Order in the matter of Pine Animation Limited[SAT Appeal No.:214/201676/2017]426/2016165/2017]396/2016]394/2016]357/2016]356/2016]64/2017][SAT Appeal No.:341/2016[SAT Appeal No.:340/2016[SAT Appeal No.:245/2016,[SAT Appeal No.:134/2016,[SAT Appeal No.:133/2016,[SAT Appeal No.:132/2016][SAT Appeal No.:122/2016,[SAT Appeal No.:121/2016,[SAT Appeal No.:120/2016,[SAT Appeal No.:119/2016,[SAT Appeal No.:118/2016,[SAT Appeal No.:117/2016,[SAT Appeal No.:116/2016]

WTM/RKA/ ISD/36/2015 SECURITIES AND EXCHANGE BOARD OF INDIA AD- INTERIM EX-PARTE ORDER UNDER SECTIONS 11(1), 11(4) AND 11B OF THE SECURITIES AND EXCHANGE BOARD OF INDIA ACT, 1992 IN THE MATTER OF PINE ANIMATION LIMITED. 1. Pursuant to detection of a huge rise in the traded volumes and price of the shares of Pine Animation Limited {formerly known as Four K Animation Limited and hereinafter referred to as "Pine"} on Bombay Stock Exchange Limited ("BSE") during the period from May 22, 2013 to January 30, 2015 (hereinafter referred to as "Examination Period"), Securities and Exchange Board of India ("SEBI") conducted a preliminary inquiry in the dealings in the scrip of Pine. 2. On May 20, 2013, the equity shares of Pine were split in the ratio 1:10 and thereafter between May 22, 2013 to June 19, 2013 ("Patch 1"), the price of the scrip increased from ₹ 472 (unadjusted and ₹ 47.2 adjusted to share split) on May 22, 2013 to ₹ 1006 (unadjusted and ₹ 100.6 adjusted to share split) on June 19, 2013 i.e. an increase by approximately 113%. Between June 20, 2013 and December 16, 2013, ("Patch 2") the scrip was traded only on 13 trading days and the price moved from ₹ 1006 (unadjusted and ₹ 100.6 adjusted to share split) to ₹ 910 (unadjusted and ₹ 91 adjusted to share split). Thereafter, there was a huge increase in the traded volume during the period December 17, 2013 to January 30, 2015 ("Patch 3"). The price of the scrip started falling from July 10, 2014 with volumes still being maintained and subsequently, there was a drastic fall in price from ₹ 707.5 (unadjusted and ₹ 70.75 adjusted to share split) on January 02, 2015 to ₹ 388.5 (unadjusted and ₹ 38.85 adjusted to share split) on January 30, 2015, in a span of 20 trading days. An illustration of the price/volume movement in the scrip of Pine during the Examination Period is given below:

800000 Pine Animation Limited 1500.00 600000 e 1000.00 m e u lo 400000 c ir P V 500.00 200000 0 0.00 3 3 3 3 3 3 3 3 4 4 4 4 4 4 4 4 4 4 4 4 5 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 y a 2 M 2 - - n 2 u 2 J - - l 2 u 2 J - - g u 2 A 2 - - p 2 e 2 S - - t c 2 O 2 - - v o 2 N 2 - - c e 2 D 2 - - No. n 2 a 2 J - - of S b 2 e 2 F - - hare r a 2 M 2 - - s r p 2 A 2 - - y a 2 M 2 - - Cl n 2 u 2 J - - ose l 2 u 2 J - - Pric g u 2 A 2 - - e p 2 e 2 S - - t c 2 O 2 - - v o 2 N 2 - - c e 2 D 2 - - n 2 a 2 J - -

Order in the matter of Pine Animation Limited

3. As per the quarterly shareholding pattern submitted to BSE, as on September 30, 2012, Pine had a share capital of ₹ 3,00,00,000 comprising 30,00,000 equity shares of ₹10 each, with the promoters holding 9,27,400 shares i.e. 30.91% of the total share holding. It was observed in the preliminary inquiry that: a) On December 13, 2012, Pine made a preferential allotment of 1,50,00,000 equity shares at the price of ₹ 10 per share (hereinafter referred to as the "1st preferential allotment") to 49 entities. b) Thereafter, the promoters namely, First Entertainment Private Limited and Unique image Production Pvt. Ltd. who were holding shares in the physical form, transferred their entire holdings i.e. 9, 27,400 shares to 6 entities, who in turn transferred the shares to 62 entities (the total of 68 entities, hereinafter referred to as "Promoter related entities ") during the period from December 28, 2012 to February 05, 2013. The list of all the Promoter related entities is annexed as Part I of Annexure A. 49 of the Promoter related entities subsequently sold 54.76% of the shares received from the promoters. c) Subsequently, on March 15, 2013, Pine made another preferential allotment of 97,00,000 equity shares at the price of ₹ 10 per share (hereinafter referred to as the "2nd preferential allotment") to 48 entities who included 5 entities who were allotted shares in the 1st preferential allotment. d) In total, Pine allotted 2,47,00,000 equity shares to 92 entities (List is annexed as Part II of Annexure A).

The equity shares allotted on preferential basis to aforesaid allottees were locked-in for a period of one year i.e. up to December 12, 2013 and March 14, 2014, respectively in terms of Securities and Exchange Board of India (Issue of Capital and Disclosure Requirements) Regulations, 2009. Thus, the shares held by 49 entities who were allotted shares in the 1st preferential allotment and shares held by 48 entities (including 5 entities who were allotted shares in the 1st preferential allotment) who were allotted shares in the 2nd preferential allotment were not tradable till December 12, 2013 and March 14, 2014 respectively. 4. On May 20, 2013, the equity shares of Pine were split in the ratio of 1:10. Consequently, the paid up share capital of Pine increased to ₹27,70,00,000 comprising 27,70,00,000 shares of ₹ 1 each, as on May 20, 2013. 5. From the Annual Reports of Pine for Financial Year ("FY") 2011-12 and FY 2012-2013, it was observed that it is in the business of animation and it had incurred a loss of ₹ 7,08,037 during 2011-12 and earned a profit of ₹ 15,60,007 during FY 2012-13, respectively.

From the Annual Report for the FY 2012-2013 it was observed that for the FY ended 2012 the earning per shares ("EPS") of Pine was negative (i.e. ₹ - 0.24) and for the FY ended March 31, 2013, EPS was ₹ 0.15. During the Examination Period there was no material corporate announcement made by Pine which could support such price rise in its scrip. Thus, the sharp rise in the price of the scrip of Pine during the Examination Period was not supported by its fundamentals or any other genuine factor. The scrip was listed on BSE on March 25, 1994 and was subsequently suspended from trading w.e.f November 09, 1998. The suspension on trading in the securities of the scrip was revoked w.e.f June 22, 2012, however, trading in the scrip started only on March 28, 2013. Also, the shareholding of the promoters in the company became nil on account of transfer of shares by the promoters to the Promoter related entities. Strangely, in spite of such fundamentals and tarnished track record of long period of suspension of trading, exit by the promoters and no available market price on account of no trading in the scrip, Pine was able to garner funds aggregating to ₹24,70,00,000 from aforesaid 92 entities at a premium of ₹ 10 per share within a short span of few months from the revocation of suspension.

Investment in a company having such poor and meagre fundamentals cannot prima facie be termed as rational investment behaviour. Such investments, as in this case, normally could be made if the allottees had a nexus with Pine and its directors/promoters and the issue of these shares was under a prior arrangement between them. 6. It was observed that within a short period after the 2nd preferential allotment, a significant increase in the price of the scrip took place and the price was maintained during the period of lock in on the shares allotted to the preferential allotees. Considering the fact that prior to the preferential allotments, there was no trading in the scrip of Pine, the increase in the traded volume in the period after the release of the lock-in period was found to be substantial. In light of the above, in order to observe the price volume behaviour of the scrip, the trading in the scrip was analysed in three Patches 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 7. On analysis of trading activity in the scrip of Pine, it was observed that, during the Examination Period, two sets /groups of entities were mainly involved.

While one group of entities was primarily involved in pushing the price up during Patch-1 (when the shares allotted in preferential allotments were under lock-in) by contributing to positive LTP through first trades with negligible order quantity, the other group of entities was acting as buyers in Patch-2 in order to provide exit to Preferential Allottees and in the process creating artificial volume. The role of these two groups is discussed in subsequent paragraphs.

8. During Patch 1 (May 22, 2013 to June 19, 2013), the price of the scrip opened at ₹ 472 on May 22, 2013 (unadjusted and ₹ 47.2 adjusted to share split). Thereafter, in 19 trading days, between May 22, 2013 to June 19, 2013, the price of the scrip increased to ₹ 1006 (unadjusted and ₹ 100.6 adjusted to share split). The average volume during the period was 62 shares, with 405 shares traded on May 28, 2013 being the highest. The price increased from ₹ 472 (unadjusted and ₹ 47.2 adjusted to share split) to ₹ 1006 (unadjusted and ₹ 100.6 adjusted to share split), through first trades by certain entities. It was noticed that these entities by putting 1 or 2 trade(s) per day with negligible/ very less quantity of buy orders contributed significantly to the price rise. 9. It was observed that in Patch 1, out of a total of 31 instances of trades establishing new high price in the scrip, six entities namely, Nellakkara Raghunath, Prem Lata Nahar, Dhirendra Kumar Gupta and Sons, J M S Financial Services Ltd., Sanjay Kumar Shah and Rajesh Kumar Shukla established new high price on 25 instances. The contribution of these six entities in establishing new high price was ₹45.75/- out of total price rise of ₹54.9/-, which constitutes 83.3% of the total new high price. The details of contribution to price rise by these six entities during Patch 1 are as under: Table 1 - Contribution to price rise in Patch 1 by six entities. PAN Name Name Positive LTP % to Total reflected in the Contribution Positive LTP Interim Order as a buyer Contribution - 17.15 31.2 AESPN9474K Nellakkara Raghunath Radford Global 9.85 17.9 Limited, First Financial AFAPN8764M Prem Lata Nahar Services Ltd - 8.2 14.9 Dhirendra Kumar Gupta AAFHD9092L And Sons Huf J M S Financial Services - AAACJ8428J Ltd. 4.4 8 - AJSPS5543F Sanjay Kumar Shah 3.15 5.7 - BGGPS9416R Rajesh Kumar Shukla 3 5.5 45.75 83.3 TOTAL 10. It is observed that the entity Prem Lata Nahar, named in the above Table was instrumental in contributing to the price rise of the scrips of Radford Global Limited and First Financial Services Limited and is already restrained from dealing in securities market in whatsoever manner vide interim orders dated December 19, 2014 in the scrips of Radford Global Limited and First Financial Services Limited for contributing to price rise in the respective scrips.

11. During Patch 2 (June 20, 2013 to December 16, 2013), the price of the scrip opened at ₹ 1006 (unadjusted and ₹ 100.6 adjusted to share split) on June 20, 2013 and closed at ₹ 910 (unadjusted and ₹ 91 adjusted to share split) on December 16, 2013. The volume continued to be insignificant, the highest being 200 shares on June 24, 2013 and the gross traded volume being 1254 shares. The scrip was traded only on 13 trading days during Patch 2. 12. During Patch 3 (December 17, 2013 to January 30, 2015), the price of the scrip opened at ₹ 921 (unadjusted and ₹ 92.1 adjusted to share split) on December 26, 2013 and closed at ₹ 385 (unadjusted and ₹ 38.5 adjusted to share split) on January 30, 2015. The scrip touched a high of ₹ 976.5 (unadjusted and ₹ 97.65 adjusted to share split) on January 01, 2014. During this period, the scrip was traded with an average volume of 2,74,922 shares per day and total volume of 7,36,79,112 shares in 268 trading days. As compared to Patch 1, the average volume in Patch 3 increased by around 4433 times. 13. On analysis of trading activity during Patch 3, certain entities related/connected to Pine were found to be the net buyers to the Preferential Allottees/Promoter related entities and thereby created artificial demand for the supply of shares from Preferential Allottees/Promoter related entities.

During Patch 3, significant increase in the trading volume was observed. It was also observed that a group of connected/related entities were acting as counterparties to the trades done by the Preferential allottees/Promoter related entities. Also on further examination, direct/indirect relationship was established among these entities through Know Your Client ("KYC") details, bank statements, off-market transactions amongst them and the information available on the Ministry of Corporate Affairs ("MCA") website. List of these entities is annexed as Part III of Annexure – A and hereinafter they shall be referred to as the "Exit Providers". Since the Exit Providers, Preferential Allottees and Promoter related entities have been prima facie found to be connected/ related to Pine / its promoters/ directors, they shall hereinafter collectively be referred to as "Pine Group". 14. Considering the large number of these related/connected entities, it was deemed necessary to shortlist those who have bought/sold in the scrip on the basis of the gravity of their conduct and the nature of the prima facie evidence available in the matter.

A set of 158 entities (hereinafter referred to as the "Shortlisted Group") were shortlisted on the basis of following parameters: A. All the Exit Providers. B. All the Preferential Allottees who have sold Pine's shares. C. All the Promoter related entities who received shares directly from the promoters and subsequently transferred the same to other Promoter related entities. D. All the Promoter related entities who have sold shares more than ₹ 1,00,00,000 as sale value, in the market, individually or collectively with other Promoter related entities connected/related to them. 15. The particulars of the above mentioned Shortlisted group are given in the following table:

Table 2 - List of Shortlisted Entities PROMOTER RELATED ENTITIES S. No. PAN NAME 1 AAECG2103R GAJAKARNA TRADING PVT LTD 2 AAHCM1333N MAHAGANAPATI FINANCIAL SERVICES PVT LTD 3 AAFPJ6734M NIMESH S JOSHI 4 AGSPJ6909M ROSHNI N JOSHI 5 AGYPK8780F HITESH N KAWA 6 ANMPK4236D ROOPAL H KAWA 7 ALDPG8381J AKASH RANCHHODBHAI GOLAKIA 8 ABFPK6567J ALOK NAVINCHANDRA KUBADIA 9 AEZPD5474N BINA DEVI DHANUKA 10 AEEPG1294G CHINTAN RANCHHODBHAI GOLAKIA 11 ADQPD6035P MADAN MOHAN DHANUKA 12 ABEPJ7142D MADANLAL JAIN 13 ACTPC4078P MANISHA NARPATKUMAR CHOPRA 14 ADLPD5568J MAYANK DHANUKA 15 ABEPJ7147G MOOLCHAND JAIN 16 ADOPB3260E NEHA DHANUKA 17 ADNPD6220D NIKUNJ DHANUKA 18 ADUPD7020N RAJKUMARI DHANUKA 19 AAYPG3878J RANCHHODBHAI JASMATBHAI GOLAKIA 20 ADLPD0494K UMANG DHANUKA 21 AAWPG3157A VIJUBEN RANCHHODBHAI GOLAKIA 22 ADIPJ9498C MUKESH KUMAR JAIN 23 AFOPJ4431P VIKAS JAIN 24 ACIPM0237D SHAKUNTALA MARU 25 ADUPM7778C PARAS CHAND MARU 26 AJWPM1991R SAURABH MARU 27 AABPF1503E SUSHILKUMAR SHRIBHAGWAN FATEHPURIA 28 AABPF1507A UMADEVI SUSHILKUMAR FATEHPURIA 29 AAGHD3018R DEEPAK AGARWAL HUF 30 AADHG0808H GOVIND AGARWAL HUF 31 ABFPB2995P PANKAJKUMAR RAJKUMAR BARIA 32 AFTPB8600D POONAM PANKAJ BERIA 33 AAPPA6950Q RAJKUMAR BUDHRAM AGARWAL 34 AAPPA6951R PINKY RAJKUMAR AGRAWAL 35 AAEPJ9602R SUDHESH JAJOO 36 AAEPJ9603Q SUNIL JAJOO 37 AALPJ9756B SNEHLATA JAJOO 38 AALPJ9757A KIRAN JAJOO 39 AAMPJ0021E ANURADHA JAJOO 40 AARPJ7854N OMPRAKASH JAJOO 41 ABVPN8122C HEENA HITENDRA NAGDA 42 AGKPB3602K DARSHAN D BHANUSHALI

AAEPG6708K ASHISH GOEL PREFERENTIAL ALLOTEES S.No. PAN NAME 1 AGMPK5927A ANIL KUMAR KASARANENI 2 AABPD9375L ANIL VISHANJI DEDHIA 3 ADZPC5979N ANILKUMAR CHAMANLAL 4 AACPM1902D ANKIT RAJIDERKUMAR MIGLANI 5 AEUPB3427L ANMOL PRAKASH BABANI 6 AREPS5118G ARCHANA MIGLANI 7 AANPS2300L ARCHANA SALUJA 8 AEKPM9977L ARVIND CHHOTALAL MORZARIA 9 AAAPB5499G BALCHAND JAIN 10 AEFPS6298M BRIJ BHUSHAN SINGAL 11 ABAPL3679D BRIJESH CHOWDHARY LAVU 12 ADPPR2047A DAMJI ANANDJI RAMBHIA 13 AAAPP9409N GOPAL NIHCHALDAS PARIANI 14 AAAHH5526G HARESH RAWANI HUF 15 AEIPG1584P HEMANT JAYANT GOGRI 16 AAEPS8716P HIRJI MORARJI SHAH 17 AJLPC9910H JAY HANSRAJ CHHEDA 18 AAIPS4820L KANTILAL LALJI SHAH 19 AADPB1550B KAUSHAL KANHAYALAL BAGADIA 20 ACMPM6181A KISHOR PRANJIVAN MEHTA 21 AEUPB2920C KUNAL RAMESH BABANI 22 AEBPM1654H MAHENDRA BMITTAL 23 AACPP0931H MAHENDRA PANDHI 24 AAEPG6125C MAYUR ISHVARDAS GANDHI 25 AABPM6332L MIGLANI ANUJ RAJINDER 26 AAJPI8348E MONESH ISRANI 27 AALPS7124C NARESHKUMAR KISHANLAL SARAF 28 AFPPM2107Q NEELAM MOR 29 AAAPV9144N NEENA SUDHIR VORA 30 ADSPA3332J NEHA BANSAL 31 AACPG7709G PANKAJ DHANJI GOSHAR 32 BGGPM9415G PEEYUSH MAKHIJA 33 ACHPB0564H POOJAMAHENDRA MITTAL 34 AAEPS7956D POONAM KAUSHAL BAGADIA 35 AABPS7441L PRADIP DAMJI SHAH 36 AAHHP7899B PRAKASH HIRALAL JAIN HUF 37 ABAPA2027N PRAVEEN KUMAR ARORA 38 APZPV0747H PRITHVI SUDHIR VORA 39 AADPR1704M PRIYANKA HARESH RAWANI 40 ARIPS3477L PRIYANKA MIGLANI 41 AAZPM0573H RAJESH CHAMPAKLAL MEHTA 42 ABSPJ2879F RAJESH DURGASHANKAR JOSHI 43 ABHPA9244J SADHA RANI

44 AATHS9775H SANJAY DNYANESHWER NIKAM HUF 45 ADQPT9711L SANTOSH YASHWANT TANDEL 46 AEJPB6903J SAVITA BANSAL 47 AKYPB3382J SHARAN MOHAN BABANI 48 ALVPM6130D SUNNY MIRCHANDANI 49 AAACT8706B TVC SHARES STOCK & INVESTMENT PVT LTD 50 AAAPH6194E VASUDEV MAHIRWAN HEMRAJANI 51 AADHA7870F ASHOK JAIN HUF 52 AAQPS5640E LATA V SHAH EXIT PROVIDERS S.No. PAN NAME 1 BABPS7447D AMIT SINGH 2 AAJCA1784D ANJALI SUPPLIERS PRIVATE LIMITED 3 AALCA7880J ANTARYAMINI TRADERS PRIVATE LIMITED 4 AAJCA4459K APEX COMMOTRADE PRIVATE LIMITED LTD 5 AABCB3052B BAZIGAR TRADING PRIVATE LIMITED 6 AAFCB0211J BLUE HORIZON COMMOSALES PRIVATE LIMITED 7 AABCB0636K BSR FINANCE AND CONSTRUCTION LTD 8 AABCB2575P BURLINGTON FINANCE LIMITED 9 AAECC9285A CHEROOT VANIJYA PVT LTD 10 AADCD7140G DEVATMA DISTRIBUTORS PRIVATE LIMITED 11 AADCD6028P DHANRAKSHA VINCOM PRIVATE LIMITED 12 AAECD8235D DHLRITI TRADERS PRIVATE LIMITED 13 AAECD8010E DHYANESHWAR DEALERS PVT LTD 14 AABCD8146J DIVYA DRISHTI TRADERS PVT LTD 15 AABCD8147K DIVYADRISHTI MERCHANTS PVT LTD 16 AADCD7017J DOVE SUPPLIERS PVT LTD 17 AAECD5782B DREAMLIGHT EXIM PRIVATE LIMITED 18 AADCD0633J DREAMVALLEY TRADING PRIVATE LIMITED 19 AAECD9323N DUARI MARKETING PRIVATE LIMITED 20 AAACE2862P ESHA SECURITIES LTD 21 AABCF5486H FUNCTION FINANCIAL CONSULTANTS PRIVATE LIMITED 22 AAFCG2554B GAJGAMINI MERCHANDISE PRIVATE LIMITED 23 AAFCG5351A GANGESHWARI TRADERS PRIVATE LIMITED 24 AAFCG4773J GOLDENSIGHT TRADERS PRIVATE LIMITED 25 AADCH3599R HANSHIKA DEALERS PRIVATE LIMITED 26 AACCH8885R HELOT PROPERTIES PRIVATE LIMITED 27 AACCH4303G HELPFUL INVESTMENT ADVISORY PRIVATE LIMITED 28 AADCI5139E INDRAWATI NIRMAN PVT LTD 29 AAECK7329P KAPEESHWAR VINTRADE PVT LTD 30 AACCL3868N LADIOS TRADING PRIVATE LIMITED 31 AADCR9508C LINUS HOLDINGS LTD 32 AAICM4750C MOBIXA DISTRIBUTORS PRIVATE LIMITED 33 AAICM6982C MUCHMORE VINCOM PRIVATE LIMITED 34 AACCN9567A NAVDURGA INVESTMENT CONSULTANTS PVT LTD 35 AABCO2236J ORCHID SOLUTION PRIVATE LIMITED

36 AABCO6950F OVERLOAD FINANCIAL ADVISORY PVT LTD 37 AAACL4269P PADMA IMPEX PRIVATE LIMITED 38 AACCM6582E PRIDE DISTILLERY PRIVATE LTD 39 AAGCR6009M RAMYA MERCANTILE PVT LTD 40 AAGCR1715E RANGAN VINCOM PRIVATE LIMITED 41 AAECR2312K RANGOLI DISTRIBUTORS PRIVATE LTD 42 AAFCR9881C REACHSMART DEALTRADE PRIVATE LIMITED 43 AAGCR8144M REACHSMART DEVELOPERS PRIVATE LIMITED 44 AAECR9858C RIDHI VINCOM PRIVATE LIMITED 45 AAGCR8142P ROCHAK VINIMAY PRIVATE LIMITED 46 AAGCR7017M ROCHI DEALCOM PRIVATE LIMITED 47 AAECR0580M RUNICHA MERCHANTS PRIVATE LIMITED 48 ACIPS8803M S N SRINIVASAN 49 AAMCS1711P SANKLAP VINCOM P LTD 50 AARCS9144H SEBIKA COMMODITIES PVT LTD 51 AAPCS7850L SHIVKHORI CONSTRUCTION PRIVATE LIMITED 52 AATCS3687H SIDHIMAN VYAPAAR PRIVATE LIMITED 53 AAMCS1712Q SIGNET VINIMAY PRIVATE LIMITED 54 AAICS0688K SKM TRAVELS PRIVATE LIMITED 55 AAOCS2216D SPARK COMMODEAL PRIVATE LIMITED 56 AAPCS7492G SPICE MERCHANTS PRIVATE LIMITED 57 AAJCS0597G SWARNA PUSHPA VANIJYA PRIVATE LIMITED 58 AATCS6718D SWARNPRAKASH TRADERS PRIVATE LIMITED 59 AADCS5411K SYMPHONY MERCHANT PVT LTD 60 AADCT8403C TOPWELL PROPERTIES PRIVATE LIMITED 61 AAACV8378B VIBGYOR FINANCIAL SERVICEPVT LTD 62 AAECV4988P VISHNUDHAM MARKETING PRIVATE LIMITED 63 AAACW8004B WINALL VINIMAY PRIVATE LIMITED LTD 16. It is observed that during Patch 3, the Preferential Allottees/Promoter related entities were net sellers and the Exit Providers were net buyers, a snapshot of which is given below:-

Table 3 - Exit provided by Exit Providers to Preferential Allottees No. of % of Shares purchased Total No. of % volume of Shares shares sold total by Exit Providers shares shares purchased by allotted/ from preferential purchased purchased by Exit received allotees/promote by the Exit Exit Providers Providers shares d related entites Providers from as% of preferential market gross allotees/Promo buy volume ter related entities Preferential 5,23,08,076 21.18 - - - - Allottees Promoter 50,78,455 54.76 - - - -related entities Exit Provider - - 2,82,65,949 3,47,34,934 81.38% 47.14% Group

17. As it can be observed from Table 3, most of the trades took place between the Preferential Allottees /Promoter related entities and Exit Providers. During this period, the Preferential Allottees/ Promoter related entities were found to be selling and in this process making a huge profit/gain. It was observed that Exit Providers contributed 47.14% to the gross buy trade during Patch 3. The details of counter parties for sale transactions by preferential allotees/Promoter related entities is given below:

Table 4 - Counter parties for sale transactions by preferential allotees/Promoter related entities % of shares bought from Total no. of Promoter shares related purchased entities from /preferential % to promoter allotees to market related/prefe Gross buy the gross buy gross S.N rential volume in volume of the buy o. PAN Name allotees Patch 3 exit provider volume DREAMVALLEY TRADING PRIVATE 1 AADCD0633J LIMITED 3459200 3797376 91.09 5.15 RANGOLI DISTRIBUTORS 2 AAECR2312K PRIVATE LTD 1608411 1755756 91.61 2.38 3 AADCR9508C LINUS HOLDINGS LTD 1551830 1992505 77.88 2.70 ORCHID SOLUTION 4 AABCO2236J PRIVATE LIMITED 1306167 1480408 88.23 2.01 INDRAWATI NIRMAN 8 AADCI5139E PVT LTD 1032824 1314641 78.56 1.78 HANSHIKA DEALERS 5 AADCH3599R PRIVATE LIMITED 1015335 1505943 67.42 2.04 DHLRITI TRADERS 22 AAECD8235D PRIVATE LIMITED 956669 1612131 59.34 2.19 GANGESHWARI TRADERS PRIVATE 7 AAFCG5351A LIMITED 956116 1134158 84.30 1.54 SPICE MERCHANTS 6 AAPCS7492G PRIVATE LIMITED 927945 1285981 72.16 1.75 ROCHAK VINIMAY 9 AAGCR8142P PRIVATE LIMITED 859672 1412932 60.84 1.92 DUARI MARKETING 10 AAECD9323N PRIVATE LIMITED 853980 963742 88.61 1.31 VISHNUDHAM MARKETING PRIVATE 11 AAECV4988P LIMITED 772648 853654 90.51 1.16 SEBIKA COMMODITIES 13 AARCS9144H PVT LTD 720449 930499 77.43 1.26 SPARK COMMODEAL 12 AAOCS2216D PRIVATE LIMITED 705374 740500 95.26 1.01 15 AAACE2862P ESHA SECURITIES LTD 6 7 0 6 4 4 700150 95.79 0.95 REACHSMART DEVELOPERS PRIVATE 20 AAGCR8144M LIMITED 666670 820282 81.27 1.11 DREAMLIGHT EXIM 18 AAECD5782B PRIVATE LIMITED 647703 726610 89.14 0.99

RIDHI VINCOM PRIVATE 14 AAECR9858C LIMITED 632995 654790 96.67 0.89 DOVE SUPPLIERS PVT 21 AADCD7017J LTD 624434 995519 62.72 1.35 APEX COMMOTRADE 17 AAJCA4459K PRIVATE LIMITED LTD 618981 904787 68.41 1.23 DHANRAKSHA VINCOM 16 AADCD6028P PRIVATE LIMITED 615991 676045 91.12 0.92 ANJALI SUPPLIERS 19 AAJCA1784D PRIVATE LIMITED 567120 449784 126.09 0.61 MOBIXA DISTRIBUTORS 23 AAICM4750C PRIVATE LIMITED 518083 483330 107.19 0.66 SIDHIMAN VYAPAAR 24 AATCS3687H PRIVATE LIMITED 469346 451088 104.05 0.61 GOLDENSIGHT TRADERS 27 AAFCG4773J PRIVATE LIMITED 411950 446000 92.37 0.61 ANTARYAMINI TRADERS 25 AALCA7880J PRIVATE LIMITED 367114 478572 76.71 0.65 GAJGAMINI MERCHANDISE PRIVATE 26 AAFCG2554B LIMITED 359150 606936 59.17 0.82 DHYANESHWAR 31 AAECD8010E DEALERS PVT LTD 337363 360763 93.51 0.49 RAMYA MERCANTILE 40 AAGCR6009M PVT LTD 321300 790516 40.64 1.07 DEVATMA DISTRIBUTORS PRIVATE 29 AADCD7140G LIMITED 314466 344566 91.26 0.47 KAPEESHWAR 28 AAECK7329P VINTRADE PVT LTD 307500 374550 82.10 0.51 SWARNPRAKASH TRADERS PRIVATE 30 AATCS6718D LIMITED 299619 346134 86.56 0.47 HELOT PROPERTIES 35 AACCH8885R PRIVATE LIMITED 202101 267156 75.65 0.36 MUCHMORE VINCOM 32 AAICM6982C PRIVATE LIMITED 198807 227000 87.58 0.31 FUNCTION FINANCIAL CONSULTANTS PRIVATE 38 AABCF5486H LIMITED 184000 187000 98.40 0.25 REACHSMART DEALTRADE PRIVATE 33 AAFCR9881C LIMITED 176545 208635 84.62 0.28 OVERLOAD FINANCIAL 34 AABCO6950F ADVISORY PVT LTD 173556 212556 81.65 0.29 BLUE HORIZON COMMOSALES PRIVATE 37 AAFCB0211J LIMITED 170434 214184 79.57 0.29 ROCHI DEALCOM 36 AAGCR7017M PRIVATE LIMITED 160758 200758 80.08 0.27 WINALL VINIMAY 39 AAACW8004B PRIVATE LIMITED LTD 159800 202000 79.11 0.27 VIBGYOR FINANCIAL 41 AAACV8378B SERVICEPVT LTD 146117 189000 77.31 0.26 DIVYADRISHTI 42 AABCD8147K MERCHANTS PVT LTD 141000 156999 89.81 0.21 HELPFUL INVESTMENT ADVISORY PRIVATE 44 AACCH4303G LIMITED 140625 161000 87.34 0.22 43 AADCT8403C TOPWELL PROPERTIES 125000 125000 100.00 0.17

PRIVATE LIMITED PADMA IMPEX PRIVATE 45 AAACL4269P LIMITED 100100 126700 79.01 0.17 RANGAN VINCOM 46 AAGCR1715E PRIVATE LIMITED 82344 89244 92.27 0.12 DIVYA DRISHTI 47 AABCD8146J TRADERS PVT LTD 81000 90900 89.11 0.12 SIGNET VINIMAY 48 AAMCS1712Q PRIVATE LIMITED 80704 85500 94.39 0.12 LADIOS TRADING 49 AACCL3868N PRIVATE LIMITED 71889 75089 95.74 0.10 CHEROOT VANIJYA PVT 52 AAECC9285A LTD 57150 104895 54.48 0.14 SKM TRAVELS PRIVATE 50 AAICS0688K LIMITED 55000 66000 83.33 0.09 SHIVKHORI CONSTRUCTION PRIVATE 51 AAPCS7850L LIMITED 55000 55000 100.00 0.07 PRIDE DISTILLERY 53 AACCM6582E PRIVATE LTD 47900 55000 87.09 0.07 54 ACIPS8803M S N SRINIVASAN 42000 71000 59.15 0.10 NAVDURGA INVESTMENT 55 AACCN9567A CONSULTANTS PVT LTD 38000 38000 100.00 0.05 SYMPHONY MERCHANT 56 AADCS5411K PVT LTD 30000 30000 100.00 0.04 RUNICHA MERCHANTS 57 AAECR0580M PRIVATE LIMITED 20000 28100 71.17 0.04 BAZIGAR TRADING 58 AABCB3052B PRIVATE LIMITED 20000 20000 100.00 0.03 59 BABPS7447D AMIT SINGH 15000 37000 40.54 0.05 BSR FINANCE AND 60 AABCB0636K CONSTRUCTION LTD 7000 7000 100.00 0.01 SWARNA PUSHPA VANIJYA PRIVATE 61 AAJCS0597G LIMITED 3470 3470 100.00 0.00 63 AAMCS1711P SANKLAP VINCOM P LTD 3000 3000 100.00 0.00 BURLINGTON FINANCE 62 AABCB2575P LIMITED 600 7100 8.45 0.01 GRAND TOTAL 28265949 34734934 81.38 47.14 18. During the same period, the Preferential Allottees were found to be selling and in the process making a huge profit/gain. It is observed that 52 allottees made a collective profit of ₹ 453.02 crore on a collective investment of ₹5.23 crore, a whopping return of approximately 8661% on their investment in a period of 25 months (including the lock in period of the shares allotted in the preferential allotment). This profit was obtained in a stock where the fundamentals/ financials of the company do not justify the price. It is evident from the above analysis of Patch 3 that the Exit Providers provided a hugely profitable exit to the allottees. The profit/gain earned by the allottees during Patch 3 is given below:-

Table 5- Profit made by the Preferential Allottees Cost purchase of shares pre- No. of No. of split at the Profit earned shares shares rate of ₹ 10 Gross sell on the sale of PAN Name alloted sold per share value shares Pankaj Dhanji AACPG7709G Goshar* 600000 10690000 10690000 886739695.1 876049695.1 Miglani Anuj AABPM6332L Rajinder 450000 4750000 4750000 417632486.1 412882486.1 Damji Anandji ADPPR2047A Rambhia 300000 3000000 3000000 274482750 271482750 Nareshkumar AALPS7124C Kishanlal Saraf 250000 2500000 2500000 233471791.3 230971791.3 AREPS5118G Archana Miglani 400000 2430000 2430000 214649485.6 212219485.6 Prakash Hiralal AAHHP7899B Jain HUF 200000 2183180 2183180 201325339.5 199142159.5 ARIPS3477L Priyanka Miglani 400000 2161000 2161000 191785800 189624800 ALVPM6130D Sunny Mirchandani 2 0 0000 2000000 2000000 165202252 163202252 Ankit Rajiderkumar AACPM1902D Miglani 440000 1519617 1519617 131408264.8 129888647.8 AEBPM1654H Mahendra Bmittal 150000 1500000 1500000 141936826.5 140436826.5 Poojamahendra ACHPB0564H Mittal 150000 1500000 1500000 142097414.5 140597414.5 AFPPM2107Q Neelam Mor 200000 1421000 1421000 115230995 113809995 AAJPI8348E Monesh Israni 200000 1125300 1125300 97848475 96723175 Anilkumar ADZPC5979N Chamanlal 300000 1000000 1000000 88654200 87654200 Hemant Jayant AEIPG1584P Gogri 100000 1000000 1000000 94448750 93448750 Kaushal AADPB1550B Kanhayalal Bagadia 100000 1000000 1000000 85655286.75 84655286.75 Poonam Kaushal AAEPS7956D Bagadia 100000 1000000 1000000 85593212.5 84593212.5 Anil Kumar AGMPK5927A Kasaraneni 200000 928500 928500 79430050 78501550 AABPS7441L Pradip Damji Shah 300000 890500 890500 79999725 79109225 Gopal Nihchaldas AAAPP9409N Pariani 200000 800000 800000 72897825 72097825 AAEPS8716P Hirji Morarji Shah 1 5 0 0 00 800000 800000 71760750 70960750 AADHA7870F Ashok Jain HUF 200000 563304 563304 48605246.6 48041942.6 Arvind Chhotalal AEKPM9977L Morzaria 200000 543900 543900 45978910 45435010 Haresh Rawani AAAHH5526G Huf 150000 500000 500000 45628900 45128900 Anil Vishanji AABPD9375L Dedhia 350000 475000 475000 40597000 40122000 AAIPS4820L Kantilal Lalji Shah 250000 469000 469000 37720230.3 37251230.3 Rajesh Champaklal AAZPM0573H Mehta 250000 448000 448000 36228835.35 35780835.35 Jay Hansraj AJLPC9910H Chheda 150000 425500 425500 39818275 39392775 ACMPM6181A Kishor Pranjivan 250000 418481 418481 33494087.45 33075606.45

Mehta AAAPB5499G Balchand Jain 200000 391994 391994 31614679 31222685 Priyanka Haresh AADPR1704M Rawani 150000 300000 300000 26845250 26545250 AEJPB6903J Savita Bansal 140000 300000 300000 28256750 27956750 ABHPA9244J Sadha Rani 120000 297000 297000 27895200 27598200 TVC Shares Stock & Investment Pvt AAACT8706B Ltd 300000 280000 280000 26596870.75 26316870.75 AANPS2300L Archana Saluja 2 5 0 0 00 270000 270000 22995750 22725750 AAAPV9144N Neena Sudhir Vora 150000 268000 268000 24731400 24463400 BGGPM9415G Peeyush Makhija 100000 266000 266000 22223694.05 21957694.05 Mayur Ishvardas AAEPG6125C Gandhi 200000 241000 241000 21957488.5 21716488.5 Prithvi Sudhir APZPV0747H Vora 150000 209000 209000 19526325 19317325 Rajesh ABSPJ2879F Durgashankar Joshi 300000 200000 200000 18787500 18587500 Santosh Yashwant ADQPT9711L Tandel 150000 189000 189000 17456750 17267750 Brijesh Chowdhary ABAPL3679D Lavu 300000 148000 148000 13388300 13240300 ADSPA3332J Neha Bansal 100000 147000 147000 13784500 13637500 Praveen Kumar ABAPA2027N Arora 100000 134500 134500 10898100 10763600 Brij Bhushan AEFPS6298M Singal 1200000 125000 125000 11847500 11722500 Sanjay Dnyaneshwer AATHS9775H Nikam Huf 300000 100800 100800 9223120 9122320 Vasudev Mahirwan AAAPH6194E Hemrajani 150000 95000 95000 8888471.65 8793471.65 Anmol Prakash AEUPB3427L Babani 150000 84500 84500 6840575 6756075 Kunal Ramesh AEUPB2920C Babani 150000 84500 84500 6831825 6747325 Sharan Mohan AKYPB3382J Babani 150000 84500 84500 6838475 6753975 AACPP0931H Mahendra Pandhi 1 5 0 0 0 0 50000 50000 4760250 4710250 AAQPS5640E Lata V Shah* 6,00,000 Total 1,13,50,000 5,23,08,076 5,23,08,076 458,25,11,633.15 453,02,03,557.15 * - Lata V Shah transferred 60,00,000 shares allotted through preferential allotment to Pankaj Dhanji Goshar on 05/08/2014 through an off-market transaction, which was subsequently sold in the market by Pankaj Dhanji Goshar

19. The transactions wherein the Exit Providers bought most of the shares sold by the Preferential Allottees and Promoter related entities cannot be just a coincidence particularly when sellers have nexus with Pine and its promoters/directors by virtue of being Preferential allotees/ Promoter related entities and other factors mentioned in Annexure –A. It is interesting to note that in Patch 1, 92.52% of the share capital of Pine was with the Preferential Allottees and the Promoter related entities. From the analysis presented for Patch 1 and 2, it was established that the shares of Pine were not in demand by the general investors of the market and saw very low volume on most of the trading days and hence could not have commanded the price as observed in Patch 3. In any market, a sudden supply if not matched by similar demand leads to price fall. Considering the same, any rational investor would not have dumped a large number of shares without facing the risk of a significant price fall until and unless he was sure of the demand side absorbing the supply. In this peculiar case, the Exit Providers created the demand against the supply from the Preferential Allottees/ Promoter related entities. In the whole process, the principle of price discovery was kept aside and the market lost its purpose. It is evident from the above analysis that the Exit Providers provided a hugely profitable exit to the Preferential Allottees/ Promoter related entities. This could be only possible if Pine and its promoters/directors, Preferential Allottees, Promoter related entities and the Exit Providers were hand in glove with each other.

20. From the above examination and factors as described in Annexure A, I am of the prima facie view that Pine, Preferential Allottees, Promoter related entities and Exit Providers are connected to each other. In this regard, I note that the Hon’ble SAT has held in many cases such as Classic Credit Ltd. Vs. SEBI (SAT Appeal No. 68/2003, Order dated December 8, 2006), Classic Credit Ltd. Vs. SEBI (SAT Appeal No. 76/2003, Order dated January 09, 2007) and Veronica Financial Services Ltd Vs. SEBI (SAT Order dated August 24, 2012) that connection/relations can be established on the basis of factors including common addresses, common directors/shareholders, etc.

21. It is pertinent to mention that the key to the scheme of operations employed by Pine Group, prima facie, lies in the preferential allotment of shares made by Pine. Due to a lock-in of one year on shares, any gains made on the sale of such shares makes the allottees eligible for long term capital gains (“LTCG”). Further, the promoters of Pine namely, First Entertainment Private Limited and Unique image Production Pvt. Ltd, by offloading the shares to its connected entities in physical form and the entities selling the shares, after holding it for a period of one year, have also made the transferees eligible for LTCG. From the observations of the preliminary inquiry, it is inter alia noted that:

 As on December 2012, Pine had 373 shareholders, with the two promoters (i.e. First Entertainment Private Limited and Unique image Production Pvt. Ltd ) holding 9,27,400 shares i.e. 30.91% of shares.  Thereafter, the aforesaid two promoters transferred a total of 927400 shares to 68 entities directly/indirectly during the period December 28, 2012 to February 05, 2012.  In the meantime, Pine also allotted 1,50,00,000 shares to 49 related/ associated entities, at a price of ₹ 10 per share.

 Subsequently, Pine allotted 97,00,000 shares at a price of ₹ 10 per share to 48 entities including 5 entities who were allotted shares in the 1st Preferential Allotment.  Thereafter, suddenly trading started in the scrip of Pine from March 28, 2013 with very low volumes.  As on May 20, 2013, 92.52% of share capital of Pine was with the Promoter related entities and Preferential allotees.  Pine announced a stock-split in the ratio of 1:10 on May 20, 2013 and also in the meanwhile, the price of the scrip increased exponentially, from ₹ 472 (unadjusted and ₹ 47.2 adjusted to share split) on May 20, 2013 to ₹ 1006 (unadjusted and ₹ 100.6 adjusted to share split) on June 19, 2013. The said increase in the price was not backed by fundamentals of Pine and its financials.  Once the lock-in period ended i.e. from December 17, 2013, the preferential allotees started selling the shares to entities connected/ related, directly or indirectly to Pine, thereby making huge profits. The Promoter related entities, also, around the same time started selling their shares, after holding them for a period of one year.

22. From the facts stated above, it can safely be assumed that the entire modus operandi of allotting shares on a preferential basis, announcing a stock split and then bringing in connected entities to provide exit was a scheme devised to make ill-gotten gains. Further, the modus operandi of pumping the share price artificially and then dumping the price so that the same cycle could be repeated, demonstrates the mala fide of the Pine Group. Also the mechanism is presumably being used to deceive the authorities by laundering black money and making tax-free profits.

23. Further, from the copies of the special resolution, passed under section 81(1A) of the Companies Act, 1956 as available on BSE website it is noted that Pine had disclosed to its shareholders and public that the purpose of aforesaid fund raising through preferential allotment was to fulfil the additional funding requirements of the company for acquisition and development of moveable and immovable property.

24. During preliminary inquiry it was observed from the bank statement of Pine that money received through two preferential allotments of equity shares were immediately transferred to the following entities:-

Table 6 - Transfer of money after the preferential allotment 1st Preferential Allotment Entities Values (₹) (approx.) Albright Consultants 2,00,00,000.00 Associated Finman Ltd 1,00,00,000.00 Biharji Constructions 25,00,000.00 Blue Circle Services 1,50,00,000.00

Denim Developers 50,00,000.00 Divya Momaya 9,25,000.00 Mehta Equities Ltd. 1,10,00,000.00 Newage Markting Ltd 1,00,00,000.00 Nextgen Infotel Pvt 1,00,00,000.00 Nirnidhi consultant 1,00,00,000.00 Pyramid Trading 1,60,00,000.00 RavindraKumar Grover 95,00,000.00 TOTAL 11,99,25,000.00 2nd Preferential Allotment Entities Values (₹) (approx.) N R Gada and Associates 12,00,000 Advent Neel Realty 50,00,000 Ajay A Rai 1,00,00,000 Divya Sameer Momaya 5,00,000 Laurus Textiles Pvt Ltd 10,00,000 Shubh Associates 50,00,000 Mehta Equities Ltd 7,25,00,000 Bihariji Constructions 25,00,000 Pyramid Trading & Finance 30,00,000 TOTAL 10,07,00,000

25. From the bank statement analysis of Pine, it is observed that funds received as proceeds of preferential allotment were immediately transferred to various entities on the same day or in a matter of next three days and was never retained in the company for executing its plans as envisaged in the special resolution passed under section 81(1A) of the Companies Act, 1956. Incidentally, some of the entities who received funds from Pine such as Pyramid Trading & Finance (presently known as Mishka Trading & Finance Ltd.), Blue Circle Services Ltd., have already been restrained from dealing in securities market in whatsoever manner, vide interim orders dated April 17, 2015 and December 19, 2014, for their dealings in the scrips of Mishka Trading & Finance Ltd. and First Financial Services Ltd, for a similar modus operandi. Other entities such as Albright Consultants and Nirnidhi Consultants were found to be connected to Blue Circle Services Ltd. Further, the directors of Bihariji Constructions namely, Umang Dhanuka, Bina Devi Dhanuka, Mayank Dhanuka and Rajkumari Dhanuka are among the Promoter related entities.

26. Further, it is also observed that prior to receipt of the proceeds of the preferential allotments, the fund available in the bank account of the company would not have been sufficient enough for transfers to various entities, as mentioned at Table – 6 above.

27. On analysis of the Annual Reports of Pine for FY 2012-13 and FY 2013-14, it is observed that the Pine's revenue from operations increased from ₹ 8,94,000 for the year ending March 31, 2012 to ₹ 8,76,36,983 for the year ending March 31, 2013 i.e. an exponential growth in the revenue by 9703%. Similarly, the revenue from operations increased from ₹

8,76,36,983 for the year ending March 31, 2013 to ₹ 86,13,67,052 for the year ending March 31, 2014, which again was an exponential increase of 883%. On further examination of the "Management Discussion and Analysis" part of the annual reports, it is observed that the reports do not discuss the factors that contributed to such exponential increase in the revenue from operations. It is also pertinent to mention that the "Management Discussion and Analysis" indicates that during the relevant period, the animation industry faced various challenges due to global and economic slowdown and increasing rates of interest rates. When the animation industry was facing various challenges and the annual reports are silent about the reasons for the substantial increase in the revenue from operations, it gives rise to a doubt, whether the reported income figures are genuine. This issue requires further investigation from the forensic angle.

28. From the observations of the preliminary inquiry, it is inter alia noted that :- a) the fund brought in by way of preferential allotment was utilised for purposes other than those disclosed and extended by way of purported loans to companies through informal arrangements; b) even when substantial number of shares i.e. 24,70,00,000 shares (89.17% of the total shareholding of Pine) were locked-in and non transferable / tradable, price of the scrip increased from ₹ 472 (unadjusted and ₹ 47.2 adjusted to share split) to ₹ 1006 (unadjusted and ₹ 100.6 adjusted to share split) with small chunk of volume / purchases by certain entities; c) after the expiry of the lock-in period (i.e. in Patch 3), the average volume increased astronomically to the extent of 4433 times. Such increase in volume was mainly on account of matched trading amongst Preferential Allotees, Promoter related entities and Exit Providers. d) 52 out of the 92 Preferential Allottees sold total 5,23,08,076 shares allotted to them by Pine at the price increased on account of the aforesaid manipulative trading in Patch 1.

29. From the above facts and circumstances it can reasonably be inferred that the Preferential Allottees along with the Promoter related entities acting in concert with Exit Providers have misused the stock exchange system to generate fictitious LTCG so as to convert their unaccounted income into accounted one with no payment of taxes as LTCG is tax exempt. I prima facie find that the above modus operandi helped the concerned entities to pay a lower rate of tax on account of LTCG and helped them to show the source of this income to be from legitimate source i.e. stock market.

30. In the facts and circumstances of this case, I am of the view that the preferential allotment was used as a tool for implementation of the dubious plan, device and artifice of Exit Providers, Preferential Allottees and Promoter related entities. One could argue that in order to make LTCG, the Preferential Allottees in question could have bought in secondary market and waited for a year before selling the shares. In the instant case, probably the preferential allotment route was preferred over secondary market route because the share capital of Pine prior to preferential allotment was very small i.e. 30,00,000 shares to accommodate the required fictitious LTCG of ₹ 453 crore approximately. As such the capital expansion through preferential allotment and stock split provided much bigger source to the persons involved in terms of volume and price manipulation to facilitate the whole operation. Further, the entire scheme of operation also helped the promoters of Pine to exit from the company.

31. Since prior to the trading in its scrip during the Examination Period, Pine did not have any business or financial standing in the securities market, in my view, the only way it could have increased its share value is by way of market manipulation. In this case, it is noted that the traded volume and price of the scrip increased substantially only after the Exit Providers, preferential allotees and Promoter related entities started trading in the scrip. The average volume increased by 4433 times during the Examination Period i.e. from 62 shares per day to 2,74,922 shares per day. It is further noted that on the days when Pine Group was not trading, the traded volumes in the scrip were very low and the substantial increase in traded volumes as observed in this case was mainly due to their trading. I further note that Exit Providers, Preferential Allottees and Promoter related entities traded amongst themselves as substantiated by their matching contribution to net buy and net sell in Patch 3. There was no change in the beneficial ownership of the substantial number of traded shares as the buyers and sellers both were part of the common group and were acting in concert to provide LTCG benefits to the Preferential Allottees and Promoter related entities. In view of the above, I prima facie find that Exit Providers, Preferential Allottees and Promoter related entities used securities market system to artificially increase volume and price of the scrip for creating bogus non taxable profits (i.e. LTCG).

32. In addition to the above, it is noted that after the preferential allotment and transfer of shares by the promoters to the Promoter related entities, about 92.52% of the share capital of Pine was with the Promoter related entities and Preferential Allottees. During the period from Mary 22, 2013 to June 19, 2013, the price of the scrip increased from ₹ 472 (unadjusted and ₹ 47.2 adjusted to share split) to ₹ 1006 (unadjusted and ₹ 100.6 adjusted to share split) in a matter of 19 trading days, with the trading volume as meager as 62 shares per day. The trading volume suddenly increased to 2,74,922 shares per day during the period from December 17, 2013 to January 30, 2015, when Exit Providers, Preferential Allottees and Promoter related entities started trading in the scrip. The prima facie modus operandi appears to be same as that used in the matter of Radford Global Limited where the stock exchange mechanism was used for the purpose of availing LTCG tax benefit and Pine was found actively involved in the whole design to misuse stock exchange mechanism to generate bogus LTCG.

33. I am of the considered view that the scheme, plan, device and artifice employed in this case, apart from being a possible case of money laundering or tax evasion which could be seen by the concerned law enforcement agencies separately, is prima facie also a fraud in the securities market in as much as it involves manipulative transactions in securities and misuse of the securities market. The manipulation in the traded volume and price of the scrip by a group of connected entities has the potential to induce gullible and genuine investors to trade in the scrip and harm them. As such the acts and omissions of Exit Providers, Preferential Allottees and Promoter related entities are ‘fraudulent’ as defined under regulation 2(1)(c) of the SEBI (Prohibition of Fraudulent and Unfair Trade Practices relating to Securities Market) Regulations, 2003 (‘PFUTP Regulations’) and are in contravention of the provisions of Regulations 3(a), (b), (c), (d), 4(1), 4(2)(a), (b), (e) and (g) thereof and section 12A(a), (b) and (c) of the Securities and Exchange Board of India Act, 1992. The said provisions are reproduced hereunder:-

SEBI ACT 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 thereunder;"

PFUTP Regulations "3. Prohibition of certain dealings in securities No person shall directly or indirectly— (a) buy, sell or otherwise deal in securities in a fraudulent manner; (b) use or employ, in connection with issue, purchase or sale of any security listed or proposed to be listed in a recognized stock exchange, any manipulative or deceptive device or contrivance in contravention of the provisions of the Act or the rules or the regulations made 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; …. (e) any act or omission amounting to manipulation of the price of a security; …. (g) entering into a transaction in securities without intention of performing it or without intention of change of ownership of such security;"

34. I note that the directors of Pine during the relevant time (i.e. Nagaraja Sharma Rajagopalan, Lalji Ramraj Yadav, Mandar Subhash Palav, Deepak Prakash Rane, Nirmal Pragjibhai Jodhani, Priyesh Prakash Pethe, Santosh Sharma, Krishnakumar Omprakash Murarka), being in control of the day to day affairs of Pine, had the knowledge of its acts and omissions. They were also under an obligation to ensure that the acts and transactions of Pine were not in violation of any of the applicable provisions of SEBI Regulations or other applicable laws. I, therefore, prima facie find that these directors as well as Pine were responsible for Pine's acts and omissions in this case.

35. I am of the opinion that a detailed investigation of the entire scheme employed in this case is necessary to find out the role of any other entity therein, connection amongst the concerned entities and the ultimate owners of funds used for manipulating the price of the scrip of Pine. Also, an investigation of the annual accounts of Pine from the forensic angle would be necessary. Therefore, while SEBI would investigate into the probable violations of the securities laws, the matter may also be referred to other law enforcement agencies such as Income Tax Department, Enforcement Directorate and Financial Intelligence Unit for necessary action at their end as may be deemed appropriate by them.

36. SEBI strives to safeguard the interests of a genuine investor in the Indian securities market. The acts of artificially increasing the price of scrip misleads investors and the fundamental tenets of market integrity get violated with impunity due for such acts. Under the facts and circumstances of this case, I prima facie find that the acts and omissions of Pine Group as described above is inimical to the interests of participants in the securities market. Therefore, allowing the entities that are prima facie found to be involved in such fraudulent, unfair and manipulative transactions to continue to operate in the market would shake the confidence of the investors in the securities market. 37. I have considered the observations in the preliminary inquiry and noted that the shortlisted entities as mentioned in Table 2 are connected directly/indirectly with Pine/ its promoters on account of factors described in Annexure A. The two promoters who were holding the shares in physical form had transferred their shareholding in off-market to the Promoter related entities. Further, Pine also allotted shares under preferential allotment.

Once the shares were allotted/ transferred to the Preferential Allottees/Promoter related entities, certain entities started moving the price of the scrip upwards by trading in very low volumes. After lock-in of 1 year on preferentially allotted shares was over, the Exit Providers gave exit opportunity to the Preferential Allottees as well as Promoter related entities. From the bank statement of Pine, I find that Pine has transferred funds to some of the Exit Providers, through layers. I also note that the shortlisted entities have contributed majorly to the market volume both at buy and the sell side. 38. Further, I note that vide Interim Orders dated December 19, 2014 in the matters of First Financial Services Limited and Radford Global Limited, Pine has been restrained from accessing securities market directly or indirectly in whatsoever manner for suspected price manipulation in the respective scrips. Further, I also note that some of the Preferential Allottees and the Exit Providers have been restrained from accessing securities market directly or indirectly in whatsoever manner vide the aforesaid interim orders dated December 19, 2015 and interim order dated April 17, 2015 in the matter of Mishka Finance and Trading Limited for suspected price manipulation in the respective scrips.

The details are as follows: Table 7 – Details of entities banned vide other Interim Orders S.No. Name of the entity PAN Interim order through which the entities have been restrained 1 Symphony Merchant Pvt Ltd AADCS5411K First Financial Services Limited, Radford Global Limited and 2 Bazigar Trading Private Limited A A B CB3052B Mishka Finance and Trading Limited. 3 East India Securities Ltd AABCE2412N First Financial Services Limited. 4 Padma Impex Private Limited AAACL4269P 5 Pride Distillery Private Ltd AACCM6582E 6 Navdurga Investment Consultants Pvt AACCN9567A Ltd

7 Bsr Finance And Construction Ltd A ABCB0636K 8 Swarna Pushpa Vanijya Private Limited AAJCS0597G 9 Ridhi Vincom Private Limited AAECR9858C Radford Global Limited. 10 Dhanraksha Vincom Private Limited AADCD6028P 11 Anjali Suppliers Private Limited AAJCA1784D 12 Devatma Distributors Private Limited AADCD7140G 13 Divyadrishti Merchants Pvt Ltd AABCD8147K 14 Divya Drishti Traders Pvt Ltd AABCD8146J 15 Shivkhori Construction Private AAPCS7850L Limited 16 Pine Animation Ltd AAECM0267A First Financial Services Limited and Radford Global Limited. 17 Burlington Finance Limited AABCB2575P 18 Prem Lata Nahar AFAPN8764M 19 Savita Bansal AEJPB6903J Mishka Finance and Trading Limited. 20 Rochak Vinimay Private Limited A A GCR8142P 21 Indrawati Nirman Pvt Ltd A ADCI5139E 22 Duari Marketing Private Limited A A ECD9323N 23 Vishnudham Marketing Private AAECV4988P Limited 24 Sebika Commodities Pvt Ltd A A RCS9144H 25 Esha Securities Ltd AAACE2862P 26 Dreamlight Exim Private Limited AAECD5782B 27 Gajgamini Merchandise Private AAFCG2554B Limited 28 Dhlriti Traders Private Limited AAECD8235D 29 Antaryamini Traders Private Limited AALCA7880J 30 Sidhiman Vyapaar Private Limited AATCS3687H 31 Mobixa Distributors Private Limited AAICM4750C 32 Goldensight Traders Private Limited AAFCG4773J 33 Kapeeshwar Vintrade Pvt Ltd A AECK7329P 34 Swarnprakash Traders Private Limited A A T CS6718D 35 Dhyaneshwar Dealers Pvt Ltd AAECD8010E 36 Muchmore Vincom Private Limited AAICM6982C 37 Reachsmart Dealtrade Private Limited AAFCR9881C 38 Overload Financial Advisory Pvt Ltd A A B CO6950F 39 Helot Properties Private Limited AACCH8885R 40 Rochi Dealcom Private Limited A A GCR7017M 41 Blue Horizon Commosales Private AAFCB0211J Limited 42 Function Financial Consultants Private AABCF5486H Limited 43 Ramya Mercantile Pvt Ltd AAGCR6009M 44 Helpful Investment Advisory Private AACCH4303G Limited 45 Cheroot Vanijya Pvt Ltd AAECC9285A 46 S N Srinivasan ACIPS8803M 47 Amit Singh BABPS7447D

48 Spice Merchants Private Limited A A PCS7492G Radford Global Limited and Mishka Finance and Trading 49 Apex Commotrade Private Limited AAJCA4459K Limited. Ltd 50 Winall Vinimay Private Limited Ltd A A A CW8004B 51 Vibgyor Financial Servicepvt Ltd A A ACV8378B 52 Topwell Properties Private Limited AADCT8403C 53 Rangan Vincom Private Limited AAGCR1715E 54 Signet Vinimay Private Limited A AMCS1712Q 55 Ladios Trading Private Limited AACCL3868N 56 Skm Travels Private Limited A AICS0688K 57 Runicha Merchants Private Limited A A E CR0580M 58 Sanklap Vincom Pvt. Ltd. AAMCS1711P 59 Brij Bhushan Singal AEFPS6298M First Financial Services Limited and Mishka Finance and Trading Limited. 39. Based on the aforesaid findings and taking into consideration the similar modus operandi of market manipulation adopted in similar matters of Radford Global Ltd, First Financial Services Ltd. and Mishka Finance and Trading Ltd., as observed by SEBI in its respective Orders, it prima facie appears that certain market manipulations are taking place in the scrip of Pine. I note that currently a major portion of the shareholding (around 65.93%) lies with the Preferential Allottees and Promoter related entities. It is further noted that as on May 06, 2015, the allottees are still holding 18,03,34,724 shares of Pine that were allotted to them in the aforesaid preferential allotments. Further, the promoter related entities who bought shares from promoters are holding 23,00,645 shares of Pine as on May 06, 2015.The price of the scrip as on May 06,2015 was ₹24/- per share. Thus, the preferential allottees and promoter related entities who are still holding these shares, may potentially book a bogus tax exempt LTCG of approximately ₹420 crore. Unless prevented they may use the stock exchange mechanism in the same manner as discussed hereinabove for the purposes of their dubious plans as prima facie found in this case. In my view, the stock exchange system cannot be permitted to be used for any unlawful/forbidden activities.

40. Considering the above facts and the indulgence of a listed company in such a fraudulent scheme, plan, device and artifice as prima facie found in this case, I am convinced that this is a fit case where, pending investigation, effective and expeditious preventive and remedial action is required to be taken by way of ad interim ex -parte in order to protect the interests of investors and preserve the safety and integrity of the market. 41. It is also pertinent to mention that vide SEBI's Orders in the matter of Radford Global Ltd and First Financial Services Ltd., Pine itself has been restrained from buying, selling or dealing in the securities market, till further directions and the said restraint is in operation as on date. Considering the above, I am of the view that as an interim, preventive and remedial measure and to maintain orderly development in the securities market, in the interests of securities market and investors, it would also be necessary to take immediate steps regarding trading in the scrip of Pine on the stock exchange. Considering these facts and the indulgence of a listed company in such a fraudulent scheme, plan, device and artifice as prima facie found in this case, I am convinced that this is a fit case where, pending investigation, effective and expeditious preventive and remedial action is required to be taken by way of ad interim ex -parte in order to protect the interests of investors and preserve the safety and integrity of the securities market. 42. In view of the foregoing, in order to protect the interest of the investors and the integrity of the securities market, I, in exercise of the powers conferred upon me in terms of section 19 read with section 11(1), section 11 (4) and section 11B of SEBI Act, 1992, pending inquiry/investigation and passing of final order in the matter, hereby issue the following directions: a. restrain the following persons/entities from accessing the securities market and buying, selling or dealing in securities, either directly or indirectly, in any manner, till further directions:-

S.NO. PAN NAME 1 AAECM0267A PINE ANIMATION LTD. DIRECTORS OF PINE ANIMATION LTD. 2 AMCPR0635A DEEPAK PRAKASH RANE 3 AAJPM6827G KRISHNAKUMAR OMPRAKASH MURARKA 4 AAPPYO422P LALJI RAMRAJ YADAV 5 AOMPP1671C MANDAR SUBHASH PALAV 6 AABPN3336R NAGARAJA SHARMA RAJAGOPALAN 7 AJZPJ7049J NIRMAL PRAGJIBHAI JODHANI 8 APUPP9069B PRIYESH PRAKASH PETHE 9 BMKPK5626B SANTOSH KUMAR PROMOTERS OF PINE ANIMATION LTD. 10 AABCF0975D FIRST ENTERTAINMENT PRIVATE LIMITED 11 AAACU9294K UNIQUE IMAGE PRODUCTION PVT. LTD. DIRECTORS OF FIRST ENTERTAINMENT PVT. LTD. AND UNIQUE IMAGE PRODUCTION PVT. LTD. 12 AEZPM6900L MURALI SHANMUGAM 13 ARUPP1577G PRABU SEKAR 14 ADRPV2013N SEKAR VASU PROMOTER RELATED ENTITIES 15 AAECG2103R GAJAKARNA TRADING PVT LTD 16 AAHCM1333N MAHAGANAPATI FINANCIAL SERVICES PVT LTD 17 AAFPJ6734M NIMESH S JOSHI 18 AGSPJ6909M ROSHNI N JOSHI

19 AGYPK8780F HITESH N KAWA 20 ANMPK4236D ROOPAL H KAWA 21 ALDPG8381J AKASH RANCHHODBHAI GOLAKIA 22 AEEPG1294G CHINTAN RANCHHODBHAI GOLAKIA 23 AAYPG3878J RANCHHODBHAI JASMATBHAI GOLAKIA 24 AAWPG3157A VIJUBEN RANCHHODBHAI GOLAKIA 25 AEZPD5474N BINA DEVI DHANUKA 26 ADLPD5568J MAYANK DHANUKA 27 ADOPB3260E NEHA DHANUKA 28 ADNPD6220D NIKUNJ DHANUKA 29 ADUPD7020N RAJKUMARI DHANUKA 30 ADLPD0494K UMANG DHANUKA 31 ADQPD6035P MADAN MOHAN DHANUKA 32 ABEPJ7142D MADANLAL JAIN 33 ABEPJ7147G MOOLCHAND JAIN 34 ACTPC4078P MANISHA NARPATKUMAR CHOPRA 35 ABFPK6567J ALOK NAVINCHANDRA KUBADIA 36 ADIPJ9498C MUKESH KUMAR JAIN 37 AFOPJ4431P VIKAS JAIN 38 ACIPM0237D SHAKUNTALA MARU 39 ADUPM7778C PARAS CHAND MARU 40 AJWPM1991R SAURABH MARU 41 AABPF1503E SUSHILKUMAR SHRIBHAGWAN FATEHPURIA 42 AABPF1507A UMADEVI SUSHILKUMAR FATEHPURIA 43 AAGHD3018R DEEPAK AGARWAL HUF 44 AADHG0808H GOVIND AGARWAL HUF 45 ABFPB2995P PANKAJKUMAR RAJKUMAR BARIA 46 AFTPB8600D POONAM PANKAJ BERIA 47 AAPPA6950Q RAJKUMAR BUDHRAM AGARWAL 48 AAPPA6951R PINKY RAJKUMAR AGRAWAL 49 AAEPJ9602R SUDHESH JAJOO 50 AAEPJ9603Q SUNIL JAJOO 51 AALPJ9756B SNEHLATA JAJOO 52 AALPJ9757A KIRAN JAJOO 53 AAMPJ0021E ANURADHA JAJOO 54 AARPJ7854N OMPRAKASH JAJOO 55 ABVPN8122C HEENA HITENDRA NAGDA 56 AGKPB3602K DARSHAN D BHANUSHALI 57 AAEPG6708K ASHISH GOEL PREFERENTIAL ALLOTEES 58 AGMPK5927A ANIL KUMAR KASARANENI 59 AABPD9375L ANIL VISHANJI DEDHIA 60 ADZPC5979N ANILKUMAR CHAMANLAL 61 AACPM1902D ANKIT RAJIDERKUMAR MIGLANI

62 AEUPB3427L ANMOL PRAKASH BABANI 63 AREPS5118G ARCHANA MIGLANI 64 AANPS2300L ARCHANA SALUJA 65 AEKPM9977L ARVIND CHHOTALAL MORZARIA 66 AADHA7870F ASHOK JAIN HUF 67 AAAPB5499G BALCHAND JAIN 68 AEFPS6298M BRIJ BHUSHAN SINGAL 69 ABAPL3679D BRIJESH CHOWDHARY LAVU 70 ADPPR2047A DAMJI ANANDJI RAMBHIA 71 AAAPP9409N GOPAL NIHCHALDAS PARIANI 72 AAAHH5526G HARESH RAWANI HUF 73 AEIPG1584P HEMANT JAYANT GOGRI 74 AAEPS8716P HIRJI MORARJI SHAH 75 AJLPC9910H JAY HANSRAJ CHHEDA 76 AAIPS4820L KANTILAL LALJI SHAH 77 AADPB1550B KAUSHAL KANHAYALAL BAGADIA 78 ACMPM6181A KISHOR PRANJIVAN MEHTA 79 AEUPB2920C KUNAL RAMESH BABANI 80 AAQPS5640E LATA V SHAH 81 AEBPM1654H MAHENDRA BMITTAL 82 AACPP0931H MAHENDRA PANDHI 83 AAEPG6125C MAYUR ISHVARDAS GANDHI 84 AABPM6332L MIGLANI ANUJ RAJINDER 85 AAJPI8348E MONESH ISRANI 86 AALPS7124C NARESHKUMAR KISHANLAL SARAF 87 AFPPM2107Q NEELAM MOR 88 AAAPV9144N NEENA SUDHIR VORA 89 ADSPA3332J NEHA BANSAL 90 AACPG7709G PANKAJ DHANJI GOSHAR 91 BGGPM9415G PEEYUSH MAKHIJA 92 ACHPB0564H POOJAMAHENDRA MITTAL 93 AAEPS7956D POONAM KAUSHAL BAGADIA 94 AABPS7441L PRADIP DAMJI SHAH 95 AAHHP7899B PRAKASH HIRALAL JAIN HUF 96 ABAPA2027N PRAVEEN KUMAR ARORA 97 APZPV0747H PRITHVI SUDHIR VORA 98 AADPR1704M PRIYANKA HARESH RAWANI 99 ARIPS3477L PRIYANKA MIGLANI 100 AAZPM0573H RAJESH CHAMPAKLAL MEHTA 101 ABSPJ2879F RAJESH DURGASHANKAR JOSHI 102 ABHPA9244J SADHA RANI 103 AATHS9775H SANJAY DNYANESHWER NIKAM HUF 104 ADQPT9711L SANTOSH YASHWANT TANDEL 105 AEJPB6903J SAVITA BANSAL

106 AKYPB3382J SHARAN MOHAN BABANI 107 ALVPM6130D SUNNY MIRCHANDANI 108 AAACT8706B TVC SHARES STOCK & INVESTMENT PVT LTD 109 AAAPH6194E VASUDEV MAHIRWAN HEMRAJANI EXIT PROVIDERS 110 BABPS7447D AMIT SINGH 111 AAJCA1784D ANJALI SUPPLIERS PRIVATE LIMITED 112 AALCA7880J ANTARYAMINI TRADERS PRIVATE LIMITED 113 AAJCA4459K APEX COMMOTRADE PRIVATE LIMITED LTD 114 AABCB3052B BAZIGAR TRADING PRIVATE LIMITED 115 AAFCB0211J BLUE HORIZON COMMOSALES PRIVATE LIMITED 116 AABCB0636K BSR FINANCE AND CONSTRUCTION LTD 117 AABCB2575P BURLINGTON FINANCE LIMITED 118 AAECC9285A CHEROOT VANIJYA PVT LTD 119 AADCD7140G DEVATMA DISTRIBUTORS PRIVATE LIMITED 120 AADCD6028P DHANRAKSHA VINCOM PRIVATE LIMITED 121 AAECD8235D DHLRITI TRADERS PRIVATE LIMITED 122 AAECD8010E DHYANESHWAR DEALERS PVT LTD 123 AABCD8146J DIVYA DRISHTI TRADERS PVT LTD 124 AABCD8147K DIVYADRISHTI MERCHANTS PVT LTD 125 AADCD7017J DOVE SUPPLIERS PVT LTD 126 AAECD5782B DREAMLIGHT EXIM PRIVATE LIMITED 127 AADCD0633J DREAMVALLEY TRADING PRIVATE LIMITED 128 AAECD9323N DUARI MARKETING PRIVATE LIMITED 129 AAACE2862P ESHA SECURITIES LTD FUNCTION FINANCIAL CONSULTANTS PRIVATE 130 AABCF5486H LIMITED 131 AAFCG2554B GAJGAMINI MERCHANDISE PRIVATE LIMITED 132 AAFCG5351A GANGESHWARI TRADERS PRIVATE LIMITED 133 AAFCG4773J GOLDENSIGHT TRADERS PRIVATE LIMITED 134 AADCH3599R HANSHIKA DEALERS PRIVATE LIMITED 135 AACCH8885R HELOT PROPERTIES PRIVATE LIMITED HELPFUL INVESTMENT ADVISORY PRIVATE 136 AACCH4303G LIMITED 137 AADCI5139E INDRAWATI NIRMAN PVT LTD 138 AAECK7329P KAPEESHWAR VINTRADE PVT LTD 139 AACCL3868N LADIOS TRADING PRIVATE LIMITED 140 AADCR9508C LINUS HOLDINGS LTD 141 AAICM4750C MOBIXA DISTRIBUTORS PRIVATE LIMITED 142 AAICM6982C MUCHMORE VINCOM PRIVATE LIMITED NAVDURGA INVESTMENT CONSULTANTS PVT 143 AACCN9567A LTD 144 AABCO2236J ORCHID SOLUTION PRIVATE LIMITED 145 AABCO6950F OVERLOAD FINANCIAL ADVISORY PVT LTD 146 AAACL4269P PADMA IMPEX PRIVATE LIMITED

147 AACCM6582E PRIDE DISTILLERY PRIVATE LTD 148 AAGCR6009M RAMYA MERCANTILE PVT LTD 149 AAGCR1715E RANGAN VINCOM PRIVATE LIMITED 150 AAECR2312K RANGOLI DISTRIBUTORS PRIVATE LTD 151 AAFCR9881C REACHSMART DEALTRADE PRIVATE LIMITED 152 AAGCR8144M REACHSMART DEVELOPERS PRIVATE LIMITED 153 AAECR9858C RIDHI VINCOM PRIVATE LIMITED 154 AAGCR8142P ROCHAK VINIMAY PRIVATE LIMITED 155 AAGCR7017M ROCHI DEALCOM PRIVATE LIMITED 156 AAECR0580M RUNICHA MERCHANTS PRIVATE LIMITED 157 ACIPS8803M S N SRINIVASAN 158 AAMCS1711P SANKLAP VINCOM P LTD 159 AARCS9144H SEBIKA COMMODITIES PVT LTD 160 AAPCS7850L SHIVKHORI CONSTRUCTION PRIVATE LIMITED 161 AATCS3687H SIDHIMAN VYAPAAR PRIVATE LIMITED 162 AAMCS1712Q SIGNET VINIMAY PRIVATE LIMITED 163 AAICS0688K SKM TRAVELS PRIVATE LIMITED 164 AAOCS2216D SPARK COMMODEAL PRIVATE LIMITED 165 AAPCS7492G SPICE MERCHANTS PRIVATE LIMITED 166 AAJCS0597G SWARNA PUSHPA VANIJYA PRIVATE LIMITED 167 AATCS6718D SWARNPRAKASH TRADERS PRIVATE LIMITED 168 AADCS5411K SYMPHONY MERCHANT PVT LTD 169 AADCT8403C TOPWELL PROPERTIES PRIVATE LIMITED 170 AAACV8378B VIBGYOR FINANCIAL SERVICEPVT LTD 171 AAECV4988P VISHNUDHAM MARKETING PRIVATE LIMITED 172 AAACW8004B WINALL VINIMAY PRIVATE LIMITED LTD LTP CONTRIBUTORS 173 AESPN9474K NELLAKKARA RAGHUNATH 174 AFAPN8764M PREM LATA NAHAR 175 AAFHD9092L DHIRENDRA KUMAR GUPTA AND SONS HUF 176 AAACJ8428J J M S FINANCIAL SERVICES LTD. 177 AJSPS5543F SANJAY KUMAR SHAH 178 BGGPS9416R RAJESH KUMAR SHUKLA b. trading in the securities of Pine Animation Limited shall be suspended till further directions. 43. This order shall come into force with immediate effect. The Stock exchanges and the depositories are directed to ensure that all the above directions are strictly enforced. 44. This order is without prejudice to the right of SEBI to take any other action that may be initiated against the aforementioned entities in accordance with law.

45. The persons/entities against whom this Order is passed may file their objections, if any, within twenty one days from the date of this order and, if they so desire, avail themselves of an opportunity of personal hearing before the Securities and Exchange Board of India, on a date and time to be fixed on a specific request, received from the said persons/entities.

Sd/-

DATE: May 8th, 2015 RAJEEV KUMAR AGARWAL PLACE: MUMBAI WHOLE TIME MEMBER SECURITIES AND EXCHANGE BOARD OF INDIA

Annexure - A Company Directors and its Promoter S. PAN Name Relationship No. 1 AAECM0267A PINE ANIMATION LTD. Pine Animation Ltd. (Allahbad Bank: A/c No: 50103075412) transferred funds to Mintage Solutions Pvt. Ltd. (Axis Bank A/c No. 096121800000361), Blue Circle Services Ltd. (Axis Bank A/c No. 909020032026872) and has off-market transaction with Compass Distributors Pvt Ltd. 2 AABCF0975D FIRST ENTERTAINMENT PRIVATE Promoter of Pine as per share holding LIMITED pattern for September 2012. 3 AAACU9294K UNIQUE IMAGE PRODUCTION PVT. Promoter of Pine as per share holding LTD. pattern for September 2012. 4 AMCPR0635A DEEPAK PRAKASH RANE Director of Pine as per its Annual Report for the year ending March 31, 2013 5 AABPN3336R NAGARAJA SHARMA RAJAGOPALAN Director of Pine as per its Annual Report for the year ending March 31, 2013 6 AAPPY0422P LALJI RAMRAJ YADAV Director of Pine as per its Annual Report for the years ending March 31, 2013 and March 31, 2014. 7 AOMPP1671C MANDAR SUBHASH PALAV Director of Pine as per its Annual Report for the year ending March 31, 2013 and March 31, 2014. 8 AJZPJ7049J NIRMAL PRAGJIBHAI JODHANI Director of Pine as per its Annual Report for the year ending March 31, 2013 9 APUPP9069B PRIYESH PRAKASH PETHE Director of Pine as per its Annual Report for the year ending March 31, 2013 10 AAJPM6827G KRISHNAKUMAR OMPRAKASH Director of Pine as per its Annual Report MURARKA for the year ending March 31, 2014 11 BMKPK5626B SANTOSH KUMAR Director of Pine as per its Annual Report for the year ending March 31, 2014 12 AEZPM6900L MURALI SHANMUGAM Director of First Entertainment Pvt. Ltd. and Unique Image Production Pvt. Ltd. as per the MCA Website 13 ARUPP1577G PRABU SEKAR Director of First Entertainment Pvt. Ltd. as per the MCA Website 14 ADRPV2013N SEKAR VASU Director of Unique Image Production Pvt. Ltd. as per the MCA Website Part I-Promoter related entities S. PAN Name Relationship No. 15 AAECG2103R GAJAKARNA TRADING PVT LTD Received shares in physical form from the promoter First Entertainment Pvt. Ltd. 16 AAHCM1333N MAHAGANAPATI FINANCIAL Received shares in physical form from the SERVICES PVT LTD promoter Unique Image Production Pvt. Ltd. 17 AAFPJ6734M NIMESH S JOSHI Received shares in physical form from the promoter First Entertainment Pvt. Ltd.

18 AGSPJ6909M ROSHNI N JOSHI Received shares in physical form from the promoter First Entertainment Pvt. Ltd. 19 AGYPK8780F HITESH N KAWA Received shares in physical form from the promoter First Entertainment Pvt. Ltd. 20 ANMPK4236D ROOPAL H KAWA Received shares in physical form from the promoter First Entertainment Pvt. Ltd. 21 ALDPG8381J AKASH RANCHHODBHAI Received shares in physical form from Hitesh N GOLAKIA Kawa 22 AAAPO8119J ALANKRUTA OMPRAKASH Received shares in physical form from Gajakarna OSWAL Trading Pvt Ltd 23 ABFPK6567J ALOK NAVINCHANDRA Received shares in physical form from KUBADIA Mahaganapati Financial Services Pvt. Ltd. 24 AAMPJ0021E ANURADHA JAJOO Received shares in physical form from Roopal H Kawa 25 AAEPG6708K ASHISH GOEL Received shares in physical form from Gajakarna Trading Pvt Ltd 26 AMCPS3169A BHARATI DHAVAL SHAH Received shares in physical form from Mahaganapati Financial Services Pvt. Ltd. 27 AAFCB1180N BHUSHIT TRADING PVT LTD Received shares in physical form from Mahaganapati Financial Services Pvt. Ltd. and Roshni N Joshi 28 AEZPD5474N BINA DEVI DHANUKA Received shares in physical form from Gajakarna Trading Pvt Ltd 29 AEEPG1294G CHINTAN RANCHHODBHAI Received shares in physical form from Hitesh N GOLAKIA Kawa 30 AGKPB3602K DARSHAN D BHANUSHALI Received shares in physical form from Mahaganapati Financial Services Pvt. Ltd. 31 AAGHD3018R DEEPAK AGARWAL (HUF) Received shares in physical form from Hitesh N Kawa 32 ARCPV4314R DEVESH VALECHA Received shares in physical form from Gajakarna Trading Pvt Ltd 33 AANPN4767E DILIP KUMAR NAGORI Received shares in physical form from Gajakarna Trading Pvt Ltd 34 ALJPS2651R DIPTI PARESH SHAH Received shares in physical form from Mahaganapati Financial Services Pvt. Ltd. 35 AANPW9528Q GANESH LAXMAN WAGH Received shares in physical form from Gajakarna Trading Pvt Ltd 36 AADHG0808H GOVIND AGARWAL HUF Received shares in physical form from Hitesh N Kawa 37 AANPA3669C HARISHCHANDER OMPRAKASH Received shares in physical form from AGARWAL Mahaganapati Financial Services Pvt. Ltd. 38 ABVPN8122C HEENA HITENDRA NAGDA. Received shares in physical form from Mahaganapati Financial Services Pvt. Ltd. 39 AQZPB2916M KAJRI NAGORI Received shares in physical form from Gajakarna Trading Pvt Ltd 40 AALPJ9757A KIRAN JAJOO Received shares in physical form from Roopal H Kawa

41 ADQPD6035P MADAN MOHAN DHANUKA Received shares in physical form from Gajakarna Trading Pvt Ltd 42 ABEPJ7142D MADANLAL JAIN Received shares in physical form from Nimesh S Joshi 43 AEUPB9878H MAMTA RISHIKUMAR BAGLA Received shares in physical form from Gajakarna Trading Pvt Ltd 44 ACTPC4078P MANISHA NARPATKUMAR Received shares in physical form from CHOPRA Mahaganapati Financial Services Pvt. Ltd. 45 ADLPD5568J MAYANK DHANUKA Received shares in physical form from Gajakarna Trading Pvt Ltd 46 ABEPJ7147G MOOL CHAND JAIN Received shares in physical form from Nimesh S Joshi 47 ADIPJ9498C MUKESH KUMAR JAIN Received shares in physical form from Roshni N Joshi 48 AAIHM2182H MURLIDHAR MUNDHRA (HUF) Received shares in physical form from Gajakarna Trading Pvt Ltd 49 AAPPT4897B NARAYAN B. TOSHNIWAL Received shares in physical form from Gajakarna Trading Pvt Ltd 50 ADOPB3260E NEHA DHANUKA Received shares in physical form from Gajakarna Trading Pvt Ltd 51 ACJPN1689D NIDHI GOEL Received shares in physical form from Gajakarna Trading Pvt Ltd 52 ADNPD6220D NIKUNJ DHANUKA Received shares in physical form from Gajakarna Trading Pvt Ltd 53 AARPJ7854N OMPRAKASH JAJOO Received shares in physical form from Roopal H Kawa 54 ADEPC7911R PANKAJ CHOURASIA Received shares in physical form from Gajakarna Trading Pvt Ltd 55 ABFPB2995P PANKAJKUMAR RAJKUMAR Received shares in physical form from Nimesh S BARIA Joshi 56 ADUPM7778C PARAS CHAND MARU Received shares in physical form from Gajakarna Trading Pvt Ltd 57 AADPO5637Q PAWANKUMAR GULABCHAND Received shares in physical form from Gajakarna OSWAL Trading Pvt Ltd 58 AAPPA6951R PINKY RAJKUMAR AGRAWAL Received shares in physical form from Hitesh N Kawa 59 AFTPB8600D POONAM PANKAJ BERIA Received shares in physical form from Nimesh S Joshi 60 ANBPS0119C POONAM P JAIN Received shares in physical form from Mahaganapati Financial Services Pvt. Ltd. and Gajakarna Trading Pvt. Ltd. 61 AIGPD9671E PRACHI RANJEET BAPAT Received shares in physical form from Gajakarna Trading Pvt Ltd 62 ADUPD7020N RAJ KUMARI DHANUKA Received shares in physical form from Gajakarna Trading Pvt Ltd 63 AAPPA6950Q RAJKUMAR BUDHRAM Received shares in physical form from Hitesh N AGARWAL Kawa 64 ADOPA8945K RAJKUMAR HARISH CHANDER Received shares in physical form from AGARWAL Mahaganapati Financial Services Pvt. Ltd. 65 AAYPG3878J RANCHHODBHAI JASMATBHAI Received shares in physical form from Hitesh N GOLAKIA Kawa 66 AAOPJ8490M RANJU JAJOO Received shares in physical form from Gajakarna Trading Pvt Ltd

67 AFRPB1406M RISHIKUMAR RAJNARAYAN Received shares in physical form from Gajakarna BAGLA Trading Pvt Ltd 68 AAFHR1225K RISHIKUMAR RAJNARAYAN Received shares in physical form from Gajakarna BAGLA HUF Trading Pvt Ltd 69 AJWPM1991R SAURABH MARU Received shares in physical form from Gajakarna Trading Pvt Ltd 70 ACHPW1315R SEEMA GANESH WAGH Received shares in physical form from Gajakarna Trading Pvt Ltd 71 ADCPP5865H SHAILESH KARAMSHI PATEL Received shares in physical form from Hitesh N Kawa 72 ACIPM0237D SHAKUNTALA MARU Received shares in physical form from Gajakarna Trading Pvt Ltd 73 AALPJ9756B SNEHLATA JAJOO Received shares in physical form from Roopal H Kawa 74 AAEPJ9602R SUDHESH JAJOO Received shares in physical form from Roopal H Kawa 75 AAEPJ9603Q SUNIL JAJOO Received shares in physical form from Hitesh N Kawa 76 AABPF1503E SUSHILKUMAR SHRIBHAGWAN Received shares in physical form from Nimesh S FATEHPURIA Joshi 77 AABPF1507A UMADEVI SUSHILKUMAR Received shares in physical form from Nimesh S FATEHPURIA Joshi 78 ADLPD0494K UMANG DHANUKA Received shares in physical form from Gajakarna Trading Pvt Ltd 79 AAWPG3157A VIJUBEN RANCHHODBHAI Received shares in physical form from Hitesh N GOLAKIA Kawa 80 AFOPJ4431P VIKAS JAIN Received shares in physical form from Mahaganapati Financial Services Pvt. Ltd.

81 AJTPJ3155F VIKAS JAIN Received shares in physical form from Gajakarna Trading Pvt Ltd 82 AEDPJ2960D VINEET JAIN Received shares in physical form from Gajakarna Trading Pvt Ltd Part II- List of Preferential Allottees S. PAN Name No. of Shares Allotted No. 83 ADSPA3332J Neha Bansal 100000 84 AALPB2800Q Ashish Bansal 80000 85 AEJPB6903J Savita Bansal 140000 86 AGNPA7990A Kanika Agarwal 60000 87 ABHPA9244J Sadhna Rani 120000 88 AAAPU3998D Bhushan Kumar Uppal 100000 89 AALPK5068M Sushil Kumar 60000 90 AFUPG1276P Anjali Gupta 140000 91 AAJPG5046R Ajit Kumar Gupta 140000 92 AABPK6886B/ Shirish L Keniya Jointly with Sejal S. 250000 AAQPK2326R Keniya 93 AABPG6662M Mansukhlal Keshavji Gala 250000 94 AALPS7124C Naresh Saraf 250000 95 AACPS8400J Arvind Jayantilal Shah 170000 96 AAAPH6194E Vasudev Mahirwan Hemrajani 150000 97 AEKPM9977L Arvind Chottalal Morzaria 200000

98 AEXPM7771B Lalit Navin Morzaria 200000 99 AADPM9918L Subhash Chottalal Morzaria 200000 100 AEIPG1584P Hemant Jayant Gogri 100000 101 AADHA7870F Ashok Jain Huf 200000 102 AAHHP7899B Prakash Hiralal Jain HUF 200000 103 AAEPG6125C/ Mayur Gandhi Jointly with Pallavi 200000 AADPG3815E Gandhi 104 AAAPP9409N Gopal Nichaldas Pariani 200000 105 AADPR1704M Priyanka Haresh Rawani 150000 106 AAAPV9144N Neena Sudhir Vora 150000 107 APZPV0747H Prithvi Sudhir Vora 150000 108 AAAHH5526G Haresh Rawani Huf 150000 109 AABPM7288D Rajinder Kumar Miglani 600000 110 AAFPM7744L Neelam Miglani 600000 111 AABPM6332L Anuj Miglani 450000 112 AACPM1902D Ankit Miglani 440000 113 AREPS5118G Archana Miglani 400000 114 ARIPS3477L Priyanka Miglani 400000 115 AARPM7331B Praveen Kumar Miglani 400000 116 ABAPL3679D Brijesh Chowdhary Lavu 300000 117 AACPG7709G Pankaj Dhanji Goshar 600000 118 ABSPJ2879F Rajesh Durgashankar Joshi 300000 119 AAQPS5640E Lata V Shah 600000 120 AABPS7441L/AAWPS1354B Pradip Damji Shah Jointly with Chhaya 300000 Pradip Shah 121 BEIPS9920L Vinod Saluja 500000 122 AQDPS8677G Ankush Saluja 500000 123 AANPS2300L Archana Saluja 250000 124 AAJPU2807N Nidhi Saluja 250000 125 ALVPM6130D Sunny Mirchandani 200000 126 AAJP18348E Monesh Israni 200000 127 AFPPM2107Q Neelam Mor 200000 128 AGMPK5927A Kasaraneni Anil Kumar 200000 129 AEDPK3759F Kasaraneni Vasundhara 200000 130 AAAPB5499G Bal Chand Jain 200000 131 AABPL2052J Kishore Premchand Lahrani 200000 132 AAAHK2645F Kishore Premchand Lahrani (HUF) 200000 133 ACQPL6691J Puneet Kishore Lahrani 200000 134 ABIPL5205F Reena Kishor Lahrani 200000 135 AFBPG4873R Lokesh Shankar Gurnani 200000 136 ASUPG4897M Mehar Lokesh Gurunani 200000 137 AJLPC9910H Jay Hansraj Chheda 150000 138 AAEPS8716P Hirji M Shah 150000

139 AABPD9375L/ADUPD6477F Anil Vishanji Dedhia jointly with 350000 Sandhya Anil Dedhia 140 ADPPR2047A Damji Anandji Rambhia 300000 141 AEUPB2920C Kunal Ramesh Babani 150000 142 AEUPB3427L Anmol Prakash Babani 150000 143 AKYPB3382J Sharan Mohan Babani 150000 144 ADQPT9711L Santosh Yashwant Tandel 150000 145 AASCS2552A Shalu Multitrade Pvt.Ltd. 150000 146 AATHS9775H S.D.Nikam (HUF) 300000 147 AAHPD2883K Sonali Kishore Dharia 150000 148 AACPK7431P Taruna Subhash Kubadia 150000 149 AJCPS8183M Shashi Kumar Sharma 250000 150 AEFPS6298M Brij Bhushan Singal 1200000 151 ANRPS7986B Neeraj Singal 1200000 152 ABHPS3711N Ritu Singal 1200000 153 AAAHB6923R Brij Bhushan Singal HUF 750000 154 AAEHN4557P Neeraj Singal HUF 750000 155 AWTPH2143C Akshay Vasudev Hemrajani 150000 156 AACPP0931H Mehendra V Pandhi 150000 157 AAACT8706B TVC Shares Stock Investment (P) Ltd. 300000 158 ABBPK9377N Harish Kumar 100000 159 ACPPD8221M Priti Devi 100000 160 BGGPM9415G Piyush Makhija 100000 161 ABBPA2178H Som Arora 100000 162 ABAPA2027N Pravin Arora 100000 163 ABKPA8096M Rajkumar Arora 100000 164 AACPJ3610K Ashok B. Jiwrajka 300000 165 AAGPJ8756J Dilip B. Jiwrajka 300000 166 AACPJ4316L Surendra B. Jiwrajka 300000 167 ADZPC5979N Anil Kumar Chamanlal 300000 168 ACMPM6181A Kishore Pranjivan Mehta jointly with 250000 Jyoti Kishorechandra Mehta 169 AAZPM0573H Rajesh Champaklal Mehta 250000 170 AAIPS4820L Kantilal Lalji Shah 250000 171 AEBPM1654H Mahendra Mittal 150000 172 ACHPB0564H Pooja Mittal 150000 173 AADPB1550B Kuashal Bagariya 100000 174 AAEPS7956D Poonam Bagariya 100000 Part III-List of Exit Providers S. PAN Relationship No.

175 AACCN9567A Navdurga Investment Consultants Pine Animation Ltd. (Allahbad Bank: A/c No: Pvt Ltd 50103075412) transferred funds to Blue Circle Services Ltd. (Axis Bank A/c No. 909020032026872) As per the KYC submitted by the trading member ‘Comfort Securities Pvt Ltd’ for its client ‘Navdurga Investment Consultants Private Ltd.’ has common director with that of the company ‘Blue Circle Services Ltd’ viz, ‘Dhruvnarayan Jha’. 176 AAJCA1784D Anjali Suppliers Private Limited Pine Animation Ltd. (Allahbad Bank: A/c No: 50103075412) transferred funds to Mintage Solutions Pvt. Ltd. (Axis Bank A/c No.096121800000361) Anjali Suppliers Pvt. Ltd and Devatma Distributors Pvt. Ltd. have common Director - Raj Kumar Dabriwal with Mintage 177 AADCD7140G Devatma Distributors Private Solutions Limited 178 AAGCR1715E Rangan Vincom Private Limited O ff-market transfer with Devatma Distributors 179 AACCL3868N Ladios Trading Private Limited Debendra Das - common director with Rangan Vincom 180 AAOCS2216D Spark Commodeal Private Limited P ine Animation Ltd. has off-market transaction with Compass Distributors Pvt Ltd. Compass Distributors Pvt Ltd. and Spark Commodeal have a common director - Jai Shankar Joshi 181 AADCD7017J Dove Suppliers Pvt Ltd Bluesnow Dealcom Pvt. Ltd. (Punjab National Bank A/c No. 4656002100003380) transferred funds to Spark Commodeal Privated Ltd. (Punjab National Bank A/c No. 4656002100003308) Bluesnow Dealcom (Punjab National Bank A/c No. 4656002100003380) transferred funds to Dove Suppliers Pvt. Ltd. (Punjab National Bank A/c No.4656002100003344) and to Rangoli Distributors Pvt. 182 AAECR2312K Rangoli Distributors Private Ltd Ltd. (Punjab National Bank A/c No.4656002100003274)

183 AABCO2236J Orchid Solution Private Limited Fund transfer from Rangoli Distributors Pvt. Ltd. (Punjab National Bank A/c No. 4656002100003274) to Orchid Solution Private Limeted (Punjab National Bank A/c No. 4656002100003247) 184 AADCD0633J Dreamvalley Trading Private Common Address, Phone No. and Email Id with Rangoli Limited Distributors - 52 Canning Street, 52 Canning Street, Ground Floor, Kolkata - 700001, PPUROHIT27@YAHOO.IN, 9836300031 185 AADCD6028P Dhanraksha Vincom Private Off-market with Spark Commodeal Limited 186 AAECR9858C Ridhi Vincom Private Limited Off-market with Spark Commodeal. Common Directors with Dhanraksh Vincom – Rajesh Kumar Agarwal and Debasis Mishra 187 AABCD8147K Divyadrishti Merchants Pvt Ltd As per the KYC submitted by the trading member 'Korp Securities Ltd.' for its clients 'Divyadrishti Merchants Pvt 188 AABCD8146J Divyadrishti Traders Pvt Ltd Ltd', 'Divya Drishti Traders Pvt Ltd', 'Dhanraksha Vincom Pvt Ltd.' and 'Ridhi Vincom Pvt Ltd', all the clients have common address viz, '163 B, M.G Road, 3rd Floor, Kolkata – West Bengal – 700007'. 189 AADCT8403C Topwell Properties Private On analyzing bank statement of the Topwell Properties Limited Private Limited (Axis Bank, Kolkata branch having account no. - 911020032366261), it was observed that funds were transferred to Divya Drishti Merchants(ICICI a/c no. 000605010065) and Alishan Estates Pvt. Ltd. (ICICI Bank a/c No. 090105500188) 190 AADCR9508C Linus Holdings Ltd Alishan Estates Pvt. Ltd. (ICICI Bank a/c No. 000605026525) transferred funds to Duari Marketing Pvt. Ltd. (HDFC Bank A/c No. 11287630000672). Common director with Alishan Estates - Arindam Roy 191 AAPCS7850L Shivkhori Construction Private Common Directors with Topwell Properties – Chiranjit Limited Mahanta and Debi Prasad Pal 192 AABCF5486H Function Financial Consultants As per MCA website 'DEBI PRASAD PAL' is one of the Private Limited directors of 'Helpful Investment Advisories Pvt. Ltd., Function Financial Consultants Private Limited and 193 AACCH4303G Helpful Investment Advisory Topwell Properties Private Limited

Private Limited 194 AAMCS1712Q Signet Vinimay Private Limited O n a nalyzing bank statement of the Topwell Properties Private Limited, it was observed that funds were also transferred to Signet Vinimay Pvt. Ltd.and Sankalp Vincom Pvt. Ltd. 195 AAECR0580M Runicha Merchants Private Common Directors and Address with Signet Vinimay – Limited Pradip Dey and Abhiset Basu, 23/1, Principal Khudiram Bose Road, Kolkata - 700 006 196 AAACW8004B Winall Vinimay Private Limited Common Directors and Address with Signet Vinimay – Ltd Pradip Dey and Abhiset Basu, 23/1, Principal Khudiram Bose Road, Kolkata - 700 006 197 AAMCS1711P Sanklap Vincom P Ltd Common Directors and Address with Signet Vinimay – Pradip Dey and Abhiset Basu, 23/1, Principal Khudiram Bose Road, Kolkata - 700 006 198 ACIPS8803M S N Srinivasan S N Srinivasan transferred shares of Anukaran Commercial Enterprises Limited to Sanklap Vincom Pvt. Ltd. through off-market transactions 199 AAICS0688K Skm Travels Private Limited T h e company 'Winall Vinimay Private Limited’ and 'SKM Travels Private Limited' have common director viz, 'Abhiset Basu’.

200 BABPS7447D Amit Singh Amit Singh has off market transactions in various scrips with Sanklap Vincom Pvt. Ltd., Signet Vinimay Pvt. Ltd. and Runicha Merchants Pvt. Ltd. 201 AAJCA4459K Apex Commotrade Private Off-market transfer with Runicha Merchants Limited Ltd 202 AAPCS7492G Spice Merchants Private Limited C o m m on Directors – Aman Sah and Shakuntal Sah and Common Address - 56 e, Hemanta Basu Sarani, Stephen House, 4th Floor, Room No. 58 C, Kolkata – 700 001, with Apex Commotrade Pvt. Ltd. 203 AAECK7329P Kapeeshwar Vintrade Pvt Ltd K a p e e shwar Vintrade Private Limited have off-market transactions with Apex Commotrade Pvt. Ltd. and Helot 204 AACCH8885R Helot Properties Private Limited Properties Private Limited in the scrips of Rander Corporation Limited and Kelvin Fincap Limited respectively. 205 AAFCB0211J Blue Horizon Commosales Private Blue Horizon Commosales Private Limited has off market Limited transactions with Kapeeshwar Vintrade Private Limited in different scrips. 206 AATCS6718D Swarnprakash Traders Private Swarnprakash Traders Private Limited has off market Limited transactions with Helot Properties Pvt. Ltd. 207 AAECC9285A Cheroot Vanijya Pvt Ltd A s per MCA website NEWTON SARKAR is one of the directors of Cheroot Vanijya Pvt Ltd and Helot Properties 208 AATCS3687H Sidhiman Vyapaar Private Limited Pvt Ltd. Further, as per MCA website SUKUMAR GHOSH 209 AAICM4750C Mobixa Distributors Private is one of the directors of Cheroot Vanijya Pvt Ltd, Limited Sidhiman Vyapaar Private Limited, Vishnudham Marketing 210 AAECV4988P Vishnudham Marketing Private Private Limited and Mobixa Distributors Private Limited Limited 211 AAFCG2554B Gajgamini Merchandise Private Gajgamini Merchandise Pvt Ltd has off market transactions Limited with Helot Properties Pvt. Ltd. and Vishnudham Marketing Pvt. Ltd. 212 AALCA7880J Antaryamini Traders Private As per MCA website RAM KRISHNA Limited BHATTACHERJEE is one of the directors of Antaryami 213 AAICM6982C Muchmore Vincom Private Traders Private Limited, Gajgamini Merchandise Private Limited Limited and Muchmore Vincom Private Limited

214 AADCI5139E Indrawati Nirman Pvt Ltd I n d r awati Nirman Private Limited has off-market transactions with Gajgamini Merchandise Private Limited, Rochak Vinimay Pvt Ltd, Sebika Commodities Private Limited, Reachsmart Construction Private Limited, Reachsmart Dealtrade Private Limited and Rangan Vincom Private Limited in different scrips.

215 AARCS9144H Sebika Commodities Pvt Ltd A s p e r MCA website RAJIB RAJBANGSHI is one of the directors of Reachsmart Constructions Private Limited, 216 AABCO6950F Overload Financial Advisory Pvt Overload Financial Advisory Pvt Ltd and Sebika Ltd Commodities Private Limited 217 AAFCR9881C Reachsmart Dealtrade Private Limited 218 AAECD8010E Dhyaneshwar Dealers Pvt Ltd A s per MCA website NIRAJ KUMAR RAY is one of the directors of Dhyaneshwar Dealers Pvt Ltd and Reachsmart Dealtrade Private Limited 219 AAFCG4773J Goldensight Traders Private Pratap Chakraborty is one of the directors of Dhyaneshwar Limited Dealers Pvt Ltd and Goldensight Traders Private Limited 220 AAECD5782B Dreamlight Exim Private Limited Dreamlight Exim Pvt. Ltd., had off-market transactions with Sebika Commodities Pvt. Ltd, Helot Properties Pvt. Ltd., Gajgamini Merchandise Pvt. Ltd., Mobixa Distributors Pvt. Ltd., Reachsmart Dealtrade Pvt. Ltd. and Rochak Vinimay Pvt. Ltd. 221 AAGCR8142P Rochak Vinimay Private Limited R o c h a k Vinimay Pvt. Ltd. had off-market transactions with Dreamlight Exim Pvt. Ltd., and Gajagamini Merchandise Pvt. Ltd. 222 AAGCR7017M Rochi Dealcom Private Limited C o m m on Directors with Rochak Vinimay Pvt. Ltd. - Koushik Chatterjee and Rohit Agarwal 223 AAECD9323N Duari Marketing Private Limited D u a r i Marketing Private Limited. received shares of Splash Mediaworks Limited from Mobixa Distributors Private Limited, Antaryami Traders Private Limited and Muchmore Vincom Private Limited through off-market transactions 224 AAFCG5351A Gangeshwari Traders Private Gangeshwari Traders Pvt. Ltd. (Axis Bank: A/c No: Limited 914020017335267) transferred funds to Duari Marketing Pvt. Ltd. (Axis Bank A/c No. 914020017196716).

225 AADCH3599R Hanshika Dealers Private Limited H a n s h ika Dealers Pvt. Ltd. (Axis Bank: A/c No: 914020017196729) transferred funds to Duari Marketing Pvt. Ltd. (Axis Bank A/c No. 914020017196716). 226 AAGCR8144M Reachsmart Developers Private Reachsmart Developers Pvt. Ltd. (Axis Bank: A/c No: Limited 914020017376815) transferred funds to Duari Marketing Pvt. Ltd. (Axis Bank A/c No. 914020017196716). 227 AADCS5411K Symphony Merchant Pvt Ltd F r o m the analysis of bank statement of Amrit Sales Promotion Pvt. Ltd.(HDFC Bank-A/c No: 00080340006392), it was observed that funds were received from Blue Circle Services Ltd who is observed to have fund transaction with Pine Animation Ltd ( Allahbad Bank: A/c No: 50103075412)Panna Lal Maloo is the common director of Amrit Sales Promotion Pvt Ltd. and Symphony Merchant Pvt Ltd. Also Fund transfer between Symphony Merchant Pvt and Amrit Sales Promotion Pvt Ltd. 228 AABCB2575P Burlington Finance Limited Director of Burlington Finance Ltd is Rabi Paul who is also director in Amrit Sales Promotion Pvt Ltd. 229 AABCB3052B Bazigar Trading Private Limited H a n u m an Mal Tater, Director of Burlington Finance Ltd., is also a director of Bazigar Trading Pvt. Ltd. 230 AAGCR6009M Ramya Mercantile Pvt Ltd Badamisati Apartments (P) Ltd. transferred shares to Saktimata Marketing Private Limited through off-market transactions.

Saktimata Marketing Private Limited received shares from Rochak Vinimay Pvt Ltd, Rochi Dealcom Pvt Ltd and Duari Marketing Private Limited.Ramya Mercantile Pvt Ltd transferrd funds to Badamisati Apartments Private Limited 231 AAECD8235D Dhlriti Traders Private Limited T here are numerous fund transactions between Dhlriti Traders Pvt.Ltd (The Ratnakar Bank : A/c no: 409000125799) and Ramya Mercantile Pvt. Ltd ( The Ratnakar Bank : A/c no: 409000115428).

232 AABCB0636K Bsr Finance And Construction Ltd B S R Finance and Construction Ltd. has made off-market transfers to Bikash Sureka. Bikash Sureka has off-market transactions wth Vishnudham Marketing Pvt. Ltd, Duarim Marketing Pvt. Ltd, Gajgamini Merchandise Pvt. Ltd. and Gangeshwarin Traders Pvt. Ltd. 233 AAACE2862P Esha Securities Ltd O n analyzing the bank statement submitted by the trading member ‘C.D Equisearch Pvt Ltd’ for its client ‘Pyramid Trading and Finance Limited’, it was observed that the client has transferred funds to Esha Securities Private Limited. Pyramid Trading and Finance Limited received funds from Pine Animation Ltd. 234 AAACL4269P Padma Impex Private Limited Rani Sati Dealers Pvt. Ltd. is a shareholder of Padma Impex Pvt. Ltd. Rani Sati Dealers Pvt. Ltd. had off-market transaction with JMD Telefilms Industries. JMD Telefilms Industries Ltd. had fund transactions with Indrawati Nirman Pvt. Ltd., Rochak Vinimay Pvt. Ltd. and Duari Marketing Pvt. Ltd. JMD Telefilms Industries Ltd. has common director with JMD Sounds Ltd. and JMD Sounds Ltd. had fund transactions with Pine Animation Ltd. 235 AACCM6582E Pride Distillery Private Ltd Jagdish purohit is the shareholder of Pride distillery as well as of JMD sounds Ltd. JMD sounds transferred funds to Pine Animation Ltd. 236 AAACV8378B Vibgyor Financial Servicepvt Ltd A s p e r the KYC submitted by the trading member 'The Calcutta Stock Exchange Ltd' for its clients 'Runicha Merchants Private Limited', 'Signet Vinimay Private Limited', 'Winall Vinimay Private Limited' and 'Sanklap Vincom P Ltd' and Gateway Financial Services Limited for its clients, 'Scope Vyapar Private Limited' and 'SKM Travels Private Limited' have common address viz, '23/1, Principal Khudiram Bose Road, Kolkata, West Bengal – 700006’.

Vibgyor Financial Service Pvt Ltd has received shares in off market from ‘Scope Vyapar Private Limited’. 237 AAJCS0597G Swarna Pushpa Traders Private Ashok Bothra was the common director in Dynamic Limited Portfolio Management & Services Ltd and Blue circle Services Ltd. Ravi Kumar Newatia is one of the directors of Dynamic Portfolio Management & Services Ltd Ritesh Projects Private and Ritesh Commercial Holdings Limited. Ritesh Commercial Holdings Limited and Hari Om Suppliers Pvt. Ltd. are among the shareholders of Surbhika vyapaar pvt Ltd. Bishwanath Agarwal is one of the directors of Hari Om Suppliers Pvt. Ltd. is a director of Swarna Pushpa Traders Private Limited

Sd/- DATE: May 8th, 2015 RAJEEV KUMAR AGARWAL PLACE: MUMBAI WHOLE TIME MEMBER SECURITIES AND EXCHANGE BOARD OF INDIA