Order against M/s. Amgis Holdings Private Limited in the Matter of M/s. Roofit Industries Limited

1.1 M/s. Roofit Industries Limited was incorporated on February 18, 1982 as a private limited company in the name and style of M/s. Ratnagiri Asbestos Private Limited. Its name was changed to M/s. Ratnagiri Building Products Limited on October 21, 1987. In December 1988, the company started commercial production under the ‘Roofit ’ brand. In 1996, the name of the company was further changed to M/s. Roofit Industries Limited (hereinafter referred to as “Roofit” or the “company”). During 1986, the Motwani Group acquired the controlling interest in the company. One of the group companies of Roofit is M/s. Sun Earth Ceramics Limited. The company is listed at Delhi Stock Exchange (DSE), National Stock Exchange (NSE), Bombay Stock Exchange (BSE) and Ahmedabad Stock Exchange, (ASE).

1.2 Based on the investigation report submitted by NSE for the period 06.10.99 - 03.12.99, the Securities and Exchange Board of India (SEBI) on March 22, 2000 initiated investigations into the scrip of Roofit to examine the reasons behind the sudden spurt in the price and the trading volume in the scrip. At the same time, SEBI had received a complaint dated 19-01-2001 from Shri Michael D’Silva to the effect that the management of the company directly/indirectly controlled the entire shareholding of the company and that it is being used to rig the share price. Thus, NSE was requested to carry out another investigation. In response, NSE submitted another investigation report on December 31, 2001, for the period 08.11.2000 to 06.02.2001. Further, NSE conducted an investigation for the period 07.02.2001 to 08.05.2001 and submitted its report on September 11, 2002.

1.3 BSE was required to investigate the matter and submit its report to SEBI as the scrip was listed and traded on BSE. BSE conducted investigations for the periods 10.10.99 -12.12.99 and 22.01.01 - 04.05.01 and submitted its investigation reports on September 26, 2001 and May 24, 2002, respectively.

1.4 Thus, cumulatively, the investigations by NSE and BSE, in the scrip of Roofit covered the following periods: a. 06.10.99 to 12.12.99 b. 08.11.2000 to 06.02.2001 and c. 07.02.2001 to 08.05.2001.

1.5 NSE and BSE in their investigation reports have identified 16 brokers including M/s. Amgis Holdings Private Limited (herein after referred to as “Amgis” or the “broker”). SEBI examined their role based on the trading details of the respective brokers in the scrip. SEBI undertook detailed investigations to look into the possible violations of the provisions of Regulation 4 of SEBI (Prohibitions of Unfair Trade Practices Relating to Securities Markets) Regulations 1995 and the provisions of the code of conduct prescribed for stock brokers set out under Regulation 7 of SEBI (Stock Brokers and Sub-Brokers) Regulations, 1992, by the broker.

1.6 The investigation report revealed the following with respect to Amgis:

1.6.1 The trades executed by the noticee are as below: Table 1

SETT. NO. CLIENT NAME BUY QTY SELL QTY GROSS QTY NET QTY 1999040 Senorita 10500 0 10500 10500 1999042 Senorita 15200 0 15200 15200 1999043 Senorita 5700 0 5700 5700 1999044 Senorita 17000 8000 25000 9000 1999045 Senorita 28300 28300 56600 0 1999046 Senorita 19000 24500 43500 -5500 1999047 Senorita 20600 19000 39600 1600 1999048 Senorita 42500 4100 46600 38400 1999050 Senorita 100 34600 34700 -34500 1999050 Senorita 82200 82200 164400 0 1999051 Senorita 400 400 800 0 2000003 Senorita 5000 5000 5000 2000004 Senorita 2900 0 2900 2900 2000046 Onlooker 53041 0 53041 53041 2000046 Habiscus 35983 35963 71946 20 2000047 Onlooker 57274 0 57274 57274 2000047 Habiscus 1800 1800 3600 0 2000048 Onlooker 6964 0 6964 6964 2000053 Habiscus 71578 0 71578 71578 2000053 Onlooker 70852 0 70852 70852 2001001 S J Impex 16478 16478 32956 0 2001001 Habiscus 36502 0 36502 36502 2001002 Mayfair Realtor 53288 0 53288 53288 2001002 S J Impex 100300 100300 200600 0 2001002 Habiscus 51076 0 51076 51076 M’Belle 2001003 71530 0 71530 71530 International 2001003 S J Impex 98186 98186 196372 0 2001003 Alkan Project 68664 0 68664 68664 M’Belle 2001004 21221 0 21221 21221 International 2001004 Alkan Project 19840 0 19840 19840 2001005 S J Impex 1200 1200 2400 0 M’Belle 2001005 172930 0 172930 172930 International 2001005 Onlooker 171710 0 171710 171710 M’Belle 2001006 26124 0 26124 26124 International M’Belle 2001007 146399 0 146399 146399 International 2001007 Alkan Projects 152000 0 152000 152000 M’Belle 2001008 8191 0 8191 8191 International

M’Belle 2001009 232520 0 232520 232520 International Onlooker 2001009 95914 0 95914 95914 Investment M’Belle 2001010 4661 0 4661 4661 International M’Belle 2001011 272100 70000 342100 202100 International Onlooker 2001011 150210 0 150210 150210 Investment M’Belle 2001012 2291 0 2291 2291 International M’Belle 2001013 1263 100 1363 1163 International Akira Investments 2001014 705 0 705 705 Ltd. Akira Investments 2001015 14001 80 14081 13921 Ltd. Akira Investments 2001016 79795 0 79795 79795 Ltd. Akira Investments 2001017 425 0 425 425 Ltd. Akira Investments 2001018 5871 100 5971 5771 Ltd.

The following are the clients for whom M/s. Amgis has executed trades: i. M/s. Senorita Impex Pvt. Ltd. ii. M/s. Onlooker Investments Pvt. Ltd. iii. M/s. Habiscus Investments Pvt. Ltd. iv. M/s. S.J.Impex v. M/s. Mayfair Realtors Pvt. Ltd. vi. M/s. M’Belle International Pvt. Ltd. vii. M/s. Alkan Projects Pvt. Ltd. viii. M/s. Akira Investments Pvt. Ltd. In almost all of the settlements, the member has bought for its clients.

1.6.2 Trade Log Analysis between M/s. Amgis Holdings Pvt. Ltd. and M/s. Goldcrest Capital Market Ltd. Table 2 BUY SELL BUY SELL TRADE TRADE TRADE BUY TM ORDER SELL TM ORDER DATE CLIENT CLIENT TIME QTY PRICE NAME ENTRY NAME ENTRY NAME NAME TIME TIME 20-Nov-00 12:32:35 659 268 Amgis Onlooker 12:32:31 Goldcrest Ami Impex 12:32:35 20-Nov-00 12:32:45 4541 268 Amgis Onlooker 12:32:45 Goldcrest Ami Impex 12:32:35 20-Nov-00 12:32:45 46800 268 Amgis Onlooker 12:32:45 Goldcrest Ami Impex 12:32:35 27-Dec-00 10:41:07 25000 121 Amgis H(Habiscus) 10:41:07 Goldcrest Mayfair 10:41:03 27-Dec-00 10:41:47 25000 121.5 Amgis H(Habiscus) 10:41:47 Goldcrest Onlooker 10:41:45 27-Dec-00 11:06:40 25000 120.25 Amgis H(Habiscus 11:06:40 Goldcrest Onlooker 11:06:28

=6658& onlook=183 42) 27-Dec-00 11:07:13 25000 120.25 Amgis H(onlooker) 11:07:13 Goldcrest Onlooker 11:07:11 27-Dec-00 11:08:07 25000 120.1 Amgis H(onlooker) 11:08:07 Goldcrest Onlooker 11:08:04 08-Jan-01 10:38:37 25000 119.5 Amgis H(Habiscus) 10:38:37 Goldcrest Habiscus 10:38:25 H(Habiscus =8903& S J 08-Jan-01 10:39:12 25000 119 Amgis 10:39:12 Goldcrest Habiscus 10:38:57 Impex 16093) O(Habiscus =48961& S 11-Jan-01 10:25:18 50000 118.75 Amgis J 10:25:18 Goldcrest Habiscus 10:25:06 Impex=103 9) 11-Jan-01 10:26:14 50000 118.85 Amgis O(Mayfair) 10:26:14 Goldcrest Habiscus 10:25:44 M(Alkan 17-Jan-01 10:15:56 25000 122 Amgis 10:15:56 Goldcrest Habiscus 10:15:39 Projects) M(Alkan 17-Jan-01 10:16:08 25000 123 Amgis 10:16:08 Goldcrest Habiscus 10:16:06 Projects) M(Alkan Projects=15 17-Jan-01 10:16:26 25000 124 Amgis 000 & 10:16:26 Goldcrest Habiscus 10:16:21 M'Belle=100 00) M(M'Belle= 22236 & 17-Jan-01 10:17:07 25000 123.75 Amgis 10:17:07 Goldcrest Habiscus 10:16:50 Alkan Proj 2764) 18-Jan-01 13:48:57 36000 121.75 Amgis M(M' belle) 13:48:57 Goldcrest Habiscus 13:48:52 AMBEL(M'B elle=19910 Alkan 24-Jan-01 10:29:21 34800 124 Amgis & 10:29:21 Goldcrest 10:29:07 Projects Alkan=1489 0) AMBEL(Alk Alkan 24-Jan-01 10:29:34 200 124 Amgis 10:29:34 Goldcrest 10:29:07 an Proj) Projects M(M'Belle= 2675& 31-Jan-01 10:00:57 10000 131.5 Amgis 10:00:57 Goldcrest Jyoti Mehta 10:00:56 Onlook=732 5) M(Onlooker =89675 & S 31-Jan-01 10:11:34 89900 124 Amgis 10:11:34 Goldcrest Onlooker 10:11:33 J Impex= 225) 31-Jan-01 10:13:31 39800 124 Amgis A(M'Belle) 10:13:31 Goldcrest Habiscus 10:13:29 31-Jan-01 10:14:00 200 124 Amgis A(Onlooker) 10:13:31 Goldcrest Habiscus 10:14:00 A(M'Belle=3 7600 & 31-Jan-01 10:14:01 49800 124 Amgis 10:14:01 Goldcrest Habiscus 10:14:00 Alkan 12200 ) 31-Jan-01 10:14:27 50000 124.25 Amgis A(Onlooker) 10:14:27 Goldcrest Habiscus 10:14:24 31-Jan-01 10:15:21 49800 124 Amgis H(M'Belle = 10:15:21 Goldcrest Ami Impex 10:15:20 M(M'Belle=4 0000 & 31-Jan-01 11:00:49 50000 124.75 Amgis 11:00:49 Goldcrest Ami Impex 11:00:42 Onlooker=1 0000) M'Belle Goldcrest Amgis Alkan 128.0 Internatio Capital 10:10: 7-Feb-01 10:10:10 20000 Holdings 10:10:10 Projects 0 nal Pvt. Markets 00 Pvt Ltd Pvt. Ltd. Ltd. Ltd M'Belle Goldcrest Amgis Alkan 127.6 Internatio Capital 10:19: 14-Feb-01 10:19:14 49500 Holdings 10:19:14 Projects 5 nal Pvt. Markets 09 Pvt Ltd Pvt. Ltd. Ltd. Ltd M'Belle Goldcrest Amgis Alkan 127.6 Internatio Capital 10:19: 14-Feb-01 10:19:24 500 Holdings 10:19:24 Projects 5 nal Pvt. Markets 09 Pvt Ltd Pvt. Ltd. Ltd. Ltd

M'Belle Goldcrest Amgis Alkan 127.5 Internatio Capital 10:19: 14-Feb-01 10:19:45 4300 Holdings 10:19:45 Projects 0 nal Pvt. Markets 42 Pvt Ltd Pvt. Ltd. Ltd. Ltd M'Belle Goldcrest Amgis Alkan 127.5 Internatio Capital 10:19: 14-Feb-01 10:19:45 4300 Holdings 10:19:45 Projects 0 nal Pvt. Markets 42 Pvt Ltd Pvt. Ltd. Ltd. Ltd M'Belle Goldcrest Amgis Alkan 127.5 Internatio Capital 10:19: 14-Feb-01 10:19:45 4300 Holdings 10:19:45 Projects 0 nal Pvt. Markets 42 Pvt Ltd Pvt. Ltd. Ltd. Ltd M'Belle Goldcrest Amgis Alkan 127.5 Internatio Capital 10:19: 14-Feb-01 10:19:45 4300 Holdings 10:19:45 Projects 0 nal Pvt. Markets 42 Pvt Ltd Pvt. Ltd. Ltd. Ltd M'Belle Goldcrest Amgis Alkan 127.5 Internatio Capital 10:19: 14-Feb-01 10:19:45 4300 Holdings 10:19:45 Projects 0 nal Pvt. Markets 42 Pvt Ltd Pvt. Ltd. Ltd. Ltd M'Belle Goldcrest Amgis Alkan 127.5 Internatio Capital 10:19: 14-Feb-01 10:19:45 4300 Holdings 10:19:45 Projects 0 nal Pvt. Markets 42 Pvt Ltd Pvt. Ltd. Ltd. Ltd M'Belle Goldcrest Amgis Alkan 127.5 Internatio Capital 10:19: 14-Feb-01 10:19:45 4300 Holdings 10:19:45 Projects 0 nal Pvt. Markets 42 Pvt Ltd Pvt. Ltd. Ltd. Ltd M'Belle Goldcrest Amgis Alkan 127.5 Internatio Capital 10:19: 14-Feb-01 10:19:45 4300 Holdings 10:19:45 Projects 0 nal Pvt. Markets 42 Pvt Ltd Pvt. Ltd. Ltd. Ltd M'Belle Goldcrest Amgis Alkan 127.5 Internatio Capital 10:19: 14-Feb-01 10:19:45 4300 Holdings 10:19:45 Projects 0 nal Pvt. Markets 42 Pvt Ltd Pvt. Ltd. Ltd. Ltd M'Belle Goldcrest Amgis Alkan 127.5 Internatio Capital 10:19: 14-Feb-01 10:19:45 3800 Holdings 10:19:45 Projects 0 nal Pvt. Markets 42 Pvt Ltd Pvt. Ltd. Ltd. Ltd M'Belle Goldcrest Amgis Alkan 127.5 Internatio Capital 10:19: 14-Feb-01 10:19:59 500 Holdings 10:19:59 Projects 0 nal Pvt. Markets 42 Pvt Ltd Pvt. Ltd. Ltd. Ltd M'Belle Goldcrest M'Belle Amgis 123.5 Internatio Capital Internatio 10:21: 14-Feb-01 10:21:18 50000 Holdings 10:21:18 0 nal Pvt. Markets nal Pvt. 15 Pvt Ltd Ltd. Ltd Ltd. Goldcrest M'Belle Amgis Alkan 122.0 Capital Internatio 10:24: 14-Feb-01 10:24:29 50000 Holdings Project 10:24:29 0 Markets nal Pvt. 10 Pvt Ltd Pvt. Ltd. Ltd Ltd. Goldcrest M'Belle Amgis Alkan 121.7 Capital Internatio 10:24: 14-Feb-01 10:25:09 57000 Holdings Project 10:25:09 5 Markets nal Pvt. 58 Pvt Ltd Pvt. Ltd. Ltd Ltd. Goldcrest M'Belle Amgis Alkan 122.7 Capital Internatio 10:28: 14-Feb-01 10:28:28 45000 Holdings Project 10:28:28 5 Markets nal Pvt. 23 Pvt Ltd Pvt. Ltd. Ltd Ltd. M'Belle Goldcrest Amgis 124.0 Internatio Capital Jyoti J. 9:59:5 28-Feb-01 10:00:03 34900 Holdings 10:00:03 0 nal Pvt. Markets Mehta 6 Pvt Ltd Ltd. Ltd M'Belle Goldcrest Amgis 124.0 Internatio Capital Jyoti J. 9:59:5 28-Feb-01 10:00:13 100 Holdings 10:00:11 0 nal Pvt. Markets Mehta 6 Pvt Ltd Ltd. Ltd 28-Feb-01 10:05:05 27200 121.0 Amgis M'Belle 10:05:05 Goldcrest Onlooker 10:05:

0 Holdings Internatio Capital Investme 02 Pvt Ltd nal Pvt. Markets nts Pvt. Ltd. Ltd Ltd. M'Belle Goldcrest Onlooker Amgis 121.5 Internatio Capital Investme 10:05: 28-Feb-01 10:05:41 25800 Holdings 10:05:41 0 nal Pvt. Markets nts Pvt. 37 Pvt Ltd Ltd. Ltd Ltd. Onlooker Goldcrest M'Belle Amgis 120.0 Investme Capital Internatio 10:09: 28-Feb-01 10:09:54 87200 Holdings 10:09:54 0 nts Pvt. Markets nal Pvt. 49 Pvt Ltd Ltd. Ltd Ltd. M'Belle Goldcrest M'Belle Amgis 120.5 Internatio Capital Internatio 10:11: 28-Feb-01 10:11:23 48600 Holdings 10:11:23 0 nal Pvt. Markets nal Pvt. 00 Pvt Ltd Ltd. Ltd Ltd. M'Belle Goldcrest M'Belle Amgis 121.0 Internatio Capital Internatio 10:12: 28-Feb-01 10:12:39 68400 Holdings 10:12:39 0 nal Pvt. Markets nal Pvt. 32 Pvt Ltd Ltd. Ltd Ltd. M'Belle Internatio Goldcrest M'Belle Amgis nal Pvt. 120.5 Capital Internatio 10:13: 28-Feb-01 10:13:19 32800 Holdings Ltd. 10:13:19 0 Markets nal Pvt. 12 Pvt Ltd (25000) Ltd Ltd. Onlooker (7800) M'Belle Goldcrest M'Belle Amgis 115.0 Internatio Capital Internatio 9:57:5 14-Mar01 9:58:06 10000 Holdings 9:58:06 0 nal Pvt. Markets nal Pvt. 8 Pvt Ltd Ltd. Ltd Ltd. M'Belle Goldcrest Habiscus Amgis 115.0 Internatio Capital Investme 10:03: 14-Mar01 10:03:04 25000 Holdings 10:03:04 0 nal Pvt. Markets nts Pvt. 01 Pvt Ltd Ltd. Ltd Ltd. M'Belle Goldcrest Habiscus Amgis 114.0 Internatio Capital Investme 10:03: 14-Mar01 10:03:23 30000 Holdings 10:03:23 0 nal Pvt. Markets nts Pvt. 20 Pvt Ltd Ltd. Ltd Ltd. M'Belle Goldcrest Habiscus Amgis 114.5 Internatio Capital Investme 10:03: 14-Mar01 10:04:04 20000 Holdings 10:04:04 0 nal Pvt. Markets nts Pvt. 47 Pvt Ltd Ltd. Ltd Ltd. Onlooker Goldcrest Amgis 112.2 Investme Capital Jyoti J. 10:13: 14-Mar01 10:13:31 24930 Holdings 10:13:31 5 nts Pvt. Markets Mehta 23 Pvt Ltd Ltd. Ltd M'Belle Goldcrest Amgis 112.2 Internatio Capital Jyoti J. 10:13: 14-Mar01 10:13:40 70 Holdings 10:13:40 5 nal Pvt. Markets Mehta 23 Pvt Ltd Ltd. Ltd Onlooker Goldcrest Amgis 112.2 Investme Capital Jyoti J. 10:14: 14-Mar01 10:14:09 15000 Holdings 10:14:09 5 nts Pvt. Markets Mehta 04 Pvt Ltd Ltd. Ltd Onlooker Goldcrest Onlooker Amgis 110.0 Investme Capital Investme 10:20: 14-Mar01 10:20:29 25000 Holdings 10:20:29 0 nts Pvt. Markets nts Pvt. 22 Pvt Ltd Ltd. Ltd Ltd. Onlooker Goldcrest Onlooker Amgis 113.0 Investme Capital Investme 10:21: 14-Mar01 10:21:13 25000 Holdings 10:21:13 0 nts Pvt. Markets nts Pvt. 08 Pvt Ltd Ltd. Ltd Ltd. Onlooker Goldcrest Onlooker Amgis 112.0 Investme Capital Investme 10:21: 14-Mar01 10:21:39 15000 Holdings 10:21:39 0 nts Pvt. Markets nts Pvt. 34 Pvt Ltd Ltd. Ltd Ltd. Amgis M'Belle Goldcrest Onlooker 112.0 10:21: 14-Mar01 10:21:56 15000 Holdings Internatio 10:21:55 Capital Investme 0 56 Pvt Ltd nal Pvt. Markets nts Pvt.

Ltd. Ltd Ltd. M'Belle Goldcrest Onlooker Amgis 113.0 Internatio Capital Investme 10:22: 14-Mar01 10:22:47 9000 Holdings 10:22:47 0 nal Pvt. Markets nts Pvt. 42 Pvt Ltd Ltd. Ltd Ltd. M'Belle Goldcrest Onlooker Amgis 112.5 Internatio Capital Investme 10:23: 14-Mar01 10:23:09 11000 Holdings 10:23:04 0 nal Pvt. Markets nts Pvt. 09 Pvt Ltd Ltd. Ltd Ltd. Onlooker Goldcrest Habiscus Amgis 110.0 Investme Capital Investme 10:01: 15-Mar01 10:01:19 25000 Holdings 10:01:19 0 nts Pvt. Markets nts Pvt. 08 Pvt Ltd Ltd. Ltd Ltd. M'Belle Internatio nal Goldcrest Habiscus Amgis 112.0 (14930), Capital Investme 10:01: 15-Mar01 10:01:50 14950 Holdings 10:01:50 0 Onlooker Markets nts Pvt. 40 Pvt Ltd Investme Ltd Ltd. nts Pvt. Ltd. (20) Onlooker Goldcrest Habiscus Amgis 112.0 Investme Capital Investme 10:01: 15-Mar01 10:01:59 50 Holdings 10:01:59 0 nts Pvt. Markets nts Pvt. 40 Pvt Ltd Ltd. Ltd Ltd. M'Belle Goldcrest Habiscus Amgis 112.2 Internatio Capital Investme 10:02: 15-Mar01 10:02:30 15000 Holdings 10:02:30 5 nal Pvt. Markets nts Pvt. 28 Pvt Ltd Ltd. Ltd Ltd. M'Belle Goldcrest Habiscus Amgis 111.5 Internatio Capital Investme 10:03: 15-Mar01 10:03:48 25000 Holdings 10:03:48 0 nal Pvt. Markets nts Pvt. 38 Pvt Ltd Ltd. Ltd Ltd. M'Belle Internatio Goldcrest M'Belle Amgis nal Pvt. 111.7 Capital Internatio 10:04: 15-Mar01 10:05:02 15000 Holdings Ltd.(1000 10:05:02 5 Markets nal Pvt. 49 Pvt Ltd 0), Ltd Ltd. Onlooker (5000) M'Belle Goldcrest M'Belle Amgis 111.9 Internatio Capital Internatio 10:05: 15-Mar01 10:05:24 35000 Holdings 10:05:24 0 nal Pvt. Markets nal Pvt. 20 Pvt Ltd Ltd. Ltd Ltd. M'Belle Goldcrest M'Belle Amgis 112.0 Internatio Capital Internatio 10:05: 15-Mar01 10:05:56 15000 Holdings 10:05:56 0 nal Pvt. Markets nal Pvt. 44 Pvt Ltd Ltd. Ltd Ltd. M'Belle Goldcrest M'Belle Amgis 112.0 Internatio Capital Internatio 10:06: 15-Mar01 10:06:38 25000 Holdings 10:06:38 0 nal Pvt. Markets nal Pvt. 26 Pvt Ltd Ltd. Ltd Ltd. M'Belle Goldcrest M'Belle Amgis 111.0 Internatio Capital Internatio 10:07: 15-Mar01 10:07:28 10000 Holdings 10:07:28 0 nal Pvt. Markets nal Pvt. 18 Pvt Ltd Ltd. Ltd Ltd. Onlooker Goldcrest M'Belle Amgis 111.5 Investme Capital Internatio 10:07: 15-Mar01 10:08:07 15000 Holdings 10:08:07 0 nts Pvt. Markets nal Pvt. 55 Pvt Ltd Ltd. Ltd Ltd.

From the above tables the following observations were made:

a) 76 structural deals amounting to 1,847,000 shares were executed between M/s. Amgis and M/s. Goldcrest. b) For all these 76 structural deals, M/s. Amgis acted as a buyer and M/s. Goldcrest acted as a seller. c) Both buy and sell orders have been placed at approximately same time, same price and for the same quantity. d) For some trades, order was placed at a price higher than the previous traded price. e) Same clients have been found trading through both these members. Clients - M/s. Onlooker, M/s. Habiscus and M/s. Alkan - are related to each other, as mentioned under para linkages. These clients traded through both these members acting both as a buyer and as a seller for the same trade / transaction.

f) In 10 trades amounting to 297,000 shares, the client – M/s. M ’ Belle International Pvt. Ltd. was buying shares through Amgis Holdings P. Ltd. and selling shares through M/s. Goldcrest Capital Markets Ltd. at the same time. As brought out under para linkages, M/s. M’Belle is related to the promoter / director of the company M/s. Roofit. g) In 7 trades, the client M/s. Onlooker Investments Pvt. Ltd. has bought shares through M/s. Amgis Holdings P. Ltd. and sold shares through M/s. Goldcrest Capital Markets Ltd. at the same time. As brought out under para linkages, M/s. Onlooker is indirectly related to the promoter / director of the company M/s. Roofit. h) 15 trades amounting to 132,910 shares have been executed on behalf of the client – M/s. M’Belle International Pvt. Ltd. on the buy side and M/s. Alkan Projects Pvt. Ltd. on the sell side. Further, 3 structured deals amounting to 152,000 shares have been executed on behalf of M/s. Alkan Projects Pvt. Ltd. on the buy side and M/s. M’Belle International Pvt. Ltd. on the sell side. As brought out under para linkages M/s. Alkan and M/s. M’Belle are related to the promoter / director of the company M/s. Roofit.

i) 11 trades amounting to 275,566 shares have been executed on behalf of the client – M/s. M’Belle International Pvt. Ltd. on the buy side and M/s. Habiscus Investments Pvt. Ltd. on the sell side. As brought out under para linkages M/s. Habiscus and M/s. M’Belle are related to the promoter / director of the company M/s. Roofit. j) 5 trades amounting to 88,000 shares have been executed on behalf of the client – M/s. M’Belle International Pvt. Ltd. on the buy side and M/s. Onlooker Investments Pvt. Ltd. on the sell side. As brought out under para linkages M/s. Onlooker and M/s. M’Belle are related to the promoter / director of the company M/s. Roofit. k) 5 structured deals have been executed on behalf of M/s. Onlooker Investments P. Ltd. on the buy side and M/s. Habiscus Investments Pvt. Ltd. on the sell side. As brought out under para linkages, M/s. Habiscus and M/s. Onlooker are related to each other and to the promoter / director of the company M/s. Roofit. l) 4 structured deals amounting to 115,000 shares have been executed on behalf of M/s. Onlooker Investments P. Ltd. on the buy side and M/s. M’Belle International Pvt. Ltd. on the sell side. As brought out under para linkages, M/s. Onlooker and M/s. M’Belle are related to the promoter / director of the company M/s. Roofit.

1.6.3 Trades between M/s. Amgis Holdings Pvt. Ltd. and Mr. Prashant J Patel Table 3 Buy Buy Order Sell Sell Order Trade Trade Trade Sell Tm Date Buy Tm Name Client Entry Client Entry Time Qty Price Name Name Time Name Time M(Habiscu s = 9017 & Bharat J 14-Nov-00 10:00:26 21965 253 Amgis 10:00:26 Prashant 10:00:23 12948 = Patel Onlooker) Bharat J 14-Nov-00 10:00:43 25 253 Amgis Onlooker 10:00:43 Prashant 10:00:23 Patel Ami 24-Nov-00 10:01:58 5000 258.9 Amgis Onlooker 10:01:58 Prashant 10:01:58 Impex A(S J 17-Jan-01 10:26:53 50000 124 Prashant Ami Impex 10:26:53 Amgis 10:26:53 Impex) A(S J 17-Jan-01 10:33:13 48185 122 Prashant Ami Impex 10:33:13 Amgis 10:33:08 Impex) O(S.J.Imp Ami 23-Jan-01 09:57:16 50000 125 Amgis ex = 09:57:16 Prashant 09:56:56 Impex 481868 &

M'belle = 1814) S. J. Ami 23-Jan-01 09:57:27 50000 125 Amgis 09:57:27 Prashant 09:56:56 Impex Impex 1000 Ami 15-Mar-01 15:33:52 109.75 prashant 15:33:52 amgis M'Belle 15:33:42 0 Impex 1000 Ami 15-Mar-01 15:34:04 109.75 prashant 15:34:04 amgis M'Belle 15:33:42 0 Impex Ami 15-Mar-01 15:49:18 2500 109.50 prashant 15:49:18 amgis M'Belle 15:49:13 Impex Ami 15-Mar-01 15:49:29 5000 109.50 prashant 15:49:29 amgis M'Belle 15:49:13 Impex Ami 15-Mar-01 15:49:37 7500 109.50 prashant 15:49:37 amgis M'Belle 15:49:13 Impex Ami 15-Mar-01 15:49:47 5000 109.50 prashant 15:49:47 amgis M'Belle 15:49:13 Impex Ami 15-Mar-01 15:49:56 5000 109.50 prashant 15:49:56 amgis M'Belle 15:49:13 Impex 2500 24-Apr-01 15:10:26 109.00 amgis Akira 15:10:26 prashant Hinduja 15:10:20 0 2500 24-Apr-01 15:10:47 109.00 amgis Akira 15:10:47 prashant Hinduja 15:10:43 0 2800 24-Apr-01 15:12:22 109.50 amgis Akira 15:12:22 prashant Hinduja 15:12:20 0 2-May-01 13:52:43 5000 107.00 amgis Akira 13:52:43 prashant Ami 13:52:43

From the above table it is evident that:

a) 18 structural deals amounting to 353,175 shares were executed between M/s. Amgis and Mr Prashant J Patel. b) 7 trades have been executed by M/s. Amgis for its client M/s. M’Belle and by M/s. Prashant for its client M/s. Ami. M/s. M’Belle is related to the promoter / director of the company M/s. Roofit.

1.6.4 Linkages M/s. Amgis has traded for clients who are related to each other and to the member. Some of the clients are related to the promoter / director of the company – M/s. Roofit as shown under:

i. M/s. Habiscus, M/s. Onlooker and M/s. Alkan are related to each other. They have a common director Mr. Suresh Hemwani. The director of both M/s. Habiscus and M/s. Onlooker is Ms. Meenal Chhabaria. Thus, clients M/s. Habiscus and M/s. Onlooker are related to each other. ii. Subscribers to MOA of M/s. M’Belle are Ms. Rita Motwani, Ms. Sangeeta Motwani and Ms. Anupama Motwani. As per the information given by NSE, Ms. Rita Motwani is the wife of Mr. Kishore Motwani who is one of the directors of M/s. Roofit. Ms. Sangeeta Motwani is the wife of Mr. Vinod Motwani who is one of the directors of M/s. Roofit. Ms. Anupama Motwani is the wife of Mr. Suresh Motwani who is one of the directors of M/s. Roofit. Thus, M/s. M’Belle is indirectly related to the promoter / director of the company M/s. Roofit. iii. M/s. Alkan is also one of the persons acting in concert with M/s. Sunearth Ceramics – a group company of M/s. Roofit, having same address as that of M/s. Roofit. Thus, M/s. Alkan is indirectly related to the promoter / director of M/s. Roofit. iv. Client M/s. Onlooker is directly / indirectly related to promoter / director of M/s. Roofit. M/s. New Bharat Builders has introduced M/s. Onlooker to the member M/s. Goldcrest. As per the information given by the exchange, Subscribers to the MOA of M/s. New Bharat Builders is Ms. Sangeeta Motwani and Mr. Kishore Motwani. Ms. Sangeeta Motwani is the wife of Mr. Vinod Motwani. Mr. Kishore Motwani and Mr. Vinod Motwani are one of the directors of M/s. Roofit. Thus, M/s. Onlooker is indirectly related to promoter / director of M/s. Roofit. Thus it can be concluded that M/s. Onlooker, M/s. Habiscus, M/s. M’Belle and M/s. Alkan are related to each other and to the promoter / director of the company M/s. Roofit.

1.6.5 ANALYSIS OF THE DEMAT STATEMENTS Demat statement of the member reveals it did not deliver the number of shares that were due to its clients.

i. In Sett No. 02, member bought 53,288 shares for M/s. Mayfair Realtor and 51,076 shares for M/s. Habiscus. The member credited only 34,788 shares into M/s. Mayfair Realtor’s a/c. and 47,576 shares into M/s. Habiscus’s a/c. The remaining 22,000 shares (104364 – 82364 = 22000) remained in the member’s a/c.

ii. M/s. Amgis had purchased 232,520 shares for M/s. M’Belle in Sett. No.2001009. As per the NSE investigation report, M/s. Amgis transferred 192,470 shares into M/s. M’Belles a/c. and 40,000 shares to another trading member, M/s. Goldcrest’s BSE beneficiary account. iii. M/s. Amgis had purchased 202,100 shares for M/s. M’Belle in Sett. No.2001011. As per the NSE investigation report, M/s. Amgis transferred 46,000 shares into another trading member, M/s. Express Securities’s account.

1.6.6 Therefore, it appears that M/s. Amgis was making adjustment for its clients as far as delivery of securities was concerned, which only highlights the close relationship / association between their clients and the trading member. Further, the transfer of large quantity of shares belonging to clients by the trading member to other trading members only reflects that the trading member was aware that the client was dealing through other trading members and was ready to accommodate the net settlement obligations arising out of transactions of other trading members.

1.6.7 I find that Shri Deven Mehta had admitted that he was aware that the clients M/s. Onlooker, M/s. Habiscus, M/s. Akira, M/s. Alkan, M/s. M’Belle and M/s. Mayfair Realtors are / were directly / indirectly related to each other. Shri Deven Mehta had introduced these related clients to various brokers who acted as financiers for them. Shri Deven Mehta stated that the clients M/s. Onlooker, M/s. Habiscus, M/s. Akira, M/s. Alkan, M/s. M’Belle and M/s. Mayfair Realtors were in need of funds and as they were known to him, on some occasions, he did introduce them to other brokers viz.M/s. Goldcrest, M/s. Prashant J Patel, M/s. Express Securities and M/s. Bharat J Patel.

1.6.8 These related entities sold shares through the above mentioned brokers. The purchases for these sales were made through M/s. Amgis Holdings

Pvt. Ltd. one of the broking entities of Shri Deven Mehta entering into structural / matched deals and the cycle of such transactions continued settlement after settlement. M/s. Amgis, by entering into structural deals with the broking entities who had made the payments ensured that these related clients did not lose control over their shares and that the cycle could be repeated. As per the statement given by Shri Deven Mehta, he was aware that the clients for whom they have executed trades were also executing trades in the scrip of M/s. Roofit through other members at either BSE or NSE. Thus, M/s. Amgis has aided and abetted the clients in their activity and has misutilised the system.

1.6.9 The investigation report has concluded the following: i) The ultimate clients of the trading member M/s. Amgis and the ultimate clients of the trading member M/s. Goldcrest with whom member has executed structural deals are related to each other and to the promoter / director of the company M/s. Roofit. ii) The trading member executed a series of matched trades with various brokers with a view to influence the price as well to create volume. iii) Demat statement of the member shows that the member was making adjustment for its clients as far as delivery of shares was concerned. iv) Member transferred large number of shares into the account of another trading member. v) Member has aided and abetted the related clients in raising fund from the market. vi) Member has misutilised the system.

1.6.10. Based on the conclusions, investigations had alleged that M/s. Amgis has aided and abetted its related client as well as acted in concert with the related client in a) Creation of false market or misleading appearance of trading in the market. b) Execution of transaction that is not genuine trade transaction and c) Execution of transaction intended to inflate or cause fluctuations in the market price of the security and therefore, has violated the provisions of Regulation 4(b), 4(c) and 4(d) of SEBI ( Prohibition of Fraudulent and Unfair Trade Practices Relating to Securities Markets), Regulations, 1995 read with Regulation 13 of the SEBI ( Prohibition of Fraudulent and Unfair Trade Practices Relating to Securities Markets), Regulations, 2003 and Clause A(1) and A(4) coming under Regulation 7 of the SEBI (Stock Brokers and Sub Brokers Rules and Regulations), 1992.

2.0 ENQUIRY REPORT AND FINDINGS

2.1 In view of irregularities brought out in the investigation report and the allegations made against Amgis, SEBI vide order dated 23rd June 2003 read with order dated 24th July 2003 appointed an Enquiry Officer to enquire into the involvement of Amgis in trading in the shares of Roofit. Enquiry Officer issued a show cause notice dated 19th September 2003 to Amgis to which Amgis responded vide its letter dated 19th September 2003. Thereafter Enquiry Officer had given an opportunity of personal hearing to Amgis on 18th December 2003. After completion of enquiry, Enquiry Officer submitted a report dated 4th April 2004. In his report, the Enquiry Officer found that Amgis had violated the provisions of Regulation 4 (b), (c) and (d) of SEBI (Prohibition of Fraudulent and Unfair Trade Practices relating to the Securities Market) Regulations, 1995 and Clauses A (1) and (4) of Schedule II as laid down under regulation 7 of SEBI (Stock Brokers and Sub-brokers) Regulations, 1992 and recommended a minor penalty of suspension of its certificate of registration for a period of two months.

3.0 SHOW CAUSE NOTICE AND REPLY

3.1 Pursuant to the above, a notice dated 15th April 2004 was issued to Amgis to show cause as to why the penalty as considered appropriate should not be imposed on Amgis. Amgis had replied vide its letter dated 3rd May 2004 to the said show cause notice. In the said reply Amgis submitted interalia as under;

a) that there has been no violation of provisions of law as brought out in the enquiry report. b) the transaction carried out on behalf of clients did not create misleading appearance since those trades had actually taken place and obligations arising out of those transactions were duly met. c) Transactions underetaken by the clients were genuine since they were done on the exchange d) It is evident that beneficial ownership was transferred to its clients and nothing to the contrary has been established. Even if it is assumed that there has been purchase and sale by one party it cannot be automatically be assumed that such transaction is motivated by an intention not to transfer beneficial ownership of shares. e) High standards of integrity were maintained with utter transparency, due skill and care. Not acted in any way that would induce investor’s interest in the buy / sell in the scrip of Roofit and have only acted on the directives of clients. f) It is impossible to execute trades without matching trades. The screen matching is such that the member on one side is never aware of the member on the other side and thus there can never be an intentional match of trades. Even if orders are matched, it is clients who are answerable and not the member who is simply carrying out the instruction of clients. Mere purchase at higher rate is not by itself violation of Securities and Exchange Board of India rules and regulations.

g) With regard to the statement of Shri. Deven Mehta, the statement does not provide anything which proves acting in concert with clients in order to manipulate market price of the scrip of Roofit. Introduction of clients by Shri. Mehta to others does not bind Amgis. Mere introduction does not mean the person introducing is also involved in the activities of clients he is introduced. h) All the allegations and recommendations made by the Enquiry Officer are erroneous and untrue, as none of the allegations proved that the acts done by Amgis in the purchase and sale of shares in the scrip of Roofit at the instruction of clients were in any way violating rules and regulations of the Securities and Exchange Board of India. i) The transactions referred to in the show cause notice, were legitimate market transactions and all the purchases on behalf the clients were executed through the exchange.

4.0 CONSIDERATION OF ISSUES

4.1 I have carefully examined the investigation report, enquiry report, show cause notice issued to Amgis and its reply. The issues for consideration before me are two fold and they are whether the noticee has violated the provisions of Regulation 4 (b), (c) and (d) of the SEBI (Prohibition of Fraudulent and Unfair Trade Practices relating to Securities Market) Regulations, 1995 and whether the noticee has violated sub-clauses (1) and (4) of Clause A of the Code of conduct prescribed for stock brokers as found in Schedule II read with Regulation 7 of the SEBI (Stock Brokers and Sub-brokers) Regulations, 1992.

4.2 From Table 2 mentioned in para 1.6.2 above, I find that there are 76 deals executed between Amgis and M/s. Goldcrest Capital Market Ltd (hereinafter referred to as “Goldcrest”). In all the 76 deals, Amgis had acted as a buying broker and Goldcrest had acted as a selling broker. I find that the orders have been placed at approximately the same time or with a difference of only a few seconds for the same price and for the same quantity. The time difference between placing of orders was about less than 30 seconds in all the trades. I find that Goldcrest has placed sell orders on behalf of its clients – M/s. Ami Impex, M/s. Mayfair, M/s. Onlooker, M/s. Habiscus, M/s. Alkan, M/s. Jyoti Mehta and M/s. M’Belle and Amgis has placed buy orders for its clients, M/s. Onlooker, M/s. Habiscus, M/s. Mayfair, M/s. Alkan and M/s. M’Belle. A reading of the table would reveal that M/s. Onlooker, M/s. Mayfair, Alkan, M/s. Habiscus and M/s. M’Belle were both sellers and buyers trading through Amgis and Goldcrest. I find that there are 10 trades for 297,000 shares where the client, M/s. M ’ Belle was buying shares through Amgis and at the same time selling the shares through Goldcrest. There were 7 trades for 2,23,017 shares where the client, M/s. Onlooker was buying through Amgis and at the same time selling shares through Goldcrest. I find that 15 trades amounting to 132,910 shares have been executed on behalf of the M/s. M’Belle on the buy side and M/s. Alkan on the sell side. Further, 3 structured deals amounting to 152,000 shares have been executed on behalf of M/s. Alkan on the buy side and M/s. M’Belle on the sell side. I find that there were 11 trades amounting to 275,566 shares executed on behalf of M/s. M’Belle on the buy side and M/s. Habiscus on the sell side. It is also observed that trades amounting to 88,000 shares were executed on behalf of M/s. M’Belle on the buy side and M/s. Onlooker on the sell side. Further, structured deals amounting to 75,250 shares have also been executed on behalf of M/s. Onlooker on the buy side and M/s. Habiscus on the sell side. Structured deals amounting to 1,15,000 shares have also been executed on behalf of M/s. Onlooker on the buy side and M/s. M’Belle on the sell side. In fact, there were 62 deals, which were matched within 10 seconds

4.3 Clients Onlooker, Habiscus and M/s. Alkan are found to be related to each other. I find that Mr. Suresh Hemwani is the director for all the three clients. Further Habiscus and Onlooker have a common director too, i.e., Ms. Meenal Chabria. I also find that these clients traded through both these members acting both as a buyer and as a seller for the same trade / transaction. I findd that M’Belle was buying shares through Amgis and selling through Goldcrest for 10 trades amounting to 2, 97, 000 shares. This shows that the client was buyer as well as seller for the same trade which obviously is a fictitious trade. I find that M’Belle is related to Roofit since Ms. Rita Motwani, Ms. Sangeeta Motwani and Ms. Anupama Motwani are Subscribers to Memorandum of Association of M’Belle. Ms. Rita Motwani is the wife of Mr. Kishore Motwani who is one of the directors of Roofit. Ms. Sangeeta Motwani is the wife of Mr. Vinod Motwani who is also one of the directors of Roofit. Ms. Anupama Motwani is the wife of Mr. Suresh Motwani who is also one of the directors of Roofit. Likewise I also find that Onlooker had brought shares through Amgis and sold through Goldcrest in 7 trades.

Onlooker is directly / indirectly related to promoter / director of Roofit. M/s. New Bharat Builders has introduced Onlooker to Goldcrest. Ms. Sangeeta Motwani and Mr. Kishore Motwani are Subscribers to the Memorandum of Association of M/s. New Bharat Builders. Ms. Sangeeta Motwani is wife of Mr. Vinod Motwani. Mr. Kishore Motwani and Mr. Vinod Motwani are directors of Roofit. Thus, M/s. Onlooker is indirectly related to promoter / director of Roofit. I find that Alkan was acting in concert with M/s. Sunearth Ceramics, a group company of Roofit, having same address as that of Roofit. Thus, Alkan is indirectly related to the promoter/ director of Roofit like Onlooker and Habiscus. I find that for 15 trades amounting to 1, 32, 910 shares were bought for M/s. M’Belle International Pvt. Ltd. which was sold by Alkan. Further, for 3 structured deals amounting to 1, 52, 000 shares were executed for which Alkan was on the buying side and M’Belle was on the selling side. I further find that M’Belle was involved in 11 trades amounting to 2, 75, 566 shares as buyer for which seller was Habiscus.

I also find that M’Belle as buyer had also executed 5 trades amounting to 88, 000 shares selling these shares to Onlooker. I find that in turn Onlooker had bought shares from Habiscus in 5 structured deals. I also find that Onlooker brought further 1, 15, 000 shares from M’Belle in 4 structured deals.

4.4 I further find that Amgis had entered into 18 structural deals amounting to 3, 53, 175 shares with Mr. Prashant J Patel, Member, NSE. 7 trades were executed by Amgis for its client M’Belle and by Amigs Prashant for its client M/s. Ami Impex. I find from in Sett No. 02, Amgis bought 53, 288 shares for M/s. Mayfair Realtor and 51, 076 shares for Habiscus. However, Amgis credited only 34, 788 shares into M/s. Mayfair Realtor’s account and credited 47, 576 shares into M/s. Habiscus’s account. Rest of 22, 000 shares (1, 04, 364 – 82, 364 = 22000) remained in the account of Amgis. I further find that Amgis had purchased 2, 32, 520 shares for M’Belle in Sett. No.2001009. Amgis transferred only 1, 92, 470 shares into M’Belle’s account and 40, 000 shares to beneficiary account of Goldcrest. Also Amgis purchased 2, 02, 100 shares for M’Belle in Sett. No. 2001011 and transferred 46, 000 shares into another trading member, M/s. Express Securities ’ account. Therefore, Amgis was making adjustments of shares from its client’s accounts.

4.5 I find that Mr. Suresh Hemwani is a common Director in Habiscus, Onlooker and Alkan. While Onlooker and Habiscus have a common director, Ms. Meenal Chhabaria. I further find that Ms. Rita Motwani, Ms. Sangeeta Motwani and Ms. Anupama Motwani are Subscribers to Memorandum of Association of M’Belle. Ms. Rita Motwani is none other than the wife Mr. Kishore Motwani who is one of the directors of Roofit. Likewise, Ms. Sangeeta Motwani is the wife of Mr. Vinod Motwani who is also a director of Roofit. Further, Ms. Anupama Motwani is the wife of yet another director of Roofit, Mr. Suresh Motwani. This clearly establishes that M’Belle is related to Roofit. I further find that in case of Alkan, it has same address as that of Roofit.

4.6 I find from the above that Amgis has dealt on behalf of clients who are related among themselves and with the promoters / directors of Roofit in this regard. The contention put forth by Amgis that they were not in anyway related to the clients has not been raised anywhere in the Enquiry report and thereby needs no consideration.

4.7 The contention of Amgis that they were not aware of the activities of the clients in regard to their dealing in the scrip of Roofit and that they had merely acted in accordance with the instructions given by the clients in this regard, through the stock exchange mechanism can be taken into account in case the same has been one or few transactions involving small proportion of the total volumes of the shares dealt in Roofit. In the present context, the dealings of Amgis with the clients have been substantial. Taking into account the magnitude of such transactions any ordinary man of prudence would have been laced with a layer of doubt and that Amgis has carried out these transactions and has adjusted the delivery of shares to the clients without any resentment is ample proof of the fact that it has failed to perform its duty with care and skill.

4.8 The above mentioned acts of Amgis like carrying out of the structured deals for clients related among themselves and with the promoters / directors of Roofit, adjusting deliveries to be made to these clients, introduction of these clients to the other brokers, in consonance with the knowledge of Shri Deven Mehta that these clients were dealing in the scrip of Roofit through other brokers, lead me to the conclusion that Amgis has aided abetted and acted in concert with related clients in the scrip of Roofit through:

a) Creation of false and misleading appearance of trading in the market b) Execution of transactions that are not genuine trade transactions.

4.9 I find that M/s. Amgis Holdings Pvt. Ltd., has aided and abetted as well as acted in concert with related clients in creating artificial market or misleading appearance of trading in the market, execute transactions that were not genuine trade transactions and executed transactions intended to inflate or cause fluctuation in the market price of the scrip of M/s. Roofit Industries Ltd and has not taken due care and diligence in observance and compliance of the statutory requirement in conduct of its business as a stock broker. Therefore, I am of the view that Amgis has violated the provisions of regulation 4 (b) and (c) of FUTP Regulations and clause A (1) and (4) of Code of Conduct as laid down under Schedule II read with regulation 7 of Broker Regulations. Thus, Amgis is liable for action under regulation 13 (1) (b) of Securities and Exchange Board of India (Procedure for Holding Enquiry by Enquiry Officer and Imposing Penalty) Regulations, 2002. Thus I conclude by holding Amgis guilty of having violated Regulation 4 (b) and (c) of the SEBI (Prohibition of Fraudulent and Unfair Trade Practices relating to Securities Market) Regulations, 1995 and Clause A(1) and (4) of the code of conduct prescribed for stock brokers mentioned in Schedule II read with Regulation 7 of the SEBI (Stock brokers and Sub-brokers Regulations), 1992.

5.0 ORDER

5.1 I, therefore in exercise of the powers conferred upon me by virtue of Section 19 of the Securities and Exchange Board of India Act, 1992 and regulation 13 (4) of SEBI (Procedure for Holding Enquiry by Enquiry Officer and Imposing Penalty) Regulations, 2002, I hereby direct that the certificate of Registration of M/s. Amgis Holdings Pvt. Ltd., INB.

230676837, Member, National Stock Exchange be suspended for a period of two (2) months.

5.2 This order shall come into force with effect from three weeks from the date of the order.

DATE:31.07.2007 T. C. NAIR PLACE: MUMBAI WHOLE TIME MEMBER