Order in the matter of Kassa Finvest Private Limited

WTM/GM/EFD/64/2020-21 SECURITIES AND EXCHANGE BOARD OF INDIA ORDER Under Section 12 (3) of SEBI Act, 1992 read with Regulation 28 (2) of SEBI (Intermediaries) Regulations, 2008 in the matter of Kassa Finvest Private Limited.

NOTICEE PAN SEBI REGISTRATION NO Kassa Finvest AAACK1206B NSE:INB230770236, INF230770236, INE230770236 Private Ltd. BSE: INB010770239, INF010770239 MSEI:INB260770236, INF260770236, INE260770236 OTCEI:INB200770232

Background 1. Kassa Finvest Private Limited ( Kassa/Noticee) having its registered office at H-35/3, Ground Floor, Connaught Circus, New Delhi -110001 is registered with SEBI as a stock broker in equity segment of National Stock Exchange Ltd. (NSE) (Registration number: INB230770236), BSE Ltd. (BSE) (Registration number: INB010770239), Metropolitan Stock Exchange India Ltd. (MSEI) (Registration number: INB260770236) & OTC Exchange of India (Registration number: INB200770232); in the equity derivative segment of NSE (Registration number: INF230770236), BSE (Registration numbers: INF010770239) & MSEI (Registration number: INF260770236); and currency derivative segment of NSE (Registration number: INE230770236) & MSEI (Registration number: INE260770236). Ashok Kumar and U.S.S. Srivastava are the directors of the Noticee.

2. SEBI started receiving a substantial number of complaints from the clients of the Noticee regarding “non-receipt/delay in payment of funds and securities” from December 2014 onwards. In view of the same, information pertaining to the delay in making payments to the clients as alleged in the complaints was sought from their director Ashok Kumar in terms of section 11(2)(i) of the SEBI Act, 1992 (SEBI Act).

Order in the matter of Kassa Finvest Private Limited

3. Ashok Kumar vide letter dated January 20, 2015 inter-alia submitted the following i. The shares of clients were sold from the pool account and the sale proceeds were credited to Kassa's account and were used to fill the gap between revenue and expenses. ii. The approximate value of default is Rupees 30 crores and the same shall be settled in instalments starting January 31, 2015. A post-dated cheque of Rupees 4 crores would be submitted with NSE on January 21, 2015 to be honored on January 31, 2015. iii. Subsequently, every 10 days, cheques of Rupees 4 crores shall be submitted to NSE till the claims are met. 4. However, despite the assurances given by Ashok Kumar, the Noticee failed to resolve investor complaints pending against it within the timeline that was indicated. NSE vide its e-mail dated March 11, 2015, informed SEBI that there were 195 pending investor complaints against the Noticee having a claim value of approximately Rupees 38.13 crores as of March 11, 2015.

5. Mr. Ashok Kumar in his submissions made on January 20, 2015, has admitted that Kassa had raised funds by illegally selling the securities of its clients/investors and such funds were purportedly used for meeting Kassa's operational expansion. It was therefore prima facie observed by SEBI that the Noticee had failed to segregate its own and clients' funds and securities as required under SEBI Circular SMD/SED/CIR/93/23321 dated November 18, 1993 and MRD/DoP/SE/Cir-11/2008 dated April 17, 2008 and Clause 15 of Rights and Obligations documents for Stock Broker, Sub-brokers and Clients as prescribed by SEBI vide its circular dated August 22, 2011.

6. It was also prima facie noted that the Noticee had failed to comply with Clause 12 of SEBI circular no. MIRSD/SE/Cir-19/2009 dated December 03, 2009 and Clause 33 of Rights and Obligations document for Stock Brokers, Sub-Brokers and Clients as prescribed by SEBI vide its circular dated August 22, 2011, regarding the timelines for settlement of funds.

7. It was further noted during the preliminary examination that the Noticee had issued letters which prima facie suggest that it has provided assured returns to its clients in violation of the provisions of 12 A (a) (b) and (c) of the SEBI Act and regulations 3(b), (c) and (d) and regulations 4(1) and 4(2) (k) of the SEBI (Prohibition of Fraudulent and Unfair Trade Practices Relating to Securities Market) Regulations, 2003(PFUTP Regulations).

8. In view of the above prima facie violations that were observed, an Investigation was ordered under Section 11C of the SEBI Act vide order dated February 23, 2015. However, pending investigation, given the serious nature of the alleged violations, SEBI in the interest of protecting the investors in the securities market, in exercise of powers under sections 11(1), 11(4), 11B and 11D of the SEBI Act, 1992, by way of an Ex-Parte -Ad- Interim Order dated March 19, 2015 issued the following directions, - “ i. Kassa Finvest Private Limited (CIN:U74899DL1994PTC060668)and its directors namely, Mr.Ashok Kumar (DIN:00405986; PAN No. AAFPK7362N), Dr. Umashankar Sharan Shrivastav (DIN: 00413213; PAN No. AGKPS7923C) and promoter Mrs. Anjana Kumar (PAN not available) are restrained from accessing the securities market and further prohibit them from buying, selling or otherwise dealing in securities, either directly or indirectly, or being associated with the securities market in any manner whatsoever, with immediate effect, till further directions;

ii. The aforesaid entities and persons shall cease and desist from undertaking any activity in the securities market, directly or indirectly, in any manner whatsoever till further directions;

iii. The aforesaid entities and persons are directed to provide a full inventory of all their assets whether movable or immovable, or any interest or investment or charge in any of such assets, including details of their all bank and demat accounts immediately but not later than 5 working days from the date of receipt of these directions iv. The aforesaid entities and persons are directed to not to dispose off or alienate any assets, whether movable or immovable, or any interest or investment or charge in any of such assets except with the prior permission of SEBI.”

9. Thereafter, SEBI vide order dated September 05, 2017, confirmed the findings in the said interim order and inter alia prohibited the Noticee and its directors from accessing the securities market and further prohibited them from buying, selling or dealing in securities, either directly or indirectly or being associated with the securities market in any manner whatsoever, for a period of ten years.

10. The Noticee preferred an appeal (Appeal No. 346 of 2017) against the said SEBI order before the Hon’ble Securities Appellate Tribunal (hereinafter referred to as “SAT”). SAT vide common order dated September 26, 2019 (hereinafter referred to as “SAT Order”) upheld the findings in the SEBI order on merits.

11. Simultaneously with the aforesaid proceedings, SEBI initiated enquiry proceedings against the Noticee under Chapter V of the SEBI (Intermediaries) Regulations, 2008 ("Intermediaries Regulations") and appointed a Designated Authority ("DA") to enquire into whether the alleged violations by the Noticee warranted cancellation or suspension of the certificate of registrations granted by SEBI or any other action provided in Chapter V of the Intermediaries Regulation. On completion of the proceedings, the DA submitted the report dated June 01, 2018 (DA’s Report) recommending that the certificates of registration of the Noticee be cancelled.

12. Pursuant to this, a post enquiry SCN dated June 19, 2018 was issued to the Noticee under Regulation 28 (1) of SEBI (Intermediaries) Regulations, 2008 to show cause as to why action, as recommended by the DA or any other action as considered appropriate by the Designated Member, should not be taken against the Noticee. A copy of the DA’s Report was also forwarded to the Noticee along with an advice to file reply, if any, within 21 days from the date of receipt of the notice. However, the SCN came back undelivered and the same could also not be served by way affixture at the address of the Noticee available with SEBI. The SCN was therefore uploaded on the SEBI website under >Enforcement>Unserved Summons/Notices.

13. Thereafter, Noticee was granted an opportunity of personal hearing on August 20, 2020. The notice of issue of the post enquiry SCN and the hearing notice was served via newspaper publication in one English newspaper having nationwide circulation, and in the Mumbai and New Delhi editions of one Hindi newspaper. However, Noticee failed to appear for the hearing. Thereafter, another opportunity of hearing was granted to the Noticee on September 24, 2020 wherein also the Noticee failed to enter appearance. I am, therefore, satisfied that sufficient opportunities have been provided to the Noticee and the principles of natural justice have been complied with in this regard. In view of the above, I am compelled to proceed with the present matter ex-parte based on the material available on record.

CONSIDERATION

14. I have considered the Investigation Report, Report submitted by the DA, the Post-Enquiry SCN issued to the Noticee along with the documents contained therein and other material available on record. I note from the records that the modus operandi alleged to have been adopted by the Noticee is as under,-

**related entities i. Kassa Holdings and Consultants Private Limited ii. Kassa Financial Advisors Pvt. Ltd. iii. Mystic Cures Ltd. iv. Mr. Siddharth Shankar(Son of Ashok Kumar) v. Ms. Neetika Shankar. (wife of Siddharth Shankar)

15. It was alleged that the Noticee promised clients fixed/assured returns for securities and funds (money) provided by the clients. The securities received from clients were sold/pledged by the Noticee. The funds received from clients and the proceeds from pledging client securities were then transferred to the bank accounts of the Noticee. Such funds were also transferred to other related entities of the Noticee and used for meeting the business expenses of the Noticee. Siphoning off of the clients’ funds and securities resulted in liquidity problems and this led to the Noticee defaulting in returning the funds and securities payable to the clients.

16. I therefore the note that the issues that arise for consideration in the present matter are,- a. Non segregation of own and clients' funds and securities and Mis-utilisation of clients funds/securities b. Indulging in activities other than stock broking business such as providing assured returns to clients/ investors c. Dealing in Cash d. Non-redressal of investor grievance and failure to follow the directions of the Orders of IGRP e. Non-compliance of the requirement of periodical settlement of client accounts and failure to return securities on clients’ request f. Failure to furnish information related to the broker’s financial ledgers, demat accounts/statements, details of all bank accounts etc. g. Failure to comply with various provisions of the Broker Regulations and applicable circulars/rules.

17. Before moving forward, it will be appropriate to refer to the relevant provisions of the SCRR, SEBI Act, Broker Regulations, PMS Regulations, and other SEBI circulars alleged to have been violated by the Noticee.

Securities Contract (Regulation) Rules, 1957 “Qualifications for membership of a recognised stock exchange. 8. The rules relating to admission of members of a stock exchange seeking recognition shall inter alia provide that : (3) No person who is a member at the time of application for recognition or subsequently admitted as a member shall continue as such if— (f) he engages either as principal or employee in any business other than that of securities or commodity derivatives except as a broker or agent not involving any personal financial liability, provided that— … ” SEBI Act, 1992 “Prohibition of manipulative and deceptive devices, insider trading and substantial acquisition of securities or control. 12A. No person shall directly or indirectly— (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;” SEBI (Prohibition of Fraudulent and Unfair Trade Practices Relating to Securities Market) Regulations, 2003 “3. Prohibition of certain dealings in securities No person shall directly or indirectly— (a) buy, sell or otherwise deal in securities in a fraudulent manner; (c) employ any device, scheme or artifice to defraud in connection with dealing in or issue of securities which are listed or proposed to be listed on a recognized stock exchange; (d) engage in any act, practice, course of business which operates or would operate as fraud or deceit upon any person in connection with any dealing in or issue of securities which are listed or proposed to be listed on a recognized stock exchange in contravention of the provisions of the Act or the rules and the regulations made there under.

4. Prohibition of manipulative, fraudulent and unfair trade practices (1) Without prejudice to the provisions of regulation3, no person shall indulge in a manipulative, fraudulent or an unfair trade practice in securities markets. 2) Dealing in securities shall be deemed to be a manipulative fraudulent or an unfair trade practice if it involves any of the following,- (m) an intermediary not disclosing to his client transactions entered into on his behalf including taking an option thereon.1” SEBI (Portfolio Managers) Regulations, 1993 Registration as portfolio manager. 3. No person shall act as a portfolio manager unless it has obtained a certificate of registration from the Board under these regulations. SEBI (Stock Brokers) Regulations, 1992 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. …

1 Regulation 4(2)(m) has since been substituted vide the SEBI (Prohibition of Unfair Trade Practices)Regulation, 2003.

(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.”

SEBI CIRCULARS ‘Collateral deposited by clients with broker’ MRD/DoP/SE/Cir- 11/2008 dated April 17, 2008 “2.1 Brokers should have adequate systems and procedures in place to ensure that client collateral is not used for any purposes other than meeting the respective client’s margin requirements / pay-ins. Brokers should also maintain records to ensure proper audit trail of use of client collateral.” ‘Simplification and Rationalization of Trading Account Opening Process. CIR/MIRSD/16/ 2011 dated August 22, 2011 Annexure – 4 RIGHTS AND OBLIGATIONS OF STOCK BROKERS, SUB- BROKERS AND CLIENTS as prescribed by SEBI and Stock Exchanges “TRANSACTIONS AND SETTLEMENTS 15. The stock broker shall ensure that the money/securities deposited by the client shall be kept in a separate account, distinct from his/its own account or account of any other client and shall not be used by the stock broker for himself/itself or for any other client or for any purpose other than the purposes mentioned in Rules, Regulations, circulars, notices, guidelines of SEBI and/or Rules, Regulations, Bye-laws, circulars and notices of Exchange. ADDITIONAL RIGHTS AND OBLIGATIONS 33. The stock broker shall make pay out of funds or delivery of securities, as the case may be, to the Client within one working day of receipt of the payout from the relevant Exchange where the trade is executed unless otherwise specified by the client and subject to such terms and conditions as may be prescribed by the relevant Exchange from time to time where the trade is executed.”

“Mode of payment and delivery” SEBI/MRD/SE/Cir- 33/2003/27/08 dated August 27, 2003 “2. It is reiterated that brokers and sub-brokers should not accept cash from the client whether against obligations or as margin for purchase of securities and / or give cash against sale of securities to the client. 3. All payments shall be received / made by the brokers from / to the clients strictly by account payee crossed cheques / demand drafts or by way of direct credit into the bank account through EFT, or any other mode allowed by RBI. The brokers shall accept cheques drawn only by the clients and also issue cheques in favour of the clients only, for their transactions. However, in exceptional circumstances the broker or sub-broker may receive the amount in cash, to the extent not in violation of the Income Tax requirement as may be in force from time to time.” ‘Investor Grievance Redressal Mechanism’ CIR/MRD/ICC/30/2013 dated September 26, 2013 “With a view to streamline and make more effective the investor grievance redressal mechanism at Stock Exchanges, and consequent to discussions with Stock Exchanges and Depositories, it has been decided to shorten the time taken for the proceedings as well as to give monetary relief to the investors, during the course of pendency of proceedings. In this regard, Stock Exchanges are advised inter alia as under: a) Stock Exchanges shall ensure that all complaints are resolved at their end within 15days.... b) In case the matter does not get resolved, conciliation process of the exchange would start immediately ............. c) Investor Grievance Redressal Committee (IGRC) shall be allowed a time of 15 days to amicably resolve the investor complaint.

d) IGRC shall adopt a two-fold approach i.e. for proceedings leading to direction to the Member to render required service in case of service related complaints and proceedings leading to an order concluding admissibility of the complaint or otherwise in case of trade related complaints. e) In case the matter is not resolved through the conciliation process, IGRC would ascertain the claim value admissible to the investor. f) Upon conclusion of the proceedings of IGRC, i.e. in case claim is admissible to the investor, Stock Exchanges shall block the admissible claim value from the deposit of the Member. g) The Stock Exchange shall give a time of 7 days to the Member from the date of signing of IGRC directions as mentioned under sub-para (d) above to inform the Stock Exchange whether the Member intends to pursue the next level of resolution ie. Arbitration.” ‘Dealings between a client and a stock broker (trading members included)’ MIRSD/ SE /Cir-19/2009 dated December 3, 2009

Running Account Authorization “12. Unless otherwise specifically agreed to by a Client, the settlement of funds/securities shall be done within 24 hours of the payout. However, a client may specifically authorize the stock broker to maintain a running account subject to the following conditions: (e) The actual settlement of funds and securities shall be done by the broker, at least once in a calendar quarter or month, depending on the preference of the client. While settling the account, the broker shall send to the client a ‘statement of accounts’ containing an extract from the client ledger for funds and an extract from the register of securities displaying all receipts/deliveries of funds/securities. The statement shall also explain the retention of funds/securities and the details of the pledge, if any.”

ISSUES FOR CONSIDERATION Non segregation of own and clients' funds and securities and Mis-utilisation of clients funds/securities a. Movement of funds from Client bank account to business bank account of the Noticee

18. I note that from the analysis of bank statements of the Noticee that it has clearly emerged that funds to the tune of Rs. 46.82 crores were transferred from client bank accounts to the business bank accounts of the Broker from 2008 onwards. The details of such transfers are provided in Table 1 below,-

Table 1 S No. Client Bank Business Bank Year Payments Receipts Net Net Total(Rs.) Account (A) Account (B) from from Client Payment/Receipt Business to to Business (Rs.) E = (D) -(C) Client Bank Bank Account Account (Rs.) (C) ( R s. ) ( D ) Where Where Movement Movement is From (B) is From (A) to (A) to (B) 1 00030340019675 KASSA FIVEST 2008 8,00,000 -8,00,000 -3,38,44,000 HDFC KASSA HDFC BUSINESS 2009 10,00,000 -10,00,000 FINVEST CLIENT AC - 2010 15,00,000 -15,00,000 ACCOUNT 03132740000012 2011 90,95,000 25,00,000 -65,95,000 2012 58,00,000 20,00,000 -38,00,000 2013 91,75,000 -91,75,000 2014 1,16,45,000 8,25,000 -1,08,20,000 2015 1,54,000 -1,54,000 2 03132740000029 KASSA FIVEST 2008 30,00,000 3,84,05,000 3,54,05,000 48,44,45,584 - HDFC KASSA HDFC BUSINESS 2009 1,79,00,000 6,15,95,000 4,36,95,000 FINVEST CLIENT AC - 2010 49,50,000 6,70,85,000 6,21,35,000 ACCOUNT 03132740000012 2011 1,10,00,000 11,72,65,000 10,62,65,000 2012 26,54,416 4,36,75,000 4,10,20,584 2013 10,82,80,000 10,82,80,000 2014 90,10,000 9,39,45,000 8,49,35,000 2015 2,50,000 29,60,000 27,10,000 3 2008 - 12,02,000 12,02,000 1,76,77,000

Table 1 S No. Client Bank Business Bank Year Payments Receipts Net Net Total(Rs.) Account (A) Account (B) from from Client Payment/Receipt Business to to Business (Rs.) E = (D) -(C) Client Bank Bank Account Account (Rs.) (C) ( R s. ) ( D ) Where Where Movement Movement is From (B) is From (A) to (A) to (B) KASSA FINVEST 2009 2,00,000 77,75,000 75,75,000 CANARA 2010 4,50,000 - -4,50,000 KASSA FINVEST BUSINESS AC - 2011 - 32,50,000 32,50,000 CANARA CLIENT 2577201017174 AC - KASSA FIVEST 2009 22,00,000 22,00,000 2577201016473 HDFC BUSINESS 2011 39,00,000 39,00,000 AC - 03132740000012 Grand Total 8,85,83,416 55,68,62,000 46,82,78,584 46,82,78,584 b. Movement of funds received after pledging securities of clients -

19. The securities received from clients were maintained by the Noticee in the client beneficiary account with the Stock Holding Corporation of India Limited bearing account number IN301330 – 20743522. I note that the investigation has brought to light the sale/ pledge of such securities by the Noticee and subsequent transfer of funds received to the bank account (8111213081) of the Noticee with Kotak Mahindra Bank, Karol Bagh Branch.

From the analysis of the bank statement of the said account, it is observed that the funds raised by pledging securities/mutual fund units of the clients were transferred to the Broker’s related entities. The details of the securities/ mutual fund units pledged with Kotak Mahindra Bank are placed below as Table 2. The details of the transfer of funds are included in Table 3.

Table 2: Status of securities/mutual fund units still pledged with Kotak Mahindra Bank

S.No. Demat account Name of scrip /Mutual Fund units in the demat No. of no (i) account (Providing Details of Scrips Pledged Securities/ with Kotak Mahindra Bank (ii) mutual funds units (Scrip /mutual funds wise pledge) (iii) 1 20743522 ICICI PRUDENTIAL MUTUAL FUND DYN 38461.834 BD FU REGULAR GROWTH 2 20743522 RELIANCE LIQUID FUND-CASH PLAN- 257.986 GROWTH 3 20743522 UTI DYNAMIC BOND FUND - GROWTH 38269.602 OPTION 4 20743522 DSP BLACKROCK DUAL ADVANTAGE 100000 FUND - SERIES 3 - 36M - GROWTH OPTION 5 20743522 RELIANCE REGULAR SAVINGS FUND - 8746.815 DEBT OPTION - GROWTH 6 20743522 HSBC INCOME FUND - SHORT TERM - 15409.93 REGULAR - GROWTH 7 20743522 BIRLA SUN LIFE MONTHLY INCOME-PLAN 4802.685 B(GROWTH 8 20743522 RELIANCE FIXED HORIZON FUND - XXV - 150000 SERIES 13 - GROWTH OPTION 9 20743522 UTI INCOME OPPORTUNITIES FUND - 13439.656 GROWTH OPTION 10 20743522 FRANKLIN INDIA CORPORATE BOND 32444.659 OPPORTUNITIES FUND - GROWTH 11 20743522 BIRLA SUN LIFE DYNAMIC BOND FUND- 29567.131 RETAIL PLAN - GROWTH 12 20743522 BIRLA SUN LIFE INCOME PLUS-GROWTH- 2028.228 REGULAR PLAN 13 20743522 DSP BLACKROCK BOND FUND-REGULAR 13363.619 PLAN-GROWTH 14 20743522 HSBC INCOME FUND - SHORT TERM - 5136.644 REGULAR - GROWTH 15 20743522 IDFC - SUPER SAVER INCOME FUND (SSIF) 11158.307 -INVESTMENT PLAN-REGULAR PLAN- GROWTH OPTION 16 20743522 IDFC - SUPER SAVER INCOME FUND (SSIF) 24342.035 - MEDIUM TERM -REGULAR PLAN- GROWTH OPTION c. Movement of funds from the Broker to other group/ associate entities/person(s) –

20. The analysis of the bank statements also revealed that Noticee had transferred funds to the tune of approximately Rs. 26.45 crores from its business/ client bank accounts to group/ associate entities namely, Kassa Holdings & Consultants Pvt. Ltd., Kassa Financial Advisors Pvt. Ltd., Mystic Cures Pvt. Ltd., Mr. Ashok Kumar, Mr. Siddharth Shankar and Ms. Neetika Shankar. Apart from this, funds transfers were also observed in favour of family owned entities - Gugu Trading, GVC Capital, AARB and G&G Impex, companies which are owned by Ms. Neetika Shankar as per the statement of Mr. Siddharth Shankar before SEBI recorded on April 14, 2015; and Durgamaya Advisors Pvt. Ltd. and Primavalue Capital Advisors Pvt. Ltd., companies owned by Mr. Ashok Kumar as per the said statement of Mr. Siddharth Shankar. The net payments to group/related entity/persons of the Noticee for the period 2008 onwards is given below,-

Table 3 S. Name of Business/ Client Year Total Payments Total Receipts Net Net Total No. group/related Bank Account of to related to related Payment/Receipt entity/person the Broker through entity(s)/ entity(s)/ E = (D) - (C) of the Broker which funds person(s) p e r s on(s) to whom funds transferred (C) ( D ) transferred (B) Where Where (A) Movement is Movement is From (B) to (A) From (A) to (B) (Rs.) (Rs.) (Rs.) (Rs.) 1 KASSA KASSA FINVEST 2013 12,50,000 -12,50,000 -10,04,60,000 FINANCIAL AXIS Client Bank ADVISORS 223010200017028 KASSA FINVEST 2011 76,85,000 - -76,85,000 CANARA BUSINESS 2012 1,73,15,000 - -1,73,15,000 AC - 2013 8,50,000 - -8,50,000 2577201017174 KASSA FINVEST 2014 54,60,000 40,00,000 -14,60,000 INDUSIND Business Bank 200998895217 KASSA FINVEST 2014 26,00,000 -26,00,000 KOTAK Bank Business 8111216136 KASSA FINVEST 2013 46,75,000 -46,75,000 KOTAK Bank OD 8111213081

Table 3 S. Name of Business/ Client Year Total Payments Total Receipts Net Net Total No. group/related Bank Account of to related to related Payment/Receipt entity/person the Broker through entity(s)/ entity(s)/ E = (D) - (C) of the Broker which funds person(s) p e r s on(s) to whom funds transferred (C) ( D ) transferred (B) Where Where (A) Movement is Movement is From (B) to (A) From (A) to (B) (Rs.) (Rs.) (Rs.) (Rs.) KASSA FIVEST 2010 50,000 -50,000 HDFC BUSINESS AC 2011 40,25,000 -40,25,000 - 03132740000012 2012 1,50,75,000 -1,50,75,000 2013 3,49,90,000 8,40,000 -3,41,50,000 2014 1,21,25,000 8,00,000 -1,13,25,000 2 KASSA KASSA FINVEST 2012 1,00,000 -1,00,000 -3,67,44,000 HOLDINGS AXIS Business Bank 2014 26,00,000 26,00,000 9120200495430130 KASSA FINVEST 2010 30,00,000 -30,00,000 AXIS Client Bank 2011 24,00,000 24,00,000 223010200017028 2012 10,00,000 -10,00,000 2013 47,05,000 -47,05,000 KASSA FINVEST 2012 8,65,000 - -8,65,000 CANARA BUSINESS 2013 18,90,000 - -18,90,000 AC - 2014 38,90,000 - -38,90,000 2577201017174 KASSA FINVEST 2009 12,00,000 12,00,000 HDFC Client Bank 2010 6,00,000 6,00,000 00030340019675 2011 12,60,000 83,00,000 70,40,000 2013 41,50,000 41,50,000 2014 21,00,000 21,00,000 KASSA FINVEST 2010 36,00,000 36,00,000 INDUSIND Business 2011 1,18,75,000 82,00,000 -36,75,000 Bank 2012 32,00,000 20,10,000 -11,90,000 200000820286 2013 89,50,000 44,30,000 -45,20,000 2014 37,50,000 32,30,000 -5,20,000 2015 1,00,000 16,00,000 15,00,000 KASSA FINVEST 2013 35,25,000 1,06,10,000 70,85,000 INDUSIND Business 2014 49,65,000 9,40,000 -40,25,000 Bank 2015 8,75,000 3,00,000 -5,75,000 200998895217 KASSA FINVEST 2012 15,00,000 -15,00,000 KOTAK Bank OD 2013 41,50,000 -41,50,000 8111213081 2014 10,00,000 -10,00,000 2015 3,50,000 -3,50,000 2008 44,00,000 -44,00,000

Table 3 S. Name of Business/ Client Year Total Payments Total Receipts Net Net Total No. group/related Bank Account of to related to related Payment/Receipt entity/person the Broker through entity(s)/ entity(s)/ E = (D) - (C) of the Broker which funds person(s) p e r s on(s) to whom funds transferred (C) ( D ) transferred (B) Where Where (A) Movement is Movement is From (B) to (A) From (A) to (B) (Rs.) (Rs.) (Rs.) (Rs.) 2009 3,00,000 3,00,000 2010 1,25,00,000 -1,25,00,000 KASSA FIVEST 2011 3,02,50,000 40,00,000 -2,62,50,000 HDFC BUSINESS AC 2012 1,04,00,000 57,00,000 -47,00,000 - 03132740000012 2013 1,47,50,000 5,02,00,000 3,54,50,000 2014 1,38,55,000 60,50,000 -78,05,000 2015 9,84,000 -9,84,000 KASSA FIVEST 2009 15,50,000 -15,50,000 HDFC CLIENT AC - 2010 30,00,000 -30,00,000 03132740000029 2011 26,50,000 1,10,00,000 83,50,000 2012 57,50,000 7,00,000 -50,50,000 2013 1,24,25,000 45,00,000 -79,25,000 2014 30,00,000 10,00,000 -20,00,000 3 ASHOK KUMAR KASSA FINVEST 2009 10,00,000 - -10,00,000 -3,35,22,009 CANARA CLIENT AC 2011 10,00,000 - -10,00,000 - 2577201016473 2012 50,00,000 - -50,00,000 KASSA FIVEST 2008 36,50,000 2,43,750 -34,06,250 HDFC BUSINESS AC 2009 27,50,000 35,845 -27,14,155 - 03132740000012 2010 24,63,046 35,00,000 10,36,954 2011 95,50,000 19,00,000 -76,50,000 2012 39,85,000 -39,85,000 2013 25,98,857 13,76,193 -12,22,664 2014 78,95,894 -78,95,894 2015 4,95,000 -4,95,000 KASSA FIVEST 2009 1,90,000 -1,90,000 HDFC CLIENT AC - 03132740000029 4 MYSTIC CURES KASSA FINVEST 2011 15,00,000 -15,00,000 -1,74,40,750 LIMITED CANARA BUSINESS AC - 2577201017174 KASSA FINVEST 2012 36,00,000 -36,00,000 HDFC Client Bank 2013 36,95,000 -36,95,000 00030340019675

Table 3 S. Name of Business/ Client Year Total Payments Total Receipts Net Net Total No. group/related Bank Account of to related to related Payment/Receipt entity/person the Broker through entity(s)/ entity(s)/ E = (D) - (C) of the Broker which funds person(s) p e r s on(s) to whom funds transferred (C) ( D ) transferred (B) Where Where (A) Movement is Movement is From (B) to (A) From (A) to (B) (Rs.) (Rs.) (Rs.) (Rs.) KASSA FINVEST 2014 4,25,000 -4,25,000 KOTAK Bank OD 8111213081

KASSA FIVEST 2013 87,00,000 11,50,000 -75,50,000 HDFC BUSINESS AC 2014 7,65,000 8,00,000 35,000 - 03132740000012 KASSA FIVEST 2012 10,00,000 -10,00,000 HDFC CLIENT AC - 2013 5,00,000 -5,00,000 03132740000029 2014 7,94,250 7,94,250

5 SIDDHARTH KASSA FINVEST 2011 13,50,000 - -13,50,000 -2,06,04,330 SHANKAR CANARA BUSINESS AC - 2577201017174 KASSA FINVEST 2015 10,00,000 10,00,000 INDUSIND Business Bank 200998895217 KASSA FIVEST 2008 11,36,758 -11,36,758 HDFC BUSINESS AC 2009 10,04,872 -10,04,872 - 03132740000012 2010 8,46,000 -8,46,000 2011 30,49,500 -30,49,500 2012 22,21,200 -22,21,200 2013 49,17,000 -49,17,000 2014 1,28,61,000 27,82,000 -1,00,79,000 2015 20,00,000 20,00,000 KASSA FIVEST 2014 10,00,000 10,00,000 HDFC CLIENT AC – 03132740000029

6 NITIKA KASSA FINVEST 2011 1,25,000 -1,25,000 -62,20,000 SHANKAR HDFC Client Bank 2012 17,00,000 -17,00,000 00030340019675 2013 38,50,000 -38,50,000

Table 3 S. Name of Business/ Client Year Total Payments Total Receipts Net Net Total No. group/related Bank Account of to related to related Payment/Receipt entity/person the Broker through entity(s)/ entity(s)/ E = (D) - (C) of the Broker which funds person(s) p e r s on(s) to whom funds transferred (C) ( D ) transferred (B) Where Where (A) Movement is Movement is From (B) to (A) From (A) to (B) (Rs.) (Rs.) (Rs.) (Rs.) KASSA FINVEST 2014 50,000 11,75,000 11,25,000 INDUSIND Business Bank 200000820286 KASSA FINVEST 2014 11,50,000 11,50,000 INDUSIND Business Bank 200998895217 KASSA FIVEST 2012 8,50,000 -8,50,000 HDFC BUSINESS AC 2013 53,40,000 -53,40,000 - 03132740000012 2014 21,30,000 -21,30,000 KASSA FIVEST 2011 10,75,000 -10,75,000 HDFC CLIENT AC - 2013 54,75,000 54,75,000 03132740000029 2014 11,00,000 11,00,000 7 AARB CAPITAL KASSA FINVEST 2011 10,70,000 -10,70,000 -45,30,000 HDFC Client Bank 2012 27,10,000 -27,10,000 00030340019675 2013 7,50,000 -7,50,000 8 DURGAMAYAA KASSA FINVEST 2013 4,50,000 -4,50,000 -30,75,000 HDFC Client Bank 2014 25,15,000 -25,15,000 00030340019675 KASSA FIVEST 2014 1,10,000 -1,10,000 HDFC CLIENT AC - 03132740000029 9 G AND G KASSA FINVEST 2008 3,30,000 -3,30,000 -1,42,30,000 IMPEX HDFC Client Bank 2009 35,05,000 -35,05,000 00030340019675 2010 3,00,000 -3,00,000 2011 16,50,000 -16,50,000 2012 58,30,000 -58,30,000 2013 23,25,000 -23,25,000 KASSA FIVEST 2008 4,40,000 -4,40,000 HDFC CLIENT AC - 2010 3,50,000 -3,50,000 03132740000029 2014 5,00,000 5,00,000 10 GUGU KASSA FINVEST 2008 5,20,000 -5,20,000 -1,06,25,000 TRADING HDFC Client Bank 2009 31,20,000 -31,20,000 00030340019675 2010 3,00,000 -3,00,000 2011 14,25,000 -14,25,000 2012 41,75,000 -41,75,000 2013 10,85,000 -10,85,000

Table 3 S. Name of Business/ Client Year Total Payments Total Receipts Net Net Total No. group/related Bank Account of to related to related Payment/Receipt entity/person the Broker through entity(s)/ entity(s)/ E = (D) - (C) of the Broker which funds person(s) p e r s on(s) to whom funds transferred (C) ( D ) transferred (B) Where Where (A) Movement is Movement is From (B) to (A) From (A) to (B) (Rs.) (Rs.) (Rs.) (Rs.) 11 GVC CAPITAL KASSA FINVEST 2008 2,25,000 -2,25,000 -1,37,75,000 HDFC Client Bank 2009 16,60,000 -16,60,000 00030340019675 2010 2,00,000 -2,00,000 2011 16,50,000 -16,50,000 2012 67,25,000 -67,25,000 2013 27,15,000 -27,15,000 2014 2,25,000 -2,25,000 KASSA FIVEST 2013 1,75,000 -1,75,000 HDFC BUSINESS AC 2014 2,00,000 -2,00,000 - 03132740000012 12 PRIMAVALUE KASSA FINVEST 2013 4,50,000 -4,50,000 -33,00,000 HDFC Client Bank 2014 26,95,000 -26,95,000 00030340019675

KASSA FIVEST 2014 1,55,000 -1,55,000 HDFC CLIENT AC - 03132740000029

Grand Total 43,58,68,127 17,13,42,038 -26,45,26,089 -26,45,26,089

21. I have also noted from the records that Ashok Kumar, in his statement before SEBI on March 16, 2015, Manoj Kumar Agrawal), Chief Financial Officer of the Noticee during the time, in his statements made on March 18 and March 19, 2015, Anil Kumar Dhawn, VP- Operations, in his statements made on March 18 and March 19, 2015 and Vivek Kumar Agrawal, who was responsible for managing the banks accounts and executing the payments to clients, in his statements made on March 26 and March 27, 2015, have admitted to the mis-utlisation of client funds and securities by the Noticee, in their statements before SEBI.

22. I note from the above that the Noticee in violation of the SEBI circulars moved funds of the clients from the client accounts to business accounts; and the securities of clients were pledged and funds transferred to accounts of the Noticee. I further note that such funds have further been transferred to related entities and persons. In view of the above, it is clearly established that the Noticee has misutilised clients’ securities by pledging them and transferring the proceeds. The Noticee has also failed to comply with the provisions of the SEBI circulars requiring it to segregate between own and clients’ funds/ securities and also has mis-utilised such client funds. The above mentioned actions of the Noticee are in violation of Rule 8(f) of Securities Contracts (Regulation) Rules, 1957, Circular no. SMD/SED/CI/93/23321 dated 18 November, 1993, Clause 2.1 of Circular no. MRD/DoP/SE/Cir-11/2008 dated April 17, 2008 and Clause 15 of Rights and Obligations document for Stock Broker, Sub-Brokers and Clients as prescribed by SEBI Circular dated August 22, 2011.

Indulging in activities other than stock broking business such as providing assured returns to clients/ investors

23. I note from the investigation report that the Noticee had written letters to clients promising assured/fixed returns for securities and funds (money) provided by them. In case of securities, the rate of interest promised varied from 9%-13%, and in case of funds, the rate of interest promised was in the range of 18-27%. Clients were also informed that Noticee will be executing all the trades on their behalf and trades could be executed in any segment/exchange including in commodities derivatives placed through associate/group company- Kassa Holdings & Consultants Pvt. Limited. The relevant portion of one such letter is produced below, - “Kassa office will execute trades on your behalf and you won’t execute any trade yourself ……..in case the profits in your account are insufficient to the tune of 27% per annum (2.25% per month), then Kassa Finvest Pvt. Ltd. will pay as loyalty bonus to the tune of minimum 2.25% per month of the capital lying with Kassa Finvest Pvt. Ltd.”

24. It was also observed from the analysis of bank statements that the payments were being made to certain clients from its business/ client bank accounts of the Noticee on a regular manner (monthly or quarterly basis). These clients appear to be in the nature of assured return/ fixed return clients. Table 4 below shows the details of such transfers.

Table 4 : Payments to assured/ fixed returns clients from business/ clients accounts

Client Name Bank Account of 2011 2012 2013 2014 2015 Grand the Broker Total

ABHAS KASSA FIVEST 75,75,200 4,53,600 3,15,000 1,26,000 1,00,00,000 1,84,69,800 KHANDELWAL HDFC BUSINESS AC - 03132740000012 ABHISHEK KASSA FIVEST 96,738 2,49,123 63,754 4,09,615 LOHTIA HDFC BUSINESS AC - 03132740000012 AJAY SINGH KASSA FIVEST 2,70,922 5,39,119 8,10,041 HDFC BUSINESS AC - 03132740000012 AKANKSHA KASSA FIVEST 3,79,559 7,83,276 28,950 11,91,785 LOHTIA HDFC BUSINESS AC - 03132740000012 ANIL KUMAR KASSA FIVEST 26,357 71,698 98,055 SARJE HDFC BUSINESS AC - 03132740000012 ANIMA KASSA FIVEST 2,18,266 2,18,266 AKHOURI HDFC BUSINESS AC - 03132740000012

Table 4 : Payments to assured/ fixed returns clients from business/ clients accounts

Client Name Bank Account of 2011 2012 2013 2014 2015 Grand the Broker Total

ANURADHA KASSA FIVEST 1,13,493 10,48,281 5,68,271 17,30,045 LOHTIA HDFC BUSINESS AC - 03132740000012 ASHVINI PURI KASSA 11,799 11,799 FINVEST HDFC Client Bank 00030340019675 ATUL KASSA FIVEST 92,000 43,833 57,078 48,600 2,41,511 CHANDRA HDFC BUSINESS AC - 03132740000012 DEVINDER KASSA FIVEST 1,36,503 10,18,011 5,19,411 16,73,925 NATH LOHTIA HDFC BUSINESS AC - 03132740000012 DWARKA KASSA FIVEST 1,05,171 6,41,839 5,25,236 12,72,246 NATH LOHTIA HDFC BUSINESS AC - 03132740000012 FAREED KASSA 28,95,000 3,43,468 32,38,468 AHMAD FINVEST HDFC Client Bank 00030340019675 GURVINDER KASSA FIVEST 17,985 40,688 31,231 89,904 SINGH HDFC BUSINESS AC - 03132740000012 HIRA JAIN KASSA FIVEST 67,812 3,45,747 4,13,559 HDFC BUSINESS AC - 03132740000012 JAVED KASSA FIVEST 13,742 34,497 2,15,076 2,63,315 AHMAD HDFC BUSINESS AC - 03132740000012 KABIR KASSA FIVEST 4,04,625 6,90,816 1,65,845 12,61,286 OBEROI HDFC BUSINESS AC - 03132740000012 KEDAR KASSA FIVEST 1,21,089 13,14,577 3,98,557 20,250 18,54,473 PRASSAD HDFC SINHA BUSINESS AC - 03132740000012 KUMAR KASSA 1,06,226 2,89,000 3,12,800 7,08,026 TRIPURARI FINVEST HDFC SINHA Client Bank 00030340019675

Table 4 : Payments to assured/ fixed returns clients from business/ clients accounts

Client Name Bank Account of 2011 2012 2013 2014 2015 Grand the Broker Total

KUSUM LATA KASSA FIVEST 60,376 2,96,130 3,56,506 HDFC BUSINESS AC - 03132740000012 MOHAMMAD KASSA FIVEST 59,400 1,72,227 1,89,000 4,20,627 ALI ZAFAR HDFC BUSINESS AC - 03132740000012 NATASHA KASSA FIVEST 27,000 1,95,000 3,66,000 66,000 6,54,000 OBEROI HDFC BUSINESS AC - 03132740000012 NAVEEN JAIN KASSA FIVEST 22,500 9,000 31,500 HDFC BUSINESS AC - 03132740000012 NEERJA KASSA 3,64,682 7,150 3,30,542 1,61,500 13,47,874 LADHA FINVEST HDFC Client Bank 00030340019675 PADMA KASSA FIVEST 50,062 70,600 89,314 2,09,976 SHARMA HDFC BUSINESS AC - 03132740000012 POONAM KASSA 32,513 2,34,146 2,10,000 2,29,763 12,22,337 AGARWAL FINVEST HDFC Client Bank 00030340019675 PRASHANT KASSA FIVEST 1,23,044 1,63,545 1,62,307 4,48,896 BAJAJ HDFC BUSINESS AC - 03132740000012 RAM BILAS KASSA FIVEST 1,23,101 88,884 2,11,985 AGARWAL HDFC BUSINESS AC - 03132740000012 RAMESH KASSA FIVEST 66,454 59,654 1,26,108 CHANDRA HDFC GUPTA BUSINESS AC - 03132740000012 SANGEETA KASSA FIVEST 1,18,333 2,32,003 3,05,009 6,55,345 SINGH HDFC BUSINESS AC - 03132740000012 SAROJ DEVI KASSA FIVEST 1,42,832 94,407 2,37,239 AGARWAL HDFC BUSINESS AC - 03132740000012

Table 4 : Payments to assured/ fixed returns clients from business/ clients accounts

Client Name Bank Account of 2011 2012 2013 2014 2015 Grand the Broker Total

SATYA KASSA FIVEST 1,55,388 1,55,388 FINVEST CO. HDFC BUSINESS AC - 03132740000012 SRG EQUITY KASSA FIVEST 1,24,643 48,908 1,73,551 INVESTME HDFC BUSINESS AC - 03132740000012 SUBHASH KASSA FIVEST 13,677 31,295 34,490 79,462 BABU GUPTA HDFC BUSINESS AC - 03132740000012 SUBHASH KASSA FIVEST 1,62,000 2,70,000 4,27,500 2,70,000 11,29,500 CHAND JAIN HDFC BUSINESS AC - 03132740000012 SUBROTO KASSA FIVEST 1,48,977 1,48,977 KUMAR HDFC CHATT BUSINESS AC - 03132740000012 SUNITA JAIN KASSA FIVEST 40,500 67,500 73,125 67,500 2,48,625 HDFC BUSINESS AC - 03132740000012 SUSHANT KASSA FIVEST 1,48,251 9,07,591 4,01,618 68,439 15,25,899 LOHTIA HDFC BUSINESS AC - 03132740000012 VIJAY KASSA 18,79,860 3,94,158 2,16,386 26,51,300 68,62,237 KHETAWAT FINVEST HDFC Client Bank 00030340019675 VIKRAM KASSA FIVEST 2,60,620 2,60,620 GARG HDFC BUSINESS AC - 03132740000012 Grand Total 1,06,50,173 62,12,965 1,16,20,386 89,97,705 1,02,61,095 5,04,62,771

25. I also note that Manoj Kumar Agarwal, Anil Kumar Dhawn, and Vivek Kumar Agrawal have admitted in their statements before SEBI that the Noticee took funds and securities from clients promising fixed returns to clients and also executing trades on their behalf.

26. Based on the above, it is clearly established that Noticee was promising fixed returns to clients and also executing trades on behalf of clients. Such activities are akin to Portfolio Management Scheme (PMS) which is regulated under the SEBI (Portfolio Managers Regulations, 1992. Since the Noticee did not have a valid certificate of registration from SEBI for offering portfolio management services, such services were being offered by the Noticee without obtaining the required regulatory approvals. Further, Regulation 14(3)(a) of the SEBI (Portfolio Managers Regulations, 1993) prohibits from guaranteeing or assuring any return.

Dealing in Cash

27. From the analysis of the bank account statements of the Noticee, it was also observed that cash receipts were received in the client/ business bank accounts.

Table 5

Account BANK ACCOUNT Year Total Account Type Receipts Type Total (Rs.) KASSA FINVEST AXIS Client Bank 2008 223010200017028 1,000 KASSA FINVEST CANARA CLIENT AC 2009 - 2577201016473 300,000 KASSA FINVEST PNB CLIENT BANK - 2011 133002100063276 570,000 KASSA FIVEST HDFC CLIENT AC - 2009 Client 1,407,910 03132740000029 215,000 2011 70,000 2012 230,900 2013 21,010 KASSA FINVEST AXIS Business Bank 2014 Business 9120200495430130 50,000 47,703,000

2 SEBI (Portfolio Managers Regulations), 1993 has since been repealed and replaced by the SEBI (Portfolio Managers Regulations, 2020.

Table 5

Account BANK ACCOUNT Year Total Account Type Receipts Type Total (Rs.) KASSA FINVEST CANARA BUSINESS 2008 AC - 2577201017174 440,000 2010 200,000 2011 400,000 2012 5,050,000 2013 2,375,000 2014 1,750,000 KASSA FINVEST INDUSIND Business 2014 Bank 200000820286 500,000 KASSA FINVEST INDUSIND Business 2013 Bank 200998895217 3,715,000 2014 2,110,000 KASSA FINVEST KOTAK Bank 2012 Business 8111216136 499,500 2013 2,500,000 2014 3,198,500 KASSA FIVEST HDFC BUSINESS AC - 2008 03132740000012 450,000 2010 500,000 2011 3,749,000 2012 6,349,000 2013 3,125,000 2014 4,339,500 2015 336,500 Business KASSA FINVEST KOTAK Bank OD 2013 Overdraft 8111213081 4,516,000 2014 1,550,000

Table 5

Account BANK ACCOUNT Year Total Account Type Receipts Type Total (Rs.) Grand Total 49,110,910 49,110,910 28. By accepting cash receipts, the Noticee is in violation of SEBI/MRD/SE/Cir- 33/2003/27/08 dated August 27, 2003 and SEBI Master Circular on AML/ CFT CIR/ISD/AML/3/2010 dated December 31, 2010.

Non-redressal of investor grievance

29. I note from the Investigation Report, that as of April 15, 2015, 421 investor complaints filed against the Noticee were pending resolution. It is also noted that there were 255 pending complaints as of March 11, 2015 and the complaints against the Noticee witnessed a 65.1% increase within just one month during the investigation period. It is therefore evident from the above that the Noticee has failed to redress investor complaints satisfactorily and therefore has not complied with the mandate under Circular no. CIR/MRD/ICC/30/2013 dated September 26, 2013 and the Conditions of registration as specified under regulation 9(e) of the SEBI (Stock Brokers and Sub Brokers) Regulations, 1992.

Non-compliance of the requirement of periodical settlement of client accounts and failure to return securities on clients’ request

30. The broker is required to ensure periodical settlement of clients’ funds/ securities on a monthly/ quarterly basis. From the sample complaints perused, it has been observed that the clients’ securities/funds have not been settled in a timely manner by the Noticee on multiple occasions. It is therefore observed that the Noticee has not complied with the timelines prescribed in Clause 12 of SEBI Circular no. MIRSD/SE/Cir-19/2009 dated

December 03, 2009 and Clause 33 of Rights and Obligations document for Stock Broker, Sub-Brokers and Clients as prescribed by SEBI Circular dated August 22, 2011, for settlement of client dues.

SEBI order dated September 05, 2017

31. As stated in para 9 above, the Noticee and its directors were prohibited from accessing the securities market by SEBI vide order dated September 05, 2017. Vide the said order, SEBI had held that the Noticee had failed to segregate own funds and clients’ funds/securities, mis-appropriated the clients’ securities, had cash dealings with clients, failed to redress investor grievances satisfactorily, and failed to settle clients’ accounts and return securities on clients’ request. As stated earlier, the findings of SEBI vide the said order was upheld by the Hon’ble Securities Appellate Tribunal vide order dated January 03. 2014.

Order –

2. Given the overwhelming nature of evidence supplicating the charges against the Noticee, I, in exercise of powers conferred under Section 19 of the Securities and Exchange Board of India Act, 1992 read with Regulation 28(2) of the SEBI (Intermediaries) Regulations, 2008, hereby cancel the following certificates of registration granted to the Noticee,-

NOTICEE SEBI REGISTRATION NO Kassa NSE:INB230770236, INF230770236, INE230770236 Finvest BSE: INB010770239, INF010770239 Private MSEI:INB260770236, INF260770236, INE260770236 Ltd. OTCEI:INB200770232

Place: Mumbai G. MAHALINGAM Date: January 29, 2021 WHOLE TIME MEMBER SECURITIES AND EXCHANGE BOARD OF INDIA