Interim order in the matter of Moryo Industries Ltd[SAT Appeal No.:136/2016]

WTM/RKA/ 140 /ISD/2014 SECURITIES AND EXCHANGE BOARD OF INDIA EX-PARTE AD- INTERIM ORDER UNDER SECTION 11(1), 11(4) AND 11B OF THE SEBI ACT, 1992 - IN THE MATTER OF MORYO INDUSTRIES LIMITED.

1. Securities and Exchange Board of India (SEBI), during surveillance noticed huge rise in the traded volumes and price of the shares of Moryo Industries Limited {hereinafter referred to as "Moryo"} on the Bombay Stock Exchange Limited (BSE) during the period from January 15, 2013 to August 31, 2014 (hereinafter referred to as "Examination Period"). Pursuant thereto it undertook preliminary inquiry in the dealings in the scrip during the said period.

2. It was noticed that during the period from January 15, 2013 to November 08, 2013 (Patch 1), the price of the scrip rose from `93.4/- to `101.74/, i.e. an increase of 8% in 107 trading days with an high of `138.6. From November 09, 2013 to August 31, 2014 (Patch 2), the price of the scrip had further increased from `106.05 to `225, i.e. an increase of 112% in 172 trading. Such price/volume movement in the scrip of Moryo during the Examination Period is given below: No.of Shares Close Price 250 300000 250000 200 200000 150 150000 100 100000 50 50000 0 0 3 3 3 3 3 3 3 3 3 3 3 3 4 4 4 4 4 4 4 4 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 n 7 a 1 J - - b 7 e 1 F - - r a 7 M 1 - - r p 7 A 1 - - y a 7 M 1 - - n 7 u 1 J - - l 7 u 1 J - - g u 7 A 1 - - p 7 e 1 S - - t c 7 O 1 - - v o 7 N 1 - - c e 7 D 1 - - n 7 a 1 J - - b 7 e 1 F - - r a 7 M 1 - - r p 7 A 1 - - y a 7 M 1 - - n 7 u 1 J - - l 7 u 1 J - - g u 7 A 1 - -

3. On November 09, 2012 Moryo had made preferential allotment of its 63,50,000 shares at the price of `25/- per share to 42 persons (list provided in Annexure A). On January 15, 2013, the shares of Moryo were split in the ratio of 1:2. Consequent to these action of Moryo its Order in the matter of Moryo Industries Ltd total number of paid up shares increased by 12,700,000 shares in FY 2012-13. The shares allotted on preferential basis to aforesaid allottees were locked -in for a period of year till November 08, 2013 in terms of Securities And Exchange Board Of India (Issue of Capital And Disclosure Requirements) Regulations, 2009. Thus, these shares held by the said 42 allottees pursuant to preferential allotment and split were not tradable till November 08, 2013.

4. It was further noted that Moryo had been consistently incurring losses and during FY 2011- 12, FY 2012-13 and FY 2013-14 it had reported losses of `91,043/-, `1,32,370/- and `1,428,739/-, respectively. It was observed that its revenue had increased to `5,34,91,444 during FY 20112-13 as against its revenue of `1,10,00 during FY 2011-12. The company's revenue were generated out of its share trading activities which were exclusively into the shares of its connected companies. The company did not have any business activities during financial year 2012-13. Though in its annual report it had shown salary amounting to `25 lakh purportedly paid to its employees. However, no debits are found in its bank account corresponding to such salary payment. Further, during the Examination Period, there was no corporate announcement. Strangely, in spite of such poor fundamentals and no business and financial standing, Moryo was able to raise `15,87,50,000/- by issuing 63,50,000 shares to the aforesaid 42 entities at `25/- per share. Investment in a company having such poor and meagre fundamentals cannot prima facie be termed as rational investment behaviour. Such investments, as in this case, normally could be made only if the allottees had nexus with Moryo and its directors/promoters and the issue of these shares was under a pre-arrangement between them.

5. The sharp price rise in the scrip as discussed above was not supported by fundamentals of Moryo or any other genuine factor. The price and volume both in the scrip increased prior to the expiry of the lock-in period on the shares held by the aforesaid allottees pursuant to preferential allotment/split. After the expiry of the lock-in period, the price and volume in the scrip further increased substantially. Considering such pattern, the trading in the scrip in two patches as aforesaid was analysed. The analysis of the trading during the aforesaid two (2) patches was carried out with a focus on the following:-  The trading frequency;  The volume generated;  Contribution to price rise;

 Buying behaviour as observed from Last Traded Price (LTP) data.

6. It was observed that during the Examination Period, certain entities related/connected to Moryo had substantially traded amongst themselves in shares of Moryo and created artificial volume and contributed to the artificial price rise in the scrip. Their inter-relationship/connection were noted from the Know Your Client (KYC) details, their bank statements, off-market transactions amongst themselves, and information available on the Ministry of Corporate Affairs (MCA) website. Considering the large number of these related/connected entities, it was deemed necessary to shortlist those who were closely connected to Moryo and/or were instrumental in the price rise and/or contributed in volume of Moryo during the Examination Period. A set of such entities (given at Annexure - B and hereinafter referred to as the "Moryo Group") was shortlisted on the basis of following parameters, viz.

A. Top entities based on gross buy/trade quantity; B. Top entities based on positive contribution in last traded price (hereinafter referred to as "LTP"); C. Promoters/Directors of Moryo who transacted with other members of Moryo Group by way of funds / securities or, had any other relationship with them.

7. During Patch 1(January 15, 2013 to November 08, 2013), the scrip opened at `93.4(post-split price) on January 17, 2013 and closed at Rs 101 on November 08, 2013. The scrip touched a high of `138.6 during this period. During this period, involving 107 trading days, the scrip was traded with an average of 1363 shares per day and an average of 3 trades per day. It was observed that Moryo Group contributed significantly to the volume traded during this period. It is observed that it contributed 34.87% to the gross trade and 69.76 % to the gross buy in Patch 1.The trades of Moryo Group during Patch 1 is given below: Table: I Gross Vol% - Vol% - Buy Gross Gr Buy Gr Trd Client Pan Client Name Vol Trade Vol Vol/Mkt Vol/Mkt AADCR6342Q Nidhi Dhanuka 28032 28032 19.21 9.60 ASIPP8140N Vasudev B Panchal 16000 16000 10.96 5.48 Insight Multitrading AACCI9518C Private Limited 15556 15558 10.66 5.33 AADCR6341P Savita Sonavane 12500 12500 8.57 4.28 AAACK1804B Kamalakshi Finance 10210 10210 7.00 3.50

Corporation Limited Limestone Properties AACCL0133G Private Limited 8000 8000 5.48 2.74 AAACV7299K Victory Sales Pvt. Ltd. 5000 5000 3.43 1.71 Sampada Chemicals AACCS7980C Limited 4000 4000 2.74 1.37 ATYPB5376M Sagar Girish Bhatt 2500 2500 1.71 0.86

8. During Patch 2 (November 09, 2013 to August 31, 2014), the price of the scrip moved from `106.05 on November 13, 2013 to `225 on August 27, 2014. The scrip touched a high of `241.5 on June 24, 2014. During this period, involving 172 trading days, the scrip was traded with an average of 51275 shares per day and an average of 150 trades per day. As compared to Patch 1, in Patch 2 the average volume increased by 3661% and price increased by 112%. The preferential shares were also unlocked for sale on November 09, 2013. It is observed that during Patch 2, the allottees were net sellers and entities forming part of the Moryo Group were net buyers, a snapshot of which is given below:- Table: II Net Sell Net Net %/ Net Buy%/ Sell Mkt Buy Mkt Preferential 7480122 84.84% - - Allottes Moryo Group - - 7119898 82.60%

9. As it can be observed from the Table II that most of the trades were happening between the allottees and the entities of Moryo Group. The details of trades of Moryo Group entities is attached as Annexure C.

10. It was also observed during Patch 2 that entities of Moryo Group were trading above the last traded price (LTP) and were mainly responsible for price rise in Patch 2 .The details of the entities of Moryo group trading above LTP is given below:-

Table: III Client Pan Client Name Overall Pos LTP Total No Total Pos LTP Contri of of Trade Trade of Contri by the Client Above Client the Client as a buyer LTP As Client Buyer In Mkt AABCO7262J Olympia Multitrading 58.8 58.8 42 1625 Private Limited AABCS1202L Surface Finance Pvt. 22.7 22.7 36 4087 Ltd. AADCI0407P Isairis Trading Private 23.45 23.45 25 852 Limited AADCR6341P Savita Sonavane 23.45 23.45 23 947 AADCR6342Q Romy Realty Private 13.5 13.5 33 1231 Limited AAECG9026 Garth Mercantile Private 63.7 35.2 59 6516 D Limited AAGPK7011 Shivkumar Kaushik 14.2 14.2 8 200 H AAJCM1338F Mahasvin Trading 20.1 20.05 3 41 Private Limited AASCS6284R Shivsathi Mercantile 18.65 18.65 6 76 Private Limited AAWHS0331J Sanjay Jethalal Soni 13 13 3 272 HUF ADMPP1798B Anand Kamalnayan 35.2 35.2 19 211 Pandit AHDPD3526 Amul Gagabhai Desai 27.45 12.05 5 196 G ANDPC7557J Suryakant Chanpur 9.55 9.55 12 59 ANGPJ6430Q Saurabh Surendra Jadhav 15.35 15.35 4 66 BVSPS9740P Soni Krupa Sanjay 28.6 21.55 6 505 BVSPS9741N Sanjay Jethalal Soni 20.6 20.6 5 64 11. During the same period, the allottees were found to be selling and in the process gaining a huge profit/gain. It is observed that 38 allottees made a collective profit of `141.3 Crores on a collective investment of `9.3 Crores, a whopping 1519 % increase in their investment in a period of 20 months (including the lock in period). The cost of investment being the allotment price multiplied by the number of shares sold. This profit was obtained in a stock where the fundamentals/financials of the company do not justify the price. It is evident from the above analysis of Patch 2 that the entities of Moryo Group provided a hugely profitable exit to the allottees. The profit/gain earned by the allottees during Patch 2 is given below:-

Table: IV Gross Sell Purchase Client Name Gr Sell Value Profit Made Vol Value Amardeep Kadam 800000 1,00,00,000 15,89,44,913 14,89,44,913 Chetna Nareshakumar Chandan 400000 50,00,000 8,25,06,940 7,75,06,940 Jagdish R Prajapati huf 400000 50,00,000 7,71,03,958 7,21,03,958 Vivek Kejriwal huf 400000 50,00,000 8,55,12,225 8,05,12,225 Bhikhabhai H Prajapatti HUF 400000 50,00,000 7,70,52,003 7,20,52,003 Nikunj Arvindbhai Desai 400000 50,00,000 8,39,43,625 7,89,43,625 Vivekkumar Kejriwal 400000 50,00,000 8,51,30,366 8,01,30,366 Naresh Balram Khatar 400000 50,00,000 7,88,09,082 7,38,09,082 Kavita B Singi 400000 50,00,000 7,82,76,068 7,32,76,068 Sanjay Anchaliya 358750 44,84,375 7,16,37,070 6,71,52,695 Veenu Jain (HUF) 250000 31,25,000 5,29,47,550 4,98,22,550 Anilkumar Manoharlal Aggarwal 236000 29,50,000 4,60,28,125 4,30,78,125 Sumit Vinod Gupta 200000 25,00,000 4,34,66,750 4,09,66,750 Devang Bhupendra Shah 200000 25,00,000 3,78,09,080 3,53,09,080 Deepak Saraf Huf 200000 25,00,000 3,91,33,900 3,66,33,900 Suchek Suresh Anchaliya 180500 22,56,250 3,48,22,653 3,25,66,403 Shivshankar Chunilal Joshi 173900 21,73,750 3,69,57,470 3,47,83,720 Vijay Hasmukhrai Bhayani 170050 21,25,625 3,41,36,550 3,20,10,925 Jugal Kishore Chirania HUF 143300 17,91,250 2,99,66,070 2,81,74,820 Pratap Uttam Purohit 141451 17,68,138 2,80,65,879 2,62,97,742 Sanjeev Chirania Huf 141002 17,62,525 3,10,62,883 2,93,00,358 Sachin Gokuldas Mehta 118000 14,75,000 2,24,21,758 2,09,46,758 Sudheer Jugalkishore Chirania HUF 106861 13,35,763 2,42,97,981 2,29,62,219 Yash Devendra Jalan 105000 13,12,500 1,92,52,500 1,79,40,000 Shah Narendra Chintan 91400 11,42,500 1,83,04,220 1,71,61,720 Sumit Jalan 63000 7,87,500 1,13,44,400 1,05,56,900 Manish Jagdish Prasad Saraf 62806 7,85,075 1,37,18,034 1,29,32,959 Amit Jalan 62000 7,75,000 1,11,26,900 1,03,51,900 Maha Devi Agrawal 60000 7,50,000 1,14,97,523 1,07,47,523 Sanjeev Kumar Agrawal 60000 7,50,000 1,13,51,800 1,06,01,800 Anand Kumar Agarwal 60000 7,50,000 1,13,42,000 1,05,92,000 Rajeev Kumar Agarwal 60000 7,50,000 1,15,44,000 1,07,94,000 Priti Akhilesh Mehta 53102 6,63,775 94,92,005 88,28,230 Naresh Kumar Chandan 42000 5,25,000 77,29,000 72,04,000 Devendra Mangturam Jalan 41000 5,12,500 81,34,900 76,22,400 Sanjeev Jugalkishore Chirania 40000 5,00,000 91,34,155 86,34,155

Manish Suresh Shah 30000 3,75,000 63,14,000 59,39,000 Nirav Anil Shah 30000 3,75,000 64,33,500 60,58,500 Total 7480122 9,35,01,525 1,50,67,51,835 1,41,32,50,310

12. The transactions wherein the entities of Moryo Group bought most of the shares sold by the allottees cannot be just a coincidence particularly when sellers have nexus with Moryo and its promoters/directors and buyer are entities connected with Moryo and its promoters directors. From the analysis presented for Patch 1, it was established that the shares of Moryo were not in demand by the general investors of the market and saw very low volume on most of the trading days and hence could not have commanded the price as observed in Patch 2. In any market, a sudden supply if not matched by similar demand leads to price fall. Considering the same, any rational investor would not have dumped a large number of shares without facing the risk of a significant price fall until and unless he was sure of the demand side absorbing the supply. In this case, the entities of Moryo Group created the demand against the supply from the preferential allotters. In the whole process, the principle of market driven price discovery was seriously breached. It is evident from the above analysis that Moryo Group entities provided a hugely profitable exit to the allottees. This could be only possible if the allottees, Moryo Group entities and Moryo and its promoter/ directors were hand in glove with each other.

13. During preliminary inquiry Moryo submitted that it had invested 66% of proceeds of preferential allotment in shares of listed as well as unlisted companies and rest of the money was given as loans and advances to certain entities as given in the following table:- Table : V Investments Shares Values 1. B anas Finance Ltd 2,80,34,913 2. C onfidence Trading Co. Ltd 26,37,751 3. E saar (India) Ltd 72,39,206 4. O ut of City Travel Solutions Ltd 1,71,83,697 5. S hreenath Commercial and Finance Ltd 4,77,66,900 6. K ayaguru Capital Market Pvt. Ltd 2,00,000 7. Daga Strips Pvt. Ltd 2,75,000 Total 10,33,37,467 Loans & Advances 1. R upak Developers Pvt. Ltd 25,34,000 2. S anjay V Parmar 25,00,000 3. F ragrant Multitrading Pvt. Ltd 26,85,000 4. R ockon Capital Market Pvt. Ltd 2,56,62,000

5. K ayaguru Capital Market Pvt. Ltd 1,18,00,000 6. I nsight Multitrading Pvt. Ltd 27,50,000 7. Y ashasvi Developers Pvt. Ltd 25,00,000 Total 5,04,31,000

14. From the copy of the special resolution passed under section 81(1A) of the Companies Act, 1956 as available on BSE website it is noted that Moryo had disclosed to its shareholders and public that the purpose of aforesaid fund raising through preferential allotment was to meet requirements for - a) capital expenditure including acquisition of company/business b) funding long term working capital requirements c) marketing d) setting up of offices abroad and e) for other approved corporate purposes.

15. The aforesaid utilisation of proceeds of preferential allotment does not appear to be for any of the aforesaid purposes as Moryo did not use them for either capital expenditure or acquisition of company/business or towards working capital or setting up office abroad or for marketing. Further in the common business parlance general corporate purposes provide the framework for ongoing decisions and activities of the business. In this case, as discussed above, Moryo did not have any business operations during relevant period.

16. On examination it was observed that most of the companies mentioned at Table V had a common promoter, i.e., Mr. Giriraj Kishore Agarwal (GKA). Companies mentioned at Sr. no. 1 to 6 in the above Table in which Moryo invested and entities mentioned at Sr. no. 1 to 6 to whom loans and advances were given, are connected to Mr. Giriraj Kishore Agarwal. It was submitted by Moryo during the preliminary inquiry that all its aforesaid loans and advances granted, were without any loan agreement. Such informal financing arrangement without any documentation clearly indicates that these entities were known or connected to Moryo.

17. From Annexure B it is observed that entities of Moryo Group who were providing exit to the allottees were also closely related to Mr. Giriraj Kishor Agarwal. The entities receiving funds from Moryo as aforesaid had funds transfers with the entities of Moryo Group providing exit to the allottees. Further, during submissions of the documents, Moryo was represented by Mr. Manhohar Lal Saraf, Director and Mr. Pankaj Trivedi. Mr. Manohar Lal Saraf informed that Mr. Pankaj Trivedi is the authorised representative of Moryo. It was also informed by Mr. Saraf that Mr. Pankaj Trivedi is not an employee of Moryo but an employee of Company Secretary(CS) Firm, ID Joshi & Associates. However, the identity proof submitted by Mr. Pankaj Trivedi showed that he is an employee of Mr. Giriraj Kishore Agarwal. The bank account statement of Mr. Pankaj Trivedi also showed that he received his salary from Shreenath Commercial & Finance Ltd, a company with Mr. Giriraj Kishor Agarwal as one of its directors. This shows that Moryo was represented by an employee of Mr. Giriraj Kishore Agarwal. This further corroborates the relation between Mr. Giriraj Kishore Agarwal and Moryo.

18. During preliminary inquiry certain entities of Moryo Group who had purchased shares during Patch 2 were called along with their trading members when only one of them; namely, Mr. Saurabh Surendra Jadhav who had bought shares of Moryo worth `1.48 Crores appeared and informed that he earns a monthly salary of only `10,000/. He also informed that he was not aware of the activities conducted under his trading or bank account. He said that he was paid by his friend Mr. Deepak Suryakant Chavan `2000 per month for letting his trading and bank account being used. He further stated that he was approached by Mr. Deepak Suryakant Chavan, who guided him in opening of trading account and bank accounts. Mr. Deepak Suryakant Chavan, is also one of the buyers in Patch 2, wherein he had purchased of shares of Moryo to the tune of `1.1 Crore. Mr. Deepak Suryakant Chavan, as evident from his bank account statements is of same economic background as Mr. Saurabh Surendra Jadhav and hence his purchases are not commensurate with his economic capability. An analysis of the bank account statement of Mr. Saurabh Surendra Jadhav and Deepak Suryakant Chavan is listed below: Table: VI Saurabh Surendra Jadhav- Funds Flow Vis-à-vis Trade In Moryo Funds Received From Total Credit Funds Transferred to Total Debit Samskara Sales Agency 50950000 Sumpoorna Portfolio 106400000 Kajal Trading 7555000 Mahasvin Trading Pvt. Ltd 9300000 Keshariya Metal Pvt. Ltd 11970000 Samay Corporation 2500000 Petrel Trades Pvt. Ltd 4700000

Flannery International 5900000 Arvind Broking Co 3000000 Total 95875000 Total 106400000 Deepak S Chavan - Funds Flow Vis-à-vis Trade In Moryo Fund received from Total Credit Funds transferred to Total Debit Artiya Enterprises 5650000 Sampoorna Portfolio 80658750 Kamalpushap Barter 2000000 Vinayaka Enterprises 900000 Meghdoot Trading 25450000 Vinit Enterprises 1623750 V M Traders 4913250 Vijaya Enterprises 17025000 Umesh Tiwari 16787000 Kartick Kamila 3050000 Kajal Trading 7950000 Hardsoft Realcon 2500000 Bohra Brothers 1000000 Bhavya Enterprises 3500000 Mahasvin Trading 3700000 Total 96049000 80658750

19. From Table VI, it is observed that the bank account of the above mentioned entities had a huge inflow of funds from different entities and the outflow is primarily to the trading member towards purchase of shares. It was also observed that some of the individuals transferring funds to the above mentioned entities were themselves receiving the funds through cash deposits, which were immediately transferred to the above mentioned entities.

20. A similar fund flow pattern was observed across all Moryo Group of entities who were found to be trading in Patch 2. It was observed that all of Moryo Group entities providing an exit to the allottees, received funds from various sources and the money received was transferred to their trading member towards purchase of shares of Moryo. Most of the Moryo Group entities are private limited companies, engaged in various kind of businesses.

However, the analysis of bank account statement reveals that they have only indulged in routing of funds. On most of the instances, the funds received by them were immediately transferred to a trading member or to another entity. It was observed that there was a significant layering by way of funds transfers hiding the true identity of ultimate owner.

21. It was also observed that some of the allottees and their promoted companies had bank transactions with Moryo Group on more than one occasion. Further some of the allottees had transferred funds to the entities of Moryo Group, who had in turn, transferred them to trading members, on most of the occasions. These facts clearly establish that Moryo Group entities mentioned in below mentioned table were connected to allottees and the funds from the allottees were used by the entities of Moryo Group for capital market activities. A snapshot of the same is provided below:- Table: VII Allottees Moryo Group a)Anand Kumar Agarwal a)Five X Finance & Investment b)Mahadevi Agarwal Ltd c)Sanjeev Kumar Agarwal b)Banas Finance Ltd d)Rajeev Kumar Agarwal c)Esaar (India) Ltd. e)Mukund Madhav Hotels* a) Sanjeev Chirania a) Five X Finance & Investment b) Sudhher Chirania Ltd c) Aadishu Securities* b) Romy Realty Pvt. Ltd d)Perfect Corporate c) Rupak Developers Pvt. Ltd Services*

Jalan Texfab - Amit Jalan & Romy realty Pvt. Ltd Sumit Jalan are directors

Confidence Trading Rupak Developers Pvt. Ltd Company Ltd** Shiv Shankar C Joshi

* Promoted or Directorship companies of Preferential Allottees. ** Sanjay Anchaliya, one of the preferential allottee has the same address as of Confidence trading company, as mentioned in his application for the issue of preferential shares.

22. SEBI had also received a reference from the office of the director of Income Tax (Investigation), Kolkata, regarding usage of preferential allotment route for claiming long term capital gains (LTCG). From the information received from director of Income Tax it is noted that one operator Mr. Deepak Patwari, had confessed that he controls 7 paper/shell companies including a company named 'Elect Coal Pvt. Ltd.'. During the preliminary inquiry in the instant case, SEBI observed that Romy Realty Pvt. Ltd., an entity belonging to Moryo Group has made off market transfers to Elect Coal Pvt. Ltd. These facts and circumstance indicate that Romy Realty Pvt. Ltd. is also a part of such operator based activities in the securities market.

23. From the above examination and factors as described in Annexure B, I note that the allottees, Moryo and Moryo Group entities are connected to each other. In this regard, I note that the Hon'ble SAT has, in many cases such as Classic Credit Ltd. vs. SEBI (SAT Appeal no. 68/2003, Order dated December 8, 2006), Classic Credit Ltd. vs. SEBI (SAT Appeal no. 76/ 2003, Order dated January 9, 2007) and Veronica Financial Services Ltd. vs. SEBI (SAT Order dated August 24, 2012), held that connection/relations can be established on the basis of factors including the common addresses, common directors/ shareholders, etc.

24. It is pertinent to mention that the key to the scheme of operations employed by Moryo Group prima facie lies in the preferential allotment of shares made by Moryo. Due to a lock-in of one year on shares any gains made on the sale of such shares makes them eligible for long term capital gains (LTCG). From the observations of preliminary inquiry it is inter alia noted that :- a) the fund brought in by way of preferential allotment was invested in the shares of connected companies and by way of purported loans to a group of companies connected with Moryo and for purposes other than those disclosed; b) even when substantial number of shares, i.e., 63.5 lakh shares (127 lakh shares after split) were locked-in and non transferable/tradable the traded volume in the scrip and its price increased substantially only on account of purchases (70% of the gross buy) of Moryo Group entities; c) after the expiry of the lock-in period (i.e. in Patch 2) the price and volume both in the scrip further increased astronomically to the extent of 112% increase in price and 3661% increase in volume. Such increase in price and volume was mainly on account of matched trading amongst Moryo Group entities and allottees and their trading above LTP; d) 38 out of the 42 preferential allottees sold total 74,80,122 shares allotted to them by Moryo at the price increased on account of the aforesaid manipulative trading in Patch 2; e) the funds required for purchase of shares by Moryo Group entities had been provided to them through layering of fund transfers.

25. From the above facts and circumstances it can reasonably be inferred that the preferential allottees acting in concert with Moryo Group have misused the stock exchange system to generate fictitious LTCG so as to convert their unaccounted income into accounted one with no payment of taxes as LTCG is tax exempt. I prima facie find that the above modus operandi helped the concerned entities to avoid payment of taxes and to show the source of this income to be from legitimate source, i.e. investment in stock market.

26. In the facts and circumstances of this case, I am of the view that preferential allotment was used as a tool for implementation of the dubious plan, device and artifice of Moryo Group and allottees. One could argue that in the order to make LTCG, the preferential allottees in question could have bought in secondary market and waited for a year before selling the shares. In the instant case, probably the preferential allotment route was preferred over secondary market route because the share capital of Moryo prior to preferential allotment was very small, i.e., 1,900,190 shares (Face Value: `10) to accommodate the required fictitious LTCG of `141 crore approximately. As such the capital expansion through preferential allotment and stock split provided much bigger source to the persons involved in terms of volume and price manipulation to facilitate the whole operation.

27. Since prior to the trading in its scrip during the Examination Period, Moryo did not have business or financial standing in the securities market, in my view, the only way it could have increased its share value is by way of market manipulation. In this case, it is noted that the traded volume and price of the scrip increased substantially only after Moryo Group and allottees started trading in the scrip. The average volume increased by 3661 % during the examination period, i.e., from 1363 shares per day to 51275 shares per day & the price increased by 112% during the same period, i.e., `93 to `225. Moryo Group entities were trading in the scrip above the last traded price (LTP) and their trades created artificial volumes and manipulated the price of the scrip during the Examination Period. It is further noted that on the days when Moryo Group entities were not trading, the trading volumes in the scrip were very low and the substantial increase in traded volumes as observed in this case was mainly due to their trading. I further note that Moryo Group entities and allottees traded amongst themselves as substantiated by their matching contribution to net buy and net sell in Patch 2. There was no change in the beneficial ownership of the substantial number of traded shares as the buyers and sellers both were part of the common group and were acting in league/concert to provide LTCG benefits to the allottees. I prima facie find that Moryo Group and allottees used securities market system to artificially increase volume and price of the scrip for making illegal gains to and to convert ill-gotten gains into genuine one.

28. I am of the considered view that the schemes, plan, device and artifice employed in this case, apart from being a possible case of money laundering or tax evasion which could be seen by the concerned law enforcement agencies separately, is prima facie also a fraud in the securities market inasmuch as it involves manipulative transactions in securities and misuse of the securities market. The manipulation in the traded volume and price of the scrip by a group of connected entities has the potential to induce gullible and genuine investors to trade in the scrip and harm them. As such the acts and omissions of Moryo Group and allottees are ‘fraudulent’ as defined under regulation 2(1)(c) of the SEBI (Prohibition of Fraudulent and Unfair Trade Practices relating to Securities Market) Regulations, 2003 (‘PFUTP Regulations’) and are in contravention of the provisions of regulations 3(a), (b), (c) and (d) and 4(1), 4(2)(a), (b), (e) and (g) thereof and section 12A(a), (b) and (c) of the SEBI Act, 1992. The said regulations are reproduced hereunder:-

PFUTP REGULATIONS, 2003 Prohibition of certain dealings in securities 3. 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 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 fraudulent or an unfair trade practice in securities. (2) Dealing in securities shall be deemed to be a fraudulent or an unfair trade practice if it involves fraud and may include all or any of the following, namely:- (a) 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; (c)……………………………………………………………… ….. (d)…………………………………………………… …………… (e) any act or omission amounting to manipulation of the price of a security; (f)…………………………………………………… ………………. (g) entering into a transaction in securities without intention of performing it or without intention of change of ownership of such security;

29. In my view a detailed investigation of the entire scheme employed in this case is necessary to find out the role of any other entity therein including the stock brokers involved in transactions as observed in this case, connection amongst the concerned entities and the ultimate owners of funds used for manipulating the price of the scrip. I am also of the view that while SEBI would investigate into the probable violations of the securities laws, the matter may also be referred to other law enforcement agencies such as Income Tax Department, Enforcement Directorate and Financial Intelligence Unit for necessary action at their end as may be deemed appropriate by them.

30. SEBI strives to safeguard the interests of a genuine investor in the Indian securities market. The acts of artificially increasing the price of scrip mislead investors and the fundamental tenets of market integrity get violated with impunity due for such acts. Under the facts and circumstances of this case, I prima facie find that the acts and omissions of Moryo Group and allottees as described above is inimical to the interests of participants in the securities market. Therefore, allowing the entities that are prima facie found to be involved in such fraudulent, unfair and manipulative transactions to continue to operate in the market would shake the confidence of the investors in the securities market.

31. In this case it is noted that as on November 15, 2014 the allottees are still holding 4032070 shares of Moryo that were allotted to them in the aforesaid preferential allotment. The price of the scrip is still around `225 per share which is 9 times more than the allotment price. Unless prevented they may use the stock exchange mechanism in the same manner as aforesaid for the purposes of their dubious plans as prima facie found in this case. In my view, the stock exchange system cannot be permitted to be used for any unlawful/forbidden activities. Considering these facts and the indulgence of a listed company in such a fraudulent scheme, plan, device and artifice as prima facie found in this case, I am convinced that this is a fit case where, pending investigation, effective and expeditious preventive and remedial action is required to be taken by way of ad interim ex -parte in order to protect the interests of investors and preserve the safety and integrity of the market.

32. In view of the foregoing, in order to protect the interest of the investors and the integrity of the securities market, I, in exercise of the powers conferred upon me in terms of section 19 read with section 11(1), section 11 (4) (b) and section 11B of the SEBI Act, 1992, pending inquiry/investigation and passing of final order in the matter, hereby restrain the following persons/entities from buying, selling or dealing in the securities markets, either directly or indirectly, in any manner, till further directions:- Sl. No. Client Name Client Pan 1 MORYO INDUSTRIES LIMITED AACCM5166G Promoters of Moryo Industries Ltd 2 MOHAN JAIN AABPJ7629P 3 DEEPIKA MOHAN JAIN AABPJ7615H Directors of Moryo Industries Ltd 4 MANOHARLAL SARAF AAIPS7577C 5 GEETA MANOHARLAL SARAF ANMPS6842B 6 DEEPTI LALWANI AFUPL5641K 7 SHASHIKUMAR JATWAL ALMPJ4216E Preferential Allottees 8 VIVEK KUMAR KEJRIWAL ACXPV7536R 9 VIVEK KUMAR KEJRIWAL HUF AAEHV3659N

10 NARESH S CHANDAN AAKPC5639D 11 CHETNA NARESH CHANDAN AADPC1398N 12 KAVITA SHREEEAM SINGHI AMCPS1116K 13 MANISH JAGDISH SARAF AUHPS6394N 14 SANJAY ANCHALIYA AABPA2723R 15 SUCHEK SURESH ANCHALIYA AJNPA8807F 16 NIKUNJ ARVIND DESAI ACJPD9611P 17 VEENU JAIN HUF AAAHJ0626D 18 KAMAL JAJOO ABVPJ3150A 19 BHIKHABHAI H PRAJPATI HUF AAGHB7871J 20 JAGDISH B PRAJAPATI HUF AAEHJ9503P 21 AMARDEEP KADAM ALTPK8993J 22 RAJEEV KUMAR AGARWAL ACPPA7567H 23 MAHA DEVI AGARWAL ABMPA2745F 24 ANAND KUMAR AGARWAL ACMPA4421D 25 SANJEEV KUMAR AGARWAL ABMPA2770N ANILKUMAR AGGRAWAL ACSPA5647B 26 NEELI AGGRAWAL AAJPA1839J 27 PRITI A MEHTA ALAPM5609E 28 SHIVSHANKER C JOSHI AAEPJ8684M GEETABEN S. JOSHI AAJPJ8345A JITENDRA DHIRAJLAL VORA AABPV8208Q VARUN YOGESH VORA AFBPV3801J 29 MANTHAN MAHISH VORA AIAPV6436F 30 NARESH B KHATAR AGYPK5408L 31 VIJAY HASMUKRAI BHAYANI AAEPB8868P 32 SACHIN GOKULDAS MEHTA AACPM6569J CHITAN NARENDRA SHAH AKIPS1272J 33 DIPANI CHINTAN SHAH AMVPS8322G 34 JAYESH POATLAL SHAN AAGPS4118M KALPANA JAYESH SHAH ABDPS8106P 35 JUGAL KISHRE CHIRANIA-HUF AABHJ8023M 36 SANJEEV CHIRANIA HUF AARHS4527D 37 SUDHEER CHIRANIA HUF AARHS4528N DEVANG BHUPENDRA SHAH AADPS1211L 38 DEVAL DEVANG SHAH 39 JAIDEV GUPTA HUF AAFHJ5373N 40 VINOD KUMAR GUPTA HUF AAAHV5024M 41 SUMIT GUPTA AABPG7826K 42 DEEPAK SARAF HUF AAFHD0142R 43 AMIT JALAN AFDPJ7855G 44 SUMIT JALAN AFDPJ7853A

45 YASH JALAN AHIPJ7654E 46 DEVENDRA JALAN ADBPJ2163K 47 PRATAP UTTAM PUROHIT AFZPP9994A 48 MANISH S SHAH HUF AAFHM0782E NIRAV ANIL SHAH AAIPS1195G 49 ANISHA NIRAV SHAH MORYO GROUP 50 GARTH MERCANTILE PRIVATE LIMITED. AAECG9026D ROMY REALTY PRIVATE LIMITED/ NIDHI 51 DHANUKA AADCR6342Q 52 SURFACE FINANCE PVT. LTD AABCS1202L 53 OLYMPIA MULTITRADING PRIVATE LIMITED. AABCO7262J 54 ISAIRIS TRADING PRIVATE LIMITED. AADCI0407P 55 ANAND KAMALNAYAN PANDIT ADMPP1798B 56 SAVITA SONAVANE/ RUPAK DEVELOPERS PVT. LTD AADCR6341P SAMSKARA SALES AGENCY PRIVATE 57 LIMITED AATCS7717A 58 SHIVKUMAR KAUSHIK AAGPK7011H 59 GULMOHAR DEALCOM PRIVATE LIMITED AADCG9091K 60 TUSHAR R RANE AJCPR9314H 61 SAURABH SURENDRA JADHAV ANGPJ6430Q 62 TISHA TUSHAR RANE AHRPK8922D 63 SONI KRUPA SANJAY BVSPS9740P 64 MANGESH MADHUKAR DHOTRE AJPPD8297E 65 DEEPAK SURYAKANT CHAVAN AJAPC0258P 66 TOPWELL PROPERTIES PRIVATE LIMITED AADCT8403C SANJAY JETHALAL SONI (HUF) SANJAY 67 JETHALAL SONI (HUF) AAWHS0331J 68 ESAAR INDIA LTD AABCE0478J 69 SURYAKANT CHANPUR ANDPC7557J HELPFUL INVESTMENT ADVISORY 70 PRIVATE LIMITED AACCH4303G 71 WAKIL RAJBHAR AOSPR9100E 72 TANU GIRIRAJ AGARWAL AADPA7003J 73 SADAKIRTI DEALER PVT. LTD AANCS5873M 74 KAMALAKSHI FINANCE CORPORATION LIMITED AAACK1804B DHARTI DEVELOPERS AND 75 CONSTRUCTIONS PVT. LTD AADCD5959M 76 GANESH EKNATH CHANDANSHIVE ARWPC4266D

77 GIRISH RAJKUMAR GOEL BDLPG2634K 78 SAPNA RAMDAS JATWAL APNPJ7211C 79 KRUPALI MADHUKAR DHOTRE BIQPD4268L 80 GOODPOINT IMPEX PRIVATE LIMITED AAFCG0606G SHIVSATHI MERCANTILE PRIVATE 81 LIMITED AASCS6284R 82 SHALLOT DEALTRADE PRIVATE LIMITED AARCS4827R 83 VASUDEV B PANCHAL ASIPP8140N 84 LIMESTONE PROPERTIES PVT. LTD AACCL0133G 85 VICTORY SALES PVT. LTD AAACV7299K 86 SAMPADA CHEMICALS LTD AACCS7980C 87 SAGAR GIRISH BHATT ATYPB5376M 88 MAHASVIN TRADING PVT. LTD AAJCM1338F 89 KRUPA SANJAY SONI BVSPS9740P 90 AMUL GAGABHAI DESAI AHDPD3526G 91 GIRIRAJ KISHOR AGARWAL AABPA4928N

33. The stock exchanges and the depositories are directed to ensure that all the above directions are strictly enforced.

34. The persons/entities against whom this Order is passed may file their objections, if any, within twenty one days from the date of this order and, if they so desire, avail themselves of an opportunity of personal hearing before the Securities and Exchange Board of India, on a date and time to be fixed on a specific request, received from the said persons.

35. This order shall come into force with immediate effect.

Sd/ RAJEEV KUMAR AGARWAL PLACE: MUMBAI WHOLE TIME MEMBER DATE:DECEMBER 4th, 2014 SECURITIES AND EXCHANGE BOARD OF INDIA

Annexure A: List of Preferential Allottees Sr. Name of the Allottees PAN No. Shares Issued Post No. Split Holding 1 VIVEK KUMAR KEJRIWAL ACXPV7536R 200000 400000 2 VIVEK KUMAR KEJRIWAL HUF AAEHV3659N 200000 400000 3 NARESH S CHANDAN AAKPC5639D 200000 400000 4 CHETNA NARESH CHANDAN AADPC1398N 200000 400000 5 KAVITA SHREEEAM SINGHI AMCPS1116K 200000 400000 6 MANISH JAGDISH SARAF AUHPS6394N 200000 400000 7 SANJAY ANCHALIYA AABPA2723R 200000 400000 8 SUCHEK SURESH ANCHALIYA AJNPA8807F 200000 400000 9 NIKUNJ ARVIND DESAI ACJPD9611P 200000 400000 10 VEENU JAIN HUF AAAHJ0626D 200000 400000 11 KAMAL JAJOO ABVPJ3150A 200000 400000 12 BHIKHABHAI H PRAJPATI HUF AAGHB7871J 200000 400000 13 JAGDISH B PRAJAPATI HUF AAEHJ9503P 200000 400000 14 AMARDEEP KADAM ALTPK8993J 400000 800000 15 RAJEEV KUMAR AGARWAL ACPPA7567H 30000 60000 16 MAHA DEVI AGARWAL ABMPA2745F 30000 60000 17 ANAND KUMAR AGARWAL ACMPA4421D 30000 60000 18 SANJEEV KUMAR AGARWAL ABMPA2770N 30000 60000 19 ANILKUMAR AGGRAWAL ACSPA5647B 200000 400000 NEELI AGGRAWAL AAJPA1839J 20 PRITI A MEHTA ALAPM5609E 50000 100000 21 SHIVSHANKER C JOSHI AAEPJ8684M 150000 300000 GEETABEN S. JOSHI AAJPJ8345A 22 JITENDRA DHIRAJLAL VORA AABPV8208Q 100000 200000 VARUN YOGESH VORA AFBPV3801J MANTHAN MAHISH VORA AIAPV6436F 23 NARESH B KHATAR AGYPK5408L 200000 400000 24 VIJAY HASMUKRAI BHAYANI AAEPB8868P 100000 200000 25 SACHIN GOKULDAS MEHTA AACPM6569J 100000 200000 26 CHITAN NARENDRA SHAH AKIPS1272J 100000 200000 DIPANI CHINTAN SHAH AMVPS8322G 27 JAYESH POATLAL SHAN AAGPS4118M 100000 200000 KALPANA JAYESH SHAH ABDPS8106P 28 JUGAL KISHRE CHIRANIA-HUF AABHJ8023M 300000 600000 29 SANJEEV CHIRANIA HUF AARHS4527D 300000 600000 30 SUDHEER CHIRANIA HUF AARHS4528N 300000 600000

31 DEVANG BHUPENDRA SHAH AADPS1211L 100000 200000 DEVAL DEVANG SHAH 32 JAIDEV GUPTA HUF AAFHJ5373N 200000 400000 33 VINOD KUMAR GUPTA HUF AAAHV5024M 200000 400000 34 SUMIT GUPTA AABPG7826K 100000 200000 35 DEEPAK SARAF HUF AAFHD0142R 100000 200000 36 AMIT JALAN AFDPJ7855G 100000 200000 37 SUMIT JALAN AFDPJ7853A 100000 200000 38 YASH JALAN AHIPJ7654E 100000 200000 39 DEVENDRA JALAN ADBPJ2163K 100000 200000 40 PRATAP UTTAM PUROHIT AFZPP9994A 100000 200000 41 MANISH S SHAH HUF AAFHM0782E 15000 30000 42 NIRAV ANIL SHAH AAIPS1195G 15000 30000 ANISHA NIRAV SHAH

Annexure B: Relationship Amongst Moryo Group Entities Sr. Client Name and Address Phone No Email Id Director's Name N PAN & Address o. 1 Limestone 95A, C R 9748788721 sun_sand1980 Chiranjit Mahanta - Properties Private Avenue, 1st @gmail.com 147/1/17, Limited Floor, Kantadanga Road Kolkata, West (Purba), Bhatpara, (AACCL0133G) Bengal - 700073 Jagaddal, North 24 Parganas, Kolkata, West Bengal - 743129 Vishal Sharma – AB-40, Prafulla Kalan (W), Krishnapur, Near Kestopur, PO Kolkata - 700059 2 Topwell Properties 95A.C R 9831619980 sun_sand198 Chiranjit Mahanta - Private Limited Avenue 1st 0@yahoo.co 147/1/17, (AADCT8403C) Floor Kolkata m Kantadanga Road West Bengal (Purba), Bhatpara, 700073 Jagaddal, North 24 Parganas, Kolkata, West Bengal - 743129 Debi Prasad Pal - 7, Rabindra Sarani, Kolkata, West Bengal - 700001 3 Rupak Developers G-4-A, Govind 9324591724 Not available Pradeep Natvarlal Private Limited Rao Appt., Dhanuka - C-201, Navghar Pathak Shree Bhadrakali (AADCR6341P) Road, Near Darshan, Station Vimal Dairy, Road, Bhayandar Godden Naka, (W), Thane, 401101 Bhayandar Savita Sonawane - (East), Mumbai G-4-A-Wing, - 401105. Govind Rao Appt.,

Sr. Client Name and Address Phone No Email Id Director's Name N PAN & Address o. Navghar Pathak Road, Near Vimal Dairy, Godden Naka, Bhayandar (East), Mumbai - 401105. 4 Insight Multitrading Room No. 75, 8451948793 insightmultitra Gangji Ganesh Private Limited 2nd Floor, ding@yahoo.i Ravariya - Shop No Krishna n 6, Bandhut CHS (AACCI9518C) Bhuvan,. Parsi Ltd, Datta Mandir Panchayat Road, Road, Vakola Andheri, Bridge, Santacruz. Mumbai - Brinda Haresh 400069 Thaker - A/201, Rajesh Park, Vakola Pipe Line, Santacruz (E), Mumbai - 400055 6 Shree Nath E-109, Crystal 9322224089 shreenathcom Giriraj Agarwal - Commercial And Plaza, New Link mercialfin@g 305, Krishna A, Finance Limited Road, Opp mail.com Vishal Nagar, (AADCS8871M) Infinity Mall, Marve Road, Mith Andheri (W), Chowk, Malad (W), Mumbai – Mumbai – 400064 400053 Tanu Agarwal - 3- A/1601-2, Green Acre CHS, Plot No 324, Lokhandwala, Andheri Vipin Ladda - 307/B, Dwarkesh II, Sukla Compound, Dahisar (E) - 400068 7 Surface Finance Pvt. F-15, Lokmanya 9323244404 surfacefin@g Dauji Laddoo Ltd (AABCS1202L) Shopping mail.com Chaturved - T1- Centre, Shivaji 113, Link Garden Chawk, Staion Tower Oshiwara,

Sr. Client Name and Address Phone No Email Id Director's Name N PAN & Address o. Road, New Link Road, Bhayander (W), Andheri (West), Thane – 401101 Mumbai, 400053 Amit Gulecha - A 104, Pramukh Heights, 48 Amboli Hill, Behind Country Club, Veera Desai Road .Andheri Wes, Mumbai, 400058, Maharashtra, INDIA 8 Fragrant 9, Sharafali 8452042447 fragrantmultitr Anadiben Gangji Multitrading Private Building, Next ading@yahoo.i Ravariya - Shop Limited to V.K. n No. 6, Badhut (AABCF9874H) Industry, Opp. CHS, Datta Mandir Taj Quarter Pais Road, Vakola Street, Byculla Bridge, Santacruz (W), Mumbai - (E), Mumbai - 400011 400055 Laxmi Vishnu Borude - Rajiv Nagar, Vakola Pipe Line, Gavdevi, Santacruz (E), Mumbai - 400055 9 Five X Finance & E-109, Crystal 9322224089 fivexfinance@ Girraj Kishor Investment Limited Plaza, New Link gmail.com Agarwal - 3A, (AABCF5412H) Road, Opp. 1601/1602, Green Fame Adlabs, Acres, Andheri (W), Lokhandwala Mumbai – Complex, Andheri ( 400053 W), Mumbai, 400053 Tanu Girraj Agarwal - 3A, 1601/1602, Green Acres,

Sr. Client Name and Address Phone No Email Id Director's Name N PAN & Address o. Lokhandwala Complex, Andheri ( W), Mumbai, 400053 10 Olympia F-15, Lokmanya 8424899416 olympiatrading Beena Vijay Multitrading Private Shopping @yahoo.com Agrawal, 842489941 Limited. Centre, Shivaji Vijaykumar Nandlal (AABCO7262J) Chawk, Staion Agarwal & Road, Bhayander (W), Gajendra Vijay Thane – 401101 Agarwal

11 Isairis Trading F-15, Lokmanya 8424899416 isairistrading@ F-15, Lokmanya Private Limited. Shopping yahoo.co.in Shopping Centre, (AADCI0407P) Centre, Shivaji Shivaji Chawk, Chawk, Staion Bhayander (W), Road, Mumbai, 401101 Bhayander (W), Thane – 401101 (All 3 Directors have same address) 12 Garth Mercantile F-15, Lokmanya 8424899416 garthmercantil Private Limited Shopping / e@yahoo.co.in (AAECG9026D) Centre, Shivaji 8497008306 Chawk, Staion Road, Bhayander (W), Thane – 401101 13. Romy Realty Pvt. F-15, Lokmanya 8424899416 Not available Vijaykumar Nandlal Ltd /Nidhi Shopping Agarwal - F-15, Dhanuka Centre, Shivaji Lokmanya Chawk, Staion Shopping Centre, (AADCR6342Q) Road, Shivaji Chawk, Bhayander (W), Bhayander (W), Thane – 401101 Mumbai, 401101

Sr. Client Name and Address Phone No Email Id Director's Name N PAN & Address o. Nidhi Pradeep Dhanuka - C-201, Shree Bhadrakali Darshan, Station Road, Bhayandar (W), Thane, 401101 14. Esaar (India) 23 - A, 12 9022241084 esaarindialtd Dheeraj Shah-23- Limited Akash CHS, @gmail.com a/12, akash chs, Talawad Nagar, talawad nagar, (AABCE0478J) Ashok Nagar, ashok nagar road, Kandivali ,Mu kandivali (e), mbai ,Maharas mumbai, 400101, htra ,400101 maharashtra, india Deepti lalwani- 335, keshav nagar, vaishali nagar, ajmer, 305001, rajasthan, india Hiral Kalpesh Mehta-301, Indraprasth Bldg., Cemetery Road, Opp.Vikas Nagar, Dhanukarwadi, Kandivali (West), Mumbai, 400067, Maharashtra, INDIA 15 Confidence Trading 9, Botawala 022- ctcl.bse@gma Amrut Cotinho- Co. Ltd / Building, 3ed 22662150 il.com 16, maryknoll, Confidence Finance Floor, 11/13, lourdes colony, & Trading Limited Horniman orlem, malad (w), Circle, Fort, mumbai, 400064, Mumbai-maharashtra, india 400001 Swati P Panchal-hari om society, karath road, limdi dist dahod, 389180, gujarat,

Sr. Client Name and Address Phone No Email Id Director's Name N PAN & Address o. india

Revti Pradeep Mykal- -1ST FLOOR R.M 15, Ganadhyaksh Co.Hsg. Soc, Near Manali Hotel, Manvelpada Road, Virar (E), THANE, 401303, Maharashtra, INDIA Manoj Naginlal Jain -602/a, mangal murti, liberty garden road no. 1, malad west, mumbai, 400064, maharashtra, india 16. Banas Finance E-109, Crystal 9322224089 banasfin@gm Girraj Kishor Limited Plaza, New ail.com Agarwal - 3A, Link Road, 1601/1602, Green Andheri, Acres, Mumbai- Lokhandwala 400053 Complex, Andheri ( W), Mumbai, 400053 Tanu Girraj Agarwal - 3A, 1601/1602, Green Acres, Lokhandwala Complex, Andheri ( W), Mumbai, 400053

Sr. Client Name and Address Phone No Email Id Director's Name N PAN & Address o. 17 Out of City Travel E-109, Crystal 9322224089 tilakfin@gmai Girraj Kishor Solutions Ltd/Tilak Plaza, New l.com Agarwal - 3A, Finance Ltd Link Road, 1601/1602, Green Andheri, Acres, Mumbai- Lokhandwala 400053 Complex, Andheri ( W), Mumbai, 400053 tushar rane-room no. 5, parshuram thakur chawl, kandar pada, dahisar (e), mumbai, 400068, maharashtra, india madhu rajkumar goel-a/102, bhalchandra complex, sudarshan cross lane, navghar road, bhayander (east), thane, mumbai, 401105, maharashtra, india Tejas Hingu-G-401, Modi Park Building, Irani Wadi Road No.3, Kandiwali (West), Mumbai, 400067, Maharashtra, INDIA 18 Kayaguru Capital E-109, Crystal 9322224089 Kayagurucapi Girraj Kishor Market Pvt. Ltd Plaza, New tal@gmail.co Agarwal - 3A, Link Road, m 1601/1602, Green Andheri, Acres, Mumbai- Lokhandwala 400053 Complex, Andheri ( W), Mumbai,

Sr. Client Name and Address Phone No Email Id Director's Name N PAN & Address o. 400053

Tanu Girraj Agarwal - 3A, 1601/1602, Green Acres, Lokhandwala Complex, Andheri ( W), Mumbai, 400053 19. Rockon Capital E-109, Crystal 9322224089 rockoncapital Girraj Kishor Market Pvt. Ltd Plaza, New @gmail.com Agarwal - 3A, Link Road, 1601/1602, Green Andheri, Acres, Mumbai- Lokhandwala 400053 Complex, Andheri ( W), Mumbai, 400053 Tanu Girraj Agarwal - 3A, 1601/1602, Green Acres, Lokhandwala Complex, Andheri ( W), Mumbai, 400053 20 VRP Financial 804, Harsh Pradeep_dha Pradeep Natvarlal Services Ltd Height, 150 Feet nuka11@redi Dhanuka - C-201, Road, Behind ffmail.com Shree Bhadrakali (AAACV7147C) Dhanlaxmi Darshan, Station Bank, Road, Bhayandar Bhayander (W), Thane, 401101 (West), Nidhi Pradeep Mumbai-401101 Dhanuka - C-201, Shree Bhadrakali Darshan, Station Road, Bhayandar

Sr. Client Name and Address Phone No Email Id Director's Name N PAN & Address o. (W), Thane, 401101

21 Kamalakshi Finance B-411, Crystal Dheeraj Shah-23- Corporation Limited Plaza, New A/12, Akash Chs, Link Road, Talawad Nagar, (AAACK1804B) Opp Infinity Ashok Nagar Road, Mall, Andheri, Kandivali (E), Mumbai- Mumbai, 400101, 400053 Maharashtra, India Sheetal Dheeraj Shah-23/A-12 Akash CHS Jalawad Nagar, Ashok Nagar Road Kandivali (East), Mumbai, 400101, Maharashtra, INDIA Naresh Suresh Gurav-z.no. 3, swami narayan nagar, varsha nagar, cementri road, v.n. shamshan bhoomi, vikhroli (w), mumbai, 400079, maharashtra, india Hitalkumar Jivanbhai Shah-A- 12 ,Flat No 12, Jalawad Nagar, Vyom Co. Hsg. Soc, Ashok Chakravarthy, Kandivali East, Mumbai, 400101, Maharashtra,

Sr. Client Name and Address Phone No Email Id Director's Name N PAN & Address o. INDIA

22 Victory Sales Pvt. 60-A Jariwala Gma21@redi Vipul Vidur Bhatt- Ltd Building 3rd ffmail.com room no. 44, 3rd fl Floor Tardeo jariwala bld, arthur (AAACV7299K) Sane,Guruji road, tardeo, Road, Mumbai-mumbai, 400034, 400034 maharashtra, india Girish Bhatt-a/10, kavita apts, natakwala lane, borivali (west), mumbai, 400092, maharashtra, india Khyati Bhatt- A/10, kavita apts, natakwala lane, borivali (west), mumbai, 400092, maharashtra, india 23 Sampada Chemicals 5/519, Sampadache Vipul Vidur Bhatt- Pvt. Ltd Navjivan m2010@gmai Room no. 44, 3rd Commercial l.com Floor Jariwala Bld, (AACCS7980C) Society,Laming Arthur Road, ton Road, Tardeo, Mumbai - Mumbai- 400034, 400008 Bijal Vipul Bhai Bhatt- Room no. 44, 3rd Floor Jariwala Bldg, Tardeo, Mumbai, 400034 24 Samskara Sales 7, Floor-1, Plot samskarasales Yogesh Vitthal Agency Pvt. Ltd 83/84, Moti @gmail.com Jadhav- Bhawan, Marin a/404,Adaivad (AATCS7717A) 4th Street, Gol Aparment,Diva Shil Maszid, Road, Ganraj DhobiTalav, nagar,Diva

Sr. Client Name and Address Phone No Email Id Director's Name N PAN & Address o. Kalbadevi, Post(Diva), Thane, Mumbai-400002 400612

Ganesh Eknath Chandanshive- a/4- 406,Vignaharta Chs,Near Kanjurmarg Railway Station,Karve nagar,Kanjur Marg - (East), Mumbai, 400042 25 Gulmohar Dealcom om Bhawan, vchirawa@g Vimal Sharma- 29, Pvt. Ltd 54/5A Strand mail.com Shrimo Ke Pas, Road, Ward Nana 14, (AADCG9091K) KOLKATA- Tehsil : Chirawa, 700006 Dist - Jhunjhunu, Chirawa, 333026, Rajasthan Lipika Bhattacharjee`- Rabindrapally Rajarhat Gopalpur, 24 Parganas (North), Rajarhat, 700102, West Bengal 26 Goodpoint Impex loco colony, 6 abcd@gmail.c Sujata Chatterjee- 9, Pvt. Ltd sadar near om B.B.Halder Lane, sukanta Shibpur, Howrah, (AAFCG0606G) pathagar, 711102, West burdwan- Bengal, India 713101 JAYANTA BOSE- Loco Colony 6 Sadar, Burdwan, 713101, West

Sr. Client Name and Address Phone No Email Id Director's Name N PAN & Address o. Bengal, INDIA

27 Shivsathi Mercantile loco colony, 6 abcd@gmail. Jayanta Bose- Loco Pvt. Ltd sadar near com Colony 6 Sadar, sukanta Burdwan, 713101, (AASCS6284R) pathagar, West Bengal, India burdwan- Amarnath Mandal- 713101 Kshetia Hindupara, Kshetia Burdwan Sadar, Burdwan, 713102, West Bengal, India 28 Shallot Dealtrade loco colony, 6 abcd@gmail. Lata Rani Dan- Pvt. Ltd sadar near com Narigram Pirtala sukanta Rayan Bardhaman (AARCS4827R) pathagar, Sadar, Burdwan, burdwan- 713101, West Bengal, INDIA Haradhan Mandal- Kshetia Hindupara, Kshetia, Burdwan, 713102, West Bengal, India 29 Helpful Investment 10a, hospital Roc2011@in. Debi Prasad Pal- 7, Advisory Pvt. Ltd. street, 2nd floor, com Rabindra Sarani, room no. Kolkata, 700001, (AACCH4303H) 205,kolkata- West Bengal, India 700072 Ashis Das- P-40, India Exchange Place, Kolkata, 700001, West Bengal, India 30 Sadakirti Dealer Pvt. 1/1 ganguli vchirawa@g Vimal Sharma- 29, Ltd lane, mail.com Shrimo Ke Pas, (AANCS5873M) mezzanine Ward Nana 14, floor room no Tehsil : Chirawa, 10b, kolkata- Dist - Jhunjhunu,

Sr. Client Name and Address Phone No Email Id Director's Name N PAN & Address o. 700007 Chirawa, 333026, Rajasthan

Lipika Bhattacharjee`- Rabindrapally Rajarhat Gopalpur, 24 Parganas (North), Rajarhat, 700102, West Bengal

Based on Table: A, the following relationships can be established:- i) Olympia Multitrading Private Limited (Sr. No.10), Isairis Trading Private Limited (Sr. No.11) & Garth Mercantile Private Limited (Sr. No.12) ,Romy Realty Pvt. Ltd(Sr. No.13,Surface Finance Pvt. Ltd(Sr. No.7)are related to each other as they have same address. ii) Olympia Multitrading Private Limited (Sr. No.10), Isairis Trading Private Limited (Sr. No.11) & Garth Mercantile Private Limited (Sr. No.12) have common Directors viz. Beena Agarwal, Vijaykumar Agarwal & Gajendra Agarwal and phone no viz. 8424899416. Vijay Kumar Agawal is also a director in Romy Realty Pvt. Ltd (Sr. No.13). iii) Shree Nath Commercial And Finance Limited (Sr. No.14) & Five X Finance & Investment Limited (Sr. No.23), Rockon Capital Market Pvt. Ltd 9Sr.No.19), Kayaguru Capital Market Pvt. Ltd (Sr. No.18), Out of City Travel Solutions Ltd (Sr. No.17) & Banas Finance Ltd (Sr.No.16) have common address viz. E-109, Crystal Plaza, New Link Road, Opp Infinity Mall, Andheri (W), Mumbai – 400053, common phone no viz. 9322224089 and common Directors viz. Girraj Agarwal & Tanu Agarwal. iv) The MCA details of Insight Multitrading Pvt. Ltd (Sr.

No.4) & Fragrant Multitrading Pvt. Ltd (Sr.No.8) do not match with respect to the address of the directors as provided in KYC details. As per the KYC details, director of Insight Multitrading Pvt. Ltd Ltd (Sr. No.4) viz. Gangji Ganesh Ravariya & Fragrant Multitrading Pvt. Ltd (Sr. No.8) viz. Andiben Gangji ravariya have common address viz. Shop No. 6, Badhut CHS, Datta Mandir Road, Vakola Bridge, Santacruz (E), Mumbai – 400055. v) Limestone Properties Pvt. Ltd (Sr.No.1) & Topwell Properties Pvt. Ltd (Sr.No.2) have same address and email id viz. 95A, C R Avenue, 1st Floor, Kolkata, West Bengal - 700073 & sun_sand1980@yahoo.com respectively. Chiranjit Mahant is a common director in both the entities. Topwell Properties Pvt. Ltd (Sr.No.2) & Helpful Investment advisory Pvt. Ltd (Sr.No.29) have common director viz. Debi Prasad Pal. Therefore Limestone properties Pvt. Ltd, Topwell Properties Pvt. Ltd & Helpful Investment advisory Pvt. Ltd are related to each other. vi) Goodpoint Impex Pvt. Ltd (Sr.No.26), Shivsathi Mercantile Pvt. Ltd (Sr.No.27) & Shallot Dealtrade Pvt. Ltd (Sr.No.28) have same address and email id viz. Loco Colony, 6 Sadar Near Sukanta Pathagar, Burdwan-713101 & abcd@gmail.com respectively.

vii) Victory Sales Pvt. Ltd (Sr.no.22) & Sampada Chemicals Ltd (Sr. No.23) have common director viz. Vipul Vidur Bhatt. viii) Pradeep Natwarlal Dhanuka, Director in Rupak Developers Pvt. Ltd (Sr. No.3) & Nidhi Pradeep Dhanuka, director in Romy Realty Pvt. Ltd (Sr.No.13) have same address viz. C-201, Shree Bhadrakali Darshan, Station Road, Bhayandar (W), Thane, 401101.Both Pradeep Dhanuka & Nidhi Dhanuka are directors in VRP Financial Services Ltd (Sr. No.20). ix) Gulmohar Dealcom Pvt. Ltd (Sr.No.25) & Sadakirti Dealer Pvt Ltd (Sr. No.30) have same email id viz. vchirawa@gmail.com and common directors. x) Kamalakshi Finance Corrporation Ltd (Sr. No.21) & Esaar (India) Ltd (Sr. No. 14) has Dheeraj Shah as common director. Esaar (India) Ltd & Moryo Industries Ltd have Deepti Lalwani as common director between them. xi) The auditor of Esaar (India) Ltd is Praveen Chandak & Associates where Giriraj Kishor Agarwal is a partner. Girraj Kishor Agarwal was one of the directors in Esaar (India) Ltd for the FY 2010-11.

Table:B - Relationship based on the analysis of bank statements. Sr. Client Name and Period of Observations from Bank Statement of clients No. PAN Transaction 1 Romy Realty Pvt. Nov 01, 2013 On analyzing bank statement of the client for the Ltd to August 23, period during which client has traded, having bank 2014 account in Axis Bank having account no. - (AADCR6342Q) 415010200002417, it was observed that client had received / transferred funds from / to various entities including VRP Financial Services Pvt. Ltd, Rupak Developers Pvt. Ltd, Surface Finance Pvt. Ltd, Keshariya Metal Pvt. Ltd. It has also received funds from Jalan Texfab Pvt. Ltd, promoted by Amit Jalan & Sumit Jalan;Aadishu Securities promoted by the Sudhir Chirania & Sanjeev Chirania. Apart from these the client has received funds from various entities towards purchase of shares.

Sr. Client Name and Period of Observations from Bank Statement of clients No. PAN Transaction 2 Rupak Developers Apr 02, 2011 On analyzing bank statement of the client for the Private Limited to August 23, period during which client has traded, having bank 2014 account in Axis Bank, Mumbai branch having (AADCR6341P) account no. 415010200002349, it was observed that client had received / transferred funds from / to various entities including Garth Mercantile Pvt. Ltd Insight Multitrading Pvt. Ltd, Romy Realty Pvt. Ltd, Moryo Industries Pvt. Ltd, Kamalakshi Finance Coproration Ltd, Surface Finance Pvt. Ltd, Perfect Corporate Services, Dhananjay Enterprises, & Somnath Corporation. 3 Moryo Industries June 04, 2013 C On analyzing bank statement of the client for the Ltd to August 07, period during which client has traded, having bank 2013 account in Axis Bank, Mumbai branch having (AACCM5166G) account no.912020048334949, it was observed that the client has received / transferred funds from/to various entities including Essar India Ltd, Rupak Developers Pvt. Ltd, Five X finance & Investment Ltd, Insight Multitrading, Fragrant Multitrading Pvt. Ltd,Giriraj Kishor Agarwal, Kayaguru Insurance Broker, Kayaguru Wellness Pvt. Lt, Shreenath Commercial & Finance Ltd, Rockon Fintech Ltd,Kamalakshi Finance Corporation Ltd, & Handful Investrade Pvt. Ltd. 4 Shree Nath January 22, On analyzing bank statement of the client for the Commercial And 2014 to period during which client has traded, having bank Finance Limited February 05, account in Axis Bank, Mumbai branch having (AADCS8871M) 2014 account no. 909020038885084, it was observed that the client has received / transferred funds from/to various entities including Five X Finance & Investment Ltd, Banas Finance Ltd, Tanu Agarwal & Girraj Kishor Agarwal, 5 Surface Finance Pvt. June 17, 2013 On analyzing bank statement of the client for the Ltd (AABCS1202L) to March 11, period during which client has traded, having bank 2014 account in Axis Bank having account no. 910020041102497, it was observed that the client has received / transferred funds from/to various entities including Romy Realty Pvt. Ltd, Rupak Developers Pvt. Ltd), Kamalakshi Finance Corporation Ltd, VRP Financial Services Pvt. Ltd & Somnath Corporation,

Sr. Client Name and Period of Observations from Bank Statement of clients No. PAN Transaction 6 Fragrant June 11, 2013 On analyzing bank statement of the client for the Multitrading Private to January 24, period during which client has traded, having bank Limited 2014 account in Yes Bank, Mumbai branch having (AABCF9874H) account no. 016283800001001, it was observed that the client has received / transferred funds from/to various entities including Moryo Industries Ltd. 7 Five X Finance & May 15,2013 On analyzing bank statement of the client for the Investment Limited to April 04, period during which client has traded, having bank (AABCF5412H) 2014 account in Axis Bank, Mumbai branch having account no. 91002003566638, it was observed that the client has received / transferred funds from/to various entities including Shree Nath Commercial & Finance Ltd, Esaar India Ltd, Moryo Industries Ltd, Girraj Kishor Agarwal, Aadishu Securities Pvt. Ltd,Banas Finance, Out of city Travel Solutions Ltd,Essar India Ltd, Handful Investrade Pvt. Ltd, Moryo Industries Ltd, Aadishu Securities Pvt. Ltd. 8 Olympia June 01, 2013 On analyzing bank statement of the client for the Multitrading Private to July 31, period during which client has traded, having bank Limited. 2014 account in The Bharat Co-op Bank (Mumbai) (AABCO7262J) Ltd, Mumbai branch having account no. 121/2452, it was observed that the client has received / transferred funds from / to various entities including VRP Financial Services Ltd, Garth Mercantile Pvt. Ltd. 9 Isairis Trading February 26, On analyzing bank statement of the client for the Private Limited. 2014 & March period during which client has traded, having bank (AADCI0407P) 14, 2014 account in, Axis Bank Mumbai branch having account no.913020052229955, it was observed that the client has received / transferred funds from/to various unidentified entities. However, none of the entities was observed to be dealing in the scrip or prima facie connected / related to the entities dealing in the scrip or to the Company.

Sr. Client Name and Period of Observations from Bank Statement of clients No. PAN Transaction 10 Garth Mercantile June 01, 2013 On analyzing bank statement of the client for the Private Limited to July 31, period during which client has traded, having bank (AAECG9026D) 2014 account in The Bharat Co-op Bank (Mumbai) Ltd, Mumbai branch having account no. 121/2451, it was observed that the client has received / transferred funds from / to various entities including Somnath Corporation, Dhananjay Enterprises, Kehsariya Metals Pvt. Ltd. 11 Samskara Sales March 28, On analyzing bank statement of the client for the Agency Pvt. Ltd 2014 to period during which client has traded, having bank (AATCS7717A) August 25, account in Axis Bank, Mumbai branch having 2014 account no. 914020011364920, it was observed that the client has received / transferred funds from/to various entities including Saurabh Surendra Jadhav, Deepak S Chavan, Keshariya Metal Pvt. Ltd,Gulmohar Dealcom Pvt. Ltd, Umesh Tiwari,Ganesh Eknath Chandan Shiv,Sadakirti Dealers Pvt. Ltd,Mahasvin Trading Pvt. Ltd & Suryakant Chanpur. 12 Sidhi Vinayak Nov 01, 2013 On analyzing bank statement of the client for the Portfolio-to August 22, period during which client has traded, having bank Proprietorship Firm 2014 account in IDBI Bank Ltd, Mumbai branch of Tushar Rane having account no. 536102000002769, it was (AJCPR9314H) observed that the client has received / transferred funds from / to various entities including Mangesh Dhotre, Girish R Goel,Wakil Rajbhar, Beena Agarwal, Krupali Dhotre &Sapna R Jatwal. 13 Yash Securities - Nov 01, 2013 On analyzing bank statement of the client for the Proprietorship firm to August 22, period during which client has traded, having bank of Tisha Tushar 2014 account in IDBI Bank Ltd, Mumbai branch Rane having account no. 536102000002745, it was (AHRPK8922D) observed that the client has received / transferred funds from / to various entities including Girish R Goel, Wakil Rajbhar, Mangesh Dhotre,Sapna R Jatwal, Krupali Dhotre & Beena Agarwal

Sr. Client Name and Period of Observations from Bank Statement of clients No. PAN Transaction 14 Shivsathi Mercantile Oct 01, 2013 On analyzing bank statement of the client for the Pvt. Ltd to Aug 31, period during which client has traded, having bank (AASCS6284R) 2014. account in HDFC Bank Ltd, Kolkata branch having account no.00088030000768, it was observed that the client has received / transferred funds from / to various entities including Dhananjay Enterprises, Aydohya Vinimay & Somnath Corporation 15 Goodpoint Impex Oct 01, 2013 On analyzing bank statement of the client for the Pvt. Ltd to Aug 31, period during which client has traded, having bank (AAFCG0606G) 2014. account in HDFC Bank Ltd, Kolkata branch having account no.00088030000751, it was observed that the client has received / transferred funds from / to various entities including Dhananjay Enterprises, Aydohya Vinimay & Somnath Corporation. 16 Saurabh Surendra March 01, On analyzing bank statement of the client for the Jadhav 2014 to period during which client has traded, having bank (ANGPJ6430Q) 31/08/2014 account in Axis Bank, Mumbai branch having account no. 914010009180553, it was observed that the client has received / transferred funds from/to various entities including Samskara Sales Agency Pvt. Ltd,Ganesh Eknath Chandanshiv,Suryakant Chanpur,Umesh Tiwari,Keshariya Metal Pvt. Ltd & Mahasvin Trading Pvt. Ltd, 17 Deepak S Chavan Jan 01, 2013 On analyzing bank statement of the client for the to September period during which client has traded, having bank (AJAPC0258P) 07, 2014 account in ICICI Bank, Mumbai branch having account no. 100005000451, it was observed that the client has received / transferred funds from/to various entities including Kamalpushp Barter, Umesh Tiwari,Keshariya Metal Pvt. Ltd, Samskara Sales Agency & Mahasvin Trading Pvt. Ltd.

From Table B, the following relationships are established:- i) Moryo Industries is related to Rupak Developers, VRP Financial Service Ltd, Five X finance, Kamalakshi Finance, G K Agarwal & Essar India.

ii) As per the account statement Tisha Tushar Rane and Tushar Rane have same address. Tisha Rane and Tushar Rane are relate to Mangesh Madhukar Dhotre, Giris R Goel, Wakil Rajbhar, Beena Agarwal, Sapna R Jatwal and Krupali Dhotre. iii) Ganesh Eknath Chandan Shiv, Samskara Sales Agency, Saurabh Surendra Jadhav, Samskara Sales Agency, Gulmohar Dealcom, Suryakant Chanpur & Deepak S Chavan are related to each other. Suryakant Chanpur and Deepak S Chavan are also directors in a company Bhudhil Commtrade Pvt. Ltd. iv) Rupak Developers, Shallot Deal trade & Garth Mercantile have received funds from Dhananjay Enterprise, Somnath Corporation. Hence related to each other. v) Samskara Sales agency is related to sadakirti dealer Pvt. Ltd. vi) Mahasvin Trading Pvt. Ltd had common director, Ganesh Eknath Chandanshiv with Samskara Sales agency hence related to each other. vii) Sanjay V Parmar also appeared to have financial relationship with Giriraj Kishor Agrawal promoted companies.

Table:C - Relationship Based on Off Market Transfers. 1.Wakil Rajbhar 2.Topwell Properties Pvt. Ltd 3.Saurabh Surendra Jadhav Romy Realty Pvt. Ltd/Surface Finance Pvt. 4.Helpful Investment advisory Pvt. Ltd Ltd/Garth Mercantile Pvt. Ltd/Olympia 5.Girish Raj Kumar Goel Multitrading Pvt. Ltd 6.Sapna Ramdas Jatwal 7.Ayodhya Vinimay Pvt. Ltd 8.Digant S Trivedi 9.Victory Sales Pvt. Ltd Ajay Mohanlal Bhatt 10.Digant S Trivedi

From Table C, the following relationships are established i) Romy Realty Pvt. Ltd. is related to Ajay Mohanlal Bhatt as both have off market relationship Digant S Trivedi (Sr.No.10) iii) Romy Realty Pvt. Ltd. is related to the entities mentioned at serial no 1 to 10, who were the net buyers in Patch 1 7 Patch 2. iv) Romy Realty Pvt. Ltd. is related to Ayodhya Vinimay Pvt. Ltd. (Sr.No.7) who has financial transactions with Shivsathi Mercantile Pvt. Ltd. and Goodpoint Impex Pvt. Ltd. v) Topwell Properties Pvt. Ltd. and Helpful Investment Advisory Pvt. Ltd. both have received shares from Meena Arvind Rambhia who in turn had received from Rajshri Rajan Bhambhale. Rajshri Rajan Bhambhale was in turn found to be tarding in off market shares with Garth Mercantile Pvt. Ltd.

Table D : Other Relationships 1.Shares common telephone no-9619192953 with Victory Sales Pvt. Ltd. 2. Ajay Mohanlal Bhatt and Vipul Bhatt, Director Ajay Mohanlal Bhatt in Victory Sales Pvt. Ltd share the same address viz.43/3 Jariwala Bldg, Sane Guruji Road, Tardeo, Mumbai-400034 1.Victory Sales Pvt. Ltd., and Shyam Alcohol & Chemicals Ltd have common director in Vipul Bhatt. Victory Sales Pvt. Ltd 2. Shyam Alcohol & Chemicals Ltd. share same address with Sanjay Trivedi Viz- 3 A/10,Kavita Apts, Natakwala Lane, S. V. Road Borivili, Mumbai-400092. 1.Shares common address with Deepak Raval viz.60/3, Jariwala Bldg,Sane Guruji Road, Tardeo, Mumbai-400034 Vasudev Panchal 2. The above mentioned address is similar to the address of Ajay Mohanlal Bhatt & Victory Sales Pvt. Ltd. Romy Realty 1. Off market with Deepak Raval & Sanjay Trivedi 1. As per KYC, he is the proprietor of Deepti Sales Corporation whose contact person is Mr. Pradeep Dhanuka, Director of Rupak Developers Pvt. Ltd. Shiv Kumar Kaushik 2. Shivkumar Kaushik alongwith Tushar Rane and Madhukar Dhotre were preferential allotees in Krishna Venture Ltd. At the time of allotment Vijay Agrawal and Beena Agrawal were directors in Krishna Vnetures Ltd. 1. Is one of the preferential allotee in Kamalakshi Anand Kamalnayan Pandit Finance Corporation Ltd. Hence connected/known to Kamalaskhi Finance corporation Ltd

From Table D: Following relationship could be observed, i) Ajay Mohanlal Bhatt, Victory Sales Pvt. Ltd & Vasudev Panchal are related to each other. ii) Romy Realty Pvt. Ltd, Ajay Mohan Lal Bhatt, Victory Sales Pvt. Ltd & Vasudev Panchal are connected to each other. iii) Anand Kamalnayan Pandit is connected to Kamalakshi Finance Corporation Ltd and hence connected to Moryo as per Table B. iv) Shiv Kumar Kaushik is connected to Rupak Developers Pvt. Ltd.

Annexure C : Trading Details Of Moryo Group Entities in Patch 2

Sr. Patch 1 Patch 2 No Buy Sell Buy. PAN Client Name GP Rate GS Rate GP Rate GS Sell Rate KAMALAKSHI FINANCE 1 AAACK1804B CORPORATION LIMITED 10210 110.04 31280 216.18 - 2 AABCE0478J ESAAR INDIA LTD 50210 167.21 - OLYMPIA MULTITRADING 3 AABCO7262J PRIVATE LIMITED 724390 191.09 - SURFACE FINANCE PVT. 4 AABCS1202L LTD 660 111.12 10 89.00 959307 194.45 - HELPFUL INVESTMENT AACCH4303 ADVISORY PRIVATE 5 G LIMITED 50000 204.59 - LIMESTONE PROPERTIES 6 AACCL0133G PRIVATE LIMITED 8000 100.66 12000 196.00 - SAMPADA CHEMICALS 7 AACCS7980C LIMITED. 4000 100.85 0 4000 196.00 DHARTI DEVELOPERS AADCD5959 AND CONSTRUCTIONS 8 M PVT. LTD 23300 229.47 - AADCG9091 GULMOHAR DEALCOM 9 K PRIVATE LIMITED 99744 224.73 - ISAIRIS TRADING PRIVATE 10 AADCI0407P LIMITED 53460 199.22 - 11 AADCR6341P SAVITA SONAVANE 12500 109.84 268156 198.04 2007 229.00 AADCR6342 NIDHI DHANUKA/ROMY 12 Q REALTY PRIVATE LIMITED 28032 106.12 1037420 196.36 - TOPWELL PROPERTIES 13 AADCT8403C PRIVATE LIMITED 52000 197.97 - 14 AADPA7003J TANU GIRIRAJ AGARWAL 40925 198.03 - AAECG9026 GARTH MERCANTILE 15 D PRIVATE LIMITED 1949901 195.73 149 226.87 AAFCG0606 GOODPOINT IMPEX 16 G PRIVATE LIMITED 248050 202.44 - AAGPK7011 17 H SHIVKUMAR KAUSHIK 107900 198.61 - AANCS5873 SADAKIRTI DEALER PVT. 18 M LTD 40425 230.00 - SHALLOT DEALTRADE 19 AARCS4827R PRIVATE LIMITED 58783 211.56 - SHIVSATHI MERCANTILE 20 AASCS6284R PRIVATE LIMITED 107715 186.02 - SAMSKARA SALES AGENCY PRIVATE 21 AATCS7717A LIMITED 136211 227.02 - SANJAY JETHALAL SONI 22 AAWHS0331J HUF 50905 225.94 15510 226.50 ANAND KAMALNAYAN 23 ADMPP1798B PANDIT 409000 222.79 - AHRPK8922 24 D TISHA TUSHAR RANE 60250 198.83 - DEEPAK SURYAKANT 25 AJAPC0258P CHAVAN 52062 219.23 - SIDHI VINAYAK 26 AJCPR9314H PORTFOLIO 81475 198.87 -

MANGESH MADHUKAR 27 AJPPD8297E DHOTRE 52100 198.65 - 28 ANDPC7557J SURYAKANT CHANPUR 50150 229.76 300 230.00 SAURABH SURENDRA 29 ANGPJ6430Q JADHAV 65449 226.47 2500 229.80 30 AOSPR9100E WAKIL RAJBHAR 49185 198.99 - 31 APNPJ7211C SAPNA RAMDAS JATWAL 31150 198.82 - ARWPC4266 GANESH EKNATH 32 D CHANDANSHIVE 44069 221.32 - 33 ATYPB5376M SAGAR GIRISH BHATT 2500 117.55 0 2500 196.00 34 BDLPG2634K GIRISH RAJKUMAR GOEL 37400 198.89 - KRUPALI MADHUKAR 35 BIQPD4268L DHOTRE 25450 199.06 - 36 BVSPS9740P KRUPA SANJAY SONI 60076 225.77 14625 221.70 AAACV7299 37 K VICTORY SALES PVT. LTD 5000 102.29 INSIGHT MULTITRADING 38 AACCI9518C PRIVATE LIMITED 15556 100.23 2 119.25 39 ASIPP8140N VASUDEV B PANCHAL 16000 110.10 10245 8 1,068.80 12 208.25 7119898 41591

Sd/ RAJEEV KUMAR AGARWAL PLACE: MUMBAI WHOLE TIME MEMBER DATE:DECEMBER 4th 2014 SECURITIES AND EXCHANGE BOARD OF INDIA