Order against Keynote Capitals Ltd

ORDER UNDER REGULATION 13(4) OF SEBI (PROCEDURE FOR HOLDING ENQUIRY BY ENQUIRY OFFICER AND IMPOSING PENALTY) REGULATIONS, 2002 1. SEBI conducted investigation into the trading in the scrips of Himachal Futuristic Communication Ltd. (hereinafter referred to as “HFCL”) and Adani Exports Ltd. (hereinafter referred to as “AEL”) subsequent to unusual increase in the price and volume of the scrip during the period

April 01, 2000 to March 31, 2001 (hereinafter referred to as the “investigation period”).

2. During the investigation it was observed that orders placed by Keynote Capitals Ltd. (hereinafter referred to as “KCL”), member of The Bombay Stock Exchange Ltd. (hereinafter referred to as “BSE”) on behalf of entities connected or controlled by Shri Ketan V. Parekh (who was the mastermind behind the wide scale manipulation in the stock market during the investigation period) and Shri Kartik K. Parekh (hereinafter referred to as “KP entities”) got matched with the select counter party brokers who were also acting on behalf of KP entities.

3. Further, it was found that the transactions of KP entities were financing transactions but given the colour of purchase and sale of shares which were being passed from one KP entitiy to same or another KP entities. KCL was found to have aided and abetted KP entities in circular trading, in creating artificial market and in executing fictitious deals in the above scrips and failed to exercise due care and skill in its dealings on behalf of KP entities. It was therefore alleged that KCL while executing these fictitious transactions in the scrips mentioned above violated Regulations 4(b),(c) and (d) of the SEBI (Prohibition of Fraudulent and Unfair Trade Practices relating to Securities Market) Regulations, 1995 (hereinafter referred to as “PFUTP Regulations”) and clause A(1) and (2) of Code of Conduct specified in Schedule II in Regulation of SEBI (Stock Brokers and Sub Brokers) Regulations, 1992 (hereinafter referred to as “Stock Brokers Regulations”).

4. Accordingly, an Enquiry Officer was appointed vide order dated October 14, 2004 under Regulation 5(1) of the SEBI (Procedure for holding Enquiry by Enquiry Officer and Imposing Penalty) Regulations,2002 (hereinafter referred to as “Enquiry Regulations”). The Enquiry Officer conducted the enquiry in terms of the Enquiry Regulations and found that transactions executed by KCL were in violation of Regulation 4(b),(c) and (d) of FUTP Regulations and Clause A (2) of Code of Conduct specified under Schedule II read with Regulation 7 of Stock Brokers Regulations. The Enquiry Officer submitted his report dated May 24, 2005 recommending a penalty of suspension of certificate of registration for a period of one month.

5. Based on the recommendations of the Enquiry Officer, a show cause notice dated June 7, 2005 along with the copy of the Enquiry Report was forwarded to KCL in terms of Regulation 13(2) of the Enquiry Regulations advising it to show cause as to why action should not be taken them as recommended by the Enquiry Officer. KCL was also advised to explain why consequential action under section 3(2) of SEBI (Criteria for Fit and Proper Person) Regulations, 2004 should not be taken against them.

6. KCL submitted its reply to the said show cause notice vide letter dated June 24, 2005, through Deval Patel Associates, which inter alia stated as under: i. All 46 trades have been executed for and on behalf of their client, SBM Group (comprising SBM Investments, a proprietary concern owned by Mr. Shirish Maniar Maniar Financial Services Ltd and Chetan Fincap, a proprietary concern of Mr. Chetan Rajnikant Mehta). They have not acted as a broker directly for KP entities for any of the 46 trades. There is no privity of contract between them and KP entities insofar as the 46 trades were concerned. ii. The 46 impugned trades were made by them for delivery and for trading on behalf of SBM Group in the normal and routine course of business and the shares were traded through normal settlement system. The delivery records of the said shares were available with them. iii. The transactions executed by them were routine stock broking transactions of buying and selling of shares at market prices, either for square off or delivery. The pay-in of funds and other stock related obligations were made in time.

They had no knowledge whatsoever of the circular nature of these transactions or a structured /synchronized trading mechanism. They have executed numerous transactions in the scrip of HFCL on NSE and BSE during period November 15, 1999 to March 7, 2001. It is impossible for them to isolate specific transactions which may be in the nature of cross deals. iv. All the transactions executed by them including the 46 transactions were effected through BOLT of BSE and NEAT of NSE, wherein the identity of the counter party/broker is not disclosed. v. Suitable risk management measures were enforced on clients involved in transactions in the nature of squaring off. All their client obligations resulted in regular settlement of differences, deliveries and monies as per the settlement schedule. The securities traded were amongst the most actively traded and market fancied scrip. CSFB Securities Ltd and Dresner Kleinwort Benson Securities Ltd. (DKB) were amongst the Foreign Institutional Brokers actively trading on the exchanges. vi. There is no method of verifying that the same client has entered into a corresponding transactions, which would result in a cross transaction, with some other broker.

They had no knowledge whatsoever of the alleged non genuine nature of the transactions and the alleged creation of artificial volume or market for the shares. They had purchased or sold the said shares on behalf of the SBM Group under the instructions of the SBM Group over a long period of time and KCL had no proprietary interest in any of the transactions. vii. They had acted as per instructions received from SBM Group. At the time of execution of the transactions, they had no knowledge of any additional parties involved in the transactions. Upon subsequent enquiry with the SBM Group, they learnt that there were further transactions effected by SBM Group in favour of other parties. viii. They have always discharged all their settlement obligations as per the schedule. They reiterated that they had no prior knowledge that any of the transactions were in the nature of cross transactions nor did they have any reasons to disbelieve the genuine nature of transactions. ix. They had not abetted any synchronize transactions and there was no intention or attempt on their part to aid, abet, assist, finance or misuse the stock exchange trading and settlement system.

In the absence of any knowledge, they cannot verify or comment on whether the SBM Group had engaged in synchronized deals. x. The chances of synchronized deal taking place through the screen based trading system is virtually impossible as the computers used by the exchanges for order trade matching can recognize the difference of 164th of a second time lag and that it is almost impossible to know the identity of the buyer in a screen based transaction. The normal prescribed computerized trading system cannot be held to be “synchronized” trade and punishable solely on the ground that buy and sell orders were placed by different unconnected brokers at the same rate within a gap of few seconds. xi. They stated that the buy and sell orders in respect of trades were, in fact made on different dates and not on the same date, as alleged. On any given day that the trades were affected, there has been either a buy order or sell order, and not a buy and sell order on the same day as alleged. At no point of time did they act as a broker for both the buyer and seller in respect of HFCL scrip on the same day in respect of any of the 46 trades.

It further submitted that the ordered quantities in the said trades are also different. xii. They submit that 46 trades relating to the scrip of the HFCL forming part of the Enquiry Report during the period of over one year between November 1999 and March 2001. These trades form a small part of a very large number of trades in the scrip of HFCL made by them on behalf of the SBM group and its other clients. The transactions were carried out over a period of over a year. Therefore under the circumstances, 46 trades cannot be said to constitute a “large number”. Furthermore, the impugned 46 trades form a very small and insignificant part of their total business.

xiii. During the same period, a total of approximately 35,99,08,925 shares of HFCL were traded on NSE and BSE and the 46 impugned trades executed by them on behalf of theys comprise a negligible 0.437% of the total number of shares traded. The scrip of HFCL was highly liquid in nature and due to high volumes of trades in the scrip they did not have prior knowledge of these alleged synchronized transactions. Therefore the inference from such large number of trades that these trades were executed in a pre determined fashion is absolutely devoid of any merit and there is no evidence sufficient to establish this serious offence.

xiv. They wish to draw the attention to the fact that no such qualification has been imputed to them by the EO. There are neither pending claim/cases against them nor any outstanding statutory dues payable by them. They have paid approximately Rs. 1.8 crore as SEBI fees and is totally free from all civil liabilities. They have always maintained high standards of efficiency and promptitude with regards to financial discipline. It has not been a party to any activity or transactions that is in violation of the SEBI Regulations. 6. Vide letter dated October 4, 2006, an opportunity of personal hearing was granted before me on October 12, 2006 wherein persons mentioned on the first page of the order appeared on behalf of KCL and made submissions.

7. I have carefully gone through the investigation report, enquiry report, the show cause notice and the reply of KCL and other material on record.

8. I find that the shares of HFCL were mainly sold by KP entities namely, Classic Credit Ltd (hereinafter referred to as “Classic Credit”), Luminant Investment Pvt. Ltd (hereinafter referred to as “Luminant”) and Panther Fincap & Management Services Ltd (hereinafter referred to as “Panther Fincap”) through the brokers Credit Suisse First Boston (India) Securities Ltd. (hereinafter referred to as “CSFB”) & Dresdner Kleinwort Benson Securities (India) Limited (hereinafter referred to as “DKB”). These shares sold were bought through different brokers either by the same entities i.e. Classic Credit, Luminant and Panther Fincap or by other KP entities i.e. Saimangal Investrade Ltd (hereinafter referred to as “Saimangal”), NH Securities Ltd (NH Securities-proprietary account), Classic Shares & Stock Brokers Ltd (Classic Shares--proprietary account), and Chitrakut Computers Private Ltd. (hereinafter referred to as “Chitrakut”). In the scrip of AEL, KP entities had bought the shares through various brokers at BSE and NSE which were earlier sold by the KP entities through CSFB.

9. From the perusal of the order log and trade log of transactions executed by KP entities, I find that in as many as 48 instances, the entire quantity or almost entire quantity of sell / buy order of KCL matched with the orders of the counterparty brokers. On analysis of the buy and sell orders, I find that the same were put at the same time or almost at the same time i.e. within a gap of few seconds of putting in of buy / sell order. From the trading pattern, it is apparent that these orders were synchronized and were put with prior understanding with a view to ensure that sell order of one KP entity matched with the buy orders of same selling KP entity or other set of KP entity.

10. I find that the transactions executed by KCL on behalf of their client facilitated KP entities to receive finance against the delivery of shares without waiting for pay-out at the exchange and were so structured to give them a semblance of actual “sale and purchase” of shares at the recognized stock exchanges. These transactions were non-genuine and involved no change in the beneficial ownership of shares as such i.e. the shares were merely rotating from one KP entity to same or other KP entities.

11. From the analysis of the order log and trade log of transactions entered by KP entities, I find that in as many as 48 instances, the entire quantity or almost entire quantity of sell/ buy order of KCL matched with the orders of counter party brokers.

12. I further note that Classic Credit and Panther Fincap indulged in circular trades in the scrip of HFCL through CSFB’s proprietary account by using the following modus operandi: KP entities first purchased the shares from CSFB proprietary account by synchronizing the trades. Then, on the same day after a short gap they sold these very shares to CSFB proprietary account, through CSFB by way of cross deals. In the similar fashion, shares of HFCL were sold by KP entities through DKB.

13. The structured transactions in the scrip of HFCL wherein KCL was a broker either on the buy side or the sell side are attached herewith as Annexure A.

14. Further KCL was also involved in structured trades in the scrip of HFCL where the counter party brokers were DKB or CSFB for their clients who were KP entities who traded on the buy side as well as sell side as under:

Sell Sell Buy Buy Buy Sell Order Order Order Order Order Order Sell Order No Time Qty Price Buy Order No Time Qty Price Remarks 200008020530363 14:08:40 25000 1375 200008020530367 14:08:40 25000 1375 Shares sold by 200008020530599 14:08:50 25000 1375 200008020530615 14:08:50 25000 1375 CSFB Proprietar 200008100104552 10:15:17 25000 1483.5 200008100104660 10:15:16 25000 1483.5 y account through 200008100105230 10:15:17 25000 1483.5 200008100104660 10:15:25 25000 1483.5 CSFB bought by 200008100105230 10:15:17 25000 1483.5 200008100105334 10:15:25 25000 1483.5 another KP entity 200008100108677 10:15:26 25000 1483.5 200008100105334 10:16:11 25000 1483.5 through KCL 27600100010000935 14:46:12 100000 1129.5 12000500010006337 14:46:10 75000 1129.5 200101040833064 13:10:13 25000 1342 200101040833118 13:10:14 25000 1342 200101040833554 13:10:24 25000 1344 200101040833614 13:10:26 25000 1344 Shares 200102140640231 12:01:54 40000 986 200102140640312 12:01:55 40000 986 sold by KP entity 200102140641061 12:02:07 40000 986.25 200102140641073 12:02:07 40000 986.25 through DKB is 200102140641711 12:02:18 40000 986 200102140641721 12:02:18 40000 986 bought by another 200102140642811 12:02:36 40000 985 200102140642839 12:02:36 40000 985 KP entity 200102140644826 12:03:10 40000 984 200102140644823 12:03:10 40000 984 through KCL

15. In the scrip of AEL, KCL purchased 1,00,000 shares of AEL which were sold by Luminant Investments, another KP entity through the broker CSFB. The said transactions were structured as under:

Sell Sell Sell Buy Buy Buy Order Order Order Order Order Order Sell Order No Time Qty Price Buy Order No Time Qty Price 200102160965301 13:27:16 50000 859 20010216096526313:27:15 50000 859 200102160965765 13:27:27 50000 859 20010216096576413:27:27 50000 859

16. From the above tables, I note that KCL executed as many as 48 trades on behalf of the KP entities. Out of these trades mentioned above, 46 trades executed in the scrip of HFCL and 2 trades were in respect of the scrip of AEL. It is pertinent to note that in the 48 trades executed by KCL for the KP entities, the buy and sell orders in respect of the said trades were placed almost simultaneously. Further, it is also pertinent to note that the ordered quantities and the order price in the said trades were almost identical.

17. On perusal of the trading data in the scrip of HFCL, I note that there were many instances of such transactions where time of placing the orders, ordered quantity and price are matching. The perfect matching of the said trades in an identical fashion over a period of 16 months clearly indicates that these transactions were synchronized.

18. On perusal of the trading data in respect of HFCL 46 trades executed by KCL on behalf of the KP entities I find that the order time, quantity, price etc. are identical. It cannot be a coincidence that in respect of such large number of trades executed over a period of time the above characteristics are identical in nature. On the contrary, it can be inferred from such large number of trades that these trades were executed in a pre-determined fashion. The intention of the parties involved in the transaction to synchronize the transactions is clearly evident from the facts and circumstances of the case. In this regard, the argument that due to high volume in the scrip, it was difficult for the broker to suspect these transactions as fictitious is devoid of merit as KCL had executed both buy and sell transactions over a period of time and the perfect matching of the said trades clearly indicate involvement of the broker in synchronizing the trades.

19. As stated above, the transactions clearly indicate the meticulous manner in which the same have been synchronized. In view of the large number of synchronized transactions executed by KCL on behalf of the KP entities on the buy side as well as sell side in the scrip of HFCL, I conclude that KCL had aided and assisted KP entities to create false and misleading appearance of trading in the said scrip, to execute transactions which are not genuine and also trades without transfer of beneficial ownership for the purpose of causing fluctuations in the market price of the securities. In view of the same it is concluded that KCL had violated the provisions of Regulation 4 (b), 4(c) and 4(d) of PFUTP Regulations, 1995.

20. The large number of synchronized trades over a period of time clearly indicate that KCL failed to exercise due skill and care as mandated under the provisions of clause A (2) of Schedule II read with Regulation 7 of the SEBI (Stock Brokers and Sub-brokers) Regulations, 1992. In view of the same, it is found that KCL violated the provisions of Clause A (2) of the Code of Conduct for Stock Brokers enumerated under Schedule II under Regulation 7 of the SEBI (Stock Brokers and Sub-brokers) Regulations, 1992.

21. Taking the overall view of the present matter, it is observed that KCL executed 46 synchronised trades in the scrip of HFCL for KP entities for a period of 16 months where the counterparts were also KP entities. KCL cannot escape their responsibility on the plea that they were not aware of Shri Ketan Parekh's manipulative intentions in the market. While appraising the conduct of KCL as a market participant, the same has to be viewed in the overall context of the happenings in the market at the material point of time and can not be viewed in isolation. I am of the view that all who have knowingly or unknowingly / directly or indirectly assisted Ketan Parekh entities in the market manipulation have to be held responsible to the extent of their acts of omissions or commissions and the penalty has to be commensurate with their contribution in the market manipulation. Taking into consideration the total number of synchronised trades executed by KCL vis a vis the total trades executed in the market during the relevant period and also the fact that trades were executed on behalf of clients and no proprietary trades were executed, in my view, the ends of justice would meet if the penalty as recommended by the Enquiry Officer is reduced.

22. Now, therefore, in exercise of powers conferred vide Regulation 13(4) of SEBI (Procedure for Holding Enquiry by Enquiry Officer and Imposing Penalty) Regulations, 2002, I hereby impose a minor penalty of suspension of certificate of registration for a period of one day on Keynote Capitals Ltd. (PAN No. AAACK2618R).

23. This order shall come into effect on expiry of 21 days from the date of this order.

PLACE: MUMBAI T. C. NAIR DATE: 09.07. 2008 WHOLE TIME MEMBER SECURITIES AND EXCHANGE BOARD OF INDIA

ANNEXURE A: STRUCTURED TRANSACTIONS IN THE SCRIP OF HFCL WHEREIN KCL ACTS AS A BROKER ON EITHER THE BUY OR THE SELL SIDE B U TIME Y/ DIFF. SETTLE S ORDE BET. BUY COUNTE CLIEN MENT TRADE TRADE TRADE TRADE TRADE ORDER EL R ORDER ORDER & SELL MEMBER R PARTY T NO. DATE NO TIME QTY PRICE NUMBER L RATE QTY TIME ORDER NAME NAME NAME Keynot e 8504000 Capital 15-Nov-99 8572 14:01:15 25000 348.00 5 S 348 25000 14:01:15 C J Dalal s CCL 199903 1200400 Keynote C J 5 15-Nov-99 8572 14:01:15 25000 348.00 20 B 348 25000 14:01:15 0:00:00 Cap Dalal CCL Keynot e 8504004 352.7 Capital 16-Nov-99 21391 12:53:48 25000 352.75 6 S 5 25000 12:53:46 C J Dalal s CCL 199903 1200400 352.7 Keynote C J 5 16-Nov-99 21391 12:53:48 25000 352.75 81 B 5 25000 12:53:47 0:00:01 Capitals Dalal CCL Keynot e 8504012 Capital 19-Nov-99 47828 13:08:36 10000 361.50 6 B 361.5 10000 13:08:36 C J Dalal s CCL 199903 1200401 Keynote C J 5 19-Nov-99 47828 13:08:36 10000 361.50 61 S 361.5 10000 13:08:35 0:00:01 Capitals Dalal CCL 1200010 Hem 0010006 1307. Keynote Securiti 04-Oct-00 28895 13:05:26 20000 1307.3 557 S 3 20000 13:05:25 Capitals es PFMS Keynot 2480030 Hem e 200002 0010001 1307. Securitie Capital 8 04-Oct-00 28895 13:05:26 20000 1307.3 527 B 3 20000 13:05:25 0:00:00 s s PFMS Keynot 8500400 e 0100023 1307. Capital 04-Oct-00 28926 13:07:37 19500 1307.5 87 B 5 20000 13:07:36 C J Dalal s PFMS 1200010 200002 0010006 1307. Keynote C J 8 04-Oct-00 28926 13:07:37 19500 1307.5 558 S 5 20000 13:07:37 0:00:01 Capitals Dalal PFMS 1200010 Hem 0010006 1224. Keynote Securiti 10-Oct-00 48020 14:22:00 34700 1224.5 709 B 5 35000 14:22:00 Capitals es PFMS Keynot 2480030 Hem e 200002 0010001 1224. Securitie Capital 9 10-Oct-00 48020 14:22:00 34700 1224.5 591 S 5 35000 14:21:57 0:00:03 s s PFMS 1200010 Hem 0010006 Keynote Securiti 13-Oct-00 133129 11:52:02 34995 1003 765 S 1003 35000 11:52:02 Capitals es PFMS Keynot 2480030 Hem e 200002 0010001 Securitie Capital 9 13-Oct-00 133129 11:52:02 34995 1003 652 B 1003 35000 11:52:00 0:00:02 s s PFMS 1200010 Milan 0010006 Keynote Mahen 16-Oct-00 18580 14:01:11 97191 1086 832 B 1086 100000 14:01:10 Capitals dra Sec PFMS Keynot 4600120 Milan e 200003 0010001 Mahendr Capital 0 16-Oct-00 18580 14:01:11 97191 1086 352 S 1086 100000 14:01:09 0:00:01 a Sec s PFMS Keynot 1200010 e 0010006 1230. Keynote Capital 20-Oct-00 169658 12:29:29 22000 1230.7 942 B 7 22000 12:29:28 Capitals s PFMS Keynot 1200050 e 200003 0010004 1230. Keynote Capital 0 20-Oct-00 169658 12:29:29 22000 1230.7 295 S 7 22000 12:29:28 0:00:00 Capitals s PFMS

Keynot 8500400 e 0100025 Capital 27-Oct-00 30626 15:29:24 11359 1178 91 S 1178 15000 15:29:23 C J Dalal s PFMS 1200010 200003 0010007 Keynote C J 2 27-Oct-00 30626 15:29:24 11359 1178 098 B 1178 15000 15:29:23 0:00:00 Capitals Dalal PFMS 1200010 Hem 0010007 Keynote Securiti 27-Oct-00 30687 15:29:54 12810 1179 099 B 1179 35000 15:29:53 Capitals es PFMS Keynot 2480030 Hem e 200003 0010001 Securitie Capital 2 27-Oct-00 30687 15:29:54 12810 1179 819 S 1179 35000 15:29:54 0:00:01 s s PFMS Keynot 8500400 e 0100027 1323. Capital 03-Nov-00 174014 14:18:20 44575 1323.5 06 B 5 50000 14:18:19 C J Dalal s PFMS 1200050 200003 0010004 1323. Keynote C J 2 03-Nov-00 174014 14:18:20 44575 1323.5 609 S 5 50000 14:18:20 0:00:01 Capitals Dalal PFMS 1200010 Latin 0010007 Keynote Manhar 20-Nov-00 22096 14:26:06 24730 1339 622 B 1339 25000 14:26:06 Capitals lal PFMS Keynot 4050460 Latin e 200003 0000001 Manharla Capital 5 20-Nov-00 22096 14:26:06 24730 1339 249 S 1339 25000 14:26:04 0:00:02 l s PFMS 1200010 Milan 0010007 Keynote Mahen 20-Nov-00 22152 14:27:22 24510 1339 623 B 1339 25000 14:27:21 Capitals dra Sec PFMS Keynot 4600120 Milan e 200003 0010001 Mahendr Capital 5 20-Nov-00 22152 14:27:22 24510 1339 576 S 1339 25000 14:27:22 0:00:01 a Sec s PFMS 1200010 Milan 0010007 1334. Keynote Mahen 20-Nov-00 22578 14:34:43 20000 1334.5 625 B 5 20000 14:34:42 Capitals dra Sec PFMS Keynot 4600120 Milan e 200003 0010001 1334. Mahendr Capital 5 20-Nov-00 22578 14:34:43 20000 1334.5 577 S 5 20000 14:34:42 0:00:00 a Sec s PFMS 1200010 Hem 0010007 Keynote Securiti 20-Nov-00 22839 14:35:54 28700 1331 626 B 1331 30000 14:35:48 Capitals es PFMS Keynot 2480030 Hem e 200003 0010002 Securitie Capital 5 20-Nov-00 22839 14:35:54 28700 1331 115 S 1331 30000 14:35:53 0:00:05 s s PFMS Keynot 8500400 e 0100035 Capital 22-Dec-00 189960 11:59:52 35995 1223 38 B 1223 40000 11:59:50 C J Dalal s PFMS 1200050 200003 0010006 Keynote C J 9 22-Dec-00 189960 11:59:52 35995 1223 202 S 1223 40000 11:59:52 0:00:02 Capitals Dalal PFMS Keynot 8500400 e 0000011 1414. Capital 21-Jul-00 109674 11:35:36 19995 1414.50 41 B 5 20000 11:35:35 C J Dalal s PFMS 1200010 200001 0000003 1414. Keynote C J 7 21-Jul-00 109674 11:35:36 19995 1414.50 017 S 5 20000 11:35:36 0:00:01 Capitals Dalal PFMS Keynot 8500400 e 0100016 Capital 25-Aug-00 130700 13:29:10 26630 1561.00 76 B 1561 30000 13:29:09 C J Dalal s PFMS 200002 1200010 Keynote C J 2 25-Aug-00 130700 13:29:10 26630 1561.00 0010004 S 1561 30000 13:29:10 0:00:01 Capitals Dalal PFMS

1200010 Hem 0010005 Keynote Securiti 29-Aug-00 49483 14:06:01 99345 1422.00 106 B 1422 100000 14:06:00 Capitals es PFMS Keynot 2480030 Hem e 200002 0010000 Securitie Capital 3 29-Aug-00 49483 14:06:01 99345 1422.00 836 S 1422 100000 14:06:00 0:00:00 s s CCL 1200010 Hem 0010005 1417. Keynote Securiti 29-Aug-00 50051 14:14:46 16529 1417.50 107 B 5 20000 14:14:46 Capitals es PFMS Keynot 2480030 Hem e 200002 0010000 1417. Securitie Capital 3 29-Aug-00 50051 14:14:46 16529 1417.50 837 S 5 20000 14:14:45 0:00:01 s s CCL 1200010 Milan 0010006 Keynote Mahen 22-Sep-00 206326 12:27:30 24875 1339.00 138 S 1339 25000 12:27:30 Capitals dra Sec PFMS Keynot 4600120 Milan e 200002 0010001 Mahendr Capital 6 22-Sep-00 206326 12:27:30 24875 1339.00 069 B 1339 25000 12:27:29 0:00:01 a Sec s PFMS Keynot 8500400 e 0100037 1164. Capital 18-Jan-01 186961 15:21:02 49050 1164.5 16 S 5 50000 15:21:00 C J Dalal s PFMS 1200010 PFMS 200004 0010009 1164. Keynote C J (7600 3 18-Jan-01 186961 15:21:02 49050 1164.5 093 B 5 50000 15:21:02 0:00:02 Capitals Dalal ) 1200050 Hem PFMS 0010006 1181. Keynote Securiti (7557 19-Jan-01 198854 11:18:06 20873 1181.8 957 S 8 25000 11:18:06 Capitals es ) Keynot 2480030 Hem e 200004 0010002 1181. Securitie Capital 3 19-Jan-01 198854 11:18:06 20873 1181.8 856 B 8 25000 11:18:06 0:00:00 s s PFMS Keynot 8500400 e 0100038 Capital 02-Feb-01 163709 11:27:32 11848 1073 93 B 1073 25000 11:27:30 C J Dalal s PFMS 1200010 200004 0010009 Keynote C J 5 02-Feb-01 163709 11:27:32 11848 1073 416 S 1073 25000 11:27:32 0:00:02 Capitals Dalal PFMS 1200010 Hem 0010009 Keynote Securiti 02-Feb-01 169542 12:28:23 14657 1074 423 S 1074 15000 12:28:22 Capitals es PFMS Keynot 2480030 Hem e 200004 0010003 Securitie Capital 5 02-Feb-01 169542 12:28:23 14657 1074 260 B 1074 14786 12:28:22 0:00:00 s s PFMS 1200050 Latin 0010007 Keynote Manhar 09-Feb-01 205448 14:12:22 158942 999 772 S 999 159000 14:12:22 Capitals lal PFMS Keynot 4050460 Latin e 200004 0000002 Manharla Capital 6 09-Feb-01 205448 14:12:22 158942 999 093 B 999 159000 14:12:22 0:00:00 l s PFMS 1200050 Hem 0010008 Keynote Securiti 23-Feb-01 216098 12:23:23 24995 786.5 425 S 786.5 25000 12:23:23 Capitals es PFMS Keynot 2480030 Hem e 200004 0010003 Securitie Capital 8 23-Feb-01 216098 12:23:23 24995 786.5 708 B 786.5 25000 12:23:22 0:00:01 s s PFMS Keynot 8500400 e 200004 0100041 Capital 9 28-Feb-01 90068 10:14:54 90395 590 45 S 590 100000 10:14:53 C J Dalal s PFMS

MAD HUR SHAR ES (7539 5) & 1200010 PFMS 0010010 Keynote C J (1500 28-Feb-01 90068 10:14:54 90395 590 055 B 590 100000 10:14:53 0:00:00 Capitals Dalal 0) 1200050 Milan 0010008 Keynote Mahen 02-Mar-01 214800 11:18:58 99825 667 660 S 667 100000 11:18:58 Capitals dra Sec PFMS Keynot 4600120 Milan e 200004 0010002 Mahendr Capital 9 02-Mar-01 214800 11:18:58 99825 667 208 B 667 100000 11:18:56 0:00:02 a Sec s PFMS 1200010 Hem 0010010 Keynote Securiti 07-Mar-01 51925 11:35:36 80000 479 247 S 479 80000 11:35:36 Capitals es PFMS Keynot 2480030 Hem e 200005 0010003 Securitie Capital 0 07-Mar-01 51925 11:35:36 80000 479 875 B 479 80000 11:35:36 0:00:00 s s PFMS 1200010 Hem 0010010 Keynote Securiti 07-Mar-01 52855 11:38:20 88555 472 248 S 472 95000 11:38:19 Capitals es PFMS Keynot 2480030 Hem e 200005 0010003 Securitie Capital 0 07-Mar-01 52855 11:38:20 88555 472 887 B 472 95000 11:38:19 0:00:00 s s PFMS