Order in the matter of Gangotri Textiles Limited - with respect to Mefcom Securities Limited

WTM/GM /EFD-DRA-III/ 08 /MAY/2017 BEFORE THE SECURITIES AND EXCHANGE BOARD OF INDIA ORDER Under regulations 28(2) of the Securities and Exchange Board of India (Intermediaries) Regulations, 2008 - In the matter of Gangotri Textiles Limited In respect of Mefcom Securities Limited (PAN: AAACM1079Q)

1. Securities and Exchange Board of India (hereinafter referred to as "SEBI") conducted investigation in respect of buying, selling and dealing in the shares of Gangotri Textiles limited (hereafter referred to as "Gangotri"/"Company") during the period from April 07, 2006 to May 31, 2006 (hereinafter referred to as "Investigation Period") at NSE and BSE. This order is in respect of Mefcom Securities Ltd. ("Mefcom") which during the investigation period was found to have executed proprietary trades in the scrip of Gangotri, both in BSE and NSE and for its client Vishvas Projects Ltd. on BSE.

2. Prior to the investigation period, the scrip of Gangotri was not listed on NSE and was only traded on BSE. During the period from January 2006 to April 6, 2006, the highest price was `52.25 (intra-day high on February 6, 2006) and lowest price was `40.55 (intra-day low on March 28, 2006). The average daily traded quantity during this period was 77,036 shares. During the Investigation Period i.e. between April 7, 2006 and May 31, 2006, the scrip of Gangotri was traded on both NSE and BSE. Details of the price volume data at BSE and NSE during the Investigation Period are as follows:- TABLE 1 Exchange Open High Low Close Average Daily Volume BSE 53.25 70.95 43.00 44.35 241675 07.04.06 05.05.06 19.04.06 31.05.06 NSE 56.00 71.05 41.25 45.40 184236 07.04.06 05.05.06 19.04.06 31.05.06

Table I reveals that during the investigation period, the price of the scrip went up by 33.24% on BSE and 26.88% on NSE while the Sensex recorded a decrease of 12.21% (from 11845.13 on April 07, 2006 to 10398.61 on May 31, 2006) and Nifty recorded a decrease of 12.89% (from 3525.6 on April 07, 2006 to 3071.05 on May 31,2006).

3. After the Investigation Period, between June 2006 to December 2006 it was noted that the price of scrip opened at `45.95/45.2 (NSE/BSE) on June 1, 2006 and closed at `27.35 / 26.7 (NSE/BSE) on December 29, 2006. The highest price during this period was `46.25 in (intra-day high on June 2, 2006) in NSE and `46.65 (intra-day high on June 5, 2006) in BSE. The lowest price during this period was `24 (intra-day low on December 13, 2006) in both NSE and BSE. The average daily traded quantity during this period was for 34,080/43,717 (NSE/BSE) shares.

4. It was observed that, during the Investigation Period, certain entities allegedly functioned as a group (hereinafter referred to as the "Vishvas Group") and by trading through their respective stock brokers or otherwise, had allegedly executed synchronized trades, circular trades and reversal trades amongst themselves and traded in significant variation to the Last Traded Price (LTP) in the shares of Gangotri. For the purpose of this order, synchronised trades are understood to be those trades where- (i) the time difference, between buy order and sell order, is less than 60 seconds. (ii) there is no difference between the price and quantity of the buy order and the sell order.

5. The list of the client members of the Vishvas Group and their stock brokers, if any, are stated below: TABLE 2 Sr. No. Name of the client Name of the stock broker 1. Ishita Finstock limited Vishvas Securities limited ("VSL") ("Isbita") 2. Sunita Gupta ("Sunita") Shri Parasram Holdings Private Limited ("Parasram") 3. Purshottam Khandelwal SIC Stocks and Services private Limited ("Purshottam") ("SIC") 4. Praveen Poddar TCP Stock Brokers Limited ("TCP") ("Praveen")

5. Vishvas Securities Ltd. Proprietary trades ("VSL") 6. Anupama Communications NIL trades Private limited ("Anupama") 7. Avisha Credit Capital Ltd. Shriram Insight Share Brokers Ltd. ("Avisha") ("Shriram") 8. ISF Securities Ltd ("ISF") Sam Global Securities Ltd. at BSE and proprietary trades at NSE 9. Quantum Global Securities Proprietary trades and Leasing Company Limited ("Quantum") 10. Cosmo Corporate Services Integrated Master Securities Pvt. Ltd. Limited ("Cosmo") ("Integrated") 11. Master Finlease limited ("Master") 12. Mefcom Securities Limited Mefcom Securities Limited ("Mefcom") ("Mefcom") 13. Vishvas Projects Limited ("VPL")

6. To enquire into the alleged violations by the Vishvas Group with respect to their trades in the Gangotri scrip, including the role of Mefcom, Shri Jayanta Jash was appointed as the Designated Authority ("DA") vide order dated November 8, 2013 under regulation 24 of SEBI (Intermediaries) Regulations, 2008 ("Intermediaries Regulations"). The DA, issued show cause notice dated January 06, 2014 to Mefcom. After completion of the proceedings, the DA submitted a Report dated November 25, 2014 in respect of Mefcom (hereinafter referred to as "the DA Report"), wherein it was found that Mefcom had violated the provisions of sections 12A(a), (b) and (c) of the SEBI Act read with regulations 3(a), (b), (c) and (d), 4(1), 4(2)(a), (e) and (g) of the SEBI (Prohibition of Fraudulent and Unfair Trade Practices) Regulations, 2003 ("PFUTP Regulations") and regulation 7 read with Clause A of Schedule II of the SEBI (Stock Brokers and Sub-brokers) Regulations ("Stock Brokers Regulations") dealing with Code of Conduct for Stock Brokers. Accordingly the DA, in his Report, recommended suspension of certificate of registration of Mefcom for a period of four months.

7. After considering the DA Report, the Designated Member (DM) caused to issue a show cause notice (SCN) dated September 30, 2015, under regulation 28(1) of the Intermediaries Regulations calling upon Mefcom to show cause as to why action as recommended in the DA Report or as otherwise deemed fit should not be taken against it.

8. Mefcom filed its reply by letter dated November 30, 2015. An opportunity of personal hearing was granted on May 26, 2016 but was rescheduled based on the Mefcom's request. Subsequently another opportunity of personal hearing was granted on October 05, 2016. The then Whole Time Member who had granted opportunity of personal hearing had subsequently demitted office. Consequently, a fresh opportunity of personal hearing was granted on January 25, 2017, wherein Mr Vijay Mehta (Director) appeared on behalf of the noticee company i.e Mefcom, and made submissions. The submissions were generally a reiteration of the written replies to the SCNs issued by the DA and the WTM. Subsequently, further written submissions dated February 3, 2017 were filed with SEBI.

9. Summary of facts and the related observations made by the DA in his Report in relation to the trades by Mefcom is discussed in the following sub-paragraphs. 9.1 Connected Entities: The DA relied on the Investigation report to note that members of the Vishvas Group were connected to each other through various means. Specifically with respect to Mefcom, the DA observed that the director of Mefcom i.e. Vijay Mehta had promoted Mefcom Agro Industries Ltd. (MAIL) now known as Vishvas Projects Ltd. and Visvhas Projects Ltd., Avisha and Master have the same address. Further Mefcom was connected to Purshottam, Ishita, Praveen, Sunita, Quantum, ISF, VSL and Cosmo on the basis of synchronised trades executed between them. 9.2 Quantum of shares traded by the Vishvas Group members at BSE and NSE during Investigation Period are as under: TABLE 3 Sr. No. Members of Traded quantity (During Investigation Period) Vishvas Gtoup BSE NSE Buy Sell Buy Sell 1. Master 38000 18386 20500 111400 2. Purshottam 2927835 2882486 0 0

3. Cosmo 445643 320630 401520 471184 4. ISF 389748 338795 453396 368574 5. Quantum 0 0 302095 286835 6. Ishita 0 0 195380 1569204 3 7. Praveen 460990 460990 0 0 8. Sunita 342246 342246 0 0 9. Mefcom 443942 348370 610646 667122 10. Avisha 50000 0 0 0 11. VSL 0 0 134460 118661 12. VPL 100000 0 0 0 Total 5198404 4711903 3876420 3592980

From the above, it is observed that as a percentage of shares traded by the Vishvas Group, Mefcom contributed to 8.54% and 7.39 % of shares bought and sold on BSE, respectively. Similarly, on NSE, Mefcom contributed to 15.75% and 18.57 % of shares bought and sold, respectively.

9.3 Trades on BSE and manipulation of volumes: On BSE, during the investigation period, seven members of the Vishvas Group including VPL trading through Mefcom had a gross buy position with total contribution of 57.1% (51,10,404 shares) of the total traded quantity and six members of the Vishvas Group, including Mefcom had a gross sell position with a total contribution of 52.5% (46,93,517 shares) of the total traded quantity. Mefcom had bought 4,43,942 shares & sold 3,48,370 shares in the Gangotri scrip. Out of total 37 trading days during the investigation period, on 20 days, Mefcom had traded in the shares of Gangotri for itself and on 4 days traded for its client VPL. It was observed that on 12 days the net position of Mefcom was zero.

9.3.1 During the Investigation Period, 24,154 trades in Gangotri scrip were executed for a total traded quantity of 89,41,975 shares at BSE. Out of these, 430 trades for 15,60,914 shares (17.45% of the total traded quantity) were synchronized i.e. the difference between buy order time and sell order time was less than 60 seconds and there was no difference between the buy order rate and the sell order rate and between the buy order quantity and the sell order quantity. Out of a total of 420 synchronized trades (buy & sell) by Vishvas Group for 24,52,618 shares, Mefcom in its proprietary capacity and for its client - VPL indulged in 81 synchronized trades for 3,79,700 shares. Mefcom bought a total of 5,43,642 shares (for itself and its client) during the Investigation Period. Out of the same, 1, 95, 284 shares bought for itself were synchronised with other members of the Vishvas Group i.e. Purshottam, Praveen, Sunita, ISF and Cosmo; and 39,958 shares bought for its client VPL were synchronised with Purshottam, ISF and Cosmo. Similarly Mefcom sold a total of 3,48,370 shares during the investigation period, out of which 1,44,458 shares were synchronized with other members of the Vishvas Group i.e. Praveen, ISF, Sunita, Cosmo and Purshottam. The DA report cited one such instance of synchronized trades and reversal of trades by Mefcom with other members of Vishvas Group on May 18, 2006. On the said date, a sale order was placed by Sunita at 13:08:18 at the rate of `55.35 for 5,000 shares and a buy order was placed by Mefcom at 13:08:37 at the rate of `55.35 for 5,000 shares. The orders resulted in sale of 5,000 shares of Gangotri at the rate of `55.35 from Sunita to Mefcom at 13:08:38. The order time difference was 19 seconds. Subsequently, a sale order was placed by Mefcom at 14:09:34 at the rate of `55.35 for 5,000 shares and a buy order was placed by Sunita at 14:09:34 at the rate of `55.35 for 5,000 shares. The order time difference was 0 seconds and resulted in a reverse trade whereby Mefcom sold 5,000 shares back to Sunita at the rate of `55.35 at 14:09:35 i.e. the trade was reversed in approximately one hour.

9.3.2 The DA observed that during the Investigation Period, circular trading among Vishvas Group was observed on BSE from April 21, 2006 till May 31, 2006. One of the instances of circular trading observed on April 24, 2006 among the group was depicted in the DA Report as under: Circular Pattern Observed on April 24, 2006 among the group is as under :

Thu

Thus the DA found that nine members of the Vishvas Group including Mefcom were involved in 2138 instances of circular trading on 29 trading days out of 37 trading days during the Investigation Period and created artificial volume of 26,90,184 shares (30.08% of total traded quantity) by buying and selling among themselves. Quantum of shares forming part of the aforesaid circular trades on BSE are as under:-

TABLE 4 Circular Trade Sellers Purshotta Pravee Grand Buyers Cosmo Sunita Master Mefcom m ISF n Total VPL 10000 8000 00 00 54509 6000 19597 98106 Avisha 00 00 00 00 50000 00 00 50000 Cosmo 5672 43875 00 59535 259186 7000 49152 424420 Sunita 38031 00 00 43901 82808 94132 29928 288800 Master 00 00 00 10000 13399 00 4000 27399 Mefcom 9500 36059 00 00 180381 45579 52274 323793 12469 Purshottam 72446 150814 8386 108126 65025 4 187160 716651 ISF 35602 19965 10000 21041 215666 00 38990 341264 Praveen 61559 29674 00 32044 279473 17001 00 419751 Grand 23281 29440 269018 Total 0 288387 18386 274647 1200447 6 381101 4

9.4 Trades on NSE and manipulation of volumes: Total traded volume of the scrip of Gangotri on NSE during the investigation period was 68,16,750 shares. During the investigation period six members of the Vishvas Group including Mefcom held a gross buy position in the Gangotri scrip with total contribution of 56.56% ( 38,55,920 shares) and six members of Vishvas Group including Mefcom held gross sell position with total contribution of 51.07% (34,81,580 shares). Out of the 37 trading days during the investigation period, on 25 days Mefcom had bought & sold the shares of Gangotri. It is observed that on 12 days, the net position of the Mefcom was zero.

9.4.1 During the Investigation Period, there were 21,451 trades for a traded quantity of 68,16,750 shares of the Gangotri scrip at NSE. Out of these, 495 trades for 14,48,679 shares (21.25% of the total traded quantity) were synchronized trades. Out of a total of 6,10,646 shares bought by Mefcom for itself on NSE during the investigation period, 3,18,875 shares were synchronised with other members of the Vishwas Group. Out of a total of 6,67,122 shares sold by Mefcom on NSE during the investigation period, 3,10,826 shares were synchronized with five other members of the Vishwas Group. Out of 624 synchronized trades (buy & sell) executed by the Vishvas Group for 24,03,502 shares, Mefcom executed 170 synchronized trades for 6,29,701 shares. One of the instances of the synchronized trade and reversal of trade by Mefcom with other members of Vishvas Group was on May 23, 2006. On the said date, a sale order was placed by Quantum at 10:10:01 at the rate of ` 50.95 for 10,000 shares and a buy order was placed by Mefcom at 10:10:04 at the rate of `50.95 for 10,000 shares, resulting in Mefcom's purchase of 10,000 shares at the rate of ` 50.95 from Quantum at 10:10:04. The order time difference was 3 seconds. Subsequently, a sale order was placed by Mefcom at 10:56:23 at the rate of ` 51.70 for 10,000 shares and a buy order was placed by Quantum at 10:56:22 at the rate of ` 51.70 for 10,000 shares. The order time difference was 1 second and the orders resulted in a reverse trade whereby Mefcom sold 10,000 shares back to Quantum at the rate of ` 51.70 at 10:56:23, i.e. the trade was reversed within 50 minutes on the same day.

9.4.2 The DA observed circular trading among members of the Vishvas Group, on NSE as well, during the period between April 21, 2006 and May 31, 2006. Some of the instances of circular trading noted were as follows-

Circular pattern observed on April 25, 2006 among the group is as under:

Circular pattern observed on May 30, 2006 among the group is as under:

Thus the DA found that seven members of Vishvas Group namely Cosmo, Master, Ishita, VSL, Quantum, Mefcom and ISF were involved in 2419 instances of circular trades on 29 trading days out of 37 trading days during investigation period and created artificial volume of 23,56,185 shares (34.56% of total market volume) by buying and selling among themselves. Details of circular trades on NSE among the seven members of Vishvas Group were noted as under:- TABLE 5

Circular Trades Sellers Mefco Grand Buyers ISF m VSL Cosmo Ishita Master Quantum Total ISF 625 110961 6552 68158 157108 00 33458 376862 Mefcom 68254 550 5000 102992 231230 7040 100574 515640 VSL 26258 24142 497 100 5022 00 14980 70999 Cosmo 36925 123702 00 00 143512 00 27975 332114 Ishita 157329 188865 2570 183095 92185 29825 107776 761645 Master 2000 00 00 00 7841 00 00 9841 Quantum 2000 76917 48823 59751 101533 00 60 289084 235618 Grand Total 293391 525137 63442 414096 738431 36865 284823 5

It was also observed that Mefcom had executed 13 self trades for 550 shares during investigation period.

9.5 Price Manipulation: On BSE, nine members of Vishvas Group namely, Cosmo, Master, Purshottam, Mefcom, Praveen, Sunita, Avisha, VPL and ISF had cumulatively contributed ` 718.05 to positive LTP and `468.65 to Negative LTP. Mefcom had contributed ` 18.30 to total cumulative positive LTP and ` 24.25 to total cumulative negative LTP. Similarly, on NSE, seven members of Vishvas Group namely, Cosmo, Master, Ishita, Mefcom, VSL, Quantum and ISF had cumulatively contributed `489.05 and. `307.90 respectively, and Mefcom had contributed `56.55 to total positive LTP and ` 45 to total negative LTP.

10. In addition to the observations in the DA Report as discussed above, I have also examined some orders placed by Mefcom and trades executed by it in the Gangotri scrip, from the relevant Order log and Trade log (copies of which had been provided to the noticee i.e. Mefcom vide the SCN dated January 06, 2014 issued by the DA). The details of this additional examination are noted below:

10.1 Synchronised Trades: It is seen from the statements of transactions for the period between 21st April, 2006 and 30th May, 2006 that on certain days, repeated buy/sell orders were placed with negligible time difference of each other and the trades have also been synchronised with respect to quantity and price.

10.1.1 A table indicating some of such orders/trades placed on BSE, as extracted from the order logs/trade logs, is given below:

TABLE 6 Buy Sell Trade Trad Trad Buy Sell Order Orde Orde Buy Sell Date Trade eQua e Buy Sell Order Order Time r r Order Orde (2006) Time ntity Price Client Client Time Time Diff price price qty r qty 1500 21/04 10:51:20 0 48.75 Cosmo Mefcom 10:51:20 10:51:11 00:00:08 48.75 48.75 15000 15000 24/04 10:39:35 7235 52.65 ISF Mefcom 10:39:34 10:39:24 00:00:10 52.65 52.65 7500 7500 25/04 13:14:04 7000 53.85 Sunita Mefcom 13:14:04 13:13:54 00:00:10 53.85 53.85 7000 7000 27/04 10:20:09 760 60.5 Mefcom PTM 10:20:05 10:20:09 00:00:04 60.5 60.5 5000 5000 1000 28/04 10:33:11 0 58.35 Mefcom PTM 10:33:11 10:32:57 00:00:14 58.35 58.35 10000 10000 Purushott 1000 am 28/04 10:42:37 0 58.35 (PTM) Mefcom 10:42:36 10:42:30 00:00:06 58.35 58.35 10000 10000 1000 29/04 11:06:15 0 59.4 Mefcom PTM 11:06:14 11:06:07 00:00:07 59.4 59.4 10000 10000 29/04 11:04:39 3010 58.95 PTM Mefcom 11:04:38 11:04:29 00:00:09 58.95 58.95 5000 5000 1000 02/05 10:08:46 0 62.35 Mefcom Praveen 10:08:45 10:08:38 00:00:08 62.35 62.35 10000 10000 02/05 10:20:54 9740 63.25 Mefcom PTM 10:20:45 10:20:54 00:00:08 63.25 63.25 10000 10000 02/05 10:22:11 719 63.3 Mefcom PTM 10:22:05 10:22:11 00:00:06 63.3 63.3 10000 10000 02/05 10:22:18 9281 63.3 Mefcom PTM 10:22:05 10:22:18 00:00:13 63.3 63.3 10000 10000 04/05 10:18:28 8802 67.35 Mefcom PTM 10:18:09 10:18:17 00:00:08 67.35 67.35 10000 10000 1000 08/05 10:09:36 0 64.95 Mefcom PTM 10:09:35 10:09:26 00:00:09 64.95 64.95 10000 10000

09/05 11:59:40 9988 61.75 Mefcom PTM 11:59:37 11:59:39 00:00:02 61.75 61.75 10000 10000 1000 09/05 12:10:38 0 61.85 Sunita Mefcom 12:10:38 12:10:31 00:00:07 61.85 61.85 10000 10000 11/05 12:05:35 5000 61.15 Mefcom Sunita 12:05:34 12:05:04 00:00:31 61.15 61.15 5000 5000 11/05 12:10:21 5000 61.25 Mefcom ISF 12:10:20 12:10:11 00:00:09 61.25 61.25 5000 5000 11/05 11:52:13 9998 60.95 Praveen Mefcom 11:52:12 11:51:46 00:00:26 60.95 60.95 10000 10000 11/05 11:52:53 9903 61.3 Praveen Mefcom 11:52:52 11:52:51 00:00:01 61.3 61.3 10000 10000 12/05 10:28:59 8851 61.45 Mefcom PTM 10:28:58 10:28:57 00:00:01 61.45 61.45 10000 10000 12/05 10:23:34 9720 60.95 Praveen Mefcom 10:23:33 10:23:05 00:00:27 60.95 60.95 10000 10000 15/05 10:52:42 2500 61.2 Mefcom PTM 10:52:41 10:52:39 00:00:02 61.2 61.2 2500 2500 15/05 10:52:54 2500 61.35 Mefcom PTM 10:52:53 10:52:51 00:00:02 61.35 61.35 2500 2500 15/05 11:27:39 5000 62.55 PTM Mefcom 11:27:39 11:27:32 00:00:07 62.55 62.55 5000 5000 16/05 11:20:43 3500 62.35 Mefcom PTM 11:20:30 11:20:43 00:00:13 62.35 62.35 6000 6000 17/05 14:19:15 4999 58.4 Mefcom PTM 14:19:06 14:19:14 00:00:08 58.4 58.4 5000 5000 18/05 10:27:32 1985 55.35 Mefcom PTM 10:27:26 10:27:32 00:00:06 55.35 55.35 2000 2000 18/05 10:29:39 1999 55.35 Mefcom PTM 10:29:33 10:29:38 00:00:04 55.35 55.35 2000 2000 18/05 10:31:04 2000 55.15 Mefcom PTM 10:31:02 10:31:03 00:00:01 55.15 55.15 2000 2000 18/05 10:50:56 1999 55.15 Mefcom PTM 10:50:51 10:50:55 00:00:04 55.15 55.15 2000 2000 18/05 13:08:38 5000 55.35 Mefcom Sunita 13:08:37 13:08:18 00:00:19 55.35 55.35 5000 5000 18/05 13:09:48 5000 55.35 Mefcom ISF 13:09:47 13:09:42 00:00:06 55.35 55.35 5000 5000 18/05 14:48:07 5000 55.05 Mefcom ISF 14:48:07 14:47:59 00:00:08 55.05 55.05 5000 5000 18/05 11:14:49 5000 55.3 Cosmo Mefcom 11:14:49 11:14:41 00:00:08 55.3 55.3 5000 5000 1000 18/05 12:49:03 0 55.35 Sunita Mefcom 12:49:02 12:48:42 00:00:21 55.35 55.35 10000 10000 18/05 14:09:35 5000 55.35 Sunita Mefcom 14:09:34 14:09:34 00:00:00 55.35 55.35 5000 5000 19/05 10:56:38 5000 55.35 Mefcom ISF 10:56:37 10:56:27 00:00:10 55.35 55.35 5000 5000 19/05 11:51:19 5000 55.55 Mefcom PTM 11:51:19 11:51:07 00:00:12 55.55 55.55 5000 5000 19/05 10:13:43 1000 55.65 PTM Mefcom 10:13:42 10:13:31 00:00:11 55.65 55.65 1000 1000 19/05 11:38:23 4911 55.65 ISF Mefcom 11:38:22 11:38:13 00:00:09 55.65 55.65 5000 5000 19/05 11:52:12 5000 55.5 ISF Mefcom 11:52:11 11:52:07 00:00:04 55.5 55.5 5000 5000 22/05 10:21:14 5000 55.1 Mefcom PTM 10:21:13 10:21:11 00:00:02 55.1 55.1 5000 5000 23/05 11:06:51 4999 50.2 Mefcom Praveen 11:06:50 11:06:48 00:00:02 50.2 50.2 5000 5000 23/05 14:56:41 2000 50.1 Mefcom PTM 14:56:40 14:56:32 00:00:08 50.1 50.1 2000 2000 23/05 15:18:52 5000 50.6 Mefcom PTM 15:18:51 15:18:50 00:00:01 50.6 50.6 5000 5000 23/05 12:55:31 5000 50.45 PTM Mefcom 12:55:30 12:55:23 00:00:07 50.45 50.45 5000 5000 23/05 15:17:14 3216 50.7 PTM Mefcom 15:17:13 15:17:04 00:00:08 50.7 50.7 5000 5000 24/05 10:10:38 2000 50.65 Mefcom Praveen 10:10:37 10:10:24 00:00:12 50.65 50.65 2000 2000 24/05 10:25:24 2000 50.5 Mefcom Cosmo 10:25:23 10:25:16 00:00:07 50.5 50.5 2000 2000 24/05 13:23:40 2500 49.85 Mefcom Cosmo 13:23:39 13:23:34 00:00:05 49.85 49.85 2500 2500 24/05 10:25:58 1700 50.55 Cosmo Mefcom 10:25:45 10:25:58 00:00:13 50.55 50.55 2000 2000 24/05 13:24:13 2500 49.8 PTM Mefcom 13:24:12 13:24:06 00:00:06 49.8 49.8 2500 2500 25/05 10:18:37 2000 47.1 Mefcom PTM 10:18:36 10:18:37 00:00:00 47.1 47.1 2000 2000 25/05 10:18:50 500 47.15 Mefcom PTM 10:18:49 10:18:45 00:00:04 47.15 47.15 500 500 25/05 10:19:13 1000 47.2 Mefcom PTM 10:19:12 10:19:09 00:00:03 47.2 47.2 1000 1000 25/05 10:19:22 500 47.15 Mefcom PTM 10:19:21 10:19:20 00:00:01 47.15 47.15 500 500

25/05 15:27:10 3820 46.2 PTM Mefcom 15:27:09 15:26:51 00:00:19 46.2 46.2 4000 4000 25/05 15:27:46 500 46.2 PTM Mefcom 15:27:45 15:27:42 00:00:03 46.2 46.2 500 500 25/05 15:27:59 200 46.2 PTM Mefcom 15:27:59 15:27:55 00:00:04 46.2 46.2 200 200 25/05 15:28:48 300 46.2 PTM Mefcom 15:28:47 15:28:43 00:00:04 46.2 46.2 300 300 26/05 10:58:00 207 46.65 Mefcom PTM 10:57:47 10:57:59 00:00:12 46.65 46.65 2000 2000 26/05 15:12:42 4000 46.45 Mefcom ISF 15:12:41 15:12:35 00:00:06 46.45 46.45 4000 4000 29/05 15:15:30 1000 45.6 Mefcom PTM 15:15:29 15:15:27 00:00:02 45.6 45.6 1000 1000 30/05 14:25:10 7000 45.7 Mefcom ISF 14:25:09 14:24:54 00:00:16 45.7 45.7 7000 7000 30/05 14:26:42 1000 45.7 Mefcom ISF 14:26:41 14:26:30 00:00:11 45.7 45.7 1000 1000 30/05 14:28:18 500 45.7 Mefcom ISF 14:28:17 14:27:25 00:00:51 45.7 45.7 500 500 30/05 15:17:35 1000 45.95 Mefcom PTM 15:17:34 15:17:31 00:00:03 45.95 45.95 1000 1000 30/05 10:01:20 4951 46.85 Sunita Mefcom 10:01:19 10:00:57 00:00:22 46.85 46.85 5000 5000 31/05 10:37:37 1000 45.35 Mefcom Sunita 10:37:36 10:37:27 00:00:10 45.35 45.35 1000 1000 31/05 10:38:03 500 45.3 Mefcom Sunita 10:38:02 10:38:01 00:00:01 45.3 45.3 500 500 31/05 11:36:41 3955 45.35 Mefcom Sunita 11:36:37 11:36:41 00:00:03 45.35 45.35 4000 4000 31/05 14:44:25 2000 44.5 Mefcom Cosmo 14:44:24 14:44:15 00:00:09 44.5 44.5 2000 2000 31/05 15:25:53 1000 44.35 Mefcom PTM 15:25:52 15:25:34 00:00:18 44.35 44.35 1000 1000 31/05 10:35:30 2494 45.85 PTM Mefcom 10:35:29 10:35:07 00:00:22 45.85 45.85 2500 2500 31/05 14:46:26 2000 44.5 Sunita Mefcom 14:46:25 14:46:13 00:00:12 44.5 44.5 2000 2000

The table above indicates that 76 synchronised orders for 3,39,742 shares were placed at BSE by Mefcom for itself within a span of 25 trading days between April 21, 2006 and May 31, 2006.

10.1.2 Similarly the table indicating some of such orders/trades placed on NSE, as extracted from the order logs/trade logs, is given below:

TABLE 7

Trad e Tra Buy Sell Date ded Buy Sell Orde Orde Buy Sell (2006 Trade Trade Pric Buy Sell Order Order Order rPric r Orde Orde ) Time Qty e client client Time Time time diff e Price r Vol rVol 53.0 24/04 10:56:28 8000 5 Mefcom ISF 10:56:28 10:56:20 00:00:08 53.05 53.05 8000 8000 52.4 24/04 10:31:27 6975 5 Cosmo Mefcom 10:31:27 10:31:24 00:00:03 52.45 52.45 8000 8000 58.3 1000 25/04 10:53:42 9905 0 Mefcom ISF 10:53:15 10:52:56 00:00:19 58.30 58.30 0 10000

55.1 25/04 12:37:12 5000 5 Mefcom Ishita 12:37:12 12:37:06 00:00:06 55.15 55.15 5000 5000 55.1 25/04 12:37:33 2500 5 Mefcom Ishita 12:37:33 12:37:26 00:00:07 55.15 55.15 2500 2500 55.1 25/04 12:37:46 2500 5 Mefcom Ishita 12:37:46 12:37:41 00:00:05 55.15 55.15 2500 2500 55.4 25/04 12:38:09 5000 0 Mefcom Ishita 12:38:09 12:38:04 00:00:05 55.40 55.40 5000 5000 58.3 1000 28/04 10:18:55 10000 5 Mefcom ISF 10:18:55 10:18:50 00:00:05 58.35 58.35 0 10000 57.9 28/04 15:24:27 5000 5 Mefcom Master 15:24:27 15:24:23 00:00:04 57.95 57.95 5000 5000 58.4 1000 28/04 10:17:20 10000 0 Ishita Mefcom 10:17:19 10:17:04 00:00:15 58.40 58.40 0 10000 57.9 28/04 15:26:05 4900 5 Ishita Mefcom 15:26:05 15:26:04 00:00:01 57.95 57.95 5000 5000 59.8 1000 29/04 10:34:39 9240 5 Ishita Mefcom 10:34:38 10:34:09 00:00:29 59.85 59.85 0 10000 63.5 1000 2/05 10:25:00 9995 5 Mefcom ISF 10:24:59 10:24:48 00:00:11 63.55 63.55 0 10000 62.7 1000 2/05 10:10:27 9000 5 Ishita Mefcom 10:10:27 10:10:21 00:00:06 62.75 62.75 0 10000 67.8 1000 4/05 10:24:26 10000 0 Ishita Mefcom 10:24:26 10:24:03 00:00:23 67.80 67.80 0 10000 68.1 1000 4/05 10:42:10 9900 5 ISF Mefcom 10:42:10 10:42:00 00:00:10 68.15 68.15 0 10000 62.0 9/05 13:03:23 710 0 Mefcom Ishita 13:03:19 13:03:23 00:00:04 62.00 62.00 1000 1000 62.4 9/05 10:26:47 4975 5 Ishita Mefcom 10:26:45 10:26:46 00:00:01 62.45 62.45 5000 5000 61.4 1000 10/05 09:58:40 9990 5 Mefcom ISF 09:58:38 09:58:21 00:00:17 61.45 61.45 0 10000 62.2 10/05 10:25:34 4509 0 Mefcom Ishita 10:25:34 10:25:31 00:00:03 62.20 62.20 5000 5000 61.9 1000 10/05 11:06:00 10000 0 Mefcom Ishita 11:06:00 11:05:53 00:00:07 61.90 61.90 0 10000 60.1 1000 10/05 14:37:18 9500 5 Mefcom Cosmo 14:37:18 14:37:11 00:00:07 60.15 60.15 0 10000 61.7 10/05 10:25:18 5000 5 Ishita Mefcom 10:25:17 10:25:18 00:00:01 61.75 61.75 5000 5000 62.1 10/05 10:26:34 1960 5 Ishita Mefcom 10:26:34 10:26:28 00:00:06 62.15 62.15 2000 2000 62.2 10/05 10:30:00 490 5 Quantum Mefcom 10:30:00 10:29:45 00:00:15 62.25 62.25 5000 5000 62.2 10/05 10:30:00 500 5 Quantum Mefcom 10:30:00 10:29:45 00:00:15 62.25 62.25 5000 5000 62.2 10/05 10:30:00 500 5 Quantum Mefcom 10:30:00 10:29:45 00:00:15 62.25 62.25 5000 5000 62.2 10/05 10:30:00 500 5 Quantum Mefcom 10:30:00 10:29:45 00:00:15 62.25 62.25 5000 5000 62.2 10/05 10:30:00 500 5 Quantum Mefcom 10:30:00 10:29:45 00:00:15 62.25 62.25 5000 5000 62.2 10/05 10:30:00 10 5 Quantum Mefcom 10:30:00 10:29:45 00:00:15 62.25 62.25 5000 5000 62.2 10/05 10:30:57 5000 0 Quantum Mefcom 10:30:57 10:30:57 00:00:00 62.20 62.20 5000 5000

62.2 1000 10/05 11:45:47 10000 0 ISF Mefcom 11:45:47 11:45:46 00:00:01 62.20 62.20 0 10000 61.6 11/05 10:36:41 4500 5 Mefcom Ishita 10:36:41 10:36:38 00:00:03 61.65 61.65 5000 5000 61.2 11/05 11:32:02 5000 5 Cosmo Mefcom 11:32:02 11:31:57 00:00:05 61.25 61.25 5000 5000 61.2 1000 11/05 11:45:44 9955 5 Cosmo Mefcom 11:45:44 11:45:27 00:00:17 61.25 61.25 0 10000 61.2 1000 11/05 11:46:17 45 5 Cosmo Mefcom 11:46:17 11:45:27 00:00:50 61.25 61.25 0 10000 61.2 1000 11/05 11:46:17 9940 5 Cosmo Mefcom 11:46:17 11:46:16 00:00:01 61.25 61.25 0 10000 60.8 1000 12/05 10:04:31 10000 5 Mefcom Ishita 10:04:31 10:04:25 00:00:06 60.85 60.85 0 10000 61.8 1000 12/05 10:44:45 9950 5 Mefcom Ishita 10:44:45 10:44:44 00:00:01 61.85 61.85 0 10000 61.3 1000 12/05 10:53:47 10000 5 Mefcom Quantum 10:53:47 10:53:40 00:00:07 61.35 61.35 0 10000 60.3 12/05 14:25:24 4625 5 Mefcom Cosmo 14:25:17 14:25:24 00:00:07 60.35 60.35 5000 5000 60.3 12/05 14:26:07 500 5 Mefcom Cosmo 14:26:07 14:25:58 00:00:09 60.35 60.35 5000 5000 60.3 12/05 14:26:07 500 5 Mefcom Cosmo 14:26:07 14:25:58 00:00:09 60.35 60.35 5000 5000 60.3 12/05 14:26:07 500 5 Mefcom Cosmo 14:26:07 14:25:58 00:00:09 60.35 60.35 5000 5000 60.3 12/05 14:26:07 500 5 Mefcom Cosmo 14:26:07 14:25:58 00:00:09 60.35 60.35 5000 5000 60.3 12/05 14:26:07 500 5 Mefcom Cosmo 14:26:07 14:25:58 00:00:09 60.35 60.35 5000 5000 60.3 12/05 14:26:07 500 5 Mefcom Cosmo 14:26:07 14:25:58 00:00:09 60.35 60.35 5000 5000 60.3 12/05 14:26:07 500 5 Mefcom Cosmo 14:26:07 14:25:58 00:00:09 60.35 60.35 5000 5000 60.3 12/05 14:26:07 500 5 Mefcom Cosmo 14:26:07 14:25:58 00:00:09 60.35 60.35 5000 5000 60.3 12/05 14:26:07 500 5 Mefcom Cosmo 14:26:07 14:25:58 00:00:09 60.35 60.35 5000 5000 60.3 12/05 14:26:07 125 5 Mefcom Cosmo 14:26:07 14:25:58 00:00:09 60.35 60.35 5000 5000 60.7 1000 12/05 10:08:41 10000 0 Cosmo Mefcom 10:08:41 10:08:38 00:00:03 60.70 60.70 0 10000 60.8 15/05 10:22:48 4000 0 Mefcom Quantum 10:22:48 10:22:40 00:00:08 60.80 60.80 4000 4000 61.6 15/05 10:45:16 5000 0 Mefcom Ishita 10:45:16 10:45:04 00:00:12 61.60 61.60 5000 5000 61.6 15/05 10:45:23 2500 0 Mefcom Ishita 10:45:23 10:45:18 00:00:05 61.60 61.60 2500 2500 60.9 15/05 10:28:21 5000 0 Cosmo Mefcom 10:28:21 10:27:57 00:00:24 60.90 60.90 5000 5000 60.9 15/05 10:28:41 2500 0 Cosmo Mefcom 10:28:41 10:28:38 00:00:03 60.90 60.90 2500 2500 62.4 15/05 11:19:30 1440 0 Vishvas Mefcom 11:19:30 11:19:12 00:00:18 62.40 62.40 1500 1500 63.4 16/05 10:02:18 1800 5 Mefcom Ishita 10:02:17 10:01:58 00:00:19 63.45 63.45 2000 2000

61.2 17/05 10:31:13 257 5 Mefcom Cosmo 10:31:13 10:30:58 00:00:15 61.25 61.25 5000 5000 61.2 17/05 10:31:13 500 5 Mefcom Cosmo 10:31:13 10:30:58 00:00:15 61.25 61.25 5000 5000 61.2 17/05 10:31:13 500 5 Mefcom Cosmo 10:31:13 10:30:58 00:00:15 61.25 61.25 5000 5000 61.2 17/05 10:31:13 500 5 Mefcom Cosmo 10:31:13 10:30:58 00:00:15 61.25 61.25 5000 5000 61.2 17/05 10:31:13 500 5 Mefcom Cosmo 10:31:13 10:30:58 00:00:15 61.25 61.25 5000 5000 61.2 17/05 10:31:13 500 5 Mefcom Cosmo 10:31:13 10:30:58 00:00:15 61.25 61.25 5000 5000 61.2 17/05 10:31:13 500 5 Mefcom Cosmo 10:31:13 10:30:58 00:00:15 61.25 61.25 5000 5000 61.2 17/05 10:31:13 343 5 Mefcom Cosmo 10:31:13 10:30:58 00:00:15 61.25 61.25 5000 5000 59.9 1000 17/05 11:08:19 10000 5 Mefcom Ishita 11:08:19 11:08:15 00:00:04 59.95 59.95 0 10000 57.9 17/05 11:45:58 500 0 Mefcom Ishita 11:45:58 11:45:55 00:00:03 57.90 57.90 5000 5000 57.9 17/05 11:45:58 500 0 Mefcom Ishita 11:45:58 11:45:55 00:00:03 57.90 57.90 5000 5000 57.9 17/05 11:45:58 500 0 Mefcom Ishita 11:45:58 11:45:55 00:00:03 57.90 57.90 5000 5000 57.9 17/05 11:45:58 500 0 Mefcom Ishita 11:45:58 11:45:55 00:00:03 57.90 57.90 5000 5000 57.9 17/05 11:45:58 500 0 Mefcom Ishita 11:45:58 11:45:55 00:00:03 57.90 57.90 5000 5000 57.9 17/05 11:45:58 500 0 Mefcom Ishita 11:45:58 11:45:55 00:00:03 57.90 57.90 5000 5000 57.9 17/05 11:45:58 500 0 Mefcom Ishita 11:45:58 11:45:55 00:00:03 57.90 57.90 5000 5000 57.9 17/05 11:45:58 500 0 Mefcom Ishita 11:45:58 11:45:55 00:00:03 57.90 57.90 5000 5000 57.9 17/05 11:45:58 843 0 Mefcom Ishita 11:45:58 11:45:55 00:00:03 57.90 57.90 5000 5000 57.9 17/05 12:49:46 4943 0 Mefcom Quantum 12:49:45 12:49:46 00:00:01 57.90 57.90 5000 5000 61.0 17/05 10:03:42 5000 0 Ishita Mefcom 10:03:42 10:03:35 00:00:07 61.00 61.00 5000 5000 60.3 1000 17/05 10:52:18 10000 0 Cosmo Mefcom 10:52:18 10:51:56 00:00:22 60.30 60.30 0 10000 56.4 18/05 10:01:08 500 5 Mefcom Vishvas 10:01:08 10:01:00 00:00:08 56.45 56.45 5000 5000 56.4 18/05 10:01:08 500 5 Mefcom Vishvas 10:01:08 10:01:00 00:00:08 56.45 56.45 5000 5000 56.4 18/05 10:01:08 500 5 Mefcom Vishvas 10:01:08 10:01:00 00:00:08 56.45 56.45 5000 5000 56.4 18/05 10:01:08 500 5 Mefcom Vishvas 10:01:08 10:01:00 00:00:08 56.45 56.45 5000 5000 56.4 18/05 10:01:08 500 5 Mefcom Vishvas 10:01:08 10:01:00 00:00:08 56.45 56.45 5000 5000 56.4 18/05 10:01:08 500 5 Mefcom Vishvas 10:01:08 10:01:00 00:00:08 56.45 56.45 5000 5000 56.4 18/05 10:01:08 500 5 Mefcom Vishvas 10:01:08 10:01:00 00:00:08 56.45 56.45 5000 5000

56.4 18/05 10:01:08 200 5 Mefcom Vishvas 10:01:08 10:01:00 00:00:08 56.45 56.45 5000 5000 55.7 18/05 10:18:00 4901 0 Mefcom Quantum 10:17:59 10:17:34 00:00:25 55.70 55.70 5000 5000 55.3 18/05 10:47:22 4677 5 Mefcom Cosmo 10:47:22 10:47:13 00:00:09 55.35 55.35 5000 5000 55.2 18/05 11:19:03 4976 0 Mefcom Quantum 11:19:03 11:19:01 00:00:02 55.20 55.20 5000 5000 55.3 18/05 14:16:02 5000 0 Mefcom Ishita 14:16:02 14:15:53 00:00:09 55.30 55.30 5000 5000 55.6 1000 18/05 15:13:08 10000 5 Mefcom Quantum 15:13:07 15:13:08 00:00:01 55.65 55.65 0 10000 55.6 18/05 15:14:22 1300 0 Mefcom Vishvas 15:14:10 15:14:22 00:00:12 55.60 55.60 1300 1300 57.8 18/05 09:58:47 4900 0 Vishvas Mefcom 09:58:47 09:58:32 00:00:15 57.80 57.80 5000 5000 57.4 18/05 09:59:42 5000 5 Ishita Mefcom 09:59:41 09:59:42 00:00:01 57.45 57.45 5000 5000 55.4 18/05 10:48:25 4627 0 Quantum Mefcom 10:48:25 10:48:14 00:00:11 55.40 55.40 5000 5000 55.3 18/05 11:08:08 4900 5 Cosmo Mefcom 11:08:08 11:08:01 00:00:07 55.35 55.35 5000 5000 55.3 18/05 14:10:47 5000 0 Cosmo Mefcom 14:10:47 14:10:38 00:00:09 55.30 55.30 5000 5000 55.6 1000 18/05 15:10:18 10000 5 Vishvas Mefcom 15:10:18 15:10:07 00:00:11 55.65 55.65 0 10000 55.5 1000 19/05 10:35:21 10000 0 Mefcom Ishita 10:35:20 10:35:21 00:00:01 55.50 55.50 0 10000 55.7 1000 19/05 11:35:55 10000 0 Mefcom Quantum 11:35:51 11:35:55 00:00:04 55.70 55.70 0 10000 55.4 19/05 13:50:37 5000 0 Mefcom Quantum 13:50:28 13:50:37 00:00:09 55.40 55.40 5000 5000 55.4 1000 19/05 10:41:56 8235 5 Quantum Mefcom 10:41:56 10:41:38 00:00:18 55.45 55.45 0 10000 55.8 1000 19/05 11:03:29 10000 5 Ishita Mefcom 11:03:29 11:03:11 00:00:18 55.85 55.85 0 10000 55.4 19/05 13:32:49 5000 5 Ishita Mefcom 13:32:49 13:32:40 00:00:09 55.45 55.45 5000 5000 54.7 1000 22/05 10:23:00 1000 0 Mefcom Cosmo 10:23:00 10:22:57 00:00:03 54.70 54.70 0 10000 54.7 1000 22/05 10:23:00 1000 0 Mefcom Cosmo 10:23:00 10:22:57 00:00:03 54.70 54.70 0 10000 54.7 1000 22/05 10:23:00 1000 0 Mefcom Cosmo 10:23:00 10:22:57 00:00:03 54.70 54.70 0 10000 54.7 1000 22/05 10:23:00 1000 0 Mefcom Cosmo 10:23:00 10:22:57 00:00:03 54.70 54.70 0 10000 54.7 1000 22/05 10:23:00 1000 0 Mefcom Cosmo 10:23:00 10:22:57 00:00:03 54.70 54.70 0 10000 54.7 1000 22/05 10:23:00 1000 0 Mefcom Cosmo 10:23:00 10:22:57 00:00:03 54.70 54.70 0 10000 54.7 1000 22/05 10:23:00 1000 0 Mefcom Cosmo 10:23:00 10:22:57 00:00:03 54.70 54.70 0 10000 54.7 1000 22/05 10:23:00 1000 0 Mefcom Cosmo 10:23:00 10:22:57 00:00:03 54.70 54.70 0 10000 54.7 1000 22/05 10:23:00 1000 0 Mefcom Cosmo 10:23:00 10:22:57 00:00:03 54.70 54.70 0 10000

54.7 1000 22/05 10:23:00 900 0 Mefcom Cosmo 10:23:00 10:22:57 00:00:03 54.70 54.70 0 10000 51.7 23/05 10:05:13 5000 5 Mefcom Ishita 10:05:13 10:05:10 00:00:03 51.75 51.75 5000 5000 50.9 1000 23/05 10:10:04 10000 5 Mefcom Quantum 10:10:04 10:10:01 00:00:03 50.95 50.95 0 10000 51.7 23/05 10:57:03 5000 5 Mefcom Ishita 10:57:03 10:56:59 00:00:04 51.75 51.75 5000 5000 50.9 23/05 11:06:18 5000 5 Mefcom Ishita 11:06:18 11:06:11 00:00:07 50.95 50.95 5000 5000 51.4 23/05 12:39:33 5000 5 Mefcom Quantum 12:39:33 12:39:19 00:00:14 51.45 51.45 5000 5000 50.4 23/05 13:39:41 500 5 Mefcom Ishita 13:39:41 13:39:21 00:00:20 50.45 50.45 500 500 50.4 23/05 13:42:21 500 5 Mefcom Ishita 13:42:21 13:42:00 00:00:21 50.45 50.45 500 500 50.8 23/05 14:34:51 5000 0 Mefcom Cosmo 14:34:51 14:34:42 00:00:09 50.80 50.80 5000 5000 50.8 23/05 15:05:47 5000 5 Mefcom Cosmo 15:05:47 15:05:41 00:00:06 50.85 50.85 5000 5000 51.7 1000 23/05 10:56:23 10000 0 Quantum Mefcom 10:56:22 10:56:23 00:00:01 51.70 51.70 0 10000 51.4 1000 23/05 12:28:12 10000 5 Ishita Mefcom 12:28:12 12:28:11 00:00:01 51.45 51.45 0 10000 50.8 23/05 12:54:28 5000 0 Ishita Mefcom 12:54:28 12:54:19 00:00:09 50.80 50.80 5000 5000 50.8 23/05 13:14:26 5000 5 Ishita Mefcom 13:14:26 13:14:22 00:00:04 50.85 50.85 5000 5000 50.8 23/05 13:15:10 5000 5 Ishita Mefcom 13:15:10 13:15:02 00:00:08 50.85 50.85 5000 5000 50.8 1000 23/05 14:29:35 9970 5 Ishita Mefcom 14:29:35 14:29:26 00:00:09 50.85 50.85 0 10000 50.8 23/05 15:07:56 2000 0 Ishita Mefcom 15:07:55 15:07:56 00:00:01 50.80 50.80 2000 2000 50.8 23/05 15:08:24 3000 0 Ishita Mefcom 15:08:24 15:08:20 00:00:04 50.80 50.80 3000 3000 50.2 23/05 15:28:22 2500 0 Ishita Mefcom 15:28:21 15:28:22 00:00:01 50.20 50.20 2500 2500 50.7 24/05 10:39:33 2000 5 Mefcom Ishita 10:39:33 10:39:23 00:00:10 50.75 50.75 2000 2000 50.7 24/05 10:39:42 1000 5 Mefcom Ishita 10:39:42 10:39:40 00:00:02 50.75 50.75 1000 1000 50.7 24/05 10:54:39 2500 0 Mefcom Ishita 10:54:39 10:54:34 00:00:05 50.70 50.70 2500 2500 50.7 24/05 10:54:50 1000 0 Mefcom Ishita 10:54:50 10:54:47 00:00:03 50.70 50.70 1000 1000 50.7 24/05 10:55:04 1500 0 Mefcom Ishita 10:55:04 10:54:59 00:00:05 50.70 50.70 1500 1500 50.9 24/05 11:44:50 4926 0 Mefcom Ishita 11:44:50 11:44:44 00:00:06 50.90 50.90 5000 5000 50.8 24/05 10:17:25 500 5 Quantum Mefcom 10:17:25 10:16:43 00:00:42 50.85 50.85 5000 5000 50.8 24/05 10:17:25 500 5 Quantum Mefcom 10:17:25 10:16:43 00:00:42 50.85 50.85 5000 5000 50.8 24/05 10:17:25 500 5 Quantum Mefcom 10:17:25 10:16:43 00:00:42 50.85 50.85 5000 5000

50.8 24/05 10:17:25 500 5 Quantum Mefcom 10:17:25 10:16:43 00:00:42 50.85 50.85 5000 5000 50.8 24/05 10:17:25 2925 5 Quantum Mefcom 10:17:25 10:16:43 00:00:42 50.85 50.85 5000 5000 50.8 24/05 10:38:21 5000 0 Cosmo Mefcom 10:38:21 10:38:16 00:00:05 50.80 50.80 5000 5000 51.9 24/05 11:45:30 4505 0 Ishita Mefcom 11:45:30 11:45:27 00:00:03 51.90 51.90 5000 5000 50.8 24/05 12:40:33 2999 0 Cosmo Mefcom 12:40:33 12:40:33 00:00:00 50.80 50.80 3000 3000 50.8 24/05 12:40:50 1999 0 Cosmo Mefcom 12:40:48 12:40:50 00:00:02 50.80 50.80 2000 2000 50.3 24/05 14:21:01 4958 5 Ishita Mefcom 14:21:01 14:20:52 00:00:09 50.35 50.35 5000 5000 48.9 24/05 15:17:23 2500 0 Ishita Mefcom 15:17:23 15:17:22 00:00:01 48.90 48.90 2500 2500 48.9 24/05 15:21:35 1500 0 Ishita Mefcom 15:21:35 15:21:28 00:00:07 48.90 48.90 1500 1500 48.2 25/05 10:00:41 5000 5 Mefcom Quantum 10:00:41 10:00:38 00:00:03 48.25 48.25 5000 5000 47.5 25/05 10:08:50 2028 0 Cosmo Mefcom 10:08:50 10:08:26 00:00:24 47.50 47.50 5000 5000 47.6 26/05 10:45:34 2000 5 Quantum Mefcom 10:45:34 10:45:24 00:00:10 47.65 47.65 2000 2000 47.5 26/05 10:46:07 1500 5 Quantum Mefcom 10:46:05 10:46:07 00:00:02 47.55 47.55 1500 1500 47.3 26/05 11:37:32 2500 0 Quantum Mefcom 11:37:32 11:36:58 00:00:34 47.30 47.30 2500 2500 46.9 26/05 15:06:50 4950 0 ISF Mefcom 15:06:50 15:06:31 00:00:19 46.90 46.90 5000 5000 45.4 29/05 15:07:32 5000 0 Mefcom ISF 15:07:32 15:07:21 00:00:11 45.40 45.40 5000 5000 46.6 29/05 10:26:21 500 5 Quantum Mefcom 10:26:21 10:26:19 00:00:02 46.65 46.65 500 500 45.3 30/05 15:29:31 2000 5 Mefcom Master 15:29:31 15:29:25 00:00:06 45.35 45.35 2000 2000 45.5 30/05 14:25:38 7000 5 ISF Mefcom 14:25:25 14:25:38 00:00:13 45.55 45.55 7000 7000 45.5 30/05 14:26:59 1000 5 ISF Mefcom 14:26:56 14:26:58 00:00:02 45.55 45.55 1000 1000 45.5 30/05 14:28:43 500 5 ISF Mefcom 14:28:43 14:28:30 00:00:13 45.55 45.55 500 500 45.4 30/05 15:28:29 2000 0 ISF Mefcom 15:28:29 15:28:24 00:00:05 45.40 45.40 2000 2000 44.6 31/05 12:40:37 500 5 Mefcom ISF 12:40:37 12:40:21 00:00:16 44.65 44.65 500 500 44.6 31/05 13:55:56 2500 0 Mefcom Cosmo 13:55:56 13:55:51 00:00:05 44.60 44.60 2500 2500 44.9 31/05 14:22:37 2500 5 Mefcom Cosmo 14:22:37 14:22:29 00:00:08 44.95 44.95 2500 2500 44.9 31/05 14:52:57 3000 0 Mefcom Cosmo 14:52:57 14:52:48 00:00:09 44.90 44.90 3000 3000 44.9 31/05 14:53:55 2000 0 Mefcom Cosmo 14:53:55 14:53:47 00:00:08 44.90 44.90 2000 2000

The above table reveals that Mefcom indulged in 170 synchronised trades for 6,29,701 shares at NSE with other members of the Vishvas Group during a period of 23 trading days between April 24 and May 31 of 2016.

10.2 Circular Trades Analysis: It was observed that on certain days, whatever quantity of shares were bought by Mefcom, from other Vishvas Group entities, were sold back to Vishvas Group entities on the same day.

10.2.1 Instances of circular trades done on BSE may be observed from the below table: TABLE 8 Buy Qty by Sell Qty by Date Mefcom Seller Name Mefcom Buyer Name 21/04 14,775 Praveen 15,000 Cosmo 24/04 7,500 Praveen 7,235 ISF 25/04 8,626 ISF, Purshottam 14,500 Purshottam, Sunita 27/04 25,000 Purshottam 10,996 Purshottam, Master 28/04 10,000 Purshottam 10,000 Purshottam 29/04 10,000 Purshottam 9,500 Purshottam, Cosmo 2/05 34,739 Purshottam, Praveen 30,022 Purshottam, Cosmo, ISF 4/05 10,000 Purshottam 8/05 10,000 Purshottam 9/05 12,000 Purshottam 10,000 Sunita 10/05 4,480 Purshottam, Sunita 5,000 Purshottam 11/05 20,000 Sunita, ISF 20,002 Purshottam, Praveen 12/05 11,351 Purshottam 12,340 Purshottam, Praveen 15/05 5,000 Purshottam 5,000 Purshottam 16/05 12,500 Purshottam, ISF, Cosmo 17/05 5,000 Purshottam 4,700 Purshottam 18/05 23,920 Purshottam, Sunita, ISF 20,000 Sunita, Cosmo 19/05 14,049 Purshottam, ISF 42,961 Purshottam, ISF 22/05 15,000 Purshottam, Praveen 666 Purshottam, Cosmo 23/05 14,028 Purshottam, Praveen 17,000 Purshottam 24/05 6,500 Praveen, Cosmo 9,260 Purshottam, Cosmo 25/05 10,850 Purshottam, Sunita 15,019 Purshottam, Sunita 26/05 8,507 Purshottam, ISF 29/05 4,000 Purshottam, Praveen 209 Purshottam 30/05 14,613 Purshottam, ISF 5,036 Purshottam, Sunita 31/05 Purshottam, Sunita, Purshottam, Sunita, Cosmo 11,355 Cosmo 10,201 Total 3,23,793 2,74,647

10.2.2. Similarly, instances of circular trades on NSE are observed from the following table: TABLE 9 Buy Seller Name Sell Qty Buyer Name Qty by by Date Mefcom Mefcom 21/04 12,400 Ishita, ISF 15,000 ISF 24/04 8,000 ISF 7,975 Ishita, Cosmo 25/04 32,105 Ishita, ISF 31,450 Ishita, ISF, Cosmo 28/04 15,000 ISF, Master 15,000 Ishita 29/04 10,000 Ishita, Cosmo 9,240 Ishita 2/05 9,995 ISF 10,000 Ishita 4/05 34,999 Ishita, Cosmo 34,899 Ishita, ISF 8/05 4,800 Ishita 9/05 14,999 Ishita 14,975 Ishita, Quantum Ishita, Quantum, ISF, Ishita, Quantum, ISF, Vishvas, 10/05 43,817 Cosmo, Mefcom 42,837 Mefcom 11/05 28,860 Ishita, Quantum 29,721 Cosmo 12/05 42,879 Ishita, Quantum, Cosmo 23,250 Ishita, Cosmo Ishita, Quantum Cosmo, Quantum, Ishita, 15/05 17,034 15,597 Vishvas Ltd 16/05 7,750 Ishita 7,500 Ishita, Cosmo 17/05 26,753 Ishita, Cosmo, Quantum 20,000 Ishita, Cosmo Ishita, Quantum, Vishvas, Ishita, Quantum, Vishvas, 18/05 34,554 Cosmo 35,567 Cosmo 19/05 25,000 Ishita, Quantum 24,995 Ishita, Quantum 22/05 12,429 Cosmo 335 Cosmo 23/05 45,214 Ishita, Quantum, Cosmo 53,935 Ishita, Quantum 24/05 19,926 Ishita, Quantum 35,940 Ishita, Quantum, Cosmo 25/05 14,830 Quantum, Cosmo, Mefcom 11,263 Quantum, Cosmo, Mefcom Quantum, Cosmo, Mefcom, Quantum, Cosmo, Mefcom, ISF 26/05 21,600 ISF Ltd 34,664 Ltd Quantum, Cosmo, Mefcom, Quantum, Cosmo, Mefcom, ISF 29/05 15,126 ISF Ltd 15,285 Ltd Quantum, Cosmo, Mefcom, Mefcom, ISF Ltd, Cosmo 30/05 6,605 Master Ltd 15,655 31/05 16,315 Cosmo, ISF 15,804 Cosmo, ISF, Quantum 5,16,190 5,25,687

11. It was observed during investigation that the day from when members of the Vishvas Group started trading, the average trading volume of the scrip at BSE / NSE had gone up significantly from 70,713/68,005 shares (during April 07, 2006 to April 20, 2006) to 3,38,391/2,13,738 shares (during April 21, 2006 to May 05, 2006) and 2,58,554/2,17,866 shares (during May 08, 2006 to May 31, 2006). Similarly price of the scrip in BSE/NSE increased from `43 / `41.25 on April 19, 2006, touched a high of `70.95 / `71.05 on May 05,

2006 and then decreased to `44.35 / `45.40 on May 31, 2006 within a period of one and half months.

12. Summary of the written and oral submissions made by Mefcom are as follows: (i) Mefcom being demonstrated as a member of the Vishvas Group is based on an erroneous appreciation of the relationship of Mefcom to Vishvas Projects Ltd. (VPL). Mefcom is a group of companies involved in assorted range of activities. Mefcom Agro Industries Ltd. (MAIL) was incorporated and went public in 1984 and was listed on BSE. MAIL was engaged in manufacturing of agro based products. On account of unfavourable business conditions, MAIL was sold in the month of August 2006 to entities of the Vishvas Group and the name of MAIL was changed to VPL. Consequent to the sale of shares, the control and management of the company got changed. The company's object clause was also amended and the directors were changed. Further the registered office address of the company was also changed. Though due intimation was given to BSE regarding change of management and control of MAIL/VPL, the changes were not recorded and reflected by BSE. A letter dated November 21, 2006 was written to BSE stating that control and management of MAIL/VPL has been changed, and the Stock Exchange was requested to make necessary changes in its records. (ii) The investigation period is of April-May, 2006, but by the time of enquiry, the company had already changed hands. Mefcom Agro was sold in open market in August/September of 2006, to Vishvas Projects Ltd. Therefore at the time of enquiry, it appeared to SEBI that during the investigation period the trades were done at the behest of Vishvas Projects Ltd., and consequently Mefcom Securities was linked to the 'Vishvas Group'. Had this error not been made, Mefcom would never have been linked to the Vishvas group and the transactions by Mefcom Securities would not have appeared to have been part of circular and synchronized trades. (iii) The very basis of the allegation that trades being synchronised is on the presumption of their association with the Vishvas Group. It is submitted that the Designated Authority has not considered our submissions with respect to the wrong facts being relied upon by it and that we have no association with the Vishvas Group as alleged.

(iv) The trading carried out by Mefcom were in the nature of jobbing transactions and with large number of trades being carried out by the so called Vishvas Group, some of Mefcom's trades did coincide with trades of the Vishvas Group entities. The very nature of jobbing transaction is that net position taken during the day gets squared off and is zero at end of the day. Mefcom provided many instances of jobbing transactions carried out in other scrips as well during the Investigation period, where net positions during the said period were zero. Mefcom used to engage in jobbing transactions for proprietary trades but never for clients. Currently it does not engage in jobbing transactions at all. (v) The expansion plans, good prospects and positive market image of Gangotri alongside the increased volume in its scrip had kindled interest for trading in the said scrip. (vi) Without prejudice to the contention that the said trades had not been in nature of synchronized trades and also the contention that in the trades alleged to be synchronized, there have been difference in time, price order quantity and also one order getting executed in multiple trades, there have been only 81(BSE) and 170(NSE) total trades executed by us. This is to say that if our intention had been to match the trades with those of Vishwas Group, the instance of such trades would have been much higher. (vii) We only traded for Mefcom Agro Industries Ltd which was also our client and a Group Company. No trades were done for so called “Vishvas Projects Ltd”. Further merely 1,00,000 shares were bought for Mefcom Agro Industries Ltd and no sale was effected for it. That we herein reiterated that we were carrying out jobbing nature of transaction both buy and sell is done so net positions become zero at times which is normal aspect of jobbing transaction and there is nothing wrong in it. (viii) The jobbing transactions may have resulted in self trades. However the trades themselves were very insignificant and did not have the potential to affect the price or volume of the scrip. (ix) The subject SCN/Enquiry Report has imputed fraudulent behaviour to us based on impermissible assumptions, without supporting the assumptions with cogent evidence.

13. I have considered the documents on record, the findings of the DA in his Report and the submissions made by Mefcom in this regard. I have identified the following issues as being relevant for my determination: I. Whether Mefcom was involved in synchronised, circular and reversal of trades in the Gangotri scrip and thereby violated sections 12A (a), 12A(b) and 12A(c) of the SEBI Act, 1992 read with regulations 3(a), 3(b), 3(c), 3(d), 4(1), 4(2)(a), 4(2)(e) and 4(2)(g) of the PFUTP Regulations? II. Whether Mefcom has violated regulation 7 read with Clause A of Schedule II of the Stock Brokers Regulations dealing with Code of Conduct for Stock Brokers? III. Whether the recommendation of the Designated Authority submitted vide Report dated November 25, 2014 must be accepted?

14. The alleged violations need to be examined against the law relating to frauds in the securities market and that of conduct of brokers. Sections 12A(a), (b) and (c) of the SEBI Act record the statutory prohibition against fraudulent and manipulative practices in the securities market. The provisions read as follows: Prohibition of manipulative and deceptive devices, insider trading and substantial acquisition of securities or control. Section 12A. No person shall directly or indirectly— (a) use or employ, in connection with the issue, purchase or sale of any securities listed or proposed to be listed on a recognized stock exchange, any manipulative or deceptive device or contrivance in contravention of the provisions of this Act or the rules or the regulations made thereunder; (b) employ any device, scheme or artifice to defraud in connection with issue or dealing in securities which are listed or proposed to be listed on a recognised stock exchange; (c) engage in any act, practice, course of business which operates or would operate as fraud or deceit upon any person, in connection with the issue, dealing in securities which are listed or proposed to be listed on a recognised stock exchange, in contravention of the provisions of this Act or the rules or the regulations made thereunder;

Further the relevant provisions of the regulations dealing with frauds in the securities market i.e. the SEBI (Prohibition of Fraudulent and Unfair Trade Practices in Securities Market) Regulations, 2003 (hereinafter referred to as "PFUTP Regulations"), are as follows: "Regulation 3: - 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 thereunder; (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 thereunder. Regulation 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; ... (e) any act or omission amounting to manipulation of the price of a security; … (g) entering into a transaction in securities without intention of performing it or without intention of change of ownership of such security;" Regulation 7 (as it then read, prior to amendment in 2013) read with Clause A of Schedule II of the Stock Brokers Regulations dealing with Code of Conduct reads as follows:

Stock brokers to abide by Code of Conduct. 7. The stock broker holding a certificate shall at all times abide by the Code of Conduct as specified in Schedule II. SCHEDULE II CODE OF CONDUCT FOR STOCK BROKERS A. General. 1) Integrity: A stock-broker, shall maintain high standards of integrity, promptitude and fairness in the conduct of all his business. 2) Exercise of due skill and care: A stock-broker shall act with due skill, care and diligence in the conduct of all his business. 3) Manipulation: A stock-broker shall not indulge in manipulative, fraudulent or deceptive transactions or schemes or spread rumours with a view to distorting market equilibrium or making personal gains.

4) Malpractices: A stock-broker shall not create false market either singly or in concert with others or indulge in any act detrimental to the investors interest or which leads to interference with the fair and smooth functioning of the market. A stockbroker shall not involve himself in excessive speculative business in the market beyond reasonable levels not commensurate with his financial soundness. 5) Compliance with statutory requirements: A stock-broker shall abide by all the provisions of the Act and the rules, regulations issued by the Government, the Board and the Stock Exchange from time to time as may be applicable to him.

15. Mefcom has emphasised in its submissions that inclusion of its name in the Vishvas Group is erroneous. According to Mefcom, shares of MAIL were held by Mr. Vijay Mehta (director of Mefcom Securities Ltd. ) and by one of the Mefcom group companies i.e. Mefcom Capital Markets Ltd.("MCML") to the extent of 1.9% and 46.38%, respectively of the shareholding of MAIL. Both the promoters sold off their stake in the open market pursuant to which MAIL's name was changed to Vishvas Infrastructure Ltd. The registered office and management of the company were also changed. Mefcom's contention is that this name change gave rise to the assumption that Mefcom was part of the Vishvas group. But even this transaction of sale of shareholding by the Mefcom group took place after the Investigation Period. In support of its contentions, Mefcom has submitted copies of correspondences with BSE from MAIL and MCML and a Corporate Announcement from BSE. Mefcom has also alleged that despite raising these issues before the DA, the same were not considered in his report. I have perused the submissions and accompanying documents filed by Mefcom in this regard. Considering the same, I note that the evidence recorded in the DA Report (in relation to the Vishvas Group because of its relationship with MAIL/VPL) does not appear to be irrefutable. I therefore do not agree that the evidence placed before me directly links Mefcom with the Vishvas Group. However, I draw reference to the decision of the Hon'ble Supreme Court in the case of SEBI v. Kishore Ajmera & Ors, wherein the Court by its order dated February 23, 2016 held that knowledge of who the counter party is, whether client or broker, is not relevant for the purpose of proving that illegal synchronised trades had taken place. The following extracts of the said order of the Hon'ble Supreme Court is instructive in this regard: ""...knowledge of who the 2nd party/client or the broker is, is not relevant at all." (para 26 of the SC Order)

"When over a period of time such transactions had been made between the same set of brokers or a group of brokers a conclusion can be reasonably reached that there is a concerted effort on the part of the concerned brokers to indulge in synchronized trades the consequence of which is large volumes of fictitious trading resulting in the unnatural rise in hiking the price/value of the scrip(s)." (Para 25 of the SC Order) "The conclusion has to be gathered from various circumstances like that volume of the trade effected; the period of persistence in trading in the particular scrip; the particulars of the buy and sell orders, namely, the volume thereof; the proximity of time between the two and such other relevant factors." (Para 26 of the SC Order)

Therefore direct proof of connection is not necessary to infer that certain persons were acting in coordination to execute illegal synchronised trades. Large scale of transactions and the repetitive nature of the same coupled with impact on volume and price on securities which are otherwise illiquid, all add to the inference that illegal synchronisation had infact taken place. I note that the relationship of Mefcom with VPL (erstwhile MAIL) is not the only factor in making Mefcom a part of the Vishvas Group. On the other hand, Mefcom had placed the orders of MAIL which got matched/reversed with other entities of the Vishvas Group as brought out earlier in this Order, which sufficiently leads one to infer that Mefcom had connection with the Vishvas Group.

16. As is evident from the relevant extracts of section 12A of the SEBI Act and regulation 3 of the PFUTP Regulations, it is clear that the scope of the prohibition against fraudulent trades is wide enough to cover illegal synchronised/circular/reversal trades. The circumstances surrounding synchronised transactions and the inferences drawn thereof provide guidance in arriving at a conclusion as to the legality of the transactions. This legal position was laid down by the Securities Appellate Tribunal (SAT) in the case of Ketan Parekh v. SEBI (Appeal No. 2/2004) in its order dated July 14, 2006, extracts of which are reproduced as follows: “.......... A synchronised transaction will, however, be illegal or violative of the Regulations if it is executed with a view to manipulate the market or if it results in circular trading or is dubious in nature and is executed with a view to avoid regulatory detection or does not involve change of beneficial ownership or is executed to create false volumes resulting in upsetting the market equilibrium. ... Whether a transaction has been executed with the intention to manipulate the market or defeat its mechanism will depend upon the intention of the parties which could be inferred from the attending circumstances because direct evidence in such cases may not be available. The nature of the transaction executed, the frequency with which such transactions are undertaken, the value of the transactions, whether they involve circular trading and whether there is real change of beneficial ownership, the conditions then prevailing in the market are some of the factors which go to show the intention of the parties. This list of factors, in the very nature of things, cannot be exhaustive. Any one factor may or may not be decisive and it is from the cumulative effect of these that an inference will have to be drawn.”

Subsequent decisions of the SAT have reinforced the aforesaid views albeit in different words and considering different circumstances. Notable amongst them include decisions in the cases of HB Stockholdings Limited v. SEBI (Appeal no. 114 of 2012), SPJ Stock Brokers Pvt. Ltd. v. SEBI (Appeal No. 52 of 2013) and Kapil Chatrabhuj Bhuptani v. SEBI (Appeal No. 95 of 2013).

17. While assessing the role of Mefcom in the trading of Gangotri scrip, the reference to its role made in SAT order dated October 21, 2016 in the case of Master Finlease Ltd. is relevant. The relevant extracts of SAT order is reproduced below: "7. Apart from the above, the A.O. has recorded a finding that in respect of several trades executed by and between appellant and Vishvas Group of entities, the difference between buy order time and sell order time was less than 60 seconds and there was no difference between buy order rate and sell order rate as well as there was no difference between buy order quantity and sell order quantity. Finding of fact recorded in the impugned order relating to the synchronised trades of the appellant with the Vishvas group entities are as follows:- b) Out of the total 1,11,400 shares of Gangotri sold by the appellant at NSE during the investigation period 7000 shares were synchronized with the member of Vishvas Group viz. MEFCOM Securities Ltd. One of the instances of the synchronized trade by the appellant with other members of Vishvas Group was that, on 28th April, 2006, the Appellant sold 5000 shares of Gangotri at the rate of Rs.57.95/- to MEFCOM Securities Limited (MEFCOM for short, a Vishvas Group entity) at 15:24:27 and the buy order was placed by MEFCOM at 15:24:27 at the rate of Rs.57.95 for 5000 shares and the sell order was placed by the appellant at 15:24:23 at the rate of Rs.57.95 for 5000 shares. The aforesaid facts establish beyond any shadow of doubt that the appellant had indulged in synchronized trades.

8. Apart from the above, the Adjudicating Officer has clearly brought on record that the appellant had indulged in circular trades by recording the following:- a) Out of the 38,000 shares of Gangotri bought by the appellant at BSE, during the investigation period, 27,399 shares were involved in circular trading with the other members of Vishvas group i.e. MEFCOM, Purshottam Khandelwal (‘Purshottam’ for short) and Praveen Poddar (‘Praveen’ for short). d) Out of 1,11,400 shares sold by the appellant during the investigation period at NSE 36,865 shares were involved in circular trading with the other members of the Vishvas Group i.e. MEFCOM and Ishita. ... In the present case, the Adjudicating Officer has not only established the connection of the appellant with the Vishvas Group but also demonstrated that the trading pattern among themselves resulted in synchronized trades and circular trades which were in violation of the PFUTP Regulations." (emphasis supplied)

Accordingly SAT upheld the finding of the Adjudicating Officer in the case, that the appellant i.e. Master Finlease Ltd. had violated provisions of sections 12A(a), 12A(b), 12A(c) of the SEBI Act and regulations 3(a), 3(b), 3(c), 3(d), 4(1), 4(2)(a) & 4(2)(e) of the PFUTP Regulations. The finding of the Appellate Tribunal against Master Finlease involving Mefcom on the other side of the synchronised trades and identifying Mefcom to be a part of the Vishvas Group involved in the illegal synchronised and circular trades leaves no room for me to arrive at a different conclusion based on the same set of facts in the instant case.

18. Nonetheless, I have examined the documents on record including the order logs and trade logs, and cannot but agree with the views expressed in related matters before the Adjudicating Officers as well as by the Hon'ble SAT. The data extracted in Tables 6 and 7 and from the DA report reveals that 81 trades for 3,79,700 shares were executed by Mefcom for itself and its client namely, VPL which synchronised with other Vishvas group members on BSE within a span of 26 trading days; and 170 synchronised trades were executed by Mefcom with other Vishvas Group members on NSE within a span of 23 trading days. On NSE on the 17th of May, for instance, there were 21 occasions of synchronisation of trades of Mefcom between 10:31:13 and 10:52:18. Within this time span, Mefcom placed 19 buy orders and 2 sell orders which got matched on the system. Similar instances are clear from a perusal of the extracts at Table 6 as well. Similarly, the extracted data in Tables 8 and 9, bring out circular transactions between members of the Vishvas Group including Mefcom. It is not necessary to establish a perfect sequence of transactions for proving circular trades.

The repeated instances of circular trading could not have taken place without the active abetment of the parties concerned, and they bear sufficient evidence leading to the inference that illegal synchronisation of trades and circular trading had infact taken place during the investigation period in the Gangotri scrip. Mefcom has also emphasised in its submissions that they were merely engaged in jobbing transactions; to support its claim, Mefcom has also submitted a list of other scrips in which also they were carrying out jobbing transactions. While this claim is not backed by any tangible evidence, even assuming it was true, the pattern of trading and instances of synchronised trading and circular trading brought out in the DA Report and in the Tables above, give rise to a strong preponderance of probability that in the case of Gangotri scrip, Mefcom was engaged in illegal, synchronised, circular and reversal trades with members of the Vishvas Group. The number of self trades though insignificant must be viewed in this context. Given the conclusion that Mefcom was engaged in illegal synchronised, circular trades, its role and impact on volumes and price of the scrip cannot be seen in isolation from the trading by Vishvas Group members in the Gangotri scrip which was illiquid in nature.

The facts detailed out in this Order indicate that Mefcom's share of impugned trades within the Vishvas Group was also substantial, particularly on NSE. As noted in preceding paragraphs of this Order, the inference of connection between Mefcom and the Vishvas Group is not solely based on Mefcom's relationship with MAIL/VPL. The analysis of the order logs/trade logs reveal that the transactions in question cannot be summarily dismissed as 'jobbing transactions'. For the reasons stated above, I am inclined to agree with the DA's conclusion that Mefcom violated section 12A (a), (b) and (c) of the SEBI Act read with regulations 3(a), 3(b), 3(c), 3(d), 4(1), 4(2)(a), 4(2)(e) and 4(2)(g) of the SEBI (Prohibition of Fraudulent and Unfair Trade Practices relating to Securities Market) Regulations, 2003.

19. The DA in his Report has also held that the Noticee i.e. Mefcom by indulging in reversal, circular, self and synchronised trades created a misleading appearance of heavy trading by artificial volumes and manipulated the price of the Gangotri scrip. Consequently, according to the DA Report, Mefcom is also liable for having violated the mandate of the Stock Brokers Regulations that require brokers not to indulge in fraudulent transactions and for failing to maintain high standards of integrity, care and due diligence. Since I have already concluded above that Mefcom is liable for having indulged in manipulative, deceptive and fraudulent transactions in the securities market, the fact that Mefcom's actions are clearly in violation of the aforesaid provisions of the Stock Brokers Regulations needs no further elaboration. I find that Mefcom's actions fall foul of the high standards of good conduct mandated by the Stock Brokers Regulations, and accordingly violate regulation 7 read with Clause A of Schedule II of the Stock Brokers Regulations.

20. With regard to the recommendation made by the DA in his Report, there is a need to consider the mitigating circumstances as well. I note that the aforesaid violations took place more than ten years before and the initiation of enquiry proceedings commenced eight years after the violation. A large proportion of the transactions in question were carried out by Mefcom in its proprietary capacity. Even though the DA has recommended suspension of Mefcom's certificate of registration as a stock broker for a period of four months, in my opinion acceptance of this recommendation at this point of time may have an adverse impact on the retail clients of Mefcom. Therefore, I am inclined to pass directions against Mefcom modifying the recommendation of the DA.

21. Therefore, in exercise of powers conferred on me under section 12 (3) of the SEBI Act read with regulation 28 (2) read with regulation 27 of the SEBI (Intermediaries) Regulations, 2008, upon consideration of the facts and circumstances listed in this Order, applicable legal provisions and submissions of Mefcom, I hereby direct that Mefcom Securities Ltd.shall be prohibited from accepting fresh clients, as a stock broker, for a period of four months from the date of this Order. Mefcom Securities Ltd. shall disclose the contents of these directions on its website(s) immediately.

22. A copy of this order shall be served on the recognised stock exchanges and on Mefcom Securities Ltd., in accordance with regulation 30 of the SEBI (Intermediaries) Regulations, 2008.

Place: Mumbai G. MAHALINGAM Date: May 05, 2017 WHOLE TIME MEMBER SECURITIES AND EXCHANGE BOARD OF INDIA