Order in the matter of Pyramid Saimira Theatre Ltd

1. There were several media reports on December 21 and 22, 2008 that Securities and Exchange Board of India (hereinafter referred to as SEBI) had ordered Shri P.S. Saminathan, one of the promoters of M/s. Pyramid Saimira Theatre Limited (herein after referred as PSTL), to make an open offer under the Securities and Exchange Board of India (Substantial Acquisition of Shares and Takeovers) Regulations, 1997 (herein after referred to as SEBI (SAST) Regulations, 1997) for an additional 20% stake, at a price not less than Rs 250/- within 14 days, for allegedly violating creeping acquisition norms. 2. With the reports in the media appearing about the impending offer at Rs 250/-, the shares of the company shot up on Monday morning i.e. December 22, 2008, when the stock markets opened for the day. On the same day, PSTL first informed the exchanges Bombay Stock Exchange Limited (herein after referred to as BSE) and National Stock Exchange of India Limited (herein after referred to as NSE) in the morning that the company had not received any communication from SEBI regarding the media reports on Open Offer.

Subsequently, PSTL received the said order at around 10.30 a.m. on the same day i.e. December 22, 2008, when the courier company Blue Dart delivered the purported SEBI letter to the company. Shri Saminathan informed BSE and NSE on December 23, 2008 about the receipt of the letter from SEBI. On December 23, 2008, SEBI too issued Press Release clarifying that no order or letter has been issued by SEBI to Shri P.S. Saminathan on December 19, 2008 and it appears that the said letter is being circulated with ulterior motives. 3. On a careful examination of the letter purported to have been sent by SEBI to Shri Saminathan, it was found that no such letter had been issued by SEBI. This letter clearly, therefore, has been forged. Further, on perusal of the said letter, it was found that the letter was dispatched through Blue Dart Couriers. The courier company revealed that they had been instructed by the person who had handed over the purported letter NOT to deliver the letter on Saturday to PSTL and to deliver it ONLY on Monday – the December 22, 2008. 4. It was further gathered that one Rakesh Sharma, then an executive with M/s. Adfactors PR Pvt. Ltd., was responsible in forwarding the letter that was sent to Shri P.S.

Saminathan, CMD of PSTL. Further, the Company Secretary of PSTL also faxed to SEBI a copy of the other letter purportedly issued by SEBI, also dated December 19, 2008, that was addressed to Shri Nirmal Kotecha, HNI and a part of the promoter group, at his residential address at 601, Sukh Niwas, Bhandarkar Road, Matunga, Mumbai – 400019. Though, Shri Nirmal Kotecha later claimed in his statement to SEBI that the said purported letter was received at his residence by his wife on Saturday, (December 20th, 2008) through courier, he stated that his wife was unable to recollect the name of the courier who delivered the letter. The said letter sought details about Shri Nirmal Kotecha’s acquisitions in the company, his relationship with Shri Saminathan and Shri N.C.Ravichandran, agreement entered into with Shri Saminathan, if any, for the interse transfer of shares, copies of his bank accounts and demat statements for the period January 2007 till December 2008, advances made to the company, if any, and details of his networth certificate and IT Returns for the period 2006-97 and 2007-08 to be furnished within 14 days period.

The original letter was later received from Shri Nirmal Kotecha. Though he claimed that the letter was received through a courier at his residence, he could not produce the cover enclosing the letter, nor name the courier agency through which the same was received. 5. SEBI, thus, prima facie found that communications on letter head and stationary styled on the pattern of the official SEBI stationary were sent to two promoters of the company. These were intended to convey the impression that SEBI has issued such communication. Hence, an FIR was registered with the BKC Police Station on January 01, 2009 in the matter of forgery of SEBI communications, for action under the relevant provisions of law. Subsequent to the lodging of FIR, it also prima facie appeared that the forgery was done to manipulate the price of PSTL shares and that Shri Nirmal Kotecha was one of the major beneficiaries of the said manipulation exercise. Therefore, an Investigating Authority was appointed to investigate into the market manipulation, which in this case, appeared to be linked to the forged SEBI letters.

6. From the interim Investigation Report submitted to me, I note that in NSE, the scrip opened on December 22, 2008 at Rs. 83, a rise of 10% from the previous day’s closing price of Rs. 75.45, before closing at Rs. 67.90, a fall of 10% on close to close basis. Similar trend was seen on BSE on that day. A total of 40,29,254 shares were traded on this date in NSE, representing a rise of 310.03% over the previous date. Similar trading pattern was observed in BSE as well. 7. On BSE, based on the intraday price movement on December 22, 2008, transactions in three time slots viz. (between 09:55:00 am and 10:28:04 am, 10.28.05 a.m. and 12:16:33 pm and between 12.16.34 p.m. and the end of the day) were analysed: a. Patch I: (9:55 a.m. and 10:28:04 a.m) On BSE, the denial by the company was put out at 10.28:04. The scrip opened at Rs. 82.90 and decreased to Rs.79.60 at 10:28:04 i.e. prior to the denial by the company of the letter purportedly issued by SEBI. The total traded quantity during this patch was 23,22,338 shares It was observed that trading member, M/s. Wallfort Financial Services Ltd. dealing on its own account was the highest net purchaser for 25,000 shares at an average price of Rs. 82.64 per share whereas the highest net seller was Shri Nirmal Kotecha dealing through trading members, Kotak Securities Ltd. and IL&FS Investsmart Ltd., who sold 2,25,444 shares at an average price of Rs. 81.02. b. Patch II: (10.28.05 a.m. and 12:16:33 p.m) After the denial by the company, the price fell from Rs. 79.60 to Rs.74.10 at 12.16.33 p.m.

The total traded quantity during this patch was 24,84,862 shares. It was observed that M/s. Mumbai Stock Broking Pvt. Ltd. (Ratna Bhatia), dealing through the trading member, M/s. Joindre Capital Services Ltd. was the highest net purchaser for 7,500 shares at an average price of Rs.76.96 whereas the highest net seller was Shri Nirmal Kotecha, dealing through the trading members, IL&FS Investsmart Ltd. and M/s. India Capital Markets Pvt. Ltd., who sold 67,983 shares at an average rate of Rs. 76. c. Patch III: (12.16.34 p.m. till the end of the day) During this period, the price decreased from Rs. 74.10 to Rs. 67.90, its intra-day low. The total traded quantity during this patch was 15,97,236 shares. It was observed that M/s. Amisha Developers Ltd. (Amar Shah), dealing through the trading member, M/s. Goldmine Stocks Pvt. Ltd. was the highest net purchaser for 50,000 shares at an average price of Rs.68.00 whereas the highest net seller was Shri Nirmal Kotecha dealing through the trading members, M/s. JM Financial Services Pvt. Ltd., M/s. Indiabulls Securities Ltd. and M/s. India Capital Markets Pvt. Ltd. who sold 3,71,768 shares at an average rate of Rs. 68.36.

8. On NSE, based on the intraday price movement on December 22, 2008, transactions in three time slots (viz. between 09:55:00 am and 10:37:00 am, 10:37:01 am and 12:25:00 pm and between 12:25:01 pm to 15:30:00 pm) were analysed: a. In the first time slot (Price Movement: Rs. 83 to Rs. 77.50), M/s. Escort Opportunities was the top net buyer with net buy of 1 lac shares accounting for 9.48% to market (net). Shri Nirmal Kotecha trading through 4 Trading members was the top net seller and has net sold 4.45 lac shares and accounted for 39.87% to market (net). b. In the second time slot (Price Movement: Rs. 77.50 to Rs. 67.90), M/s. Meet Shares and Stocks was the top net buyer with net buy of 0.32 lac shares accounting for 6.05% to market (net). Shri Nirmal Kotecha trading through 3 Trading members was the top net seller and sold 3.45 lac shares (net) and accounted for 66.20% to market (net). c. In the third time slot, when the scrip hit the lower circuit, M/s. Regent Finance Corporation was the top net buyer with net buy of 0.25 lac shares accounting for 10.67% to market net. Shri Nirmal Kotecha trading through 2 Trading members was the top net seller and has net sold 0.51 lac shares and accounted for 66.20% to market (net).

9. From the above, I note that Shri Nirmal Kotecha, a HNI and a part of the then promoter group, was a major seller in the PSTL scrip on December 22, 2008, having sold 15,05,862 shares on market at an average price of Rs. 75.85 per share on that day. It is seen that out of the same, he sold 6,69,611 shares on BSE and NSE at an average rate of Rs. 80.92 per share on December 22, 2008, before Shri Saminathan denied receipt of the purported SEBI letter that morning. 10. I further observe from the interim Investigation Report that Shri Deepak Thakkar, who is the maternal uncle of Shri Nirmal Kotecha, bought 19,758 shares, 80,000 shares and 85 PSTL shares on December 16, 2008, December, 17, 2008 and December 22, 2008 respectively and sold 99,843 PSTL shares on December 22, 2008. The purchase price was in the range of Rs.53.96 and Rs.62.04 and only 85 shares were bought by Shri Deepak Thakkar at Rs.80.49 on December 22, 2008. The sale price was in the range of Rs.80.10 to Rs.82.30. I find that Shri Deepak Thakkar, in the bargain, has made a profit of Rs. 20,76,064 from the said transaction.

11. I further note that the purchases by Shri Deepak Thakkar were just prior to the publication of the news about the forged SEBI open offer letter that was sent to Shri P S Saminathan on December 19, 2008. The sale of shares by Shri Thakkar were again prior to the announcement by Shri Saminathan denying the open offer, on the morning of December 22, 2008. I further note that the buy and sell instructions to the broker on Shri Thakkar’s behalf were given by Shri Nirmal Kotecha. 12. From the interim Investigation Report placed before me, I further find that the bank trail of Shri Nirmal Kotecha and his related/ associated persons/ entities has revealed details of certain persons/ entities through whom he had routed funds. Prima facie, it appears that this was done to disguise the trail of his trading. I find that on November 19, 2008, Rs. 15 lacs were transferred from the account of M/s. Nirman Management Services Pvt. Ltd. (herein after referred to as Nirman), one of the companies of Shri Nirmal Kotecha, to Shri Deepak Thakkar’s account. On December 02, 2008, I again find that Rs. 15 lacs were transferred by Shri Nirmal Kotecha from his account to the account of Nirman, and from there, this amount was transferred to the account of Shri Deepak Thakkar on December 04, 2008. Subsequently, I find that on December 16, 2008, Shri Deepak Thakkar, in turn, has transferred Rs. 25 lacs to his client account held with M/s. Kotak Securities Ltd. (herein after referred as Kotak).

I further find that Shri Deepak Thakkar had bought 19,758 shares of PSTL on December 16, 2008 and 80,000 shares on December 17, 2008 through Kotak. I observe that the buy orders in Shri Deepak Thakkar’s account were placed by his representative Shri Nirmal Kotecha. The pay-in of the funds for shares bought on December 16, 2008 was due on December 18, 2008. On that day, Shri Thakkar had a credit balance of Rs. 19,84,225.05 in his account after adjusting Rs. 25 lacs transferred to his client account with Kotak. The pay-in of the funds for shares bought on December 17, 2008 was due on December 19, 2008. However, Shri Thakkar did not make any further payment on December 19, 2008, and as a result, there was an outstanding debit of Rs. 35,15,874.82 in the account of Shri Thakkar as on December 19, 2008. Instead of bringing in the funds, I observe that Shri Nirmal Kotecha had in the morning of December 22, 2008, instructed Shri Thakkar’s broker to sell the shares of PSTL lying in the account of Shri Deepak Thakkar. 13. Further, from the interim investigation report, I find that though Shri Nirmal Kotecha claimed that mobile number 9819988816 belonged to him, I note that the investigation has revealed that the mobile number 9819988816 is actually registered in the name of Shri Amol Anand Kokane, 24 (resident of 622/B, Kushaba Kale Chawl, N.M.

Joshi Marg, Byculla, Mumbai – 400027). I further note that Shri Amol Kokane has claimed that he is a student of Engineering College at Navi Mumbai and that he did not have any personal income. He claimed to have opened an account with the broker M/s. India Capital Markets Pvt. Ltd. on the recommendation of his late brother-in-law, Shri Sandeep Shripati Gavhane, who worked as an accountant with M/s. Kotecha Capital Services Pvt. Ltd. In his statement, I find that Shri Amol Kokane has also claimed that his brother-in-law was operating that account for his boss Shri Nirmal Kotecha and that he used to take his signatures on forms and documents. I note that Shri Kokane has also claimed that he does not have any idea about the share market, that he has never visited the broker’s office, and had never given any order (buy or sell) to the broker. Further, I note that he has also claimed that his account was being operated by his brother-in-law, till his brother-in-law met with an accident on October 16, 2008 and had to be hospitalized. Further, after the death of his brother-in-law on November 01, 2008, Shri Kokane avers that Shri

Nirmal Kotecha was operating all his accounts. Shri Kokane claimed that Shri Nirmal Kotecha used to send one Shri Anil to get his signature affixed on the cheque book and the Depository Instruction Slip (herein after referred to as DIS) and that he had signed as many as 8-10 blank cheque leaves and full DIS. 14. I further also note that cash payments as high as Rs. 40,000 in a month, has been made towards charges incurred on the aforesaid mobile number. The details of the monthly charges incurred on the said mobile number and the cash payments made are at Annexure – A. I also find it pertinent that Shri Kokane has claimed that the mobile number 9819988816, which was registered in his name, was never used by him nor his brother-in-law, but was used by his brother-in-law’s office staff. Considering that Shri Amol Kokane was a student and also the fact that the family’s annual income as disclosed in the Client Registration form of the broker (M/s. India Capital Markets Pvt. Ltd.) was only in the range of Rs. 1-5 lacs, it becomes clear that such sizable cash outflow was beyond the family’s capacity.

Therefore, I can only infer that such payments could have been funded only by a third party. 15. As per the trade data provided by the Exchanges BSE and NSE, I observe that Shri Amol Kokane has traded from September 16, 2008 to November 17, 2008 on NSE and from September 16, 2008 to November 20, 2008 on BSE. I find that Shri Kokane traded in the scrips of PSTL, Usher Agro, SEL Mfg. Suzlon Energy, Akruti City, RIL, REL, Unitech Ltd. etc. through the broker M/s. India Capital Markets Pvt. Ltd. (herein after referred to as India Capital Market). I find that the client account with India Capital Market was opened in his name on September 12, 2008 and on the same day, Shri Nirmal Kotecha too has opened a new client account with India Capital Market. 16. I also note from the interim Investigation Report that during the period from September 29, 2008 to November 17, 2008, Shri Kokane was generally buying at a higher rate and selling at a lower rate on both Exchanges (BSE and NSE) in the PSTL scrip. A detailed analysis of the same is at Annexure - B. I further find that during the period October 10, 2008 to November 27, 2008, 218 of the trades in PSTL on BSE of Shri Amol A. Kokane were at prices 0.5% higher than the last traded price during this period and were in the range of Rs.0.25 to Rs.5.1, higher than the last traded price on BSE.

It would be correct to deduce that this has contributed to the price movement from Rs.40.45 to Rs.65.45 during that period. On NSE too, in the scrip of PSTL, I note that in 120 instances, the trades of Shri Amol A. Kokane were at price 0.5% higher than the last traded price. I further find that the trading of Shri Kokane in PSTL scrip on BSE during the period October 10 to November 27, 2008 accounted for around 14.98% of the total traded volume during the ten trading days on which he has traded on BSE. I also find that on two consecutive trading days in November 2008, Shri Kokane has contributed to more than 20% of the market volume on those days, thereby influencing the price considerably. These trades done from Shri Kokane’s trading account have, thus, influenced volumes and price of the scrip. A detailed analysis of the same is at Annexure - C. 17. Besides, I note from the interim investigation report that as on September 30, 2008, Shri Nirmal Kotecha was holding around 4% shareholding (7,24,536 shares) in M/s. Usher Agro Ltd., one of the scrips in which 86,372 shares were bought and sold on BSE in the name of Shri Amol Konkane in a period of 4 days from September 16 to 19, 2008 at a profit of Rs. 4,66,753.25.

Shri Nirmal Kotecha evidently had a close link with M/s. Usher Agro Ltd., as seen from the fact that Shri Kotecha was constantly in touch with one Shri Pandoo Prabhakar Naig, (understood to be on the Board of various companies, and is one of the independent directors on Board of M/s. Usher Agro Ltd., as per the information available on M/s. Usher Agro Ltd.’s website). I further find that Shri Nirmal Kotecha, was holding more than 10% stake (18,74,755 shares) as on June 30 2008 in M/s. SEL Mfg. Co. Ltd., one of the other scrips in which 96,938 shares were bought and sold on BSE and NSE in the name of Shri Amol Konkane during the period September to November 2008 at a profit of Rs. 8,46,761. The stock price of M/s. SEL Manufacturing Company is understood to have plunged from Rs.626.10 on 7 August 2008 to Rs. 400.75 on BSE after Nirmal Kotecha offloaded 3.4% of the company’s equity stake in open market between 7 August 2008 and 11 August 2008. It is also understood that M/s. SEL Mfg. which came out with its IPO in July 2007 at a price band of Rs. 80-90 per share (face value Rs. 10 each) had made a pre-IPO placement of 5 lac shares to Shri Nirmal Kotecha at Rs. 75 per share.

I also observe Shri Nirmal Kotecha’s close link with M/s. SEL Mfg. Co. Ltd. from the fact that Shri Nirmal Kotecha was constantly in touch with Shri Neeraj Saluja, MD of M/s. SEL Manufacturing Company. Further, I note that on February 27, 2008, when the process of recording of Shri Amol Kokane’s statement by SEBI officials was in progress at his residence, Shri Nirmal Kotecha came to Shri Kokane’s residence and directed him not to disclose any material information to SEBI officials and only to record the statement to the effect that he does not have any knowledge of anything in the matter of PSTL. He also advised him to say “I don’t know” to any question that SEBI officials would ask him in the matter. Shri Kotecha was advised by the concerned officers of SEBI, that he should not interfere and disrupt the recording of the statement. However, he remained there and tried to influence Shri Kokane and prevent him from disclosing any further material information to SEBI. He also advised Shri Kokane to change his statement that had already been recorded. As a result, further statement of Shri Kokane could not be recorded.

This act of Shri Kotecha, I find, was a clear interference by him in preventing SEBI officials in carrying out their activities as public servants. I note that a complaint was lodged by SEBI officials with the Sr. Inspector, Agripada Police Station immediately thereafter to take necessary action under law in the matter. 18. I further find that in the PSTL scrip, in particular, Shri Kokane has made gross purchases of 4,59,084 shares against gross sales of 4,21,974 shares on BSE and gross purchases of 73,509 shares against gross sales of 1,09,619 shares on NSE. I also find that, on BSE, he had a net purchase value of Rs. 47,76,022 as against net sales value of Rs. 19,33,354 on NSE in the PSTL scrip. Thus, based on his transactions in PSTL on BSE and NSE taken together, I find that Shri Kokane has incurred an overall loss of Rs. 28,42,668. 19. Further, considering the overall trading done on behalf of Shri Kokane across scrips, I observe that Shri Kokane has made gross purchases of 6,01,554 shares against gross sales of 5,75,978 shares on BSE and gross purchases of 1,66,097 shares against gross sales of 1,01,695 shares on NSE.

Again, taking his overall trading on BSE into consideration, I find that he had purchased shares for a value of Rs. 23,78,347.55 (net) and on NSE he had further purchased shares for a value of Rs. 3,11,134 (net). Thus, I find that based on the overall trading done by him, Shri Kokane has incurred an overall loss of Rs. 26,89,481.55. 20. I also observe that Shri Kokane had bought 1,60,883 shares and 1,52,095 shares at a price of Rs. 49.97 and Rs. 56.21 respectively through bulk deals in the PSTL scrip in BSE on November 03, 2008 and November 04, 2008. However, I note that Shri Kokane in his statement has stated that his brother-in-law expired on November 01, 2008 and so his family had gone to his village at post Salgaon, Tal. Ambegaon, Dist. Pune and returned only on November 15, 2008. He also claimed that he has never given any order of buy/ sell to the broker. After the death of his brother-in-law on November 01, 2008, Shri Kokane further claimed that Shri Nirmal Kotecha was operating all his accounts. 21. I find that the above facts taken together with other related observations (viz. volume of trades done by Shri Amol Kokane through India Capital Market, the scrips that were selected for trading in his name and the losses incurred by him on these trades, the counterparty details that have emerged from the bank trail and the call/ Short Messaging Service (SMS) charges incurred by Shri Kokane on his mobile number 9819988816, relative to his family’s annual income) prime facie, go to establish that Shri Nirmal Kotecha was using Shri Amol Kokane as an instrument for his own trades.

Prima facie, it emerges from the evidence discussed above that Shri Nirmal Kotecha was fraudulently carrying out manipulative activities, in an otherwise falling market, using Shri Amol Kokane’s name and his various linkages, even prior to the forged SEBI letter and this further stands established from the pattern of his trades described earlier in this order. 22. Shri Amol Kokane in his statement has admitted that Shri Nirmal Kotecha was operating all his accounts. All of the above, I note, prime-facie confirms an inference that the only intention behind these trades of Shri Nirmal Kotecha through Shri Amol Kokane, was to artificially inflate the price of PSTL scrip. This coupled with the claim of Shri Amol Kokane that Shri Nirmal Kotecha was operating his accounts, clearly indicates that the whole plot involving the forgery of SEBI letters has been for the purpose of enabling Shri Nirmal Kotecha to sell in the market at artificially raised prices. 23. The above inference is further strengthened by the fact that the bank trail of the high value funds transferred to Shri Kokane’s account, from where they were transferred to the stock market, has revealed that these funds have been received from various entities/ persons who appear to be connected to each other, and in whose bank accounts, funds appear to have been circulated through a large network of their connected accounts, in a complex pattern and without any ostensible and bonafide business purpose.

The investigation has also revealed frequent high value cash withdrawals and cash deposits, by limiting individual cash withdrawals and deposits to below Rupees ten lacs, in these accounts. From the above, I infer that these numerous bank accounts may have been opened with the sole purpose to disguise the trail of the suspicious transactions being carried out in these accounts. It is also seen that some of these persons/ entities, in whose names these accounts stood, have traded in the stock market. These high value money transactions through Shri Kokane’s accounts and his trades, only indicate that he was a necessary party to the events, which culminated in the execution of trades in the shares of the company. The details of bank trail of Shri Amol Kokane’s bank account carried out so far is at Annexure - D. 24. Further more, the examination done so far, of the bank accounts of Shri Nirmal Kotecha and his immediate relatives/ entities, over a six month period from June to December 2008, has revealed that he has withdrawn cash of about Rs. 1.25 crore around August end and mid-September, 2008. For this purpose, I find, he has also transferred funds from his account to his immediate relatives/ his related entities account.

Further, I find that that the same modus operandi (withdrawing high value cash by keeping individual cash withdrawals below Rupees 10 lacs, to avoid triggering of Rules framed under the Prevention of Money Laundering Act in the aforesaid suspicious transactions accounts, discussed earlier in the order, and subsequently transferring the funds to Shri Amol Kokane’s account), has been adopted in the transfer of funds into and out of Shri Nirmal Kotecha’s account, as well as the accounts of his immediate relatives/ his related entities. I also find that significant amount of cash has been withdrawn by Shri Kotecha, a day before the forged letter was dispatched to Shri Saminathan by courier, on the day the forgery received wide media publicity, and again, immediately thereafter. The details of bank trail of Shri Nirmal Kotecha’s bank accounts and that of his immediate relatives / his related entities bank accounts, available at this stage of the investigation are at Annexure - E. Considering all these facts together, I am compelled to prima facie arrive at the conclusion that Shri Nirmal Kotecha has masterminded the forged SEBI letter that was sent to Shri Saminathan.

25. Further, from the interim investigation report before me, I find that an amount of Rs. 10 lacs has been transferred from Shri Nirmal Kotecha’s account to his wife Ms. Viral Doshi’s account on September 25, 2008, and from here these funds, in turn, have been transferred to one Shailesh Jayantilal Shah’s account on the very same day. This amount of Rs. 10 lacs has been returned to Ms. Viral Doshi’s account by Shri Shailesh Jayantilal Shah in three tranches of Rs. 4 lacs, Rs. 5 lacs and Rs. 1 lac on December 26, 27 and 31, 2008 respectively. I note that Shri Shailesh Jayantilal Shah’s account also reflects repeated cash deposits of Rs. 90,000, Rs. 32,000, Rs. 1.5 lacs and Rs. 1 lac on December 01, 04, 23 and 31, 2008 respectively, Rs. 1.6 lacs on January 05, 2009 and two cash deposits of Rs. 45,000 and Rs. 1.5 lacs on the same day i.e. January 07, 2009. 26. I further find that Shri Shailesh Jayantilal Shah had bought 8,336 PSTL shares (net) from December 16, 2008 to December 19, 2008 at an average price of Rs. 69.67 per share. On December 22, 2008, he sold 32,000 shares (between 9:57:20 and 10:35:32) at an average price of Rs. 79.18 per share, before the announcement denying the open offer was made by Shri Saminathan.

The investigation, so far, has also revealed that on the same day, he bought 28,700 shares after the said sale, out of which 21,557 shares match with Shri Nirmal Kotecha’s sales on the same day at an average price of Rs. 77.50 per share. The trade details of Shri Shailesh Jayantilal Shah in the PSTL scrip during the period December 15, 2008 to December 23, 2008 are at Annexure - F. 27. Here again, I find prima facie, that the sequence of events (i.e. transfer of funds from Shri Nirmal Kotecha’s account to his wife Ms. Viral Doshi’s account on September 25, 2008 and from there to Shri Shailesh Jayantilal Shah’s account, repeated cash deposits made in Shri Shailesh Jayantilal Shah’s account during the period, purchases just prior to the forgery and sale immediately on opening of the market after the news of the purported issue of the letter by SEBI became public, but, before its denial by Shri Saminathan, matching of subsequent purchases on December 22, 2008 with Shri Nirmal Kotecha’s sales and returning of funds back to Ms. Viral Doshi’s account on December 26, 27 and 31, 2008) leads to the conclusion that Shri Shailesh Jayantilal Shah had aided and abetted Shri Nirmal Kotecha in disguising his manipulative trading.

28. I also find from the interim investigation report that Shri Rajesh Jayantilal Shah, Ms. Binaben Shaileshkumar Shah, Shri Nirmal Rohitbhai Shah, Ms. Ritaben Rohitkumar Shah, Ms. Manishaben Rajeshkumar Shah, all of whom share the same address with Shri Shailesh Jayantilal Shah (hereinafter referred to as Shah group), traded during the period December 15, 2008 to December 23, 2008 in PSTL scrip. The details of their trades are at Annexure - G. Shri Rajesh Jayantilal Shah, in particular, is found to be one of the top five net sellers on December 22, 2008 till 10.28.04 a.m. i.e. prior to the denial by the company of the letter purportedly issued by SEBI. He has sold 49,000 shares on December 22, 2008 at an average rate of Rs. 82.87 per share through trading member M/s. J M Financial Services, prior to this denial. From the trading pattern of the Shah Group, it prima facie, emerges that the all the entities in the Shah group have abetted Shri Nirmal Kotecha in disguising his manipulative trading and gaining undue profits. 29. I further observe that one Raju G. Shah traded in the scrip of PSTL through the broker India Capital Market on two trading days viz. December 19 and 22, 2008 on BSE.

Shri Raju G. Shah’s client account was opened with the Borivali branch of India Capital Market in July 2008. From the interim investigation report before me, I find that on December 19, 2008, Shri Raju G. Shah bought and sold 71,805 shares on BSE. Out of the total buy of 71,805 shares of Shri Raju G. Shah on December 19, 2005, 13,731 shares matched with the sales by Shri Nirmal Kotecha. On December 22, 2008, 7,345 shares bought by Shri Raju G. Shah matched with the sales of Shri Nirmal Kotecha. Again on NSE I find that out of the 51,738 shares bought by Shri Raju G. Shah on December 19, 2008, 4006 shares matched with the sales by Shri Nirmal Kotecha. Similarly, out of 1,05,202 shares bought by Shri Raju G. Shah on December 22, 2008, 22,460 shares matched with the sales by Shri Nirmal Kotecha. Therefore, a total of 47,542 shares bought by Shri Raju G. Shah matched with Shri Nirmal Kotecha’s sales on December 19 and 22, 2008. I find it significant to mention here that the bank trail has revealed that Shri Raju G. Shah had received Rs. 5 lacs from Shri Nigam Vinod Shah on November 04, 2008, and Shri Nigam Vinod Shah, in turn, had received these funds from Shri Rajesh Jani, who is the Director of M/s. Dynamic Stock Broking (India) Pvt. Ltd. From the interim Investigation Report, I find that Shri Nigam Vinod Shah was introduced by one Nimesh Chitalia, who is the Head, Business Development of India Capital Market, where Shri Raju G. Shah himself had opened his trading account in July 2008. I have also noted the fact that Shri Nigam Vinod Shah is the person who had on an earlier occasion on October 10, 2008, transferred Rs. 15 lacs to Shri Amol Kokane’s account.

In view of the above, I find prima facie that Shri Raju G. Shah has also abetted Shri Nirmal Kotecha in carrying out the suspicious banking transactions observed and disguising his manipulative intent in the transactions in PSTL scrip. 30. I further find that during the period November 19, 2008 to January 07, 2009, Shri Nirmal Kotecha has off-loaded almost his entire stake in PSTL on BSE and NSE. In this period, Shri Nirmal Kotecha was a net seller in the scrip of PSTL having sold 70,99,117 shares (net). The details of his transactions in PSTL scrip during the period are at Annexure - H. I prima facie find from the above that Shri Nirmal Kotecha was operating in the PSTL scrip during the period October to mid-November 2008, primarily through Shri Amol Kokane to disguise his manipulative transactions. During the later stages, it appears that Shri Nirmal Kotecha used the trading account of his uncle Shri Deepak Thakkar, the Shah Group and Shri Raju G. Shah to disguise his manipulative transactions and the profits earned by him. I find that Shri Nirmal Kotecha last traded in the scrip of PSTL on January 7, 2009. On the previous day i.e. January 6, 2009 the scrip closed at Rs.41.40 at BSE.

I observe that subsequent to the transactions of Shri Nirmal Kotecha in PSTL shares as mentioned above, the scrip witnessed a significant fall and closed at Rs.26.25 on January 20,

2009 on BSE. The fall in the price of the scrip continued further and the price of the scrip reached a low of Rs.13.15 on March 5, 2009 on BSE. Hence, I observe that Shri Nirmal Kotecha off-loaded almost his entire stake at artificially inflated price levels, before the scrip witnessed significant value erosion. Thus, in short Shri Nirmal Kotecha has transferred the shares of PSTL to the investors at inflated prices. 31. The above shows that besides Shri Amol Kokane, a number of entities who have traded in PSTL scrip, have connections with Shri Nirmal Kotecha, who has directly or indirectly used these entities, to disguise his manipulation of the volume and price of trades in the scrip of PSTL. From the above, I find prima facie evidence of both -the manipulative intent of Shri Nirmal Kotecha in his trading in the market through front entities, as well as his knowledge of the forgery. I, therefore, find prima facie that Shri Nirmal Kotecha has engaged in fraudulent, abusive, manipulative and illegal activities, detrimental to the interests of investors and to the integrity of securities market and that this warrants immediate preventive action by SEBI.

32. Shri Amol Kokane had lent his name for facilitating Shri Nirmal Kotecha to carry out his fraudulent, abusive, manipulative and illegal activities, detrimental to the interests of investors and to the integrity of the securities market. I am of the view that he has, whether willfully or not, aided Shri Nirmal Kotecha in carrying out his fraudulent activities. 33. I also find prima facie that Shri Deepak Thakkar, the maternal uncle of Shri Nirmal Kotecha, the Shah Group and Shri Raju G. Shah - have all played a key role in facilitating Shri Nirmal Kotecha in carrying out suspicious banking transactions, carrying out and disguising his manipulative intent and gaining advantage from the forgery. 34. Further, I find that the operations appear to have involved activities which are potentially money laundering in nature, and are detrimental to the genuine investors, at large. The persons/ entities and their proprietors/ partners/ directors (including Shri Nirmal Kotecha and his immediate relatives/ related entities), identified in this order have primia facie carried out suspicious banking transactions and have routed these funds, either directly or indirectly in the stock markets, to finance spurious transactions, thereby defrauding genuine investors.

35. From the interim investigation report, I also find that one Rakesh Sharma played a major role and was instrumental in publicizing the contents of the forged SEBI letter that was sent to Shri Saminathan, through his circle of friends connected to the media, and also, ensuring that they publish the news of the open offer before the opening of the markets on December 22, 2008. Shri Rakesh Sharma, then an executive with M/s. Adfactors PR Pvt. Ltd. (herein after referred to as Adfactors) and is one of the accused in the FIR filed by SEBI. He had made certain oral statements to SEBI officials, before he was arrested by the police in respect of the FIR lodged by SEBI. He subsequently changed his statement when he appeared before SEBI after his release on bail for recording of his statement. However, the mobile tower locations as stated below in this Order (obtained from mobile service providers) clearly corroborate the earlier version given by him. As seen below in this order, another person Shri Rajesh Unnikrishnan, also appears to have facilitated the publication in the media of the forged letter that was sent to Shri Saminathan.

Shri. Rajesh Unnikrishnan is presently the Assistant Editor of Economic Times. He was also a former colleague of Shri Rakesh Sharma in Business Standard. Shri.

Unnikrishnan had also covered some stories for Economic Times on transfer of PSTL shares from one promoter to another, prior to the forgery. It was also further observed that Shri Unnikrishnan was in touch with Shri Nirmal Kotecha, particularly after December 10, 2008. 36. The tower locations of Shri Kotecha’s number (registered in the name of Shri Amol Kokane), Shri Rakesh Sharma’s number and Shri Rajesh Unnikrishnan’s number indicate that the three had met in the afternoon of December 20, 2008 i.e. the day and around the time when the forged SEBI letter was circulated to the media through Shri Rakesh Sharma’s contacts in the media. An analysis of the data received from the mobile service providers reveals that on December 20, 2008, at 12:13 p.m., Shri Nirmal Kotecha was at (opposite) Swami Narayan Mandir and at 12:23 p.m., he was at Pritam Hotel. Shri Rajesh Unnikrishnan too was near Pritam Hotel at 12:03 p.m., 12:09 p.m. and at 12:23 p.m. on the same day. Shri Rakesh Sharma was also at Hindu Colony, Dadar TT at 12:11 p.m. I find that the tower location details indicates that Shri Nirmal Kotecha was at Matunga (E) (from 1:12 p.m. to 2:27 p.m.).

Similarly, the tower location details shows that Shri Rajesh Unnikrishnan was also at Matunga (E) between 12:57 p.m. and 1:44 p.m. I find that the tower location details too indicates that Shri Rakesh Sharma was at Maheshwari Udyan, Matunga at 1:52 p.m. and King Circle at 1:53 p.m. The above seems to corroborate the admission made by Shri Rakesh Sharma, before he was arrested by the police that the three of them had met at Hotel Pritam at Dadar TT. I also note that in the same statement, later retracted by Shri Rakesh Sharma, he had further admitted that they had gone to Shri Nirmal Kotecha’s residence by taxi between 12:30 p.m. to 1:30 p.m. from where Shri Rakesh Sharma had e-mailed the forged SEBI letter that was addressed to Shri Saminathan, CMD, PSTL, to some of his friends in the media. 37. Shri Rakesh Sharma, before being arrested had claimed that the forged SEBI letter was e-mailed by him from Shri Nirmal Kotecha’s residence by using his own personal e-mail ID to his following media contacts, (Shri Raj Nambisan of DNA, Shri Partha Sinha of TOI and Shri Ashish Rukhaiyar of ET) before accompanying Shri Rajesh Unnikrishnan to Dalal Street side around 2:00 p.m.

Based on the copies of the e-mail submitted to SEBI by the reporters, I find that the Investigation has revealed that the e-mail to Shri Partha Sinha was sent at 1:43 p.m. i.e. around the time when the tower location for all three of them as seen in the data was Matunga (East)/ King Circle. Shri Kotecha’s residence is also at Matunga (East)/ King Circle. This corroborates Shri Rakesh Sharma’s initial admission that the e-mail to Shri Partha Sinha was forwarded from the computer in Shri Kotecha’s residence, when all three of them were at his residence. Shri Raj Nambisan of DNA informed the investigation team that he seemed to have deleted the e-mail that was sent to him. The e-mail details forwarded by Shri Ashish Rukhaiyar of Economic Times shows that the e-mail was sent by Shri Rakesh Shrama from his personal e-mail ID to Shri Rukhaiyar’s personal e-mail ID at 3:03 p.m. Further, though Shri Rakesh Sharma claimed that the forged SEBI letter was e-mailed by him to only three of his friends in the media, I find that he had also forwarded the forged SEBI letter by e-mail to Shri Dheer Kothari (one of his ex-colleagues in Adfactors who is based in Kolkata).

From the copy of the e-mail made available by Shri Dheer Kothari, I observe that Shri Rakesh Sharma had forwarded the e-mail to him at 1:43 p.m. on December 20, 2008 i.e. again at a time when all three of them were at Matunga. 38. Further, I find that the telephone records show that Shri Rakesh Sharma was in constant touch with Shri Dheer Kothari on December 20, 2008 from about 12:30 p.m. in the afternoon to about 10:00 p.m.at night. Shri Dheer Kothari informed that he, as per their understanding, had disseminated the information to three newspapers – Business Standard, Telegraph and Hindu Business Line. Shri Dheer Kothari further informed SEBI that he was paid Rs. 10,000/- for doing this. From the bank statement of the concerned period made available by him, I observe that funds of Rs. 10,000/- were transferred to Shri Dheer Kothari’s account on December 23, 2008. From the trail of these funds, I find that Rs. 10,000/- was transferred to Shri Dheer Kothari’s account from Shri Rakesh Sharma’s account with HDFC Bank, Borivali (West) branch (opened in July 2008). 39. I see from the interim Investigation Report that Shri Rakesh Sharma had prior to his arrest, admitted that after sending the e-mails as above to the persons in the media from Shri Nirmal Kotecha’s residence, he and Shri Rajesh Unnikrishnan proceeded to Dalal Street side in a cab around 2:00 p,m., and that Shri Rajesh Unnikrishnan went to his office and that he himself had gone to Shri Ashok Jainani’s office at M/s. Khandwala Securities Ltd. He had further claimed that through Shri Ashok Jainani’s computer, he e-mailed the scanned letter from his e-mail account to Shri Ashok Jainani’s email account, and then, Shri Ashok Jainani sent the same to Business Standard (herein after referred to as BS) at around 3:00 – 3:30 p.m.

From the e-mail copies received by Shri Ashok Jainani, I find that the e-mail from Shri Rakesh Sharma’s personal e-mail ID to Shri Ashok Jainan’s office account was sent at 3:02 p.m. and that on his personal e-mail ID was sent at 3:03 p.m. The e-mail receipt details forwarded by the BS reporter Ms. Priya Nadkarni, indicates that the e-mail was sent to her by Shri Ashok Jainani from his personal e-mail ID to her personal e-mail ID at 3.22 p.m. This too, substantively confirms the e-mail sequences and the timings in the admission made by Shri Rakesh Sharma prior to being arrested. 40. From the above, I find prime facie, that Shri Rakesh Sharma has abetted in providing wide media publicity to the forged letter (containing the SEBI directives on the open offer) that was sent to Shri Saminathan. 41. I further observe that Shri Rakesh Sharma had admitted before his arrest that that when one of the reporters to whom Shri Ashok Jainani had e-mailed the forged letter, desired to ascertain the authenticity of the information by counter checking with the company officials, he contacted Shri Nirmal Kotecha (around 4:30 -5:00 p.m.) on his mobile.

He had further stated that Shri Kotecha responded and sent an SMS to him providing the Company Secretary’s telephone number and his name (as one Shri Ganesan, serving at Chennai office). This, Shri Sharma admitted was passed on by Shri Ashok Jainani to the BS reporter. However, Shri Rakesh Sharma had claimed that Shri Ganesan had informed the BS reporter that there was no such development and denied the contents of the letter. Shri Rakesh Sharma had further admitted that at about 6:00- 6:30 p.m., the reporter of BS had called back Shri Ashok Jainani to inform him about this response from Shri Ganesan. Shri Rakesh Sharma also claimed to have informed Shri Nirmal Kotecha then that the Company Secretary had denied the development and that, in turn, Shri Nirmal Kotecha gave details of another Company Secretary, (name and telephone number of Shri Kanu Sahu) by SMS to him (between 7.00 to 8.00 p.m.). He further claimed that Shri Rajesh Unnikrishnan also sent two SMS’s to him – one to inform the telephone number and the second to inform the name of the Company Secretary (Shri Kanu Sahu). Shri Rakesh Sharma, before his arrest had then stated that he also sent this number through an SMS to all those whom he had forwarded the e-mail earlier, so that, they could confirm the information by talking to Shri Kanu Sahu.

42. I find that the call records indicate that Shri Rakesh Sharma had called Shri Nirmal Kotecha on his number (registered in the name of Shri Amol Kokane) at about 6.13 p.m. Immediately thereafter, I find that Shri Nirmal Kotecha from his number (registered in the name of Shri Amol Kokane) has called Shri Rajesh Unnikrishnan at about 6.14 p.m. and again at about 6.35 p.m. Shri Rakesh Sharma too, called Shri Rajesh Unnikrishnan at around 6.41 p.m. and Shri Ashok Jainani at around 6.51 p.m. Subsequently, thereafter, I find, there had been repeated and long exchange of calls between the three of them. Subsequently, Shri Nirmal Kotecha sent four SMSes, of which two were sent to Shri Rakesh Sharma and two to Shri Rajesh Unnikrishnan between 7.31 p.m. to 7.33 p.m. Shri Rajesh Unnikrishnan, I find, thereafter also sent two SMSes to Shri Rakesh Sharma at about 7.36 p.m. The flow of calls and SMSes continued between the three till about 7.40 p.m. Further, after receiving the SMSes from Shri Kotecha’s number (registered in the name of Shri Amol Kokane) and from Shri Rajesh Unnikrishnan, Shri Rakesh Sharma’s call/ SMS records, I find, indicate that he had sent SMSes to - Shri Raj Nambisan of DNA, Shri Ashish Rukhaiyar of ET, Shri Partha Sinha of TOI, Shri Ashok Jainani of M/s. Khandelwal Securities Ltd., Shri Dheer Kothari, ex-Adactors and Shri Sudhir Shetty, Adfactors.

This, therefore, further corroborates Shri Rakesh Sharma’s admission made before his arrest, that he had received two SMSes each from Shri Nirmal Kotecha and Shri Rajesh Unnikrishnan informing the name and number of the Company Secretary of PSTL (Shri Kanhucharan Sahu) and, that he in turn, had passed on the same to all those to whom he had forwarded the e-mail earlier. 43. From the interim Investigation report, I further note that Shri Kanhucharan Sahu is the Compliance Officer and Company Secretary of PSTL since March 2008. In his statement recorded on January 28, 2009 at SEBI, he claimed that only mobile numbers 9790910824 and 9940249404 belong to him. He further stated that he did not receive any calls on December 19, 20 and 21, 2008 in the matter of the forged SEBI letter advising Shri P.S. Saminathan to make an open offer. I further note that he has also stated that neither any person from the media or any reporter called him on those days, nor did he receive any calls from Shri Nirmal Kotecha on those days. In his statement given to the investigation team, he has stated that he had not confirmed to anybody regarding the receipt of the letter by the company, and that, he spoke to Shri Nirmal Kotecha only after issue of SEBI’s press release and that the conversations were in the routine matters including the forged SEBI letter.

44. In view of the statement as above made by actual Shri Kanhucharan Sahu, the actual Compliance Officer and Company Secretary of PSTL, the billing name and address of mobile number 9947219100 was called for from the service provider. I find that the number belongs to one Shri Pratheesh Kumar V. K. with billing address as (Vanury House, Palakkat Lane, Thrissur). The call records of Shri Kotecha’s number (registered in the name of Shri Amol Kokane), I find, also indicates that immediately thereafter, Shri Nirmal Kotecha has sent two SMSes each at (about 7:32 p.m. and 7:33 p.m.) to Shri Rakesh Sharma and Shri Rajesh Unnikrishnan conveying Shri Kanhucharan Sahu’s number as 9947219100. At about 7:43 p.m. Shri Kotecha called Shri Pratheesh Kumar V. K. (the billing name and address of whom is given as above) and the call lasted for around 320 seconds, after which he SMSed him at around 08:06 p.m. Further, the call records also indicate that Shri Pratheesh Kumar too called him back around 10:28 p.m. and the call lasted for about 847 seconds. The tower location details pertaining to the mobile number of Shri Pratheesh Kumar

V.K. indicates that he was in Cochin during that period. However, he failed to present himself when he was summoned by SEBI to record his statement. 45. I further observe that the reporters in their statements given to the Investigation team have also stated that when they contacted Shri Rakesh Sharma or Shri Ashok Jainani to verify the authenticity of the facts mentioned in the forged letter that was e-mailed to them, they were directed to Shri Kanhucharan Sahu, the Company Secretary and given his mobile number 9947219100. Some of the reporters who called that number either on December 20 or 21, 2008, have further informed that the person who took the call confirmed that they had received the letter and were looking into the matter. Details of the reporters’ versions given to SEBI are at Annexure - I. 46. Thus, I find prima facie, from the above that the trio of Shri Nirmal Kotecha, Shri Rakesh Sharma and Shri Rajesh Unnikrishnan had plotted to mislead the media into believing the authenticity of the information that was circulated by them. I further find prima facie, that they had together designed and executed a plan with great precision, that the reporters who called them to confirm the genuineness of the information, were actually led to believe in its genuineness.

In this manner, i.e. by using Shri Pratheesh Kumar V. K as an imposter in place of the actual Company Secretary, Shri Kanhu Charan Sahu, I find, that the trio of Shri Nirmal Kotecha, Shri Rakesh Sharma, Shri Rajesh Unnikrishnan had ensured that the reporters published the news item the very next day. This helped achieve the objective to ensure wide publicity for the news on the open offer through media circles before the opening of the market on December 22, 2008. In turn, this helped achieve what prima facie appears to have been the end objective - to facilitate Shri Nirmal Kotecha to offload his stake on December 22, 2008 when the market opened, at artificially inflated price as against the last traded price, and earn a sizable profit (both directly as well as indirectly by using persons such as his maternal uncle Shri Deepak Thakkar, Shah Group etc.) as observed previously in the order, before news of the forgery became public. I, thus, find that prima facie, Shri Nirmal Kotecha planned and executed the forgery as a means to accelerate the upward movement of the share price of PSTL and to derive unlawful profit, whether directly or indirectly, before the forgery came to light.

That the person who delivered the forged letter to the courier company Blue Dart for dispatching it to Shri Saminathan would have been advised to give instructions to the courier company - NOT to deliver the letter on Saturday to PSTL and to deliver it ONLY on Monday (December 22, 2008) seems to therefore fit into well in what prima facie appears to be a very devious plan. 47. In view of the above, I have no hesitation in concluding that Shri Nirmal Kotecha, Shri Rakesh Sharma and Shri Rajesh Unnikrishnan, have jointly played a key role in an arrangement contrived to defraud investors in the market and derive illegal profits thereof. As brought out above in this order, this scheme was elaborate in its design with several elements which included forgery, dissemination of the false information contained in the forged letter to the media and an attempt to mislead the media to believe in the authenticity of the information that was circulated to them. 48. I further note that certain corporate announcements which prime-facie are misleading in nature were made by Shri P.S. Saminathan, promoter and CMD of PSTL, just prior to the issue of the purported SEBI letter.

PSTL had come out with a public issue of 84,44,000 shares in December 2006. I find that vide its letter dated June 20, 2008, PSTL had informed the stock Exchanges (NSE and BSE) that Shri

P.S.Saminathan, Chairman and Managing Director had purchased 13,70,000 equity shares of the company, representing 4.845% of the paid-up capital of the Company, from Shri Nirmal Kotecha, belonging to the Promoters Group. From the interim Investigation Report before me, I observe that the above transaction was done through the stock broker M/s. Keynote Capital Ltd. (hereinafter referred as Keynote) in the form of a cross deal. The trade was executed at a price of Rs.250 per share, and thus, the total value of the sale was Rs. 34.25 crore. Shri Nirmal Kotecha had requested broker Keynote to transfer the credit of Rs. 34 crore lying in his account with Keynote on account of sale of shares on June 20, 2008 to the account of Shri P.S. Saminathan by debiting his account with Rs. 34 crore, as per his mutual understanding with Shri Saminathan. It is seen from the client ledger provided by Keynote that the money was not actually received in Shri Nirmal Kotecha’s account and that only a ledger entry was passed in the books for transferring an amount of Rs. 33,99,04,292.28 (i.e. credit lying in Shri Nirmal Kotecha’s account after adjusting the debit accumulated in his account of Rs. 1,57,837.24) towards balance transferred to Shri Saminathan’s account, as per client (Shri Nirmal Kotecha’s) written instruction.

It is seen that Shri Kotecha paid Rs. 25,95,707.26 (vide post dated cheque) dated December 02, 2008 to Keynote and requested Keynote to credit the said amount to the account of Shri P.S. Saminathan with Keynote and also requested that 13.70 lac shares be transferred to the Depository Participant (DP) account of Shri P.S. Saminathan. It is seen that though the transaction was executed on June 20, 2008 on BSE, the settlement by delivery of shares was done only on July 24, 2008 by Keynote i.e. after more than one month from the date of the transaction and after it received the post dated cheque from Shri Kotecha on behalf of Shri Saminathan. The balance amount was also paid by Shri Saminathan on July 24, 2008. I observe that there was no receipt of funds by Shri Nirmal Kotecha from Shri Saminathan on the date of the transaction and that on the basis of the letter from Shri Nirmal Kotecha, Keynote has only made book entries. The shares were also not exchanged on the pay-out date. The announcement and the timing by the company, based on information provided by Shri Saminathan and Shri Nirmal Kotecha to the company, were therefore misleading.

49. Further, any acquirer who intends to acquire shares, which along with his existing shareholding would entitle him to more than 15% voting rights, can acquire such additional shares only after making a public announcement (“PA”) to acquire at least additional 20% of the voting capital of the target company from the shareholders through an open offer, unless he is exempted under Regulation 3 of the SEBI (SAST) Regulations, 1997. 50. On April 03, 2008 and April 14, 2008, Shri P.S. Saminathan bought 1,11,335 shares and 8,90,665 shares respectively from Shri V. Natarajan, one of the other promoter in off market transaction, as a result of which, Shri Saminathan’s holding increased from 13.75% to 17.29%. Hence, Shri P.S.Saminathan was already holding more than 15% stake in the company, when he acquired the aforesaid 13,70,000 shares from Shri Nirmal Kotecha. 51. As per Regulation 3(1)(e)(iii)(b) of the SEBI (SAST) Regulations, 1997, an acquisition pursuant to inter-se transfer of shares amongst promoters is eligible for exemption from the applicability of the Regulations 10, 11 and 12 of the SEBI (SAST) Regulations, 1997, as the case may be, subject to certain conditions.

One of these conditions is that the transferees (collectively) as well as the transferors (collectively)

should have been holding the shares in the target company for a period of at least three years prior to the date of acquisition. 52. I observe that the transferor promoter Shri V. Natarajan and transferee promoter Shri P.S. Saminathan were both holding shares for a period more than three years at the time of the April transaction, hence, the transaction was exempt under Regulation 3(1)(e)(iii)(b) of the SEBI (SAST) Regulations, 1997. However, I observe that Shri Nirmal Kotecha was holding shares in PSTL since April 27, 2006. Hence, as the transferor, i.e. Shri Nirmal N. Kotecha did not satisfy the condition that he should have held the shares for three years, such a transaction prima facie was not eligble to be considered for grant of exemption under Regulation 3(1)(e)(iii)(b) of the SEBI (SAST) Regulations, 1997. I find that, in this case, the acquirer was bound by the regulations to make a public announcement in terms of the SEBI (SAST) Regulations, 1997, in respect of his acquisitions, as it triggers the provisions of the SEBI (SAST) Regulations, 1997. 53. Besides the above, it is also seen that Shri P.S.

Saminathan had informed the stock Exchanges (BSE and NSE) on October 10, 2008 that he proposed to acquire 70,45,619 equity shares aggregating to 24.9169% of the shareholding rights of PSTL from Shri N.C. Ravichandran and Shri Nirmal Kotecha, by way of inter-se transfer. The date of the proposed acquisition communicated was November 28, 2008 and the price per share was Rs. 200/-. The shareholding of Shri P.S. Saminathan after the proposed acquisition would have been 1,32,58,575 shares aggregating to 46.8891% of the shares/ voting rights of PSTL. Subsequently, on November 27, 2008, I find that Shri Saminathan again informed the Exchanges (BSE and NSE) that after discussions with the transferees and considering the present market conditions, the price of the proposed acquisition had been revised to Rs.200/- or market price, whichever is lower, and the that the deal would take place on December 22, 2008 and not on November 28, 2008. 54. However, from the interim investigation report, I find that despite announcing on October 10, 2008, the above proposal to acquire shares through interse transfer at Rs. 200/- per share and even before revising the proposed acquisition price, Shri Saminathan acquired 2,80,000 shares from Shri Nirmal Kotecha on November 19, 2008 at an average price of Rs. 50/- per share on BSE.

He also subsequently purchased 61,757, 50,000 and 48,071 shares on November 28, 2008, December 01, 2008 and December 05, 2008 respectively from Shri Nirmal Kotecha. The details of his purchases from Shri Nirmal Kotecha are at Annexure - J. 55. From all of the above, I am of the view that prima facie, the above mentioned public announcements by Shri Saminathan were made only to create public interest in the scrip so as to facilitate Shri Nirmal Kotecha in offloading his PSTL shares in the market at artificially inflated prices. 56. I also note, that that despite Shri Saminathan’s claims to the media that PSTL was grossly undervalued and Rs.200/- was a fair price, Shri Saminathan himself had purchased a total of 8,43,942 shares of PSTL in market transactions at an average price of Rs.45.67 per share during the period from October 24, 2008 to December 5, 2008. I also find that Shri Saminathan had sold a total of 6,000 shares at an average price of Rs.46.66 per share, during this period. The details of the said transactions are at Annexure - K.

57. The interim investigation, so far, has also revealed that Shri Saminathan and Shri Nirmal Kotecha were in touch with each other immediately before the forgery came to light. There was also a sudden spurt in the calls between the Group Company Secretary, Shri S. Ganesan and Shri Nirmal Kotecha in the month of December 2008. The investigation has further revealed that an amount of Rs. 5 lacs was paid by Shri Nirmal Kotecha to the Group Company Secretary, Shri S. Ganesan, through his entity Nirman on December 17, 2008, i.e. two days prior to the dispatching of the forged SEBI letter to Shri Saminathan. This coupled with the misleading announcements made by Shri Saminathan just prior to the forgery, as discussed above, I find, is clearly indicative of the fact that Shri Saminathan was facilitating Shri Nirmal Kotecha in offloading the shares of PSTL in the market at artificially raised price. 58. I also see from the records that Keynote research report dated February 05, 2008 maintained "buy" recommendation on PSTL with 13-month target price of Rs. 1,074/- in February 2008, when the market price was around Rs. 408/- (average price on NSE).

From the perusal of other available research reports of other brokers on PSTL, I find that the recommended buy price around that period was in the range of Rs. 400/- to Rs. 600/-. For example, M/s. Anand Rathi Securities Ltd. had recommended a target price of Rs. 575/- as on January 30, 2008, when the then prevailing market price was around Rs. 350/- (average price on NSE). M/s. Religare Securities Ltd. had recommended a target price of Rs. 557/- as on April 21, 2008, when the prevailing market price was around Rs. 353/- (average price on NSE). M/s. Goldman Sachs Ltd. had recommended a target price of Rs. 499/- as on May 29, 2008, when the prevailing market price was around Rs. 353/- (average price on NSE). M/s. Religare Securities Ltd. had recommended a target price of Rs. 480/- as on July 07, 2008, when the market price was around Rs. 177/- (average price on NSE). I find that it was only on August 05, 2008 update, that Keynote had cut the 18-month target price of PSTL to Rs.285/-, when the market price of the stock was around Rs. 163/- (average price on NSE). It is also pertinent to observe here that Keynote’s Research team had not published any other media/ entertainment industry sector report giving target/ recommended price since November 2004. It is also important to note that Keynote had lead managed and had underwritten PSTL IPO in December 2006. It had also acted as Advisors to PSTL for raising of 90 million dollar (Rs 369 crore) through issue of Foreign Currency Convertible Bonds (FCCBs) in the international market to fund PSTL’s overseas acquisition plans.

Further more, Keynote was also associated with the company in the deal to acquire Dimple Cine Advertisers. I, therefore, prima facie find that the recommendations of Keynote and the related valuation of the PSTL scrip, are not genuine and were intended to facilitate fraudulent transactions in PSTL scrip at an artificially inflated price. Such action on the part of Keynote, breaches all professional and ethical standards, besides misleading unsuspecting investors in the market. 59. Further, I find that the client account in the name of Shri Amol Kokane was opened with India Capital Market, a Corporate member of NSE and BSE on September 12, 2008. On the same day, a new client account in the name of Shri Nirmal Kotecha too was also opened. I observe that trades in the name of Shri Amol Kokane through India Capital Market on NSE Cash were done from September 16, 2008 to November 17, 2008, in the Futures and Options (F&O) segment of NSE from September 18 to September 25, 2008 and on Cash segment of BSE from September 16, 2008 to November 20, 2008, in several scrips that included PSTL, Usher Agro, SEL Mfg.

Suzlon Energy, Akruti City, RIL, REL and Unitech Ltd. I note that Shri

Harsh Shah, Vice President of India Capital Market, in his statement recorded on March 05, 2009, informed that details about the opening of the new account in the name of Shri Amol Kokane and Shri Nirmal Kotecha and also the details about the orders placed by them can be obtained from the Branch Manager Shri Darshan Desai of Borivali (West) branch located at Goyal Shopping Centre. On a visit by SEBI officials to the Borivali (West) office of India Capital Market, Shri Darshan Desai claimed that he was the Branch Head of the Borivali (West) branch of India Capital Market. I find that he informed SEBI officials that one of the peons by the name Siddhartha, who worked with him for only 15 days had introduced him to Shri Sandeep Guvhane, who in turn, introduced Shri Amol Kokane and Shri Nirmal Kotecha to him. Shri Darshan Desai further informed that before November 03, 2008, Shri Sandeep Guvhane used to place orders on behalf of Shri Kokane and subsequently he himself had traded in the account of Shri Kokane by debiting other client accounts that had credit balances. He, however, stated that though it was he who was trading in Kokane’s account, the trade confirmations were automatically transmitted by SMS to Shri Kokane on his mobile number 9967838402 (reflected in the record with India Capital Market).

It was seen that trading was done on 13 trading days in the account of Shri Kokane since November 03, 2008 i.e. after the death of Shri Kokane’s brother in law, Shri Sandeep Guvhane, and on January 15, 2009, a pay out of Rs. 4,29,562 was issued to Shri Amol Kokane. Shri Darshan Desai, in his statement first stated that it was only in the account of Shri Amol Kokane that he had traded without any instructions/ knowledge of the client, by adjusting the credits lying to the other client’s accounts; however, he subsequently stated that he was carrying out such trades in one or two more client accounts also. He also stated that he was one of the Directors of Nine Group Securities Pvt. Ltd. and that his wife Ms. Priyanka Desai was a remisier of BSE and also that, Borivali branch of India Capital Market was registered in his wife’s name. From the interim Investigation Report, I find that SEBI officials who visited India Capital Market, found from a perusal of a few Client Registration Forms of clients registered with India Capital Market, that the details of Reference/ Introducer, were always left blank in these forms.

60. From the interim Investigation Report, I further find that, though Shri Darshan Desai claimed to be the branch head, neither he nor Shri Harsh Shah could produce any document proving Shri Darshan Desai’s employment with India Capital Market. It is understood that the Borivali (West) branch is in the name of Smt. Priyanka Desai, Shri Darshan Desai’s wife. Further, the bank trail of Shri Kokane’s account has revealed that the credit of Rs. 15 lacs on October 10, 2008 was received in Shri Kokane’s account from one Shri Nigam Vinod Shah (of 203, A Wing, Ratna Sagar CHS, 80 feet Road, Near Jain Temple, Bhayander (West) Dist. Thane). In the Know Your Customer (KYC) records, it is seen that Shri Nigam Vinod Shah was introduced by one Shri Nimesh Chitalia, who is the Head, Business Development of India Capital Market. An examination of the details of the bank account of Shri Nigam Vinod Shah further showed that an amount of Rs. 5 lacs was also transferred from Shri Nigam Vinod Shah’s account to Shri Raju G. Shah’s account on November 04, 2008. Shri Raju G.Shah’s client account was opened with the Borivali branch of India Capital Market in July 2008 and as stated earlier in the order, Shri Raju G. Shah has traded in the PSTL scrip through broker India Capital Market, on the two trading days viz. December 19 and December 22, 2008 on BSE.

The trading accounts of Shri Raju G. Shah, Shri Amol Kokane and Shri Nirmal Kotecha were opened at the same branch of the broker India Capital Market and around the same period. Further, I find, from the documents submitted by Shri Raju G. Shah at the time of opening of the bank account in November 2006, that Shri Raju G. Shah’s annual family income was Rs. 30,000/- only. 61. I note here that Shri Darshan Desai, as per his own admission, appears to have carried out fraudulent trades in the account of Shri Amol Kokane. 62. Further, I find that Shri Kokane’s account had received credits of Rs. 5.25 lacs, Rs. 2.75 lacs, Rs. 15 lacs and Rs. 12 lacs from different parties viz. Shri Praful P. Vora of M/s. Viren Trading Agency, Shri Hemal H. Gandhi HUF of Datapro, Shri Nigam Vinod Shah and Shri Janak H. Chitalia of M/s. J.H. Chitalia & Co., respectively on October 10, 2008. I find that each of these persons, in turn, had received credit of similar amounts in their account from one Shri Rajesh Jani, just immediately before they transferred the funds to Shri Kokane on October 10, 2008. I also find that an amount of Rs. 5 lacs that was transferred from Shri Nigam Vinod Shah’s account to Shri Raju Shah’s account on November 04, 2008, as stated in the earlier para, in turn, was also received in Shri Nigam Shah’s account from Shri Rajesh Jani.

The interim investigation report has revealed that Shri Rajesh Jani is the Director of M/s. Dynamic Stock Broking (India) Pvt. Ltd. (herein after referred to as Dynamic). 63. Shri Rajesh Jani in his statement recorded on April 17, 2009, at his office had claimed that these credits from his bank account to those of Shri Nigam. V. Shah and Shri Janak. H. Chitalia are repayments of loans taken from them in the year 2007-08. As per his statement, these loans were arranged by one Chartered Accountant Shri Nitin Goradia. However during the process of investigation, it was found that there is no loan agreement to substantiate Shri Nitin Goradia and/ or Shri Jani’s statement that these amounts were actually loans. Further, as per the documents submitted by Shri Nigam Vinod Shah to Dynamic at the time of opening of client account with broker Dynamic, I find that his family’s annual income is only Rs. 50,000/-. I observe that it is less than credible that Shri Nigam Shah (25 years in age), whose family income is relatively so low, can advance a loan of Rs. 25 lacs in the year 2007-08 to Shri Rajesh Jani, and that too, without any loan agreement regarding interest rate and repayment schedule.

It is further seen that Shri Nitin Goradia’s client account with Dynamic reflects a debit balance of Rs. 15 lacs since April 2008, which has not been cleared. Shri Jani in his statement has informed that as he is not able to pay interest to parties from whom Shri Nitin Goradia had arranged loans for him, the outstanding amount due to Dynamic has also not been cleared by Shri Garodia. Further, a perusal of the KYC of M/s. Kankeshwari Securities Pvt. Ltd., who had lent an amount of Rs. 30 lacs to Shri Rajesh Jani in April 2006, by way of friendly interest free loan as claimed by Shri Jani in his statement, shows that its directors are/ were Ms. Rita N. Goradia, wife of Shri Nitin Goradia, Shri Nimesh H. Chitalia, who is the Head, Business Development of India Capital Market and the brother-in-law of Shri Nitin Goradia and one Shri Vilas P. Shah. Further, Shri Janak H. Chitalia, who had lent an amount of Rs. 12 lacs to Shri Jani in December 2007, and subsequently lent the said funds to Shri Amol Kokane in October 2008 immediately after receiving the amount from Shri Jani, is also the brother-in-law of Shri Nitin Goradia.

Shri Nitin Goradia, in the statement of Shri Rajesh Jani, has also admitted that on the guarantee of Shri Darshan Desai, he had further arranged loan of Rs. 15 lacs from his client Shri Nigam V. Shah and Rs. 2.75 lacs from his other client Shri Hemal Gandhi for Shri Amol Kokane in October 2008.

64. I find the investigation done so far, thus reveals, that Shri Nitin Goradia, the Chartered Accountant of Shri Rajesh Jani, is the link through Shri Rajesh Jani, Shri Darshan Desai and Shri Nimesh Chitalia, for transfer of funds of Rs. 5.25 lacs, Rs. 2.75 lacs, Rs. 15 lacs and Rs. 12 lacs from the accounts of Shri Praful P. Vora of M/s. Viren Trading Agency, Shri Hemal H. Gandhi HUF of Datapro, Shri Nigam Vinod Shah and Shri Janak H. Chitalia of M/s. J.H. Chitalia & Co. to Shri Amol Kokane’s account on October 10, 2008. Further, since It has been brought out that all Shri Amol Kokane’s accounts were operated by Shri Nirmal Kotecha, I find, there is clear nexus between Shri Nirmal Kotecha and the above mentioned persons. It has also become evident from the above, that persons with either meager family income, or, families below poverty line, appear to have been extensively used in the operation which appears to have involved potential money laundering activities detrimental to the genuine investors at large. 65. I further find that Shri Nigam V. Shah’s occupation details, his financial details, name and designation of the employee who had interviewed him, as also, the agreement between the stock broker and the client have all been left blank in his Client Registration Form with Dynamic.

A perusal of some other clients KYCs, of clients registered with Dynamic, also similarly revealed that all of the above crucial information have been kept blank in these KYCs as well. I further find from the Unique Client Code (UCC) database of Dynamic that 8 client codes have been assigned in the name of Shri Sameer C. Sanghvi, the other director of Dynamic. The explanation given by him does not appear to be satisfactory. As per the trade log of BSE, for the period June to January 20, 2009, I find that Dynamic has traded on BSE in the scrip of PSTL on its own account on a regular and continuous basis during the period, and some of the trades, though in very small quantities, have matched with the trades of Shri Nirmal Kotecha and Shri Amol Kokane. Of the bulk purchase of 1,52,789 shares done by Dynamic on January 01, 2009, I find that 5523 shares sold by Shri Nirmal Kotecha through broker M/s. J M Financial Services Ltd. and 2000 shares sold by Shri Kotecha through M/s. Vertex Securities Ltd. on that day has matched with Dynamic’s purchase. On the previous day, i.e. December 31, 2008, I find that again 1000 shares bought by Dynamic through M/s. Kotak Securities Ltd. have matched with the sale by Shri Kotecha.

ORDER 1. In view of the grave emergency arising out of the fact that a forged letter (purported to have been issued by SEBI) was sent to the promoters/Persons Acting in Concert of a listed company, Pyramid Saimira Theatre Limited, and taking into consideration the fraudulent, abusive, manipulative and illegal activities committed by certain entities/persons to the detriment of the genuine investors and adversely affecting the integrity of securities market, I find it necessary that SEBI as a Regulator should immediately intervene to restore the confidence of the investors and to stop further harm to investors from being committed by the persons, who prima facie have indulged in such activities. I find that the manipulative conduct has resulted in substantial losses to investors, who are left holding stocks with little or no value. It is SEBI’s sacrosanct duty to make the securities market more credible and efficient by establishing and enforcing principles which ensure fairness, and, which prevent activities which damage investor confidence. In the instant case, the forgery was prima facie done to manipulate the stock price of Pyramid Saimira Theatre Limited.

As brought out above, it prima facie emerges that Shri Nirmal Kotecha was one of the major beneficiaries of the said manipulation and has masterminded the forgery. Therefore, with a view to protect the interest of investors and securities market from further such acts, in exercise of the powers delegated to me in terms of Section 19 of the Securities and Exchange Board of India Act, 1992 read with Section 11, 11B and 11(4) (b) thereof and read with Regulation 11 of SEBI (Prohibition of Fraudulent and Unfair Trade Practices relating to Securities Market) Regulations, 2003, pending investigation and passing of final order, I hereby issue the following directions, by way of ad interim, ex-parte order: 2. The following persons/ entities who prima facie have, played a key role in the forgery, dissemination of the information contained in the forged letter to the media, and misleading the media to believe in the authenticity of the information that was circulated to them are directed not to buy, sell or deal in the securities market including in Initial Public Offerings, in any manner, either directly or indirectly, till further directions: BANK SR ACCOUNT NO NAME BANK BRANCH NO. PAN NO. Nirmal Narendra HDFC 1 Kotecha BANK MATUNGA 4241000014692 AEZPK2016H HDFC BORIVALI 2 Rakesh Sharma BANK (WEST) 5461000013182 AGZPS8586N Rajesh 3 Unnikrishnan Pratheesh Kumar 4 V. K.

3. The following persons/ entities of/ related/associated with Shri Nirmal Kotecha, who prima facie have played a key role in facilitating Shri Nirmal Kotecha in carrying out suspicious banking transactions, carrying out and disguising his manipulative intent and gaining advantage from the forgery, or otherwise, are directed not to buy, sell or deal in the securities market including in IPOs, directly or indirectly, till further directions:

NAME OF SR BANK PROPRIETOR/ NO NAME BANK BRANCH ACCOUNT NO. DIRECTOR PAN NO. MANILAL DAMJI HDFC 1 KOTECHA BANK MATUNGA 4241000014884 AEZPK2015E VEENA N HDFC 2 KOTECHA BANK MATUNGA 4241000019158 VIRAL DINESH HDFC 3 DOSHI BANK MATUNGA 4241000033671 AJSPD4942P KOTECHA CAPITAL SERVICES PVT HDFC NIRMAL 4 LTD BANK MATUNGA 4242320000482 KOTECHA NIRMAL NIRMAN MGT. KOTECHA AND SERVICES PVT. HDFC MANILAL D 5 LTD. BANK MATUNGA 4242020000341 KOTECHA AACCN3493P

NIRMAL NISHWET MGT. KOTECHA AND SERVICES PVT. HDFC SHWETA 6 LTD. BANK MATUNGA 4242020000238 KOTECHA AACCN2307A DEEPAK 7 THAKKAR AAAPT5512C BANK AMOL ANAND OF D N ROAD 8 KOKANE INDIA BRANCH 1710100058428 AZZPK1169N 9 DARSHAN DESAI ADTPD8926G RAJESH ICICI NARIMAN ACNPJ4374R, 10 VAMANRAI JANI BANK POINT 401009554 AABHJ9273K RAJU GHANSHYAMDAS AXIS 11 SHAH BANK VIRAR 023010100247221 AZHPS2985G SHAILESH 12 JAYANTILAL SHAH AFDPS6203H RAJESH 13 JAYANTILAL SHAH AFDPS6216A BINABEN SHAILESHKUMAR 14 SHAH ANYPS5527K NIRMAL 15 ROHITBHAI SHAH ANYPS5526J RITABEN ROHITKUMAR 16 SHAH AFDPS6214C MANISHABEN RAJESHKUMAR 17 SHAH ANYPS5523P 18 NITIN GORODIA AAMPG0512D NIMESH H. 19 CHITALIA ADGPC5953K

4. The promoter Shri P.S. Saminathan has prime-facie made misleading public announcements, only to create public interest in the scrip of PSTL, for facilitating Shri Nirmal Kotecha in offloading his shares in PSTL at artificially inflated price in the market, is directed not to access or buy, sell or deal in the securities market, including in Initial Public Offerings, in any manner, either directly or indirectly, till further directions. 5. From the evidence available till date that has been discussed in the order, I find that the acts of the above mentioned persons/entities including that of Shri Nirmal Kotecha, Shri P. S. Saminathan and other connected entites /associates/ persons are prima-facie in violation of Regulations 3 and 4 of Securities and Exchange Board of India (Prohibition of Fraudulent and Unfair Trade Practices Relating to Securities Market) Regulations, 2003. 6. In view of prima facie violation of code of conduct as specified under Schedule II of SEBI (Stock Brokers and Sub-Brokers) Regulations, 1992, I, in exercise of powers conferred on me in terms of Section 19 read with Sections 11(1), 11B and 11(4) of the Securities and Exchange Board of India Act, 1992 hereby prohibit M/s. India Capital Markets Pvt. Ltd. from entering into any fresh agreements with new clients in its operations as stock broker till further orders. I also simultaneously direct the Market Intermediaries Regulation and Supervisory Department (MIRSD) of SEBI to look into whether the transactions, being carried out in any of the client accounts registered at M/s. India Capital Market Pvt. Ltd. are suspicious in nature and whether there has been any unlawful breach of requirements prescribed in the margin collection system being followed at the branch, and submit their report within a month’s time, to enable the Board take a further view in the matter.

7. In view of prima facie violation of code of conduct as specified under Schedule II of SEBI (Stock Brokers and Sub-Brokers) Regulations, 1992, I, in exercise of powers conferred on me in terms of Section 19 read with Sections 11(1), 11B and 11(4) of the Securities and Exchange Board of India Act, 1992 also hereby prohibit M/s. Dynamic Stock Broking (India) Pvt. Ltd. from entering into any fresh agreements with new clients, in its operations as stock broker, till further orders. I also simultaneously direct the Market Intermediaries Regulation and Supervisory Department (MIRSD) of SEBI to carry out a detailed inspection of all activities of the broker M/s. Dynamic Stock Broking (India) Pvt. Ltd., including the conformance with the KYC requirements prescribed, and, submit their report within a month’s time, to enable the Board take a further view in the matter. 8. For the reason that M/s. Keynote Capital Limited has issued unfounded and questionable trade recommendation about the shares of PSTL which has had the effect of misleading investors, it is hereby prohibited from giving any trade recommendations in respect of companies listed in any of the recognized stock exchanges till further directions in this regard. 9. The following persons/ entities and their proprietors/ partners/ directors who, as per the investigation carried out so far, prima facie appear to have carried out suspicious banking transactions and have channeled these funds either directly or indirectly in the stock markets, are directed not to buy, sell or deal in the securities market including in Initial Public Offerings, in any manner, either directly or indirectly, till further directions:

NAME OF SR BANK PROPRIETOR/ NO NAME BANK BRANCH ACCOUNT NO. DIRECTOR PAN NO. DINESH ADINO TRADING AXIS LAMINGTON BAFNA/VINOD 1 COMPANY PVT LTD BANK ROAD 465010200004558 BAFNA ANAND HUNIA/POPATL AL SHAH/SANJAY HUNDIA/RAJES ADVANCE FINSTOCK AXIS PALANPUR, H HUDIA, 2 PVT LTD. BANK GUJARAT 256010200005289 KARUL SHAH ALFA CERAMIC MUKESH TRADING AGENCIES AXIS THAKUR CHOKSI/JAYES 3 PVT LTD BANK VILLAGE 572010200002639 H SAMPAT AXIS 4 ALKA DIAMOND BANK POWAI 246010200005258 GOPAL VERMA ALLIANCE MUKESH INTERMEDIARIES & I AXIS THAKUR CHOKSI/JAYES 5 NETWORK BANK VILLAGE 572010200001946 H SAMPAT AXIS CHURCHGA 6 AMAN ENTERPRISES BANK TE 695010200000480 GANESH JAIN ACVPJ7984R AXIS NEWMARIN PATEL RAKESH 7 AMAR ENTERPRISES BANK E LINES 233010200018179 ROHITBHAI APBPP1077N ASHRAM ROAD AHMEDABA BHAVIK 8 AMAR TRADING CO. I.O.B. D CD-3069 H.SHAH AQZPS 5222M ICICI AMBE SALES BANK OMPRAKAHSAG 9 CORPORATION LTD GIRGAUN 641105000072 ARMAL JAIN AGYPJ8762C AMOL ANAND BANK OF 10 KOKANE INDIA D N ROAD 1710100058428 AZZPK1169N

NAME OF SR BANK PROPRIETOR/ NO NAME BANK BRANCH ACCOUNT NO. DIRECTOR PAN NO. INDIAN BHAVIK OVERSEA KALBADEVI HASMUKH 11 AMRUT TRADING CO. S BANK ROAD CD6704 SHAH AQZPS5222M AXIS ANAND 12 ANAND MARATHE BANK FORT 004010200983075 MARATHE AKWPM0699M PRAVEEN KUMAR ANCHAL PROPERTIES AXIS JAIN/DATTARA 13 PVT LTD BANK POWAI 246010200005951 M LADE NEW AXIS MARINE ANJALI 14 ANJALI AKHADE BANK LINES 233010100203142 AKHADE AHKPA4470D AXIS CHURCHGA 15 ANKIT ENTERPRISES BANK TE 695010200000471 PARVIN SHAH ALVPS52685M ANKIT KUMAR AXIS LAMINGTON 16 PAGARIYA BANK ROAD 465010100010177 ASLPP8026A AXIS ARVIND 17 ARAVIND KUMAR SONI BANK BORIVALI(W) 018010100504942 KUMAR SONI NEW AXIS MARINE ANKIT KUMAR 18 ARIHANT GEMS BANK LINES 233010200015446 PAGARIYA ASLPP8026A STANDAR D JOSHI ASHOK METAL & CHARTER 23-25 TARACHAND 19 TUBES ED BANK M.G.ROAD 22506013282 BHURARAM AFRPJ9303F DIRECTORS 1) KISHORMAL B AXIS NEWMARIN JAIN, KIRAN K 20 ASHOK METAL CORP BANK E LINES 233010200015950 JAIN AADPJ2942H MUKESH JAIN / AXIS SPRINGFIEL PRAVEEN 21 BAFNA EXIM P LTD BANK DS 415010200001205 KUMAR JAIN AXIS BURRA AMIT KUMAR 22 BAGORIA ENTERPRISE BANK BAZAR 277010200019211 BAGORIA AHMPB7273R NARIMAN AXIS POINT ARVIND 23 BALAJEE DIAMOND BANK BRANCH 173010200012005 KUMAR SONI STANDAR D CHARTER 23-25 SHAH BANTY 24 BALAJI CORPORATION ED BANK, M.G.ROAD 000022506031191 DINESH BOMPS6427Q AXIS LAMINGTON RAJENDRAKUM 25 BHAIRAV DIAMONDS BANK ROAD 465010200002127 AR M JAIN AFNPJ7710E AXIS BHAYANDA BHIVRAJ B 26 BHAIRAV TRADING CO BANK R-WEST 575010200003339 GUJAR AMDPG8940L STANDAR D CHARTER 23-25 BAFNA VINOD 27 BHAKTI TRADING ED BANK M.G.ROAD 22505894587 KUMAR AIFPB1312F AXIS NARIMAN 28 BHAVANI TRADING CO BANK POINT 173010200015491 CHIRAG PATEL ARSPP2297H NEW AXIS MARINE 29 BINAL SHAH BANK LINES 233010100120333 BINAL SHAH NEW AXIS MARINE MANGALRAM 30 BOSTON AGENCY BANK LINES 233010200005050 SHAH AMFPS2966N CAPETOWN AXIS 31 MERCANTILE CO PVT BANK POWAI 246010200005234 PANKAJ JAIN UMESH AXIS NARIMAN NEMCHAND 32 CHANDAN GEMS BANK POINT 173010200012139 BUNTH AMXPB1214G AXIS CRAWFORD CHANDU 33 CHANDU KHIMAVAT BANK MARKET 294010100033345 KHIMAVAT NEW AXIS MARINE HUKUMCHAND 34 CHOKNI DANI RESORT BANK LINES 233010200002653 JAIN AAMCS29882L

NAME OF SR BANK PROPRIETOR/ NO NAME BANK BRANCH ACCOUNT NO. DIRECTOR PAN NO. INDIAN JIGNESH OVERSEA KALBADEVI AMRUTBHAI 35 CLASSIC ENTERPRISES S BANK ROAD CD6707 PATEL STANDAR D CHARTER 23-25 NOT 36 CROWN METAL INDIA ED BANK M.G.ROAD 22505684329 SHAH SURESH P AVAILABLE KALBA DEVI AMIT KUMAR S. 37 D AMIT KUMAR I.O.B. RD CD-6705 SONETHA BHOPS 7325A SANJAY AXIS BHAYANDA RAI/RAMBHAR 38 DADA TRADING CO BANK R-WEST 575010200003513 OS YADAV DARSHAN TRADING AXIS VILE PARLE SOURABH 39 CO. BANK (WEST) BR 064010200009942 RAJENDRA JAIN AKDPJ4570F STANDAR D DARSHANA CHARTER 23-25 SHAH 40 CORPORATION ED BANK M.G.ROAD 22505894773 MANGLARAM H AMFPS2966N THE KAPOL CO-OP. BORIVALI HEMAL H. 41 DATAPRO BANK (WEST) CA4015 GANDHI HUF AXISBAN NARIMAN DEEPAK 42 DEEP ENTERPRISE K POINT 173010200016074 BHATEVARA STANDAR D DEEPAK STEEL CHARTER CHOWPATT RANMAL J 43 CENTRE ED BANK Y 22405268218 BHANSALI ACUPB4642D STANDAR D DELUX METAL CHARTER CHOWPATT CHAUHAN NOT 44 CORPORATION ED BANK Y 22405266975 HASTIMAL P AVAILABLE AXIS AHMEDABA 45 DEVAM IMPEX PVT LTD BANK D 003010200066121 PIYUSH DAND V P ROAD BRANCH, RAJUKUMAR DHANLAXMI TUBES BANK OF MUMBAI - AMARCHAND. 46 AND METAL BARODA, 400004 BHANSALI AABPB3080G AXIS HUKMICHAND 47 DIAMOND EXPORT BANK FORT 004010200517423 JAIN ADCPJ9311Q ICICI DINESH KUMAR M BANK DADAR DINESH KUMAR 48 GUPTA LTD BRANCH 3201016671 M GUPTA AABPG5149F ICICI OPERA BANK HOUSE JAGDISH R 49 DOSHI TRADING CO. LTD BRANCH 34805003271 DOSHI ALOPB9958K EDEX PRODUCTION AND BROADCASTING AXIS PRITHI PAUL 50 PVT BANK DADAR 124010200006002 SETHI AXIS BORIVALI(W PRAMOD 51 EKTA SHARES AND BANK EST) BR 018010200030241 GADIA ADUPG6871G FASTSTONE TRADING AXIS 52 CO PVT LTD BANK POWAI 246010200005302 PANKAJ JAIN ICICI OPERA SOHANLAL S. 53 FERRO N ALLOYS BANK, HOUSE 000088106140661 BISHNOI FOREMOST AXIS BORIVALI DINESH KUMAR 54 MERCHANDISE BANK (WEST) BR 018010200029120 JAIN AABCF1921D ICICI BUNDGRAD FUNKE HEAT BANK EN RD, 55 EXCHANGER INDIA LTD PUNE 505008462 PETER FUNKE NEW AXIS MARINE DEEPAK D 56 GANESH TRADING CO BANK LINES 233010200019062 WAGHE AAVPW1401E NEW GAUTAM KUMAR AXIS MARINE 57 BHANSALI BANK LINES 233010100265423 AJJPB5305N AXIS NEW RATAN KUMAR 58 GAYATRI GEMS BANK MARINE 233010200018373 AGRAWAL AGFPA0894B

NAME OF SR BANK PROPRIETOR/ NO NAME BANK BRANCH ACCOUNT NO. DIRECTOR PAN NO. LINES

NEW VIRAG GENUS COMMU TRADE AXIS MARINE PATEL/HITESH 59 LIMITED BANK LINES 233010200010265 PANCHAL NARIMAN HARE KRISHNA AXIS POINT 60 EXPORT BANK BRANCH 173010200012023 SONU BAFNA SPRINGFIEL DS, APNESH AXIS LOKHANDW RANGNATH 61 HARI OM TRADING CO. BANK ALA 415010200001250 SANGLE BESPS6459A LOWER HARISH METAL & HDFC PAREL 62 TUBES BANK (WEST) 003562560005149 HARISH S JAIN AHYPJ8223D HEMA TRADING CO AXIS VASUDEO 63 PVT LTD BANK POWAI 246010200005319 SOLIWAL AXIS 64 HETAL RAJESH PATEL BANK NASHIK 115010100385909 PRAVEEN NEW KUMAR LODHA, HI-CLASS DIAMOND AXIS MARINE SANJAY KUMAR 65 EXPORTS P LTD BANK LINES 233010200015905 LODHA AABCH9360G HONEY AXIS NARIMAN OMPRAKASH 66 INTERNATIONAL BANK POINT 173010200012245 SHRISHRIMAL ASYPJ2705J NEW AXIS MARINE MANGLARAM 67 IMPEX SALES CORPN BANK LINES 233010200004633 SHAH AMFPS2966N AXIS SPRINGFIEL JAFARBHAI 68 INDIAN CORPN. BANK DS 415010200001243 DANAVALA AJGPD9220L BANK OF JANAK MAHARAS BORIVALI HARKINSHAND 69 J H CHITALIA & CO. HTRA (WEST) 000020115901202 AS. CHITALIA AXIS CRAWFORD PANKAJ KUMAR 70 J P ENTERPRISES BANK MARKET 294010200007856 JAIN ADIPJ4296J ASHRAM ROAD AHMEDABA JIGNESH 71 JAGAT ENTERPRISE I.O.B. D CD-3097 A.PATEL AGAPP 3290K STANDAR D CHARTER 23-25 VISHNOI 72 JANAK METAL INDIA ED BANK M.G.ROAD 22505922297 MANGILAL R AEHPV3945C JAVDA INDIA IMPEX AXIS 73 LTD BANK POWAI 246010200005272 RAMESH JAVDA STANDAR D CHARTER 23-25 74 JAY AMBE MARBLES ED BANK M.G.ROAD 22505752766 SURESH JAIN AFFPJ8944J AXIS CRAWFORD JODHARAM 75 JODHARAM BISHNOI BANK MARKET 294010100033327 BISHNOI AJIPB7825P NEW JPK TRADING I PVT AXIS MARINE 76 LTD BANK LINES 233010200019257 MANISH JAIN AXIS BHAYANDA RAKESH 77 JYOTI ENTERPRISES BANK R-WEST 575010200003896 KUMAR SEN BATPS1606L AXIS BHAYANDE PAWANKUMAR 78 KALASH DIAM BANK R WEST 575010200002967 S TIWARI AFWPT7162H AXIS NARIMAN PAWAN KUMAR 79 KALASH DIAMONDS BANK POINT 173010200015969 TIWARI AFWPT7162H KALPANA AXIS CRAWFORD KALPANA A 80 CORPORATION BANK MARKET 294010200007061 SHAH BHHPS5861S KALYAN KIRTI AXIS CHURCHGA MANGLARAM 81 INTERNATIONAL BANK TE 695010200000453 SHAH AMFPS2966N AXIS NARIMANPO SONU BAFNA, NOT 82 KAMAL DIAMONDS BANK INT 173010200010885 KAMLESH AVAILABLE

NAME OF SR BANK PROPRIETOR/ NO NAME BANK BRANCH ACCOUNT NO. DIRECTOR PAN NO. DHAMMANI

NEW AXIS MARINE KAMLESH 83 KAMLESH DHAMMAN BNAK LINES 233010100315692 DHAMMAN AXIS NARIMAN MAHENDRA 84 KANAK IMPEX BANK POINT 173010200015826 JAIN AIIPJ8463C NEW AXIS MARINE 85 KANCHAN IMPEX BANK LINES 233010200018160 SUSHIL MEHTA AHPPM9754K ASHWINBHAI KASTBHANJANDEV AXIS AHMEDABA PATEL/BIPINCH ANMPP3820G 86 DEVELOPERS BANK D 003010200051484 ANDRA BHATT /ACLDB9082C VIJAY NARENDRA KOTHARI, KESHARIYA DIAM PVT AXIS BHAYANDA PAWANKUMAR 87 LTD BANK R-WEST 575010200003032 TIWARI AADCK2217M AXIS NARIMAN ANIL 88 KESHAV IMPEX BANK POINT 173010200014155 CHOKHARA AGZPC7831L AXIS NARIMAN PREM PRAKASH 89 KHUSHI CORPORATION BANK POINT 173010200013998 TAILOR AHSPT9280G AXIS NARIMAN PREM PRAKASH 90 KIRTI ENTERPRISES BANK POINT 173010200014757 TAILOR AHSPT9280G HDFC KOHINOOR BANK FORT AMOL ANAND 91 INVESTMENT LTD BRANCH 00602020003219 KOKANE AZZPK1169N DHARMENDRA KOTHARI, KOTSONS IMPEX PVT. AXIS LAMINGTON CHANDRAMOH 92 LTD. BANK ROAD 465010200002189 AN VERMA AACCK9104C AXIS NARIMANPO NOT 93 KRINA GEMS BANK INT 173010200003537 KAMLESH SHAH AVAILABLE AXIS ASHOK RATAN 94 KUNAL GEMS BANK POWAI 246010200005609 SONI AAOPV6321K AXIS 95 KUSH HINDUSTAN ENT BANK POWAI 246010200005289 AJAY DIXIT AXIS 96 KUSH INTERNATIONAL BANK POWAI 246010200005616 RAMESH JAVDA ABCPJ7139G AXIS LAMINGTON GANPAT P 97 LANKA DIAM BANK ROAD 465010200002240 BHADIRKE AXIS LAMINGTON LAXMANCHAN 98 LARSEN EXPORTS BANK ROAD 465010200001625 D JAIN ACXPJ4337Q AXIS LAMINGTON NOT 99 LEENA GEMS BANK RD 465010200001083 RAJESH ZAVERI UPDATED AXIS 100 LEXUS INFOTECH LTD BANK POWAI 246010200005265 ROSE PADBIDRI AXIS CRAWFORD JODHARAM 101 LOVE KHUSH BANK MARKET 294010200005210 BISHNOI AJJPB7825P SANJAY RAI/ AXIS BHAYANDA RAM BHAROS 102 LUXURY TRADING CO. BANK R-WEST 575010200003520 YADAV AXIS CRAWFURD NANDALAL G 103 M G CORPORATION BANK MARKET 294010200005562 NAGPAL ADFPN5684B NEW MAHESH AXIS MARINE PYARELAL 104 M M DIAMOND P LTD BANK LINES 233010200015604 MEHTA AEQPM5416E NEW AXIS MARINE MOHANLAL 105 MAHAK IMPEX BANK LINES 233010200011060 JAIN (HUF) AAEHM7566H NEW AXIS MARINE 106 MAHALAXMI CORP. BANK LINES 233010200019053 ASHWIN PATEL ANFPP7250H

NAME OF SR BANK PROPRIETOR/ NO NAME BANK BRANCH ACCOUNT NO. DIRECTOR PAN NO. STANDAR D MAHAVIR CHARTER 23-25 BAFNA VINOD 107 CORPORATION ED BANK M.G.ROAD 22505894846 KUMAR AIFPB1312F NEW AXIS MARINE 108 MAHENDRA JAIN BANK LINES 233010100277983 AIIPJ8463C JITENDRA K JAIN & RAJENDRA MANAN TRADING PVT AXIS NARIMAN RANKA & 109 LTD BANK POINT 173010200015084 PRAKASH JAIN AADCM5896J AXIS RAMU PEMA 110 MANISH ENTERPRISES BANK DAHISAR(W) 701010200000620 GUJJAR AXIS BHAYANDA BHAGWAN 111 MANN IMPEX BANK R-WEST 575010200003063 SINGH BSWPS8701D AXIS LAMINGTON 112 MANOJ KUMAR BANK ROAD 465010100009928 AKKPM3857F MASTER SURVEYORS & AXIS DEVALALI, SURESH 113 CONTRACTORS BANK NASHIK 779010200000231 THANAGE AXIS BORIVALI VASANT 114 MATRIX EXPORTS BANK (WEST) BR 18010200028495 KUMAR P AMXPM9372L AXIS NARIMAN DILKUSH 115 MAULIK DIAMONDS BANK POINT 173010200015039 BABEL AMLPB2470Q

DIRECTOR 1) MAHENDRA AMRITLAL JAIN, VIKRAM AMRITLAL JAIN, AXIS CRAWFORD GIRISH 116 MAYA JEWELS PVT LTD BANK MARKET 294010200006040 AMRITLAL JAIN AAFCM5335G AXIS AASHISH 117 MEET CORPORATION BANK POWAI 246010200005227 MAHAWAR APMPM2937B AXIS NARIMAN 118 MEGHA TRADERS BANK POINT 173010200012236 DESHRAJ JAT AFHPJ6071J MUKESH CHOKSHI / AXIS THAKUR JAYESH 119 MIHIR AGENCIES P LTD BANK VILLAGE 572010200002592 SAMPAT NEW AXIS MARINE MANOJ KUMAR 120 MILAN GEMS BANK LINES 233010200015437 MEHTA AKKPM3857F NEW AXIS MARINE 121 MOHANLAL B JAIN BANK LINES 233010100177726 AABPJ1092Q MOHIT AXIS NILESH 122 INTERNATIONAL BANK POWAI 246010200005586 PARMAR AIXPP8680Q NEW MUKTA AXIS MARINE 123 INTERNATIONAL BANK LINES 233010200013934 RAKESH H JAIN HDFC AMOL ANAND 124 N R SECURITIES BANK FORT 000602020003184 KOKANE AZZPK1169N AXIS 125 NATASHA ENTERPRISE BANK POWAI 246010200005593 ROSE PADBIDRI AIPPP6372H AXIS NOT 126 NAVKAR TRADING CO BANK PANIPAT 240102000008839 ASHISH JAIN UPDATED AXIS BHAYANDA 127 NAVKAR TRADING CO BANK R-WEST 575010200003322 AOHPG2600R NEW GEETA AXIS MARINE JADHAV/HUKM 128 NEER TRADERS BANK LINES 233010200010539 ICHAND JAIN AACPJ9676P NEW VIRENDRA NEW PLANET TRADING AXIS MARINE ABHANI & ROSE 129 CO LTD BANK LINES 233010200019512 PADDIBIRI AABCN8176E

NAME OF SR BANK PROPRIETOR/ NO NAME BANK BRANCH ACCOUNT NO. DIRECTOR PAN NO. NEW GOPAL NEW WAVE AXIS MARINE KHATRI/AVINA 130 MERCANTILECOMPANY BANK LINES 233010200004732 SH TRIMAKE SODAWALA LANE, AXIS BORIVALI 131 NIGAM VINOD SHAH BANK (WEST) 018010100237734 AWEPS0987Q STANDAR D SHARMA CHARTER SANJAY 132 NIRMAL ENTERPRISES ED BANK PUNE 22905026957 MANILAL AQQPS1225P THAKUR VILLAGE, KANTILAL AXIS KANDIVALI SAMELAJI 133 OM ASSOCIATES BANK EAST 572010200003001 PUROHIT APTPP6092D AXIS NEWMARIN 134 OM CORPORATION BANK E LINES 233010200017754 CHIRAG PATEL ARSPP2297H AXIS SHANTILAL NOT 135 OM CORPORATION BANK BORIVALI 018010200029023 PRAJAPAT UPDATED SURYAJI K 136 OMEGA PETRO PLAST I.O.B. BORIVALI CD-2770 BHONDE AMJPBS 4612J AXIS NARIMAN 137 ORBIT GEMS BANK POINT 173010200013138 VINIT JAIN AHMPJ0332K OSTWAL TRADING I AXIS 138 PVT LTD BANK POWAI 246010200005524 MANISH JAIN AAACO7995M AXIS NARIMAN NARAYAN LAL 139 P R DIAMONDS BANK POINT 173010200015020 SHARMA AEUPS4865H STANDAR D PADMAVATI METAL & CHARTER 23-25 140 ALLOYS ED BANK M.G.ROAD 22506013231 JAIN SURESH AFSPJ4124P NEW AXIS MARINE RATANKUMAR 141 PARAS GEMS BANK LINES 233010200007627 D AGARWAL AGFPA0894B STANDAR D VOHERA PARASMANI TUBES PVT CHARTER CHOWPATT PIYUSH 142 LTD ED BANK Y 22405343341 CHANDULAL AABCP7664D AXIS 143 PATTANI YOGESH B BANK NASHIK 115010200017091 AXIS NARIMAN RAJENDRA K 144 PRACHI GEMS BANK POINT 173010200015057 RANKA ACRPR7932F AXIS DEVALALI, 145 PRITESH A PATEL BANK NASHIK 779010100046774 AXIS SPRINGFIEL JITENDRA 146 PRIYANSH EXPORTS BANK DS 415010200001267 KUMAR JAIN AHNPJ5721D PROFICIENT INFRA P AXIS NARIMAN 147 LTD BANK POINT 173010200013396 ASHOK JAIN AAECP5791Q AXIS NARIMAN DULRAJ JAIN & NOT 148 PUSHPA DIAM PVT LTD BANK POINT 173010200010894 ASHOK JAIN UPDATED AXIS RAVI KUMAR 149 R B TRADERS BANK WORLINAKA 653010200001601 JAIN AXIS SPRINGFIEL 150 R K TRAVELS BANK DS 415010200001151 AJGPD9220L RATANKUMAR NEW AGARWAL & AXIS MARINE SUNIL KUMAR 151 R S ENTERPRISES BANK LINES 233010200007634 AGARWAL AFSPA5223J NEW RAGHUKUL DIAM PVT AXIS MARINE NIRMAL JAIN & 152 LTD BANK LINES 233010200021049 SANJAY TIWARI AADCR6608P NEW RAGHUNANDAN AXIS MARINE UTTAMCHAND 153 RAYONS LTD BANK LINES 233010200019017 HINGER

NAME OF SR BANK PROPRIETOR/ NO NAME BANK BRANCH ACCOUNT NO. DIRECTOR PAN NO. RAJKUMAR RAJ ALLOYS AND AXIS LAMINGTON JAIN/NITIN 154 STEEL PVT LTD BANK ROAD 465010200002714 SHAH AXIS NARIMAN 155 RAJ DIAMONDS BANK POINT 173010200015093 PANKAJ SINGHI BLFPS2616R KANDIVALI WEST, AXIS MAHAVIR NIRMAL K 156 RAJ RATNA JEWELLERS BANK NAGAR 201010200006781 BHAVSAR AFZPB3668K AXIS THAKUR 157 RAJ TRADERS BANK VILLAGE 572010200002998 AVICHAL SONI BHTPS1033E AXIS LAMINGTON 158 RAJESH JAIN BANK ROAD 465010100011714 AIJPS3849H NEW AXIS MARINE 159 RAJESH PAMECHA BANK LINES 233010100001342 AEZPP6573L RAJESH VAMANRAI ICICI NARIMAN 160 JANI BANK POINT 000000401009554 STANDAR D CHARTER 23-25 BAFNA VINOD 161 RAJKAMAL STEEL ED BANK M.G.ROAD 22505894544 KUMAR AIFPB1312F AXIS 162 RAJU G SHAH BANK VIRAR 023010100247221 AZHPS2985G NEW AXIS MARINE 163 RAKHI GEMS BANK LINES 233010200016986 VIPUL SHARMA AXIS CRAWFORD OATMAL 164 RATAN ENTERPRISES BANK MARKET 294010200006804 PUROHIT NEW YOGESH AXIS MARINE KUMAR 165 RATAN EXPORTS BANK LINES 233010200015020 SANCHETI AHEPS6566L AXIS NARIMAN 166 RAVI ENTERPRISES BANK POINT 173010200012698 BABULAL JAIN NEW AXIS MARINE RAVI PRAKASH 167 RAVI EXPORTS BANK LINES 173010200013855 JAIN AKJPJ6022E REALGOLD TRADING AXIS NILESH 168 CO. PVT LTD BANK POWAI 246010200005326 PARMAR STANDAR D RELIANT METAL CHARTER 23-25 RAJPUROHIT 169 CORPORATION ED BANK M.G.ROAD 22505894315 ARJUN P ALAPR6303A RENISHA IMPEX PVT AXIS NARIMAN DINESH JAIN / 170 LTD BANK POINT 173010200009591 DULRAJ JAIN NEW RIDDHI SIDDHI AXIS MARINE 171 MULTITRADE LTD BANK LINES 233010200019114 PANKAJ JAIN NEW AXIS MARINE RAJKUMAR 172 RIDHAM ENTERPRISES BANK LINES 233010100008853 AGRAWAL AFSPA5222K NEW AXIS MARINE KAMAL 173 ROHIT TRADING CO. BANK LINES 233010200017329 THAKUR ADXPT2249Q AXIS NARIMAN 174 ROOP IMPEX BANK POINT 173010200008716 DULRAJ U JAIN ABTPJ4754E AXIS NEWMARIN 175 RUKAMANI GEMS BANK E LINES 233010200013989 RAJESH JAIN AIJPJ3849H AXIS LAMINGTON MAHENDRAKU 176 S K IMPEX BANK ROAD 465010200003049 MAR BISHNOI ACRPB9546E STANDAR D CHARTER 23-25 NOT 177 SAGAR TRADING CO ED BANK M.G.ROAD 22505551442 SHAH SURESH P AVAILABLE V P ROAD BANK OF BRANCH, VASTUPAL M. 178 SAHARA IMPEX (INDIA) BARODA, MUMBAI - JAIN ADOPJ2732P

NAME OF SR BANK PROPRIETOR/ NO NAME BANK BRANCH ACCOUNT NO. DIRECTOR PAN NO. 400004

AXIS NARIMAN 179 SAHIL JEWEL BANK POINT 173010200011857 POONAM JAIN AIZPJ6835D AXIS NARIMAN NAVRATAN S 180 SAI KRUPA TRADING BANK POINT 173010200015066 JAIN AHYPJ4038J VIJAY SURESH SAI LEELA TRADING AXIS LAMINGTON TAWARE, NITIN 181 PVT LTD BANK ROAD 465010200002172 ARJUN GHARAT AAKCS4578C ICICI SANDEEP STEEL BANK BABULAL K 182 INDUSTRIES LTD GIRGAUN 641105000101 BISHNOI AHZPB11158

VIRENDRA ABHANI/ NEW JITENDRA SANJIVANI ENVIRO AXIS MARINE TATER/VASUD 183 PROTECTION LTD BANK LINES 233010200019150 EV SOLIWAL AXIS BHAYANDE 184 SANSKAR TRADING CO BANK R WEST 575010200003049 GANAPAT LAL ADGPL2513A NEW AXIS MARINE 185 SAPNA DIAMOND BANK LINES 233010200010548 SUSHIL MEHTA AHPPM9754K NEW AXIS MARINE 186 SARITA DIAMONDS BANK LINES 233010200016977 JITENDER JAIN AFOPJ3543C NEW AXIS MARINE MANISH JAIN/ 187 SBJ TRADING PVT LTD BANK LINES 233010200019044 PRAVEEN JAIN AXIS NOT 188 SHAH TRADING CO BANK VIRAR 023010200019752 HETAL R SHAH UPDATED STANDAR D CHARTER 23-25 BAFNA VINOD 189 SHAKTI TRADING CO ED BANK M.G.ROAD 22506013487 KUMAR AIFPB1312F JAVARILAL SHANKESHWAR AXIS BHAYANDA GAUTAMCHAH 190 TRADERS PVT LTD BANK R-WEST 575010200003346 D JAIN ICICI NARIMAN BANK POINT SHASHIKANT P 191 SHASHIKANT P BAYANI LTD BRANCH 401138671 BAYANI AAHPB3652Q AXIS NEWMARIN CHANDRAKAN 192 SHIYON ENTERPRISE BANK E LINES 233010200015039 T PATEL AOZPP4246C RAJEMDRA SHREE EARTH MOVERS AXIS JANARDAN 193 & LAND DEVELOPERS BANK NASHIK 115010200013299 SURVE AXIS NARIMAN ASHOK NOT 194 SHREE EXPORT BANK POINT 173010200009140 SHRISHRIMAL UPDATED ICICI SHREE FORGE BANK HUGES BABULAL K 195 INDUSTRIES LTD ROAD 41605000091 BISHNOI AERPB1242C OKHARAM AXIS LAMINGTON RAMSHIJI 196 SHREE RAMDEV METAL BANK ROAD 465010200002790 CHOUDHARY AGFPC9225L NEW AXIS MARINE SUKHPAL NOT 197 SHRI GANESH GEMS BANK LINES 233010200016524 PRAJAPAT UPDATED AXIS BHAYANDA LALARAM 198 SHUBH TRADING CO BANK R-WEST 575010200003902 GUJAR APRPG3369G NEW GAUTAM AXIS MARINE KUMAR 199 SHUBHAM EXPORTS BANK LINES 233010200016056 BHANSALI AJJPB5305N AXIS BHAYENDE JAFARBHAI 200 SIDDHAM EXPORTS BANK R(W) 575010200003117 DANAVAL A SIGMA TOURS & AXIS NARIMAN KAMAL B 201 TRAVELS BANK POINT 173010200014331 THAKUR ADXPT2249Q

NAME OF SR BANK PROPRIETOR/ NO NAME BANK BRANCH ACCOUNT NO. DIRECTOR PAN NO. AXIS NARIMAN SANDEEP S 202 SIMI IMPEX BANK POINT 173010200011705 RATHORE ALUPR5979E NEW HUKMICHAND SONAL GEMS TRADING AXIS MARINE JAIN / GEETA 203 P LTD BANK LINES 233010200016834 JADHAV STANDAR D SOUNDARYA GRANITE CHARTER 23-25 204 & MARBLE ED BANK M.G.ROAD 22505752758 SURESH JAIN AFFPJ8944J NEW PAWAN AXIS MARINE TARACHAND 205 STAR ENTERPRISES BANK LINES 233010200015677 JAIN AIAPJ2539D AXIS NARIMANPO BHAGIRATHI 206 STAR GEMS BANK INT 173010200011875 PUHAN ARTPP7106J SU JEWELS EXIM PRIVATE LIMITED NEW HUKMICHAND (ERSTWHILE CHOKHI AXIS MARINE JAIN, GULAB 207 DHANI RESORTS P LTD) BANK LINES 233010200002653 JAIN SANDEEP DALAL/RAJEND SUNBLINK TRADING AXIS CRAWFORD RAKUMAR 208 AND INVT LTD BANK MARKET 294010200004787 BHIMRAJKA SUNIL MANSINGHANI SUNCHAN SECURITIES AXIS /KANCHAN 209 LTD BANK BANDRA 028010200004954 MANSINGHANI GEETA JADHAV NEW & SUPER GOLD TRADIN AXIS MARINE HUKUMCHAND 210 CO PVT LTD BANK LINES 233010200012740 JAIN AAHCS7254E NEW AXIS MARINE 211 SUPRE GOLD TRADERS BANK LINES 233010200012740 GEETA JADHAV SWASTIK DIAM PVT AXIS NARIMAN DULRAJ JAIN & 212 LTD BANK POINT 173010200009164 DINESH JAIN ABOPJ2176M NEW AXIS MARINE GHEVARCHAN 213 TAMANNA GEM BANK LINES 233010200016533 D B PAMECHA AFWPP6341Q STANDAR D TARACHAND CHARTER CHOWPATT NOT 214 BHOORCHAND JAIN ED BANK Y 22410417102 - AVAILABLE TRITOP TRADING PVT AXIS BORIVALI- BHASKAR 215 LTD BANK WEST 018010200029953 UBARE

AXIS NEWMARIN MAHESH 216 U M EXPORTS BANK E LINES 233010200010973 MEHTA AEQPM5416E RAKHI GAUTAM/DINE SH U P MERCANTILE AXIS TRIPATHI/VIRE 217 CREDIT SAHAKARI LTD BANK INDORE 043010100641593 NDRA YADAV AXIS NARIMAN UMAKANT 218 UMA EXPORT BANK POINT 173010200013545 MUDULI ABTPJ4754E AXIS NARIMAN UMESH N 219 UMESH BUNTH BANK POINT 173010100106825 BUNTH AMXPB1214G AXIS NARIMAN BHAGIRATHI 220 UNIVERSAL TRADERS BANK POINT 173010200013253 PUHAN ARTPP7106J STANDAR D CHARTER 23-25 KANUNGO 221 VALIANT METAL ED BANK M.G.ROAD 22505893653 PIYUSH APTPK5975N VANGUARD JEWELS AXIS 222 LIMITED BANK POWAI 246010200005241 UMA KANSARIA

NAME OF SR BANK PROPRIETOR/ NO NAME BANK BRANCH ACCOUNT NO. DIRECTOR PAN NO. AXIS THAKUR MUKESH 223 VIJAYLAXMI CORPN. BANK VILLAGE 572010200002653 CHOKSI AAAPC7767J AXIS NARIMAN 224 VIMAL DIAMOND BANK POINT 173010200012254 VIMAL JAIN AEUPJ3948Q STANDAR D CHARTER 23-25 225 VINOD KUMAR BAFNA ED BANK M.G.ROAD 22510936721 - AIFPB1312F KOTAK MODEL VIRAT STAINLESS MAHINDR TOWN NEW RAM MILAN 226 INDIA A DELHI 001852000001294 PAL ALHPP5125B THE JAIN SAHAKAR PRAFUL I BANK BORIVALI PARSHOTTAMD 227 VIREN TRADE AGENCY LTD. (WEST) 056/0000700 AS VORA VISHNULENE NEW HUKMICHAND SYNTHETICS PRIVATE AXIS MARINE JAIN / GULAB 228 LIMITED BANK LINES 233010200013800 JAIN AXIS JAYANT 229 YASH V JEWELS LTD BANK POWAI 246010200005296 KANSARA SUKHRAJ AXIS BHAYANDA TARACHAND 230 YASHRAJ ENTERPRISE BANK R-WEST 575010200003636 JAIN ACQPJ7210D 10. As the transactions discussed in the Order (including Shri Nirmal Kotecha’s transactions and his relatives/related entities transactions) prima facie, appears to be linked to potential money laundering activities detrimental to the genuine investors at large, a copy of this Order is also being sent to the Director, Financial Intelligence Unit (FIU) – India and to the Reserve Bank of India (RBI) for necessary action against the concerned entitles/persons as deemed fit by them.

11. It was observed that number of front accounts were used prima facie by Shri. Nirmal Kotecha and his associates/ relatives, as stated above, to manipulate the securities market. I also find it appropriate to bring the financial transactions observed in this Order to the attention of the Income Tax Department. Hence, a copy of the order is also being sent to the Income Tax Department for their information and further necessary action, as the Income Tax Department deems fit.

12. A copy of the order shall also be sent to the Depositories for necessary action.

13. This order shall be treated as show cause notice against the entities/persons named hereinabove. The entities/persons against whom this order is issued may file their objections, if any, to this order within thirty days from the date of this order and, if they so desire, avail of an opportunity of personal hearing (after making a request in this regard) at the Securities and Exchange Board of India, Head Office, SEBI Bhavan, C-4A, G Block, Bandra Kurla Complex, Bandra (East) Mumbai – 400051. They may also inspect the relevant documents, if they so desire, on any working day prior to the hearing during office hours at the above mentioned address

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

PLACE: MUMBAI Dr. K. M. ABRAHAM DATE: 23rd April 2009 WHOLE-TIME MEMBER

Annexure – A Monthly charges incurred on mobile number 9819988816 in the name of Shri Amol Anand Kokane

The details, as provided by the service provider, of the monthly charges incurred on mobile number 9819988816 in the name of Shri Amol Anand Kokane and the cash payments received is as given below:

TRANS_TYPE NAME DATE_OF_TRANS TRANS_AMT (Rs.) Invoice 18-Sep-07 2,788.56 Amol Invoice Konkane 18-Oct-07 2,831.39 Amol Invoice Konkane 18-Nov-07 5,299.25 Amol Invoice Konkane 18-Dec-07 18,730.30 Amol Invoice Konkane 18-Jan-08 8,179.83 Amol Invoice Konkane 18-Feb-08 14,176.28 Amol Invoice Konkane 18-Mar-08 8,043.48 Amol Invoice Konkane 18-Apr-08 7,872.74 Amol Invoice Konkane 18-May-08 7,942.00 Amol Invoice Konkane 18-Jun-08 45,097.72 Amol Invoice Konkane 18-Jul-08 20,863.02 Amol Invoice Konkane 18-Aug-08 6,526.88 Amol Invoice Konkane 18-Sep-08 40,525.81 Amol Invoice Konkane 18-Oct-08 4,099.08 Amol Invoice Konkane 18-Nov-08 2,897.58 Amol Invoice Konkane 18-Dec-08 4,725.62 Amol Invoice Konkane 18-Jan-09 3,328.85 Amol Invoice Konkane 18-Feb-09 14.94 Total Invoice Amount 2,03,943.33

Annexure – A (continued 1)

TRANS_TYPE NAME DATE_OF_TRANS TRANS_AMT (Rs.) Amol Payments Konkane 10-Sep-07 500.00 Amol Payments Konkane 05-Oct-07 2,280.00 Amol Payments Konkane 05-Nov-07 2,885.00 Amol Payments Konkane 06-Nov-07 2,839.95 Amol Payments Konkane 29-Nov-07 2,414.00 Amol Payments Konkane 26-Dec-07 4,000.00 Amol Payments Konkane 26-Dec-07 4,000.00 Amol Payments Konkane 26-Dec-07 4,100.00 Amol Payments Konkane 26-Dec-07 4,000.00 Amol Payments Konkane 26-Dec-07 2,700.00 Amol Payments Konkane 24-Jan-08 9,000.00 Amol Payments Konkane 22-Feb-08 2,500.00 Amol Payments Konkane 29-Feb-08 13,000.00 Amol Payments Konkane 03-Apr-08 6,000.00 Amol Payments Konkane 07-May-08 2,000.00 Amol Payments Konkane 07-May-08 3,000.00 Amol Payments Konkane 07-May-08 3,000.00 Amol Payments Konkane 03-Jun-08 20,000.00 Amol Payments Konkane 21-Jun-08 35,000.00 Amol Payments Konkane 26-Jul-08 19,000.00 Amol Payments Konkane 26-Aug-08 7,000.00 Amol Payments Konkane 06-Oct-08 40,000.00 Amol Payments Konkane 05-Nov-08 3,800.00 Amol Payments Konkane 08-Dec-08 2,855.00 Amol Payments Konkane 14-Jan-09 4,000.00 Amol Payments Konkane 14-Jan-09 700.00 Total Payment Amount 2,00,573.95

Annexure – B

Trading Pattern of Shri Amol Kokane on BSE and NSE

During the period from September 29, 2008 to November 17, 2008, it is observed from the below mentioned table that Shri Amol Kokane was generally buying at a higher rate and selling at a lower rate on BSE and NSE. The details of such transactions are as given below:

TRADE Buy Sell GP_QTY GS_QTY GP_VALUE GS_VALUE DATE Price Price (Rs.) (Rs.) (Rs.) (Rs.) BSE 29-Sep-2008 25,000 0 2,374,776.60 0.00 94.99 03-Oct-2008 15,000 0 1,400,471.60 0.00 93.36 27-Oct-2008 110 8110 4,444.50 321,280.95 40.40 39.62 31-Oct-2008 0 5000 0.00 216,445.05 43.29 03-Nov-2008 1,60,883 155196 8,039,316.60 7,501,375.70 49.97 48.33 04-Nov-2008 1,52,095 117828 8,548,541.55 6,149,882.15 56.21 52.19 05-Nov-2008 45,222 64222 2,690,043.80 3,559,922.15 59.49 55.43 06-Nov-2008 13,275 20275 677,288.65 1,031,781.10 51.02 50.89 07-Nov-2008 10,247 14091 540,677.20 739,147.65 52.76 52.46 10-Nov-2008 28,924 28924 1,624,881.65 1,612,147.60 56.18 55.74 11-Nov-2008 6,870 6870 365,113.45 357,499.75 53.15 52.04 12-Nov-2008 393 393 18,758.45 18,944.45 47.73 48.20 17-Nov-2008 1,065 1065 47,083.50 46,948.90 44.21 44.08 4,59,084 4,21,974 26,331,397.55 2,15,55,375.45

Annexure – B (continued 1)

NSE Buy Sell TRADE DATE GP_QTY GS_QTY GP_VALUE GS_VALUE Price Price (Rs.) (Rs.) (Rs.) (Rs.) 03-November- 2008 7,000 11,000 33,2,183 5,20,617 47.45 47.33 04-November- 2008 32,948 32,059 17,94,031 17,34,198 54.45 54.09 05-November- 2008 27,342 60,342 15,44,731 33,50,550 56.50 55.53 06-November- 2008 104 103 5,586 5,452 53.71 52.93 07-November- 2008 213 213 11,324 11,145 53.16 52.32 10-November- 2008 5,868 5,868 3,31,254 3,30,475 56.45 56.32 11-November- 2008 34 34 1,829 1,855 53.79 54.56 73,509 1,09,619 40,20,938 59,54,292

Annexure – C

Day-wise contribution of Shri Amol Kokane to the total trading volume of PSTL scrip on BSE

The day wise contribution of Shri Amol Kokane to the total trading volume of PSTL scrip on BSE during the ten days that shares were purchased on his behalf during the period October 10 to November 27, 2008 is as given below:

Quantity bought by Total traded volume on % contribution. to total Date Shri Amol Kokane BSE on these days traded volume 10/27/2008 110 2,91,298 0.03 11/3/2008 1,60,883 6,58,892 24.41 11/4/2008 1,52,095 7,38,689 20.58 11/5/2008 45,222 3,16,324 14.29 11/6/2008 13,275 1,29,528 10.24 11/7/2008 10,247 81,398 12.58 11/10/2008 28,924 1,52,670 18.94 11/11/2008 6,870 78,437 8.75 11/12/2008 393 1,42,282 0.27 11/17/2008 1,065 2,07,996 0.51 Gross 4,19,084 27,97,514 14.98

Annexure - D Shri Amol Kokane’s Bank Trail

Amounts of Rs. 10 lacs, Rs. 15 lacs and Rs. 10 lacs were transferred to Shri Amol Kokane’s account on September 10, October 04 and October 07, 2008 respectively, which in turn, were transferred to his client account India Capital Market on September 16, October 06 and October 08, 2008 respectively. The bank trail from where these funds were received has, so far, revealed as follows:

The first credit of Rs. 10 lacs was transferred to Shri Kokane’s account on September 10, 2008 from the account of one M/s. Om Associates with Axis Bank, whose Proprietor is Shri Kantilal Samelaji Purohit. The address of M/s. Om Associates as per the KYC copy is 301, Bldg. 45, Shwetrajhans Soc., Khodiyan Nagar Road, Surat. This address of M/s. Om Associates was found to be identical with another account holder of the bank Shri Avichal Soni, Proprietor of M/s. Raj Traders. The KYC copy of the two account holders reveal that both hold the same mobile number 9930994504. Also, both the account holders M/s. Om Associates and M/s. Raj Traders have entered into Leave and Licence Agreement separately on October 21, 2007 and October 19, 2007 with the same person Shri Ghanshyambhai M. Patel for the same premises viz. 301, Bldg. 45, Shwetrajhans Soc., Khodiyan Nagar Road, Surat, 120 sq. ft. built up area consisting of one room for official purpose only on a monthly compensation of Rs. 1200/- for the period of 11 months with effect from October 01, 2007. Also, the account statement of M/s. Om Associates reveals that immediately prior to transfer of Rs. 10 lacs to Shri Amol Kokane on September 10, 2008, M/s. Om Associates had received credits from the following counter parties viz. M/s. Shree Earthmovers and Land Developers, M/s. Balaji Corporation, M/s. Shakti Trading Co., M/s. Om Corporation, M/s. Gayatri Gems, M/s. Raj Traders, M/s. Kanchan Impex, M/s. Sarita Diamond, M/s. Bhairav Diamond, M/s. Harish Metal and Tubes, M/s. Paras Steel India, M/s. Ferro N Alloys, M/s. Chandan Gems, M/s. Shree Forge Industries, M/s. R.S. Enterprise and Shri Pravin Babulal Jain. From the further trail of these accounts, carried out so far, it is observed that funds are being rotated through all these accounts as well as through the large network of their connected accounts in a complex circuitous manner and without any seemingly bonafide business purpose. To understand the modus operandi being followed in routing of funds, the trail for the period September 19, 2008 to September 25, 2008 of one of the connected accounts M/s. Raj Traders, which shares the same office address as that of M/s. Om Associates is given below:

Annexure – D (continued 1)

Axis Bank, Thakur Village Account of M/s. Raj Traders from 19-09-2008 to 25-09-2008 Date Debits Credits (Rs.) To (Rs.) From 19.09.2008 37,00,000 Om Associates 37,00,000 Hare Krishna Expo 38,75,000 Om Associates 22,25,000 Balajee Diamonds 41,50,000 Om Associates 45,50,000 Om Associates 43,05,000 Om Associates 40,50,000 Hare Krishna Expo 38,75,000 Hare Krishna Expo 35,50,000 Hare Krishna Expo 38,20,000 Om Associates 42,25,000 Hare Krishna Expo 27,75,000 Balajee Diamonds

20.09.2008 35,00,000 Hare Krishna Expo 38,00,000 Hare Krishna Expo 40,00,000 Hare Krishna Expo 36,00,000 Om Associates 36,00,000 Om Associates 41,00,000 Om Associates

22.09.2008 32,00,000 Balajee Diamonds 21,00,000 Balajee Diamonds 38,50,000 Hare Krishna Expo 35,00,000 Hare Krishna Expo 29,00,000 Hare Krishna Expo 38,50,000 Om Associates 36,50,000 Om Associates 41,00,000 Om Associates 39,50,000 Om Associates 30,00,000 Balajee Diamonds 28,00,000 Hare Krishna Export 27,00,000 Hare Krishna Export 43,00,000 Om Associates 42,00,000 Om Associates 23.09.2008 38,25,000 Om Associates 38,30,000 Balajee Diamonds 25.09.2008 30,00,000 Balajee Diamonds 5,25,000 Hare Krishna Export 36,50,000 Balajee Diamonds 36,75,000 Om Associates 35,00,000 Om Associates

Annexure – D (Continued 2) Also, high value cash transactions (cash withdrawals and cash deposits), below rupees ten lacs, have been carried out in some of these connected accounts. Many other accounts which again appear to be linked to these accounts in some manner are yet to be identified. There are about 230 entity/ persons names that have been identified so far based on high value debits/ credits appearing in the accounts of some of these connected entities. Some of these entities are found to be trading in the stock market. The second credit of Rs. 15 lacs was transferred to Shri Kokane’s account on October 04, 2008 from the account of one Shri Bhavik Hasmukh Shah of M//s. Amrut Trading Co. having address at B Wing, 8, Sangam Apts. Bldg. No. 3, Janta Station Road, Bhayander (West), Maharashtra – 401101. M/s. Amrut Trading Co. also appears to be one of the connected entities whose bank account shows suspicious transactions. Further, a quick perusal of M/s. Amrut Trading Co.’s account for the limited period of September 26, 2008 to October 07, 2008 i.e. around the time when funds were transferred to Shri Kokane’s account reveals repetitive cash withdrawals of high value but just below rupees ten lacs as well as repeated cheque returns.

It is seen that Rs. 8.7 lacs, Rs. 8.5 lacs, Rs. 9.90 lacs, Rs. 7.40 lacs, Rs. 9.9 lacs and Rs. 5 lacs in cash was withdrawn on September 26, 27, October 01, 03, 04 and 06, 2008 respectively. Also, M/s. Amrut Trading Co., whose proprietor is Shri Bhavik Hasmukh Shah has traded in the stock market. Further, against Rs. 15 lacs that was transferred to Shri Kokane’s account, it is seen that M/s. Amrut Trading Company, in turn, had received credit of Rs. 7.5 lacs each in its account from M/s. Vasundhara Corporation, whose proprietor is Shri Jignesh Amrutbhai Patel, and, from M/s. Raj Enterprises, whose proprietor is Shri Hiral H. Shah. Shri Jignesh Amrutbhai Patel, who is the proprietor of M/s. Vasundhara Corporation, is also seen to be the proprietor in M/s. Classic Enterprises, from where too Rs. 18 lacs has been transferred to Kokane’s account and the same is discussed below. Further, M/s. Vasundhara Corporation account, in turn, has been introduced by M/s. Mayur Corporation, which is represented by its proprietor Shri Bhavik H. Shah, No. 8, Sangam Apartments, B Wing, Building No. 3, Janta Nagar Station Road, Bhayander (West), who, as stated above is the proprietor of M/s. Amrut Trading Co. Similarly, M/s. Raj Enterprises account is introduced by M/s. Classic Enterprises and here one S.R.

Shah is shown as the proprietor of M/s. Classic Enterprise, having address as C/3, Neelkanth Nagar, Opp. Pushpa Park Society, S.V. Road, Borivali (West), Mumbai. Besides, these two accounts M/s. Vasundhara Corporation and M/s. Raj Enterprises, again demonstrate the same modus operandi of their operation – viz. frequent and high value cash withdrawals, large number of cheque returns and high value fund transfers in and out of these accounts. The third credit of Rs. 10 lacs that was received in Shri Kokane’s account on October 07, 2008, was again transferred from the account of Shri Bhavik Hasmukh Shah of Amrut Trading Co.

Annexure – D (Continued 3) The bank statement of Shri Amol Kokane further indicates that an amount of Rs. 50 lacs was transferred on October 17, 2008 from Kokane’s account to the account of one M/s. Nikhil Securities Ltd., who is a stock broker having office at 710, 5th Floor, UP Stock Exchange, Civil Lines Kanpur 208001 and whose director is Shri Sarwesh Dubey of 127/576-77, W-1, Saket Nagar, Kanpur 208014. On BSE, it is seen that M/s. Nikhil Securities Ltd. had bought 1 lac shares in bulk deal on own account on October 07, 2008 at Rs. 132.99 in M/s. Usher Agro Ltd., in which, Shri Nirmal Kotecha was holding around 4% shareholding (7,24,536 shares) as on September 30, 2008. Further trail of these funds that were transferred to M/s. Nikhil Securities Ltd. is not yet complete. Prior to transferring this amount of Rs. 50 lacs to the account of M/s. Nikhil Securities Ltd. on October 17, 2008, Shri Kokane’s account had received credits of Rs. 5.25 lacs, Rs. 2.75 lacs, Rs. 15 lacs and Rs. 12 lacs from different parties on October 10, 2008 and of Rs. 18 lacs on October 15, 2008. The details of what the trail of these accounts has so far revealed is given below: The credit of Rs. 5.25 lacs on October 10, 2008 was received in Shri Kokane’s account from one Shri Praful P. Vora of M/s. Viren Trading Agency.

It is seen that outcall for 2,624 seconds had been made from Shri Nirmal Kotecha’s Kokane number to one Shri Mandeep P. Vora on December 17, 2008 and again for 437 seconds on December 18, 2008. Also, incoming call for 560 seconds on December 20, 2008 at 14.16 was received on Shri Nirmal Kotecha’s Konkane number from Shri Mandeep P. Vora’s number. The investigation, so far, has revealed that Shri Praful P. Vora, in turn, had received this credit from one Shri Rajesh Jani. Shri Rajesh Jain is the Director of Dynamic Stock Broking Pvt. Ltd., as discussed in the Order The credit of Rs. 2.75 lacs on October 10, 2008 was received in Shri Kokane’s account from one Shri Hemal H. Gandhi HUF (Datapro) of 204, B Neelyog Apt. M G Cross Road North Opp. Patel Nagar Kandivli (West) Mumbai - 400067. The credit against this debit of Rs. 2.75 lacs in Shri Hemal H. Gandhi HUF (Datapro) account, in turn, has also been received again from Shri Rajesh Jani. The credit of Rs. 15 lacs on October 10, 2008 was received in Shri Kokane’s account from one Shri Nigam Vinod Shah of 203. A Wing, Ratna Sagar CHS, 80 feet Road, Near Jain Temple, Bhayander (West) Dist.

Thane. As per the bank KYC, it is observed that Shri Nigam Vinod Shah was introduced by one Shri Nimesh Chitalia, who is the Head, Business Development of M/s. India Capital Market Ltd. From a perusal of the bank account of Shri Nigam Vinod Shah, it is seen that an amount of Rs. 5 lacs has also been transferred from this account to Shri Raju Shah’s account on November 04, 2008. Shri Raju Shah’s client account was opened with the Borivali branch of M/s. India Capital Market Ltd. in July 2008 and he has also traded in the PSTL scrip on December 19 and 22, 2008. Here again, it is seen that the credit against the debit of Rs. 15 lacs that was issued to Shri Amol Kokane by Shri Nigam Vinod Shah was received in the account of Shri Nigam Vinod Shah from Shri Rajesh Jani, just prior to this Annexure – D (Continued 4) transaction. Further, the credit against the debit of Rs. 5 lacs that was issued to Shri Raju Shah, in turn, has also been received from Shri Rajesh Jani. The credit of Rs. 12 lacs on October 10, 2008 was received in Shri Kokane’s account from one Shri Janak H. Chitalia of M/s. J.H.

Chitalia & Co. of 102, Rajbharan Apartment L T Road, Borivli (West) Mumbai -400092. The credit against this debit of Rs. 12 lacs in Shri Janak H. Chitalia’s account, in turn, has again been received again from Shri Rajesh Jani.

The credit of Rs. 18 lacs on October 15, 2008 was received in Shri Kokane’s account from one Shri Jignesh Amrutbhai Patel of Classic Enterprises having address at R. No. 3, Tipco Niwas, Khot Dongri R.S., Malad, Mumbai – 400097. M/s. Classic Enterprises also appears to be one of the connected entities whose bank account shows suspicious transactions. Further, from a quick perusal of Classic Enterprises account for the limited period of October 01, 2008 to October 15, 2008 i.e. just prior to the transfer of funds to Shri Kokane’s account, it is seen that there are repetitive cash withdrawals of high value, but, just below rupees ten lacs, as well as repeated cheque returns of deposited cheques. It is observed that Rs. 7 lacs, Rs. 7 lacs, Rs. 5 lacs, Rs. 8.5 lacs, Rs. 5.9 lacs and Rs. 1.5 lacs, Rs. 2.9 lacs and Rs. 50,000 in cash was withdrawn on October 03, 04, 06, 07, 08, 13, 14 and 15, 2008 respectively.

Annexure E Shri Nirmal Kotecha’s bank trail A perusal of the bank accounts of Shri Nirmal Kotecha and his immediate relatives/ related entities, over a six month period from June to December 2008, so far has revealed the following: Shri Nirmal Kotecha’s account with HDFC, Matunga: Shri Nirmal Kotecha’s account shows that he has withdrawn cash of about Rs. 1.25 crore around August end and mid-September, 2008 by withdrawing Rs. 24 lacs from his account and by transferring funds of Rs. 25 lacs each to Ms. Veena Kotcha’s account, Shri Manilal Kotecha’s account, M/s. Nirman Mgt. Services Pvt. Ltd. account and M/s. Nishwet Mgt. Services Pvt. Ltd. account and then withdrawing Rs. 24 lacs from each of these accounts, in three different tranches of Rs. 8 lacs each. It is further seen that Rs. 5 lacs cash has been withdrawn from his account on December 22, 2008 and Rs. 9 lacs cash has been withdrawn on December 29, 2008. It is seen that transfer of funds from this account have been made to his brokers account and also to the account of his relatives and to his two entities M/s. Nirman Mgmt. Services Pvt. Ltd. and M/s. Nishwet Mgmt Services Pvt. Ltd. It is seen from the above that cash of high value was withdrawn on the day the forgery received wide media publicity.

Ms. Viral Doshi’s account with HDFC, Matunga: It is seen that Shri Nirmal Kotecha transferred funds in his wife Ms. Viral Doshi’s account. Funds amounting to Rs.10 lacs have been transferred from Shri Nirmal Kotecha’s account to his wife Ms. Viral Doshi’s account on September 25, 2008, and these funds, in turn, have been transferred to one Shri Shailesh Jayantilal Shah’s account on the very same day. This amount of Rs. 10 lacs has been returned to Ms. Viral Doshi’s account by Shri Shailesh Jayantilal Shah in three tranches of Rs. 4 lacs, Rs. 5 lacs and Rs. 1 lac on December 26, 27 and 31, 2008 respectively. From Ms. Viral Doshi’s account this amount of Rs. 10 lacs has again been transferred to one Darshan Trading Co.’s account on December 31, 2008. Further on December 31, 2008, it is seen that that Shri Kotecha has transferred Rs. 5 lacs from his account to his wife’s account, and again on the very same day, credited back Rs. 1.90 lacs in two tranches of Rs. 95,000 each back to his account. Ms. Veena Kotecha’s account with HDFC, Matunga: It is seen that an amount of Rs. 25 lacs was transferred on August 22, 2008 from Shri Nirmal Kotecha’s account to his mother Ms. Veena Kotecha’s account.

From this account, three self withdrawals of Rs. 8 lacs each have been done on September 11, 12 and 15, 2008 respectively. On December 11, 2008, two credits of Rs. 4 lacs each have been received in this account. And, thereafter again two cash withdrawals of Rs. 5 lacs and Rs. 4 lacs have been done on the very same day i.e. December 18, 2008. I observe that the modus operandi of cash withdrawals and deposits followed, appears to be similar to the one observed in the accounts of the connected entities, from where funds were transferred to Shri Kokane’s account, and which in turn, were ultimately transferred to stock market through broker India Capital Market. Also, I observe that cash of high value (Rs. 5 lacs and Rs. 4 lacs) in two lots was withdrawn on the very same day i.e. December 18, 2008 i.e. just a day prior to the dispatch of the forged SEBI letter on open offer to Shri Saminathan.

Annexure E (continued 1) Shri Manilal Kotecha’s account with HDFC, Matunga: It is seen that an amount of Rs. 25 lacs was transferred on August 22, 2008 from Shri Nirmal Kotecha’s account to Shri Manilal Kotecha’s account. From this account, it is seen that three self withdrawals of Rs. 8 lacs each have been done on August 22, 25 and 26, 2008 respectively. M/s. Nirman Mgt. Services Pvt. Ltd. account with HDFC Matunga: It is observed that an amount of Rs. 40 lacs has been transferred from Shri Nirmal Kotecha’s account to M/s. Nirman Management Services Pvt. Ltd. on June 13, 2008, and this in turn, has been transferred to Indiabulls Securities. On July 08, 2008, an credit of Rs. 1.15 crore has been received from Indiabulls Securities in the account of M/s. Nirman Mgt. Services Pvt. Ltd., which in turn, has been transferred back to Shri Nirmal Kotecha’s account on the same day. On July 11, 2008, an amount of Rs. 1 crore was transferred from Shri Nirmal Kotecha’s account to M/s. Nirman Mgt. Services Pvt. Ltd. and two high value cheques of Rs. 50 lacs each were issued from this account on July 16, 2008 – one to M/s. Hema Trading Co. Pvt. Ltd. and other to M/s. Real Gold Trading Co. Pvt. Ltd. These two entities appear to be connected to the entities carrying out suspicious banking transactions.

Again an amount of Rs, 25 lacs was transferred from Shri Nirmal Kotecha’s account to M/s. Nirman Mgt Ser Ltd. account on August 22, 2008 and from here cash withdrawal of Rs. 8 lacs each was done on August 22, 23 and 25, 2008. Funds have been received in Nirman Management Services Pvt. Ltd. account in two lots of Rs. 50 lacs and Rs. 68 lacs on October 11 and 13, 2008 respectively from one M/s. Darshan Trading Co. High value credits have been received in this account on October 13, 2008, which have been transferred to Shri Nirmal Kotecha’s account and M/s. Shree Salasar Suppliers’ account subsequently. The funds transferred to M/s. Shree Salasar Suppliers’ account, have been returned back by Shree Salasar Suppliers to Nirman Mgt. Services in three lots of Rs. 1 crore, Rs. 50 lacs and Rs. 50 lacs on October 24, 2008, November 10 and 14, 2008 respectively. It is further seen that on November 19, 2008, Rs. 15 lacs was transferred from the account of Nirman to Shri Deepak Thakker’s account. Again on December 02, 2008, it is seen that Shri Nirmal Kotecha has transferred Rs. 15 lacs from his account to the account of Nirman and from Nirman’s account on December 04, 2008, Rs. 15 lacs has been transferred to Shri Deepak Thakker’s account.

It is further seen that an amount of Rs. 5 lacs has been transferred by Shri Nirmal Kotecha on December 17, 2008 (i.e. just two days prior to the dispatch of forged SEBI letter to Shri Saminathan) from his account to Nirman Mgt. Services account and the same has been transferred from there to Shri S. Ganesan, the Group Company Secretary of PSTL on the same day. Further trail of this account is being carried out. M/s. Nishwet Mgt. Services Pvt. Ltd. account with HDFC Matunga: It is seen that an amount of Rs. 25 lacs was transferred on August 22, 2008 from Shri Nirmal Kotecha’s account to M/s. Nishwet Magmt. Services Pvt. Ltd. account. From this account, again three self withdrawals of Rs. 8 lacs each have been done on August 22, 25 and 26, 2008 respectively. An amount of Rs. 15 lacs transferred from Shri Nirmal Kotecha’s account has been further transferred to the account of M/s. Salasar Suppliers Pvt. Ltd. Further trail of this account is being carried out.

Annexure F Shri Shailesh Jayantilal Shah’s trades in PSTL during the period December 15, 2008 to December 23, 2008 The trade details of Shri Shailesh Jayantilal Shah in the PSTL scrip during the period December 15, 2008 to December 23, 2008 are as given below: On BSE

Date Name of the broker Quantity Bought Quantity sold

16-Dec-08 Motilal Oswal Securities 1,890 1,890 17-Dec-08 Motilal Oswal Securities 3,336 0 19-Dec-08 Motilal Oswal Securities 5,000 0 22-Dec-08 Motilal Oswal Securities 0 5,000 22-Dec-08 Marwadi Shares and Finance 0 500 Total 10,226 7,390 On NSE

Date Name of the broker Quantity Bought Quantity sold 16-Dec-08 Motilal Oswal Securities 4,912 4,912 22-Dec-08 Motilal Oswal Securities 28,700 32,000 22-Dec-08 JM Financial Services Pvt 0 5,000 Total 33,612 41,912

Annexure G Trades of persons/ entities that have the same address as that of Shri Shailesh Jayantilal Shah and have traded in PSTL scrip during the period December 15, 2008 to December 23, 2008 The following persons/ entities that have the same address as that of Shri Shailesh Jayantilal Shah, as per Unique Client Code (UCC) database of BSE (hereinafter referred to as Shah group), have traded in PSTL scrip during the period December 15, 2008 to December 23, 2008, the details of which are given below: Quantity Quantity Date Name of the client Name of the broker Bought sold BSE Rajesh Jayantilal 12/15/2008 Shah JM Financial Services Pvt 17,408 0 Rajesh Jayantilal 12/16/2008 Shah JM Financial Services Pvt 15,478 15,478 Rajesh Jayantilal 12/17/2008 Shah JM Financial Services Pvt 15,838 7,097 Rajesh Jayantilal 12/18/2008 Shah JM Financial Services Pvt 5,000 739 Rajesh Jayantilal 12/22/2008 Shah JM Financial Services Pvt 22,252 62,000 Rajesh Jayantilal 12/22/2008 Shah Motilal Oswal Securities 0 3,000 75,976 88,314 Binaben 12/16/2008 Shaileshkumar Shah Motilal Oswal Securities 2,714 2,714 Binaben 12/17/2008 Shaileshkumar Shah Motilal Oswal Securities 5,002 Binaben 12/22/2008 Shaileshkumar Shah Motilal Oswal Securities 0 4,262 7,716 4,262 Marwadi Shares and 12/16/2008 Nirmal Rohitbhai Shah Financ 800 800 12/17/2008 Nirmal Rohitbhai Shah JM Financial Services Pvt 1,000 0 12/22/2008 Nirmal Rohitbhai Shah JM Financial Services Pvt 0 10,000 12/23/2008 Nirmal Rohitbhai Shah JM Financial Services Pvt 1,000 0 2,800 10,800 Ritaben Rohitkumar 12/22/2008 Shah JM Financial Services Pvt 0 5000 Ritaben Rohitkumar 12/19/2008 Shah Motilal Oswal Securities 3,000 0 3,000 5,000 Manishaben 12/22/2008 Rajeshkumar Shah Motilal Oswal Securities 0 2,000 0 2,000

Annexure G (continued 1)

Quantity Quantity Date Name of the client Name of the broker Bought sold NSE 15-Dec-08 Nirmal Rohitbhai Shah JM Financial Services Pvt 10,000 0 16-Dec-08 Nirmal Rohitbhai Shah JM Financial Services Pvt 2,856 13,356 17-Dec-08 Nirmal Rohitbhai Shah JM Financial Services Pvt 2,723 0 18-Dec-08 Nirmal Rohitbhai Shah JM Financial Services Pvt 20,000 0 22-Dec-08 Nirmal Rohitbhai Shah JM Financial Services Pvt 0 13,000 23-Dec-08 Nirmal Rohitbhai Shah JM Financial Services Pvt 500 0 19-Dec-08 Nirmal Rohitbhai Shah Motilal Oswal Securities 1000 0 22-Dec-08 Nirmal Rohitbhai Shah Motilal Oswal Securities 0 2000 37,079 28,356 Ritaben Rohitkumar 16-Dec-08 Shah Motilal Oswal Securities 5,000 5,000 Ritaben Rohitkumar 19-Dec-08 Shah JM Financial Services Pvt 15,000 0 Ritaben Rohitkumar 19-Dec-08 Shah Motilal Oswal Securities 4,000 0 Ritaben Rohitkumar 22-Dec-08 Shah JM Financial Services Pvt 0 10000 Ritaben Rohitkumar 22-Dec-08 Shah Motilal Oswal Securities 7,000 24,000 22,000 Rajesh Jayantilal 15-Dec-08 Shah JM Financial Services Pvt 5,000 0 Rajesh Jayantilal 16-Dec-08 Shah JM Financial Services Pvt 11,013 43,513 Rajesh Jayantilal 16-Dec-08 Shah Motilal Oswal Securities 0 183 Rajesh Jayantilal 17-Dec-08 Shah JM Financial Services Pvt 26,264 0 Rajesh Jayantilal 18-Dec-08 Shah JM Financial Services Pvt 5,000 0 Rajesh Jayantilal 19-Dec-08 Shah JM Financial Services Pvt 10,000 5,000 Rajesh Jayantilal 22-Dec-08 Shah JM Financial Services Pvt 10,000 22,000 Rajesh Jayantilal 22-Dec-08 Shah Motilal Oswal Securities 0 537 67,277 71,233

Annexure G (continued 2)

Quantity Quantity Date Name of the client Name of the broker Bought sold NSE (continued) Manishaben 15-Dec-08 Rajeshkumar Shah Motilal Oswal Securities 10000 0 Manishaben 16-Dec-08 Rajeshkumar Shah Motilal Oswal Securities 0 11136 Manishaben 18-Dec-08 Rajeshkumar Shah Motilal Oswal Securities 5000 0 Manishaben 22-Dec-08 Rajeshkumar Shah Motilal Oswal Securities 0 3000 15000 14136 Binaben 17-Dec-08 Shaileshkumar Shah Motilal Oswal Securities 5000 0 Binaben 22-Dec-08 Shaileshkumar Shah Motilal Oswal Securities 0 8240 5000 8240

Annexure - H Trading of Shri Nirmal Kotecha during the period October 24, 2008 to January 07, 2009 The interim investigation report has revealed that Shri Nirmal Kotecha, on his own account, traded in the shares of PSTL during the period October 24, 2008 to January 07, 2009, the details of which are as given below: At BSE At NSE Across Both the Exchanges Net across Trade Date GP GS Net GP GS Net GP GS both Exchanges 24-Oct-08 1,40,000 1,40,000 0 331 331 0 1,40,331 1,40,3310 27-Oct-08 2,00,000 1,97,985 2,015 50,000 52,015 -2,015 2,50,000 2,50,0000 19-Nov-08 0 2,80,000 -2,80,000 0 0 0 0 2,80,000 -2,80,000 28-Nov-08 0 62,101 -62,101 0 1,439 -1,439 0 63,540 -63,540 1-Dec-08 0 50,000 -50,000 0 0 0 0 50,000 -50,000 5-Dec-08 0 48,071 -48,071 0 0 0 0 48,071 -48,071 8-Dec-08 0 2 -2 0 3,934 -3,934 0 3,936 -3,936 16-Dec-08 0 1,02,088 -1,02,088 0 53,188 -53,188 0 1,55,276 -1,55,276 17-Dec-08 0 1,40,000 -1,40,000 0 1,40,000-1,40,000 0 2,80,000 -2,80,000 19-Dec-08 0 25,000 -25,000 0 25,000 -25,000 0 50,000 -50,000 22-Dec-08 0 6,65,195 -6,65,195 0 8,40,667-8,40,667 0 15,05,862 -15,05,862 23-Dec-08 0 1,40,982 -1,40,982 0 1,40,000-1,40,000 0 2,80,982 -2,80,982 30-Dec-08 0 1,30,000 -1,30,000 0 1,06,921-1,06,921 0 2,36,921 -2,36,921 31-Dec-08 0 2,38,983 -2,38,983 0 0 0 0 2,38,983 -2,38,983 1-Jan-09 0 9,81,000 -9,81,000 0 9,82,000-9,82,000 0 19,63,000 -19,63,000 2-Jan-09 0 6,06,156 -6,06,156 1,449 8,53,641-8,52,192 1,449 14,59,797 -14,58,348 5-Jan-09 0 1,87,256 -1,87,256 0 2,66,067-2,66,067 0 4,53,323 -4,53,323 7-Jan-09 0 0 0 0 30,875 -30,875 0 30,875 -30,875 70,99,117

Annexure I Reporters’ version of response received on mobile number 9947219100 on December 20 and 21, 2008 The gist of the reporters’ version as informed to SEBI is given below: As per the Statement of Shri Raj Nambisan, Business Editor of DNA, recorded on January 29, 2009 at SEBI, on Saturday, the December 20th, 2008, in the evening around 5-6 p.m., Shri Rakesh Sharma called him to give the mobile number of Shri Kanhucharan Sahu, the Company Secretary of Pyramid Saimira Theatre Ltd., which was 9947219100. He stated that he passed on the said mobile number to his special correspondent, Shri N. Sundaresha Subramanian, who called Shri Kanhucharan Sahu on the said number, and the person who answered the call confirmed the receipt of the letter. Hence DNA decided to publish the news. However, as per Shri Nambisan’s statement when Shri Sundaresha Subramanian called on the same mobile number i.e. 9947219100 of Shri Kanhucharan Sahu on Tuesday i.e. on December 23, 2008, nobody answered the call. Later, Shri Sundaresha Subramanian realized that a media release on BSE site on December 23, 2008 showed a different number for Shri Kanhucharan Sahu.

When Shri N. Sundaresha Subramanian called on that number of Shri Kanhu Charan Sahu i.e. the actual Company Secretary of Pyramid Saimira Theatre Ltd., he denied having received any call from Sundaresha Subramanian on Saturday. As per the Statement of Shri Partha Sinha, Asst. Markets Editor of Times of India recorded on January 29, 2009 at SEBI, he met Shri Rakesh Sharma on Saturday, the December 20th, 2008 at around 2.30 p.m. in Howrah Restaurant in Hotel New Bengal near Crawford market and they had food together. Shri Partha Sinha in his statement stated that during the time that they were having food together, Shri Rakesh Sharma received a call, which he said was from Shri Nirmal Kotecha, and he told him that he was having lunch and would call later. During lunch Shri Rakesh Sharma told Shri Partha Sinha regarding the contents of the SEBI letter and also told him that he will forward the contact number of Shri Kanhucharan Sahu, the Company Secretary of PSTL, from whom he can confirm the details. Shri Rakesh Sharma forwarded the mobile number of Shri Kanhucharan Sahu by SMS in the evening.

Shri Partha Sinha later e-mailed the number of Shri Kanhucharan Sahu that was given by Shri Rakesh Sharma as 9947219100. Shri Partha Sinha stated that he called to contact on that number after 7.30 P.M. on Saturday, but the number was not reachable. Shri Partha Sinha stated that he again called that number on Sunday around 8.00 p.m. and the person who took the call confirmed that they had received the letter and are looking into the matter. As per the Statement of Shri Ashish Rukhaiyar, Principal Correspondent of Economic Times, recorded on February 2, 2009 at SEBI, on Saturday, at around 9.45 p.m., Shri Rakesh Sharma sent by SMS the mobile number of Shri Kanhu Charan Sahu, the company secretary and compliance officer of Pyramid Saimira Theatre Ltd. and mentioned that he can confirm from Shri Sahu. However, Shri Ashish Rukhaiyar in his statement stated that he did not call Shri Sahu on Sunday and when on Monday he called on that number, the person who answered the call informed him that it was not the number of Shri Kanhucharan Sahu.

Annexure I (continued 1) As per the statement of Shri Jayanta Mallick, Special Correspondent, The Hindu Business Line recorded on March 26, 2009 at SEBI’s Eastern Regional Office, he got Shri Saminathan’s mobile number as 09840980111, the Company Secretary Shri Kanhu Charan’s mobile number as 09947219100 and Shri Rakesh Sharma’s mobile number as 09821419263, and that all these numbers were SMSed to him by Shri Dheer Kothari who passed on the e-mail of the forged letter to him. Shri Mallick in his statement has stated that call to Shri Saminathan’s mobile did not elicit any response. On contacting on the number of Shri Kanhu Charan that was provided to him, Shri Mallick stated that the person who answered the call admitted that an order on Shri Saminathan was received by the company. As per Shri Mallick, the person further said that he would not be able to comment on it and that he was new to the company before disconnecting the line. When he contacted Shri Rakesh Sharma on the number provided to him, Shri Mallick claimed that Shri Rakesh Sharma informed him that he got the release and the order from the company. Shri Mallick in his statement has stated that he decided to write the story as he had no reasonable basis to disbelieve the so called press release and the order as he was clearly told by Shri Dheer Kothari and Shri Rakesh Sharma that the release was from the company.

Annexure J Details of Shri P.S. Saminathan’s purchases from Shri Nirmal Kotecha The details of Shri P. S. Saminathan’s purchases from Shri Nirmal Kotecha are as given below: Trade Price Counter Party Trade Date Time Member Name Quantity (Rs.) Member Name JM FINANCIAL JM FINANCIAL 11/19/2008 13:38:12 SERVICES PVT 1,40,000 50 SERVICES PVT JM FINANCIAL KOTAK 11/19/2008 13:38:12 SERVICES PVT 1,40,000 50 SECURITIES LTD. JM FINANCIAL INDIABULLS 11/28/2008 12:03:54 SERVICES PVT 36,386 42 SECURITIES LTD JM FINANCIAL INDIABULLS 11/28/2008 14:41:05 SERVICES PVT 24,371 38.9 SECURITIES LTD JM FINANCIAL KOTAK 11/28/2008 14:42:11 SERVICES PVT 1,000 37 SECURITIES LTD. JM FINANCIAL KOTAK 12/1/2008 15:15:24 SERVICES PVT 50,000 38.9 SECURITIES LTD. JM FINANCIAL KOTAK 12/5/2008 15:27:01 SERVICES PVT 48,071 46.9 SECURITIES LTD.

Annexure - K Details of Shri P.S. Saminathan’s transactions in the market during the period from October 24, 2008 to December 5, 2008 The details of Shri P.S. Saminathan’s transactions in the market during the period from October 24, 2008 to December 5, 2008 are as given below: At BSE At NSE Across Both the Exchanges Net across Trade Date GP GS Net GP GS Net GP GS both Exchanges 24-Oct-08 30,600 0 30,600 0 0 0 30,600 0 30,600 28-Oct-08 2,000 0 2,000 300 0 300 2,300 0 2,300 19-Nov-08 4,00,000 0 4,00,000 0 0 0 4,00,000 0 4,00,000 25-Nov-08 60,892 0 60,892 5000 0 5,000 65,892 0 65,892 26-Nov-08 16,000 0 16,000 15,000 0 15,000 31,000 0 31,000 28-Nov-08 1,47,000 0 1,47,000 51,650 0 51,650 1,98,650 0 1,98,650 1-Dec-08 62,500 0 62,500 0 0 0 62,500 0 62,500 5-Dec-08 53,000 2,000 51,000 0 4,000 -4,000 53,000 6,000 47,000 Gross 7,71,992 2,000 7,69,992 71,950 4,000 67,950 8,43,942 6,000 8,37,942 GP- Gross Purchase GS- Gross Sale