Order in the matter of Kelvin Fincap Limited

WTM/RKA/ 103 /ISD/2014 SECURITIES AND EXCHANGE BOARD OF INDIA ORDER UNDER SECTION 11(1), 11(4) AND 11B OF THE SEBI ACT, 1992 AND SECTION 12A OF THE SECURITIES CONTRACTS (REGULATION) ACT, 1956 - IN THE MATTER OF KELVIN FINCAP LIMITED.

1. Pursuant to the detection of a huge rise in the traded volumes and price of the shares of Kelvin Fincap Limited {formerly known as Dahyabhai Sons Limited and hereinafter referred to as "Kelvin "} on the Bombay Stock Exchange Limited (BSE) during the period from June 18, 2013 to May 29, 2014 (hereinafter referred to as "Examination Period"), Securities and Exchange Board of India (SEBI) undertook preliminary inquiry in the dealings in the scrip during the said period.

2. It was noticed that during the period from June 18, 2013 to July 23, 2013 (Patch 1), the price of the scrip rose from `151.55/- to `225/, i.e. an increase of 48% in 26 trading days. On July 24, 2013, the shares of Kelvin were split in the ratio of 1:1 and from July 24, 2013 to May 29, 2014 (Patch 2), the price of the scrip increased from `118/- to `535/-, i.e. an increase of 353% in 205 trading days. An illustration of price/volume movement in the scrip of Kelvin during the Examination Period is given below:

Total Volume Close Price 600 200000 180000 500 160000 140000 400 120000 300 100000 80000 200 60000 40000 100 20000 0 0

3. Kelvin had a share capital of 9,96,000 shares of `10/- each as on December 31, 2011.From the Annual Reports of Kelvin for FY 2011-12 and FY 2012-2013, it was observed that it is in the business of financing and investing and it had earned a negligible profit of `25,869/-during 2011-12 which marginally increased to `43,957.13/-, at the end of the FY 2012-13, with negative reserves. Kelvin's financial statements for the quarters ending June 2013, September 2013, December 2013 and March 2014 also indicated negligible profits earned by it during the relevant period. It was further noted that during the Examination Period there was no corporate announcement made by Kelvin which could support such price rise in its scrip. Thus, the sharp rise in the price of the scrip of Kelvin during the Examination Period was not supported by its fundamentals or any other genuine factor. It is interesting to note that the shares of Kelvin were suspended on BSE till November 2011 and till March 29, 2012, there were no trades on BSE except a single trade of 50 shares at a price of `8.55/-. Strangely, inspite of such poor fundamentals, Kelvin was able to raise `13,00,00,000/- by issuing 1,30,00,000 shares in physical form to certain entities ( individuals and a few corporate entities) at `10/- per share on March 20, 2012. To invest in a company having such poor and meagre fundamentals at a price which is at a premium to the prevailing market price cannot prima-facie be termed as rational buying behaviour. Such investments, as in this case, normally could be made only if the allottees had nexus with directors/promoters of Kelvin and the issue of these shares was under a pre-arrangement between them.

4. On analysis of the trading activity in the above scrip, it was observed that, during the Examination Period, certain related/connected entities had substantially traded amongst themselves in shares of Kelvin and created artificial volume and contributed to the artificial price rise in the scrip. The list of those related/connected entities is given at Annexure - A and they are hereinafter referred to as the "Kelvin Fincap Group". It was observed that prior to the Examination Period, shares of Kelvin had low liquidity, which increased substantially only after those related/connected entities commenced trading heavily in the scrip. Their inter-relationship/connection were noted from the Know Your Client (KYC) details, their bank statements, off-market transactions amongst themselves including the abovementioned allotment of shares, and information available on the Ministry of Corporate Affairs (hereinafter referred to as "MCA") website.

5. Considering the large number of related/connected entities of Kelvin Fincap Group, it was deemed necessary to shortlist those entities who were closely connected to Kelvin and/or were instrumental in the rise in price /buy volume of Kelvin. A set of 22 (twenty two) such entities (hereinafter referred to as the "Shortlisted Group") of Kelvin Fincap Group was shortlisted on the basis of following parameters, viz.

A. Top 10 entities based on gross buy quantity; B. Top 10 entities based on positive contribution in last traded price (hereinafter referred to as "LTP"); C. Promoters/Directors of Kelvin who transacted with other members of Kelvin Fincap Group by way of funds / securities or, had any other relationship with them.

6. The particulars of the members of the Shortlisted Group and the basis of their inter-se relationship/connection are given in the following table :

Table 1: Basis of inter-se relationship/ connection amongst the Shortlisted Group. Sl No PAN Name Basis of Relationship 1 AAACD1880G Dahyhabhai Shares 1. The entity is the promoter of Kelvin as on June 30, 2014 and Stock Brokers as per BSE website. Ltd. 2. The entity has received ` 25,000 from Cromakem Limited on 12/05/2012. 2. AAHPS4084K Keyur M Shah 1. The entity is the director of Dahyhabhai Shares and Stock Brokers Ltd as per MCA website and was a promoter of Kelvin as per shareholding pattern disclosed on BSE website for quarter ending December 2012. 2. The entity transferred shares to Mr. Narendra R Shah, Mr. Mahesh R Shah, Mr. Abhishek N Shah and Ms. Geeta N Shah in physical form. 3. AAAHK5034L Keyur M Shah 1. The entity is HUF with Keyur M Shah as karta and was a (HUF) promoter of Kelvin as per shareholding pattern disclosed on BSE website as on March 31, 2012. 2. The entity transferred shares to Narendra R Shah (HUF) in physical form on 07/04/2012. 4. AAYPS3458E Kavita K Shah 1. The entity is the director of Dahyhabhai Shares and Stock Brokers Ltd as per MCA website and a promoter of Kelvin as per shareholding pattern disclosed on BSE website for quarter ending December 2012. She also shares common address with Keyur M Shah viz, 22 / 23, Purab Apartment, 42, B. G. Kher Marg, Malbar Hill Mumbai 400006. 2. The entity transferred shares to Mr. Narendra R Shah, Mr. Abhishek N Shah and Ms. Geeta N Shah in physical form on 07/04/2012. 5. ALRPB9295L Bhavik Satish Badani 1. The entity is director of Kelvin as per BSE and MCA websites. 2. The entity is one of the directors of Cromakem Limited. 6. AIDPP3653M Bipin Bhikhabhai 1. The entity is director of Kelvin as per BSE and MCA Patel websites. 2. The entity shares common address, viz. 401 B-28, Shanti Nagar Co. Op. Hsg. Ltd. Shanti, Nagar, Sec - 7, Above Indra Hospital, Mira Road, Mumbai - 401107 with Mr. Jitendra

Patel, director of RFL International Limited and Fast Track Entertainment Limited. 7. BBPPE7839K Sushma Vimalkumar 1. The entity is one of the directors of Kelvin as per MCA Raval website. 2. The entity is also director of Millennum Cybertech Limited. 3. The entity shares common address, viz. 23 Shri Ram Vihar Rokadia Lane, Borivali West, Mumbai, 400092, with Mr. Vimalkumar Sureshchandra Raval, Ms. Padmaben Jagdish Jani, Ms. Jalpa Mitesh Jani, Mr. Jagdish Jani (Director of Sapan Chemical Limited, Surya Mangal Media and Entertainment Pvt. Ltd. and Acil Cotton Limited) and Mr. Mitesh Jagdish Jani (Director of Novagold Petro-Resources Limited). 8. AJMPS0962J Mahendrabhai 1. The entity is one of the directors of Kelvin as per MCA Sakalchand Shah Website. 2. The entity is also a director of Heema Infocom Limited and GFL Financial India Limited. 9. AYBPS0534J Vishal Kumar Shah 1. The entity is one of the directors of Kelvin as per BSE website. 2. The entity is one of the directors of Cornhill Trading Co. Pvt. Ltd., Earth Exim Limited and Do Max Steel Limited. 10. AAECC0841Q Cromakem Limited 1. Mr. Bhavik Satish Badani is one of the directors of Kelvin and Cromakem Limited.

2. Narendra Ramanlal Shah and Cromakem Limited share common address, viz. 24, jalaram Nagar, opp.chamunda Circle, ganjawala Lane,Borivali(w), Mumbai, Maharashtra - 400092. 3. Ms. Pallavi Chetan Pandit is one of the directors of Cornhill Trading Co. Pvt. Ltd, Cromakem Limited, Sonal International Limited, Stardom Trading Co. Pvt. Ltd. and IFSL Limited. 4. Mr. Jayshree Shankar Bhosle, Heema Infocom Limited, Do Max Steel Limited, Suryamangal Media And Entertainment Limited, Cornhill Trading Company Pvt Ltd, Sapan Chemicals Limited, Ms. Padmaben Jagdish Jani, Ms. Jalpa Mitesh Jani, Cromakem Limited, Acil Cotton Industries Limited, Mr. Rupesh Balkrishna Bhoir, Mr. Chirag Dineshkumar Shah, Mr. Namdeo Shantaram Gole, Ms. Varsha Praful Trivedi, Mr. Mahesh Ramanlal Shah, Ms. Geeta Narendra Shah, Zimig Trading Company Private Limited and Mr. Parag Chandrkant Shah share common e-mail ID 'NOVAGOLD2007@YAHOO.CO.IN'. 5. The entity received/transfered funds from/to SDFC Finance Limited and Kosha Cubidor Containers Limited. 11. AACCD7020L Do Max Steel 1. The entity shares common director, Mr. Vishal Kumar Limited Shah, with Kelvin, Cornhill Trading Co. Pvt. Ltd. and Earth Exim Limited.

2. Mr. Jayshree Shankar Bhosle, Heema Infocom Limited, Do Max Steel Limited, Suryamangal Media And Entertainment Limited, Cornhill Trading Company Pvt

Ltd, Sapan Chemicals Limited, Ms. Padmaben Jagdish Jani, Ms. Jalpa Mitesh Jani, Cromakem Limited, Acil Cotton Industries Limited, Mr. Rupesh Balkrishna Bhoir, Mr. Chirag Dineshkumar Shah, Mr. Namdeo Shantaram Gole, Ms. Varsha Praful Trivedi, Mr. Mahesh Ramanlal Shah, Ms. Geeta Narendra Shah, Zimig Trading Company Private Limited and Mr. Parag Chandrkant Shah share common e-mail ID 'NOVAGOLD2007@YAHOO.CO.IN'. 12. AAHCS1332H Stardom Trading 1. Cornhill Trading Company Pvt Ltd, Stardom Trading Company Pvt. Ltd Company Pvt Ltd and Acil Cotton Industries Limited share common address, viz. 38, Ganga Vihar, 3rd Floor, Rokadia Lane, Borivali (w), Mumbai - 400092. 2. Ms. Pallavi Chetan Pandit is one of the directors of Cornhill Trading Co. Pvt. Ltd, Cromakem Limited, Sonal International Limited, Stardom Trading Co. Pvt. Ltd. and IFSL Limited. 3. Cornhill Trading Company Pvt Ltd, Earth Exim Ltd, Stardom Trading Company Pvt Ltd, Mr. Rupesh Balkrishna Bhoir, Fast Track Entertainment Limited and Mr. Chirag Dineshkumar Shah, share common e-mail ID 'NOVAGOLD2011@GMAIL.COM'. 13. AAFCS2725Q Sapan Chemicals 1. Earth Exim Ltd, Ms. Geeta N Shah, Sapan Chemicals Limited Limited and Mr. Narendra Ramanlal Shah share common address, viz. 23 Jalaram Nagar Nr.

Chamunda Circle Gajawala Lane Borivli West, Mumbai, 400092. 2. Ms. Sushma Vimalkumar Raval (Director of Kelvin as per MCA website), Mr. Vimalkumar Sureshchandra Raval, Ms. Padmaben Jagdish Jani, Ms. Jalpa Mitesh Jani, Mr. Jagdish Jani (Director of Sapan Chemical Limited, Surya Mangal Media and Entertainment Pvt. Ltd. and Acil Cotton Limited) and Mr. Mitesh Jagdish Jani (Director of Novagold Petro-Resources Limited) share common address, viz. 23 Shri Ram Vihar Rokadia Lane, Borivali West, Mumbai, 400092. 3. Mr. Jayshree Shankar Bhosle, Heema Infocom Limited, Do Max Steel Limited, Suryamangal Media And Entertainment Limited, Cornhill Trading Company Pvt Ltd, Sapan Chemicals Limited, Ms. Padmaben Jagdish Jani, Ms. Jalpa Mitesh Jani, Cromakem Limited, Acil Cotton Industries Limited, Mr. Rupesh Balkrishna Bhoir, Mr. Chirag Dineshkumar Shah, Mr. Namdeo Shantaram Gole, Ms. Varsha Praful Trivedi, Mr. Mahesh Ramanlal Shah, Ms. Geeta Narendra Shah, Zimig Trading Company Private Limited and Mr. Parag Chandrkant Shah share common e-mail ID 'NOVAGOLD2007@YAHOO.CO.IN'. 4. Jaishree Shankar Bhosle is the promoter of Sapan Chemical Limited, as per BSE website.

14. AAACF7961Q Fast Track 1. Director of Fast Track Entertainment Limited and RFL Entertainment International Limited (Jitendra Patel) share same address Limited with the Director of Kelvin, Mr. Bipin Patel, viz. 401 B- 28, Shanti Nagar Co. Op. Hsg. Ltd. Shanti, Nagar, Sec - 7, Above Indra Hospital, Mira Road, Mumbai, 401107 2. Acil Cotton Industries Limited and Fast Track Entertainment Limited share common address, viz. B- 7/404 A, Natraj Township Part-ii,near Parshuram Nagar Society, Sayaji Ganj, Vadodara, Gujarat, India, 390005. 3. Cornhill Trading Company Pvt Ltd, Earth Exim Ltd, Stardom Trading Company Pvt Ltd, Mr. Rupesh Balkrishna Bhoir, Fast Track Entertainment Limited and Mr. Chirag Dineshkumar Shah, share common e-mail ID 'NOVAGOLD2011@GMAIL.COM'. 15. AACCC0591P Cornhill Trading 1. Mr. Vishal Kumar Shah is one of the directors of Kelvin, Company Pvt. Ltd Cornhill Trading Co. Pvt. Ltd., Earth Exim Limited and Do Max Steel Limited. 2. Universal Credit and Securities Limited, Suryamangal Media And Entertainment Limited, Cornhill Trading Company Pvt Ltd and Gfl Financials India Limited share common address, viz. 15 Shriram Vihar, Rokadia Lane, Borivali (w), Mumbai, Maharashtra, India, 400092. 3. Cornhill Trading Company Pvt Ltd, Stardom Trading Company Pvt Ltd and Acil Cotton Industries Limited share common address, viz. 38, Ganga Vihar, 3rd Floor, Rokadia Lane, Borivali (w), Mumbai, Maharashtra, India, 400092. 4. Ms. Pallavi Chetan Pandit is one of the director of Cornhill Trading Co. Pvt. Ltd, Cromakem Limited, Sonal International Limited, Stardom Trading Co. Pvt. Ltd. and IFSL Limited.

5. Mr. Jayshree Shankar Bhosle, Heema Infocom Limited, Do Max Steel Limited, Suryamangal Media And Entertainment Limited, Cornhill Trading Company Pvt Ltd, Sapan Chemicals Limited, Ms. Padmaben Jagdish Jani, Ms. Jalpa Mitesh Jani, Cromakem Limited, Acil Cotton Industries Limited, Mr. Rupesh Balkrishna Bhoir, Mr. Chirag Dineshkumar Shah, Mr. Namdeo Shantaram Gole, Ms. Varsha Praful Trivedi, Mr. Mahesh Ramanlal Shah, Ms. Geeta Narendra Shah, Zimig Trading Company Private Limited and Mr. Parag Chandrkant Shah share common e-mail ID 'NOVAGOLD2007@YAHOO.CO.IN'. 6. Cornhill Trading Company Pvt Ltd, Earth Exim Ltd, Stardom Trading Company Pvt Ltd, Mr. Rupesh Balkrishna Bhoir, Fast Track Entertainment Limited and Mr. Chirag Dineshkumar Shah, share common e-mail ID 'NOVAGOLD2011@GMAIL.COM'. 16. AACCS1185R Sonal International 1. Ms. Pallavi Chetan Pandit is one of the directors of Ltd Cornhill Trading Co. Pvt. Ltd, Cromakem Limited, Sonal International Limited, Stardom Trading Co. Pvt. Ltd. and IFSL Limited. 2. Sonal International Ltd and RFL International Limited share common address, viz. 304, Akruti Complex,nr.stadium Six Cross Road, Navrangpura, Ahmedabad, Gujarat, India, 380009.

17. AAACO2454R Nova Gold Petro 1. Ms. Sushma Vimalkumar Raval (Director of Kelvin as per Resources Limited M CA website), Mr. Vimalkumar Sureshchandra Raval, Ms. Padmaben Jagdish Jani, Ms. Jalpa Mitesh Jani, Mr. Jagdish Jani (Director of Sapan Chemical Limited, Surya Mangal Media and Entertainment Pvt. Ltd. and Acil Cotton Limited as per MCA website) and Mr. Mitesh Jagdish Jani (Director of Novagold Petro-Resources Limited) share common address, viz. 23 SHRI RAM VIHAR ROKADIA LANE, BORIVALI WEST, MUMBAI, 400092. 2. The entity received `25,00,000 from Cromakem Ltd on 20/11/2013. 18. AABCA7788F Acil Cotton 1. Cornhill Trading Company Pvt Ltd, Stardom Trading Industries Limited C o m pany Pvt Ltd and Acil Cotton Industries Limited share common address, viz. 38, Ganga Vihar, 3rd Floor, Rokadia Lane, Borivali (w), Mumbai, 400092. 2. Acil Cotton Industries Limited and Fast Track Entertainment Limited share common address, viz. B- 7/404 A, Natraj Township Part-ii,near Parshuram Nagar Society, Sayaji Ganj, Vadodara, Gujarat, India, 390005. 3. Ms. Sushma Vimalkumar Raval (Director of Kelvin as per MCA website), Mr. Vimalkumar Sureshchandra Raval, Ms. Padmaben Jagdish Jani, Ms. Jalpa Mitesh Jani, Mr. Jagdish Jani (Director of Sapan Chemical Limited, Surya Mangal Media and Entertainment Pvt. Ltd. and Acil Cotton Limited) and Mr. Mitesh Jagdish Jani (Director of Novagold Petro-Resources Limited) share common address, viz. 23 Shri Ram Vihar Rokadia Lane, Borivali West, Mumbai, 400092. 4. Mr. Jayshree Shankar Bhosle, Heema Infocom Limited, Do Max Steel Limited, Suryamangal Media And Entertainment Limited, Cornhill Trading Company Pvt Ltd, Sapan Chemicals Limited, Ms. Padmaben Jagdish Jani, Ms. Jalpa Mitesh Jani, Cromakem Limited, Acil Cotton Industries Limited, Mr. Rupesh Balkrishna Bhoir, Mr. Chirag Dineshkumar Shah, Mr. Namdeo Shantaram Gole, Ms. Varsha Praful Trivedi, Mr. Mahesh Ramanlal Shah, Ms. Geeta Narendra Shah, Zimig Trading Company Private Limited and Mr. Parag Chandrkant Shah share common e-mail ID 'NOVAGOLD2007@YAHOO.CO.IN'. 5. Vimalkumar Raval is one of the directors of Zimig Trading Pvt. Ltd. and Acil Cotton Industries Limited.

19. AAACZ6848C Zimig Trading 1. Mr. Jayshree Shankar Bhosle, Heema Infocom Limited, Company Private Do Max Steel Limited, Suryamangal Media And Limited Entertainment Limited, Cornhill Trading Company Pvt Ltd, Sapan Chemicals Limited, Ms. Padmaben Jagdish Jani, Ms. Jalpa Mitesh Jani, Cromakem Limited, Acil Cotton Industries Limited, Mr. Rupesh Balkrishna Bhoir, Mr. Chirag Dineshkumar Shah, Mr. Namdeo Shantaram Gole, Ms. Varsha Praful Trivedi, Mr. Mahesh Ramanlal Shah, Ms. Geeta Narendra Shah, Zimig Trading Company Private Limited and Mr. Parag Chandrkant Shah share common e-mail ID 'NOVAGOLD2007@YAHOO.CO.IN'. 1.1.1 Vimalkumar Raval is one of the directors of Zimig Trading Pvt. Ltd. and Acil Cotton Industries Limited. 20. AMVPJ5720H Jalpa Jani 1. Ms. Sushma Vimalkumar Raval (Director of Kelvin as per MCA website), Mr. Vimalkumar Sureshchandra Raval, Ms. Padmaben Jagdish Jani, Ms. Jalpa Mitesh Jani, Mr. Jagdish Jani (Director of Sapan Chemical Limited, Surya Mangal Media and Entertainment Pvt. Ltd. and Acil Cotton Limited) and Mr. Mitesh Jagdish Jani (Director of Novagold Petro-Resources Limited) share common address, viz. 23 SHRI RAM VIHAR ROKADIA LANE, BORIVALI WEST, MUMBAI, 400092. 2. Mr. Jayshree Shankar Bhosle, Heema Infocom Limited, Do Max Steel Limited, Suryamangal Media And Entertainment Limited, Cornhill Trading Company Pvt Ltd, Sapan Chemicals Limited, Ms. Padmaben Jagdish Jani, Ms. Jalpa Mitesh Jani, Cromakem Limited, Acil Cotton Industries Limited, Mr. Rupesh Balkrishna Bhoir, Mr. Chirag Dineshkumar Shah, Mr. Namdeo Shantaram Gole, Ms. Varsha Praful Trivedi, Mr. Mahesh Ramanlal Shah, Ms. Geeta Narendra Shah, Zimig Trading Company Private Limited and Mr. Parag Chandrkant Shah share common e-mail ID 'NOVAGOLD2007@YAHOO.CO.IN' 21. AKSPM3939N Kirti Mehta As per the bank Account No. 911010005936771 of Kirti Mehta with Axis Bank Limited, the entity received/transferred funds from/to Kelvin, Cromakem Limited, Stardom Trading Co. Pvt. Ltd., Fast Track Entertainment Limited, Earth Exim Limited, Cornhill Trading Co. Pvt. Ltd., IFSL Limited, GFL Financial India Limited, Inventure Finance Pvt. Ltd., Sonal International Limited, Kosha Cubidor Containers Limited and Acil Cotton Industries Limited.

22. AFMPB0449P Jayshree Shankar 1. Mr. Jayshree Shankar Bhosle, Heema Infocom Limited, Bhosle Do Max Steel Limited, Suryamangal Media And Entertainment Limited, Cornhill Trading Company Pvt Ltd, Sapan Chemicals Limited, Ms. Padmaben Jagdish Jani, Ms. Jalpa Mitesh Jani, Cromakem Limited, Acil Cotton Industries Limited, Mr. Rupesh Balkrishna Bhoir, Mr. Chirag Dineshkumar Shah, Mr. Namdeo Shantaram Gole, Ms. Varsha Praful Trivedi, Mr. Mahesh Ramanlal Shah, Ms. Geeta Narendra Shah, Zimig Trading Company Private Limited and Mr. Parag Chandrkant Shah share common e-mail ID 'NOVAGOLD2007@YAHOO.CO.IN'. 2. Jaishree Shankar Bhosle is the promoter of Sapan Chemical Limited as per BSE website.

7. In addition, from the bank accounts of Kelvin (account No. 912020012135343) and Cromakem Limited (account No. 910020027467767) with Axis Bank, inter se fund transfers between Kelvin and certain entities of the Kelvin Fincap Group during January 01, 2012 to March 31, 2014, were observed. Instances of such inter se fund transfers amongst the related/connected entities of Kelvin Fincap Group and Kelvin are as under:

Table 2: Funds Flow among the Kelvin Fincap Group

Date Transferer Name Transferee Name Amount (`) 9/3/2012 Kelvin Fincap Limited SDFC Finance Limited 5000000 10/3/2012 Kelvin Fincap Limited Universal Credit And Securities Ltd 1600000 13-03-2012 Kelvin Fincap Limited Keyur M Shah 3000000 19-03-2012 Kelvin Fincap Limited Millennium Cybertech Limited 10000000 19-03-2012 Kelvin Fincap Limited Stardom Trading Co.Pvt.Ltd. 10000000 21-03-2012 Kelvin Fincap Limited Novagold Petro-Resources Ltd 9000000 22-03-2012 Kelvin Fincap Limited Acil Cotton Indutries Limited 8000000 24-03-2012 Kelvin Fincap Limited Kirti Mehta 1200000 25-04-2012 Geeta Shah Kelvin Fincap Limited 500000 27/04/2012 Abhishek Narendra Shah Kelvin Fincap Limited 500000 13/09/2012 Cromakem Limited Kelvin Fincap Limited 500000 8/2/2013 Do Max Steel Limited Kelvin Fincap Limited 30000 20/02/2013 Earth Exim Ltd Kelvin Fincap Limited 300000 6/5/2013 Sapan Chemicals Ltd Kelvin Fincap Limited 20000 29/01/2014 Kelvin Fincap Limited Fast Track Entertainment Ltd 300000 3/1/2012 Cromakem Limited Sonal International Limited 400000 11/2/2012 Cromakem Limited Fast Track Entertainment Ltd 205000 11/2/2012 Cromakem Limited SDFC Finance Limited 210000 15/02/2012 Cromakem Limited RFL International Limited 15000 29/02/2012 Gfl Financials India Ltd Cromakem Limited 1000000 11/4/2012 Cromakem Limited Kirti Kantilal Mehta 2000000 16/04/2012 Cromakem Limited Chirag Dinesh Kumar Shah 1775000 20/04/2012 Cromakem Limited Namdeo Shantaram Gole 190000 2/5/2012 Kosha Cubidor Containers Ltd Cromakem Limited 2000000 5/5/2012 Cromakem Limited Millennium Cybertech Limited 200000 5/5/2012 Cromakem Limited IFSL Limited 200000 8/5/2012 Cromakem Limited Yogesh Bhogilal Chauhan 685000 9/5/2012 Stardom Trading Company Private Cromakem Limited 1000000 Limited 10/5/2012 Cromakem Limited Parag Chandrkant Shah 1000000 12/5/2012 Cromakem Limited Dahyabhai Sons Limited 25000 16/05/2012 Suryamangal Media And Entertainment Cromakem Limited 380000 Pvt Ltd. 2/7/2012 Cromakem Limited Universal Credit And Securities Ltd 25000 28/01/2013 Cromakem Limited Earth Exim Ltd 25000

13/03/2013 Cromakem Limited Inventure Finance Pvt Ltd 2522400 14/03/2013 Cromakem Limited Do Max Steel Limited 2523000 15/03/2013 Cromakem Limited Cornhill Trading Company Private Limited 2522400 19/03/2013 Dahyhabhai Shares and Stock Brokers Cromakem Limited 1000000 Ltd. 28/03/2013 Cromakem Limited Padmaben Jagdish Jani 510000 20/05/2013 Cromakem Limited Jalpa Jani 200000 18/07/2013 Cromakem Limited Rupesh Bhoir 500000 25/07/2013 Cromakem Limited Mahesh Ramanlal Shah 400000 6/8/2013 Cromakem Limited Varsha Trivedi 1000000 8/8/2013 Cromakem Limited Jayshree Shankar Bhosle 1000000 12/8/2013 Cromakem Limited Geeta Narendra Shah 65000 11/9/2013 Acil Cotton Industries Limited Cromakem Limited 500000 27/09/2013 Cromakem Limited Sapan Chemicals Limited 1500000 20/11/2013 Cromakem Limited Novagold Petro Resources Ltd 2500000 7/2/2014 Cromakem Limited Zimig Trading Co Pvt Ltd 365000 8/3/2014 Heema Infocom Limited Cromakem Limited 3890000 19/03/2014 Cromakem Limited Abhishek N Shah 115000

8. It is observed from the disclosures made on BSE website that prior to the allotment of shares made in March 2012, Kelvin had a share capital of 9,96,000 shares with promoters' holding 7,43,800 shares constituting 74.67% in the company. Pursuant to the issuance of 1,30,00,000 shares to certain entities, the promoter shareholding decreased to 5.31% and the total number of shareholders in Kelvin increased from 176 to 225.

9. It was further observed that during the quarter ending June, 2012, the Kelvin Fincap Group entities consolidated their holding in Kelvin which resulted in number of shareholders decreasing to 64. During the same period, the promoters of Kelvin also transferred 7,11,050 shares in physical form to certain Kelvin Fincap Group entities through off-market transactions. Thereafter, the Kelvin Fincap Group entities were observed to have transferred shares in physical form as well as in dematerialised form within the group and started trading heavily in the scrip pursuant to June 18, 2013. Analysis of trading in the scrip of Kelvin 10. The analysis of the trading of entities of Kelvin Fincap Group during the aforesaid two (2) patches was carried out with a focus on the following:-  The trading frequency;  The volume generated;  Contribution to price rise;

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

Patch 1: June 18, 2013 to July 23, 2013 (prior to share split) 11. During the Patch 1, price of Kelvin rose from ` 151.55 to ` 225/-( i.e. 48% increase) and was accompanied by rise in the traded volumes. The daily average volume in the scrip which was merely 6 shares during January 1, 2013 to June 17, 2013( i.e. six months prior to Patch 1) increased to 22,237 shares during Patch 1. It was observed that during Patch 1, Kelvin Fincap Group entities collectively bought 5,47,818 shares (94.75% of trade volume) and sold 5,64,913 shares (97.71% of trade volume), out of a total of 5,78,174 shares traded at BSE. As high as 5,36,292 shares which constitute 92.76% of trade volume, were traded amongst the group entities. As high as 97.90% of the total buy volume of the group matched with the sell orders of one or the other group entity. Similarly, 94.93% of their sell volume matched with the buy orders within the group.

12. It was observed that in Patch 1, out of a total of 17 instances of trades establishing new high price in the scrip, the Kelvin Fincap Group established new high price on 4 instances. The contribution of the Kelvin Fincap Group in establishing new high price was ` 19/- out of total price rise of ` 82.40/-, which constitutes 23.06% of the total new high prices.

13. On LTP analysis during Patch 1, it was observed that out of the 24 instances of positive contribution to the LTP, Kelvin Fincap Group contributed positively to the LTP in as many as 9 instances. By executing such trades above the LTP, Kelvin Fincap Group contributed to positive LTP to the extent of `52.20/-, which was 41.04% of overall positive LTP contribution of `127.20/- in the scrip. The details of contribution to price rise by Kelvin Fincap Group during Patch 1 are as under: Table 3: Contribution of Kelvin Fincap Group to price rise in Patch 1 PAN Name Contribution No. of Contribution to No. of in positive Instances New High Instances of LTP (in `) of positive Price (in `) New High LTP Price AAACF7961Q Fast Track Entertainment 19.7 2 9 1 Limited AMVPJ5720H Jalpa Jani 13.75 3 1.25 1 AAECC0841Q Cromakem Limited 8.55 1 8.55 1 AABCE3676Q Earth Exim Ltd 5 1 0 0 AKSPM3939N Kirti Mehta 5 1 0 0 ADQPJ5053P Padmaben Jagdish Jani 0.2 1 0.2 1

14. It was observed that the Shortlisted Group contributed to the positive LTP to the extent of `47/-, which was 90.04% of the contribution made by the Kelvin Fincap Group to the extent of `52.20/-. It was further observed that the Shortlisted Group has contributed in establishing new high price to the extent of `18.80/-, which is 98.95% of the Kelvin Fincap Group's overall contribution of `19/-.

Patch 2: July 24, 2013 to May 29, 2014 (post share split) 15. During Patch 2, price of Kelvin rose from ` 118/- to ` 535/- and was accompanied by a substantial rise in the traded volumes. The average volume in the scrip during Patch 2 increased to 40,974 shares from 22,237 shares in Patch 1. It was observed that during Patch 2, Kelvin Fincap Group collectively bought 81,99,511 shares (97.62% of traded volume) and sold 81,12,737 shares (96.58% of traded volume) out of a total of 83,99,726 shares traded at BSE. As high as 80,53,453 shares which constitute 95.88% of traded volume, were traded amongst the Kelvin Fincap Group entities. As high as 98.22% of their total buy volume matched with the sell orders of one or the other Kelvin Fincap Group entity. Similarly, 99.27% of their sell volume matched with the buy orders within the Kelvin Fincap Group.

16. It was observed that during Patch 2, out of a total of 81 instances of trades establishing new high price in the scrip, the Kelvin Fincap Group established new high price on as many as 64 instances. The contribution of the Kelvin Fincap Group in establishing new high price was ` 328.10/-, which constitutes 77.75% of total new high price of ` 422/- in this Patch.

17. On LTP analysis during Patch 2, it was observed that out of the 472 instances of positive contribution to the LTP, Kelvin Fincap Group contributed to positive LTP in as many as 414 instances. By executing such trades above the LTP, Kelvin Fincap Group contributed to the positive LTP to the extent of `1,712.65/-, which was 86.25% of overall positive LTP contribution of `1,985.65/-. in the scrip. The details of contribution to price rise by the Kelvin Fincap Group during Patch 2 are as under:

Table 4: Contribution of Kelvin Fincap Group to price rise in Patch 2 PAN Name Contributio No. of Contributio No. of n to Positive Instance n to New Instance LTP (in `) s to High Price s to New Positive (in `) High LTP Price AAFCS2725Q Sapan Chemicals Limited 2 3 3 .1 51 40.5 8 AACCD7020L Do Max Steel Limited 2 1 6.15 45 52.6 7

AAECC0841Q Cromakem Limited 203.65 53 48.9 9 AACCC0591P Cornhill Trading Company Pvt Ltd 118.9 24 6.5 2 AACCS1185R Sonal International Ltd 94.4 21 34.1 6 AAHCS1332H Stardom Trading Company Pvt Ltd 91.75 26 19.5 4 AMVPJ5720H Jalpa Jani 90.3 26 5 1 AABCA7788F Acil Cotton Industries Limited 8 2. 6 5 15 0 0 AAACO2454R Nova Gold Petro Resources Limited 7 8. 8 17 34.5 6 AAHCS4914K Suryamangal Media & Entertainment 63.45 18 19 4 Ltd AAACZ6848C Zimig Trading Company Private 54.2 12 2 1 Limited AKSPM3939N Kirti Mehta 52.15 15 7 3 AAACI4383H IFSL Limited 51.05 9 0 0 AAACF7961Q Fast Track Entertainment Limited 49 11 11 3 AQQPG4855K Maruti Shankar Gaude 45 8 0 0 AFMPB0449P Jayshree Shankar Bhosle 38.2 16 8 2 ALZPB9604R Rupesh Balkrishna Bhoir 29.35 8 6 2 AHNPD1452H Vidyadhar Ramnaresh Dubey 26.85 9 5 1 ATRPK4534D Ramesh Krishna Kulaye 21.5 3 1 1 AOYPM7851H Madhuben H Modi 18.5 1 17.5 1 AIYPD1020H Vinod Gajanan Dhadave 14.95 4 0 0 AADCH2621N Heema Infocom Limited 1 1. 0 5 6 0 0 ADQPJ5053P Padmaben Jagdish Jani 10.5 2 5 1 AEKPK6751Q Santosh Kumar 5 1 4 1 AAGCR4662J Reachsmart Construction Private 3 1 0 0 Limited AIOPG4980F Hiren Kirit Gandhi 2.6 4 0 0 ANIPR5608Q Vimalkumar Sureshchandra Raval 2. 1 4 0 0 AAOPS2034A Mahesh Ramanlal Shah 2 1 0 0 AHAPP5916H Jaswant Kantilal Parmar 1.5 2 0 0 ABBPT1431A Varsha Trivedi 1 1 1 1 Total 1712.65 414 328.1 64

18. It was observed that the Shortlisted Group contributed to positive LTP to the extent of ` 1,403.25/-, which is 81.93% of contribution (`1,712.65/-) made by Kelvin Fincap Group. Further, the Shortlisted Group contributed ` 269.60/- in establishing new high price, which is 82.17% of the Kelvin Fincap Group's overall contribution of `328.10/-.

19. From the above analysis, it was observed that the trades of Kelvin Fincap Group contributed significantly to both traded volume and to price rise in the scrip during the Examination Period.

20. It was observed that during the Examination Period the connected/related entities belonging to Kelvin Fincap Group had traded amongst themselves in the scrip and their buy and sell orders placed in those trades persistently matched. An illustration of the trading patterns of order placements followed by Kelvin Fincap Group entities are as under:-

 One of the patterns of order placement by the Kelvin Fincap Group entities was where a buy order placed by one group entity exactly matched with the sell order placed by another group entity. For instance, on January 16, 2014, Jeetandra Janani (HUF) placed a sell order at 11:22:56 AM for a quantity of 2,500 at a price of ` 350/-. After 7 seconds, i.e. 11:23:03, Fast Track Entertainment Limited placed a buy order of same quantity of 2500 shares at a price of `350/-, which immediately matched. Similarly, Prameela Mohandas placed a sell order of 3,000 shares at a price of `340/- at 13:50:53 on the same day, which matched with a buy order of 3,000 shares at a price of `340/- placed by Sapan Chemicals Limited at 13:51:11. In the same manner, the buy and sell orders for 4,000 shares placed by Sapan Chemicals Limited and Zubin K Shah, respectively within a gap of 3 seconds matched at 13:52:13.  In another pattern, the order placed by one group entity matched with the orders placed by more than one entity belonging to the Kelvin Fincap Group. For instance, on January 16, 2014, Ashok Jasraj Jain (HUF) placed 2 sell orders of 5,000 and 2,000 shares at a price of `340/- at 14:44:10 and 14:44:42, respectively. The said sell orders matched with the buy orders placed by the following 8 entities belonging to Kelvin Fincap Group:

Table 5: Counterparties to Ashok Jasraj Jain(HUF) Buyer Name Buy Buy Buy Order Order Order Time Quantity Price Jayshree Shankar Bhosle 1 4 : 4 4 :24 3750 340 Nova Gold Petro Resources 14:48:36 1700 340 Limited Stardom Trading Company Pvt 14:54:23 550 340 Ltd Fast Track Entertainment Limited 1 4 : 5 5 : 1 5 400 340 Cornhill Trading Company Pvt 14:57:22 300 340 Ltd Cromakem Limited 1 4 :5 8 :05 100 340 IFSL Limited 1 4 :58:31 100 340 Stardom Trading Company Pvt 14:58:59 100 340 Ltd

Day wise Trading Analysis 21. The shares of Kelvin were traded on 231 days during the Examination Period. It was observed that on the days when the Kelvin Fincap Group did not trade, the average volume in the scrip was significantly low. The details of group’s concentration vis-a-vis average volume in the scrip during the Examination Period are as under:

Table 6: Concentration of Kelvin Fincap Group Group's Concentration No. of Days Average Market Volume No Trading 1 25 Between 0% and 50% 10 5,743 Between 50% and 80% 13 13,705 Between 80% and 100% 152 44,370 100% 55 36,328 Total 231 38,865

22. Thus, the Kelvin Fincap Group’s concentration in the scrip was significant on the majority of the days it traded and the average volume in the scrip increased with an increase in group’s concentration. Also, on 55 out of 231 days, Kelvin Fincap Group was present in all the trades, both on buy and sell sides and average volume of 36,328 shares was created on account of trades amongst the entities of Kelvin Fincap Group.

23. It was observed that out of the trades of Kelvin Fincap Group during the Examination Period, the Shortlisted Group bought 72,83,765 shares, which constitutes 83.27% of Kelvin Fincap Group's total purchase volume of 87,47,329 shares. Further, the Shortlisted Group contributed to the positive LTP to the extent of `1,450.25/- which was 82.17% of the contribution made by the Kelvin Fincap Group to the extent of `1,764.85/-. The Shortlisted Group also contributed in establishing new high price to the extent of `288.40/-, which is 83.09% of the Kelvin Fincap Group's overall contribution of `347.10/-.

24. In view of the above analysis, it was observed that, in this case, the connected/related entities of Kelvin Fincap Group continuously and persistently traded in substantial volumes in the scrip of Kelvin which was an illiquid one. They traded among themselves substantially and executed matched trades in very large number. In these matched trades amongst connected/ related entities of Kelvin Fincap Group there was no change in beneficial ownership of the traded shares. Their trades created artificial volumes and manipulated the price of the scrip during the Examination Period. Such manipulation in the traded volume and price of any scrip by a group of connected entities has the potential to induce gullible and genuine investors to trade in the scrip and harm them.

25. Apart from the above, it was observed that Kelvin had disclosed to BSE on March 20, 2012 inter-alia stating that it had made a preferential allotment of 1,30,00,000 shares to certain entities as described in the following table :

Table 7: List of Preferential Allottees disclosed by Kelvin on BSE website Number of Equity Shares Sr. No. Name of Allottees/Entities Allotted 1 Mukesh N Desai 500000 2 Mukesh N Desai Huf 500000 3 Sunish B.Bhel/Kavita Sunish Behl 530000 4 Dinesh Jaiswal/Sunita D.Jaiswal/Santlal Jaiswal 345000 5 Subhash Tikamdas Mithawalla/Jignasa S.Mithawalla 150000 6 Tasneem Iqbal Syed/Krishna M.Dawda/Prem Agarwal 330000 7 Mukeshbhai Nanjibhai Moradiya 200000 8 Shehul Vallabhbhai Moradiya 200000 9 Dhanjibhai Shamjibhai Donda 200000 10 Hiren Tulsibhai Moradia 200000 11 Dharmesh Tulsibhai Moradia 200000 12 Bharatbhai Nanjibhai Moradia 200000 13 Vallabhbhai D Sachapara 200000 14 B D Sachpara 200000 15 Rajesh Haribhai Moradia 200000 16 Vasantben Dhanjibhai Donda 200000 17 Chhotubha Shivubha Saravaiya 200000 18 Shobhanaben Nareshbhai Mpradiya 200000 19 Ramniranjan C Jhunjhunwala 200000 20 Hasmukhlal R.Shah 200000 21 Ashok Jashraj Jain HUF 200000 22 Ketan Bhupendrkumar Shah 100000 23 Shantilal Dungarshi Maru HUF 200000 24 Kalpesh Shantilal Maru/Rachana Kalpesh Maru 600000 25 Saloni Ramniklal Maru 100000

26 Manisha Pramesh Rambhia 200000 27 Nirmala Shantilal Maru 400000 28 Sejul Pratish Maru 100000 29 Mitesh Rajnikant Shah 150000 30 Bhavini B.Furia 250000 31 Rajesh Gopaldas Villaitramani 200000 32 Kamlesh Hari Thakur 200000 33 Jagdish Hari Thakur 200000 34 Ashok Gopaldas Kripalani 200000 35 Mrs Lajwanti Hari Thakur 200000 36 Zubin Kamlesh Shah/Zeenal Zubin Shah 400000 37 Prameela Mohandas 200000 38 Inventure Finance Private Limited 600000 39 Deepaben Trabakbhai Makwana 150000 40 Champaben Devjibhai Makwana 150000 41 MrsBhavani Bharatbhai Dangar 100000 42 Mithalal Manoharlal Sahlot 300000 43 Poonam Premsagar Pasricha/Premsagar L Pasricha 100000 44 M.V.R.S Prasad 300000 45 N.Satyanarayana 150000 46 Ravi Sancheti HUF 200000 47 Rakesh Agrawal/Trapti Agrawal 100000 48 GFL Financial India Ltd 898000 49 Suryamangal Media & Entertainment Ltd 897000

26. It is curious to note that the list of entities mentioned in the table above actually have more than one entity clubbed together at serial nos. 3, 4, 5, 6, 24, 36, 43 and 47. On inquiry from the Share Transfer Agent of Kelvin, i.e. Purva Sharegistry (India) Pvt. Ltd. (hereinafter referred to as "Purva Sharegistry) it was observed that the shares were issued to 56 entities and not 49 entities, as disclosed by Kelvin to BSE. It was observed that different share certificates were issued to the following 56 entities and not to 49 as disclosed by Kelvin:- Table 8: List of Preferential Allottees provided by Purva Sharegistry

S. PAN Name Share Certificate Distinctive Number No. Number 1 AATPD0728R Mukesh N Desai 5001-5050 996001 1496000 2 AACHM2754B Mukesh N Desai HUF 5051-5100 1496001 1996000 3 AAAPB8093N Sunish B. Bhel 5101-5119 1996001 2186000 5120-5153 2186001 2526000 4 AAJPB7775N Kavita Sunish Behl

5 AAQPJ0509B Shantilal Jaiswal 5154-5164 2526001 2636000 6 ABVPJ5592Q Sunita Dinesh Jaiswal 5165-5175 2636001 2746000 7 ABVPJ5571B Dinesh Jaiswal 5176-5188 2746001 2871000 8 AADPM3931D Subhash Tikamdas Mithawalla 5189-5195 2871001 2941000 5196-5203 2941001 3021000 9 AGKPM6963C Jignasa Subhash Mithawalla 5204-5213 3021001 3121000 10 AQQPS2059B Tasneem Iqbal Syed ADPPD5068B Krishna M.Dawda 5214-5224 3121001 3231000 11 12 AETPA7958N Prem Agarwal 5225-5236 3231001 3351000 13 AIVPM3622K Mukeshbhai Moradiya 5237-5256 3351001 3551000 14 AIVPM3623J Shehul Vallabhbhai Moradiya 5257-5276 3551001 3751000 15 AEIPD5332A Dhanjibhai Shamjibhai Donda 5277-5296 3751001 3951000 16 AMTPM8714C Hiren Tulsibhai Moradia 5297-5316 3951001 4151000 17 ALEPM6311R Dharmesh Tulsibhai Moradia 5317-5336 4151001 4351000 18 AMTPM0749H Bharatbhai Nanjibhai Morada 5337-5356 4351001 4551000 19 ACXPP9026C Vallabhbhai D Sachapara 5357-5376 4551001 4751000 20 ACXPP9049B B.D.Sachpara 5377-5396 4751001 4951000 21 ACRPM4534E Rajesh Haribhai Moradia 5397-5416 4951001 5151000 22 AEGPD4889J Vasantben Dhanjibhai Donda 5417-5436 5151001 5351000 23 AGBPS6488F Chhotubha Shivubha Saravaiya 5437-5456 5351001 5551000 24 AIKPM4674N Shobhanaben Nareshbhai Mpradiya 5457-5476 5551001 5751000 25 AARPJ2757L Ramniranjan C Jhunjhunwala 5477-5496 5751001 5951000 26 AADPS8752L Hasmukhlal R.Shah 5497-5516 5951001 6151000 27 AAAHJ0191D Ashok Jashraj Jain HUF 5517-5536 6151001 6351000 28 AAFPS1767F Ketan Bhupendrakumar Shah 5537-5546 6351001 6451000 29 AAFHS8932L Shantilal Dungarshi Maru Huf 5547-5566 6451001 6651000 30 AAAPM8353N Kalpesh Shantilal Maru 5567-5568 6651001 6851000 31 AAOPS6468G Rachana Kalpesh Maru 5569-5572 6851001 7251000 32 AAAPM8349Q Saloni Ramniklal Maru 5627-5636 7251001 7351000 33 AAFPM7257G Manisha Pramesh Rambhia 5637-5656 7351001 7551000 34 AAFPM7256H Nirmala Shantilal Maru 5657-5696 7551001 7951000 35 AQWPM5566H Sejul Pratish Maru 5697-5706 7951001 8051000 36 AAJPS0851L Mitesh Rajnikant Shah 5707-5721 8051001 8201000 37 AAAPM8354M Bhavin B. Furia 5722-5746 8201001 8451000 38 AAAPV4085A Rajesh Gopaldas Villaitramani 5747-5766 8451001 8651000 39 AAAPT6038P Kamlesh Hari Thakur 5767-5786 8651001 8851000 40 AAAPT3253A Jagdish Hari Thakur 5787-5806 8851001 9051000 41 AABPK2469A Ashok Gopaldas Kripalani 5807-5826 9051001 9251000 42 AAEPT2433N Mrs Lajwanti Hari Thakur 5827-5846 9251001 9451000 43 AMIPS6846A Zubin Kamlesh Shah 5847-5886 9451001 9851000 44 ACJPN8415H Prameela Mohandas 5887-5906 9851001 10051000 45 AAACM0623J Inventure Finance Private Ltd 5907-5966 10051001 10651000 46 AZTPM3476A Deepaben Trabakbhai Makwana 5967-5981 10651001 10801000 47 ACKPM8513A Champaben Devjibhai Makwana 5982-5996 10801001 10951000 48 ADXPD6143K Mrs Bhavani Bharatbhai Danga 5997-6006 10951001 11051000 49 AAIPS9404N Mithalal Manoharlal Sahlot 6007-6036 11051001 11351000 50 AHCPP2686C Poonam Pramesagar Pasricha 6037-6046 11351001 11451000 51 AAZPM0394A M.V.R.S Prasad 6047-6084 11451001 11826000 52 ABEPN6198B N.Satyanarayana A6084-6091 11826001 11901000

53 AAIHR3732E Ravi Sancheti HUF 6092-6111 11901001 12101000 54 ABYPA6388G Rakesh Agrawal 6112-6121 12101001 12201000 55 AABCG0597Q GFL Financial India Ltd 6122-6214 12201001 13099000 Suryamangal Media & Entertainment 56 AAHCS4914K Ltd 6215-6306 13099001 13996000

27. From the above, it is observed that Kelvin had prima facie given false information to the BSE with regard to the number of allottees and had concealed the actual number of allottees. The method of disclosure i.e. clubbing of one or more allottees under one suggests that the Kelvin showed the false number so as to show such allotment as private placement, which it actually was not. In this regard, it is relevant to mention that Hon'ble Supreme Court in its judgement and order dated August 31, 2012 in matter of Sahara India Real Estate Corporations Limited & Ors Vs SEBI & Anr. - Civil Appeal No. 9813 and 9833 of 2011 [(2013) 1 SCC 1 has held that an offer to fifty or more persons becomes public issue by virtue of first proviso to section 67(3) of the Companies Act, 1956. Hence, it is prima-facie observed that the above allotment was not a preferential allotment (private placement) but was a public issue. Thus, prima-facie, the said allotment of shares by Kelvin was in violation of sections 56, 60 and 73 read with section 67(3) of the Companies Act, 1956 and regulations 4(2), 5(1), 5(7), 6, 7, 25, 36, 37, 46 and 57 of SEBI (Issue of Capital and Disclosure Requirement) Regulation 2009 (hereinafter referred to as "ICDR Regulations").

28. As discussed above, Kelvin had disclosed that the above allotment was a preferential allotment. Assuming it was so, in terms of regulation 78(2) of the ICDR Regulations, the shares so allotted had to be locked-in for a period of one year from the date of allotment on March 20, 2012. However, in this case, two of the allottees viz, Mr. Ravi Sancheti (HUF) and GFL Financial India Limited sold a total of 6,00,000 shares of Kelvin held by them to 4 other entities of Kelvin Fincap Group on September 29, 2012. It was observed from the Annual Report of Kelvin for the FY 2012-13 that the transfer of physical shares was looked after by Shareholders' Grievance and Share Transfer Committee of Kelvin, which comprised three of its directors viz. Mansukh Sanghvi, Bipin Patel and Bhavik Badani. Thus, Kelvin and its directors were under obligation to ensure that the shares allotted under the purported preferential allotment are not transferred within one year from the date of the allotment. Therefore, it was observed that such transfer of shares in violation of regulation 78(2) of ICDR Regulations was in connivance with Kelvin and its these three directors.

29. It was further observed from the shareholding pattern filed by Kelvin with BSE for quarters ending June 30, 2012 and September 30, 2012, that the promoters of Kelvin were holding 7,43,800 shares, i.e. 5.31% of its share capital, as on June 30, 2012, which decreased to 0.01% of the share capital of Kelvin during the quarter ended September 30, 2012. However, from the data regarding transactions in Kelvin as shared by Purva Sharegistry it was noted that three promoters of Kelvin viz. Keyur M. Shah, Kavita Shah and Keyur M. Shah HUF transferred a total of 7,11,050 shares (5% of the share capital of Kelvin) to five other entities of the Kelvin Fincap Group on April 07, 2012 and April 14, 2012. Keyur M. Shah had further transferred 25,750 shares to Abhishek N Shah on January 15, 2013. All such transfers were off-market transfers involving shares in physical form. The details of such transfers are as under:

Table 9: Off-Market Transactions by the Promoters Date Of Transferor Transferee Name Quantity Transaction Name Transferred 07/04/2012 Keyur M Shah Narendra R Shah HUF 50000 HUF 07/04/2012 Kavita K Shah Narendra R Shah 50000 07/04/2012 Kavita K Shah Geeta Narendra Shah 50000 07/04/2012 Kavita K Shah Abhishek N Shah 30000 07/04/2012 Keyur M Shah Narendra R Shah 200000 07/04/2012 Keyur M Shah Geeta Narendra Shah 50000 07/04/2012 Keyur M Shah Mahesh R Shah 70000 07/04/2012 Keyur M Shah Abhishek N Shah 40000 14/04/2012 Keyur M Shah Abhishek N Shah 41050 14/04/2012 Keyur M Shah Geeta Narendra Shah 50000 14/04/2012 Keyur M Shah Narendra R Shah 80000 15/01/2013 Keyur M Shah Abhishek N Shah 25750

30. However, the abovementioned transactions (for April 07, 2012 and April 14, 2012) were not disclosed in the shareholding pattern filed by Kelvin with BSE for the quarter ended June 30, 2012 as required under Clause 35 of the Listing Agreement. Further, the aforesaid promoters failed to disclose the above changes in their shareholding under the provisions of regulation 13(4A) of the SEBI (Prohibition of Insider Trading) Regulations, 1992, (hereinafter referred to as "PIT Regulations").

31. Apart from the above irregularities by Kelvin, it was observed that details of the Board of Directors of Kelvin as available on BSE and MCA websites are different. Mr. Mansukh Sanghvi, who is shown as a Managing Director of Kelvin on BSE website, is not shown in the list of directors disclosed on MCA website by Kelvin. Mr Mansukh Sanghvi is also the Authorized Signatory for Kelvin’s bank accounts with Axis Bank. Similarly, Surekhaben K Shah is not shown as a director on MCA website. However, as per annual report for FY 2011-12, she was non-executive independent director of Kelvin at the time of preferential allotment. The difference in details of directors as observed from disclosures available at BSE and MCA websites are given below:

Table 10: Details of Directors on MCA and BSE websites List of Directors (Source: MCA List of Directors (Source: BSE Website website as on April 25, 2014) as on April 25, 2014) Bhavik Satish Badani Mansukh Sanghvi Bipin Bhikhabhai Patel Bhavik Satish Badani Sushma Vimalkumar Raval Bipin Bhikhabhai Patel Mahendrabhai Sakalchand Shah Vishal Kumar Shah Surekhaben K Shah

32. Further, Kelvin has avoided SEBI's advices seeking information from it regarding its board of directors and above mentioned allotment, vide email dated May 22, 2014 and letter dated May 27, 2014. Therefore, all the above persons at Table 10 are considered to be in charge of affairs of Kelvin.

33. Although none of the directors have traded on their own account during the Examination Period, it is observed that most of them were not merely directors of Kelvin but were deeply connected with entities belonging to the Kelvin Fincap Group, who had traded in the scrip as described in preceding paragraphs. Details of their connection with the entities belonging to the Kelvin Fincap Group are as follows: Table 11: Connection with other Kelvin Fincap Group Entities Name of Director Connection with other Kelvin Fincap Group Entities Bhavik Satish Badani He is one of the directors of Cromakem Limited. Bipin Bhikhabhai Patel He shares common address with Mr. Jitendra Patel, director of RFL International Limited and Fast Track Entertainment Limited. Sushma Vimalkumar She is one of the directors of Millennum Cybertech Limited. Raval She also shares common address with Mr. Vimalkumar Sureshchandra Raval, Ms. Padmaben Jagdish Jani, Ms. Jalpa Mitesh Jani, Mr. Jagdish Jani (Director of Sapan Chemical Limited, Surya Mangal Media and Entertainment Pvt. Ltd. and Acil Cotton Limited) and Mr. Mitesh Jagdish Jani (Director of Novagold Petro-Resources Limited). Mahendrabhai He is one of the directors of Heema Infocom Limited and GFL Sakalchand Shah Financial India Limited. Vishal Kumar Shah He is one of the directors of Cornhill Trading Co. Pvt. Ltd., Earth Exim Limited and Do -Max Steel Limited.

34. I note from the above examination and the factors mentioned at Annexure A, that the entities belonging to the Kelvin Fincap Group are prima-facie related/connected with each other and with Kelvin.

35. I also note that during the Examination Period, the traded volume and the liquidity in the shares of Kelvin increased substantially only after the Kelvin Fincap Group started trading in the said shares. The Kelvin Fincap Group entities brought up the share price from ` 151.55 to almost ` 1070/- (adjusted)/ ` 535/- (unadjusted) through persistently matched trades within the group during the Examination Period. Also, the Kelvin Fincap Group entities continuously executed orders at a price above LTP leading to an artificial price rise. In my view, such a pattern of trading by placing buy orders at a price higher than the LTP is apparently against the accepted economic rationale that a buyer would always wish to purchase shares at the lowest available price. The modus operandi used by Kelvin Fincap Group to raise the price of the scrip and to create artificial volume is as under:

A. Kelvin issued 1,30,00,000 shares in physical form to 56 related entities on March 20, 2012. It made false disclosure about number of allottees to camouflage the issuance to more than 49 persons so as to avoid compliance of issuance of prospectus and detailed disclosures therein. It concealed the actual number of allottees. B. Thereafter, the shares of Kelvin were transferred among Kelvin Fincap Group entities in physical as well as dematerialized form after April 01, 2012. C. Suddenly after June 18, 2013, Kelvin Fincap Group entities started to trade heavily in Kelvin with huge trading volume concentration on BSE. D. Kelvin Fincap Group entities dealt amongst themselves in the market i.e. they were observed to be buying and selling shares amongst each other thereby creating artificial trading volume. Such artificial volume constituted almost 95.68% of the total market volume during the Examination Period. Sans these entities, the volume of trading in Kelvin was very low. E. Kelvin Fincap Group also significantly exerted an upward pressure on the price, an act inconsistent with normal buyer behaviour.

36. I further note that the sequence of events and pattern of transactions in this case prima facie indicate that Kelvin issued new shares to certain entities, which were subsequently transferred by these allottees to other Kelvin Fincap Group entities. The promoters of Kelvin viz. Keyur Shah, Kavita Shah and Keyur Shah HUF also transferred their shares off-market in physical form to other entities belonging to the Kelvin Fincap Group. Thereafter, the Kelvin Fincap Group entities by indulging in non-genuine trading amongst themselves through repeated and continuous substantial matched transactions in the illiquid scrip of Kelvin created artificial volumes in the scrip and manipulated its price. Such transactions were prima facie carried out for the sole or dominant purpose of creating artificial volumes in the scrip and manipulating its price by taking the scrip to entice trading therein at artificial price. The acts, omissions and conduct of the Kelvin Fincap Group as observed during preliminary examination prima facie fall in the definition of "fraud' under regulation 2(1) (c) of the SEBI(Prohibition of Fraudulent and Unfair Trade Practices Relating to Securities Market) Regulation 2003 (hereinafter referred to as "PFUTP Regulations") which reads as under:- “fraud” includes any act, expression, omission or concealment committed whether in a deceitful manner or not by a person or by any other person with his connivance or by his agent while dealing in securities in order to induce another person or his agent to deal in securities, whether or not there is any wrongful gain or avoidance of any loss, and shall also include— (1) a knowing misrepresentation of the truth or concealment of material fact in order that another person may act to his detriment; (2) a suggestion as to a fact which is not true by one who does not believe it to be true; (3) an active concealment of a fact by a person having knowledge or belief of the fact; (4) a promise made without any intention of performing it; (5) a representation made in a reckless and careless manner whether it be true or false; (6) any such act or omission as any other law specifically declares to be fraudulent, (7) deceptive behaviour by a person depriving another of informed consent or full participation, (8) a false statement made without reasonable ground for believing it to be true.

(9) the act of an issuer of securities giving out misinformation that affects the market price of the security, resulting in investors being effectively misled even though they did not rely on the statement itself or anything derived from it other than the market price." And “fraudulent” shall be construed accordingly;” 37. In view of the above, I am of the prima facie view that Kelvin Fincap Group entities adopted fraudulent device and artifice to defraud the genuine shareholders of Kelvin and have thus violated sections 12A (a) (b) and (c) of the SEBI Act, 1992 and regulations 3(a), (b), (c), (d), 4(1) and 4(2)(a), (b), (e) and (g) of the PFUTP Regulations which read as under: 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 – (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 there under;" PFUTP Regulations "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 securities listed or proposed to be listed in a recognized stock exchange, any manipulative or deceptive device or contrivance in contravention of the provisions of the Act or the rules or the regulations made there under; (c) employ any device, scheme or artifice to defraud in connection with dealing in or issue of securities which are listed or proposed to be listed on a recognized stock exchange; (d) engage in any act, practice, course of business which operates or would operate as fraud or deceit upon any person in connection with any dealing in or issue of securities which are listed or proposed to be listed on a recognized stock exchange in contravention of the provisions of the Act or the rules and the regulations made there under.” "4. Prohibition of manipulative, fraudulent and unfair trade practices (1) Without prejudice to the provisions of regulation 3, no person shall indulge in a fraudulent or an unfair trade practice in securities.

(2) Dealing in securities shall be deemed to be a fraudulent or an unfair trade practice if it involves fraud and may include all or any of the following, namely:- (a) indulging in an act which creates false or misleading appearance of trading in the securities market; (b) dealing in a security not intended to effect transfer of beneficial ownership but intended to operate only as a device to inflate, depress or cause fluctuations in the price of such security for wrongful gain or avoidance of loss; (c)…………………………………………………………………………………….. (d)…………………………………………………………………………………… (e) any act or omission amounting to manipulation of the price of a security; (f)…………………………………………………………………………………. (g) entering into a transaction in securities without intention of performing it or without intention of change of ownership of such security; 38. I further note that the shares of Kelvin were allotted to 56 entities. However, it appears that Kelvin concealed the actual number of allottees and prima facie made false disclosure in that regard to camouflage the issuance to more than 49 persons so as to avoid compliance of issuance of prospectus and detailed disclosures therein.

Such act omission and conduct, prima facie, apart from being fraudulent and in violation of the provisions of sections 12A (a) (b) and (c) of the SEBI Act, 1992, regulations 3(b), (c), (d) and 4(1) of the PFUTP Regulations were also in contravention of the provisions of sections 56, 60 and 73 read with section 67(3) of the Companies Act, 1956 and regulations 4(2), 5(1), 5(7), 6, 7, 25, 36, 37, 46, and 57 of ICDR Regulations. Even if the allotment in this case was a preferential allotment the Kelvin and its directors prima facie contravened the provisions of regulation 78(2) of the ICDR Regulations as they connived and allowed transfer of shares during the lock-in period of one year. Kelvin’s non-cooperative attitude during the Preliminary Examination further leads to these preliminary findings against it.

39. In this case, as observed hereinabove, the shareholding pattern filed by Kelvin with BSE for the quarter ended June 30, 2012 was incorrect. I am of the view that this act and omission of Kelvin is prima facie in violation of clause 35 of the Listing Agreement read with section 21 of the Securities Contracts (Regulation) Act, 1956 (hereinafter referred to as “SCRA”). Further, Keyur M. Shah, Keyur M Shah (HUF) and Kavita K Shah have failed to disclose changes in their shareholding to BSE and have thereby prima facie violated provisions of regulation 13(4A) of the PIT Regulations.

40. It is trite to say that SEBI is mandated to regulate activities in the securities market thereby encouraging transparent and fair practices by the market participants. The entities of Kelvin Fincap Group as stated in this order are prima facie found to be instrumental in manipulating trading in scrip of Kelvin by the intricate modus operandi. The acts, omissions and conduct of Kelvin and entities of the Kelvin Fincap Group as described above is prima facie inimical to the interests of participants in the securities market. It is noted that the entities of Kelvin Fincap Group have continued with their trading in the scrip in the same manner as discussed hereinabove even after the Examination Period. The price of the scrip Kelvin has further increased from `535/-to `599.50/- after the Examination Period (i.e. from May 30, 2014 to August 01, 2014) with an average volume of 14,223 shares. The Kelvin Fincap Group is still actively trading in the scrip by contributing 66% to gross market volume and 79.14% to total positive LTP contribution in the price of the scrip. Such trading and price rise is neither supported by fundamentals of Kelvin nor by any other factor including any corporate announcement by it during the post Examination Period, which may justify the kind of rise which the price of the scrip has gone through. If such concerted and prima facie fraudulent dealings in securities of an illiquid scrip as in this case are allowed to continue in the market, the same is fraught with danger of immense mischief and incalculable damage to the securities market besides undermining the confidence of the investors in the fairness and integrity of the market.

41. In this case, it has been observed that out of total contribution of Kelvin Fincap Group to the total purchase volume, positive LTP and new high price, Shortlisted Group of Kelvin Fincap Group has been observed to have contributed 83.27%, 82.17% and 83.09% of the total purchase volume, positive LTP and new high price respectively. Further, all directors including Mansukh Sanghvi and Surekhaben K Shah are prima facie liable for the acts, omissions and conduct of Kelvin as prima facie found in this case. I further note that promoters and some of the directors of Kelvin are part of the Shortlisted Group.

42. Apart from the above, I note that, as on August 11, 2014, the following entities of Kelvin Fincap Group which is prima facie found to have adopted fraudulent device and artifice, are holding substantial quantity of shares in Kelvin ( more than 1% of its share capital):-

Table 12: Kelvin Fincap Group Entities holding substantial shares in Kelvin S.No. PAN Name Shareholding No. % 1 AAACM0623J Inventure Finance Private Limited 1106112 3.95 2 ARYPS5993F Naresh Nagindas Shah 1009163 3.61 3 AAFCS2725Q Sapan Chemicals Limited 863281 3.08 4 AACCD7020L Do Max Steel Limited 757224 2.71 5 AATPD0728R Mukesh Nanubhai Desai 734527 2.62 6 AAACR9384B RFL International Limited 700602 2.50 7 ALZPB9604R Rupesh Balkrishna Bhoir 699902 2.50 8 AAJPB7775N Kavita Sunish Behl 675500 2.41 9 AMVPJ5720H Jalpa M Jani 630472 2.25 10 AKSPM3939N Kirti Kantilal Mehta 522345 1.87 11 AAOPS2033H Geeta Narendra Shah 400000 1.43 12 AADPS8752L Hasmukhlal Ramanlal Shah 391300 1.40 13 AIKPM4674N Shobhanaben N. Moradia 390750 1.40 14 AMTPM0749H Bharat N. Moradiya 390600 1.40 15 AEGPD4889J Vasantben Dhanjibhai Donda 385590 1.38 16 AIVPM3622K Mukesh N. Moradia 384160 1.37 17 AIVPM3623J Shehul V. Moradia 378377 1.35 18 ACXPP9049B Bhimjibhai D. Chanchapara 374950 1.34 19 AEIPD5332A Dhanjibhai S. Donda 366460 1.31 20 ACXPP9026C Vallabhbhai D. Sachapra 360900 1.29 21 AMTPM8714C Hiren Tulsibhai Moradia 339500 1.21 22 ACRPM4534E Rajesh Moradia 334900 1.20

23 AFMPB0449P Jayshree Shankar Bhosle 325847 1.16 24 AACCC0591P Cornhill Trading Company Pvt Ltd 316521 1.13 25 ALEPM6311R Dharmesh Tulsibhai Moradia 300000 1.07

43. The entities mentioned in the above table have either been alloted shares by way of further issue or have transacted in the scrip through off-market transfers amongst the entities of the Group as discussed hereinabove. These entities, by virtue of having sizeable holding (i.e. more than 1%) and being, prima facie, part of the scheme executed by Kelvin Fincap Group, have the potential of not only disturbing the market equillibrium but also inducing the gullible investors to buy their holding at the artificially raised price.

44. Considering the above facts and circumstances, I am of the view that an urgent preventive and remedial action needs to be taken by way of ad interim ex-parte order in this case, during pendency of investigation in the matter.

45. I, therefore, in order to protect the interest of the investors and the integrity of the securities market, in exercise of the powers conferred upon me in terms of section 19 read with section 11(1), section 11 (4) (b) and section 11B of the SEBI Act, 1992 and section 12A of the SCRA, pending investigation and passing of final order, hereby issue following directions, by way of this ad-interim ex-parte order:

a) The following entities are restrained from accessing the securities market and further prohibited from buying, selling or dealing in the securities markets, either directly or indirectly, in any manner whatsoever, till further directions: Sl. Name of the entity PAN No. 1 Kelvin Fincap Limited AAACD1881H 2 Keyur M Shah AAHPS4084K 3 Keyur M Shah (HUF) AAAHK5034L 4 Kavita K Shah AAYPS3458E 5 Dahyabhai Shares And Stock Brokers Ltd AAACD1880G 6 Bhavik Satish Badani ALRPB9295L 7 Bipin Bhikhabhai Patel AIDPP3653M 8 Sushma Vimalkumar Raval BBPPE7839K 9 Mahendrabhai Sakalchand Shah AJMPS0962J 10 Mansukh Sanghvi ABJPS8618E 11 Vishal Kumar Shah AYBPS0534J 12 Surekhaben K Shah BORPS0804Q 13 Cromakem Limited AAECC0841Q

14 Do Max Steel Limited AACCD7020L 15 Stardom Trading Company Pvt Ltd AAHCS1332H 16 Sapan Chemicals Limited AAFCS2725Q 17 Fast Track Entertainment Limited AAACF7961Q 18 Cornhill Trading Company Pvt Ltd AACCC0591P 19 Sonal International Ltd AACCS1185R 20 Jalpa Jani AMVPJ5720H 21 Kirti Mehta AKSPM3939N 22 Jayshree Shankar Bhosle AFMPB0449P 23 Nova Gold Petro Resources Limited A A A CO2454R 24 Acil Cotton Industries Limited AABCA7788F 25 Zimig Trading Company Private Limited A A A C Z6848C 26 Inventure Finance Private Limited AAACM0623J 27 Naresh Nagindas Shah ARYPS5993F 28 Mukesh Nanubhai Desai AATPD0728R 29 RFL International Limited AAACR9384B 30 Rupesh Balkrishna Bhoir ALZPB9604R 31 Kavita Sunish Behl AAJPB7775N 32 Geeta Narendra Shah AAOPS2033H 33 Hasmukhlal Ramanlal Shah AADPS8752L 34 Shobhanaben N. Moradia AIKPM4674N 35 Bharat N. Moradiya AMTPM0749H 36 Vasantben Dhanjibhai Donda AEGPD4889J 37 Mukesh N. Moradia AIVPM3622K 38 Shehul V. Moradia AIVPM3623J 39 Bhimjibhai D. Chanchapara ACXPP9049B 40 Dhanjibhai S. Donda AEIPD5332A 41 Vallabhbhai D. Sachapra ACXPP9026C 42 Hiren Tulsibhai Moradia AMTPM8714C 43 Rajesh Moradia ACRPM4534E 44 Dharmesh Tulsibhai Moradia ALEPM6311R b) Kelvin Fincap Limited (PAN: AAACD1881H) is restrained from raising further capital, either directly or indirectly, in any manner whatsoever, till further directions.

46. SEBI reserves right to proceed against other entities of Kelvin Fincap Group at any stage of the investigation or thereafter. The persons/entities against whom this order is passed may file their replies, if any, to SEBI within 21 days from the date of receipt of this order, if they so desire, avail an opportunity of personal hearing on a date, place and time fixed in that regard by Securities and Exchange Board of India.

47. This order is without prejudice to the right of SEBI to take any other action that may be initiated against the aforementioned entities, mentioned in para 40 above, in accordance with law.

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

DATE: AUGUST 14th, 2014 RAJEEV KUMAR AGARWAL PLACE: MUMBAI WHOLE TIME MEMBER SECURITIES AND EXCHANGE BOARD OF INDIA

ANNEXURE - A S. PAN Name Basis of Relationship No. 1 AAACD1880G Dhayhabhai Shares 1. The entity is the promoter of Kelvin Fincap Limited and Stock Brokers ("Kelvin") as on June 30, 2014 as per BSE website. Pvt. Ltd. 2. The entity has received `25,000 from Cromakem Limited on 12/05/2012. 2 AAHPS4084K Keyur M Shah 1. The entity is director of Dhayhabhai Shares and Stock Brokers Pvt. Ltd and was promoter of Kelvin as per shareholding pattern on BSE website quarter ending December 31, 2012. 2. The entity transferred shares to Mr. Narendra R Shah, Mr. Mahesh R Shah, Mr. Abhishek N Shah and Ms. Geeta N Shah in physical form. 3 AAAHK5034L Keyur M Shah 1. The entity is an HUF with Keyur M Shah as the karta and (HUF) was the promoter of Kelvin as on March 31, 2012 as per BSE website. 2. The entity transferred 50,000 shares to Narendra R Shah (HUF) in physical form on 07/04/2012. 4 AAYPS3458E Kavita K Shah 1. The entity is director of Dhayhabhai Shares and Stock Brokers Pvt. Ltd and was promoter of Kelvin as per shareholding pattern on BSE website for quarter ending December 31, 2012. She also shares common address with Keyur M Shah viz, 22 / 23, Purab Apartment, 42, B. G. Kher Marg, Malbar Hill Mumbai 400006. 2. The entity transferred shares to Mr. Narendra R Shah, Mr. Abhishek N Shah and Ms. Geeta N Shah in physical form, on 07/04/2012.

5 ALRPB9295L Bhavik Satish 1. The entity is director of Kelvin as per MCA and BSE Badani websites 2. The entity is one of the directors of Cromakem Limited. 6 AIDPP3653M Bipin Bhikhabhai 1. The entity is one of the directors of Kelvin as per MCA and Patel BSE website. 2. The entity shares common address, viz. 401 B-28, Shanti Nagar Co. Op. Hsg. Ltd. Shanti, Nagar, Sec - 7, Above Indra Hospital, Mira Road, Mumbai, 401107, with Mr. Jitendra Patel (director of RFL International Limited and Fast Track Entertainment Limited). 7 BBPPE7839K Sushma 1. The entity is one of the directors of Kelvin as per MCA Vimalkumar Raval website. 2. The entity is also the director of Millennum Cybertech Limited. 3. The entity shares common address, viz. 23 Shri Ram Vihar Rokadia Lane, Borivali West, Mumbai, 400092, with Mr. Vimalkumar Sureshchandra Raval, Ms. Padmaben Jagdish Jani, Ms. Jalpa Mitesh Jani, Mr. Jagdish Jani (Director of Sapan Chemical Limited, Surya Mangal Media and Entertainment Pvt. Ltd. and Acil Cotton Limited) and Mr. Mitesh Jagdish Jani (Director of Novagold Petro-Resources Limited).

8 AJMPS0962J Mahendrabhai 1. The entity one of the directors of Kelvin as per MCA Sakalchand Shah Website. 2. The entity is also a director of Heema Infocom Limited and GFL Financial India Limited. 9 AYBPS0534J Vishal Kumar Shah 1. The entity is one of the directors of Kelvin as per BSE website. 2. The entity is one of the directors of Cornhill Trading Co. Pvt. Ltd., Earth Exim Limited and Do Max Steel Limited. 10 AAECC0841Q Cromakem Limited 1. Mr. Bhavik Satish Badani is one of the directors of Kelvin and Cromakem Limited. 2. Narendra Ramanlal Shah and Cromakem Limited share common address, viz. 24, jalaram Nagar, opp.chamunda Circle, ganjawala Lane,Borivali(w), Mumbai, Maharashtra - 400092. 3. Ms. Pallavi Chetan Pandit is one of the directors of Cornhill Trading Co. Pvt. Ltd, Cromakem Limited, Sonal International Limited, Stardom Trading Co. Pvt. Ltd. and IFSL Limited 4. Mr. Jayshree Shankar Bhosle, Heema Infocom Limited, Do Max Steel Limited, Suryamangal Media And Entertainment Limited, Cornhill Trading Company Pvt Ltd, Sapan Chemicals Limited, Ms. Padmaben Jagdish Jani, Ms. Jalpa Mitesh Jani, Cromakem Limited, Acil Cotton Industries Limited, Mr. Rupesh Balkrishna Bhoir, Mr. Chirag Dineshkumar Shah, Mr. Namdeo Shantaram Gole, Ms. Varsha Praful Trivedi, Mr. Mahesh Ramanlal Shah, Ms. Geeta Narendra Shah, Zimig Trading Company Private Limited and Mr. Parag Chandrkant Shah share common e-mail ID 'NOVAGOLD2007@YAHOO.CO.IN'.

5. The entity received/transfered funds from/to SDFC Finance Limited and Kosha Cubidor Containers Limited. 11 AACCD7020L Do Max Steel 1. The entity shares common director viz, Mr. Vishal Kumar Limited S hah, with Kelvin, Cornhill Trading Co. Pvt. Ltd. and Earth Exim Limited. 2. Mr. Jayshree Shankar Bhosle, Heema Infocom Limited, Do Max Steel Limited, Suryamangal Media And Entertainment Limited, Cornhill Trading Company Pvt Ltd, Sapan Chemicals Limited, Ms. Padmaben Jagdish Jani, Ms. Jalpa Mitesh Jani, Cromakem Limited, Acil Cotton Industries Limited, Mr. Rupesh Balkrishna Bhoir, Mr. Chirag Dineshkumar Shah, Mr. Namdeo Shantaram Gole, Ms. Varsha Praful Trivedi, Mr. Mahesh Ramanlal Shah, Ms. Geeta Narendra Shah, Zimig Trading Company Private Limited and Mr. Parag Chandrkant Shah share common e-mail ID 'NOVAGOLD2007@YAHOO.CO.IN'. 12 AAHCS1332H Stardom Trading 1. Cornhill Trading Company Pvt Ltd, Stardom Trading Company Pvt Ltd Company Pvt Ltd and Acil Cotton Industries Limited share common address, viz. 38, Ganga Vihar, 3rd Floor, Rokadia Lane, Borivali (w), Mumbai, Maharashtra - 400092. 2. Ms. Pallavi Chetan Pandit is one of the directors of Cornhill Trading Co. Pvt. Ltd, Cromakem Limited, Sonal International Limited, Stardom Trading Co. Pvt. Ltd. and IFSL Limited.

3. Cornhill Trading Company Pvt Ltd, Earth Exim Ltd, Stardom Trading Company Pvt Ltd, Mr. Rupesh Balkrishna Bhoir, Fast Track Entertainment Limited and Mr. Chirag Dineshkumar Shah, share common e-mail ID 'NOVAGOLD2011@GMAIL.COM'. 13 AAFCS2725Q Sapan Chemicals 1. Earth Exim Ltd, Ms. Geeta N Shah, Sapan Chemicals Limited Limited and Mr. Narendra Ramanlal Shah share common address, viz. 23 Jalaram Nagar Nr. Chamunda Circle Gajawala Lane Borivli West, Mumbai, Maharashtra - 400092. 2. Ms.Sushma Vimalkumar Raval (Director of Kelvin as per MCA website), Mr. Vimalkumar Sureshchandra Raval, Ms. Padmaben Jagdish Jani, Ms. Jalpa Mitesh Jani, Mr. Jagdish Jani (Director of Sapan Chemical Limited, Surya Mangal Media and Entertainment Pvt. Ltd. and Acil Cotton Limited) and Mr. Mitesh Jagdish Jani (Director of Novagold Petro- Resources Limited) share common address, viz. 23 Shri Ram Vihar Rokadia Lane, Borivali West, Mumbai, 400092. 3. Mr. Jayshree Shankar Bhosle, Heema Infocom Limited, Do Max Steel Limited, Suryamangal Media And Entertainment Limited, Cornhill Trading Company Pvt Ltd, Sapan Chemicals Limited, Ms. Padmaben Jagdish Jani, Ms. Jalpa Mitesh Jani, Cromakem Limited, Acil Cotton Industries Limited, Mr. Rupesh Balkrishna Bhoir, Mr. Chirag Dineshkumar Shah, Mr. Namdeo Shantaram Gole, Ms. Varsha Praful Trivedi, Mr. Mahesh Ramanlal Shah, Ms. Geeta Narendra Shah, Zimig Trading Company Private Limited and Mr. Parag Chandrkant Shah share common e-mail ID 'NOVAGOLD2007@YAHOO.CO.IN'. 4. Jaishree Shankar Bhosle is the promoter of Sapan Chemical Limited, as per BSE website. 14 AAACF7961Q Fast Track 1. Director of Fast Track Entertainment Limited and RFL Entertainment International Limited (Jitendra Patel) share same address with Limited the Director of Kelvin, Mr. Bipin Patel, viz. 401 B-28, Shanti Nagar Co. Op. Hsg. Ltd. Shanti, Nagar, Sec - 7,Above Indra Hospital, Mira Road, Mumbai, 401107. 2. Acil Cotton Industries Limited and Fast Track Entertainment Limited share common address, viz. B-7/404 A, Natraj Township Part-ii, near Parshuram Nagar Society, Sayaji Ganj, Vadodara, Gujarat - 390005. 3. Cornhill Trading Company Pvt Ltd, Earth Exim Ltd, Stardom Trading Company Pvt Ltd, Mr. Rupesh Balkrishna Bhoir, Fast Track Entertainment Limited and Mr. Chirag Dineshkumar Shah, share common e-mail ID 'NOVAGOLD2011@GMAIL.COM'.

15 AACCC0591P Cornhill Trading 1. Mr. Vishal Kumar Shah is one of the director of Kelvin, Company Pvt Ltd Cornhill Trading Co. Pvt. Ltd., Earth Exim Limited and Do Max steel limited. 2. Universal Credit and Securities Limited, Suryamangal Media And Entertainment Limited, Cornhill Trading Company Pvt Ltd and Gfl Financials India Limited share common address, viz. 15 Shriram Vihar, Rokadia Lane, Borivali (w), Mumbai, Maharashtra, India, 400092. 3. Cornhill Trading Company Pvt Ltd, Stardom Trading Company Pvt Ltd and Acil Cotton Industries Limited share common address, viz. 38, Ganga Vihar, 3rd Floor, Rokadia Lane, Borivali (w), Mumbai, Maharashtra, India, 400092. 4. Ms. Pallavi Chetan Pandit is one of the directors of Cornhill Trading Co. Pvt. Ltd, Cromakem Limited, Sonal International Limited, Stardom Trading Co. Pvt. Ltd. and IFSL Limited. 5. Mr. Jayshree Shankar Bhosle, Heema Infocom Limited, Do Max Steel Limited, Suryamangal Media And Entertainment Limited, Cornhill Trading Company Pvt Ltd, Sapan Chemicals Limited, Ms. Padmaben Jagdish Jani, Ms. Jalpa Mitesh Jani, Cromakem Limited, Acil Cotton Industries Limited, Mr. Rupesh Balkrishna Bhoir, Mr. Chirag Dineshkumar Shah, Mr. Namdeo Shantaram Gole, Ms. Varsha Praful Trivedi, Mr. Mahesh Ramanlal Shah, Ms. Geeta Narendra Shah, Zimig Trading Company Private Limited and Mr. Parag Chandrkant Shah share common e-mail ID 'NOVAGOLD2007@YAHOO.CO.IN'.

6. Cornhill Trading Company Pvt Ltd, Earth Exim Ltd, Stardom Trading Company Pvt Ltd, Mr. Rupesh Balkrishna Bhoir, Fast Track Entertainment Limited and Mr. Chirag Dineshkumar Shah, share common e-mail ID 'NOVAGOLD2011@GMAIL.COM'. 16 AACCS1185R Sonal International 1. Ms. Pallavi Chetan Pandit is one of the directors of Cornhill Ltd Trading Co. Pvt. Ltd, Cromakem Limited, Sonal International Limited, Stardom Trading Co. Pvt. Ltd. and IFSL Limited. 2. Sonal International Ltd and RFL International Limited share common address, viz. 304, Akruti Complex,nr.stadium Six Cross Road, Navrangpura, Ahmedabad, Gujarat, India, 380009. 17 AAACO2454R Nova Gold Petro 1. Ms. Sushma Vimalkumar Raval (Director of Kelvin as per Resources Limited M C A website), Mr. Vimalkumar Sureshchandra Raval, Ms. Padmaben Jagdish Jani, Ms. Jalpa Mitesh Jani, Mr. Jagdish Jani (Director of Sapan Chemical Limited, Surya Mangal Media and Entertainment Pvt. Ltd. and Acil Cotton Limited) and Mr. Mitesh Jagdish Jani (Director of Novagold Petro- Resources Limited) share common address, viz. 23 Shri Ram Vihar Rokadia Lane, Borivali West, Mumbai, 400092, Maharashtra, India.

2. The entity received ` 25,00,000 from Cromakem Ltd on 20/11/2013 18 AAACI4383H IFSL Limited  M s. P a l l a v i Chetan Pandit is one of the directors of Cornhill Trading Co. Pvt. Ltd, Cromakem Limited, Sonal International Limited, Stardom Trading Co. Pvt. Ltd. and IFSL Limited

19 AABCA7788F Acil Cotton 1. Cornhill Trading Company Pvt Ltd, Stardom Trading Industries Limited C o m pany Pvt Ltd and Acil Cotton Industries Limited share common address, viz. 38, Ganga Vihar, 3rd Floor, Rokadia Lane, Borivali (w), Mumbai, Maharashtra, India, 400092. 2. Acil Cotton Industries Limited and Fast Track Entertainment Limited share common address, viz. B-7/404 A, Natraj Township Part-ii,near Parshuram Nagar Society, Sayaji Ganj, Vadodara, Gujarat, India, 390005. 3. Ms. Sushma Vimalkumar Raval (Director of Kelvin as per MCA website), Mr. Vimalkumar Sureshchandra Raval, Ms. Padmaben Jagdish Jani, Ms. Jalpa Mitesh Jani, Mr. Jagdish Jani (Director of Sapan Chemical Limited, Surya Mangal Media and Entertainment Pvt. Ltd. and Acil Cotton Limited) and Mr. Mitesh Jagdish Jani (Director of Novagold Petro- Resources Limited) share common address, viz. 23 Shri Ram Vihar Rokadia Lane, Borivali West, Mumbai, 400092. 4. Mr. Jayshree Shankar Bhosle, Heema Infocom Limited, Do Max Steel Limited, Suryamangal Media And Entertainment Limited, Cornhill Trading Company Pvt Ltd, Sapan Chemicals Limited, Ms. Padmaben Jagdish Jani, Ms. Jalpa Mitesh Jani, Cromakem Limited, Acil Cotton Industries Limited, Mr. Rupesh Balkrishna Bhoir, Mr. Chirag Dineshkumar Shah, Mr. Namdeo Shantaram Gole, Ms. Varsha Praful Trivedi, Mr. Mahesh Ramanlal Shah, Ms. Geeta Narendra Shah, Zimig Trading Company Private Limited and Mr. Parag Chandrkant Shah share common e-mail ID 'NOVAGOLD2007@YAHOO.CO.IN'.

5. Vimalkumar Raval is one of the directors of Zimig Trading Pvt. Ltd. and Acil Cotton Industries Limited. 20 AAACZ6848C Zimig Trading 1. Mr. Jayshree Shankar Bhosle, Heema Infocom Limited, Do Company Private Max Steel Limited, Suryamangal Media And Entertainment Limited Limited, Cornhill Trading Company Pvt Ltd, Sapan Chemicals Limited, Ms. Padmaben Jagdish Jani, Ms. Jalpa Mitesh Jani, Cromakem Limited, Acil Cotton Industries Limited, Mr. Rupesh Balkrishna Bhoir, Mr. Chirag Dineshkumar Shah, Mr. Namdeo Shantaram Gole, Ms. Varsha Praful Trivedi, Mr. Mahesh Ramanlal Shah, Ms. Geeta Narendra Shah, Zimig Trading Company Private Limited and Mr. Parag Chandrkant Shah share common e-mail ID 'NOVAGOLD2007@YAHOO.CO.IN'. 2. Vimalkumar Raval is one of the directors of Zimig Trading Pvt. Ltd. and Acil Cotton Industries Limited. 21 AAHCS4914K Suryamangal Media 1. The entity is one of the preferential allottees. & Entertainment Ltd 2. Universal Credit and Securities Limited, Suryamangal Media And Entertainment Limited, Cornhill Trading Company Pvt Ltd and Gfl Financials India Limited share common address, viz. 15 Shriram Vihar, Rokadia Lane, Borivali (w), Mumbai, Maharashtra, India, 400092.

22 AABCE3676Q Earth Exim Ltd 1. Mr. Vishal Kumar Shah is one of the directors of Kelvin, Cornhill Trading Co. Pvt. Ltd., Earth Exim Limited and Do Max Steel Limited. 2. Earth Exim Ltd, Ms. Geeta N Shah, Sapan Chemicals Limited and Mr. Narendra Ramanlal Shah share common address, viz. 23 Jalaram Nagar Nr. Chamunda Circle Gajawala Lane Borivli West, Mumbai, Maharashtra, India, 400092. 3. Mr. Narendra R Shah is one of the directors of Earth Exim Limited and Universal Credit and Securities Limited. 4. Cornhill Trading Company Pvt Ltd, Earth Exim Ltd, Stardom Trading Company Pvt Ltd, Mr. Rupesh Balkrishna Bhoir, Fast Track Entertainment Limited and Mr. Chirag Dineshkumar Shah, share common e-mail ID 'NOVAGOLD2011@GMAIL.COM'. 23 AADCH2621N Heema Infocom 1. Mr. Mahendrabhai Sakalchand Shah is one of the directors of Limited Kelvin, Heema Infocom Limited and GFL Financials India Limited. 2. Mr. Jayshree Shankar Bhosle, Heema Infocom Limited, Do Max Steel Limited, Suryamangal Media And Entertainment Limited, Cornhill Trading Company Pvt Ltd, Sapan Chemicals Limited, Ms. Padmaben Jagdish Jani, Ms. Jalpa Mitesh Jani, Cromakem Limited, Acil Cotton Industries Limited, Mr. Rupesh Balkrishna Bhoir, Mr. Chirag Dineshkumar Shah, Mr. Namdeo Shantaram Gole, Ms. Varsha Praful Trivedi, Mr. Mahesh Ramanlal Shah, Ms. Geeta Narendra Shah, Zimig Trading Company Private Limited and Mr. Parag Chandrkant Shah share common e-mail ID 'NOVAGOLD2007@YAHOO.CO.IN'.

24 AABCG0597Q GFL Financial 1. The entity is one of preferential allottees of Kelvin. India Ltd 2. Mr. Mahendrabhai Sakalchand Shah is one of the directors of Kelvin, Heema Infocom Limited and GFL Financials India Limited. 3. Universal Credit and Securities Limited, Suryamangal Media And Entertainment Limited, Cornhill Trading Company Pvt Ltd and GFL Financials India Limited share common address, viz. 15 Shriram Vihar, Rokadia Lane, Borivali (w), Mumbai, Maharashtra, India, 400092. 25 AAACR9384B RFL International 1. Director of Fast Track Entertainment Limited and RFL Limited. International Limited (Jitendra Patel) share same address with the Director of Kelvin, Mr. Bipin Patel, viz. 401 B-28, Shanti Nagar Co. Op. Hsg. Ltd. Shanti, Nagar, Sec - 7,Above Indra Hospital, Mira Road, Mumbai, 401107, Maharashtra, India. 2. Sonal International Ltd and RFL International Limited share common address, viz. 304, Akruti Complex,nr.stadium Six Cross Road, Navrangpura, Ahmedabad, Gujarat, India, 380009. 26 AABCM8712D Millennum Ms. Sushma Vimalkumar Raval is one of the directors of Kelvin Cybertech Ltd and Millennium Cybertech Limited.

27 AAACU2627G Universal Credit 1. Mr. Narendra R Shah is one of the directors of Earth Exim And Securities Ltd Limited and Universal Credit and Securities Limited. 2. Universal Credit and Securities Limited, Suryamangal Media And Entertainment Limited, Cornhill Trading Company Pvt Ltd and Gfl Financials India Limited share common address, viz. 15 Shriram Vihar, Rokadia Lane, Borivali (w), Mumbai, Maharashtra, India, 400092. 28 AADCS2886E SDFC Finance Ltd  The entity received/transferred funds from/to Kelvin and Cromakem. 29 AAACK6201G Kosha Cubidor  The entity received/transferred funds from/to Cromakem. Containers Ltd 30 AAOPS2034A Mahesh Ramanlal 1. The entity is one of the directors of Sapan Chemical Limited. Shah 2. The entity received shares from Keyur M Shah, promoter of Kelvin till December 31, 2012, in physical form. 3. Ms. Geeta Narendra Shah, Mr. Narendra Ramanlal Shah, Mr. Mahesh Ramanlal Shah and Mr. Abhishek Narendra Shah share common address, viz. D-28-205 Yogi Nagar Borivali West Mumbai. 4. Mr. Jayshree Shankar Bhosle, Heema Infocom Limited, Do Max Steel Limited, Suryamangal Media And Entertainment Limited, Cornhill Trading Company Pvt Ltd, Sapan Chemicals Limited, Ms. Padmaben Jagdish Jani, Ms. Jalpa Mitesh Jani, Cromakem Limited, Acil Cotton Industries Limited, Mr. Rupesh Balkrishna Bhoir, Mr. Chirag Dineshkumar Shah, Mr. Namdeo Shantaram Gole, Ms. Varsha Praful Trivedi, Mr. Mahesh Ramanlal Shah, Ms. Geeta Narendra Shah, Zimig Trading Company Private Limited and Mr. Parag Chandrkant Shah share common e-mail ID 'NOVAGOLD2007@YAHOO.CO.IN'.

31 ANIPR5608Q Vimalkumar 1. Ms. Sushma Vimalkumar Raval (Director of Kelvin as per Sureshchandra MCA website), Mr. Vimalkumar Sureshchandra Raval, Ms. Raval Padmaben Jagdish Jani, Ms. Jalpa Mitesh Jani, Mr. Jagdish Jani (Director of Sapan Chemical Limited, Surya Mangal Media and Entertainment Pvt. Ltd. and Acil Cotton Limited) and Mr. Mitesh Jagdish Jani (Director of Novagold Petro- Resources Limited) share common address, viz. 23 Shri Ram Vihar Rokadia Lane, Borivali West, Mumbai, 400092. 2. Vimalkumar Sureshchandra Raval is one of the directors of Zimig Trading Pvt. Ltd. and Acil Cotton Industries Limited. 32 ARYPS5993F Naresh Nagindas The entity is director of GFL Financial India Limited. Shah 33 AAPPS6559P Narendra Shah 1. The entity received shares from Keyur M Shah and Kavita K Shah, promoters of Kelvin till December 31, 2012, in physical form. 2. Ms. Geeta Narendra Shah, Mr. Narendra Ramanlal Shah, Mr. Mahesh Ramanlal Shah and Mr. Abhishek Narendra Shah share common address, viz. D-28-205 Yogi Nagar Borivali West Mumbai. 3. Earth Exim Ltd, Ms. Geeta N Shah, Sapan Chemicals Limited and Mr. Narendra Ramanlal Shah share common address, viz. 23 Jalaram Nagar Nr.

Chamunda Circle Gajawala Lane Borivli West, Mumbai, Maharashtra, India, 400092. 4. Mr. Narendra R Shah is one of the directors of Earth Exim Limited and Universal Credit and Securities Limited.

5. Narendra Ramanlal Shah and Cromakem Limited share common address, viz. 24,jalaram Nagar,opp.chamunda Circle,gemjawala Lane, Borivali(w), Mumbai Maharashtra, India, 400092. 34 AAAHN2023C Narendra R Shah 1. The entity is HUF of Narendra R Shah. (HUF) 2. The entity received 50,000 shares from Keyur M Shah (HUF), promoter of Kelvin, in physical form, on 07/04/2012. 35 AAOPS2033H Geeta Narendra 1. The entity received shares from Keyur M Shah and Kavita K Shah Shah, promoter of Kelvin till December 31, 2012, in physical form. 2. Ms. Geeta Narendra Shah, Mr. Narendra Ramanlal Shah, Mr. Mahesh Ramanlal Shah and Mr. Abhishek Narendra Shah share common address, viz. D-28-205 Yogi Nagar Borivali West Mumbai. 3. Earth Exim Ltd, Ms. Geeta N Shah, Sapan Chemicals Limited and Mr. Narendra Ramanlal Shah share common address, viz. 23 Jalaram Nagar Nr. Chamunda Circle Gajawala Lane Borivli West, Mumbai, Maharashtra, India, 400092. 4. Mr. Jayshree Shankar Bhosle, Heema Infocom Limited, Do Max Steel Limited, Suryamangal Media And Entertainment Limited, Cornhill Trading Company Pvt Ltd, Sapan Chemicals Limited, Ms. Padmaben Jagdish Jani, Ms. Jalpa Mitesh Jani, Cromakem Limited, Acil Cotton Industries Limited, Mr. Rupesh Balkrishna Bhoir, Mr. Chirag Dineshkumar Shah, Mr. Namdeo Shantaram Gole, Ms. Varsha Praful Trivedi, Mr. Mahesh Ramanlal Shah, Ms. Geeta Narendra Shah, Zimig Trading Company Private Limited and Mr. Parag Chandrkant Shah share common e-mail ID 'NOVAGOLD2007@YAHOO.CO.IN'.

36 BFVPS2543P Abhishek N Shah 1. The entity received shares from Keyur M Shah and Kavita K Shah, promoter of Kelvin till January 15, 2013, in physical form. 2. Ms. Geeta Narendra Shah, Mr. Narendra Ramanlal Shah, Mr. Mahesh Ramanlal Shah and Mr. Abhishek Narendra Shah share common address, viz. D-28-205 Yogi Nagar Borivali West Mumbai. 37 ADQPJ5053P Padmaben Jagdish 1. Ms. Sushma Vimalkumar Raval (Director of Kelvin as per Jani MCA website), Mr. Vimalkumar Sureshchandra Raval, Ms. Padmaben Jagdish Jani, Ms. Jalpa Mitesh Jani, Mr. Jagdish Jani (Director of Sapan Chemical Limited, Surya Mangal Media and Entertainment Pvt. Ltd. and Acil Cotton Limited) and Mr. Mitesh Jagdish Jani (Director of Novagold Petro- Resources Limited) share common address, viz. 23 Shri Ram Vihar Rokadia Lane, Borivali West, Mumbai, 400092, Maharashtra, India. 2. Mr. Jayshree Shankar Bhosle, Heema Infocom Limited, Do Max Steel Limited, Suryamangal Media And Entertainment Limited, Cornhill Trading Company Pvt Ltd, Sapan Chemicals Limited, Ms. Padmaben Jagdish Jani, Ms. Jalpa Mitesh Jani, Cromakem Limited, Acil Cotton Industries Limited, Mr. Rupesh Balkrishna Bhoir, Mr. Chirag

Dineshkumar Shah, Mr. Namdeo Shantaram Gole, Ms. Varsha Praful Trivedi, Mr. Mahesh Ramanlal Shah, Ms. Geeta Narendra Shah, Zimig Trading Company Private Limited and Mr. Parag Chandrkant Shah share common e-mail ID 'NOVAGOLD2007@YAHOO.CO.IN'. 38 AMVPJ5720H Jalpa Jani 1. Ms. Sushma Vimalkumar Raval (Director of Kelvin as per MCA website), Mr. Vimalkumar Sureshchandra Raval, Ms. Padmaben Jagdish Jani, Ms. Jalpa Mitesh Jani, Mr. Jagdish Jani (Director of Sapan Chemical Limited, Surya Mangal Media and Entertainment Pvt. Ltd. and Acil Cotton Limited) and Mr. Mitesh Jagdish Jani (Director of Novagold Petro- Resources Limited) share common address, viz. 23 Shri Ram Vihar Rokadia Lane, Borivali West, Mumbai, 400092, Maharashtra, India. 2. Mr. Jayshree Shankar Bhosle, Heema Infocom Limited, Do Max Steel Limited, Suryamangal Media And Entertainment Limited, Cornhill Trading Company Pvt Ltd, Sapan Chemicals Limited, Ms. Padmaben Jagdish Jani, Ms. Jalpa Mitesh Jani, Cromakem Limited, Acil Cotton Industries Limited, Mr. Rupesh Balkrishna Bhoir, Mr. Chirag Dineshkumar Shah, Mr. Namdeo Shantaram Gole, Ms. Varsha Praful Trivedi, Mr. Mahesh Ramanlal Shah, Ms. Geeta Narendra Shah, Zimig Trading Company Private Limited and Mr. Parag Chandrkant Shah share common e-mail ID 'NOVAGOLD2007@YAHOO.CO.IN'.

39 AKSPM3939N Kirti Mehta As per the bank Account No. 911010005936771 of Kirti Mehta with Axis Bank Limited, the entity received/transferred funds from/to Kelvin, Cromakem Limited, Stardom Trading Co. Pvt. Ltd., Fast Track Entertainment Limited, Earth Exim Limited, Cornhill Trading Co. Pvt. Ltd., IFSL Limited, GFL Financial India Limited, Inventure Finance Pvt. Ltd., Sonal International Limited, Kosha Cubidor Containers Limited and Acil Cotton Industries Limited 40 AFMPB0449P Jayshree Shankar 1. Mr. Jayshree Shankar Bhosle, Heema Infocom Limited, Do Bhosle Max Steel Limited, Suryamangal Media And Entertainment Limited, Cornhill Trading Company Pvt Ltd, Sapan Chemicals Limited, Ms. Padmaben Jagdish Jani, Ms. Jalpa Mitesh Jani, Cromakem Limited, Acil Cotton Industries Limited, Mr. Rupesh Balkrishna Bhoir, Mr. Chirag Dineshkumar Shah, Mr. Namdeo Shantaram Gole, Ms. Varsha Praful Trivedi, Mr. Mahesh Ramanlal Shah, Ms. Geeta Narendra Shah, Zimig Trading Company Private Limited and Mr. Parag Chandrkant Shah share common e-mail ID 'NOVAGOLD2007@YAHOO.CO.IN'. 2. Jaishree Shankar Bhosle is the promoter of Sapan Chemical Limited, as per BSE website.

41 ALZPB9604R Rupesh Balkrishna Mr. Jayshree Shankar Bhosle, Heema Infocom Limited, Do Max Bhoir Steel Limited, Suryamangal Media And Entertainment Limited, Cornhill Trading Company Pvt Ltd, Sapan Chemicals Limited, Ms. Padmaben Jagdish Jani, Ms. Jalpa Mitesh Jani, Cromakem Limited, Acil Cotton Industries Limited, Mr. Rupesh Balkrishna Bhoir, Mr. Chirag Dineshkumar Shah, Mr. Namdeo Shantaram Gole, Ms. Varsha Praful Trivedi, Mr. Mahesh Ramanlal Shah, Ms. Geeta Narendra Shah, Zimig Trading Company Private Limited and Mr. Parag Chandrkant Shah share common e-mail ID 'NOVAGOLD2007@YAHOO.CO.IN'.

42 ARIPG5267E Gole Namdeo Mr. Jayshree Shankar Bhosle, Heema Infocom Limited, Do Max Shantaram Steel Limited, Suryamangal Media And Entertainment Limited, Cornhill Trading Company Pvt Ltd, Sapan Chemicals Limited, Ms. Padmaben Jagdish Jani, Ms. Jalpa Mitesh Jani, Cromakem Limited, Acil Cotton Industries Limited, Mr. Rupesh Balkrishna Bhoir, Mr. Chirag Dineshkumar Shah, Mr. Namdeo Shantaram Gole, Ms. Varsha Praful Trivedi, Mr. Mahesh Ramanlal Shah, Ms. Geeta Narendra Shah, Zimig Trading Company Private Limited and Mr. Parag Chandrkant Shah share common e-mail ID 'NOVAGOLD2007@YAHOO.CO.IN'. 43 CFPPS4835H Chirag Mr. Jayshree Shankar Bhosle, Heema Infocom Limited, Do Max Dineshkumar Shah Steel Limited, Suryamangal Media And Entertainment Limited, Cornhill Trading Company Pvt Ltd, Sapan Chemicals Limited, Ms. Padmaben Jagdish Jani, Ms. Jalpa Mitesh Jani, Cromakem Limited, Acil Cotton Industries Limited, Mr. Rupesh Balkrishna Bhoir, Mr. Chirag Dineshkumar Shah, Mr. Namdeo Shantaram Gole, Ms. Varsha Praful Trivedi, Mr. Mahesh Ramanlal Shah, Ms. Geeta Narendra Shah, Zimig Trading Company Private Limited and Mr. Parag Chandrkant Shah share common e-mail ID 'NOVAGOLD2007@YAHOO.CO.IN'.

44 ARRPS2518R Parag Chandrkant Mr. Jayshree Shankar Bhosle, Heema Infocom Limited, Do Max Shah Steel Limited, Suryamangal Media And Entertainment Limited, Cornhill Trading Company Pvt Ltd, Sapan Chemicals Limited, Ms. Padmaben Jagdish Jani, Ms. Jalpa Mitesh Jani, Cromakem Limited, Acil Cotton Industries Limited, Mr. Rupesh Balkrishna Bhoir, Mr. Chirag Dineshkumar Shah, Mr. Namdeo Shantaram Gole, Ms. Varsha Praful Trivedi, Mr. Mahesh Ramanlal Shah, Ms. Geeta Narendra Shah, Zimig Trading Company Private Limited and Mr. Parag Chandrkant Shah share common e-mail ID 'NOVAGOLD2007@YAHOO.CO.IN'. 45 ABBPT1431A Varsha Trivedi Mr. Jayshree Shankar Bhosle, Heema Infocom Limited, Do Max Steel Limited, Suryamangal Media And Entertainment Limited, Cornhill Trading Company Pvt Ltd, Sapan Chemicals Limited, Ms. Padmaben Jagdish Jani, Ms. Jalpa Mitesh Jani, Cromakem Limited, Acil Cotton Industries Limited, Mr. Rupesh Balkrishna Bhoir, Mr. Chirag Dineshkumar Shah, Mr. Namdeo Shantaram Gole, Ms. Varsha Praful Trivedi, Mr. Mahesh Ramanlal Shah, Ms. Geeta Narendra Shah, Zimig Trading Company Private Limited and Mr. Parag Chandrkant Shah share common e-mail ID 'NOVAGOLD2007@YAHOO.CO.IN'.

46 AMIPS6846A Zubin Kamlesh The entity is one of the preferential allottees. Shah 47 AAZPM0394A M.V.R.S Prasad The entity is one of the preferential allottees. 48 AAAHJ0191D Ashok Jashraj Jain The entity is one of the preferential allottees. HUF 49 AAIPS9404N Mithalal Manoharlal The entity is one of the preferential allottees. Sahlot 50 ACKPM8513A Champaben The entity is one of the preferential allottees. Devjibhai Makwana

51 AZTPM3476A Deepaben The entity is one of the preferential allottees. Trabakbhai Makwana 52 AAAPT3253A Jagdish Hari The entity is one of the preferential allottees. Thakur

53 AATPD0728R Mukesh N Desai The entity is one of the preferential allottees. 54 AAAPV4085A Rajesh Gopaldas The entity is one of the preferential allottees. Villaitramani 55 AAAPT6038P Kamlesh Hari The entity is one of the preferential allottees. Thakur 56 ACJPN8415H Prameela The entity is one of the preferential allottees. Mohandas 57 AABPK2469A Ashok Gopaldas The entity is one of the preferential allottees. Kripalani 58 AAEPT2433N Mrs. Lajwanti Hari The entity is one of the preferential allottees. Thakur 59 AAJPS0851L Mitesh Rajnikant The entity is one of the preferential allottees. Shah 60 AARPJ2757L Ramniranjan C The entity is one of the preferential allottees. Jhunjhunwala 61 AETPA7958N Prem Aggarwal T h e e n t ity is one of the preferential allottees. 62 AAFPS1767F Ketan The entity is one of the preferential allottees. Bhupendrakumar Shah 63 AACHM2754B Mukesh N Desai The entity is one of the preferential allottees. (HUF) 64 AHCPP2686C Poonam The entity is one of the preferential allottees. Pramesagar Pasricha 65 AAIHR3732E Ravi Sancheti 1. The entity is one of the preferential allottees. (HUF) 2. The entity transferred a total of 2,00,000 shares to Jitendra Tejmal Dugar and Dhiraj Parasmal Dugar in physical form. 66 AQQPS2059B Tasneem Iqbal The entity is one of the preferential allottees. Syed 67 ABEPN6198B N.Satyanarayana The entity is one of the preferential allottees. 68 ADXPD6143K Mrs.Bhavani The entity is one of the preferential allottees. Bharatbhai Danga 69 AGKPM6963C Jignasa Subhash The entity is one of the preferential allottees. Mithawalla 70 ACXPP9026C Vallabhbhai D The entity is one of the preferential allottees. Sachapara 71 AADPM3931D Subhash Tikamdas The entity is one of the preferential allottees. Mithawalla 72 ACXPP9049B B.D.Sachpara The entity is one of the preferential allottees. 73 AAACM0623J Inventure Finance 1. The entity is one of the preferential allottees. Private Ltd 2. The entity received `25,22,400 from Cromakem Limited on 13/03/2013. 74 AIVPM3623J Shehul Vallabhbhai The entity is one of the preferential allottees. Moradiya

75 AEIPD5332A Dhanjibhai The entity is one of the preferential allottees. Shamjibhai Donda 76 ACRPM4534E Rajesh Haribhai The entity is one of the preferential allottees. Moradia 77 AIVPM3622K Mukeshbhai The entity is one of the preferential allottees. Moradiya 78 AEGPD4889J Vasantben The entity is one of the preferential allottees. Dhanjibhai Donda 79 AMTPM8714C Hiren Tulsibhai The entity is one of the preferential allottees. Moradia 80 ADPPD5068B KRISHNA The entity is one of the preferential allottees. M.DAWDA 81 AIKPM4674N Shobhanaben The entity is one of the preferential allottees. Nareshbhai Mpradiya 82 AMTPM0749H Bharatbhai The entity is one of the preferential allottees. Nanjibhai Morada 83 AAJPB7775N Kavita Sunish Behl T h e e n t i t y i s o n e o f t h e preferential allottees. 84 AADPS8752L Hasmukhlal R.Shah The entity is one of the preferential allottees. 85 ABVPJ5592Q Sunita Dinesh 1. The entity is one of the preferential allottees of Kelvin. Jaiswal 2. The entity transferred 2,20,000 shares to Naresh Nagindas Shah on 12/8/2013 through off market transactions. 86 ABVPJ5571B Dinesh 1. The entity is one of the preferential allottees of Kelvin. Gangaprasad Jaiswal 2. The entity transferred 2,50,000 shares to Naresh Nagindas Shah on 12/8/2013 through off market transactions. 87 ALEPM6311R Dharmesh The entity is one of the preferential allottees. Tulsibhai Moradia 88 AFZPS4055B Falguni Ketan Shah 1. The entity shares common address with Ketan Shah, preferential allottee. 2. The entity received 1700 shares from Ketan Bhupendrakumar Shah on 6/11/2013 and transferred the same number of shares on 27/11/2013 through off market transactions 89 ABOPM3631N Banubibi Sarwar The entity received 3000 shares from Cornhill Trading Company Mohid Pvt Ltd on 26/6/2013 through off market transactions 90 ABOPM3630P Sarwar Abdulkadir The entity received 3000 shares from Cornhill Trading Company Mohid Pvt Ltd on 26/6/2013 through off market transactions

91 AABHM5423J Maheshwari The entity received 3000 shares and 5000 shares from Cornhill Omprakash Trading Company Pvt Ltd on 8/7/2013 and 16/7/2013 Basantilal (HUF) respectively and 2000 shares from Dadima Capital (P) Ltd on 19/11/2013 through off market transactions 92 AKXPR4288E S Rajesh The entity received 5000 shares from Cornhill Trading Company Pvt Ltd on 15/7/2013 through off market transactions 93 ABOPC2448M Anilbhai Devjibhai The entity received 14000 shares from Cornhill Trading Company Chauhan Pvt Ltd on 2/8/2013 and 5500 shares from Dadima Capital (P) Ltd on 4/9/2013 through off market transactions

94 AAVPU3814B Bharati Bharat The entity received 72600 shares from Cromakem Limited on Upadhyay 1/2/2014 through off market transactions and 67400 shares from Mukesh N Desai (HUF) on 16/11/2013 in physical form 95 AGSPD5628B Niranjanaben The entity received 4800 shares from Naresh Nagindas Shah on Ashwinkumar 5/3/2014 through off market transactions Desai 96 AAVPS2772G Haresh Rajmal The entity received 9100 shares from Naresh Nagindas Shah on Shah 5/11/2013 through off market transactions 97 AABHS8946N Sanjay Madanlal The entity received 10000 shares from Naresh Nagindas Shah on Sanghvi (HUF) 29/3/2014 through off market transactions

98 AAAPI4645P Dinesh Dhanjibhai The entity received 9000 shares from Naresh Nagindas Shah on Italia 5/11/2013 through off market transactions 99 AAGCR4662J Reachsmart The entity received 40000 shares from Naresh Nagindas Shah on Construction 24/1/2014 through off market transactions Private Limited. 100 AEQPS7882A Priti Vipul Shah The entity received 17400 shares from Naresh Nagindas Shah from 3/12/2013 to 16/1/2014 through off market transactions 101 AADPT0508R Rekha Manoj The entity received 15400 shares from Naresh Nagindas Shah on Thakkar 5/11/2013 through off market transactions 102 AAVPS6090F Mamta Mahesh The entity received 15200 shares from Naresh Nagindas Shah on Sanghavi 5/11/2013 through off market transactions 103 ABWPT3678G Chhaya Deepak The entity received 15400 shares from Naresh Nagindas Shah on Thakker 5/11/2013 through off market transactions 104 AABPS8536Q Chandrika The entity received 15300 shares from Naresh Nagindas Shah on Dharmendra 5/11/2013 through off market transactions Sanghavi 105 AMVPS6299J Geeta Bharat The entity received 15300 shares from Naresh Nagindas Shah on Sanghvi 5/11/2013 through off market transactions 106 BMMPS8777F Rushabh Vipul The entity received 13200 shares from Naresh Nagindas Shah Shah from 3/12/2013 to 21/1/2014 through off market transactions 107 ACQPS5671M Sanjay Madanlal The entity received 20000 shares from Naresh Nagindas Shah on Sanghvi 14/3/2014 through off market transactions

108 AXFPS1272E Seema Haresh Shah The entity received 9200 shares from Naresh Nagindas Shah on 5/11/2013 through off market transactions 109 ACNPS2202F Priti Sanjay Sanghvi The entity received 20000 shares from Naresh Nagindas Shah on 14/3/2014 through off market transactions 110 AFIPP4761L Dharmeshkumar The entity received 3200 shares each from Sonal International Ltd Vinodchandra Patel and Dadima Capital (P) Ltd. on 30/8/2013 through off market transactions 111 AABCD2140E Dadima Capital (P) Narendra R Shah is one of the directors of the entity. The entity Ltd received 1,50,000 shares from Stardom Trading Pvt. Ltd. On August 21, 2013 and 1,00,500 shares from Padmaben Jain on September 04, 2013 through off market transactions.

112 AHAPP5916H Jaswant Kantilal The entity transfered 11430 shares to Cornhill Trading Company Parmar Pvt Ltd from 7/4/2014 to 28/4/2014 and 5000 shares to Vijay Govindarajan on 11/4/2014 through off market transactions 113 AIOPG4980F Hiren Kirit Gandhi The entity transfered 2825 shares to Do Max Steel Limited on 30/4/2014 through off market transactions 114 AQQPG4855K Maruti Shankar The entity transfered 2130 shares to Dadima Capital (P) Ltd on Gaude 9/1/2014 and 85025 shares to Earth Exim Ltd. From 9/1/2014 to 6/5/2014 through off market transactions 115 AHNPD1452H Vidyadhar The entity transfered 4100 shares to Narendra Shah on Ramnaresh Dubey 2/11/2013, 5530 shares to Dadima Capital (P) Ltd on 9/1/2014 and 61460 shares to Sonal International Limited from 8/2/2014 to 5/3/2014 through off market transactions 116 BPLPR1372B Maheshbhai The entity transfered 39350 shares to Naresh Nagindas Shah on Chhanalal Raval 2/1/2014 through off market transactions

117 BPPPR0616L Amitkumar The entity transfered 29950 shares to Naresh Nagindas Shah on Maheshbhai Raval 2/1/2014 through off market transactions

118 AIYPD1020H Vinod Gajanan The entity transfered a total of 29925 shares to Naresh Nagindas Dhadave Shah on 13/3/2014, 27/3/2014 and 30/4/2014 through off market transactions 119 BINPP6932L Bharatkumar The entity transferred a total of 10,150 shares to Naresh Shah, Prahladbhai Sonalben Dhirenkumar Patel, Minaben Ambalal Patel, Ambalal Prajapati Ranchhodbhai Patel, Bhavika Jaykumar Patel And Keyur Babulal Patel during the period from 21/11/2013 to 6/3/2014. 120 AOYPM7851H Madhuben H Modi The entity transfered 2900 shares to Naresh Nagindas Shah on 5/3/2014 through off market transactions 121 AADPA1333M Hansaben The entity received 200000 shares from GFL Financial India Ltd Mahendra Amin o n 29/9/2012 in physical form 122 AABPA4050H Mahendra The entity received 200000 shares from GFL Financial India Ltd Dhanjibhai Amin o n 2 9/9/2012 in physical form 123 AABPD2576M Jitendra Tejmal The entity received 100000 shares from Ravi Sancheti (HUF) on Dugar 29/9/2012 in physical form 124 ADXPD9319B Dhiraj Parasmal The entity received 100000 shares from Ravi Sancheti (HUF) on Dugar 29/9/2012 in physical form 125 AAACU8715B Umang Projects The entity received 1,00,000 shares from Geeta Narendra Shah on Limited 30/4/2012 in physical form 126 AADCS7899F Solex Commercial The entity received 100000 shares from Narendra R Shah on & Credit Pvt.Ltd. 30/4/2012 in physical form

127 AAICS0162N Dukes Products The entity received 10000 shares from Geeta Narendra Shah on (India) Limited 30/4/2012 in physical form 128 AADCV0856B Viren Shelters The entity received 30000 shares from Abhishek N Shah and Limited 70,000 shares from Mahesh R Shah on 30/4/2012 in physical form 129 AABCA7142D Ankit Biscuits Pvt. The entity received 100000 shares from Narendra R Shah on Ltd. 30/4/2012 in physical form 130 AABCD4645E Dukes Consumer The entity received 50000 shares from Narendra R Shah (HUF) Care Limited and 50,000 shares from Narendra R Shah on 30/4/2012 in physical form

131 AAAHO2774F Omprakash The entity received 40000 shares from Abhishek N Shah on Agarwal (HUF) 30/4/2012 in physical form 132 ACLPA3472F Omprakash The entity received 40000 shares from Narendra R Shah on Agarwal 30/4/2012 in physical form 133 AFCPJ6983L Ruchit Hiralal Jain The entity received 15000 shares from Mukesh N Desai (HUF) on 25/7/2013 in physical form 134 ADSPA1892P Ajay Shridhar The entity received 15000 shares from Mukesh N Desai (HUF) on Acharya 25/7/2013 in physical form 135 AAAPJ9174C Champalal The entity received 15000 shares from Mukesh N Desai (HUF) on Mohanlalji Jain 25/7/2013 in physical form 136 ABOPG4132E Vikas Sarwankumar The entity received 30000 shares from Suryamangal Media & Gupta Entertainment Ltd on 6/7/2013 in physical form

137 AAGHM2012J Gopi Krishna The entity received 26500 shares from Mukesh N Desai (HUF) on Manepally (HUF) 14/12/2013 in physical form 138 AAGHM2011M Muralikrishna The entity received 26500 shares from Mukesh N Desai (HUF) on Manepally 14/12/2013 in physical form 139 ABLPJ0975H Premchand The entity received 30000 shares from Suryamangal Media & Gainchand Jain Entertainment Ltd on 29/6/2013 in physical form 140 AGJPA1748G Ankit Agarwal The entity received 120000 shares from Suryamangal Media & Entertainment Ltd on 29/6/2013 in physical form 141 CAJPS1111F Madhu K The entity received 22600 shares from Mukesh N Desai (HUF) on Shyamsukha 16/11/2013 in physical form 142 AJGPK7846K Nitin K Kagzi The entity received 5000 shares from Cromakem Limited on 31/10/2012 and 5,000 shares from Millennum Cybertech Limited on 4/5/2013 in physical form 143 AGKPB1054B Suraj Prakash The entity received 10000 shares from Suryamangal Media & Bhalla Entertainment Ltd on 25/7/2013 in physical form 144 AFCPB9484J Naveen Bhalla The entity received 10000 shares from Poonam Premsagar Pasricha on 25/7/2013 in physical form 145 AMDPB7288C Garima Bhalla The entity received 10000 shares from Poonam Premsagar Pasricha on 25/7/2013 in physical form 146 ABHPM9092L Sonalben Vijaybhai The entity received 10000 shares from Suryamangal Media & Makwana Entertainment Ltd on 25/7/2013 in physical form

147 ABHPM9090J Rakshaben The entity received 10000 shares from Suryamangal Media & Arunbhai Makwana Entertainment Ltd on 25/7/2013 in physical form

148 AAPPM6446H Mohanbhai The entity received 10000 shares from Suryamangal Media & Ranchodlal Entertainment Ltd on 25/7/2013 in physical form Makwana 149 AAGPP4875J Jyoti D Parekh The entity received 12500 shares from Poonam Premsagar Pasricha on 25/7/2013 in physical form 150 AHMPP5481H Prakash The entity received 10000 shares from Suryamangal Media & Narayanbhai Entertainment Ltd on 25/7/2013 in physical form Prajapati 151 AAAPD5694H Vinod K Doshi The entity received 40000 shares from Mukesh N Desai (HUF) on 16/11/2013 in physical form

152 ALZPP3198A Bhagwatilal Pagaria The entity received 17000 shares from Mukesh N Desai (HUF) on 25/7/2013 in physical form 153 ADGPD0192D Rakesh Dhariwal The entity received 8500 shares from Suryamangal Media & Entertainment Ltd on 25/7/2013 in physical form 154 AEEPG7912H Devibai Bhawarlal The entity received 16200 shares from Mukesh N Desai (HUF) on Gandhi 16/11/2013 in physical form

155 ABSPT8049H Sadhana Tolasariya The entity received 16000 shares from Mukesh N Desai (HUF) on 26/10/2013 in physical form 156 ABTPT0016D Laxmi Kanta The entity received 16000 shares from Mukesh N Desai (HUF) on Tolasariya 26/10/2013 in physical form 157 ADFPJ1887Q Krunal Ramesh The entity received 12000 shares from SDFC Finance Ltd on Janani 14/7/2012 in physical form 158 AJSPP5881H Prachi Nitin Kagzi The entity received 7800 shares from Kosha Cubidor Containers Ltd on 31/10/2012 in physical form 159 AAEPP2449Q Shivali D Parekh The entity received 12500 shares from Poonam Premsagar Pasricha on 25/7/2013 in physical form 160 AHMPP6874C Rakesh The entity received 30000 shares from Suryamangal Media & Narayanbhai Entertainment Ltd on 25/7/2013 in physical form Prajapati 161 AQSPS3383G Karnesh The entity received 30000 shares from Mukesh N Desai (HUF) on Shyamsukha 16/11/2013 in physical form 162 ABCPN0097M Anand Kumar The entity received 13000 shares from Mukesh N Desai (HUF) on Nahar 14/12/2013 in physical form 163 ACTPR0863K Jaya Lalit Shah The entity received 6000 shares from Suryamangal Media & Entertainment Ltd on 25/7/2013 in physical form 164 AATPC3367M Bhavna Bharatbhai The entity received 6000 shares from Suryamangal Media & Chopra Entertainment Ltd on 25/7/2013 in physical form

165 AFYPB2359C Sweetydevi Hitesh The entity received 6000 shares from Suryamangal Media & Chopra Entertainment Ltd on 25/7/2013 in physical form 166 AAAHC6262J Nemichand B The entity received 6000 shares from Suryamangal Media & Chopra Huf Entertainment Ltd on 25/7/2013 in physical form 167 AAMPC2665F Bharatkumar The entity received 6000 shares from Suryamangal Media & Nemichand Chopra Entertainment Ltd on 25/7/2013 in physical form

168 AAQPC7475F Nemichand The entity received 6000 shares from Suryamangal Media & Baxiram Chopra Entertainment Ltd on 25/7/2013 in physical form 169 ADRPM4459K Mahendra K Mehta The entity received 8500 shares from GFL Financial India Ltd on 25/7/2013 in physical form 170 AEGPS6711Q Suman Rajesh Shah The entity received 6000 shares from Suryamangal Media & Entertainment Ltd on 25/7/2013 in physical form 171 AFZPG5363E Mamta Pravin The entity received 18000 shares from Mukesh N Desai (HUF) on Gandhi 16/11/2013 in physical form

172 AAPPM6445E Vijaybhai The entity received 10000 shares from Suryamangal Media & Mohanbhai Entertainment Ltd on 25/7/2013 in physical form Makwana 173 AAJPJ4929L Babita Mahendra The entity received 5500 shares from GFL Financial India Ltd on Jain 25/7/2013 in physical form 174 ACWPJ4028K Anjana Satish Jain The entity received 5500 shares from GFL Financial India Ltd on 25/7/2013 in physical form 175 AAJPJ8038L Rajashree The entity received 5500 shares from GFL Financial India Ltd on Nitinkumar Jain 25/7/2013 in physical form 176 ALLPJ0145R Alka Ankit Jain The entity received 5500 shares from GFL Financial India Ltd on 25/7/2013 in physical form 177 AAJPJ4928M Sukhiben Sagarmal The entity received 5500 shares from GFL Financial India Ltd on Jain 25/7/2013 in physical form 178 AADHJ2188K Satish Sagarmal Jain The entity received 5500 shares from GFL Financial India Ltd on (HUF) 25/7/2013 in physical form 179 AAAHM8205M Mahendra Sagarmal The entity received 5500 shares from GFL Financial India Ltd on Jain (HUF) 25/7/2013 in physical form

180 AAAHN4499J Nitin Sagarmal Jain The entity received 5500 shares from GFL Financial India Ltd on (HUF) 25/7/2013 in physical form 181 AAKHA9197C Ankit Mahendra The entity received 5500 shares from GFL Financial India Ltd on Jain Huf 25/7/2013 in physical form 182 AAUPS6522K Sailesh Pragji Shah The entity received 10000 shares from Suryamangal Media & Entertainment Ltd on 29/6/2013 in physical form 183 AAAHN3298K Nainesh G Jain Huf The entity received 8200 shares and 50 shares from Kosha Cubidor Containers Ltd on 14/7/2012 and 14/8/2012 respectively and 1000 shares from SDFC Finance Limited on 29/9/2012 in physical form 184 AAEPJ2561P Vaishali Nainesh The entity received 8300 shares from Kosha Cubidor Containers Jain Ltd and 1200 shares from SDFC Finance Limited on 14/7/2012 in physical form 185 AACPP8181B Kalpesh D Parekh The entity received 12500 shares from Poonam Premsagar Pasricha on 25/7/2013 in physical form 186 ADVPD5950A Priti Dharewa The entity received 5000 shares from Suryamangal Media & Entertainment Ltd on 25/7/2013 in physical form 187 AEDPA7637Q Manish Agrawal The entity received 5000 shares from GFL Financial India Ltd on 25/7/2013 in physical form 188 ACKPS1326D Nitin K Shah The entity received 15000 shares from Suryamangal Media & Entertainment Ltd on 29/6/2013 in physical form 189 AFLPD0265J Kapilaben The entity received 5000 shares from GFL Financial India Ltd on Umiyashankar Joshi 25/7/2013 in physical form

190 ACXPM5128N Sheetal S Mehta The entity received 8500 shares from GFL Financial India Ltd on 25/7/2013 in physical form 191 ABIPM7371D Chandrika M Mehta The entity received 8500 shares from GFL Financial India Ltd on 25/7/2013 in physical form 192 AACPP8180A Dhirajlal J Parekh The entity received 12500 shares from Poonam Premsagar Pasricha on 25/7/2013 in physical form

193 AAPPM6035J Shardaben The entity received 10000 shares from Suryamangal Media & Mohanbhai Entertainment Ltd on 25/7/2013 in physical form Makwana 194 AFDPJ1441A Ankit N Janani The entity received 8000 shares from RFL International Limited and 4000 shares from SDFC Finance Limited on 14/7/2012 in physical form 195 ABOPP8114D Manish Porwal The entity received 10000 shares from Suryamangal Media & Entertainment Ltd on 25/7/2013 in physical form 196 AABHD3494G Pramod Kumar The entity received 8000 shares from Mukesh N Desai (HUF) on Dalmia (HUF) 14/12/2013 in physical form 197 AAAHR0144Q Ramesh C Janani The entity received 8000 shares from RFL International Limited Huf and 2500 shares from SDFC Finance Limited on 14/7/2012 in physical form 198 AOQPJ6594N Manav J Janani The entity received 10500 shares from SDFC Finance Ltd on 14/7/2012 in physical form 199 AJCPD4157A Kunal Prabhakar The entity received 8000 shares from Mukesh N Desai (HUF) on Deshmukh 14/12/2013 in physical form

200 AAZPD5085B Hema Prabhakar The entity received 8000 shares from Mukesh N Desai (HUF) on Deshmukh 14/12/2013 in physical form 201 BMTPS0594M Shreya U Sanghavi The entity received 3500 shares from GFL Financial India Ltd on 25/7/2013 in physical form 202 CAQPK7555L Nimishaben A The entity received 6000 shares from Suryamangal Media & Kadia Entertainment Ltd on 25/7/2013 in physical form 203 AKSPK4046N Harshadkumar B The entity received 6000 shares from Suryamangal Media & Kadia Entertainment Ltd on 25/7/2013 in physical form 204 AFNPK8525J Alkeshkumar The entity received 6000 shares from Suryamangal Media & Babubhai Kadia Entertainment Ltd on 25/7/2013 in physical form 205 AGFPK2166G Shakuntala Karwa The entity received 6500 shares from Mukesh N Desai (HUF) on 14/12/2013 in physical form 206 AAFHP5115A Praveen Chand The entity received 6500 shares from Mukesh N Desai (HUF) on Amichand (HUF) 14/12/2013 in physical form 207 AGFPK2169K Kamal Kishore The entity received 6500 shares from Mukesh N Desai (HUF) on Karwa 14/12/2013 in physical form 208 AGFPK2167H Venu Gopal Karwa The entity received 6500 shares from Mukesh N Desai (HUF) on 14/12/2013 in physical form 209 AGFPK2155H Shrikant Karwa The entity received 6500 shares from Mukesh N Desai (HUF) on 14/12/2013 in physical form 210 AACHM6405R Makwana Arunbhai The entity received 10000 shares from Suryamangal Media & Mohanbhai (HUF) Entertainment Ltd on 25/7/2013 in physical form

211 AJCPD8627M Mayuri Prabhakar The entity received 8000 shares from Mukesh N Desai (HUF) on Deshmukh 14/12/2013 in physical form

212 AFJPR1610P Ramesh Chhallani The entity received 3000 shares from Suryamangal Media & Entertainment Ltd on 25/7/2013 in physical form 213 AAFHS8024K Sheetal S Mehta The entity received 8500 shares from GFL Financial India Ltd on Huf 25/7/2013 in physical form

214 AALHR9880C Ramesh Chhallani The entity received 3000 shares from Suryamangal Media & Huf Entertainment Ltd on 25/7/2013 in physical form 215 AAEHN0043C Narendra C Janani The entity received 8200 shares from RFL International Limited Huf and 2300 shares from SDFC Finance Limited on 14/7/2012 in physical form 216 AAAHJ0488F Jitendra C Janani The entity received 8900 shares from Universal Credit And Huf Securities Ltd and 1600 shares from SDFC Finance Limited on 14/7/2012 in physical form 217 AJEPB3408Q Shailesh Z The entity received 4000 shares from Poonam Premsagar Pasricha Bhandari on 25/7/2013 in physical form 218 ANZPD8205A Anup Prabhakar The entity received 8000 shares from Mukesh N Desai (HUF) on Deshmukh 14/12/2013 in physical form 219 ALWPS7304N Rekha Manoj Shah The entity received 40000 shares from Mukesh N Desai (HUF) on 16/11/2013 in physical form 220 ADGPJ0194B Geetaben The entity received 16800 shares from Mukesh N Desai (HUF) on Rajeshkumar Jain 16/11/2013 in physical form

221 AEGPN6094P Urmila P Nemani The entity received 3000 shares from Suryamangal Media & Entertainment Ltd on 25/7/2013 in physical form 222 AIVPN2183N Prerak P Nemani The entity received 3000 shares from Suryamangal Media & Entertainment Ltd on 25/7/2013 in physical form 223 AEMPN1814R Nishant P Nemani The entity received 3000 shares from Suryamangal Media & Entertainment Ltd on 25/7/2013 in physical form 224 AKLPJ5402A Minal Krunal The entity received 8000 shares from Universal Credit And Janani Securities Ltd on 14/7/2012 in physical form 225 AJZPP1664P Avinash Porwal The entity received 10000 shares from Suryamangal Media & Entertainment Ltd on 25/7/2013 in physical form 226 AABHU0096B U R Sanghvi Huf The entity received 3500 shares from GFL Financial India Ltd on 25/7/2013 in physical form 227 AAFHS1862M Srikant Karwa Huf The entity received 5000 shares from Mukesh N Desai (HUF) on 14/12/2013 in physical form 228 AMTPJ9069K Pooja Jain The entity received 2500 shares from Suryamangal Media & Entertainment Ltd on 25/7/2013 in physical form 229 AAEHP3764Q Pawan Kumar The entity received 3000 shares from Suryamangal Media & Nemani Huf Entertainment Ltd on 25/7/2013 in physical form 230 AAEHK3969C Manoj Z Khivsara The entity received 5000 shares from GFL Financial India Ltd on Huf 25/7/2013 in physical form 231 ACAPS2670J Chaya Sailesh Shah The entity received 10000 shares from Suryamangal Media & Entertainment Ltd on 29/6/2013 in physical form 232 AACHK9840E Kamal Kishor The entity received 5000 shares from Mukesh N Desai (HUF) on Karwa Huf 14/12/2013 in physical form 233 AJHPK7359L Murari Ramnarayan The entity received 5000 shares from Mukesh N Desai (HUF) on Karwa 14/12/2013 in physical form

234 ALFPK4226Q Sulochana R Karwa The entity received 5000 shares from Mukesh N Desai (HUF) on 14/12/2013 in physical form 235 AABHV8959A Venu Gopal Karwa The entity received 5000 shares from Mukesh N Desai (HUF) on Huf 14/12/2013 in physical form

236 AGFPK2158L Ramanarayan H The entity received 5000 shares from Mukesh N Desai (HUF) on Karawa 14/12/2013 in physical form 237 AUFPK2191R Archana G Karwa The entity received 5000 shares from Mukesh N Desai (HUF) on 14/12/2013 in physical form 238 AGCPK5348P Neelu Manoj The entity received 5000 shares from GFL Financial India Ltd on Khivsara 25/7/2013 in physical form 239 AACHS8497K Suresh The entity received 2400 shares from Suryamangal Media & Rameshwarlal Entertainment Ltd on 25/7/2013 in physical form Kothari Huf 240 AFHPV9545F Vishal Jain The entity received 2500 shares from Suryamangal Media & Entertainment Ltd on 25/7/2013 in physical form 241 AAQPB9783P Zumberlal H The entity received 4000 shares from Poonam Premsagar Pasricha Bhandari on 25/7/2013 in physical form 242 AAFHB8657P Bhavin Chandulal The entity received 6000 shares from Suryamangal Media & Shah Huf Entertainment Ltd on 25/7/2013 in physical form 243 AMGPB6442B Anil Hiralal The entity received 5000 shares from GFL Financial India Ltd on Bhandari 25/7/2013 in physical form 244 AAVPA0108L Rameshwarlal G The entity received 2400 shares from Suryamangal Media & Kothari Entertainment Ltd on 25/7/2013 in physical form 245 ACXPM5129P Meera Sheetal The entity received 8500 shares from GFL Financial India Ltd on Mehta 25/7/2013 in physical form 246 DFHPS4978L Divyang Ramesh The entity received 2000 shares from Suryamangal Media & Sadhwani Entertainment Ltd on 25/7/2013 in physical form 247 AAMHR5898D Ramesh The entity received 2000 shares from Suryamangal Media & Morandmal Entertainment Ltd on 25/7/2013 in physical form Sadhwani (HUF) 248 AADPA6233E Sunita Rakesh The entity received 2000 shares from Suryamangal Media & Agarwal Entertainment Ltd on 25/7/2013 in physical form 249 AALHR9586F Rakesh R Agarwal The entity received 2000 shares from Suryamangal Media & Huf Entertainment Ltd on 25/7/2013 in physical form 250 AAPPB2953C Nilesh Vijay The entity received 2000 shares from Suryamangal Media & Bhatevara Entertainment Ltd on 25/7/2013 in physical form 251 ACVPA5077A Rakesh Agarwal The entity received 2000 shares from Suryamangal Media & Entertainment Ltd on 25/7/2013 in physical form 252 ATIPP5949C Saurabh N Patel The entity received 5000 shares from GFL Financial India Ltd on 25/7/2013 in physical form 253 BMDPP9341R Mittal P Patel The entity received 5000 shares from GFL Financial India Ltd on 25/7/2013 in physical form 254 AASPV1975F Ravi Vajawat The entity received 3000 shares from Suryamangal Media & Entertainment Ltd on 25/7/2013 in physical form 255 AABPS7373R Amita Parag Shah The entity received 15100 shares from Cromakem Limited and 1100 shares from Millennium Cybertech Limited on 14/7/2012 in physical form 256 AIGPP8081J Neha D Patel The entity received 5000 shares from GFL Financial India Ltd on 25/7/2013 in physical form 257 ADPPK8753Q Suresh The entity received 2000 shares from Suryamangal Media & Rameshwarlal Entertainment Ltd on 25/7/2013 in physical form Kothari

258 BBZPB0749L Archana Rohit The entity received 3000 shares from GFL Financial India Ltd on Bhandari 25/7/2013 in physical form 259 AADHR6147N Rameshwarlal The entity received 1600 shares from Suryamangal Media & Gulabchand Huf Entertainment Ltd on 25/7/2013 in physical form 260 AIGPP8011N Dinesh M Patel The entity received 5000 shares from GFL Financial India Ltd on 25/7/2013 in physical form 261 AVJPS3232Q Pallavi M Shirude The entity received 4000 shares from Poonam Premsagar Pasricha on 25/7/2013 in physical form 262 AAQHS5761J Shirude Milind R The entity received 3500 shares from GFL Financial India Ltd on Huf 25/7/2013 in physical form 263 AGFPK2157F Ghanshyamdas The entity received 5000 shares from Mukesh N Desai (HUF) on Karwa 14/12/2013 in physical form 264 EFMPS7289C Yash Parag Shah The entity received 2000 shares from Millennium Cybertech Ltd and 8000 shares from Cromakem Limited on 31/7/2012 in physical form 265 AGLPK7190G Surinder The entity received 7000 shares from Suryamangal Media & Charansingh Kaur Entertainment Ltd on 25/7/2013 in physical form

266 ABMPK0516A Deepak The entity received 1600 shares from Suryamangal Media & Rameshwarlal Entertainment Ltd on 25/7/2013 in physical form Kothari 267 ACNPS1799P Milind R Shirude The entity received 3500 shares from GFL Financial India Ltd on 25/7/2013 in physical form 268 AEJPB4820Q Vandana Anil The entity received 5000 shares from GFL Financial India Ltd on Bhandari 25/7/2013 in physical form 269 AAAPJ7220P Jayanthi Kumari The entity received 2500 shares from Mukesh N Desai (HUF) on 14/12/2013 in physical form 270 ABWPM8495Q Mangi Devi The entity received 2500 shares from Mukesh N Desai (HUF) on 14/12/2013 in physical form 271 AAIHM3818E Mahaveerkumar The entity received 2500 shares from Mukesh N Desai (HUF) on Praveenchand 14/12/2013 in physical form (HUF) 272 AAEHV8290D Vimalkumar The entity received 2500 shares from Mukesh N Desai (HUF) on Praveenchand 14/12/2013 in physical form (HUF) 273 AAFHV9245P Vikramkumar The entity received 2500 shares from Mukesh N Desai (HUF) on Praveenchand 14/12/2013 in physical form (HUF) 274 AABPS7371P Parag Anandlal The entity received 18400 shares from Millennum Cybertech Ltd Shah on 14/7/2012 in physical form 275 AFAPD5513L Dinesh Kumar Jain The entity received 5000 shares from Mukesh N Desai (HUF) on 14/12/2013 in physical form 276 ABAPJ3319G Prakash Kumar Jain The entity received 2500 shares from Suryamangal Media & Entertainment Ltd on 25/7/2013 in physical form 277 AIMPB3417A Rohitkumar S The entity received 4000 shares from Poonam Premsagar Pasricha Bhandari on 25/7/2013 in physical form

278 AJXPB9684M Rakesh S Bhandari The entity received 4000 shares from Poonam Premsagar Pasricha on 25/7/2013 in physical form 279 AIDPD8304R Pritesh G Deo The entity received 2000 shares from GFL Financial India Ltd on 25/7/2013 in physical form 280 AARPV3324P P Vimal Kumar The entity received 2500 shares from Mukesh N Desai (HUF) on 14/12/2013 in physical form 281 AONPB7989N Bhandari Kanchan The entity received 3000 shares from GFL Financial India Ltd on Sumtilal 25/7/2013 in physical form 282 AAQPD5950Q Govind D Deo The entity received 2000 shares from GFL Financial India Ltd on 25/7/2013 in physical form 283 AACHV0256P Vijay F Sabadra The entity received 2000 shares from GFL Financial India LTD Huf on 25/7/2013 in physical form 284 ANMPS8650B Vijay F Sabadra The entity received 2000 shares from GFL Financial India Ltd on 25/7/2013 in physical form 285 ACMPS2295K Sunanda Vijay The entity received 2000 shares from GFL Financial India Ltd on Sabadra 25/7/2013 in physical form 286 BGWPS0440K Rashmi Vijay The entity received 2000 shares from GFL Financial India Ltd on Sabadra 25/7/2013 in physical form 287 AACHM6406N Makwana Vijaybhai The entity received 10000 shares from Suryamangal Media & Mohanbhai Huf Entertainment Ltd on 25/7/2013 in physical form

288 BHXPS4067C Shilpa Bagreecha The entity received 2500 shares from Mukesh N Desai (HUF) on 14/12/2013 in physical form 289 AJLPJ2277L Vikas Kumar Jain The entity received 2500 shares from Mukesh N Desai (HUF) on 14/12/2013 in physical form 290 ABTPB2111P Sumtilal Pannalal The entity received 3000 shares from GFL Financial India Ltd on Bhandari 25/7/2013 in physical form 291 ABWPM8494R P Mahaveer Kumar The entity received 2500 shares from Mukesh N Desai (HUF) on 14/12/2013 in physical form 292 AAFHN2519A Narendra M The entity received 5500 shares from Suryamangal Media & Agrawal Huf Entertainment Ltd on 25/7/2013 in physical form 293 AAPPV3421M Bindu Vajawat The entity received 3000 shares from Suryamangal Media & Entertainment Ltd on 25/7/2013 in physical form 294 AOFPV5904B Rohin Vajawat The entity received 3000 shares from Suryamangal Media & Entertainment Ltd on 25/7/2013 in physical form 295 AAQPD5949R Usha G Deo The entity received 2000 shares from GFL Financial India Ltd on 25/7/2013 in physical form 296 AABPY4151B Shashikant N Yeola The entity received 2000 shares from GFL Financial India Ltd on 25/7/2013 in physical form 297 ALJPS5991A Ramesh The entity received 800 shares from Suryamangal Media & Morandmal Entertainment Ltd on 25/7/2013 in physical form Sadhwani 298 ANYPS3580Q Sunita The entity received 800 shares from Suryamangal Media & Rameshchandra Entertainment Ltd on 25/7/2013 in physical form Sadhwani 299 AXDPK5755C Mohit Rajkumar The entity received 800 shares from Suryamangal Media & Kothari Entertainment Ltd on 25/7/2013 in physical form

300 ABNPK6901A Durga Rajkumar The entity received 800 shares from Suryamangal Media & Kothari Entertainment Ltd on 25/7/2013 in physical form 301 AAEHR3848D Rajkumar The entity received 800 shares from Suryamangal Media & Rameshwarlal Huf Entertainment Ltd on 25/7/2013 in physical form

302 AFAPB6534M Shweta Vivek The entity received 800 shares from Suryamangal Media & Kothari Entertainment Ltd on 25/7/2013 in physical form 303 ABBPD8991K Padma Devi The entity received 2500 shares from Suryamangal Media & Entertainment Ltd on 25/7/2013 in physical form 304 AIDPD8303J Hitesh G Deo The entity received 2000 shares from GFL Financial India Ltd on 25/7/2013 in physical form 305 AAJHA8394Q Arvind M Agrawal The entity received 6000 shares from Suryamangal Media & Huf Entertainment Ltd on 25/7/2013 in physical form 306 AAAHB8392L Abhay P Bora Huf The entity received 2000 shares from GFL Financial India Ltd on 25/7/2013 in physical form 307 AASPA8019P Kiran Dineshkumar The entity received 1600 shares from Suryamangal Media & Agrawal Entertainment Ltd on 25/7/2013 in physical form

308 AARPV3323L P Vikram Kumar The entity received 2500 shares from Mukesh N Desai (HUF) on 14/12/2013 in physical form 309 AESPJ3783R Rupali Atul Jain The entity received 1500 shares from GFL Financial India Ltd on 25/7/2013 in physical form 310 AALPJ3459K Atul Satishchandra The entity received 1500 shares from GFL Financial India Ltd on Jain 25/7/2013 in physical form

311 AAKPT6824H Nandkishor The entity received 1500 shares from GFL Financial India Ltd on Kantilal Tated 25/7/2013 in physical form 312 AFSPB0852N Anita Abhay Bora The entity received 2000 shares from GFL Financial India Ltd on 25/7/2013 in physical form 313 AFRPB3527R Neena Tejpal Bora The entity received 2000 shares from GFL Financial India Ltd on 25/7/2013 in physical form 314 AABHT0453R Tejpal P Bora Huf The entity received 2000 shares from GFL Financial India Ltd on 25/7/2013 in physical form 315 ADHPB4828M Tejpal P Bora The entity received 2000 shares from GFL Financial India Ltd on 25/7/2013 in physical form 316 ADHPB4825G Abhaykumar P The entity received 2000 shares from GFL Financial India Ltd on Bora 25/7/2013 in physical form 317 AFRPB3530L Suganbai P Bora The entity received 2000 shares from GFL Financial India Ltd on 25/7/2013 in physical form 318 AWNPB0219R Sailee A Bora The entity received 2000 shares from GFL Financial India Ltd on 25/7/2013 in physical form 319 AFQPA2808F Alka Jain The entity received 2500 shares from Mukesh N Desai (HUF) on 14/12/2013 in physical form 320 AANPA7734J Mithailal K The entity received 5000 shares from Suryamangal Media & Agarawal Entertainment Ltd on 25/7/2013 in physical form 321 AFQPA9253C Ranibai M The entity received 5000 shares from Suryamangal Media & Agarawal Entertainment Ltd on 25/7/2013 in physical form

322 ADPPA4146F Arvind Mithailal The entity received 7000 shares from Suryamangal Media & Agrawal Entertainment Ltd on 25/7/2013 in physical form 323 AALHP4640Q Narayan P Panicker The entity received 5000 shares from GFL Financial India Ltd on Huf 25/7/2013 in physical form 324 AMLPB2241H Piyush Sunil Bafna The entity received 1200 shares from Suryamangal Media & Entertainment Ltd on 25/7/2013 in physical form 325 ABGPA9107R Narendra M The entity received 6500 shares from Suryamangal Media & Agrawal Entertainment Ltd on 25/7/2013 in physical form 326 AFQPA9251A Swati Narendra The entity received 6000 shares from Suryamangal Media & Agrawal Entertainment Ltd on 25/7/2013 in physical form 327 AHGPB6587L Leena Sunil Bafna The entity received 1000 shares from Suryamangal Media & Entertainment Ltd on 25/7/2013 in physical form 328 AZXPB5572E Priyanka Sunil The entity received 1000 shares from Suryamangal Media & Bafna Entertainment Ltd on 25/7/2013 in physical form 329 AFQPA9252D Neelam Arvind The entity received 5500 shares from Suryamangal Media & Agrawal Entertainment Ltd on 25/7/2013 in physical form 330 AYUPK7834Q Sarthak The entity received 2000 shares from Suryamangal Media & Sureshkumar Entertainment Ltd on 25/7/2013 in physical form Kothari 331 ADVPG5413H Aniruddha R The entity received 2500 shares from GFL Financial India Ltd on Gawade 25/7/2013 in physical form 332 AALPY6141M Vijaya Shashikant The entity received 2000 shares from GFL Financial India Ltd on Yeola 25/7/2013 in physical form

333 AAEPC5128R Sampatraj Chhallani The entity received 3000 shares from Suryamangal Media & Entertainment Ltd on 25/7/2013 in physical form 334 AADHB8997E Balkishan Innani The entity received 6500 shares from Mukesh N Desai (HUF) on Huf 14/12/2013 in physical form 335 ATHPG7447B Akash A Gawade The entity received 2500 shares from GFL Financial India Ltd on 25/7/2013 in physical form 336 AAFHD8458Q Dineshkumar Jain The entity received 2500 shares from Mukesh N Desai (HUF) on Huf 14/12/2013 in physical form 337 AEXPK9060M Lalita Suresh The entity received 2000 shares from Suryamangal Media & Kothari Entertainment Ltd on 25/7/2013 in physical form 338 AABHG8591H Ghanshyamdas The entity received 1950 shares from Ghanshyamdas Karwa on Harikishan Karwa 27/3/2014 through off market transactions Huf 339 AACHM6051K Mohanbhai R The entity received 10000 shares from Suryamangal Media & Makwana Huf E ntertainment Ltd on 25/7/2013 in physical form 340 AAQPT4000M Namdeo Kisan The entity received 80000 shares from Dadima Capital (P) Ltd on Tajane 30/8/2013 through off market transactions 341 AGSPT2723R Minal Namdeo The entity received 40000 shares from Dadima Capital (P) Ltd on Tajane 30/8/2013 through off market transactions

342 ADKPP2023P Bharatbhai The entity received 6000 shares and 4500 shares from Dadima Zaverbhai Prajapati Capital (P) Ltd on 11/9/2013 and 9/10/2013 respectively through off market transactions 343 ARGPA6417L Aishwarya The entity received 9000 shares from Dadima Capital (P) Ltd on Abhishek Agrawal 21/8/2013 through off market transactions

344 BHZPA3199P Esha Ankit The entity received 9000 shares from Dadima Capital (P) Ltd on Agrawal 21/8/2013 through off market transactions 345 AABHP8743A Gordhanbhai The entity received 8400 shares from Dadima Capital (P) Ltd on Narandas Patel 5/9/2013 through off market transactions 346 AOMPC0772K Komilkumar The entity received 7000 shares from Dadima Capital (P) Ltd on Anilbhai Chauhan 31/10/2013 through off market transactions

347 ACTPP7683H Dhanjibhai The entity received 6000 shares from Dadima Capital (P) Ltd on Ravjibhai Dholaria 27/9/2013 through off market transactions

348 AAEHD9550L Dhanjibhai The entity received 6000 shares from Dadima Capital (P) Ltd on Ravjibhai Dholaria 27/9/2013 through off market transactions (Huf) 349 ANPPP5555K Saritaben D Patel The entity received 6000 shares from Dadima Capital (P) Ltd on 27/9/2013 through off market transactions 350 AACCS6506N Siddhachal The entity received 3200 shares from Dadima Capital (P) Ltd on Tradelink Pvt Ltd 28/8/2013 through off market transactions 351 AFNPS9308B Vimlaben Kantilal The entity received 3200 shares from Dadima Capital (P) Ltd on Sanghvi 28/8/2013 through off market transactions

352 ATRPK4534D Ramesh Krishna The entity transfered a total of 32370 shares to Dadima Capital Kulaye (P) Ltd from 7/4/2014 to 7/5/2014 through off market transactions 353 AEKPK6751Q Santosh Kumar The entity transfered 13000 shares to Dadima Capital (P) Ltd on 26/12/2013 through off market transactions 354 ABNPV8151B Vijay Govindarajan The entity received 5000 shares from Jaswant Kantilal Parmar on 11/4/2014 through off market transactions 355 ARCPP2280L Keyur Babulal Patel The entity received a total of 2100 shares from Bharatkumar Prahladbhai Prajapati on 21/11/2013 and 27/11/2013 through off market transactions and 5000 shares from Mukesh N Desai HUF on 26/10/2013 in physical form. 356 ACQPP0211N Minaben Ambalal The entity received a total of 1800 shares from Bharatkumar Patel Prahladbhai Prajapati on 10/12/2013 and 11/12/2013 through off market transactions 357 APLPP4465J Sonalben The entity received a total of 1800 shares from Bharatkumar Dhirenkumar Patel Prahladbhai Prajapati on 10/12/2013 and 11/12/2013 through off market transactions 358 AACHP4026P Ambalal The entity received 1800 shares from Bharatkumar Prahladbhai Ranchhodbhai Prajapati on 11/12/2013 through off market transactions Patel -

359 AXMPP3283D Bhavika Jaykumar The entity received 700 shares from Bharatkumar Prahladbhai Patel Prajapati on 10/12/2013 through off market transactions 360 AEKPJ9968A Pawan Jain T h e e n t i t y r e c e iv e d 6 5 0 0 s h a r e s f rom Mukesh N Desai (HUF) on 14/12/2013 in physical form 361 AAHHV3712M Vikas Kumar Jain The entity received 2500 shares from Mukesh N Desai (HUF) on (HUF) 14/12/2013 in physical form

DATE: AUGUST 14th, 2014 RAJEEV KUMAR AGARWAL PLACE: MUMBAI WHOLE TIME MEMBER SECURITIES AND EXCHANGE BOARD OF INDIA