Order in the matter of M/s Everlight Realcon Infrastructure Limited

WTM/PS/163/ERO/RLO/FEB/2016 BEFORE THE SECURITIES AND EXCHANGE BOARD OF INDIA CORAM: PRASHANT SARAN, WHOLE TIME MEMBER ORDER Under Sections 11, 11(4), 11A and 11B of the Securities and Exchange Board of India Act, 1992 In the matter of Everlight Realcon Infrastructure Limited In respect of: 1. Everlight Realcon Infrastructure Limited [PAN: AACCE6725D], 2. Mr. Biplab Kumar Dey [PAN: AHXPD7948N], 3. Ms. Juthika Ghosh [DIN: 02888132], 4. Mr. Seikh Kutubuddin [PAN: DNRPK1802D; DIN: 06979183] and 5. Mr. Chandan Sinha Roy [PAN: AJGPR9741N; DIN: 0345979]. Date of Hearing: September 04, 2015 Appearances: For Noticees: Mr. Preetam Kundu, Advocate For SEBI: Mr. Prashanta Mahapatra, General Manager, Mr. T. Vinay Rajneesh, Assistant General Manager, Mr. Mohd. Sahid, Assistant Manager, Ms. Nikki Agarwal, Assistant Manager. 1. Securities and Exchange Board of India (hereinafter referred to as ‘SEBI’), vide an ex-parte interim Order dated March 16, 2015 (hereinafter referred to as ‘the interim order’) had observed that the company, Everlight Realcon Infrastructure Limited(hereinafter referred to as ‘Everlight’ or ‘the Company’) is prima facie engaged in fund mobilising activity from the public, through the Offer of Redeemable Preference Shares (hereinafter referred to as ‘RPS’) and had allegedly violated the provisions of Sections 56, 60 read with Section 2(36), 73 of the Companies Act, 1956 read with SEBI (Issue and Listing of Non-Convertible Redeemable Preference Shares) Regulations, 2013. In order to protect the interest of investors and to ensure that only legitimate fund raising activities are carried on by the Company and its directors, SEBI had issued the following directions: “… … 19. In view of the foregoing, I, in exercise of the powers conferred upon me under Sections 11(1), 11(4), 11A and 11B of the SEBI Act read with the Issue and Listing of Non– Convertible Redeemable Preference Shares Regulations, hereby issue the following directions – i. ERIL shall forthwith cease to mobilize any fresh funds from investors through the offer of RPS or through the issuance of equity shares or any other securities, to the public and/or invite subscription, in any manner whatsoever, either directly or indirectly till further directions; ii.

ERIL and its Directors, viz. Mr. Biplab Kumar Dey (DIN: 02550446, PAN: AHXPD7948N), Ms. Juthika Ghosh (DIN:02888132), Mr. Seikh Kutubuddin PAN:DNRPK1802D DIN:06979183) and Mr. Chandan Sinha Roy (DIN:03459797, PAN: AJGPR9741N)are prohibited from issuing prospectus or any offer document or issue advertisement for soliciting money from the public for the issue of securities, in any manner whatsoever, either directly or indirectly, till further orders; iii. ERIL, its abovementioned Directors are restrained from accessing the securities market and further prohibited from buying, selling or otherwise dealing in the securities market, either directly or indirectly, till further directions; iv. ERIL shall provide a full inventory of all its assets and properties; v. ERIL 's abovementioned Directors shall provide a full inventory of all their assets and properties; vi. ERIL, its abovementioned Directors shall not dispose of any of the properties or alienate or encumber any of the assets owned/acquired by that company through the offer of RPS, without prior permission from SEBI; vii. ERIL, its abovementioned Directors shall not divert any funds raised from public at large through the offer of RPS, which are kept in bank account(s) and/or in the custody of ERIL; viii.

ERIL, its abovementioned Directors shall furnish complete and relevant information within 21 days from the date of receipt of this Order. 20. The above directions shall take effect immediately and shall be in force until further orders. … 23. This interim order cum show cause notice is without prejudice to the right of SEBI to take any other action that may be initiated against ERIL, its abovementioned Directors in accordance with law.”

2. The interim order observed that the prima facie observations made therein were on the basis of the correspondences exchanged between SEBI and the Company along with the documents contained therein and the information/ documents obtained from the ‘MCA-21’ portal. The interim order was also treated as a show cause notice which advised the Company and its directors to file their replies within 21 days from the date of receipt of its receipt and also seek an opportunity of personal hearing.

3. The interim order was forwarded to the Company and its directors namely Mr. Biplab Kumar Dey, Ms. Juthika Ghosh, Mr. Seikh Kutubuddin and Mr. Chandan Sinha Royvide letter dated March 20, 2015. The letter sent to the Company and its directors had returned undelivered except that sent to Mr. Seikh Kutubuddin.SEBI proceeded further and granted an opportunity of personal hearing to the Company and its directors on September 04, 2015. The scheduled date was communicated vide SEBI letter dated August 10, 2015. The date of hearing was also communicated vide the public notice in the newspapers namely ‘Hindustan’ and ‘Times of India’ both dated August 15, 2015. The Company and its directors were advised that in case they fail to appear for the personal hearing before SEBI on the aforesaid date, then the matter would be proceeded ex-parte on the basis of the material available on record.

4. On the date fixed for personal hearing i.e. September 04, 2015, one Mr. Preetam Kundu, Advocate appeared for Ms. Juthika Ghosh, Mr. Seikh Kutubuddin and Mr. Chandan Sinha Roy and requested liberty for filing reply/ written submissions within 15 days, which was duly granted. The Company and Mr. Biplab Kumar Dey had remained absent. No reply/ written submissions have been filed by Ms. Juthika Ghosh, Mr. Seikh Kutubuddin and Mr. Chandan Sinha Roy till date. Considering the reasonable opportunities already afforded for making submissions in the matter, I am inclined to proceed further with the matter.

5. I have considered the interim order and the material available on record. The following are the observations from the interim order: “… i ERIL (CIN:U70100JH2011PLC014743) was incorporated on March 16, 2011 with the RoC, Jharkhand having its registered office at Saraidhela, Amba Tower, Steel Gate, Dhanbad, Jharkhand, India- 826001.

ii The present directors in ERIL are Mr. Biplab Kumar Dey, Ms. Juthika Ghosh, Mr. Seikh Kutubuddin. Mr. Chandan Sinha Roy was earlier director in ERIL. iii It is observed from copies of Letters of Allotment of RPS issued by ERIL provided by the complainants that the company issued Redeemable Preference Shares (‘RPS’) of face value Rs.10/- each during the Financial Years 2011-12, 2012-13 and 2013-14. The details of the same are provided below: Financial No. of No. of RPS Face Value per Amount Mobilised Year Investors Allotted RPS (in Rs.) (in Rs.) 2011-12 29 88,905 10 8,89,050 2012-13 84 4,92,512 10 49,25,120 2013-14 18 1,35,000 10 13,50,000 Total 131 7,16,417 10 71,64,170 iv It is noted from Balance Sheets for the FY 2011-12 and 2012-13 provided by ERIL vide letter dated March 21, 2014 that - a. Authorised Redeemable Preference Shares Capital of ERIL as on March 31, 2012 was Rs.19,95,00,000/- while Authorised Redeemable Preference Shares Capital as on March 31, 2013 was mentioned as Rs.15,00,00,000/-. b. An amount of Rs.8,50,46,694/- was mentioned as 'Share application money pending allotment' in the Balance Sheet of the company as on March 31, 2012. However, it was observed that amount mentioned as 'share application money pending allotment' was added to and shown as 'advance against product' under the head of other current liabilities as at March 31, 2012 in the Balance Sheet as on March 31, 2013. …” 6. Having considered the above, it is now necessary to determine whether the Company had made a public issue as alleged in the interim order and if so, whether the Company had complied with the public issue norms. The liability of the directors of the Company also needs to be determined as they have also been alleged in the interim order.

7. In order to ascertain whether an issue of securities is a ‘public issue’ or done on ‘private placement’, it is necessary to make a reference to Section 67(3) of the Companies Act, 1956, which reads as under: “67. (1) Any reference in this Act or in the articles of a company to offering shares or debentures to the public shall, subject to any provision to the contrary contained in this Act and subject also to the provisions of sub-sections (3) and (4), be construed as including a reference to offering them to any section of the public, whether selected as members or debenture holders of the company concerned or as clients of the person issuing the prospectus or in any other manner. (2) ...

(3) No offer or invitation shall be treated as made to the public by virtue of sub-section (1) or sub-section (2), as the case may be, if the offer or invitation can properly be regarded, in all the circumstances- (a) as not being calculated to result, directly or indirectly, in the shares or debentures becoming available for subscription or purchase by persons other than those receiving the offer or invitation; or (b) otherwise as being a domestic concern of the persons making and receiving the offer or invitation … Provided that nothing contained in this sub-section shall apply in a case where the offer or invitation to subscribe for shares or debentures is made to fifty persons or more: Provided further that nothing contained in the first proviso shall apply to non-banking financial companies or public financial institutions specified in section 4A of the Companies Act, 1956 (1 of 1956).” In terms of Section 67(3), as amended by the Companies (Amendment) Act, 2000, with effect from December 13, 2000, no offer or invitation shall be treated as made to the public by virtue of sub-sections (1) or (2), as the case may be, if the offer or invitation can properly be regarded, in all circumstances - (a) as not being calculated to result, directly or indirectly, in the shares or debentures becoming available for subscription or purchase by persons other than those receiving the offer or invitation; or (b) otherwise as being a domestic concern of the persons making and receiving the offer or invitation. In terms of the first proviso to the aforesaid section, the provisions of Section 67(3) shall not apply in a case where the offer or invitation to subscribe for shares or debentures is made to fifty persons or more. Therefore, the number of subscribers becomes relevant to conclude whether an issue of shares are for public or on a private placement basis. In view of the same, if an offer of securities are made to fifty or more persons, it would be deemed to be a public issue.

8. I now place my reliance on the order of Hon'ble Supreme Court of India in the matter of Sahara India Real Estate Corporation Limited & Others Vs. SEBI and another(Civil Appeal Nos. 9813 and 9833 of 2011; decided on August 31, 2012) (‘the Sahara case’) had inter alia held that - “Section 67(1) deals with the offer of shares and debentures to the public and Section 67(2) deals with invitation to the public to subscribe for shares and debentures and how those expressions are to be understood, when reference is made to the Act or in the articles of a company. The emphasis in Section 67(1) and (2) is on the “section of the public”. Section 67(3) states that no offer or invitation shall be treated as made to the public, by virtue of subsections (1) and (2), that is to any section of the public, if the offer or invitation is not being calculated to result, directly or indirectly, in the shares or debentures becoming available for subscription or purchase by persons other than those receiving the offer or invitation or otherwise as being a domestic concern of the persons making and receiving the offer or invitations.

Section 67(3) is, therefore, an exception to Sections 67(1) and (2). If the circumstances mentioned in clauses (1) and (b) of Section 67(3) are satisfied, then the offer/invitation would not be treated as being made to the public. The first proviso to Section 67(3) was inserted by the Companies (Amendment) Act, 2000 w.e.f. 13.12.2000, which clearly indicates, nothing contained in Sub-section (3) of Section 67 shall apply in a case where the offer or invitation to subscribe for shares or debentures is made to fifty persons or more. … Resultantly, if an offer of securities is made to fifty or more persons, it would be deemed to be a public issue, even if it is of domestic concern or proved that the shares or debentures are not available for subscription or purchase by persons other than those received the offer or invitation. … I may, therefore, indicate, subject to what has been stated above, in India that any share or debenture issue beyond forty nine persons, would be a public issue attracting all the relevant provisions of the SEBI Act, regulations framed thereunder, the Companies Act, pertaining to the public issue. …” 9. In the present case, I note, on the basis of letters of allotment of RPS provided by the complainants, that the Company had offered and allotted RPS to atleast 131 allottees (the Company has failed to submit the complete details about its issue of RPS) and had raised about `71.64 lakh during the financial years of 2011-12, 2012-13 and 2013-14.

The Company has not provided the date of resolution for the offer and issue of RPS. In view of the same, it can be said that the Company had allotted RPSs to more than 49 persons out of a single offer. The interim order had also observed that the balance sheet of the Company as on March 31,

2012, had shown an amount of 8,50,46,694 as ‘share application money’ pending allotment. However, the balance sheet of the Company as on March31, 2013 revealed that the said amount had been added as ‘advance against product’ under the head of other current liabilities. The Company has not provided any explanation to this allegation. It is therefore clear that the Company has mobilized large sums, at least to the tune of Rs.8.5 crore. The number of investors is also likely to be large and at least 131. In view of the above discussion, it is held that the Company had made an offer and allotted RPSs to more than 49 persons, thereby making a public issue of RPSs (in terms of the first proviso to Section 67(3) of the Companies Act, 1956) during the period alleged in the interim order.

10. By making a public issue of RPS, as discussed above, the Company was mandated to comply with all the legal provisions that govern and regulate public issue of such securities, including the Companies Act, 1956 and the SEBI Act and regulations. In this context, I refer and rely on the below mentioned observation made by the Hon'ble Supreme Court of India in the matter of Sahara case: “... ... that any share or debenture issue beyond forty nine persons, would be a public issue attracting all the relevant provisions of the SEBI Act, regulations framed thereunder, the Companies Act, pertaining to the public issue. …” 11. In view of the above observations, by virtue of Section 55A(a) and (b), SEBI has jurisdiction and would govern the issue of RPS as the same was clearly made to more than 49 persons. As alleged in the interim order, the Company was mandated to comply with the provisions of Sections 56, 60, 67 and 73 of the Companies Act, 1956, in respect of its offer and issue of RPS. In terms of Section 56(1) of the Companies Act, 1956, every prospectus issued by or on behalf of a company, shall state the matters specified in Part I and set out the reports specified in Part II of Schedule II of that Act. Further, as per Section 56(3) of the Companies Act, 1956, no one shall issue any form of application for shares in a company, unless the form is accompanied by abridged prospectus, contain disclosures as specified. Section 2(36) of the Companies Act read with Section 60 thereof, mandates a company to register its ‘prospectus’ with the RoC, before making a public offer/ issuing the ‘prospectus’.

12. The interim order further alleged that the Company had failed to comply with Section 73 of the Companies Act, 1956, in respect of its issuance of RPS. By issuing RPSs to more than 49 persons, the Company had to compulsorily list such securities in compliance with Section 73(1) of the Companies Act, 1956. As per Section 73(1) of the Companies Act, 1956, a company is required to make an application to one or more recognized stock exchanges for permission for the shares or debentures to be offered to be dealt with in the stock exchange. There is no material on record to say that the Company has filed an application with a recognized stock exchange to enable the RPS to be dealt with in such exchange. Therefore, the Company has failed to comply with this requirement.

13. Section 73(2) of the Companies Act, 1956 states that "Where the permission has not been applied under subsection (1) or such permission having been applied for, has not been granted as aforesaid, the company shall forthwith repay without interest all moneys received from applicants in pursuance of the prospectus, and, if any such money is not repaid within eight days after the company becomes liable to repay it, the company and every director of the company who is an officer in default shall, on and from the expiry of the eighth day, be jointly and severally liable to repay that money with interest at such rate, not less than four per cent and not more than fifteen per cent, as may be prescribed, having regard to the length of the period of delay in making the repayment of such money". As the Company failed to make an application for listing such RPSs, the Company had to forthwith repay such money collected from investors. If such repayments are not made within 8 days after the Company becomes liable to repay, the Company and every director of the Company, who is an officer in default, is jointly and severally liable to repay with interest at such rate. There is no material on record to say that the Company has complied with the provisions of Section 73(3).

14. As the RPSs issued by the Company are ‘non-convertible redeemable preference share’ in terms of the SEBI (Issue and Listing of Non-Convertible Redeemable Preference Shares) Regulations, 2013, the Company was also mandated to comply with provisions of the SEBI (Issue and Listing of Non-Convertible Redeemable Preference Shares) Regulations, 2013 in respect of its public issue of RPSs. However, the Company has failed to comply with the following provisions of the SEBI (Issue and Listing of Non-Convertible Redeemable Preference Shares) Regulations, 2013. i. Regulation 4(2)(a) – Application for listing of debt securities ii. Regulation 4(2)(b) – In-principle approval for listing of debt securities iii. Regulation 4(2)(c) – Credit rating has been obtained iv. Regulation 4(2)(d) – Dematerialization of debt securities v. Regulation 4(4) – Appointment of Debenture Trustee vi. Regulation 5(2)(b) – Disclosure requirements in the Offer Document vii. Regulation 6 – Filing of draft Offer Document viii. Regulation 7 – Mode of disclosure of Offer Document ix. Regulation 8 – Advertisements for Public Issues x. Regulation 9 – Abridged Prospectus and application forms xi. Regulation 12 – Minimum subscription xii. Regulation 14 – Underwriting xiii. Regulation 15 – Prohibition of mis-statements in the Offer Document xiv. Regulation 16 – Mandatory Listing xv. Regulation 22 – Obligations of the Issuer, etc.

From the foregoing, it is concluded that the Company has failed to comply with the provisions of Sections 56, 60 (read with Section 2(36), 73 of the Companies Act, 1956 read with Companies Act, 2013 and the aforesaid provisions of the SEBI (Issue and Listing of Non-Convertible Redeemable Preference Shares) Regulations, 2013, in respect of its offer and issuance of RPSs as discussed in this Order and liable for suitable action under the Companies Act, 1956, the SEBI Act and the SEBI (Issue and Listing of Non-Convertible Redeemable Preference Shares) Regulations, 2013. 15. Liability of Directors: The interim order was issued against the directors of the Company namely Mr. Biplab Kumar Dey, Ms. Juthika Ghosh, Mr. Seikh Kutubuddin and Mr. Chandan Sinha Roy. a. The details of their appointment and resignations are as under: Name Date of Date of Cession Appointment Mr. Biplab Kumar Dey 16/03/2011 Continuing as director Ms. Juthika Ghosh 16/03/2011 Continuing as director Mr. Seikh Kutubuddin 19/09/2014 Continuing as director Mr. Chandan Sinha Roy 16/03/2011 22/09/2014 b. I note that the Company had offered and issued RPS in the financial year 2011-12, 2012-13 and 2013-14. Section 56 of the Companies Act, 1956 imposes the liability for the compliance, on the company, every director, and persons responsible for the issuance of the prospectus. The liability of the Company to repay under Section 73(2) of the Companies Act, 1956 read with Section 27 of the SEBI Act, is continuing and the same continues till all the repayments are made to the investors/ public. Therefore, the directors who were present during the period when the Company had made the offer and allotted RPS shall be liable for violation of Sections 56, 60 and 73 of the Companies Act, 1956 including the default in making refunds as mandated therein. As the liability to make repayments under Section 73(2) of the Companies Act read with Section 27 of the SEBI Act is a continuing liability, the persons who joined the Company’s Board pursuant to the offer and allotment of RPS shall also be liable if the Company and the concerned directors have failed to make refunds, as mandated under the discussed provisions of law.

c. From the table above, it is noted that Mr. Biplab Kumar Dey, Ms. Juthika Ghosh and Mr. Chandan Sinha Roy (though he resigned in September 2014) were the directors of the Company at the time of impugned issue and allotment of RPSs and were responsible for the affairs of the Company, at the relevant point of time. In view of the same, it can be concluded that Mr. Biplab Kumar Dey, Ms. Juthika Ghosh and Mr. Chandan Sinha Roy are liable for the violations committed by Company, as discussed above, and jointly and severally, for making refunds along with interest to the investors as mandated under Section 73(2) of the Companies Act, 1956 read with Section 27 of the SEBI Act.

d. Mr. Seikh Kutubuddin was appointed as director of the Company on September 19, 2014 i.e. after the last available details of allotment of RPS. He is also one of the present directors of the Company. It is observed that he has not exercised necessary diligence after becoming the director in the Company. The inaction by him against the management (for violating the public issue norms as stipulated under the Companies Act, 1956, while making the offer and issuing the RPSs), leads one to conclude on a possible collusion with the Company and its management. Further, Mr. Seikh Kutubuddin has also not taken any steps to remedy the violations committed. Accordingly, I hold Mr. Seikh Kutubuddinto be responsible for the same.

16. I note that the Company and its directors namely Mr. Biplab Kumar Dey, Ms. Juthika Ghosh, Mr. Seikh Kutubuddin and Mr. Chandan Sinha Roywere required to provide full inventory of the assets and properties within 21 days from the date of receipt of the interim order. However, no details have been submitted by these, till date.

17. In view of the discussion above, appropriate action in accordance with law needs to be initiated against the Company and the directors/ promoters in charge of the affairs of the Company, during the relevant period.

18. Therefore, I, in exercise of the powers conferred upon me under section 19 of the Securities and Exchange Board of India Act, 1992 read with sections 11 and 11B thereof hereby issue the following directions:

a. The Company, Everlight Realcon Infrastructure Limited [PAN: AACCE6725D], Mr. Biplab Kumar Dey [PAN: AHXPD7948N; DIN: 02550446], Ms. Juthika Ghosh [DIN:02888132], Mr. Seikh Kutubuddin [PAN: DNRPK1802D; DIN:06979183] and Mr. Chandan Sinha Roy [PAN: AJGPR9741N; DIN:03459797], jointly and severally, shall forthwith refund the money collected by the Company through the issuance of Redeemable Preference Shares (which have been found to be issued in contravention of the public issue norms stipulated under the Companies Act, 1956), to the investors including the money collected from investors, till date, pending allotment of RPS, if any, with an interest of 15% per annum compounded at half yearly intervals, from the date when the repayments became due (in terms of Section 73(2) of the Companies Act, 1956) to the investors till the date of actual payment.

b. The repayments to investors shall be effected only in cash through Bank Demand Draft or Pay Order.

c. The Company/ its present management are permitted to sell the assets of the Company only for the sole purpose of making the refunds as directed above and deposit the proceeds in an Escrow Account opened with a nationalised Bank.

d. The Company, its directors and other persons named above shall issue public notice, in all editions of two National Dailies (one English and one Hindi) and in one local daily with wide circulation, detailing the modalities for refund, including details on contact persons including names, addresses and contact details, within fifteen days of this Order coming into effect.

e. After completing the aforesaid repayments, the Company shall file a certificate of such completion with SEBI, within a period of three months from the date of this Order, from two independent peer reviewed Chartered Accountants who are in the panel of any public authority or public institution. For the purpose of this Order, a peer reviewed Chartered Accountant shall mean a Chartered Accountant, who has been categorized so by the Institute of Chartered Accountants of India (‘ICAI’).

f. In case of failure of the Company, Everlight Realcon Infrastructure Limited, its directors including Mr. Biplab Kumar Dey, Ms. Juthika Ghosh, Mr. Seikh Kutubuddin and Mr. Chandan Sinha Roy in complying with the aforesaid directions, SEBI, on expiry of three months from the date of this Order,- i. shall recover such amounts in accordance with section 28A of the SEBI Act including such other provisions contained in securities laws. ii. may initiate appropriate action against the Company, its promoters/ directors and the persons/ officers who are in default, including adjudication proceedings against them, in accordance with law. iii. would make a reference to the State Government/ Local Police to register a civil/ criminal case against the Company, its promoters, directors and its managers/ persons in-charge of the business and its schemes, for offences of fraud, cheating, criminal breach of trust and misappropriation of public funds; and iv. would also make a reference to the Ministry of Corporate Affairs, to initiate the process of winding up of the Company.

g. The Company namely Everlight Realcon Infrastructure Limited is directed not to, directly or indirectly, access the capital market by issuing prospectus, offer document or advertisement soliciting money from the public and is further restrained and prohibited from buying, selling or otherwise dealing in the securities market, directly or indirectly in whatsoever manner, from the date of this Order till the expiry of 4 years from the date of completion of refunds to investors, made to the satisfaction of SEBI, as directed above.

h. Mr. Biplab Kumar Dey, Ms. Juthika Ghosh, Mr. Seikh Kutubuddin and Mr. Chandan Sinha Roy are restrained from accessing the securities market and are further prohibited from buying, selling or otherwise dealing in securities, directly or indirectly, with immediate effect. They are also restrained from associating themselves with any listed public company and any public company which intends to raise money from the public, with immediate effect. This restraint shall continue to be in force for a further period of 4 years on completion of the repayments, as directed above.

i. The above directions shall come into force with immediate effect.

19. This Order is without prejudice to any action, including adjudication and prosecution proceedings that might be taken by SEBI in respect of the above violations committed by the Company, its promoters, directors and other key persons.

20. Copy of this Order shall be forwarded to the recognized stock exchanges and depositories for information and necessary action.

21. A copy of this Order shall also be forwarded to the Ministry of Corporate Affairs/concerned Registrar of Companies, for their information and necessary action with respect to the directions/restraint imposed above against the Company and the individuals.

Date : February 23rd, 2016 PRASHANT SARAN Place : Mumbai WHOLE TIME MEMBER SECURITIES AND EXCHANGE BOARD OF INDIA