Interim Order in the matter of MI Research(Proprietor - Ashish Jain)

Under Sections 11(1), 11(4) and 11B of the Securities and Exchange Board of India Act, 1992 and Regulation 35 of Securities and Exchange Board of India (Intermediaries) Regulations, 2008

In Re: Securities and Exchange Board of India (Investment Advisers) Regulations, 2013 In respect of:

S. No. Name of the Entity PAN 1 MI Research and its Proprietor Mr. Ashish Jain ANIPJ1043K

In the matter of MI Research

1. MI Research, a proprietary firm (hereinafter referred to as “MIR” / “IA”) is registered as an Investment Adviser under the Securities and Exchange Board of India (Investment Advisers) Regulations, 2013 (hereinafter referred to as the “IA Regulations”) with effect from November 02, 2017. The SEBI registration No. is INA000008783. The proprietor of MI Research is Mr. Ashish Jain. The registered office address of MI Research is at 18, Old Palasia, 101, AB Kanchan Sagar Apartment, Indore. M.P. – 452001.

2. Securities and Exchange Board of India (“SEBI”) received complaints through SCORES portal against an unregistered entity namely, A2 Financial Services, a partnership firm (hereinafter referred to as “A2FS”), inter alia prima facie alleging the engagement in unregistered investment advisory activities. The partners of A2FS are Mr. Ashish Jain and Mr. Ashutosh Mishra.

Interim Order in the matter of MI Research – Ashish Jain

3. SEBI conducted an examination in relation to the affairs of A2FS. The examination entailed inter alia an analysis of the details available on the website of A2FS, complaints filed by the complainants and bank account details of A2FS. The prima facie findings based on the examination are noted in the subsequent paragraphs.

4. Upon perusal of Account Opening Forms (AoF) and KYC documents of A2FS obtained from ICICI bank and Axis Bank, it was observed that one of the partners Mr. Ashish Jain, having PAN: ANIPJ1043K, is currently registered with SEBI as an Investment Advisor under the proprietorship MI Research.

5. Upon perusal of the Application Form A submitted by Mr. Ashish Jain at the time of applying for registration of MI Research, the following was observed:

5.1. Mr. Ashish Jain through his application dated March 14, 2017 has declared that he was not engaged in investment advisory services prior to making the said application. 5.2. Mr. Ashish Jain once again in his revised application dated July 24, 2017, has again declared that he was not engaged in investment advisory services prior to making the said application.

6. I have perused the materials available on record such as details available on the website of A2FS, complaints filed by the complainants against A2FS, bank account details of A2FS and Application FORM – A submitted by MI Research etc. A preliminary examination of the material available raises the prima facie question of whether A2FS carried on / engaged in unregistered Investment Advisory activities and whether MI Research had submitted wrong information to SEBI while obtaining certificate of registration under IA Regulations. In view of the facts and circumstances of the case, the following prima facie issues arise for determination in the instant matter:

1) Whether the activities of Mr. Ashish Jain, one of the Partner of A2FS, prima facie, are in the nature of unregistered Investment Advisory activities?

Interim Order in the matter of MI Research – Ashish Jain

2) If answer to issue no. 1 is in affirmative, whether MI Research, Proprietor Mr. Ashish Jain had submitted wrong information to SEBI while obtaining the certificate of registration under IA Regulations? 3) If answer to issue no. 2 is in affirmative, whether urgent directions, if any should be issued against MI Research and its Proprietor Mr. Ashish Jain?

ISSUE NO. 1: Whether the activities of Mr. Ashish Jain, one of the Partner of A2FS, prima facie, are in the nature of unregistered Investment Advisory activities?

7. Upon examination the following prima facie findings were observed against A2FS (Mr. Ashish Jain):

8. Examination of the details available on website of A2FS: The website www.a2financial.co.in of the entity was browsed for information, but the same was not active / functional. The archive pages of the website was downloaded from www.archive.org to gather information and the following was observed wherein the Company has claimed as follows: 8.1. A2FS is India’s no.1 accurate tips providing company which basically provides quality calls for stocks- Cash and F&O traded in NSE, & BSE, Commodities including bullion, metals and agro commodities traded in MCX, NCDEX & Forex. 8.2. The Vision and Mission is to be the best advisory in terms of service and job provider. They provide best quality services in terms of research and client satisfaction. 8.3. It is providing services in various categories viz., Stock cash tips, Stock Future tips, Stock option, Commodity Tips, Nifty Futures, MCX tips, BTST/STBT pack, FIIs, FOREX, etc. 8.4. Various packages were being offered for subscription at specified rates and for specific products. One such illustration is given below: Commodity Tips – We provide market informative tips in commodity market by keeping an eye on the global market. Commodity tips cover all the precious metals, base metals and energy products. 8.5. The fee ranges from Rs.10,000/- per month to Rs.85,000/- per year.

Interim Order in the matter of MI Research – Ashish Jain

8.6. The payment to subscribe to the services can be made directly to the bank accounts opened in the name of A2FS with ICICI Bank (A/c No. 091605500514), Axis Bank (A/c No. 914020056109429) and SBI (A/c No. 34704656278) respectively, the details of which were mentioned on their website.

9. Examination of bank accounts of A2FS: The Account Opening Forms (AoF), KYC documents and transaction/ account statements of bank accounts of A2FS obtained from ICICI Bank, Axis Bank and SBI were examined and following is observed:

9.1. ICICI Bank (A/c No. 091605500514)

9.1.1. A/c No. 091605500514 was opened in November 2014 in the name of partnership firm, A2FS, having its address at 215, president Tower 6/2, South Tukoganj, Indore. 9.1.2. Email Id given is a2financial@yahoo.com 9.1.3. The partners are Mr. Ashish Jain, having PAN: ANIPJ1043K and Mr. Ashutosh Mishra, PAN: BLBPM4170N. 9.1.4. As per the AOF, the type of industry is Share advisory consultancy. 9.1.5. A2FS has received credits aggregating to Rs.79,80,378/- between December 2014 and January 2018. Out of Rs.79 lakhs, there were credits from PayU Money into the bank account which amounted to Rs.22,09,197/-. Further, there were also credits into ICICI bank account from Atom payment gateway amounting to Rs.18,38,302/. 9.1.6. Credits from PayU Money were observed to be between June 2015 and March 2017, and credits from Atom gateway were from March 2016 to January 2018. 9.1.7. From the transaction / bank statement it appears that the entity was active till January 2018, and credits from Atom gateway was observed upto the month of January 2018. 9.1.8. Balance amount available in the a/c as on January 25, 2018 is Nil balance. 9.1.9. Analysis of bank account revealed that there were 217 credit transactions which were in round figure ranging from Rs.500/- to Rs.1,51,800/- aggregating to Interim Order in the matter of MI Research – Ashish Jain

Rs.39,32,879/- (excluding credits from payment gateways). These amounts prima facie appears to have been collected as an advisory fee. Further, A2FS has also collected money for its advisory services through PayU Money and Atom payment Gateway amounting to Rs. 40 lakhs.

9.2. Axis Bank (A/c No. 914020056109429)

9.2.1. A/c No. 914020056109429 was opened in December 2014 in the name of A2 Financial Services (PAN: ABBFA0964B), having its address at 215, President Tower 6/2, South Tukoganj, Indore. 9.2.2. Email Id given is ashish@a2financial.co.in 9.2.3. The partners are Mr. Ashish Jain having PAN: ANIPJ1043K and Mr. Ashutosh Mishra, PAN: BLBPM4170N. 9.2.4. As per the partnership deed dated September 06, 2014, A2 Financial is in the business of providing tips and advisory services in commodity and equity share market. 9.2.5. The entity has received credits aggregating to Rs.18,43,500/- between January 2015 and July 2017. 9.2.6. Balance amount available in the A/c as on July 22, 2017 is Nil balance. 9.2.7. Analysis of bank account revealed that there were 133 credit transactions which were in round figure ranging from Rs.1000/- to Rs.3,00,000/ aggregating Rs. 18,43,500/-. Debit transactions were mainly in the form of cheque payments to the two partners and various third parties.

9.3. SBI (A/c No. 34704656278)

9.3.1. From the partial bank account statements received from SBI, it is observed that the entity has received credits aggregating to Rs.10,06,902/- during the period February 2015 and May 2017. 9.3.2. Balance amount available in the a/c as on November 2, 2018 is Nil balance. Interim Order in the matter of MI Research – Ashish Jain

9.3.3. SBI was unable to provide a copy of the KYC as the same is no longer available in their records.

9.4. Analysis of aforesaid bank accounts revealed that A2FS has prima facie collected money for its advisory services through PayU Money and Atom payment Gateway amounting to Rs.40 lakhs. In aggregate, prima facie it appears that A2FS has collected Rs.1,08,30,780/-in the name of advisory fee. The amount credited into the various bank accounts held by A2FS is as under:

Sl. no Bank Account No Transaction Aggregate Value of Credit Period Transactions (in Rs.) 1. ICICI Bank A/c No. December 2014 79,80,378 091605500514 to January 2018 2. Axis Bank. A/c No. January 2015 to 18,43,500 914020056109429 July 2017 3. SBI A/c No. February 2015 10,06,902 34704656278 to May 2017 Total 1,08,30,780 4. Credits through PayU Money and Atom 40,47,499* gateway* *Sl. No. 4 entry is included in Sl No. 1 entry

10. Complaints filed by the complainants against A2FS:

10.1. The complainant Mr. Dilip Jaubani vide complaint dated February 23, 2015 has inter-alia, alleged that he started services from A2FS to receive stock tips and they stated they will provide very accurate tips, however, A2FS made him incur loss. Mr. Dilip Jaubani submitted the copy of email dated February 02, 2015 received from A2FS. The extract of email is as under:

“Greetings from A2FINANCIAL SERVICES! (Research home) We have charges applicable for the services of Stock Cash.

Interim Order in the matter of MI Research – Ashish Jain

Services Charges - BASIC PREMIUM BTST Monthly - 7000 25000 49000 Quarterly - 15000 50000 1 lakh Our Company provide Daily 2-3 calls per day BASIC PREMIUM BTST MONTHLY CALLS- 75-80 25-30 15-20 Our company provide per call Profit on first Target BASIC PREMIUM BTST Daily Profit – 1% SL 1.5% SL 2% SL Min 2% Trgt 4% Trgt 5% Trgt (1-2 Days Holding) Profit Sharing (Terms N Conditions) Registration Charges – 4000 then pay after 15 days to 15 days, 25% of your profit. But now as a offer (Offer_id-off02_04) Note: We provide 25% off on Registration Charge and 5% off on profit Sharing before 4 of Feb For more information visit http://www.a2financial.co.in Or Call 24*7 - 8109000014”

11. In summary, following prima facie findings are observed: 11.1. That as per the partnership deed between Mr. Ashish Jain and Mr. Ashutosh Mishra dated September 06, 2014, the partnership firm in the name of A2 Financial Services is in the business of providing tips and advisory services in commodity and equity share market from August 18, 2014. 11.2. That as per the information disclosed on A2FS website, it is providing investment advisory services. 11.3. That A2FS in its website has disclosed the bank accounts details and link to PayU Money payment gateway for payment of advisory fee. The payments through cash / other deposits and credits from payment gateways were observed in the account of A2FS from December 2014 to January 2018. This shows that A2FS has received consideration for its advisory services from December 2014 to January 2018.

Interim Order in the matter of MI Research – Ashish Jain

11.4. That A2FS vide email dated February 02, 2015 to complainant Mr. Dilip Jaubani had stated their charges applicable for the services of Stock Cash.

12. Meanwhile I note that, as per section 4 of Indian Partnership Act, 1932, the ‘partnership’ is the relation between persons who have agreed to share the profits of a business carried on by all or any of them for all; persons who have entered into partnership with one another are called individually ‘partners’ and collectively a ‘firm’ and the name under which their business is carried on is called the ‘firm name’. As per Section 2(a) of Indian Partnership Act, 1932 an ‘Act of Firm’ means any act or omission by all the partners, or by any partner or agent of the firm which gives rise to a right enforceable by or against the firm. As per Section 25 of Indian Partnership Act, 1932 every partner is liable, jointly with all the other partners and also severally, for all acts of the firm done while he is a partner.

13. Thus, from the above it is noted that an act done by all or any partner of the partnership firm is an act by the partnership firm and vice versa. Hence, in the present case, the activities carried out by A2FS are basically the activities carried out by its partners and in the limited context of the present matter, Mr. Ashish Jain who was one of the partners of A2FS.

14. The definition of investment adviser as given in regulation 2(m) of the IA Regulations, states that investment adviser means “any person, who for consideration, is engaged in the business of providing investment advice to clients or other persons or group of persons and includes any person who holds out himself as an investment adviser, by whatever name called”. Regulation 2(l) of the IA Regulations defines investment advice as “advice relating to investing in, purchasing, selling or otherwise dealing in securities or investment products, and advice on investment portfolio containing securities or investment products, whether written, oral or through any other means of communication for the benefit of the client and shall include financial planning.”

15. Thus, from paragraphs 8, 9, 10, 11, 12, 13 and 14 above, there is a prima facie evidence that Mr. Ashish Jain as partner of A2FS was engaged in ‘investment advisory services’ through Interim Order in the matter of MI Research – Ashish Jain

A2FS, which falls under the definition of investment advice and investment advisor as defined under Regulations 2(l) & 2(m) of IA Regulations.

16. The regulation 3(1) of the IA regulations, states that “On and from the commencement of these regulations, no person shall act as an investment adviser or hold itself out as an investment adviser unless he has obtained a certificate of registration from the Board under these regulations”.

17. The proviso to Regulation 3 of the IA Regulations states that “a person acting as an investment adviser immediately before the commencement of these regulations may continue to do so for a period of six months from such commencement or, if it has made an application for a certificate … within the said period of six months, till the disposal of such application.” The IA Regulations were notified on January 21, 2013. The IA Regulations came into effect on April 21, 2013. Therefore, any person who had been providing investment advisory service before the IA Regulations came into effect can, by virtue of the proviso under regulation 3, continue to do so without a certificate of registration till October 20, 2013, beyond which the said person would have to obtain a certificate of registration or may continue to do so till the time his application for registration is disposed of.

18. Further, Section 12(1) of the Securities and Exchange Board of India Act, 1992 (hereinafter referred to as “SEBI Act”) states that “No stock broker, sub -broker, share transfer agent, banker to an issue, trustee of trust deed, registrar to an issue, merchant banker, underwriter, portfolio manager, investment adviser and such other intermediary who may be associated with securities market shall buy, sell or deal in securities except under, and in accordance with, the conditions of a certificate of registration obtained from the Board in accordance with the regulations made under this Act”

19. Thus, as per regulation 3(1) of IA Regulations and Section 12(1) of SEBI Act, any person carrying out investment advisory activities has to necessarily obtain registration from SEBI and conduct its activities in accordance with the provisions of SEBI regulations i.e. the registration of the investment advisers is mandatory.

Interim Order in the matter of MI Research – Ashish Jain

20. The activities of A2FS, as brought out from the various materials described above, seen in the backdrop of the aforesaid provisions shows that A2FS through its partners has acted as investment advisers. However, no material was available on record to indicate that A2FS has a certificate of registration as investment adviser. Therefore, I find that the activities of A2FS through its partners, including Mr. Ashish Jain, such as giving trading tips, stock specific recommendations, etc. to the investors and general public on payment of fees clearly indicate that they were engaged in providing unregistered investment advisory services.

21. In this context, it is noted that A2FS is not registered with SEBI in the capacity as an Investment Advisor and the characteristics and features of the business activity carried out by A2FS as discussed in the preceding paragraphs, prima facie, leads to the conclusion that Mr. Ashish Jain being one of the partners of A2FS had provided services of an investment adviser through A2FS without a certificate of registration during the period August 18, 2014 to January 2018.

22. Additionally, SEBI has also taken note of the complaints made against A2FS. The said complaints have not been relied upon to arrive at the aforesaid prima facie findings against the A2FS, nevertheless have been reproduced below to have a complete representation of the actions against A2FS.

22.1. The complainant, Mr. Dinesh Kumar vide complaint dated March 01, 2017 has alleged that he had invested Rs.3 lakhs in A2FS in September 2016 and A2FS had said that they will invest the said amount on their own. He had not received a single documentary details for the trades made on his investment. Now A2FS neither responding nor taking any responsibility of his investment.

22.2. The complainant, Mr. Kastubh Agrawal vide complaint dated February 10, 2017 has alleged that he was told to pay Rs. 25,000/- and promised to get a return of Rs. 80,000/-in 1-2 months. Subsequently, they asked for more payment, on refusal of which they are refusing to return the initial money. Interim Order in the matter of MI Research – Ashish Jain

22.3. The complainant, Ms. Nirmala Hulle vide complaint dated January 19, 2016 alleged that he joined investment advisory services of A2FS on November 16, 2015. Till January 19, 2016 he had paid a total amount of Rs. 2,50,000 / - for the process and upon claiming refund, the company is not refunding the amount.

23. SEBI has a statutory duty to protect the interests of investors in securities and promote the development of, and to regulate, the securities market. Section 11 of the SEBI Act has empowered it to take such measures as it thinks fit for fulfilling its legislative mandate. IA Regulations have been formulated with the main objective of regulating such activities to safeguard the interests of investors and hence registration of such activities with SEBI has been made mandatory. IA Regulations inter alia seek to create a structure within which investment advisers will operate and also make them duly accountable for their investment advice by requiring investment advisers to comply with the criteria set out in the relevant provisions of the IA Regulations. The same is imperative for the protection of interests of investors and to safeguard the integrity of the securities market. In the instant case, the A2FS and its partner Mr. Ashish Jain were soliciting and inducing the investors to deal in securities market on the basis of their investments advice, stock tips etc. prima facie without having the requisite registration / certification as mandated under IA Regulations. This prima facie indicates that Mr. Ashish Jain being one of the partners of A2FS was carrying on unregistered investment advisory activity through A2FS and was in violation of the provisions of Section 12(1) of the SEBI Act and regulation 3(1) of the IA Regulations.

24. Thus, there is prima facie evidence that by being partner of A2FS (PAN: ABBFA0964B), Mr. Ashish Jain (PAN: ANIPJ1043K) had carried on unregistered investment advisor activities through A2FS from August 18, 2014 to January 2018 which is prima facie in violation of Section 12(1) of SEBI Act read with Regulations 3(1) of the IA Regulations.

Interim Order in the matter of MI Research – Ashish Jain

ISSUE NO. 2: If answer to issue no. 1 is in affirmative, whether MI Research, Proprietor Mr. Ashish Jain had submitted wrong information to SEBI while obtaining the certificate of registration under IA Regulations?

25. Before the second issue is determined, it would be apposite to refer to the passage from the judgment of the Hon’ble Supreme court in Ashok Transport Agency v. Awadhesh Kumar & another, [(1998) 5 SCC 567] regarding the legal status of the proprietary firm. “…..A proprietary concern is only the business name in which the proprietor of the business carries on the business. A suit by or against a proprietary concern is by or against the proprietor of the business…”.

26. For obtaining registration from SEBI under IA regulations, an applicant has to submit an application in the prescribed FORM – A as specified in the first schedule of IA Regulations, along with the declaration that “whether the applicant is engaged in investment advisory services prior to making application under these regulations”.

27. Upon perusal of the document available on record i.e. Application FORM – A dated March 14, 2017 and July 24, 2017 submitted by Mr. Ashish Jain, Proprietor, MI Research, I find that Mr. Ashish Jain, proprietor, MI Research, had twice submitted the undertaking that he was not involved / engaged in investment advisory services prior to making the said application. I also find that on the basis of said declaration and other documents attached to the said application FORM, SEBI had granted registration to Mr. Ashish Jain, proprietor, MI Research under IA Regulations on November 02, 2017. It is also noted that Mr. Ashish Jain, Partner, A2FS and Mr. Ashish Jain, proprietor, MI Research are one and the same person. Thus, there is a prima facie findings that Mr. Ashish Jain, as a Partner of A2FS has carried on unregistered investment advisory activities from August 18, 2014 to January 2018 i.e. prior and after obtaining SEBI registration (registration granted on November 02, 2017) in the name of Mr. Ashish Jain, proprietor, MI Research.

Interim Order in the matter of MI Research – Ashish Jain

28. It is found that Mr. Ashish Jain while applying to SEBI for registration as an Investment Advisor through the proprietorship MI Research, had prima facie submitted false and misleading undertaking to SEBI stating that “…I am not involved in any Investment Advisory activity prior to filling application to SEBI. Further I am also submitting that I will not engage in any Investment Advisory activity before getting registration from SEBI”. Further, it is found that Mr. Ashish Jain, prima facie involved in unauthorized / unregistered investment advisory services through A2FS before applying to SEBI for registration and continued to carry out unauthorized / unregistered investment advisory services through A2FS even after obtaining SEBI registration. By rendering unregistered investment advisory services and by willfully concealing the same and submitting false and misleading information to SEBI, Mr. Ashish Jain has committed illegal acts and created unlawful gain to himself in the form of obtaining certificate of registration from SEBI. Further, as per Regulations 13(b) of IA Regulations, Mr. Ashish Jain, proprietor MI Research, after obtaining SEBI registration, was under an obligation to inform SEBI in writing, if any information or particulars previously submitted to SEBI are found to be false or misleading.

Thus, it is noted that even after obtaining SEBI Registration Mr. Ashish Jain, proprietor MI Research failed to submit the correct information to SEBI in accordance with Regulations 13(b) of IA Regulations. 29. Thus, Mr. Ashish Jain, prima facie by continuing to carry out unauthorized / unregistered investment advisory services through A2FS, even after obtaining SEBI Registration and also by not informing SEBI in writing about the prima facie wrong / false undertaking to SEBI, after obtaining the SEBI Registration, has not acted in honesty and fairness, thereby prima facie violating the Clause 1 of Code of Conduct for Investment Adviser read with regulation 15(9) of IA Regulations. The said clause requires an investment adviser to act honestly, fairly and in the best interests of its clients and in the interest of integrity of the market. Even though at the first instance it may appear as a mere code of conduct violation, it needs to be seen what is the conduct which is in question that made Mr. Ashish Jain, Proprietor of MI Research to violate this provision. Providing false information to the Regulator who assess the suitability of granting a certificate of registration to the Investment Adviser is a serious prima facie violation of code of conduct as it goes to the very root of the conditions of the registration.

Interim Order in the matter of MI Research – Ashish Jain

ISSUE NO. 3: If answer to issue no. 2 is in affirmative, whether urgent directions, if any should be issued against MI Research and its Proprietor Mr. Ashish Jain?

30. Considering the facts and circumstances of the present matter and on the basis of prima facie findings, it is necessary to take urgent preventive action in this matter and to take immediate steps, to prevent, Mr. Ashish Jain, proprietor, MI Research from taking any new clients, which would be on the basis of SEBI registration obtained through wrongful means. SEBI has a mandate of promoting the orderly development of the securities market. SEBI Act also empowers through section 11B of the SEBI Act, interim directions to be passed if it is necessary for the orderly development of securities market. Allowing such Investment adviser, who has obtained certificate of registration prima facie on the basis of wrong and incorrect information, to register new clients, would not be in the interest of orderly development of the securities market. 31. I note that MI Research website is in operation. Therefore, the probability of investors reaching MI research through a website is high. Further, the risk of any new investors getting attracted to the registered advisory services, for which SEBI registration was obtained through wrongful means, is still looming large and is imminent.

It may be argued that activities of Mr. Ashish Jain, proprietor, MI Research, should be stopped completely at this interim stage itself to protect all the existing and incoming clients. However, I note that the existing clients have already committed investments and the nature of the prima facie violation is not one which can support stopping of existing activities at interim stage, in respect of the existing clients. However, I consider it would be in the fitness of the things, not to permit Mr. Ashish Jain, proprietor, MI Research to accept new clients. Permitting Mr. Ashish Jain, proprietor, MI Research to accept new clients (whose access to his service can be stopped at this stage) would expose the new clients to the service to be rendered by Mr. Ashish Jain, proprietor, MI Research whose conduct in obtaining the certificate of registration is prima facie, wrongful. Therefore, the balance of convenience is also not in favour of Mr. Ashish Jain, proprietor, MI Research. In light of the same, I find that there is no other alternative but to take recourse through an interim ex-parte order against MI Research and its proprietor Mr. Ashish Jain for preventing it from registering any new clients.

Interim Order in the matter of MI Research – Ashish Jain

ORDER:

32. In view of the foregoing, I, in exercise of the powers conferred upon me under Sections 11(1), 11(4) and 11B read with Section 19 of the SEBI Act and Regulation 35 of Securities and Exchange Board of India (Intermediaries) Regulations, 2008 hereby direct by way of this interim ex-parte order, that MI Research and its proprietor, Mr. Ashish Jain stands prohibited from accepting any fresh clients until further orders. MI Research shall disclose the contents of these directions on its website(s) immediately and submit certificate of compliance with evidence to SEBI.

33. This Order is without prejudice to the right of SEBI to take any other action that may be initiated against MI Research and its proprietor Mr. Ashish Jain in accordance with law.

34. The prima facie observations contained in this Order, pending enquiry, are made on the basis of the material available on record. In this context, MI Research and its proprietor Mr. Ashish Jain may, within 21 days from the date of receipt of this Order, file their reply/objections, if any, to this Order and may also indicate whether they desire to avail an opportunity of personal hearing on a date and time to be fixed on a specific request to be made in that regard.

35. The above directions shall take effect immediately and shall be in force until further orders.

36. A copy of this order shall be served upon MI Research and its proprietor Mr. Ashish Jain, Banks, Stock Exchanges, Registrar and Transfer Agents and Depositories for necessary action and compliance with the above directions.

-Sd- Date: August 30, 2019 MADHABI PURI BUCH Place: Mumbai WHOLE TIME MEMBER SECURITIES AND EXCHANGE BOARD OF INDIA

Interim Order in the matter of MI Research – Ashish Jain