shah Bhashit 127679 1.15% 119350 1.08% -0.4 2.5 2.1 2.35% Deepak Shah Yash Manish 120719 1.09% 84739 0.77% -34.85 10.15 -24.7 -27.59% Mehta Total (A) 3116151 28.16% 3887772 35.13% 137.06 - 114.5 127.92% 22.5 6 Sahilkumar 7000 0.06% 0 0.00% 0 0 0 0.00% Amrutbhai Vaghela Ravi 5833 0.05% 0 0.00% 0 0 0 0.00% Kannadasan Adidravid Pritiben 7340 0.07% 0 0.00% 0 0 0 0.00% Popatbhai Parmar Manishkumar 5500 0.05% 0 0.00% 0.65 0 0.65 0.73% Rajput Chiragkumar 4532 0.04% 0 0.00% 0 0 0 0.00% Makwana Makwana 4286 0.04% 0 0.00% 0 0 0 0.00% Madhuben Lilaben 5939 0.05% 0 0.00% 0 0 0 0.00% Popatbhai Parmar Popatbhai 3637 0.03% 0 0.00% 0 0 0 0.00% Ramjibhai Parmar 8594 0.08% 0 0.00% -0.05 0 -0.05 -0.06% Hina Barot Dipika 4540 0.04% 0 0.00% 0 0 0 0.00% Popatbhai Parmar Shahrukhkha 4600 0.04% 0 0.00% 0 0 0 0.00% n Pathan

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling

Entity Name Buy % Buy to Sell %Sell to Net Buy Net Total %contrib Quantity total Quantity total LTP Sell Net ution to Market Market LTP LTP net price Buy Sell rise Volume Volume Karan 1000 0.01% 0 0.00% 0 0 0 0.00% Birjubhai Sanghvi Krusha 1600 0.01% 0 0.00% -0.55 0 -0.55 -0.61% Birjukumar Sanghvi Fuldeep 1000 0.01% 0 0.00% -0.25 0 -0.25 -0.28% Popatbhai Sehgal 5533 0.05% 0 0.00% 0 0 0 0.00% Keval Savant 70934 0.64% 0 0.00% -0.2 0 -0.2 -0.22% Total(B) Highgrowth 62500 0.56% 0 0.00% -0.2 0 -0.2 -0.22% Vincom Private Limited Linkup 66580 0.60% 4600 0.04% -0.55 -1.5 -2.05 -2.29% Financial Consultants Private Limited Glorious 12988 0.12% 0 0.00% -0.1 0 -0.1 -0.11% Vincom Pvt. Ltd. 28500 0.26% 0 0.00% 0.95 0 0.95 1.06% Dibakar Laha 9150 0.08% 630 0.01% 0.5 0.25 0.75 0.84% Tapas Laha 1500 0.01% 0 0.00% -0.35 0 -0.35 -0.39% Subrata Laha 15700 0.14% 140 0.00% -0.45 0.05 -0.4 -0.45% Arun Laha Suprabhat 34960 0.32% 27160 0.25% 0.25 1.45 1.7 1.90% Laha 11393 0.10% 390 0.00% -2.9 0 -2.9 -3.24% Ujjal Laha 13050 0.12% 7000 0.06% -0.65 -0.6 -1.25 -1.40% Sumit Laha 1500 0.01% 0 0.00% -0.35 0 -0.35 -0.39% Sanjay Dey 30468 0.28% 11011 0.10% -3.2 -5.6 -8.8 -9.83% Arpan Das 15550 0.14% 14000 0.13% -5.05 -1.8 -6.85 -7.65% Uma Dutta Debashish 19800 0.18% 0 0.00% 0.2 0 0.2 0.22% Dutta 30578 0.28% 20050 0.18% -0.6 6.05 5.45 6.09% Minu Mallick 354217 3.20% 84981 0.77% -12.5 -1.7 -14.2 -15.86% Total ( C ) 3541302 32.00% 3972753 35.90% 124.36 - 100.1 111.83% Total (A+B+C) 24. 26 Total(Within 1432725 12.95% 1432725 1432725 12.95% -21.87 -24.43% Group) 11065900 100.00% 11065900 100.00% 89.51 Market Total

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling

147. As can be seen from the above table, the Darjeeling group entities have prima facie collectively contributed 32% of the market buy volumes and 35.90% of the market sell volume during the pre-SMS period along with Sub-groups 2 and 3. Further, by trading amongst each other by posing counterparties to each other’s trade orders, these entities have contributed 12.95% of the total market traded volumes of the scrip during the pre-SMS period. It is also noticed that the aforesaid connected entities have contributed to the tune of INR 100.10/- (111.83%) to the net price rise of INR 89.51/-seen in the scrip of Darjeeling during the pre-SMS period. In other words, though the impact of the trades of the PV Influencers on the price of the scrip was INR 100.10/- (net basis) but some of the impact of the trades of PV Influencers was also absorbed by the presence of other investors in the securities market, resulting in an overall impact of INR 89.51/- on the price of the scrip of Darjeeling during the pre-SMS period. The trades of the said connected entities were further analysed to determine as to how the said connected entities were trying to influence the volumes and price in the scrip during the pre-SMS period so as to present the scrip as an attractive proposition before the investors in the securities market. Some illustrations of such artificial trades executed by these connected entities are as follows: 147.1. On June 13, 2018, Mr. Shashikant Chinubhai Kapadia had placed a sell order (order number 1528860600002304097) for 13,000 shares at the price of INR 33.50/- per share at 15:28:35 hours and after two seconds of the placement of the aforementioned sell order i.e. at 15:28:37 hours, a buy order (order number 1528860600002304098) was placed by Ms. Kruti Kevin Kapadia for 13,000 shares at a price of INR 33.50/-, resulting into execution of trade of 13,000 shares in the scrip of Darjeeling. 147.2. On April 12, 2019, Mr. Arvind Shantilal Shah had placed a sell order (order number 1555558200002610048) for 10,000 shares at the price of INR 92/- per share at 14:41:14 hours and after one second of the placement of the aforementioned sell order i.e. at 14:41:14 hours, a buy order (order number 555558200002610049) was placed by Ms. Kruti Kevin Kapadia for 10,000

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling shares at price of INR 92/-, resulting into execution of trade of 10,000 shares in the scrip of Darjeeling. 147.3. On June 21, 2019, Ms. Bharati Arvind Shah had placed a sell order (order number 1561087800002316060) for 15,000 shares at the price of INR 94.40/-at 09:59:28 hours, which was subsequently modified by the entity to INR 97/- at 10:21:39 hours and after one second of the modification of the said sell order i.e. at 10:21:40 hours, a buy order (order number 1561087800002316066) was placed by Mr. Shashikant Chinubhai Kapadia for 15,000 shares at price of INR 97/-, resulting into execution of trade of 15,000 shares in the scrip of Darjeeling. The aforesaid trade apart from contributing to the trading volume by 15,000 shares also resulted in contributing to the positive LTP by INR 0.85/- (0.88% of LTP). 147.4. On April 12, 2019, Ms. Kruti Kevin Kapadia (part of Darjeeling Group) had placed a sell order (order number 1555039800002597030) for 3,181 shares at a price of INR 93/- per share (previous day’s LTP was INR 91.6/-) at 09:28:47 hours and after five seconds of the placement of the aforementioned sell order i.e. at 09:28:52 hours, a buy order (order number 1555039800002597031) was placed by Mr. Shashikant Chinubhai Kapadia for 3,181 shares at a price of INR 93/-, resulting into execution of trade of 3,181 shares in the scrip of Darjeeling. The aforesaid trade, apart from contributing to the trading volume by 3,181 shares has also resulted in contributing to the positive LTP by INR 1.40/- (1.53% of LTP). It is also pertinent to note that this was the 1st trade of the day which also set the momentum for a positive movement in the price of the scrip on that particular day. It is noted that the next two trades (2nd and 3rd trades) were executed at higher prices i.e. at INR 93.05/- and INR 93.10/- per share. 148. It is also noted from the above cited illustrations and from the trade log of the scrip that while trading amongst each other, these entities (Darjeeling Group) have traded in close proximity of time inter se between them. It is noted from the trade log that out of 570 trades executed amongst each other by these 15 entities (Darjeeling Group), in Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling

178 trades, the time difference between placing of buy order and sell order was within 0 seconds to 60 seconds. It is worthwhile to mention here that in the aforementioned prima facie 178 synchronised trades, these entities have contributed to trading volume of 6,16,259 shares (5.56% of total trading volume and 55.10% of the total number of shares traded amongst the Darjeeling group during the pre-SMS period). It is noted from the trade log that out of 570 trades executed amongst each other by these 15 entities (Darjeeling Group), in 98 trades, the time difference between placing of buy order and sell order was within 0 second to 10 seconds. It is worthwhile to mention here that in the aforementioned 98 synchronised trades, these entities have contributed to trading volume of 4,70,046 shares (4.24% of total trading volume and 42.02% of total number of shares traded amongst the Darjeeling group during the pre-SMS period). By the said act, the entities have not only prima facie made an attempt to artificially inflate the volume in the scrip on a particular trading day thereby trying to set the momentum for the trading in the scrip but considering the fact that the counter parties to the trades were connected with each other, the beneficial ownership of the shares that were traded by these connected entities amongst each other practically stayed within the group, which prima facie shows that these trades executed by the members of the Darjeeling group were nothing but concerted attempts on the part of the PV Influencers (Darjeeling group) to create artificial volume in the scrip.

It is clarified that the aforesaid strategy of executing prima facie synchronised trades may not be the only method adopted by the Darjeeling group of entities to manipulate the volume in the scrip but it was the predominant method adopted by them. 149. As noted above, the Darjeeling group of entities were also executing prima facie synchronised trades above the LTP and were also executing first trades of the day above the previous day’s closing price. The said act of the entities is not an isolated case but was being committed in a consistent manner over many such trades. Matching of trades within the same set of entities on a regular basis that too within a time difference of few seconds, especially in a scrip which was not highly liquid, prima facie leads to an inference that the principle of anonymity of counter parties while

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling dealing in any scrip, which is one of the hallmarks of trading on a Stock Exchange platform, has been subverted by these connected entities as they were prima facie trading in an unusual manner apparently pursuant to their pre-determined plan and prior meeting of minds. The trading practices followed by the PV Influencers to influence the volume and price in the scrip becomes further glaring from the fact that the entities were placing their buy and sell orders for identical quantities and price so as to ensure that their orders match with each other. Therefore, the acts of these entities while trading in the scrip of Darjeeling prima facie does not appears to be genuine trades executed with bonafide intention in due course of trading in the scrip and rather were being executed to prima facie cause artificial upward movement in the volumes and price of the scrip in pursuance of the scheme employed in the scrip. It is further observed that the aforesaid strategy of executing prima facie synchronised trades may not be the only method adopted by the Darjeeling group of entities to manipulate the volume in the scrip but was the predominant strategy adopted by them.

150. In addition to the Darjeeling group of entities, it is noted that entities belonging to Sub-group 2 and Sub-group 3 were also trying to influence the volume and price in the scrip during the pre-SMS period so as to give a misleading presentation of the scrip to other investors as an attractive proposition for investment in the securities market. Illustrations of some such trades are presented as follows: 150.1. On July 23, 2019, Linkup Financial Consultants Private Limited (part of Sub-group 3) had placed a buy order (order number 1563852600002368126) for 11,000 shares at the price of INR 92.10/- per share at 12:55:06 hours and after two seconds of the placement of the aforementioned buy order i.e. at 12:55:08 hours, a sell order (order number 1563852600002368127) was placed by Mr. Suprabhat Laha (part of Sub-group 3) for 11,000 shares at a price of INR 92.10/- per share, resulting in the execution of trade for 11,000 shares in the scrip of Darjeeling. It is pertinent to mention here that the aforesaid trade apart from contributing to the trading volume by 11,000 shares also resulted in contributing to the positive LTP by INR 0.10/- (0.11% of LTP).

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling

150.2. On September 24, 2019, Ms. Uma Dutta (part of Sub-group 3) had placed a sell order (order number 1569295800002358085) for 6,950 shares at the price of INR 80.10/- per share at 13:44:36 hours and almost at the same time i.e. at 13:44:36 hours, a buy order (order number 1569295800002358086) was placed by Mr. Suprabhat Laha (part of Sub-group 3) for 6,950 shares at a price of INR 80.10/-, resulting in the execution of trade for 6,950 shares in the scrip of Darjeeling. It is pertinent to mention here that the aforesaid trade, apart from contributing to the trading volume by 6,950 shares also resulted in contributing to the positive LTP by INR 0.10/- (0.13% of LTP). 150.3. On May 27, 2019, Mr. Sumit Laha, Ms. Minu Mallick, Mr. Arpan Das and Mr. Suprabhat Laha (all part of Sub-group 3) placed seven different buy orders for a cumulative quantity of 38,000 shares, at the price of INR 90/- per share between 15:02:55 hours to 15:13:23 hours. The aforesaid seven buy orders were matched with 4 different sell orders placed by Mr. Himanshu Ramniklal Shah between 15:12:17 hours to 15:14:48 hours for a cumulative quantity of 40,000 shares at a price of INR 90/- per share, resulting in the execution of 10 trades for a cumulative quantity of 33,510 shares in the scrip of Darjeeling. Details of these 10 trades executed on May 27, 2019 are tabulated below: Table No. 60 Trade Buyer Seller Name Buy Sell Trade Buy Sell Trade Number Name Order Order Time Order Order Qty Time Time Qty Qty 112 Arpan Das Himanshu 15:02:55 15:12:17 15:12:17 3000 10000 3000 Ramniklal Shah 113 Sumit Laha Himanshu 15:04:10 15:12:17 15:12:17 6000 10000 4509 Ramniklal Shah 118 Sumit Laha Himanshu 15:04:10 15:14:31 15:14:31 6000 10000 1491 Ramniklal Shah 119 Minu Mallick Himanshu 15:07:21 15:14:31 15:14:31 5000 10000 5000 Ramniklal Shah 120 Suprabhat Himanshu 15:10:01 15:14:31 15:14:31 5000 10000 3010 Laha Ramniklal Shah

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling

Trade Buyer Seller Name Buy Sell Trade Buy Sell Trade Number Name Order Order Time Order Order Qty Time Time Qty Qty 122 Suprabhat Himanshu 15:10:01 15:14:39 15:14:39 5000 10000 1990 Laha Ramniklal Shah 123 Suprabhat Himanshu 15:10:05 15:14:39 15:14:39 5000 10000 4510 Laha Ramniklal Shah 124 Suprabhat Himanshu 15:10:05 15:14:48 15:14:48 5000 10000 490 Laha Ramniklal Shah 125 Suprabhat Himanshu 15:10:10 15:14:48 15:14:48 5000 10000 5000 Laha Ramniklal Shah 126 Arpan Das Himanshu 15:10:10 15:14:48 15:14:48 9000 10000 4510 Ramniklal Shah

150.4. The aforesaid trading pattern wherein certain Sub-group 3 entities acted as buyers and the Promoter of Darjeeling (Mr. Himanshu Shah) acted as a seller for creating huge volumes in the scrip of Darjeeling is not a single instance. The aforesaid pattern was further observed on various other occasions. For instance, on August 29, 2019, it was noticed that Mr. Himanshu Shah had placed a sell order (order number 1567049400002360195) for 50,000 shares of Darjeeling at 14:49:49 hours at price of INR 94/- per share. It is noticed that the aforesaid sell order was partly matched with 38 different buy orders trades placed by 20 entities belonging to Sub-group 2 and Sub-group 3 and resulted into 38 different trades for a cumulative quantity of 36,150 shares at a price of INR 94/ per share. Details of the aforesaid 38 buy orders and trades are tabulated below: Table No. 61

Trade Buyer Sub Order Buy Trade Time Buy Trade Number Name Group Number Order Time difference Order Qty Time between Qty previous buy order 121 Vaghela 2 156704940000 14:59:14 14:59:14 - 1200 1200 Prakash 2360198 Kantilal

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling

Trade Buyer Sub Order Buy Trade Time Buy Trade Number Name Group Number Order Time difference Order Qty Time between Qty previous buy order 123 Krusha 2 156704940000 14:59:26 14:59:26 00:00:12 500 500 Birjukumar 2360200 Sanghvi 124 Ravi 2 156704940000 14:59:34 14:59:34 00:00:08 1100 1100 Kannadasan 2360201 Adidravid 125 Chiragkumar 2 156704940000 14:59:49 14:59:49 00:00:15 250 250 Makwana 2360202 126 Makwana 2 156704940000 14:59:59 14:59:59 00:00:10 250 250 Madhuben 2360203 127 Dipika 2 156704940000 15:00:36 15:00:36 00:00:37 2000 2000 Popatbhai 2360204 Parmar 129 Popatbhai 2 156704940000 15:00:45 15:00:45 00:00:09 1000 1000 Ramjibhai 2360206 Parmar 130 Hina Barot 2 156704940000 15:00:50 15:00:50 00:00:05 1000 1000 2360207 132 Pritiben 2 156704940000 15:00:59 15:00:59 00:00:08 1000 1000 Popatbhai 2360209 Parmar 134 Sahilkumar 2 156704940000 15:01:07 15:01:07 00:00:08 2000 2000 Amrutbhai 2360211 Vaghela 135 Lilaben 2 156704940000 15:01:09 15:01:09 00:00:03 1000 1000 Popatbhai 2360212 Parmar 138 Arun Laha 3 156704940000 15:02:02 15:02:02 00:00:53 1000 1000 2360215 139 Arun Laha 3 156704940000 15:02:06 15:02:06 00:00:04 700 700 2360216 140 Manishkuma 2 156704940000 15:02:14 15:02:14 00:00:09 500 500 r Rajput 2360217 141 Manishkuma 2 156704940000 15:02:48 15:02:48 00:00:34 500 500 r Rajput 2360218 142 Keval Savant 2 156704940000 15:02:49 15:02:49 00:00:01 1000 1000 2360219 144 Vaghela 2 156704940000 15:03:05 15:03:05 00:00:16 200 200 Prakash 2360221 Kantilal

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling

Trade Buyer Sub Order Buy Trade Time Buy Trade Number Name Group Number Order Time difference Order Qty Time between Qty previous buy order 146 Ravi 2 156704940000 15:03:22 15:03:22 00:00:17 200 200 Kannadasan 2360223 Adidravid 147 Vaghela 2 156704940000 15:03:44 15:03:44 00:00:22 200 200 Prakash 2360224 Kantilal 148 Dipika 2 156704940000 15:03:47 15:03:47 00:00:03 1000 1000 Popatbhai 2360225 Parmar 150 Hina Barot 2 156704940000 15:04:00 15:04:00 00:00:14 1000 1000 2360227 151 Vaghela 2 156704940000 15:04:16 15:04:16 00:00:16 750 750 Prakash 2360228 Kantilal 152 Uma Dutta 3 156704940000 15:04:20 15:04:20 00:00:04 1550 1550 2360229 153 Hina Barot 2 156704940000 15:04:38 15:04:38 00:00:17 1000 1000 2360230 154 Hina Barot 2 156704940000 15:04:45 15:04:45 00:00:07 1000 1000 2360231 156 Hina Barot 2 156704940000 15:04:54 15:04:54 00:00:09 1000 1000 2360233 157 Ravi 2 156704940000 15:04:59 15:04:59 00:00:05 250 250 Kannadasan 2360234 Adidravid 158 Keval Savant 2 156704940000 15:05:11 15:05:11 00:00:12 250 250 2360235 159 Sumit Laha 3 156704940000 15:05:41 15:05:41 00:00:30 500 500 2360236 160 Suprabhat 3 156704940000 15:06:59 15:06:59 00:01:18 500 500 Laha 2360237 161 Ujjal Laha 3 156704940000 15:07:06 15:07:06 00:00:07 2100 2100 2360238 162 Sumit Laha 3 156704940000 15:07:15 15:07:15 00:00:09 500 500 2360239 163 Sumit Laha 3 156704940000 15:07:24 15:07:24 00:00:08 50 50 2360240 164 Arpan Das 3 156704940000 15:07:27 15:07:27 00:00:03 5000 5000 2360241 165 Debashish 3 156704940000 15:07:58 15:07:58 00:00:31 500 500 Dutta 2360242

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling

Trade Buyer Sub Order Buy Trade Time Buy Trade Number Name Group Number Order Time difference Order Qty Time between Qty previous buy order 166 Suprabhat 3 156704940000 15:08:42 15:08:42 00:00:44 500 500 Laha 2360243 167 Suprabhat 3 156704940000 15:08:46 15:08:46 00:00:04 950 950 Laha 2360244 169 Debashish 3 156704940000 15:11:33 15:11:33 00:02:47 5150 2150 Dutta 2360247

150.5. From the aforesaid table, a clear pattern is indicated where under, the aforesaid entities are seen to be taking turns one after the other, for placing buy orders wherein entities from Sub-group 2 and 3 are placing orders within a few seconds of each other’s orders to ensure that the sell orders placed by Mr. Himanshu Shah gets executed by matching with their buy orders. It is also noticed that though the time difference between the sell order of Mr. Himanshu Shah (14:49:49 hours) and 1st buy order (out of 38 buy orders) placed by Mr. Vaghela Prakash Kantilal (14:59:14 hours) was 9 minutes and 25 seconds, however, the time difference between every order in the said 38 buy orders was mostly within seconds (less than 1 minute). Notably also, the aforesaid 1st buy order (out of 38 buy orders) placed by Mr, Vaghela Prakash Kantilal also resulted in contribution of positive LTP of INR 1/- (1.08% higher than previous LTP of INR 93/-). 151. It is noted from the records that in 118 trades, entities belonging to Sub-group 2 and 3 who are prima facie connected with Mr. Hanif Shekh, were acting as buyers and Mr. Himanshu Shah who is the Promoter and Managing Director of Darjeeling was acting as seller and through such 118 trades, Mr. Himanshu Shah has sold 2,17,335 shares to the entities from Sub-group 2 and 3. From further analysis, it is noted that these 118 trades were executed on only 6 trading days wherein a similar trading pattern as discussed above at paragraph no. 150.4 of this Order (illustration of August 29, 2019) was observed as the entities from Sub-group 2 and 3 were found to be taking turns one after the other for placing buy orders consecutively within the time

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling difference of a few seconds of each other’s orders to ensure that the sell order placed by Mr. Himanshu Shah surely gets matched with their buy orders. Details of such 118 trades are tabulated below: Table No. 62

Date Number of Number of Time difference Number Number of Buy Orders Sell Orders between sell order of Shares placed by placed by and the 1st buy order Trades traded Hanif Himanshu (range) Connected Shah Entities 27.05.2019 7 4 01 minute 25 seconds 10 33510 to 10 minutes 21 seconds 07.06.2019 10 2 43 seconds to 6 10 41000 minutes 05 seconds 14.06.2019 7 1 02 seconds to 03 7 41457 minutes 02 seconds 21.08.2019 23 1 01 minute 09 seconds 23 27750 to 16 minutes 51 seconds 23.08.2019 30 1 14 minutes 02 seconds 30 37468 to 24 minutes 51 seconds 29.08.2019 38 1 21 minutes 25 seconds 38 36150 to 21 minutes 44 seconds Total 118 2,17,335

152. The aforesaid trade practices followed by the PV Influencers to influence the volumes and price while trading in the scrip of Darjeeling prima facie do not appear to be leading to execution of any genuine trades backed by any bonafide intention to trade in the scrip in due course of dealing in securities. Instead, such a dishonest trading pattern as was followed by the PV Influencers, was apparently undertaken with an aim to prima facie increase the trading volumes and price in the scrip in pursuance of a prima facie pre-decided scheme employed in the scrip. Further, as noted in the case of the other scrips discussed earlier in this Order, the aforesaid strategy of executing prima facie synchronised trades and / or structured trades and / or placing of multiple small orders to match a single big order may not be the only

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling method adopted by Sub-groups 2 and 3 entities to manipulate the volume and price in the scrip, but I find these are the predominant methods adopted by them to artificially influence the volumes and price of the scrip. Interestingly, in the aforesaid process of prima facie manipulating the price and volume in the scrip, the entities belonging to Sub-groups 2 and 3 are also seen to have provided exit to the Promoter and Managing Director of the Company, Mr. Himanshu Shah from the scrip of his own Company. It is noted that in the process of prima facie manipulating the scrip of Darjeeling, the Darjeeling Group (15 entities) have also made prima facie wrongful gains. The records indicate that majority of their sell trades through which the prima facie wrongful gains were generated were undertaken during the pre-SMS period, therefore, their complete share of prima facie wrongful gains are considered as wrongful gains while acting as PV Influencers. SMS Period

153. Once a momentum was generated in the scrip by the dealings in the scrip of Darjeeling by the PV Influencers in a sustained manner so as to maintain the price and volume in the scrip at a desired level to attract the market participants, the next vital step to fructify the scheme employed in the scrip was taken by the mastermind behind the said scheme, viz: Mr. Hanif Shekh by his act of sending bulk SMSs with buy recommendations in the scrip and also making use of the website, www.midcapgains.in to give buy recommendations in the scrip. A few sample of such SMS texts circulated in the said scrip and their prima facie impact on volume and price in the scrip of Darjeeling, are highlighted in the table below: Table No. 63

Sl. SMS Sample SMS Text Date of SMS % volume increase % price increase No. Header circulation from previous from previous trading day trading day 1. BH- JACKPOT Call: Buy 12,12,928 shares Weighted Average December MGAINS DARJEELING ROPEWAY traded on December price on 24-Dec- 26, 2019 (539770) For INTR- 26, 2019 from 2019 was INR DAY Target 105+ 1,83,318 shares 97.74/- and the Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling

Sl. SMS Sample SMS Text Date of SMS % volume increase % price increase No. Header circulation from previous from previous trading day trading day -TOMORROW Target traded on December scrip touched the 110+ 24, 2019 i.e. 561.65 % high of INR -FINAL Target 125+ in 1 increase. 103.4/- on 26- WEEK Dec-2019 i.e. the EVERYDAY PRICE WILL scrip witnessed a GO UP MINIMUM 5% movement of 5.79% in its price. 2. BH- OPEN CHALLENGE: MGAINS BUY BUY BUY AS MUCH AS YOU CAN DARJEELING (539770) NOW@81 101% STOCK WILL CROSS 105++ LEVEL TODAY- BEST OPPORTUNITY- EARN 20% PROFIT IN 1 DAY.

Thus, from the aforesaid table it can be seen that there has been a marked increase in the volume of the scrip noticed immediately on the next day of sending of the SMS including an upward movement in the price of the scrip. It is further observed from the records that there has been 1310% increase in the volume of the scrip during the SMS period vis-à-vis pre-SMS period. The aforesaid figures prima facie accentuates the role played by the bulk SMSs in luring the investors to deal in the scrip. The records reflect that the circulation of bulk SMSs and the use of the website to give buy recommendations was not a solitary instance and was frequently used during the SMS period by using different sender IDs. The same had a noticeable impact on the volume movement in the scrip. Apart from sending the afore-quoted scrip specific recommendation in scrip of Darjeeling, automatic messages were also received by public from calling on missed call service number. A sample of such a SMS text received from calling missed call service number (926667330) is reproduced below: “Thank You For Joining Us For MULTI-BAGGER Stock 2019. Our Executive Will Call You Soon. Please Check Our 100% Successful PAST PERFORMANCE on www.MidcapGains.in”.

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling

Off Loaders 154. It is noted from the material available on record that in the scrip of Darjeeling, bulk SMSs circulation period was limited to 4 days only (December 23, 2019 to December 27, 2019), as the scrip of Darjeeling was brought under SMS framework surveillance of Stock Exchange for dealing with unsolicited messages on December 27, 2019 by timely regulatory intervention. Since, the scrip was put under the active surveillance framework and was monitored closely by the Exchange, it became a public knowledge serving as a big red flag for the general investors and as a consequence of that the price of the scrip started falling. Consequently, the prima facie scheme employed in the scrip by Mr. Hanif Shekh apparently could not yield in giving the intended fruition of elevating the price and volume (though there was spurt in the volume of the scrip) in the scrip to a high level as per the pre-design of the said scheme, as a result of which it is seen that the Off Loaders had to exit the scrip at prices lower than the expected. The Off Loaders in the scrip are those entities which belonged to Sub-groups 2 and 3. The details of trading done by the Off Loaders during the SMS period are presented as follows: Table No. 64 Profits made by Sub-group 2

S No Entity name Buy Value Sell Value Profit during during IP during IP IP (A) (B) (C)=(B)-(A)

1. Sahilkumar Amrutbhai 1228100 1166550 -61550 Vaghela 2. Hina Barot 811727 858137.1 46410.1 3. Pritiben Popatbhai Parmar 696320 743451 47131 4. Lilaben Popatbhai Parmar 562724.5 585646.35 22921.85 5. Ravi Kannadasan Adidravid 552643.5 575431.95 22788.45 6. Vaghela Prakash Kantilal 532343.5 554098.2 21754.7 7. Keval Savant 524443.5 545952.45 21508.95 8. Manishkumar Rajput 521175 540457.5 19282.5 9. Shahrukhkhan Pathan 438800 465465 26665 10. Dipika Popatbhai Parmar 428570 461586 33016

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling

S No Entity name Buy Value Sell Value Profit during during IP during IP IP (A) (B) (C)=(B)-(A)

11. Chiragkumar Makwana 430349 447622.8 17273.8 12. Makwana Madhuben 406852 421634.4 14782.4 13. Popatbhai Ramjibhai Parmar 344033.5 369592.05 25558.55 14. Krusha Birjukumar Sanghvi 151900 157224 5324 15. Fuldeep Popatbhai Sehgal 95500 98265 2765 16. Karan Birjubhai Sanghvi 95500 98265 2765 Total 268397.3

Table No. 65 Dealings of Sub-group 3

S No Entity name Buy_Value Sell_Value Profit during during IP during IP IP (A) (B) (C)=(B)-(A)

1. Linkup Financial Consultants 6365651.65 4445672 -1919979.65 Private Limited 2. Highgrowth Vincom Private 6069685 4531350 -1538335 Limited 3. Suprabhat Laha 3142026.95 3321620.8 179593.85 4. Minu Mallick 2796637.7 3052895 256257.3 5. Arpan Das 2766682.65 2796391.45 29708.8 6. Dibakar Laha 2789619.2 2387775 -401844.2 7. Debashish Dutta 1899190 1825320 -73870 8. Arun Laha 1415562.5 1585105 169542.5 9. Uma Dutta 1258700 1270248.05 11548.05 10. Sumit Laha 1151200 1171050 19850 11. Glorious Vincom Private 1168920 839674.2 -329245.8 Limited 12. Ujjal Laha 992722.6 1148954 156231.4 13. Tapas Laha 820050 921463 101413 14. Subrata Laha 132355 151980 19625 15. Sanjay Dey 132692.5 151500 18807.5 Total -3300697.25

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling

The Ultimate Beneficiary 155. As noted in the earlier paragraphs of this Order, one set of Off Loaders, namely, Sub-group 2 (Ahmedabad based entities) have made profit by exiting the scrip while another set of Off Loaders, namely, Sub-group 3 (Kolkata based entities) have suffered losses while exiting the scrip during the SMS period. The reason for the same as noted above, is that the last leg of the prima facie scheme employed in the scrip (circulation of bulk SMSs to induce investors to the scrip and giving of buy recommendations in the scrip by using the website, www.midcapgains.in) did not pan out the way it was pre-planned by Mr. Hanif Shekh and his connected entities, since the scrip came under surveillance measure by the Stock Exchange as soon as the bulk SMSs started getting circulated. However, prima facie there is no room for doubt that, but for the surveillance measures, the prima facie scheme would have followed the same successful trajectory as it has followed in the other four scrips and would have brought huge monetary benefits to the mastermind and perpetrators of such a scheme, viz: Mr. Hanif Shekh and his connected entities in the same manner as it did for the other scrips discussed earlier.

The above noted new developments surrounding this scrip all the more emphasise the invaluable role played by the bulk SMSs as one of the leg of the prima facie scheme of the fraudulent trade practices employed in the aforesaid scrips to make the scheme a thumping success by way of generating huge amounts of wrongful gains. The facts and circumstances based on which the aforesaid prima facie inferences have been drawn are as follows: 155.1. There is an uncanny resemblance in the way the prima facie scheme has unfolded in the other four scrips and in the scrip of Darjeeling. In other words, the first leg of the prima facie scheme across all the afore-discussed five scrips was that of manipulating the price and volume in the scrip so as to generate momentum and positive sentiment about the scrip in the market for dealing in the scrip. Having achieved a certain attractive level of volumes and price in the scrips through the manipulative trades engaged in by the set of connected entities who performed the role of PV Influencers, as per the pre-conceived scheme, the next leg of sending out bulk SMSs with buy recommendation in those Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling scrips was to commence in a big way including using websites to give buy recommendations in the scrip and subsequent to circulation of such bulk SMSs, certain entities connected either to the Company or the SMS sender were to exit the scrip predictably and expectedly, by making profits.

Finally, post exiting the scrip, the said entities called in this Order as Off Loaders, would transfer the sales proceeds to the Company related entities or to the SMS sender and / or his connected entities through a series of layered transactions so that the real identities of the ultimate recipients of those sales proceeds would remain hidden behind those layered transactions. All the legs of the prima facie scheme have played out exactly in the same manner across the five scrips including Darjeeling. 155.2. I find that not only the prima facie scheme employed in Darjeeling is the same as that of other four scrips, even some of the entities involved in the said scheme pertaining to Darjeeling are the same who have also played a part in other four scrips. For instance, PV Influencers in the scrip of Darjeeling namely, entities belonging to Sub-groups 2 and 3 were also the PV Influencers in the scrips of VFL and 7NR (Sub-group 3), the prima facie SMS sender, Mr. Hanif Shekh is the common active link and single source of bulk SMSs across the five scrips, the Off Loaders in Darjeeling namely, the entities belonging to Sub-groups 2 and 3 were also the Off Loaders in the scrips of MUL, VFL, 7NR (Sub-group 3) and GBL (Sub-group 3) and last but not the least, the Ultimate Beneficiary in Darjeeling (discussed in subsequent paragraphs) remains Mr. Hanif Shekh and / or his connected entities as is the case in other four scrips.

156. It is noted from the records that Mr. Himanshu Shah who is the Promoter and Managing Director of Darjeeling was not only involved in the prima facie manipulation of price and volume in the scrip as part of the Darjeeling group but also he has exited from the scrip by mostly trading (2,74,487 shares out of 7,44,723 shares) with entities of Sub-groups 2 and 3, i.e. the entities which played the role of not only PV Influencers in the scrip but were also the Off Loaders in the scrip apart from being prima facie connected with Mr. Hanif Shekh. Thus, Mr. Himanshu Shah has prima facie played the same role as was being played by other entities of Sub-groups 2 and 3 and in fact the Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling said role is prima facie played by most of the Darjeeling group entities. Therefore, the very act of all these entities of the aforesaid three groups coming together to deal in the scrip in the market in a concerted manner as an united group, when critically examined with their timing of coming together to deal in the scrip including the fact that all of them have prima facie played the same kind of role while dealing in the scrip, cannot be brushed aside as a mere coincidence of events and such a role played by these entities in a coordinated and pre-orchestrated manner was bound to be played only pursuant to a prima facie pre-determined plan.

It further shows the complicity of the Company connected entities in the prima facie scheme along with Mr. Hanif Shekh. As noted from the facts and evidence earlier, Mr. Hanif Shekh is undoubtedly the person who was sending bulk SMSs in all the aforesaid five scrips and was managing the website www.midcapgains.in to give buy recommendations in the scrip. A comprehensive scrutiny of all the relevant facts and circumstances of the matter now throws up a compelling scenario which shows that prior to circulation of bulk SMSs in the scrip of Darjeeling, entities connected to the Company and Mr. Hanif Shekh have prima facie artificially influenced the price and volume in the scrip and thereafter, coinciding with the circulation of bulk SMSs in the scrip which was done by Mr. Hanif Shekh, entities connected directly and / or indirectly with Mr. Hanif Shekh, exited the scrip. However, unlike other four scrips, the Off Loaders connected with Mr. Hanif Shekh could not make huge profits due to timely surveillance measure taken by the Stock Exchange which prevented the general investors to jump into the fray by getting induced by the artificially elevated volumes and price of the scrip.

However, the entities connected with the Company had started exiting the scrip when the price in the scrip was substantially high compared to its past performance. The details of the profits so made by the Company connected entities are provided in the table below:

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling

Table No. 66 Profits made by the Darjeeling Group Sl No Entity Name Buy Qty Buy Value Sell Qty Sell Value Net Profit (INR) (INR) (INR) (A) (B) (A)- (B)

1. Shashikant 815535 71117598 849068 61324319 -9793279 Chinubhai Kapadia 2. Kruti Kevin 620334 44239778 532069 47130561 2890784 Kapadia 3. Arvind 511385 33389145 703830 56733153 23344008 Shantilal Shah 4. Bharati Arvind 267474 20250074 272473 26118880 5868806 Shah 5. Ramnaresh 237112 21536058 242518 22436289 900231 Dashadeen Nirmal 6. Mehul 203893 16911670 116117 17293482 381812 Hasmukh Shah 7. Dhavani 157173 14484940 69036 11807501 -2677439 Jayantkumar Shah 8. Bhashit Deepak 127679 9719111 125050 9971966 252855 Shah 9. Yash Manish 120719 10958055 140739 12622677 1664622 Mehta 10. Aakash Doshi 73206 9170506 271202 18761902 9591396 11. Ankur Suresh 55863 5314239 92443 8821836 3507597 Mehta 12. Rupal Bhavin 37936 4838002 188251 15852032 11014029 Shah 13. Vidhi Mehul 25000 2266489 0 1616250 -650239 Shah 14. Himanshu Shah 11190 9485701 744988 67108263 57622563 15. Rajvi Naresh 9000 845852 9500 899451 53599 Shah Total 3273499 274527216.2 4357284 378498562 103971344

157. I have already noted in the preceding paragraphs of this Order, while discussing the dealing in the scrip of MUL, that the entities pertaining to Sub-groups 2 and 3 were funded by Sub-groups 2.A and 3.A and in return, Sub-groups 2 and 3 were found to Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling transferring funds back to Sub-groups 2.A and 3.A from the sales proceed received by them after off-loading the shares of the scrip during the SMS period. Subsequently, Sub-groups 2.A and 3.A, through multiple layers of funds transfers were observed to be transferring money (so received back from Sub-groups 2 and 3) to Mr. Hanif Shekh. In similar lines and by following similar modus operandi, in the scrip of Darjeeling also, the entities pertaining to Sub-group 2 have transferred funds to Hanif Shekh and / or his connected entities. Thus, it can be prima facie inferred that though the Sub-group 2 entities were found to be actively dealing in the scrip of Darjeeling but in reality they were prima facie, just acting as front entities of Mr. Hanif Shekh to transact in the scrip and therefore, the latter, i.e. Mr Hanif Shekh (through his connected entities of Sub-groups 2.A and 3.A) was funding their trades.

Consequently, after off-loading their shares of Darjeeling during the SMS period, the Sub-group 2 entities have transferred funds out of the sales proceeds received by them by way of exiting the scrip, to Mr. Hanif Shekh or to his connected entities albeit through multiple layers of conduit channels. In the given facts and circumstances of the matter, prima facie there cannot be any other plausible explanation for the peculiar way in the which the funds have flown from the accounts of Sub-group 2 entities to Mr. Hanif Shekh and/or his connected entities, other than for sending the remitting the gains so made by implementing the scheme to the ultimate mastermind as well as the main beneficiary of the said scheme. 158. To sum up the aforesaid discussion, as one wades through the multiple layers and multiple stages of implementation the aforesaid prima facie scheme that was prima facie employed in all the five scrips including Darjeeling, the facts and circumstances of the matter come back with a great force of clarity as to why the entire scheme was hatched which was apparently nothing but to prima facie benefit the entities connected with the Company and Mr. Hanif Shekh and / or his connected entities.

159. Now moving on to the determination of the prima facie violations committed by the entities involved in the scrip of Darjeeling, I find from that facts that prima facie the scheme for engaging in fraudulent trades as employed in the scrip of Darjeeling is almost identical to the schemes employed while dealing in the scrips of MUL, VFL, 7NR

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling and GBL, wherein the modus operandi followed by the involved entities is also similar and the role of different groups of entities such as PV Influencers, SMS Sender and Ultimate Beneficiary etc., is also similar. Consequently, the justification for holding each entity liable for its role played in the prima facie scheme in Darjeeling would also be similar to that of other four scrips. Therefore, for the sake of brevity, the rationale behind holding these entities liable for their prima facie violations is not repeated once again. 160. The entities who have played the prima facie role of PV Influencers in the scrip and have been mentioned at Table No. 59 including Mr. Bhavin Shah (prima facie trading on behalf of his mother, father and wife who are prima facie PV Influencers in the scrip) and Mr. Kevin Kapadia (prima facie trading on behalf of wife who is prima facie PV Influencer in the scrip) have by their manipulative acts of dealing in the scrip have prima facie violated the provisions of Sections 12A (a), (b) and (c) of SEBI Act and regulations 3 (a), 3 (b), 3 (c), 3(d), 4(1) and 4(2)(a), (b), (e) and (g) of PFUTP Regulations.

161. Next comes, the SMS Sender, Mr. Hanif Shekh who was responsible for sending of bulk SMSs in the scrip including using the website www.midcapgains.in to give buy recommendations in the scrip. The complicity of the Promoter and Managing Director of Darjeeling namely, Mr. Himanshu Shah in the prima facie scheme has already been noted in the preceding paragraphs. Therefore, for the said actions, Mr. Hanif Shekh and Mr. Himanshu Shah have prima facie violated Sections 12A (a), (b) and (c) of SEBI Act and regulations 3 (a), 3 (b), 3 (c), 3(d), 4(1) and 4(2)(k) and (r) of PFUTP Regulations. Further, as noted in preceding paragraphs, Sambhavanath Traders (Proprietor – Mr. Chandraprakash Valchand Parekh) has prima facie played a decisive role in operationalising the website, www.midcapgains.in without which the prima facie scheme would not have been able to be implemented at its full vigour. Therefore, the actions of Sambhavanath Traders (Proprietor – Mr. Chandraprakash Valchand Parekh) has prima facie led to the violation of Sections 12A (a), (b) and (c) of SEBI Act and regulations 3 (a), 3 (b), 3 (c), 3(d), 4(1) and 4(2)(k) and (r) of PFUTP Regulations.

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling

162. Moving on to the prima facie violations committed by the Off Loaders, I find that the action of the Off Loaders was nothing but giving finality to the consequence of the previous legs of the prima facie scheme. In other words, their action of off-loading the shares by dealing the scrip in a fraudulent manner by playing their assigned role as part of the entire scheme would not have been possible without the efforts / actions of the kingpin of the prima facie scheme, Mr. Hanif Shekh. Therefore, the Off Loaders as mentioned at Table Nos. 64 and 65 along with Mr. Hanif Shekh have prima facie violated Sections 12A (a), (b) and (c) of SEBI Act and regulations 3 (a), 3 (b), 3 (c), 3(d), 4(1) and 4(2)(a) of PFUTP Regulations. 163. It is noted from records that the entities connected to Mr. Hanif Shekh namely Mr. Kasambhai Shekh, Ms. Hasina Kasambhai Shekh, Robert Resources Ltd., Econo Trade India Ltd., Econo Broking (Erstwhile Bansal Finstock) and Sai Metaltech LLP, the entities mentioned at Table No. 21 and also the entities mentioned at Table No. 17 have prima facie actively aided, abated and enabled Mr Hanif Shekh to encash the benefit of the scheme employed by him along with the Promoters of the Company in the scrip as these entities have facilitated in transferring of funds which were received by them from the other connected entities of Mr. Hanif Shekh namely Sub-groups 2.A, 3 and 3.A, who had dealt in the scrip pursuant to the prima facie scheme employed in the matter.

Thus, the aforesaid actions on the part of the connected entities of Mr. Hanif Shekh have prima facie led to the violation of Sections 12A (a), (b) and (c) of SEBI Act and regulations 3 (a), 3 (b), 3 (c), 3(d) and 4(1) of PFUTP Regulations. 164. The issue which now merits discussion is who amongst the aforesaid entities, would be prima facie held liable for the proceeds wrongfully generated by the employment of the prima facie scheme in the scrip. From the above discussions, I note that the kingpin and mastermind, Mr. Hanif Shekh was prima facie pulling the strings from behind for successfully implementing the scheme at its various stages along with active support and collusion of the Promoter and Managing Director of Darjeeling namely, Mr. Himanshu Shah. Not only that, among others entities, they were also the major Ultimate Beneficiaries of the said prima facie scheme. Therefore, based on the available records, it is prima facie inferred that Mr. Hanif Shekh and his connected

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling entities namely, Mr. Kasambhai Shekh, Ms. Hasina Kasambhai Shekh, Robert Resources Ltd., Econo Trade India Ltd., Econo Broking (Erstwhile Bansal Finstock) and Sai Metaltech LLP including the relevant entities of Sub-group 2 and 3 as mentioned at Table No. 64 and 65 and Mr. Himanshu Shah, are jointly and severally liable for the wrongful gains generated in the scrip by the employment of the afore-discussed prima facie scheme, to the tune of INR 2,68,397/-. Further, the entities as mentioned at Table No. 66 along with Mr. Hanif Shekh are jointly and severally liable for the wrongful gains generated in the scrip by the employment of the prima facie scheme, to the tune of INR 10,39,71,344/-. 165. Before proceeding further, it will be appropriate here to recapitulate the prima facie findings in the matter. It has been exhaustively discussed in the foregoing paragraphs of this Order, the intricate details of the prima facie scheme employed across all the five scrips which, apart from certain minor variations in terms of particulars of the parties involved, essentially envisaged the same pre-conceived design and steps to fraudulently deal in all the afore-noted five scrips to generate wrongful gains.

To begin with, a group of connected entities who have been named as PV Influencers in this Order, have deliberately placed orders over a period in a manner to prima facie manipulate the price and volume in the said scrips and to sustain the rise in price and volume in the scrip over the pre-SMS period so as to create a momentum of positive market perception about those scrips. The frequency of such trades amongst the connected entities did not continue for merely one or two stray incidents, but went on consistently with much more frequency in a manner to ensure that there are sustained trading activities in the scrip over a period of time. In the second leg of implementation of the scheme that unfolded with the circulation of bulk SMSs with buy recommendations in favour of the aforesaid five schemes including using websites to give buy recommendations in the said scrips, one can get a glimpse of the prima facie ingenious mastermind who worked behind such a well-crafted scheme, viz: Mr. Hanif Shekh. As the materials before me suggest, in order to evade regulatory detection and to maintain anonymity, Mr. Hanif Shekh possessed multiple mobile numbers under different names and by subscribing in cash, he was Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling already owning multiple SMS sender IDs.

The said sender IDs were used to send bulk SMSs during different periods for different scrips, to thousands of mobile phone owners therein recommending to buy the aforesaid scrips. Further, he also made use of certain websites to give buy recommendations in the scrip. Post the circulation of such bulk SMSs, the prima facie scheme entered its final phase wherein the entities connected either with the kingpin, Mr. Hanif Shekh or in case of some scrips, related to the Promoters of the Company, had exited the scrip by offloading their shares (acquired previously) on the innocent investors who were prima facie induced to invest in those scrips by witnessing the steady rise in the price and volume in the scrip over a period which got further amplified by the SMSs that were being circulated in relation to these scrips. 166. Going by the unabated misconduct of the connected entities (PV Influencers) as demonstrated by their sustained prima facie manipulative trading activities in these five scrips over a period as discussed aforesaid and moreover, the desperate attempt by the kingpin and / or Promoters of the Company, to put up front entities and in some cases the entities connected to them, to deal in the scrip in a fraudulent manner including off-loading the shares during the SMS period with huge amounts of wrongful gains, when seen along with the prima facie fact that post off-loading of such shares, the wrongful gains were transferred to the Ultimate Beneficiaries (the kingpin and / or Promoters of the Company) using clandestine channels, show the meticulous effort put in by the kingpin, Mr. Hanif Shekh and in some cases by the Promoters of the Company to ensure that the prima facie scheme succeeds in its objective of bring home bountiful of wrongful gains to the Ultimate Beneficiaries of the scheme.

167. SEBI Act was enacted to protect the interests of investors in the securities market. Protection of interest of investors should necessarily include prevention of misuse of the market. Orchestrated trades are a misuse of the market mechanism which affects the market integrity. Ordinarily, the trading would have taken place between anonymous parties on the Stock Exchange platform and the price and the volume would have been determined by the market forces of demand and supply. In the instant case however, the entities did not stop at prima facie executing synchronised

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling trading over a sustained period. Their intent behind dealing in the scrips as indicated by the facts gathered during investigation, goes beyond that. The particulars of the trade in this case indicate that the connected parties of different groups who engaged in apparent ingenuine trades during the pre-SMS period and thereafter primarily to influence the price and volume of the scrips, did not intend to transfer the beneficial ownership of the shares that were traded between them, since by trading amongst themselves as a group or being a counterparty to other connected entities’ trades, the entities have ensured that the ownership of the shares stays within the group or amongst the other connected entities. The facts reveal that whenever such trades were not prima facie synchronizing, the entities were executing either prima facie structured trades or first trades above the closing price of the previous day or were placing several small orders to match one big counterparty order or were executing only miniscule trades or were attempting to manipulate the closing price.

The aforesaid methods of trading in the scrips prima facie give a strong indication that the entities primarily intended to play with the market forces of demand and supply and were not behaving like regular prudent investors behaving in normal course of dealing in any securities. 168. A unique feature of the Stock Exchange is that, unlike other moveable properties, securities are bought and sold amongst the unknowns who never get to meet and the securities are traded at prices determined by the forces of demand and supply. While the screen-based trading system keeps the identity of the parties anonymous, it will be too naive to rest the findings on the said basis which overlooks a meeting of minds elsewhere. To put it differently, a lip service can be paid to a screen based trading system when the trading entities decide in advance to employ a well-planned scheme to deceitfully deal in a particular scrip on the Stock Exchange platform. Direct proof of such meeting of minds elsewhere would rarely be forthcoming. The test is one of preponderance of probabilities. The proof of manipulation in the circumstances always depends on inferences drawn from a mass of factual details.

Findings must be gathered from patterns of trading data and the nature of the transactions etc. Several circumstances of a determinative character coupled with the inference arising from Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling the conduct of the parties in a major market manipulation could reasonably lead to a conclusion that the entities have indulged in distorting the price and volume in a scrip. The inference of non-genuine trades in the instant matter has been drawn based on the cumulative effect of a host of attending circumstances viz., nature of transactions which were prima facie synchronized or were structured trades or were miniscule trades or were multiple trades to match one big order etc., the frequency with which such transactions were undertaken which was on a regular basis and between the same set of entities over a period of time, the value of the transactions which as noted above was beyond the financial capacity of some of the entities as they were either being funded by some other individuals or were prima facie front entities of the Promoters of the Company and also the conditions then prevailing in the market especially in the peer group companies which showed that the impugned scrips were trading differently than the peer group scrips while there were no material corporate announcements made by the companies involved in the instant matter.

This list of factors, in the very nature of things, cannot be exhaustive. As the market grows, ingenuous means of manipulation are employed. There can be several such situations but some of the recurrently used methods by the entities in the instant matter have been discussed at length in the preceding paragraphs of this Order. 169. In the light of the aforesaid factors, it can be prima facie inferred that the entities by repeatedly carrying out the impugned trades in the scrips have not allowed the market forces to operate in their natural course and thereby depriving the other market players from having the correct picture about the performance of those five scrips while taking a call about dealing in those respective five scrips. Not only the prima facie deceptive behavior of the entities have affected the price discovery system but also had an adverse impact on the fairness, integrity and transparency of the stock market. 170. Securities market is wide spread and via its screen based trading system, it gives a common platform to all the traders to come together and deal in various scrips.

It is through the trading screens of the Stock Exchanges that a potential investor is able to track a scrip and is able to gauge whether a particular scrip is active or not, whether

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling it is trading in large volumes and whether the price is going up or down. Thus, when a potential investor decides to invest in a scrip or to sell his holding in a scrip, among other things, also considers the aforesaid factors before making an informed decision. But when an individual either of his own or as part of a group, deals in the scrip with the sole purpose of artificially influencing its price and volume, the said deceptive behavior invariably influences the decision of the other investors in the market to deal in the scrip depending upon how the volume and price of the impugned scrip has been manipulated by the former. It goes without saying that any transaction executed to defeat the market mechanism would be illegal. In the instant matter the impugned transactions which were part of a well calculated scheme have subverted the Stock Exchange platform to benefit a few individuals at the expense of other investors in the scrip and the same deserves to be dealt with a firm hand.

171. Further, in the Indian securities market, stock brokers play a crucial role in initiating and hand holding the investors and in channelizing their investments into the securities market. In this context, reputed and established brokerage houses who cater to lakhs of investors play the role of credible gateways for the investors to enter into the securities market. In such a scenario, when an investor receives a recommendation from the end of a reputed stock broker, he is most likely to act upon such recommendation. In the instant matter, if the IDs (BT-ZROHDA, BT-ICISEC, etc.) from where the SMSs were sent giving buy recommendations in the five afore-stated scrips are examined including the website namely www.midcapgains.in, one can clearly ascertain that the SMSs sender / website owner was trying to deceive the innocent investors by using the Sender IDs in such a manner that closely resembled some of the major brokerage houses viz. Zerodha Broking Ltd., ICICI Securities, etc. Such a deceptive behaviour of the kingpin, Mr. Hanif Shekh, did not stop merely at prima facie manipulating the volumes and prices of the aforementioned five scrips in inducing investors through the SMSs, but he went ahead and attempted to impersonate the big brokerage houses in order to prima facie give credence to the historical price movement in the said five scrips (mainly caused by the PV Influencers) as well as to reinforce the authenticity of the misleading buy recommendations made

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling through those bulk SMSs. In the said process, the kingpin alongwith his connected entities as well as with other set of entities including Promoters of some of these Companies generated huge amount of wrongful gains by employing the afore-discussed prima facie scheme while dealing in the aforesaid five scrips. The following table succinctly chalks out the details of scrip wise aggregate amount of wrongful gains earned by various entities in the process of implementing the afore discussed prima facie manipulative and fraudulent scheme: Table No. 67 Scrip Wrongful gains earned the relevant entities (amount in INR) Mauria Udyog Ltd 67,06,08,145 Vishal Fabrics Ltd 32,30,68,639 7NR Retail Ltd 29,60,46,866 GBL Industries Ltd 4,39,37,085 Darjeeling Ropeway Company Ltd 10,42,39,741 Total 1,43,79,00,476 (One hundred forty-three crore seventy nine lakh and four hundred seventy six only)

Directions

172. Keeping in view the aforesaid facts and circumstances and the detailed deliberations on the fraudulent trade practices indulged in by different entities, and also keeping in view the prima facie commission of the alleged violation of securities laws by the entities through their acts in the aforesaid five scrips, which have prima facie led to unlawful enrichment of the entities in the manner discussed as above, I observe that it is a fit case to pass interim directions to insulate the securities market from the mischievous acts of the entities and also to urgently prevent these entities from continuing with their prima facie fraudulent activities while dealing in the securities market. Further, there is an urgency to protect the wrongful gains from getting siphoned off beyond the regulatory reach. Accordingly, I, in exercise of the Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling powers conferred upon me under Sections 11, 11 (4), 11B (1) read with Section 19 of the SEBI Act hereby by way of the present interim order issue the following directions, which shall remain in force until further order:

In the scrip of Mauria Udyog Ltd

172.1. The entities mentioned at Table No. 12, Table No. 13, Table No. 14 and Table No. 20 alongwith Mr. Navneet Kumar Sureka (Entity no. 8), Ms. Deepa Sureka (Entity no. 9), Mauria Udyog Ltd. (Entity no. 10) and Vee Em Infocenter Ltd. (Entity no. 11) are restrained from buying, selling or dealing in the securities market or associating themselves with the securities market, either directly or indirectly, in any manner whatsoever until further orders. If the aforesaid entities 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 entities 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.

172.2. An amount of INR 33,48,04,829/- being the wrongful gains generated in the scrip of MUL by the employment of the prima facie scheme as discussed in preceding paragraphs is impounded, jointly and severally from the entities mentioned at Table No. 13, Table No. 14 and Table No. 20 alongwith Mr. Navneet Kumar Sureka (Entity no. 8) and Ms. Deepa Sureka (Entity no. 9).

172.3. An amount of INR 26,19,68,781/- being the wrongful gains generated in the scrip of MUL by the employment of the prima facie scheme as discussed in preceding paragraphs is impounded, jointly and severally from the Mr. Navneet Kumar Sureka (Entity no. 8), Ms. Deepa Sureka (Entity no. 9), Mauria Udyog Ltd. (Entity no. 10), Vee Em Infocenter Ltd. (Entity no. 11) and entities mentioned at Table No. 20.

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling

In the scrip of Vishal Fabrics Ltd

172.4. The entities mentioned at Table No. 20, Table No. 39, Table No. 40 and Table No. 41 are restrained from buying, selling or dealing in the securities market or associating themselves with the securities market, either directly or indirectly, in any manner whatsoever until further orders. If the entities 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 entities 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.

172.5. An amount of INR 1,34,67,773/- being the wrongful gains generated in the scrip of VFL by the employment of the prima facie scheme as discussed in preceding paragraphs is impounded, jointly and severally from the entities mentioned at Table No. 20, Table No. 39, Table No. 40 and Table No. 41.

172.6. An amount of INR 30,96,00,866/- being the wrongful gains generated in the scrip of VFL by the employment of the prima facie scheme as discussed in preceding paragraphs is impounded, jointly and severally from the entities mentioned at Table No. 20 and Table No. 39.

In the scrip of 7NR Retail Ltd

172.7. The entities mentioned at Table No. 20, Table No. 46 and Table No. 47 are restrained from buying, selling or dealing in the securities market or associating themselves with the securities market, either directly or indirectly, in any manner whatsoever until further orders. If the entities 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 entities are permitted

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling 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.

172.8. An amount of INR 29,60,46,866/- being the wrongful gains generated in the scrip of 7NR by the employment of the prima facie scheme as discussed in preceding paragraphs is impounded, jointly and severally from the entities mentioned at Table No. 20, Table No. 46 and Table No. 47.

In the scrip of GBL Industries Ltd

172.9. The entities mentioned at Table No. 20, Table No. 55 and Table No. 56 are restrained from buying, selling or dealing in the securities market or associating themselves with the securities market, either directly or indirectly, in any manner whatsoever until further orders. If the entities 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 entities 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.

172.10. An amount of INR 4,39,37,085/- being the wrongful gains generated in the scrip of GBL by the employment of the prima facie scheme as discussed in preceding paragraphs is impounded, jointly and severally from the entities mentioned at Table No. 20, Table No. 55 and Table No. 56.

In the scrip of Darjeeling Ropeway Company Ltd

172.11. The entities mentioned at Table No. 20, Table No. 64 and Table No. 65 alongwith Mr. Himanshu Shah (Entity no. 167) are restrained from buying, selling or dealing in the securities market or associating themselves with the securities market, either directly or indirectly, in any manner whatsoever until further orders. If the entities have any open position in any exchange traded derivative contracts, as on the date of the order, they can close out /square off

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling such open positions within 3 months from the date of order or at the expiry of such contracts, whichever is earlier. The entities 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.

172.12. An amount of INR 2,68,397.3/-being the wrongful gains generated in the scrip of Darjeeling by the employment of the prima facie scheme as discussed in preceding paragraphs is impounded, jointly and severally from the entities mentioned at mentioned at Table No. 20 and Table No. 64 alongwith Mr. Himanshu Shah (Entity no. 167).

172.13. The entities as mentioned at paragraph 172.2, 172.3, 172.5, 172.6, 172.8, 172.10 and 172.12 above are directed to credit/deposit the aforesaid respective amount of wrongful gains into an interest bearing Escrow Account or Savings a/c with a lien marked in favour of SEBI created specifically for the purpose in a Nationalized Bank. The Escrow Account(s) and/or Savings Account(s) shall create a lien in favour of SEBI and the monies kept therein shall not be released without permission from SEBI. The credit/deposit of aforesaid unlawful gains in the Escrow Account(s) and/or Savings Account(s) shall be made within a period of 15 days from the date of the Order. 172.14. Banks are directed that no debits shall be made, without permission of SEBI, out of the bank accounts held jointly or severally by the entities as mentioned at paragraph 172.2, 172.3, 172.5, 172.6, 172.8, 172.10 and 172.12, except for the purposes of transfer of funds to the Escrow Account(s) and/or Savings Account(s) to be created as directed above at paragraph no. 172.13. Further, the Depositories are also directed that no debit shall be made, without permission of SEBI, in the demat accounts held by the aforesaid persons (mentioned at paragraph 172.1, 172.4, 172.7, 172.9, and 172.11).

However, credits, if any, into the bank accounts and demat accounts maybe allowed. Banks and the Depositories are directed to ensure that all the aforesaid directions are strictly enforced. However, debits in the bank accounts may also be allowed in Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling the event the amounts available in the said accounts are in excess of the amount directed to be impounded above at paragraph nos. 172.2, 172.3, 172.5, 172.6, 172.8, 172.10 and 172.12. Banks are allowed to debit the accounts for the purpose of complying with this Order. It is clarified that once the impounding amount has been deposited by the entities as directed in this Order, the Banks would defreeze their accounts held by them. 172.15. The Registrar and Transfer Agents are directed to ensure that, they neither permit any transfer nor redemption of the securities, including Mutual Funds units, held by the entities (mentioned at paragraph 172.1, 172.4, 172.7, 172.9, and 172.11). 172.16. The entities (mentioned at paragraph 172.2, 172.3, 172.5, 172.6, 172.8, 172.10 and 172.12) are directed not to dispose of or alienate any of their assets/properties/securities, till such time the amount of wrongful gains is credited to Escrow Account(s) and/or Savings Account(s) as directed at paragraph no. 172.13 above, except with the prior permission of SEBI.

In case of failure to deposit the amounts within the timelines as directed at paragraph no. 172.13 above, such entities 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 within 7 working days from the date of completion of 15 days given to open an Escrow Account(s) and/or Savings Account(s) to deposit the wrongful gains as directed at paragraph no. 172.13 above.

173. The prima facie observations/findings contained in this Order are made on the basis of the materials available on record. In the light of the alleged violations of the provisions of the SEBI Act and PFUTP Regulations by the entities as stated in this order, this Order shall be treated as a show cause notice under Sections 11(1), 11(4), 11(4A), 11B (1), 11B (2) and 11(5) of SEBI Act, read with SEBI (Procedure for Holding

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling

Inquiry and Imposing Penalties) Rules, 2005, calling upon all the entities to show cause as to why certain directions including some as proposed below shall not be passed against them, as proposed hereunder:

173.1. Direction to disgorge an amount equivalent to the total wrongful gains (as mentioned in table below) made on account of the alleged manipulative and fraudulent trades, along with interest @ 12% per annum, if any thereon; Table No. 68 Scrip Amount of Entities jointly and severally liable for wrongful gains wrongful Gains (in INR) 7,38,34,535 Entities mentioned at Table No. 15 alongwith Mr. Navneet MUL Kumar Sureka (Entity no. 8) and Ms. Deepa Sureka (Entity no. 9) 33,48,04,829 Entities mentioned at Table No. 13, Table No. 14 and Table No. 20 alongwith Mr. Navneet Kumar Sureka (Entity no. 8) and Ms. Deepa Sureka (Entity no. 9). 26,19,68,781 Entities mentioned at Table No. 20 alongwith Mr. Navneet Kumar Sureka (Entity no. 8), Ms. Deepa Sureka (Entity no. 9), Mauria Udyog Ltd. (Entity no. 10) and Vee Em Infocenter Ltd. (Entity no. 11). 1,34,67,773 Entities mentioned at Table No. 20, Table No. 39, Table No. VFL 40 and Table No. 41 30,96,00,866 Entities mentioned at Table No. 20 and Table No. 39 29,60,46,866 Entities mentioned at Table No. 20, Table No. 46 and Table 7NR No. 47 4,39,37,085 Entities mentioned at Table No. 20, Table No. 55 and Table GBL No. 56. 10,39,71,344 Entities mentioned at Table No. 20 and Table No. 66 Darjeeling alongwith Mr. Bhavin Shah (Entity no. 201) and Mr. Kevin Kapadia (Entity no. 202). 2,68,397.3 Entities mentioned at Table No. 20 and Table No. 64 alongwith Mr. Himanshu Shah (Entity no. 167).

173.2. Direction to restrain them from accessing the securities market and prohibiting them from buying, selling or otherwise dealing in securities for an appropriate period;

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling

173.3. Direction to restrain them from associating themselves with the securities market, either directly or indirectly, in any manner and 173.4. Directions for imposition of monetary penalty under Sections 11B (2) and 11(4A) read with Section 15HA of the SEBI Act as may be deemed appropriate under SEBI Act. 174. The entities may file their reply with SEBI within 21 days from the date of receipt of this Order and avail an opportunity of personal hearing in the matter, if they so desire. 175. This Order is without prejudice to any other action that SEBI may initiate under the securities laws, as deemed appropriate, against the above mentioned persons/ entities. 176. This Order shall come into force with immediate effect and shall be in force till further Order. 177. A copy of this Order shall be forwarded to the entities, Stock Exchanges, Depositories, Registrar and Share Transfer Agents and Banks to ensure necessary compliance.

-Sd- DATE: JUNE 19, 2023 S. K. MOHANTY PLACE: MUMBAI WHOLE TIME MEMBER SECURITIES AND EXCHANGE BOARD OF INDIA

List of Enclosures: Sl. No. Particulars 1. Godaddy Replies 2. FEPL Replies

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling

Sl. No. Particulars 3. Awadh Info Replies 4. Spark TG Replies 5. Newrise securities Replies 6. Hanif Shekh – UCC details 7. Hanif Shekh communication with SEBI 8. CDR-location 9. Indigo Submission 10. Yahoo- Hanif email id 11. CDR- 9537570268- Call wth Awadh Info, Spark TG 12. Same IMEI Number -CDR 13. Make My Trip Replies 14. Swiggy Replies 15. Forgot Password – dgfindia website 16. Mauria Udyog Ltd PV data 17. MKSKA – partners and Bank statement 18. Address of MKSKA, Vepar and Juscorp 19. E-mail of Juscorp – MCA, directorship- Supriya Agarwal 20. Bank statements of Mauria Group-01 -LTP contributors 21. Bank statement of Mauria Group-02 -LTP contributors 22. UCC of Kalpesh Dantani and Goenka Business 23. Fund transfer from Mauria Employees to Kalpesh Dantani

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling

Sl. No. Particulars 24. Shyam Kumar Singh- KYC, address 25. Director details of Corredor services 26. Fund transfer among Group-01 LTP Contributors 27. K M Enterprise Bank statement 28. Fund transfer between MKSKA&CO and Group-01 LTP Contributors 29. Kamal Gupta and Piyush Agarwal friends 30. Mauria Trade Log 31. Scrips under ASM LT Stage -1 32. Darjeeling price movement – SMS period 33. Mauria – Reply – Employee List 34. Mauria connected entities- Bank KYC 35. Mauria connected entities- Bank account- Union Bank 36. CBDT Reply- ITR 37. Gmail reply- Google 38. Linkwise Marketing Pvt Ltd- Rent Agreement -Sign Deepak Garg 39. UCC details of all entities 40. UCC- Deepak Kumar Garg 41. Ahmedabad –Subgroup 02 bank statements 42. Ahmedabad Bank KYC 43. Mauria Bank statements 44. Net Sellers trading pattern across SMS scrips.

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling

Sl. No. Particulars 45. Glorious and Highgrowth address and director 46. Kolkata –Subgroup 3 Bank Statements 47. DK Jain, Econo Trade, Linkup Address 48. Arun Laha n group Bank- IP address 49. Arun Laha n group broker data- IP address 50. Linkup Gmail data 51. Shareholding pattern – Kolkata entities 52. Sub-group 2 and Sub-group 2.A bank statement 53. Ahmedabad- Sub-group 2.A bank statement 54. Kolkata- Sub-group 3.A bank statement 55. D K Jain, Amuly, MR Merchants shareholding 56. Reply of Hanif Shekh 57. Robert resources Ltd, Sai Metaltech LLP details 58. Econo Trade India Details 59. Econo broking details 60. Hanif@bansalonline.com details 61. Bank statement of Hanif entities 62. Android device id of Briya, Purple, Kanungo 63. Replies of Supreme securities and Ebixcash World Money 64. Bank statement of Forex Companies 65. Bank transfer between Samukh Trade and Mauria Entities

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling

Sl. No. Particulars 66. Bank transfer between Armeva/Frexon and Mauria Entities 67. Bank transfer between K M Enterprise and Forex Companies 68. Forex and hanif related fund transactions( Ahmedabad and Kolkata entities) 69. Fund transfer between Ahmedabad and Kolkata entities – Bank statement of Sub-group 2.A and 3.A 70. Kolkata entities IP address- Bank provided 71. Common director- Nandu Shaw 72. Relation/connection between Gemmy, Donum, Velox, Malacca 73. Bank statement of NIlratan, Briya, Kanungo, Lagan barter, Purple 74. Forex replies – No bills 75. 7 NR and Aneel& CO, Samukh Trade transfers 76. 7 NR and Kolktata entities 77. Trading details of Kolkata entities across scrip 78. Address- DK Jain and Econo Trade 79. Fund transactions between Kolkata entities(Linkup, Glorious, Highgrowth) and Hanif entities (Nilratan, Lagan barter, 80. BForiryeax) a. nd Kolkata bank statement 81. 7 N R Retail Ltd related entities-bank statements. 82. Forex Companies KYC-Bank, RBI approval letter 83. Forex- Authorised representative submission 84. Trading pattern Mauria entities 85. Forex GST registrations 86. Trading pattern of Ahmedabad based entities

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling

Sl. No. Particulars 87. Kolkata entities bank transaction with hanif related entities 88. ITR- Complete- Incommensurate Income 89. Shareholding pattern- Ahmedabad based 90. No reply to Summons 91. Complaints- Zerodha 92. SMS-headers compilation-CDR 93. Vishal- SMS details 94. PV- GBL 95. PV- Darjeeling Ropeway 96. Profit- Mauria Connected 97. Connection of Darjeeling Group 98. Profit- Ahmedabad based 99. Profit- Kolkata based 100. P rofit- Gohil group 101. P rofit- Vishal group 102. P rofit- Mauria LTP contributors 103. P rofit- Darjeeling LTP contributors 104. C ombined bank statement 105. V ishal- Popular Softtech reply 106. S ai Metaltech LLp – OBC/PNB and SBI 107. H anif statement recording

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling

Sl. No. Particulars 108. V ishal- Zomato Reply 109. V ishal- Hotel Hilton Reply 110. T rade Log- 7NR 111. T rade Log- Darjeeling 112. P V-7NR 113. P V-GBL 114. F und transfer- Ramu Jsoneya and Chintukumar Pandya 115. P V-Vishal 116. T rade log- GBL 117. C onnection table- Vishal 118. T rade Log- Vishal – NSE and BSE 119. F und Flow- Gohil group- 7 NR 120. V ishal- Dubai Fund flow 121. I mpact on Retail Investors 122. S ubmission- Sub-group 01 123. E -mail – D.K. Gupta- Contractor shares 124. S ubmission- Sub-group 02 125. S ubmission- Sub-group 2.A 126. S ubmission- Sub-group 3 127. S ubmission- Sub-group 3.A 128. S ubmission- Sub-group 4

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling

Sl. No. Particulars 129. S ubmission- Sub-group 5 130. S ubmission- Sub-group 5.A 131. S ubmission- Sub-group 6 132. S ubmission- Sub-group 7 133. S ubmission- LTP-Mauria –Group 01 134. S ubmission- LTP-Mauria –Group 02 135. S ubmission- LTP-Darjeeling 136. S ubmission- LTP-7 NR 137. S ubmission- LTP-GBL 138. S ubmission- LTP-Vishal 139. C onnection-7 NR Retail Ltd

Interim Order-cum-Show Cause Notice in the matter of Mauria Udyog Ltd., 7NR Retail Ltd., Darjeeling