Order under sections 11(1), 11(4)(d) and 11B of the SEBI Act, 1992 in the matter of trading by certain entities in the scrip of Polytex India Ltd.

WTM/PS/41/IVD/AUG/2015 SECURITIES AND EXCHANGE BOARD OF INDIA ORDER Under Sections 11(1), 11(4) and 11B of the Securities and Exchange Board of India Act, 1992 in the matter of Polytex India Limited In respect of - S. No. Name Permanent Account Number 1 Mr. Jigar Praful Ghogari ASFPG8598L 2 Mr. Kiran Bhiku Bhanaes AQUPB0853G 3 Mr. Janak Chimanlal Dave AEPPD9110D 4 Mr. Dilipkumar Pukhraj Jain AACPJ5643C 5 Mr. Bhupesh Harischandra Rathod AACPR3785K 6 Mr. Kishan Balaram Shigvan BAWPS1264D 7 Mr. Kiran Madhusudan Sheth ALJPS1874Q 8 Mr. Jatin Shah AACPS6128D 9 Shree Shagun Financial Services ABTFS0353F 10 Oliwonders Financial Services Pvt. Ltd. AABCO2030J 11 Neevan Capital Markets Pvt. Ltd. AACCN7650G 12 Mr. Bhavesh Pabari AKGPP8679N 13 Mr. Hemant Sheth ANOPS8607E 14 Mr. Prem Parikh ALHPP3489N 15 Mr. Ankit Sanchaniya BLNPS3316L 16 Mr. Jinal Apurval Rawal ATHPR5041C

1. Securities and Exchange Board of India (hereinafter referred to as ‘SEBI’), undertook a preliminary examination in the trading in the shares of Polytex India Limited (“PIL” or “Polytex”) {for the period – 13.04.2012 to 17.12.2012}, KGN Enterprises Limited (“KGN”) {for period – 27.12.2011 to 17.12.2012} and Gemstone Investments Limited (“Gemstone”) {for the period – 18.04.2012 to 17.12.2012}. Pursuant to such examination, SEBI vide an ad interim ex-parte Order dated May 10, 2013 (“the interim order”), restrained certain persons/entities, namely, Mr. Jigar Praful Ghoghari, Mr. Kiran Bhiku Bhanaes, Mr. Jinal Apurval Rawal, Mr. Janak Chimanlal Dave, Mr. Dilipkumar Pukhraj Jain, Mr. Bhupesh Harischandra Rathod, Mr. Kishan Balaram Shigvan, Mr. Kiran Madhusudan Sheth, Shree Shagun Financial Services (“SSFS”), Oliwonders Financial Services Pvt. Ltd. (“OFSPL”) and Neevan Capital Markets Private Limited (“NCMPL”) from accessing the securities market and further prohibited them from buying, selling or dealing in securities in any manner whatsoever, till further directions. The interim order alleged that the above persons/entities prima facie violated the provisions of section 12A of the Securities and Exchange Board of India Act, 1992 (“the SEBI Act”) and regulations, 3, 4(1) & (2) of the SEBI (Prohibition of Fraudulent and Unfair Trade Practices Relating to Securities Market) Regulations, 2003 (“the PFUTP Regulations”) while dealing in the shares of the above said companies. After affording opportunity to file replies and personal hearing, SEBI, vide Order dated January 07, 2014, confirmed the interim directions against the aforementioned 11 persons/entities. The above said Orders were issued when the investigations in the matters were in progress.

2. Investigation was carried out in the matter of trading by suspected persons/entities in the scrips of Gemstone, KGN and Polytex, to ascertain whether there was any violation of the provisions of SEBI Act 1992 and PFUTP Regulations by suspected entities and completed. In addition to the 11 persons/entities mentioned in paragraph 1 above, the investigation identified Jatin Shah as forming part of the ‘suspected entities’. The investigation observed that Mr. Jigar Ghogari, Mr. Kiran Bhanaes, Mr. Janak Dave, Mr. Dilip Jain, Mr. Bhupesh Rathod, Mr. Kishan Shigvan, Mr. Kiran Sheth and Mr. Jatin Shah had traded in the shares of Polytex during April 13, 2012 to December 17, 2012 by means of manipulative and unfair trading practices and allegedly made profits. In this regard, the relevant observations of the investigation are noted:

(a) Polytex India Limited (also referred to as “the Company”) was incorporated under the Companies Act, 1956 in the year 1987. It is registered with the Reserve bank of India (RBI) as a Non-Banking Finance Company.

(b) The equity shares of the Company are listed on the Bombay Stock Exchange Limited (“BSE”). The price of the scrip in BSE moved from Rs.136.50/- to Rs.281/- from April 13, 2012 to December 17, 2012 (which is the period of investigation), registering an increase of Rs.144.50/- (105.86%).

(c) During the investigation period, the trading activity of the suspected entities in the scrip of Polytex was as under :

Gross summary of Buy / Sell of suspected entities SN % of % of % of Net Gross Gross Buy Gross Sell Net Client Name Gross Sell Qty. to Buy to Mkt. to Mkt. Qty. Mkt. Volume Volume Volume 1 DILIPKUMAR JAIN 2895780 16.47 2897891 16.48 -2111 (0.01) 2 RAWAL JINAL 2093677 11.91 2079421 11.83 14256 0.08 3 JIGAR GHOGHARI 1809523 10.29 1955124 11.12 -145601 (0.83) 4 KIRAN SHETH 1489452 8.47 1378459 7.84 110993 0.63 5 BHUPESH RATHOD 1258640 7.16 1172846 6.67 85794 0.49 6 KISHAN SHIGVAN 1106199 6.29 1091124 6.21 15075 0.09 7 KIRAN BHANAES 1032053 5.87 1079497 6.14 -47444 (0.27) 8 JANAK DAVE 591428 3.36 560947 3.19 30481 0.17 9 JATIN SHAH 296196 1.68 405608 2.31 -109412 (0.62) Total 12572948 71.50 12620917 71.77 -47969 (0.27) (d) From the above data, it is observed that during the investigation period the suspected entities had bought 71.50% i.e. 1,25,72,948 shares and sold 71.77% i.e. 1,26,20,917 shares, of the total traded volume in the stock exchange.

(e) Based on the above, it can also be inferred that major trading in the scrip during the relevant period was executed by the suspected entities and such trading allegedly contributed to the trading volume in the scrip of Polytex.

(f) During the investigation, the suspected entities had traded among themselves and executed reversal trades which are as under:

Summary of Reversal trades and trade amongst themselves by suspected entities Entity (1) Entity (2) Entity (1) sells Entity (1) Reversal % of reversal No. of to Entity (2) buys from Quantity Quantity Trades buy Entity (2) w.r.t. market volume JigarGhogari Dilip Jain 519,411 584,300 519411 2.95 281 Dilip Jain JinalRawal 585,968 506,247 506247 2.88 490 JigarGhogari BhupeshRathod 151,282 161,318 151282 0.86 93 JigarGhogari Jatin Shah 27,255 5,000 5000 0.03 3 JigarGhogari Janak Dave 77,147 92,739 77147 0.44 47 JigarGhogari KiranSheth 141,288 146,050 141288 0.80 82 JigarGhogari KiranBhanaes 124,617 180,144 124617 0.71 77 JigarGhogari JinalRawal 322,306 220,572 220572 1.25 81 JigarGhogari KishanShigvan 264,101 278,133 264101 1.50 171 Dilip Jain BhupeshRathod 269,475 353,331 269475 1.53 204 Dilip Jain Jatin Shah 76,277 162,982 76277 0.43 33 Dilipjain Janak Dave 143,547 103,016 103016 0.59 172 Dilip Jain KiranSheth 164,226 142,590 142590 0.81 139

Dilip Jain KiranBhanaes 250,035 258,226 250035 1.42 134 Dilip Jain KishanShigvan 130,215 104,111 104111 0.59 110 BhupeshRathod Jatin Shah 65,589 143,107 65589 0.37 57 BhupeshRathod Janak Dave 29,970 7,850 7850 0.04 18 BhupeshRathod KiranSheth 42,250 87,841 42250 0.24 21 BhupeshRathod KiranBhanaes 79,204 100,760 79204 0.45 50 BhupeshRathod JinalRawal 213,754 254,405 213754 1.22 114 BhupeshRathod KishanShigvan 91,893 74,719 74,719 0.42 54 Jatin Shah KiranSheth 25,800 2000 2000 0.01 1 Jatin Shah KiranBhanaes 1,721 44,561 1721 0.01 1 Jatin Shah JinalRawal 47,256 43,229 43,229 0.25 21 Janak Dave KiranSheth 58,218 31,169 31,169 0.18 29 Janak Dave KiranBhanaes 85,893 40,629 40,629 0.23 20 Janak Dave JinalRawal 69,046 132,382 69046 0.39 44 Janak Dave KishanShigvan 45,516 38,368 38,368 0.22 38 KiranSheth KiranBhanaes 32,563 18,551 18,551 0.11 14 KiranSheth JinalRawal 254,675 274,465 254675 1.45 97 KiranSheth KishanShigvan 84,652 130,785 84652 0.48 97 KiranBhanaes JinalRawal 156,400 167,040 156400 0.89 101 KiranBhanaes KishanShigvan 76,798 99,797 76798 0.44 84 JinalRawal KishanShigvan 197,264 173,879 173,879 0.99 83 Total 4,905,612 5,164,296 4,429,652 25.18 3061 (g) From the above data, it can be observed that suspected entities had bought 49,05,612 shares from the other suspected entities i.e. 38.86% (4905612/12620917 *100) of the total sell quantity by the suspected entities, while suspected entities had sold 51,64,296 shares to the other suspected entities i.e. 41.07% (5164296/12572948*100) of the total buy quantity by the suspected entities. Based on the trading among themselves by the suspected entities they had created 25.18 % of the total market as artificial volume through reversal trades.

(h) It was also observed that 10,57,537 shares of PIL were traded in a synchronized manner during the investigation period amongst the suspected entities wherein quantity, price and time matched (i.e. trades were executed within 60 seconds). Such synchronized trades of these entities represented 6.01% of the total market volume and 10.39% of the total quantity traded amongst the suspected entities. A summary of such trades are given below:

Summary of the Synchronized quantity traded amongst the suspected entities Name Trade Volume through synchronization Bhupesh Harishchandra Rathod 54,077 Dilipkumar Pukhraj Jain 294,220 Janak Chimanlal Dave 32,672 Jatin Shantilal Shah 5,000

Jigar PrafulchandraGhoghari 179,172 Kiran Bhiku Bhanaes 108,707 Kiran Madhusudan Sheth 83,952 Kishan Balaram Shigvan 142,863 Rawal Jinal Apurva 156,874 Total 1,057,537 (i) The investigation also observed that the suspected entities had contributed to the price rise of the scrip during the investigation period. (A) The following table shows the contribution in New High Price (“NHP”) by the suspected entities are as under: Contribution in NHP by the suspected entities NHP where the counter-parties were % of from the suspected total No. of entities out of total mkt Entity Name PAN Qty trades NHP (Rs.) NHP NHP DILIPKUMAR JAIN AACPJ5643C 1877 21 11.85 4.55 8.20 RAWAL JINAL ATHPR5041C 149 4 5 2.5 3.46 Total of suspected 2026 25 16.85 7.05 11.66 Remaining 12921 39 127.65 - 88.34 Total 14947 64 144.5 - 100

From the above data it can be observed that suspected entities had contributed Rs.16.85/- to the new high price, out of which Rs.7.05/- contribution where counterparties were from the suspected entities. (B) The following table shows the contribution in positive LTP by the suspected entities: Contribution in Positive LTP by suspected entities LTP Diff. >0 LTP QTY % of positive LTP to Total Name impact traded No of trades Market positive LTP Dilipkumar Jain 597.35 933966 738 30.59 Kishan Shigvan 298.65 347736 393 15.30 Rawa lJinal 91.7 443289 197 4.70 Jigar Ghoghari 78.35 358100 155 4.01 Kiran Bhanaes 58.45 159097 95 2.99 Janak Dave 38.3 66695 51 1.96 Bhupesh Rathod 36 214017 108 1.84 Kiran Sheth 28.3 193705 70 1.45 Jatin Shah 12.15 61733 35 0.62 Total of Suspected 1239.25 2778338 1842 63.47 Remaining 713.3 1183718 968 36.53 Total 1952.55 3962056 2810 100.00

It can be observed that suspected entities had contributed Rs.1239.25/- in positive LTP which was 63.47% of the total positive LTP in the market. The table below shows the positive LTP contribution by the suspected entities where the counterparties were also from the group of suspected entities: Contribution in Positive LTP by suspected entities where Counterparties were also from suspected entities LTP Diff >0 where CPs from % of positive LTP where LTP Diff >0 the suspected entities CPs from the suspected entities w.r.t. LTP diff >0 Particulars LTP impact Qty LTP impact Qty in market. Dilipkumar Jain 597.35 933966 130.45 613899 6.68 Kishan Shigvan 298.65 347736 72.65 283166 3.72 Rawal Jinal 91.7 443289 40.95 352705 2.10 Jigar Ghoghari 78.35 358100 40.9 316721 2.10 Kiran Bhanaes 58.45 159097 22.9 116256 1.17 Janak Dave 38.3 66695 10.9 55480 0.56 Bhupesh Rathod 36 214017 18.9 173234 0.97 Kiran Sheth 28.3 193705 12 105836 0.61 Jatin Shah 12.15 61733 6.6 51716 0.34 Total 1239.25 2778338 356.25 2069013 18.24

The suspected entities had contributed Rs.1239.25/- in positive LTP out of which Rs. 356.25 was contributed when counterparties were from the suspected entities i.e. 18.24% of the total positive LTP was contributed by the suspected entities through trading amongst themselves.

(j) Based on the analysis as given above, it is noted that the suspected entities had traded substantially amongst themselves, created artificial volume in the market and also contributed into the positive LTP and through which they manipulated the price - volume in the scrip of PIL. In the process, the persons/entities also made unlawful gains which has been calculated and given hereunder:

Statement showing the profits made by the suspected persons/entities while trading in the shares of Polytex:

S Profit/Loss Client Name PAN Buy Qty. Buy Value (INR) Sell Qty. Sell Value (INR) N (INR) DILIPKUMAR PUKHRAJ 2,895,780 609,903,118 2,897,891 615,793,547 AACPJ5643C JAIN 2,111* 286,120 1 Total 2,897,891 610,189,238 2,897,891 615,793,547 5,604,309 591,428 134,901,303 560,947 129,756,403 2 JANAK CHIMANLAL DAVE AEPPD9110D 30,481$ 7,675,349

Total 591,428 134,901,303 591,428 137,431,752 2,530,449 BHUPESH 1,258,640 229,575,527 1,172,846 214,945,454 HARISHCHANDRA AACPR3785K 85,794$ 21,644,084 3 RATHOD Total 1,258,640 229,575,527 1,258,640 236,589,538 7,014,010 KISHAN BALARAM 1,106,199 250,008,841 1,091,124 247,071,957 BAWPS1264D 4 SHIGVAN 15,075$ 3,792,000 Total 1,106,199 250,008,841 1,106,199 250,863,957 855,116 KIRAN MADHUSUDAN 1,489,452 341,942,011 1,378,459 316,251,708 ALJPS1874Q SHETH 110,993$ 28,035,811 5 Total 1,489,452 341,942,011 1,489,452 344,287,519 2,345,508 296,196 52,142,414 405,608 70,499,388 JATIN SHANTILAL SHAH AACPS6128D 109,412 * 14,784,773 6 Total 405,608 66,927,187 405,608 70,499,388 3,572,200 1,032,053 224,298,774 1,079,497 233,056,559 KIRAN BHIKU BHANAES AQUPB0853G 47,444* 6,444,545 7 Total 1,079,497 230,743,319 1,079,497 233,056,559 2,313,240 JIGAR PRAFULCHANDRA 1,809,523 404,751,928 1,955,124 431,156,517 ASFPG8598L GHOGHARI 145,601 * 20,040,247 8 Total 1,955,124 424,792,175 1,955,124 431,156,517 6,364,342 * Shares bought prior to the investigation period. $ Shares sold post investigation period. (k) The investigation also observed that the aforementioned entities were connected to each other based on fund movement and KYC details or a combination of both.

Connection based on KYC details are as under S. Name of Entity PAN Connection details No. 1 Kiran Bhikhu AQUPB0853G  Common land line no.:- Chirag Jariwala (a Pabari-Parikh entity), Bhanaes Jigar Ghogari and Kiran Bhikhu Bhanaes - 40229880.  Kiran Bhanaes had received funds from Shree Shagun Financial Services (SSFS), Oliwonders Financial Services Pvt. Ltd. (OFSPL) and Jigar Ghogari. 2 Jigar P ASFPG8598L  Common address: Jigar Ghogari, Prem Parikh and OFSPL – Ghoghari H No 140k Cavel Cross Lane No 7 3rd Floor 6 Gai Wady Kalbadevi Road, Mumbai, Maharashtra, India, 400002.  Common Mob. no. : Chirag Jariwala*, Jigar Ghogari. - 9920134780.  Common Land line no. : Chirag Jariwala, Jigar Ghogari and Kiran Bhikhu Bhanaes - 40229880.  Common Mob. no.: Dilip Jain and Jigar Ghogari - 9870895035.  Common E-mail ID : Chirag Jariwala*, and Jigar Ghogari.- BIGFINS1@GMAIL.COM / KANAKSHAGUN@GMAIL.COM/ SSF2AN0J0046@JAADOOMAIL.COM/ CHIRAG_BHAI@YAHOO.COM  Common E-mail ID: Jigar Ghogari and Bhavesh Pabari - BHAVESH_PABARI2005@YAHOO.COM.

 Common E-mail ID : Jigar Ghogari and Prem Parikh and Chirag Jariwala - PARIKHPREM@GMAIL.COM / PARIKHPREM@YAHOO.COM  Jigar Ghogari received funds from SSFS, OFSPL  Jigar Ghogari had given funds to Kishan Shigvan, Jinal Rawal, Kiran Bhanaes, Kiran Sheth, Janak Dave, Dilip Jain and Bhupesh Rathod. 3 Dilip Pukhraj AACPJ5643C  Common Mob. no.: Dilip Jain and Jigar Ghogari - 9870895035. Jain  Dilip Jain had received funds from SSFS* and Jigar Ghogari.

4 Kishan BAWPS1264D  Kishan Shigvan had received funds from SSFS, OFSPL and Balaram Jigar Ghogari. Shigvan 5 Janak C Dave AEPPD9110D  Janak Dave had received funds from SSFS, OFSPL and Jigar Ghogari. 6 Bhupesh  Bhupesh Rathod had received funds from SSFS and Jigar Rathod AACPR3785K Ghogari. 7 Jinal Rawal  Jinal Rawal had received funds from SSFS, OFSPL, Jigar ATHPR5041C Ghogari and Janak Dave. 8 Kiran ALJPS1874Q  Common E-mail ID: Kiran Sheth and Hemant Sheth - Madhusudan DEVHEMANT@REDIFFMAIL.COM. Sheth  Common address: Kiran Sheth and Hemant Sheth - H No 113/115 3rd Floor above Ratanlal Barfiwala Shop Bhuleshwar Road, Mumbai, Maharashtra, India, 400002.  Kiran Madhusudan Sheth and Hemant MadhusudanSheth both have common middle name.  Kiran Sheth had received funds from SSFS, ,Neevan Capital Markets Pvt. Ltd. (NCMPL) and Jigar Ghogari. 9 Jatin Shantilal AACPS6128D  Common Mob. no.: Jatin Shah and Jigar Ghogari - 9821229502. Shah  Jatin Shah has also received fund from the SSFS.

10 Shree Shagun ABTFS0353F  Provided funds to various entities as mentioned above. Financial  SSFS is partnership firm of Bhavesh Pabari & HemantSheth. Services (SSFS)  Prem Parikh &Ankit Sanchaniya are the director of OFSPL. 11 Oliwonders AABCO2030J  Bhavesh Pabari &Prem Parikh are the director of NCMPL. Financial Services Pvt. Ltd. (OFSPL) 12 Neevan Capital AACCN7650G Markets Pvt. Ltd. (NCMPL) Persons/entities at sr. nos. 1 - 9 are treated as part of the suspected group as they had traded in the securities market, while entities at sr. nos. 10-12 had funded the persons/entities at sr. nos. 1 - 9.

Summary of the fund movement between the suspected entities SN Particulars Funds details 1 Shree Shagun SSFS a/c. no. '911020040956496 Financial Services  Jigar Ghogari received Rs. 39.72 crore and paid back Rs. 21.19 crore  Janak dave received. Rs. 18.08 crore & paid back Rs. 2.32 crore  Jinal Rawal received Rs. 24.26 crore & paid back Rs. 1.40 crore  Kiran Bhanaes received Rs. 27.97 crore & paid back Rs. 5.01 crore  Kiran Sheth received Rs. 8.37 crore & paid back Rs. 0.12 crore  Jatin Shah received Rs. 4.67 crore  Kishan Shigavn received Rs. 16.58 crore & paid back Rs. 0.25 crore  Dilip Jain received Rs. 7.27 crore & paid back Rs. 0.85 crore  Bhupesh Rathod received Rs. 3.61 crore & paid back Rs. 0.52 crore 2 Oliwonders  Jigar Ghogari received Rs. 2.43 crore & paid back Rs. 0.20 crore Financial Services  Jinal Rawal received Rs. 1.59 crore & paid back Rs. 0.09 crore Pvt. Ltd.  Kiran Bhanaes received Rs. 0.15 crore  Kishan Shigvan received Rs. 0.37 crore  Janak Dave received Rs. 0.62 crore 3 Neevan Capital  Jigar Ghogari received Rs. 0.20 crore Markets Pvt. Ltd.  Kiran Sheth received Rs. 0.43 crore 4 Jigar Ghogari Observed from SSFS a/c. no. '911020040956496  Jigar Ghogari received Rs. 39.72 crore & paid back Rs. 21.19 crore. Jigar Ghogari a/c. no. '910010002119761  OFSPL paid Rs. 2.43 crore & received Rs. 0.20 crore  Kiran Bhanesh received Rs. 0.29 crore  Janak Dave received Rs. 0.08 crore  Jinal Rawal received 0.05 crore  Neevan Capital Markets paid Rs. 0.2 crore Jigar Ghogari a/c. no. :911020043354844  OFSPL received Rs. 0.11 crore & paid back Rs. 2.43 crore  Jinal Rawal received Rs. 3.17 crore & paid Rs. 0.78 crore  Kiran Bhanesh received. Rs. 2.01 crore  Kiran Sheth received Rs. 0.85 crore  Janak Dave received Rs. 0.76 crore  Dilip Jain received Rs. 0.53 crore  Bhupesh Rathod received Rs. 1.42 crore & paid back Rs. 0.09 crore  Kishan Shigvan received Rs. 2.31 crore

13. From the above, it is noted that the partners of Shree Shagun Financial Services are Mr. Bhavesh Pabari and Mr. Hemant Sheth. The directors of OFSPL and NCMPL are Mr. Prem Parikh and Mr. Ankit Sanchaniya and Mr. Bhavesh Pabari and Mr. Prem Parikh respectively. It is noted that the above said companies are private limited companies. Therefore, it is appropriate that they are also made liable for the actions of the respective partnership firm and private limited companies in the alleged funding to the suspected persons/entities.

14. Considering the alleged connection amongst the said 16 persons/entities, the manner of trading and specifically the fund movement, as outlined in this Order, it is reasonable to view all of them as a ‘group’ and make them jointly and severally liable for the alleged illegal profits made while dealing in the shares of Polytex during the investigation period. I note that the persons/entities are aware of the investigations as also the likely findings of the investigation, in the light of the evidences gathered and the statements given during the investigation. All these factors point to the possibility that the persons/ entities involved may divert the unlawful gains. Therefore, in order to prevent such persons/ entities from diverting the funds and to safeguard the interests of securities market, it becomes necessary for SEBI to take urgent preventive steps of impounding and retaining the proceeds by way of an interim measure.

15. As the alleged gains were made during the year 2011, it becomes reasonable and necessary to levy an interest at the rate of 12% simple interest per annum. The gains along with the interest are calculated as follows:

Summary of the Profit made by the suspected entities through trading in the scrip of PIL

Profit (Amount in Interest Total Entity Name PAN Rs.) 12% p.a.** (Rs.) DILIPKUMAR PUKHRAJ JAIN AACPJ5643C 56,04,309 20,51,900 76,56,209 JANAK CHIMANLAL DAVE AEPPD9110D 25,30,449 9,26,471 34,56,920 BHUPESH HARISHCHANDRA AACPR3785K RATHOD 70,14,010 25,68,033 95,82,043 KISHAN BALARAM SHIGVAN BAWPS1264D 8,55,116 3,13,083 11,68,199 KIRAN MADHUSUDAN ALJPS1874Q SHETH 23,45,508 8,58,758 32,04,266 JATIN SHANTILAL SHAH AACPS6128D 35,72,200 13,07,886 48,80,087 KIRAN BHIKU BHANAES AQUPB0853G 23,13,240 8,46,944 31,60,184 JIGAR PRAFULCHANDRA ASFPG8598L GHOGHARI 63,64,342 23,30,171 86,94,513 Total 3,05,99,174 1,12,03,246 4,18,02,420

** Interest calculated on illegal gains from 01/08/2012 till 19/08/2015 Alleged illegal profits made during April – December 2012, the investigation period. From the above table, it can be observed that the above persons/ entities had made alleged illegal profits to the tune of Rs.4.18 crore in aggregate through trading in the scrip of Polytex.

16. Accordingly, as an interim measure, an ad-interim ex-parte Order for impounding such alleged profits under section 11(4)(d) of the Securities and Exchange Board of India Act, 1992 needs to be issued against–

S. No. Name Permanent Account Number 1 Mr. Jigar Praful Ghogari ASFPG8598L 2 Mr. Kiran Bhiku Bhanaes AQUPB0853G 3 Mr. Janak Chimanlal Dave AEPPD9110D 4 Mr. Dilipkumar Pukhraj Jain AACPJ5643C 5 Mr. Bhupesh Harischandra Rathod AACPR3785K 6 Mr. Kishan Balaram Shigvan BAWPS1264D 7 Mr. Kiran Madhusudan Sheth ALJPS1874Q 8 Mr. Jatin Shah AACPS6128D 9 Shree Shagun Financial Services ABTFS0353F 10 Oliwonders Financial Services Pvt. Ltd. AABCO2030J 11 Neevan Capital Markets Pvt. Ltd. AACCN7650G 12 Mr. Bhavesh Pabari AKGPP8679N 13 Mr. Hemant Sheth ANOPS8607E 14 Mr. Prem Parikh ALHPP3489N 15 Mr. Ankit Sanchaniya BLNPS3316L 16 Mr. Jinal Apurval Rawal ATHPR5041C

17. In view of the foregoing, in order to protect the interest of the investors and the integrity of the securities market, I, in exercise of the powers conferred upon me by virtue of section 19 read with sections 11(1), 11(4)(d) and 11B of the SEBI Act, 1992, hereby impound the alleged unlawful gains of a sum of ₹4,18,02,420/- (alleged gain of ₹3,05,99,174/- + interest of ₹ 1,12,03,246/- (from 01.08.2012 to 19.08.2015), jointly and severally from persons/entities tabulated in the paragraph above.

18. The Banks and Depositories are directed that no debits shall be made, without permission of SEBI, in respect of the bank accounts and demat accounts, held jointly or severally, by all the persons/entities tabulated in paragraph 16 above. The Banks and the Depositories are directed to ensure that all the above directions are strictly enforced.

19. The persons/entities tabulated in paragraph 16 above are also directed not to dispose off or alienate any of their assets/properties/securities, till such time the amounts mentioned in paragraph 17 are credited to an escrow account {“Escrow Account in Compliance with SEBI Order dated August 20, 2015 – A/c (in the name of the respective persons/entities)”} created specifically for the purpose in a Nationalized Bank. The escrow account/s shall create a lien in favour of SEBI and the monies kept therein shall not be released without permission from SEBI. After the said monies are deposited in the escrow account, SEBI shall communicate to the Banks and Depositories to defreeze the accounts.

20. Further, the persons/entities tabulated in paragraph 16 above are directed to provide, within 7 days of this order, a full inventory of all their assets and properties and details of all their bank accounts, demat accounts and holdings of shares/securities, if held in physical form and details of companies in which they hold substantial or controlling interest.

21. The above direction shall come into force with immediate effect.

22. This Order is without prejudice to the right of SEBI to take any other action that may be initiated against the 16 persons/entities covered under this Order, in accordance with law. The persons/ entities against whom this Order has been passed may file their replies to SEBI within 21 days from the date of receipt of this order, if they so desire. They may also indicate in their replies whether they wish to avail an opportunity of personal hearing in the matter.

PRASHANT SARAN WHOLE TIME MEMBER SECURITIES AND EXCHANGE BOARD OF INDIA Date: August 20, 2015 Place: Mumbai