Order under Section 11 and 11B of the SEBI Act, 1992 and Regulation 11 of the PFUTP Regulations, 2003 in respect of Bhavesh Prakash Pabari, Hemant M Sheth and 40 other entities in the matter of manipulation in the scrip of Crazy Infotech Ltd.[SAT Appeal No.:266/2015]

WTM/SR/IVD/ID- 3/ 20 /02/2015

BEFORE THE SECURITIES AND EXCHANGE BOARD OF INDIA, MUMBAI CORAM: S. RAMAN, WHOLE TIME MEMBER ORDER Under Sections 11 and 11B of the Securities and Exchange Board of India Act, 1992 read with Regulation 11 of the SEBI (Prohibition of Fraudulent and Unfair Trade Practices relating to Securities Market) Regulations, 2003 in respect of Bhavesh Prakash Pabari, Hemant M Sheth and 40 other entities in the matter of manipulation in the scrip of Crazy Infotech Ltd. 1. Securities and Exchange Board of India (hereinafter referred to as "SEBI") and Bombay stock Exchange (BSE) conducted investigation into buying, selling and dealing in the scrip of Crazy Infotech Ltd. (hereinafter referred to as "Crazy Infotech"), for various periods between August 2005 to August 2007, on observing spurt in the price of the scrip.

2. On the basis of the Report submitted by BSE, SEBI conducted a detailed investigation into the buying, selling and dealing in the scrip of Crazy Infotech during the period from April 1, 2005 to December 31, 2007 (hereinafter referred to as "investigation period") in order to ascertain any instances of contravention of provisions of SEBI Act, 1992 (SEBI Act)/Rules/Regulations etc.

2.1 It was observed that prior to the investigation period i.e. during the period January 21, 2004 to March 31, 2005, the price of the scrip was in the range from, ` 0.57 to `2.76/- with daily average volume of 16,270 shares and three months prior to the investigation period i.e from January 1, 2005 to March 31, 2005, the price of the scrip was in the range from `1.64 to `2.74/-. However, it was observed that during the investigation period (i.e. from April 1, 2005 to December 31, 2007), price of the scrip increased from `1.99 to reach a high of `268/- on September 28, 2007 and later closed at ` 255.80 on December 31, 2007. After the investigation period, price of the scrip fell sharply to close at `21.5/- on March 27, 2008. It was also noted that there were no major corporate announcements during the said periods.

2.2 Investigation found that a group of 823 connected entities (connected through common telephone number, address, off market transaction, bank transactions and hereinafter collectively referred to as "connected entities" and individually by their names) were trading in the scrip during the investigation period in the manner of circular and reversed trades among themselves. Some of the connected entities were also found to have indulged in self trades during the investigation period. Details of these 823 connected entities along with their trading details during the investigation period and details of connections amongst a few of these entities were already given in the respective Show Cause Notices (SCN) sent to them.

2.3 The total traded volume in the scrip of Crazy Infotech during the investigation period was 2,92,46,282 shares. The aforesaid connected entities traded on 566 days out of 653 days on which the scrip was traded on the exchange (BSE) during the investigation period. They traded among themselves for 66,57,790 shares i.e. 22.73% of traded volume in the market. They were involved in trades for 2,14,07947 shares on either buy side or sell side or both sides of same trades accounting for around 73.07% of the total traded volume of 2,92,46,282 shares. The aforesaid group of connected entities were also observed to be transferring shares through off-market transactions/trades among themselves during the investigation period.

2.4 On analyzing the pattern of transactions executed by the connected entities, it was found that the connected entities had indulged in self trades and also traded in circular/ reversal/ synchronized/ structured pattern, creating artificial volume and price rise in the scrip of Crazy Infotech. The price volume data of the scrip for the investigation period was forwarded to the entities along with their respective SCNs.

3. Out of the entire 823 connected entities identified by the investigation (Paragraph No. 2.2), 780 entities were found to have either traded individually on 10 or less number of instances during the 653 days on which the scrip was traded on the exchange (BSE) during the investigation period, or traded on more than 10 instances but bought/sold less than 75,000 shares in market and/or off-market. On the basis of the said criteria, SEBI issued administrative warning to the aforesaid 780 entities in May 2011, advising the entities to take care in future and to be more vigilant, in the manner they execute trades, so the their trades do not compromise market integrity in any manner. Adjudicating proceedings were initiated against one of the entities, viz. Arcadia Share & Stock Brokers Pvt. Ltd.

3.1 Out of the remaining 42 entities, 37 entities were alleged to have traded in both market and off-market and bought/sold at least 75,000 or more shares in market and/or in off-market during the investigation period in circular/reversal,/synchronized/ structured trades in connivance with other connected entities, which resulted in artificial volumes and rise in price of the scrip of Crazy Infotech. The remaining 5 entities were found to have indulged only in off-market transactions and were an important off-market link between the other connected entities trading in market, thereby completing the circular pattern of trading among themselves and creating artificial volume in the market. These five entities were selected based on criteria that they had either totally bought or sold 75,000 shares or more in the off-market trading in more than 10 instances.

3.2 The following table contains the list of the remaining 42 entities(i.e. the 37 entities who traded in both market and off-market and the 5 entities who traded only in off-market), who were found to have traded in both market and off-market and bought/sold 75,000 or more shares in market and/or off-market during the entire investigation period in circular/reversal,/synchronized/structured trades, in connivance with other connected entities which resulted in creation of artificial volumes and impacted the price of the scrip of Crazy Infotech which distorted the price and volume of the scrip. The following 42 entities are hereinafter collectively referred to as "Noticees" and individually by their respective names : Serial Name of 42 connected entities PAN No. 1. Bhavesh Prakash Pabari AKGPP8679N 2. Hemant M Sheth ANOPS8607E 3. Anand Kalu Rapu Marathe AKWPM0699M 4. Rakesh Parasmal Singhvi BCQPS0499L 5. Rajesh Pravin Bhanushali AABPB2744H 6. Prem Mohanlal Parikh ALHPP3489N 7. Shriprakash Vinaykumar Sardesai AMYPS0171J 8. Vikram Damodar Jalan AGTPJ5257D 9. Kishore B Chauhan AFPPC9703G 10. Vinayak Maruti Bhange ABQPB5361E 11. Mayank Gandhi Aditi AKCPG0247R 12. Mayank Navnitbhai Gandhi AKCPG0246Q 13. Gokulbhai Patel Rakesh AGPPP7771C 14. Alliance Intermediaries and Network Pvt. Ltd. AAECA6031C 15. Amar Premchand Balmiki AAUPW9971A 16. Archana Arunkumar Upadhyay AAAPU3454C 17. Ankit Rajendra Sanchaniya BLNPS3316L 18. Arvind Mulraj Udeshi AAOPU9404C

19. Balasaheb Jagannath Kamble AQUPK2396P 20. Bharat Shantilal Thakkar AAZPT9542R 21. Bhavarlal Sonaji Malvi AUXPM5267G 22. Dilip Sadanand Utekar AAAPU0835B 23. Dilipkumar Shantilal Mehta ASDPS0763J 24. Dineshkumar Ramchandra Pandey AONPP7058J 25. Jaya Talakshi Chheda AAJPB7882N 26. Jayshree Shriprakash Sardesai AAQPS2141G 27. Jitendra Mehta ALWPM4683J 28. Kirit Shantilal Gandhi AAMPG4381Q 29. Pradeep Bhat AGSPB0964C 30. Pravinbhai Shah (DNG Mercantile Pvt. Ltd.) AACCD0126H 31. Rikesh R Shah APXPS9344F 32. Samir Shah Shital AGIPS3507J 33. Samir Sureshchandra Shah (HUF) AAHHS5122G Samir Sureshchandra Shah AGEPS0157L 34. Santosh Abhayraj Shukla BCRPS0029P 35. Santosh Kondu Gharat AIDPG7206M 36. Shyam Sunder Bohra AKCPB6054D 37. Vijay Kumar Bohra ABYPB1940P 38. Arunkumar Chhaganlal Upadhyay AAAPU0565E 39. Indrapratap Gajraj Singh APEPS7258B 40. Sachin Suresh Gaikawad ALFPG5902R 41. Chandrakant Keru Shinde ALUPS1679Q 42. Priyanka Dilip Utekar AABPU3762C

3.3 In respect of the aforesaid 42 entities, SEBI issued separate Show Cause Notices (SCNs) on November 7, 2012 to show cause as to why suitable directions under Section 11& 11B of the SEBI Act, 1992 read with Regulation 11 of the SEBI (Prohibition of Fraudulent and Unfair Trade Practices relating to Securities Market) Regulations, 2003 (hereinafter referred to as "PFUTP Regulations, 2003"), including a direction to restrain from accessing the securities market and prohibit from buying, selling or dealing in securities for a particular duration should not be passed against them for the violation of the provisions of SEBI (Prohibition of Fraudulent and Unfair Trade Practices relating to Securities Market) Regulations, 2003. The aforesaid 37 entities (traded in both market and off-market) were alleged to have violated Regulation 3 (a), 4(1), 4(2)(a), (b), (e) & (g) of PFUTP Regulations, 2003 and the remaining 5 entities (who transacted only in off-market) were alleged to have violated Regulation 3 (a), 4(1), 4(2)(a) of PFUTP Regulations, 2003.

3.4 The relevant provisions alleged to have been violated by the aforesaid entities are reproduced below

PFUTP Regulations, 2003 3. Prohibition of certain dealings in securities No person shall directly or indirectly— (a) buy, sell or otherwise deal in securities in a fraudulent manner; 4. Prohibition of manipulative, fraudulent and unfair trade practices (1) Without prejudice to the provisions of regulation 3, no person shall indulge in a fraudulent or an unfair trade practice in securities. (2) Dealing in securities shall be deemed to be a fraudulent or an unfair trade practice if it involves fraud and may include all or any of the following, namely:— (a) indulging in an act which creates false or misleading appearance of trading in the securities market; (b) dealing in a security not intended to effect transfer of beneficial ownership but intended to operate only as a device to inflate, depress or cause fluctuations in the price of such security for wrongful gain or avoidance of loss; (e) any act or omission amounting to manipulation of the price of a security; (g) entering into a transaction in securities without intention of performing it or without intention of change of ownership of such security;

3.5 Replies to the SCNs were received from the following Noticees:  Mr. Rakesh Parasmal Singhvi filed his reply vide letter dated February 17, 2014,  Mr. Shriprakash Vinaykumar Sardesai and Mrs. Jayshree Shriprakash Sardesai filed their reply vide separate letters dated February 4, 2014,  Mr. Vikram Damodar Jalan filed his reply, vide letter dated February 15, 2014,  Mr. Amar Premchand Balmiki filed his reply vide letter dated February 17, 2014,  Mr. Mayank Navnitbhai Gandhi and Ms. Aditi Mayank Gandhi filed their replies vide separate letters dated December 2, 2012,  Ms. Jaya Talakshi Chheda filed her reply vide letter dated December 17, 2012,  Mr. Samir Sureshbhai Shah and Ms. Shital S Shah filed their replies vide separate letters dated December 10, 2012,  Mr. Dilip Sadanand Utekar filed his reply vide letter dated July 19, 2014,  Mr. Chandrakant Keru Shinde, Ms. Priyanka Dilip Utekar filed his reply vide letter dated June 28, 2014,  Alliance Intemediateries and Network Pvt. Ltd. filed its reply vide letter dated November 27, 2012,  Jitendra Mehta vide letter dated February 17, 2012 filed his reply,

 Pradeep Bhat filed his reply vide letter dated December 2, 2012,  Vijay Kumar Bohra filed his reply dated August 23, 2014,  Vinayak Maruti Bhange filed his reply vide letter dated February 17, 2014  Gokulbhai Patel Rakesh filed his reply vide letter dated February 5, 2014,  The wife of Mr. Kishore B Chauhan, replied to SEBI vide letter dated January 17, 2014 forwarding the death certificate of the Noticee.

3.6 All the 42 Noticees were given opportunity for personal hearing before me, on February 5, 2014. On the scheduled date, nine of the entities appeared and made submissions before me. Following are the details of the entities who appeared, a. One Mr. Vikas Bengani appeared and made submissions on behalf of 4 of the entities, viz. Mr. Amar Premchand Balmiki, Mr. Vinayak Maruti Bhange, Mr. Vikram Damodar Jalan and Mr. Jitendra Mehta.

b. Five of the Noticees, viz Mr. Gokulbhai Patel Rakesh, Mr. Samir Sureshchandra Shah, Mrs. Shital Samir Shah (represented by Mr. Samir Shah), Mr. Mayank Navnitbhai Gandhi and Mrs. Aditi M. Gandhi (represented by Mr. Mayank Navnitbhai Gandhi) also appeared for hearing and made submissions.

3.7 Another opportunity of hearing was granted to the remaining 33 entities on September 10, 2014. On the scheduled date, eight of the entities appeared and made submissions. The details are as under, a. Mr. Vikas Bengani appeared and made submissions on behalf of 5 entities viz. Mr. Rakesh Parasmal Singhvi, Mr. Dilip Sadanand Utekar, Mr. Vijay Kumar Bohra, Mr. Chandrakant Keru Shinde and Ms. Priyanka Dilip Utekar.

b. Mr. Arunkumar Chhaganlal Upadhyay appeared for himself and his wife viz. Mrs. Archana Arunkumar Upadhyay and made submissions.

c. Mr. Sachin Suresh Gaikwad appeared and made oral submissions.

d. Out of the remaining 25 entities, who did not appear for hearing, 19 Noticees did not file their replies to the SCNs.

3.8 The aforesaid 19 Noticees, who neither replied to the SCNs nor availed the opportunity of hearing granted to them on February 5, 2014 and September 10, 2014, it can be reasonably concluded that the said 19 Noticees have no submissions to make in respect of the SCNs issued to them.

The Noticees inter alia made the following submissions, i. Mr. Rakesh Parasmal Singhvi, Mr. Vikram Damodar Jalan, Mr. Vijay Kumar Bohra, Mr. Dilip Sadanad Utekar and Mr. Vinayak Maruti Bhanage inter alia made the following common submissions:  In a synchronized trade, quantity, time and price are important factors and in respect of the trades executed by the Noticee, the quantity did not match,  An order, which got executed into trades became normal trade with certain counter parties and at the same time it became synchronized trade with other counter parties,  Noticee has not executed any reversal of trades. All the trades were delivery based trades and shares have changed beneficial ownership,  Noticee's transaction was spread across hundreds of persons and there was no evidence to prove connection with all the 823 entities,  Crazy Infotech was a highly liquid scrip, and, in a screen based trading, the counter parties are anonymous,  Out of the 823 connected entities, 780 were let off by SEBI with an administrative warning and the Noticee has been issued SCN under Section 11, 11B of the SEBI Act, 1992,  SEBI has not provided investigation report and complete trade and order log relied by the investigation,  No material has been provided in respect of the connection /relation amongst the connected entities.

ii. In addition to the above, Mr. Vikram Damodar Jalan made the following submission:

 The trade log containing the complete details of synchronized trades were not provided (with the SCN) to him.

iii. Mr. Shriprakash Vinaykumar Sardesai and Mrs Jayshree Shripraksah Sardesai inter alia made the following common submissions:  Noticee trades in securities market to earn profit, and their trades were primarily short term trades/jobbing and arbitrage transactions,  It is denied that the trades were circular/reversal/synchronized and created artificial volume,  No trades matched with Mr. Prem Parikh with whom there is connection by way of a single bank transaction,  SEBI has not shown meeting of minds between the Noticee and counter parties,  SCN is vague and does not contain any material particulars,  Matching of trades is coincidental and not deliberate,  11B SCN has been issued to the Noticee, when 780 connected entities were given administrative warning.  SEBI has not provided investigation report and complete trade and order log relied by the investigation,  No material has been provided in respect of the connection /relation amongst the connected entities.

iv. Amar Premchand Balmiki inter alia made the following submissions:  Mere connection does not prove anything and no document has been provided to show the connection of the Noticee to any of the connected entities,  All trades were executed during market hours and within circuit filter limits of the scrip.

v. Pradeep Bhatt inter alia made the following submissions:  Traded only with 68 entities and clubbing with 823 entities is not correct,  Cross-examination must be given of the all the connected entities,  No cogent connection has been established with each and every entity,  Names of parties who have done off-market transfers have not been provided,  Off-market trades were insignificant and were used to meet market exigencies.

vi. Samir Bhai Shah and Shital S. Shah inter alia made the following common submissions  Lent the account to an operator and did not carry out any trading by themselves,  The Accounts were misused by the operator, viz. Mr. Para Chaplot.

vii. Jaya Talakshi Chheda inter alia made the following submissions:  Only instructed broker to procure shares on the basis of its fundamentals,  Not connected to any entities,  Only entered into a single transaction and did not benefit from the increse in the price of the scrip as the Noticee exited much before the rise in price.

viii. Alliance Intermediaries inter alia made the following submissions:  Only dealt in 88,820 shares of which 19,820 shares were purchased from market wherein counterparties were unknown,  69,000 shares purchased from one associate,  No connection with any of the parties.

ix. Mayank N. Gandhi and Aditi Mayank Gandhi inter alia made the following common submissions:  Lent the account to an operator on advice of Samir Shah and did not carry out any trading by themselves,  The Accounts were misused by the operator.

x. Mr. Chandrakant Shinde and Ms. Priyanka Dilip Utekar inter alia made the following submissions  The Noticees had executed only off-market trades,  The off market transactions are valid as per law,  SCN does not provide for the complete details of off market transactions by the Noticees,  Out of the 823 connected entities, 780 were let off by SEBI with an administrative warning and the Noticee has been issued SCN under Section 11, 11B of the SEBI Act, 1992,  SCNs do not specifically provide any details about the allegations. Allegations are general in nature.

xi. Mr. Sachin Gaikwad during the course of personal hearing submitted that:  Noticee is an illiterate and was working as peon in a Chartered Accountant firm, during the time of the alleged transactions,  He was made to sign some documents by his employer and all the transactions were done by his employer.

4. I have carefully examined the SCNs issued against each of the Noticees, their replies, written and oral submissions made before me during the hearing along with the documents submitted therewith. In the next few paragraphs, the charges vis-a'-vis each Noticee will be examined in the light of the findings of the investigation, replies filed by the Noticees, and submissions made before me during the personal hearing.

4.1 On analyzing the data given in the SCNs issued to the Noticees along with the Annexures therein, the following are observed, a. Noticees Nos. 1 to 37 are alleged to have indulged in reversal/circular and synchronized/structured trades in connivance with other connected entities. In addition to this, the Noticees Nos. 1 to 9 are alleged to have indulged in self trades on several days during the investigation period. The aforesaid activities alleged to have resulted in artificial volume and price rise in the scrip of Crazy Infotech, thereby violating the provisions of Regulation 3 (a), 4(1), 4(2)(a), (b), (e) & (g) of PFUTP Regulations, 2003.

b. Noticees Nos. 38 to 42 are alleged to have indulged in off market transactions in connivance with other connected entities including the aforesaid Noticees Nos. 1 to 37, who inturn offloaded the shares in the market. Thus, the Noticees Nos. 38 to 42 are alleged to have aided and abetted other connected entities, violating the provisions of Regulation 3 (a), 4(1), 4(2)(a) of PFUTP Regulations, 2003.

Connection/relation amongst the Connected Entities:

4.2 The SCNs allege that the group of 823 connected entities is inter-connected through common telephone number, address, off market transaction, bank transactions. The details of the connection amongst the Noticees and a few of the connected entities, are already provided in Annexure 3 of the respective SCNs.

Market and Off-market Transactions by Noticees-

4.3 The market and off market transactions entered into by the Noticees during the investigation period are detailed in the table below:

Noticees Period of Market/Off Sold/transferre Bought/received (No. transactions market d (No. of of shares) shares) Bhavesh Prakash March 24, 2006 to Pabari December 27, Market 3,30,647 10,30,678 2007 Off market 12,47,052 8,34,688 Hemant M Sheth March 24, 2006 to December 31, Market 3,80,102 5,84,795 2007 Off market 2,66,327 1,58,825 Anand Kalu Rapu January 29, 2007 Marathe to December 31, Market 7,48,687 18,45,931 2007 Off market 13,76,656 8,51,223 Rakesh Parasmal May 05, 2006 to Market December 31, 8,38,326 11,92,122 2007 Off market 3,41,945 - Rajesh Pravin August 18, 2006 to Bhanushali December 31, Market 1,28,983 2,47,264 2007 Off market 1,03,000 5,900 Prem Mohanlal July 10, 2006 to Parikh December 24, Market 1,86,790 2,73,888 2007 Off market 1,97,496 1,13,100 Shriprakash July 10, 2007 to Vinaykumar December 07, Market 2,60,594 4,71,856 Sardesai 2007 - - Off market Vikram Damodar May 30, 2006 to Market 10,25,256 13,30,856 Jalan March 09, 2007 3,05,352 - Off market Kishore B June 14, 2006 to Chauhan December 24, Market 1,87,748 2,55,406 2007 Off market 7,79,46 2,000 (from Hemant Sheth) Vinayak Maruti 2,77,445 3,81,810 Bhange Market 3,24,862 2,93,408 Off market Mayank Gandhi August 10, 2007 to 394825 485909 Aditi October 29, 2007 Market 90673 - Off market Mayank August 16, 2007 to 279086 265896 Navnitbhai November 13, Market Gandhi 2007, 5489 18679 Off market

Gokulbhai Patel October 18, 2007 253445 626337 Rakesh to December 31, Market 2007 11200 - Off market Alliance August 1, 2006 to 8,450 24,720 Intermediaries May 22, 2007 Market and Network Pvt. Ltd Off market 1,12,870 96,620 Amar Premchand November 6, 2006 3885 179722 Balmiki to April 12, 2007, Market 175837 63769 Off market Archana June 29, 2005 to 2200 7300 Arunkumar March 27, 2006 Market Upadhyay 113500 (both received and transferred) Off market Ankit Rajendra July 16, 2007 to 127441 155412 Sanchaniya December 28, Market 2007 2500 - Off market Arvind Mulraj December 13, 114285 1366 Udeshi 2006 to December Market 26, 2007 169965 234266 Off market Balasaheb July 12, 2006 to 48527 316914 Jagannath March 05, 2007 Market Kamble 255777 79181 Off market Bharat Shantilal December 29, 133899 237442 Thakkar 2005 to December Market 04, 2007 99600 - Off market Bhavarlal Sonaji September 12, 242118 239018 Malvi 2005 to July 05, Market 2006 0 3400 Off market Dilip Sadanand March 13, 2006 to 281463 634074 Utekar August 18, 2007 Market 353610 393422 Off market Dilipkumar May 25, 2005 to 468120 443020 Shantilal Mehta June 29, 2006 Market 3400 30000 Off market Dineshkumar August 11, 2006 to 13565 94095 Ramchandra December 26, Market Pandey 2007 78644 - Off market Jaya Talakshi ----- - - Chheda Market - - Off market Jayshree 122078 244358 Shriprakash June 27, 2007 to Market Sardesai December 07, - - 2007 Off market

Jitendra Mehta August 1, 2006 to 76903 115590 December 03, Market 2007 38625 - Off market Kirit Shantilal 60062 193577 Gandhi October 12, 2006 Market to July 03, 2007 133500 - Off market Pradeep Bhat April 18, 2007 to 8903 90545 December 31, Market 2007 83450 1808 Off market Pravinbhai Shah September 02, 277469 506188 (DNG Mercantile 2005 to December Market Pvt. Ltd.) 17, 2007 227219 - Off market Rikesh R Shah March 05, 2007 to 102625 370660 October 29, 2007 Market 266035 - Off market Samir Shah Shital March 28, 2007 to 426408 707967 December 28, Market 2007 269038 5100 Off market Samir December 21, 20378 108139 Sureshchandra 2006 to August 1, Market Shah and Samir 2007 87747 - Sureshchandra Off market Shah, HUF Santosh Abhayraj October 30, 2006 10654 113944 Shukla to December 11, Market 2007 93956 - Off market Santosh Kondu September 11, 33954 65694 Gharat 2006 to May 18, Market 2007 81629 50000 Off market Shyam Sunder July 19, 2006 to 7500 80383 Bohra December 31, Market 2007 75133 - Off market Vijay Kumar July 18, 2006 to Bohra December 28, Market 40776 126619 2007 - Off market 89753 Arunkumar October 06, 2005 Chhaganlal to February 13, Off market 167500 161500 Upadhyay 2007 Indrapratap April 10, 2007 to Gajraj Singh November 29, Off market 1243649 1244749 2007

Sachin Suresh July 9, 2007 to Gaikawad December 31, Off market 1390950 1403325 2007 Chandrakant Keru Shinde Off market 0 116633 Priyanka Dilip November 26 and Utekar 30, 2006 Off market 89742 89742

4.4 In view of the connection alleged against the entities, the SCNs allege that the trades executed by the connected entities including the Noticees, were mainly in the manner and pattern of i) Reversal Trades and ii) Synchronized/Structured Trades, in collusion with each other. It is also alleged that five of the entities had indulged in off market transactions aiding and abetting other connected entities including the Noticees. All of these transactions alleged to have resulted in the artificial volume and price rise in the scrip of Crazy Infotech.

The allegations are dealt under the following paragraphs.

Reversal Trades by the Noticees-

4.5 The SCNs allege that the Noticees Nos. 1 to 37 have indulged in reversal trades with the connected entities. In this regard, I have perused the SCNs issued against each of the Noticees. A few instances of trades executed by one of the Noticees, viz. Bhavesh Pabari, as alleged in the SCN as reversed trades, are being detailed below, as an illustration of the instances of reversal trades:

4.5.1 The SCN alleges that Bhavesh Pabari executed reversal trades in both market and off-market, with connected entities. The reversed trades entered into by Bhavesh Pabari (in market), with the connected entities, as observed from the SCN are reproduced as under;

Bought by Bhavesh Sold by Bhavesh Pabari Pabari Counterparty Name Market Market

Hemant M Sheth 23550 40500 Prem Mohanlal Parikh 12750 20185 Rajesh Pravin Bhanushali 7271 6721

Samir Shah Shital 15462 7868 Bharat Shantilal Thakkar 11681 11396 Anand Kalu Rapu Marathe 1005 22234 Ankit Rajendra Sanchaniya 8471 17450 Gokulbhai Patel Rakesh 5000 5000 Kishore B Chauhan 9055 20990 M Gandhi Aditi 5030 19760 Mala Hemant Sheth 0 4144 Rakesh Parasmal Singhvi 3538 13084 Vijay Kumar Bohra 10000 2386 Vikram Damodar Jalan 6642 20959

4.5.2 In order to examine the manner in which the reversals were executed by the Noticee, the Annexure -6 of the SCN (individual trade log data of Bhavesh Pabari) containing the entire trades executed by Bhavesh Pabari during the investigation period has been examined.

4.5.3 From the said Annexure, it is observed that on April 28, 2006 Bhavesh Pabari bought 9000 shares from Hemant Sheth and on August 24, 2006 Bhavesh Pabari sold 1500 shares back to Hemant Sheth. It is noted that out of the 9000 shares bought by Bhavesh Pabari from Hemant Sheth only 1500 shares were sold back to Hemant Shah. As regards, the date of the alleged transactions, it is noted that the buy transaction was on April, 2006, and the corresponding alleged reversal by sale was on August 2006.

4.5.4 Among several instances of alleged reversal of trades, such buy trades being reversed by sale trades or vice versa in between Bhavesh Pabari and Hemant Sheth were carried out after a large gap of time, in some cases more than 3 months. Similar instances of reversal trades have also been noticed in respect of the transactions entered into by Bhavesh Pabari with the connected entities mentioned in the above table. In view of this, it is difficult to consider such trades being reversed after a huge gap of time, as reversal of trades.

4.5.5 Similar instances of trades are noted in respect of the trades executed by other Noticees also. Even though the table shown in the respective SCNs in respect of reversed trades indicate that connected entities including the Noticees are seen in both buy and sell side during the investigation period, the SCNs did not identify and provide specific instances of the alleged reversals between the connected entities which could be treated as exact reversals.

4.5.6 It is also observed that the SCNs issued to the Noticees refer to certain factors common to some of the Noticees. SCNs, however do not specifically explain the connection/relation amongst all the Noticees and the counterparties of their trades, which are alleged to be reversed and synchronized. Moreover, the connection amongst certain Noticees alone cannot be a decisive factor to determine the collusion amongst all the 823 connected entities including the Noticees herein as the SCNs do not contain specific data indicating the specific role/contribution of the Noticees to the volume and price generated through the alleged reversals/circular and synchronized trades in the scrip. It is also relevant to note that out of these 823 connected entities, 780 entities were issued administrative warning and these 780 entities were counter parties to several of the alleged trades executed by the Noticees.

Synchronized Trades

4.6 The SCNs allege that the Noticees Nos. 1 to 37 had indulged in synchronized trades in connivance with other connected entities resulting in price rise and volume in the scrip of Crazy Infotech. The details/instances of synchronized trades executed by Noticees are given in the Annexure – 7 of the respective SCNs issued to them.

4.6.1 From the said Annexure, it is noted that the Noticees had indulged in trades wherein the difference in time between buy and sell orders was within a minute and the difference between buy order price and sell order price was virtually zero. From the Annexure -7 of the respective SCNs, containing the details of the synchronized trades, I find that aforesaid pattern of synchronized trades has been observed in respect of the trades executed by all the Noticees. It is, however observed that the counter parties in a majority of synchronized trades executed by the Noticees are from the 780 connected entities against whom SEBI had issued an administrative warning and the precise connection amongst all the connected entities have not been satisfactorily explained in the SCNs. The SCNs are silent regarding the specific contribution of the synchronized trades of each of the Noticees, to the total volume generated and also to the price rise in the scrip of Crazy Infotech during the investigation period.

Price Manipulation by Noticees-

4.7 The SCNs issued to the Noticees allege that on the basis of analysis of Last Traded Price (LTP), the trades of Noticees had impacted/led to rise in price in the scrip of Crazy Infotech. In this regard, it is pertinent to note that rise in price of the scrip is alleged as a result of the transactions alleged in the SCN as reversed and synchronized trades. However as mentioned earlier, in the absence of clear data in the Annexure to the SCNs, the nature of trades executed by the Noticees cannot be conclusively determined as synchronized/reversed trades with pre-meditated intention to artificially inflate the price and volume in the scrip. Further, the counter parties to many transactions, are from the 780 entities against whom SEBI has already issued an administrative warning.

Off-market Transactions by Noticees No. 38 to 42

4.8 Five Noticees (Nos. 38 to 42), viz. Arunkumar Chhaganlal Upadhyay, Indrapratap Gajraj Singh, Sachin Suresh Gaikawad,Chandrakant Keru Shinde and Priyanka Dilip Utekar were alleged to have indulged in offmarket transactions with other connected entities including the Noticees No. 1 to 37, who inturn offloaded the shares in the market. By doing so, the Noticees Nos. 38 to 42 were alleged to have aided and abetted the other connected entities including the Noticees No. 1 to 37 to artificially inflate the price and volume in the scrip during the investigation period.

4.8.1 The details of the off market transactions executed by them are given in the table at Paragraph No.4.3 above. As has been discussed in the forgoing paragraphs that the reversed and synchronized trades, alleged to have been executed by the other Noticees (i.e the Noticees Nos. 1 to 37), have not been conclusively proved. In view of this, I am unable to hold that the off market transactions entered into by the Noticees Nos. 38 to 42 were for aiding and abetting other connected entities in creating artificial volume and price rise in the scrip during the investigation period.

5. To sum up, the trades of the Noticees Nos. 1 to 42, as per the SCNs, largely, fall under the category of self trades, synchronized, reversal/circular trades and off market transactions. As has been observed earlier, while analyzing the synchronized, reversal/circular trades and off market transactions executed by the Noticees, it is observed that the annexures to the SCNs contain details of the transactions executed by the Noticees during the entire investigation period. The SCNs, however do not contain sufficient details specifying and delineating the transactions which were alleged to be synchronized and reversed vis a vis the Noticees. The specific instances of reversed and synchronized trades executed by the Noticees with the entities alleged to have been connected with each other are difficult to be isolated from the said trade logs annexed with the respective SCNs, as the trades are spread across the entire investigation period and the counterparties to their trades include the 823 connected entities and also some non-connected entities. In this regard, it is relevant to note that the common contention put forth by the Noticees, who have replied to the SCNs was that, out of the 823 entities alleged to have been connected to each other and have traded concertedly in the scrip during the investigation period (in both market and off market, creating artificial volume and price rise), 780 entities were let off by SEBI with an administrative warning and the Noticees were issued SCNs, alleging price and volume manipulation in the scrip of Crazy Infotech. In this regard, it is observed that eventhough such a course of action was adopted by SEBI in order to filter data and identify the main entities involved in the alleged manipulation, the fact that the counter parties to many of the trades (alleged to be synchronized and reversed trades) executed by the Noticees include entities against whom administrative warning had been issued by SEBI, cannot be ignored.

5.1 The material provided in the SCNs narrates instances of unusual trading pattern amongst the 823 connected entities including the Noticees casting doubt on the intent of the Noticees, in respect of the impugned transactions. However, considering the large number of transactions involving many entities, spread over many days during the investigation period, coupled with the fact that 780 of the 823 connected entities have been issued administrative warning by SEBI, I am of the view that, for the sake of uniformity, Noticees Nos. 1 to 42 also be afforded the same treatment.

5.2 In view of the discussions above, I am constrained to observe that a warning would be reasonable for the Noticees in respect of the reversed/circular, synchronized trades and the off market transactions alleged to have executed by them, in the scrip of Crazy Infotech.

Self Trades by the Noticees

6. In addition to the reversal/circular and synchronized trades, Noticees No. 1 to 9 were also found to have indulged in self trades for several days during the investigation period, thereby creating artificial volume and price rise in the scrip of Crazy Infotech. Following are the said nine Noticees, who are alleged to have indulged in self trades:

1. Mr. Bhavesh Prakash Pabari (Bhavesh Pabari) 2. Mr. Hemant M Sheth (Hemant Sheth) 3. Mr. Anand Kalu Rapu Marathe (Anand Marathe) 4. Mr. Rakesh Parasmal Singhvi (Rakesh Singhvi) 5. Mr. Rajesh Pravin Bhanushali (Rajesh Bhanushali) 6. Mr. Prem Mohanlal Parikh (Prem Parikh) 7. Mr. Shriprakash Vinaykumar Sardesai (Shriprakash Sardesai) 8. Mr. Vikram Damodar Jalan (Vikram Jalan) 9. Mr. Kishore B Chauhan (Kishore Chauhan) The SCNs allege that the Noticees had indulged in self trades (i.e the Noticees were on both buy side and sell side of the same transaction). The details of the self trades executed by the Noticees No. 1 to 9, as observed from the Annexures to their respective SCNs, are as under:

Self Trades by Bhavesh Pabari i. The Noticee is involved in self trades for 19,055 shares in the market. The details are as under:

Trade Date Name of the buyer Qty Price Name of the seller 29-Aug-06 Bhavesh Prakash Pabari 2500 58.45 Bhavesh Prakash Pabari 23-Nov-06 Bhavesh Prakash Pabari 2500 104.50 Bhavesh Prakash Pabari 23-Nov-06 Bhavesh Prakash Pabari 1000 103.90 Bhavesh Prakash Pabari 4-Dec-06 Bhavesh Prakash Pabari 2000 98.00 Bhavesh Prakash Pabari 4-Dec-06 Bhavesh Prakash Pabari 500 98.00 Bhavesh Prakash Pabari 4-Dec-06 Bhavesh Prakash Pabari 100 98.00 Bhavesh Prakash Pabari 14-Dec-06 Bhavesh Prakash Pabari 1000 72.50 Bhavesh Prakash Pabari 28-Aug-07 Bhavesh Prakash Pabari 600 197.90 Bhavesh Prakash Pabari 28-Aug-07 Bhavesh Prakash Pabari 50 197.90 Bhavesh Prakash Pabari 4-Sep-07 Bhavesh Prakash Pabari 150 200.00 Bhavesh Prakash Pabari 4-Sep-07 Bhavesh Prakash Pabari 100 202.00 Bhavesh Prakash Pabari 5-Sep-07 Bhavesh Prakash Pabari 10 200.20 Bhavesh Prakash Pabari 12-Nov-07 Bhavesh Prakash Pabari 3000 203 Bhavesh Prakash Pabari 15-Nov-07 Bhavesh Prakash Pabari 2000 207.9 Bhavesh Prakash Pabari 16-Nov-07 Bhavesh Prakash Pabari 445 207.9 Bhavesh Prakash Pabari 27-Dec-07 Bhavesh Prakash Pabari 600 235 Bhavesh Prakash Pabari 27-Dec-07 Bhavesh Prakash Pabari 2500 239 Bhavesh Prakash Pabari

Self Trades by Hemant Sheth ii. Hemant Sheth was involved in self trades for 87,555 shares during the period August 2006 to December 2007. The details/instances of self trade executed by him are given under:

Name of the seller Trade Date Name of the buyer Qty Price 24-Aug-06 Hemant Sheth 1500 57.30 Hemant Sheth 30-Aug-06 Hemant Sheth 950 58.95 Hemant Sheth 1-Sep-06 Hemant Sheth 2900 55.45 Hemant Sheth 1-Sep-06 Hemant Sheth 100 55.45 Hemant Sheth 4-Sep-06 Hemant Sheth 12000 52.55 Hemant Sheth 4-Sep-06 Hemant Sheth 3000 52.25 Hemant Sheth 7-Sep-06 Hemant Sheth 3500 46.50 Hemant Sheth 8-Sep-06 Hemant Sheth 7000 47.70 Hemant Sheth 11-Oct-06 Hemant Sheth 1205 69.45 Hemant Sheth 7-Nov-07 Hemant Sheth 6000 199.5 Hemant Sheth 7-Nov-07 Hemant Sheth 500 202 Hemant Sheth 12-Dec-07 Hemant Sheth 10000 221.5 Hemant Sheth 18-Dec-07 Hemant Sheth 4400 218 Hemant Sheth 20-Dec-07 Hemant Sheth 11000 229 Hemant Sheth 20-Dec-07 Hemant Sheth 500 230 Hemant Sheth 20-Dec-07 Hemant Sheth 6500 229 Hemant Sheth 24-Dec-07 Hemant Sheth 6500 230.1 Hemant Sheth 27-Dec-07 Hemant Sheth 10000 239 Hemant Sheth

Self Trades by Anand Marathe iii. The Noticee is involved in self trades for 7,982 shares on several dates during the period April 2007 to November 2007. The details of the same are as under:

Name of the Trade Date Name of the buyer Qty Price seller 30-Apr-07 Anand Marathe 100 83.00 Anand Marathe 11-May-07 Anand Marathe 115 93.35 Anand Marathe 17-May-07 Anand Marathe 500 100.00 Anand Marathe 17-May-07 Anand Marathe 500 100.00 Anand Marathe 18-May-07 Anand Marathe 15 100.10 Anand Marathe 11-Jun-07 Anand Marathe 30 108.05 Anand Marathe 5-Jul-07 Anand Marathe 300 140.10 Anand Marathe 13-Jul-07 Anand Marathe 100 170.10 Anand Marathe 16-Jul-07 Anand Marathe 799 180.60 Anand Marathe 31-Jul-07 Anand Marathe 21 193.05 Anand Marathe 24-Sep-07 Anand Marathe 35 227.75 Anand Marathe 30-Nov-07 Anand Marathe 1467 204 Anand Marathe 30-Nov-07 Anand Marathe 4000 202.5 Anand Marathe

Self Trades by Rakesh Singhvi iv. Rajesh Sanghvi has indulged in self trades for 4,698 shares on several days during the period July 2006 to July 2007,

Name of the Name of the Trade Date buyer Qty Price seller 27-Jul-06 Rakesh Sanghivi 15 35.70 Rakesh Sanghivi 27-Jul-06 Rakesh Sanghivi 5 35.25 Rakesh Sanghivi 27-Jul-06 Rakesh Sanghivi 10 35.05 Rakesh Sanghivi 13-Oct-06 Rakesh Sanghivi 150 74.50 Rakesh Sanghivi 31-Oct-06 Rakesh Sanghivi 104 110.50 Rakesh Sanghivi 31-Oct-06 Rakesh Sanghivi 96 110.50 Rakesh Sanghivi 20-Dec-06 Rakesh Sanghivi 2 72.05 Rakesh Sanghivi 5-Jan-07 Rakesh Sanghivi 50 90.95 Rakesh Sanghivi 2-Feb-07 Rakesh Sanghivi 100 87.65 Rakesh Sanghivi 8-Mar-07 Rakesh Sanghivi 55 104.90 Rakesh Sanghivi 8-Mar-07 Rakesh Sanghivi 45 104.90 Rakesh Sanghivi 8-Mar-07 Rakesh Sanghivi 50 96.05 Rakesh Sanghivi 26-Mar-07 Rakesh Sanghivi 45 84.10 Rakesh Sanghivi 29-Mar-07 Rakesh Sanghivi 30 87.00 Rakesh Sanghivi 4-Apr-07 Rakesh Sanghivi 500 75.50 Rakesh Sanghivi 28-Jun-07 Rakesh Sanghivi 295 125.50 Rakesh Sanghivi 29-Jun-07 Rakesh Sanghivi 50 130.10 Rakesh Sanghivi 29-Jun-07 Rakesh Sanghivi 250 129.60 Rakesh Sanghivi 17-Jul-07 Rakesh Sanghivi 298 182.00 Rakesh Sanghivi 17-Jul-07 Rakesh Sanghivi 400 182.50 Rakesh Sanghivi Rakesh Sanghivi 17-Jul-07 9 181.70 Rakesh Sanghivi 17-Jul-07 Rakesh Sanghivi 9 182.00 Rakesh Sanghivi 17-Jul-07 Rakesh Sanghivi 1 182.25 Rakesh Sanghivi 17-Jul-07 Rakesh Sanghivi 299 182.00 Rakesh Sanghivi 19-Jul-07 Rakesh Sanghivi 1200 183.00 Rakesh Sanghivi 20-Jul-07 Rakesh Sanghivi 98 188.95 Rakesh Sanghivi 20-Jul-07 Rakesh Sanghivi 332 188.50 Rakesh Sanghivi 27-Jul-07 Rakesh Sanghivi 200 187.50 Rakesh Sanghivi v. It is observed that Rakesh Singhvi has not given any explanation in respect of the aforesaid instances of self trades executed by him during the investigation period, either in his reply dated February 17, 2014 nor during the personal hearing granted to him on September 10, 2014.

Self Trades by Rajesh Bhanushali vi. Rajesh Bhanushali was involved in self trades for 7,578 shares on two different dates. The details of self trades executed by the Noticee are given under:

Trade Date Name of the buyer Qty Price Name of the seller 31-Aug-07 Rajesh Pravin Bhanushali 483 198.50 Rajesh Pravin Bhanushali 31-Aug-07 Rajesh Pravin Bhanushali 50 198.90 Rajesh Pravin Bhanushali 31-Aug-07 Rajesh Pravin Bhanushali 2000 199.50 Rajesh Pravin Bhanushali 31-Aug-07 Rajesh Pravin Bhanushali 34 199.50 Rajesh Pravin Bhanushali 31-Aug-07 Rajesh Pravin Bhanushali 250 199.75 Rajesh Pravin Bhanushali 31-Aug-07 Rajesh Pravin Bhanushali 54 199.50 Rajesh Pravin Bhanushali

31-Aug-07 Rajesh Pravin Bhanushali 650 200.00 Rajesh Pravin Bhanushali 31-Aug-07 Rajesh Pravin Bhanushali 10 200.60 Rajesh Pravin Bhanushali 31-Aug-07 Rajesh Pravin Bhanushali 425 200.50 Rajesh Pravin Bhanushali 31-Aug-07 Rajesh Pravin Bhanushali 900 200.00 Rajesh Pravin Bhanushali 31-Aug-07 Rajesh Pravin Bhanushali 25 200.00 Rajesh Pravin Bhanushali 31-Aug-07 Rajesh Pravin Bhanushali 5 200.50 Rajesh Pravin Bhanushali 31-Aug-07 Rajesh Pravin Bhanushali 500 201.50 Rajesh Pravin Bhanushali 31-Aug-07 Rajesh Pravin Bhanushali 5 201.70 Rajesh Pravin Bhanushali 31-Aug-07 Rajesh Pravin Bhanushali 25 200.00 Rajesh Pravin Bhanushali 31-Aug-07 Rajesh Pravin Bhanushali 495 199.00 Rajesh Pravin Bhanushali 3-Sep-07 Rajesh Pravin Bhanushali 150 199.60 Rajesh Pravin Bhanushali 3-Sep-07 Rajesh Pravin Bhanushali 250 199.50 Rajesh Pravin Bhanushali 3-Sep-07 Rajesh Pravin Bhanushali 4 199.35 Rajesh Pravin Bhanushali 3-Sep-07 Rajesh Pravin Bhanushali 346 199.35 Rajesh Pravin Bhanushali 3-Sep-07 Rajesh Pravin Bhanushali 300 199.50 Rajesh Pravin Bhanushali 3-Sep-07 Rajesh Pravin Bhanushali 75 199.50 Rajesh Pravin Bhanushali 5-Sep-07 Rajesh Pravin Bhanushali 250 201.35 Rajesh Pravin Bhanushali 6-Sep-07 Rajesh Pravin Bhanushali 292 198.50 Rajesh Pravin Bhanushali

Self Trades by Prem Parikh vii. Prem Parikh was involved in self trades in market for 5200 shares on six different dates. The details/instances of self trades executed are given under:

Market (M)/Off- Name of the Name of the seller market (O) Trade Date buyer Qty Price M 22-Dec-06 Prem Mohanlal Parikh 500 78.90 Prem Mohanlal Parikh M 2-Jan-07 Prem Mohanlal Parikh 325 91.00 Prem Mohanlal Parikh M 2-Jan-07 Prem Mohanlal Parikh 200 91.00 Prem Mohanlal Parikh M 2-Jan-07 Prem Mohanlal Parikh 475 91.00 Prem Mohanlal Parikh M 2-Jan-07 Prem Mohanlal Parikh 1000 91.30 Prem Mohanlal Parikh M 2-Jan-07 Prem Mohanlal Parikh 100 91.25 Prem Mohanlal Parikh M 2-Jan-07 Prem Mohanlal Parikh 250 91.25 Prem Mohanlal Parikh M 2-Jan-07 Prem Mohanlal Parikh 50 91.25 Prem Mohanlal Parikh M 23-Nov-07 Prem Mohanlal Parikh 2000 205 Prem Mohanlal Parikh M 23-Nov-07 Prem Mohanlal Parikh 300 205 Prem Mohanlal Parikh

Self trades by Shriprakash Sardesai viii. The Noticee is involved in self trades for 30,300 shares (on market)on 3 three different dates (July 17, 2007, October 10, 2007 and November 6, 2007). The details of the self trades by the Noticee in market are as under:

Market (M)/Off- Name of the seller market (O) Trade Date Name of the buyer Qty Price M 17-Jul-07 Shriprakash Sardesai 15000 182.05 Shriprakash Sardesai M 10-Oct-07 Shriprakash Sardesai 10000 225 Shriprakash Sardesai M 6-Nov-07 Shriprakash Sardesai 5300 200.75 Shriprakash Sardesai ix. Shriprakash Sardesai in his reply dated February 4, 2014 stated that these trades are coincidental and not deliberate. It is observed from the trade log data provided to the Noticee that on July 17, 2007 he had placed both buy and sell orders within a time difference of 5 seconds through two different stock brokers for the same quantity and at the same price. On October 10, 2007 he had placed only one buy order and one sell order within a time difference of 10 seconds through two different stock brokers for the same quantity and at the same price. Similarly, on November 6, 2007 the orders were placed within a time difference of 53 seconds in a synchronized manner. In view of this, the contention put forth by the Noticee that the matching of orders were coincidental cannot be accepted.

Self Trades by Vikram Jalan x. The Noticee is involved in self trades for 27,343 shares during the period July 2006 to November 2006. A few instances of self trades executed by the Noticee are as under:

Trade Date Name of the buyer Qty Price Name of the seller 19-Jul-06 Vikram Jalan 10 27.80 Vikram Jalan 19-Jul-06 Vikram Jalan 5 27.40 Vikram Jalan 19-Jul-06 Vikram Jalan 5 27.50 Vikram Jalan 20-Jul-06 Vikram Jalan 5 28.95 Vikram Jalan 24-Jul-06 Vikram Jalan 3 31.80 Vikram Jalan 24-Jul-06 Vikram Jalan 58 32.00 Vikram Jalan 26-Jul-06 Vikram Jalan 25 33.50 Vikram Jalan 26-Jul-06 Vikram Jalan 39 33.55 Vikram Jalan 31-Jul-06 Vikram Jalan 202 38.75 Vikram Jalan 1-Aug-06 Vikram Jalan 2 39.50 Vikram Jalan 1-Aug-06 Vikram Jalan 75 41.00 Vikram Jalan 1-Aug-06 Vikram Jalan 1750 41.10 Vikram Jalan 2-Aug-06 Vikram Jalan 50 42.20 Vikram Jalan 2-Aug-06 Vikram Jalan 10 42.45 Vikram Jalan 2-Aug-06 Vikram Jalan 70 42.45 Vikram Jalan 3-Aug-06 Vikram Jalan 100 43.00 Vikram Jalan 3-Aug-06 Vikram Jalan 993 44.85 Vikram Jalan 3-Aug-06 Vikram Jalan 1 44.80 Vikram Jalan

Self Trades by Kishore Chauhan xi. Kishore Chauhan was involved in self trades for totally 3,150 shares on two days. The details/instances of self trade executed by him are given under:

Trade Date Name of the buyer Qty Price Name of the seller 13-Nov-07 Kishor Balubhai Chauhan 700 214 Kishor Balubhai Chauhan 13-Nov-07 Kishor Balubhai Chauhan 100 214 Kishor Balubhai Chauhan 13-Nov-07 Kishor Balubhai Chauhan 850 204.9 Kishor Balubhai Chauhan 28-Nov-07 Kishor Balubhai Chauhan 500 200.5 Kishor Balubhai Chauhan 28-Nov-07 Kishor Balubhai Chauhan 100 200.5 Kishor Balubhai Chauhan 28-Nov-07 Kishor Balubhai Chauhan 100 200.5 Kishor Balubhai Chauhan 28-Nov-07 Kishor Balubhai Chauhan 100 200.5 Kishor Balubhai Chauhan 28-Nov-07 Kishor Balubhai Chauhan 100 200.5 Kishor Balubhai Chauhan 28-Nov-07 Kishor Balubhai Chauhan 100 200.5 Kishor Balubhai Chauhan 28-Nov-07 Kishor Balubhai Chauhan 100 200.5 Kishor Balubhai Chauhan 28-Nov-07 Kishor Balubhai Chauhan 100 200.5 Kishor Balubhai Chauhan 28-Nov-07 Kishor Balubhai Chauhan 100 200.5 Kishor Balubhai Chauhan 28-Nov-07 Kishor Balubhai Chauhan 100 200.5 Kishor Balubhai Chauhan 28-Nov-07 Kishor Balubhai Chauhan 100 200.5 Kishor Balubhai Chauhan

6.1 From the aforesaid tables, it is evident that all the nine Noticees had indulged in self trades on several days during the investigation period. The instances of self trades entered into by the said Noticees clearly indicate that the trades were executed by them with the fraudulent and manipulative intention to create artificial volume in the scrip of Crazy Infotech during the investigation period. As no proper explanation has been given by the Noticees and in view of the facts and circumstances of the case, it can be concluded that such self trades were indeed executed to manipulate the market.

6.2 Self trades perse are illegal and hence fictitious. The Hon'ble Securities Appellate Tribunal (SAT) has held in several cases that self trades call for punitive action since they are illegal by their very nature. Following are a few cases in respect of self trades decided by SAT:

 In Appeal No. 85/2011- M/s Marwadi Shares and Finance Limited Vs. SEBI 2012 Indlaw SAT 114, SAT held, "......Self Trades by their very nature, are fictitious. ................Such transactions executed for and on behalf of the clients will fall within the definition of suspicious transactions having no economic rationale or bona fide purpose..."

 In M/s. Jayantilal Khandwala & Sons Pvt. Ltd. vs. Securities and Exchange Board of India 2010 Indlaw MUM 521 (Appeal no. 24 of 2011 decided on June 8, 2011) SAT observed:

"One cannot buy and sell shares from himself. Such transactions are obviously fictitious and meant only to create false volumes on the trading screen of the exchange".

 In H.J. Securities Pvt. Ltd. vs. SEBI (Appeal No. 76 of 2012 decided on 11.05.2012), Tribunal held that appellant may adopt any business model, but has to ensure that whatever business model is adopted, is in conformity with regulatory framework and Appellant was held guilty of violative of PFUTP Regulations.

6.3 It is also relevant to note that the Hon'ble Supreme Court recently dismissed an appeal (Civil Appeal No. 11899 of 2014) filed by Angel broking Pvt. Ltd., challenging SAT Order dated October 1, 2014 in Appeal No. 46 of 2014, Angel broking Pvt. Ltd. Vs. SEBI, wherein the entity was found guilty of having executed self trades at the behest of their clients in the scrip of Sterling Green Woods. In the SAT appeal, the entity had taken the plea that the self trades were due to jobbing/arbitrage nature of their business. The Hon'ble SAT, while rejecting the plea, quoted their own judgment in H.J. Securities Pvt. Ltd. vs. SEBI (mentioned in the preceding paragraph) that the appellant may adopt any business model, but has to ensure that whatever business model is adopted, it is in conformity with regulatory framework.

6.4 As has been observed earlier, self trades do not result in change in beneficial ownership of shares and are per se illegal. Indulging in self trades can only be for the purpose of artificially increasing the volume of trading in the scrip.In the instant case, in addition to the reversal/synchronized/off-market transactions, the Noticees Nos. 1 to 9 have also been charged in their respective SCNs as having indulged in self trades in the shares of Crazy Infotech on several occasions. It is observed that the Noticees, viz. Rakesh Singhvi, Shriprakash Sardesai and Vikram Jalan, failed to give any satisfactory explanation for indulging in self trades, during the course of investigation or in their replies filed before SEBI or during the course of personal hearing.

7. Taking in view the facts and circumstances as explained above, I find that the said charge of self trades has been conclusively proved against the Noticees No. 1 to 9 and such fraudulent transactions undertaken by the Noticees Nos. 1 to 9, in the scrip of Crazy Infotech by entering into self trades with no intention of transfer of beneficial ownership in the scrip per se are illegal and are in violation of Regulation 3 (a), 4(1), 4(2)(a), & (g) of PFUTP Regulations, 2003.

7.1 It is observed from the records that one of the above 9 Noticees, Mr. Kishore B Chauhan had expired on May 29, 2013. The death certificate of the Noticee was forwarded to SEBI by his wife, vide letter dated January 17, 2014. In view of this, the proceedings in respect of Mr. Kishore B Chauhan stand abated.

8. The proceedings in the instant matter had commenced pursuant to the issuance of separate SCNs dated November 7, 2012 to all the 42 connected entities. Thereafter, an opportunity of personal hearing was granted to all the 42 entities on various dates i.e February 5, 2014 and September 10, 2014. Having regard to the fact that all the 9 Noticees were charged with manipulation of price and volume in the scrip by executing reversed, synchronized trades amongst themselves and self trades, during the investigation period, a consolidated view in the instant proceedings was possible only on completion/conclusion of hearings in respect of all the Noticees who had indulged in reversed/synchronized and self trades during the investigation period and thereafter, examination and consideration of each of their replies (wherever made) to the SCNs issued to them.

Order-

9. In view of the forgoing, I, in exercise of the powers conferred upon me by virtue of Section 19 read with Section 11 and 11B of the SEBI Act, 1992 and Regulation 11 of the PFUTP Regulations, 2003, hereby- i. warn Noticees Nos. 1 to 8 and Noticees Nos. 10 to 42 to be cautious in their future dealings and exercise due care and diligence in the conduct of their dealings as participants in the securities market (for the reasons mentioned at Paragraph No. 5.1above), ii. restrain Noticees No. 1 to 8, Mr. Bhavesh Prakash Pabari (PAN: AKGPP8679N), Mr. Hemant M Sheth (PAN: ANOPS8607E), Mr. Anand Kalu Rapu Marathe (PAN: AKWPM0699M), Mr. Rakesh Parasmal Singhvi (PAN: BCQPS0499L), Mr. Rajesh Pravin Bhanushali (PAN: AABPB2744H),

Mr.Prem Mohanlal Parikh (PAN: ALHPP3489N), Mr. Shriprakash Vinaykumar Sardesai (PAN:AMYPS0171J) and Mr. Vikram Damodar Jalan (PAN: AGTPJ5257D) from accessing the securities market and further prohibit them from buying, selling or dealing in securities market, directly or indirectly, for a period of two years, iii. dispose of the SCN dated November 7, 2012 issued against Noticee No. 9, Mr. Kishore B. Chauhan (PAN: AFPPC9703G) without any directions (in view of the reason mentioned at Paragraph No. 7.1, above),

10. This Order shall come into force with immediate effect.

11. The copy of the said Order shall be forwarded to the concerned Stock Exchanges and Depositories.

Place: Mumbai S. RAMAN Date: February 10, 2015 WHOLE TIME MEMBER SECURITIES AND EXCHANGE BOARD OF INDIA