Order w.r.t. Mr. Jayendra Chandulal Sheth in the matter of Grandma Trading and Agencies Ltd.

Under Sections 11(1), 11(4) and 11B of the Securities and Exchange Board of India Act, 1992 In Re: Securities and Exchange Board of India (Prohibition of Fraudulent and Unfair Trade Practices Relating to Securities Market) Regulations, 2003 In respect of: S. No. Name of the Entity PAN Mr. Jayendra Chandulal Sheth AEUPS9690E 1.

In the matter of Grandma Trading and Agencies Ltd.

BACKGROUND 1. Grandma Trading and Agencies Ltd. (hereinafter referred to as “GTAL / Company”) was in the business of export of soya oil until the year 1996 after which the said business was discontinued. The company thereafter has been engaged in the business of textile, fabric and yarn trading and other commission agency business. The company has been listed on BSE since 1982. It is listed only on BSE.

2. Securities and Exchange Board of India (hereinafter referred to as “SEBI”) conducted an investigation in the scrip of GTAL based on a reference received from the Principal Director of Income Tax (Investigation), Kolkata. The focus of the investigation was to ascertain whether there were any violations of the provisions of Securities and Exchange Board of India Act, 1992 (hereinafter referred to as “SEBI Act”) and SEBI (Prohibition of Fraudulent and Unfair Trade Practices relating to Securities Market)

Order in the matter of Grandma Trading and Agencies Ltd.

Regulations, 2003 (hereinafter referred to as “PFUTP Regulations”) by certain entities in the scrip of GTAL during the period April 4, 2012 to March 13, 2015 (hereinafter referred to as “Investigation Period”).

3. During the investigation period, corporate announcements were made by the company regarding stock split, declaration of financial results and meeting of the Board of Directors of the Company. Further, it is observed from the Investigation Report (hereinafter referred to as “IR”) that GTAL earned profit (net) of ` 0.08 crore until 2012 which increased to ` 0.62 crore during year ending 2013. The net profit started decreasing after 2013 and fell to ` 0.15 crore in the year ending 2014 and thereafter increased marginally to ` 0.16 crore in the year ending 2015 and 2016.

4. During the investigation period, 84,49,340 shares were traded through 29,813 trades. Trading in GTAL was suspended w.e.f September 10, 2001 on account of non-payment of annual listing fees and later revoked w.e.f June 27, 2011. However, no trades were executed from the date of revocation of suspension i.e. June 27, 2011 till April 3, 2012. The price and volume in the scrip during the investigation period and post investigation period is as follows:

Period Particulars Open High Low Close Avg. Volume ` 15 ` 309.95 ` 12.95 Price ` 12.05 (11/03/15) (04/04/12) (13/11/14) (13/03/15) 10 April 4, 2012 to (14/09/2012, March 13, 2015 12/02/2013, 17788 -Investigation 200 309667 135373 Volume 13/03/2013, period (04/04/12) (03/03/15) (13/03/15) 10/05/2013, 14/05/2013,15/05/2013, 23/05/2013, 26/02/15) March 16, 2015 ` 12.05 ` 25.4 22.6 Price ` 12 (16/03/15) to June 16, (16/03/15) (11/06/15) (16/06/15) 2015- Post 122900 223312 543096 1 15701 Investigation Volume (16/03/15) (31/03/15) (14/05/15) (16/06/15) period

5. On the basis of price movement, 4 patches were identified. The open, high, low, close price of the scrip before, during the period of investigation are as under:

Period Particulars Open High Low Close Avg. Volume per day Patch I 235.25 15 Price(`) 15 234 April 4, 2012 (12/06/2013) (04/04/2012) – June 12, 10 258 2013 (14/09/2012,12/02/2013, Volume(No. 6,884 200 18/03/2013,10/05/2013, 6884 of shares) (12/06/2013) 14/05/2013,15/05/2013, 23/05/2013) Patch II 294 230 Price(`) 230 288 June 13, (24/03/2013) (13/006/2013) 2013 – 23,211 Volume(No. 59,537 1,510 March 31, 11360 37818 of shares) (05/09/2013) (22/03/2014) 2014 Patch III 309.95 135 Price(`) 287.5 179.8 April 1,2014 (13/11/2014) (06/02/2015) 14,457 to February Volume(No. 84,887 17 23000 22 25, 2015 of shares) (15/01/2015) (08/12/2014) Patch IV 23.4 12.05 Price(Rs.) 19.5 12.8 February 26, (27/02/2015) (11/03/2015) 2015 – 75,496 Volume(No. 3,09,667 10 March 13, 10 135373 of shares) (03/03/2015) (26/02/2015) 2015 SHOW CAUSE NOTICE 6. Consequent to the investigation, a show cause notice dated August 7, 2017 (hereinafter referred to as “SCN”) was served on Mr. Jayendra Chandulal Sheth (hereinafter referred to as “Noticee”) in the extant matter. The SCN inter alia alleged as follows: a) The LTP analysis of the 4 patches was done and the details of patch 4 qua the Noticees is given below:

LTP Analysis: Patch 4: February 26, 2015 to March 13, 2015 (Post stock split-price fall patch):  During this period, the price of the scrip opened at ` 19.5, reached a high of ` 23.4 and closed at ` 12.8. An analysis of buyers during patch 4 was carried out. The following table illustrates the trading by top 10 LTP contributors as buyers:

LTP LTP % of QTY No of QTY No of QTY No of LTP impact impact Negative QTY No of traded trades traded trades traded trades impact (with (with LTP to traded trades (with (with (with (with (with (with Buyer Name all LTP LTP Total (all (all LTP LTP LTP LTP LTP LTP trades diff > diff < Market trades) trades) diff > diff > diff < diff < diff = diff = in Rs. 0) in 0) in Negative 0) 0) 0) 0) 0) 0) Rs. Rs. LTP Jayendra Chandulal Sheth -14.95 213 41 0.05 1 1 -15 154 34 58 6 15.11% Megha Jakhetia -7.5 2141 14 0.2 410 2 -7.7 1031 4 700 8 7.76% Kalpesh Chandubhai Patel -5.8 241 11 2.05 102 3 -7.85 79 5 60 3 7.91% Paramjeet Kaur -4.7 12000 2 0 0 0 -4.7 12000 2 0 0 4.74% Himanshu Chittoria -4.6 212 5 0.1 30 1 -4.7 112 3 70 1 4.74% Mukesh Patel -4.4 200 2 0 0 0 -4.4 200 2 0 0 4.43% Mahendra Singh -3.85 646 23 0.7 36 2 -4.55 475 12 135 9 4.58% Sangram Kadam -3.4 1 1 0 0 0 -3.4 1 1 0 0 3.43% Vipin Kumar -2.75 402 4 0 0 0 -2.75 302 3 100 1 2.77% Anjali Panwar -2.4 250 2 0.05 50 1 -2.45 200 1 0 0 2.47% Top 10 Sub Total -54.35 16306 105 3.15 629 10 -57.5 14554 67 1123 28 57.93% Rest of Market 47.65 889654 688 89.4 219027 168 -41.75 106022 117 564605 403 42.07% Market Total -6.7 905960 793 92.55 219656 178 -99.25 120576 184 565728 431 100%  From the IR it is observed that the Noticee has traded on 6 days with total 41 trades.

Out of these 41 trades Noticee has contributed negative LTP as buyer in 34 trades. Total negative LTP contribution by Noticee is ` -15 (15.11% of the total market negative LTP). The following table is the summary of these 34 trades: LTP Buy at Sell Ord LTP Buy Trad Order er Sell Buy Diff Trade Date Seller Name Buyer Name Orde e Disclos Discl Order Order ere r Price e ose LMT LMT nce Entr Volume Volu y me Jayendra Chandulal 27/02/2015 Surinder Singh Dutta Sheth 20 17.2 -2.8 1 10 13:32:26 13:31:16 Jayendra Chandulal 27/02/2015 Surinder Singh Dutta Sheth 20 17.2 -2.8 99 10 13:33:17 13:31:16 Jayanthi Shiva Jayendra Chandulal 27/02/2015 Shankar Sheth 19.9 18.1 -1.7 20 10 14:05:18 13:50:55 Jayendra Chandulal 27/02/2015 Sumicksha Sheth 19.6 17.1 -0.6 149 1 15:27:09 15:22:30 Jayendra Chandulal 27/02/2015 Sumicksha Sheth 20 16.3 -0.2 149 10 15:28:53 13:31:32 Anupam Narain Jayendra Chandulal 27/02/2015 Gupta Sheth 19.9 17.9 -0.2 10000 1 15:00:27 13:51:19 Rakesh Virendra Jayendra Chandulal 27/02/2015 Dwivedi Sheth 20 16.3 -0.1 1000 10 15:28:49 13:31:32 Rakesh Virendra Jayendra Chandulal 27/02/2015 Dwivedi Sheth 20 16.4 -0.1 1000 1 15:28:49 13:31:44

LTP Buy at Sell Ord LTP Buy Trad Order er Sell Buy Diff Trade Date Seller Name Buyer Name Orde e Disclos Discl Order Order ere r Price e ose LMT LMT nce Entr Volume Volu y me Anupam Narain Jayendra Chandulal 27/02/2015 Gupta Sheth 19.9 17.7 -0.1 10000 10 15:00:27 13:50:41 Anupam Narain Jayendra Chandulal 27/02/2015 Gupta Sheth 19.9 17.8 -0.1 10000 1 15:00:27 13:51:07 Anupam Narain Jayendra Chandulal 27/02/2015 Gupta Sheth 19.6 18.1 -0.1 10000 1 15:00:27 14:27:31 Paru Securities Jayendra Chandulal 02/03/2015 Pvtltd Sheth 16.8 15.8 -1 500 10 14:02:06 13:54:21 Paru Securities Jayendra Chandulal - 02/03/2015 Pvtltd Sheth 16.6 14.25 0.75 100 1 15:14:54 14:49:19 Paru Securities Jayendra Chandulal 02/03/2015 Pvtltd Sheth 15 15 -0.3 500 13 14:02:20 14:19:09 Paru Securities Jayendra Chandulal 02/03/2015 Pvtltd Sheth 15.75 14.05 -0.1 100 1 15:14:54 14:12:43 Paru Securities Jayendra Chandulal 02/03/2015 Pvtltd Sheth 16.8 15.55 -0.1 500 1 14:02:20 13:54:38 Paru Securities Jayendra Chandulal - 02/03/2015 Pvtltd Sheth 16.6 14.15 0.05 100 1 15:14:54 14:49:30 Paru Securities Jayendra Chandulal - 02/03/2015 Pvtltd Sheth 16.6 14.2 0.05 100 1 15:14:54 14:49:06 Jayendra Chandulal 04/03/2015 Kamendra Ram Singh Sheth 14.1 13.8 -0.3 100 1 14:46:21 14:23:29 Jayendra Chandulal - 04/03/2015 Kamendra Ram Singh Sheth 14.1 13.6 0.15 100 10 14:46:21 14:23:06 Jayendra Chandulal - 04/03/2015 Lokesh Kumar Sheth 16.45 14.05 0.05 1000 14 15:29:50 15:26:33 Jayendra Chandulal - 04/03/2015 Kalpesh Patel Sheth 16.45 16.45 0.05 5 5 15:15:28 15:26:07 Jayendra Chandulal - 05/03/2015 Nilesh J Prajapati Sheth 14.5 14.35 0.15 150 31 15:44:53 15:40:04 Rakesh Virendra Jayendra Chandulal - 11/03/2015 Dwivedi Sheth 14.95 12.8 2.15 2500 1 14:59:28 14:58:53 Jayendra Chandulal - 11/03/2015 Lokesh Kumar Sheth 14.3 14.35 0.05 276 1 14:37:21 13:54:19 Jignesh Rajendra Jayendra Chandulal 13/03/2015 Chowhan Sheth 13.2 12.95 -0.3 3000 1 13:45:23 13:39:09 Jayendra Chandulal - 13/03/2015 Sumicksha Sheth 13.05 13.05 0.25 1990 1 15:18:08 14:43:04 Shobhana Arvind Jayendra Chandulal 13/03/2015 Shah Sheth 13.1 13.05 -0.1 719 1 13:38:06 13:35:20 Jayendra Chandulal - 13/03/2015 Sumicksha Sheth 12.8 12.8 0.05 150 1 15:23:08 13:45:51 Jayendra Chandulal - 13/03/2015 Sumicksha Sheth 12.95 12.85 0.05 150 1 15:23:08 13:47:05 Jayendra Chandulal - 13/03/2015 Sumicksha Sheth 13.4 12.9 0.05 150 1 15:23:08 14:25:45

LTP Buy at Sell Ord LTP Buy Trad Order er Sell Buy Diff Trade Date Seller Name Buyer Name Orde e Disclos Discl Order Order ere r Price e ose LMT LMT nce Entr Volume Volu y me Shobhana Arvind Jayendra Chandulal - 13/03/2015 Shah Sheth 13.15 12.9 0.05 719 10 13:38:10 13:34:45 Shobhana Arvind Jayendra Chandulal - 13/03/2015 Shah Sheth 13.1 12.95 0.05 719 1 13:38:10 13:34:59 Jayendra Chandulal - 13/03/2015 Nitin Jakhetia Sheth 13.45 13.05 0.05 700 10 13:35:01 13:34:28

 Except for two trades, first executed on 27/02/2015 at 13:31:16 Sell Order LMT and second on 04/03/2015 at 15:15:28 Sell Order LMT, in all the remaining trades the disclosed volume of sellers was significantly higher than buy volumes of the Noticee.

 Thus, it is alleged from the trading pattern that the Noticee was not acting as genuine buyer and had no bona fide intention to buy because, he repeatedly purchased very small quantity of shares in each transaction at lower than LTP. Further, it is also alleged that in view of the repeated nature of such trades by the Noticee his culpability in decreasing the price is thus established. It is evident from the above trading pattern that the intention of the Noticee was to mark the price lower and not merely to enter into buy transactions carried out by him. Hence, it is alleged that the Noticee contributed to manipulation in the scrip price and created a misleading appearance of trading in the scrip by such trades as explained above. b) In view of the above it is alleged that Noticee has violated Regulations 3(a), (b), (c), (d) and Regulations 4(1), 4(2) (a), (e) of PFUTP Regulations. c) Noticee was advised to show cause as to why suitable actions/directions in terms of Sections 11(1), 11(4) and 11B of SEBI Act should not be initiated against him for the alleged violation of the provisions of PFUTP Regulations. Further, Noticee was advised to submit a reply to the SCN within 21 days from the date of receipt of the SCN.

REPLY & HEARING 7. In response to the SCN, Noticee vide his letter dated August 11, 2017 inter alia made the following submissions:  I had started trading after my retirement but now I have stopped trading.  I used to trade expecting to make a small profit as I was an intra-day trader.  There was a daily turnover of approximately 75,000 shares in the scrip. Therefore, I do not understand as to how my buy /sell of 20 shares on either side can make a price difference.  I must have traded for approximately 200 shares over a period of 20 days. I have a trading pattern of 1 to 10 shares per scrip. I have bought and sold 1 to 10 shares in other scrips also during the investigation period.  I do not have resources to trade in bulk quantity nor do I have capacity to take delivery of shares. I have always tried to square off my position at the end of the day by booking profit or loss.  I have always looked for 50 paise to 90 paise price difference in my trade which sometimes materialized and sometimes it had failed.  I have no connection with the company. 8. Noticee vide his letter dated May 7, 2018 requested for inspection of documents in the matter. Further, he authorized Mr. Vikas Bengani to conduct the inspection and to represent him before SEBI (hereinafter referred to as “AR”). Vide an email dated May 14, 2018, the AR was advised to conduct the inspection on May 21, 2018 at 10:30 am at SEBI Bhavan, Mumbai. The AR conducted the inspection on the scheduled date and was provided with a copy of the IR. The AR vide his email dated May 22, 2018 requested to be provided with a soft copy of the complete order log trade log for the investigation period. The AR was informed vide an email dated May 22, 2015 that the relevant extract of trade log relied upon to issue the SCN has already been provided to the Noticee along with the SCN. However the same was once again provided to the AR.

9. Subsequent to the inspection, the Noticee vide his letter dated June 6, 2018 inter alia made the following submissions:  I have purchased 213 shares and sold 157 shares of Grandma during patch 4 of the Investigation Period. I have total purchases of 398 shares and sold 433 shares (pre-split purchased 34 shares and sold 30 shares) during the entire Investigation Period. I have net delivery of one share in my hand and earned few hundreds of rupees as profit while trading in the scrip of GTAL. However, my complete trades were not considered and only trades executed during patch 4 on buying side were considered.  Executing trades in market lot i.e. 1 shares or in multiple of market lot is valid and allowed by the Stock Exchange. I have traded within the circuit filter set by the Exchange.  In absence of any collusion in between me and counterparties to my trades, I should not have been issued SCN in the matter. 10. Vide hearing notice dated November 5, 2018, Noticee was granted an opportunity of hearing on November 29, 2018 at SEBI Bhavan, Mumbai. On the day of scheduled hearing, the AR appeared on behalf of the Noticee and submitted as follows:  Complete trade log and order log has not been provided to him by SEBI.  He has traded in all the 4 patches of the investigation but details have been provided to him only for patch 4.  He has no connection with the company, its Promoters or Directors.

There is also no connection with the counterparties.  Negative contribution to LTP is normally not considered by SEBI but in this case, it has been made the basis of the allegations against him.  He has been trading for 5 years and his trading pattern in the scrip of GTAL is similar to his pattern in other scrips.  In the investigation report he was not named as a suspected entity.  100% of his trades were delivery based and none of his trades were cancelled.  In the list of his trades noted in the SCN, one trade has been executed at 3:44 pm which is after the closure of regular trading no manipulation can take place at that point of time since trading can only take place at that time at closing price.  Most of his trades were executed after 3 pm. There was a gap of more than 2 hours between placement of orders by him and execution of the said orders.  Out of the 41 trades, in around 38 trades, he did not correct or modify his price.  No action has been taken against preferential allottees.  Relying upon SEBI’s order in the matter of SMS Techsoft, he submitted that LTP variation is not per se illegal.

In support of his submissions, the AR was asked to provide the following information:

 Scrip-wise trading history including buy / sell and profit / loss details for 2012-13, 2013-14 and 2014-15.  Bank statement for 2 years prior to the investigation period. The AR was given time till December 15, 2018 to file the written submissions in the matter.

11. Pursuant to the hearing, Noticee vide his letter dated December 12, 2018, Noticee submitted his bank statements and transaction summary of his trades in securities market for the period 2011-2016.

FINDINGS & CONSIDERATIONS

12. I have perused the SCN, written and oral submissions and other materials available on record. On perusal of the same, the following issues arise for consideration: (i) Whether the Noticee has manipulated the price in the scrip and have created a misleading appearance of trading in the scrip of GTAL during the period February 26, 2015 to March 13, 2015? (ii) If answer to issue No. (i) is in affirmative, whether the Noticee has violated the provisions of PFUTP Regulations? (iii) If answer to issue Nos. (ii) is in affirmative, what directions, if any should be issued against the Noticee? 13. Before embarking upon the necessary discussions, I would like to reproduce the relevant provisions of PFUTP Regulations: Regulation 3. Prohibition of certain dealings in securities

No person shall directly or indirectly— (a) buy, sell or otherwise deal in securities in a fraudulent manner;

(b) use or employ, in connection with issue, purchase or sale of any security listed or proposed to be listed in a recognized stock exchange, any manipulative or deceptive device or contrivance in contravention of the provisions of the Act or the rules or the regulations made there under;

(c) employ any device, scheme or artifice to defraud in connection with dealing in or issue of securities which are listed or proposed to be listed on a recognized stock exchange;

(d) engage in any act, practice, course of business which operates or would operate as fraud or deceit upon any person in connection with any dealing in or issue of securities which are listed or proposed to be listed on a recognized stock exchange in contravention of the provisions of the Act or the rules and the regulations made there under.

Regulation 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;

… (e) any act or omission amounting to manipulation of the price of a security;

Issue No. 1 - Whether the Noticee has manipulated the price in the scrip and have created a misleading appearance of trading in the scrip of GTAL during the period February 26, 2015 to March 13, 2015?

14. It is noted from the material made available on record that the Noticee has executed 41 buy trades in the scrip during the patch-4 for 213 shares. Out of the said 41 buy trades, Noticee has executed 34 trades below the LTP. Total negative LTP contribution by the Noticee is ` -15 (15.11% of the total market negative LTP). 15. It is noted that the Noticee has traded on 6 days out 12 days on which the scrip was traded in the patch. As per the data available on BSE website, it is noted that the average volume of shares traded per day on the 6 days on which the Noticee traded is 61,274 shares with on an average 147 trades executed per day. The spread (High- Low) in the scrip during the said scrip was in the range of ` 1.9 - ` 7.4. The facts indicate that during the said 6 days, the scrip was quite actively traded and there was some volatility in the price. Seen in this light, the submission of the Noticee that he has always looked for 50 paise to 90 paise price difference in his trades which sometimes materialized and sometimes failed, appears tenable. Moreover, a reasonable buyer would be looking for an opportunity to buy shares at a low price. 16. Noticee has also submitted that he has bought and sold 1 to 10 shares in other scrips also during the investigation period. In this regard, Noticee’s trades for the financial year 2014-2015 was analysed. It is noted that during the said financial year, the Noticee has traded in over 40 other scrips, excluding GTAL wherein the Noticee as a buyer has frequently placed buy orders in miniscule quantity (1-11 shares). On further analysis, it was noted that when the Noticee has placed buy orders in miniscule quantity even when the sell order quantity was substantial. On 632 instances his buy order price was less than the LTP. Thus, it can be said that placing buy orders in miniscule quantity at lower than LTP even when the sell order quantity is for substantial number of shares, is in the normal course of business of the Noticee.

The same pattern was followed by the Noticee in the scrip of GTAL. Hence, the trading behavior of the Noticee in other scrips also demonstrates the consistency in his trading behavior including that in the scrip of GTAL. 17. I note that in cases of market manipulation, admittedly, no direct evidence would be forthcoming / available. Manipulative transactions are to be tested on the conduct of parties and abnormality of practices which defy normal logic and laid down procedures. What is needed, is to prove that in a factual matrix, preponderance of probabilities indicate a fraud. In this regard, the observations of Hon’ble Supreme Court of India in SEBI Vs. Kishore R Ajmera et.al. decided on February 23, 2016 wherein the Hon’ble Court while deciding the matter under SEBI Act and PFUTP Regulations where there was no direct evidence forthcoming, observed as follows: “It is a fundamental principle of law that proof of an allegation levelled against a person may be in the form of direct substantive evidence or, as in many cases, such proof may have to be inferred by a logical process of reasoning from the totality of the attending facts and circumstances surrounding the allegations/charges made and levelled.

While direct evidence is a more certain basis to come to a conclusion, yet, in the absence thereof the Courts cannot be helpless. It is the judicial duty to take note of the immediate and proximate facts and circumstances surrounding the events on which the charges/allegations are founded and to reach what would appear to the Court to be a reasonable conclusion therefrom. The test would always be that what inferential process that a reasonable/prudent man would adopt to arrive at a conclusion…” 18. Taking support of the observations of Hon’ble Apex Court in Kishore R Ajmera matter, I note that in order to determine whether a trade is manipulative in nature or not, the same has to be inferred from the attending circumstances because direct evidence in such cases may not be available. The list of factors to be taken note of, in the very nature of things, cannot be exhaustive. Any one factor may or may not be decisive and it is from the cumulative effect of attending circumstances an inference will have to be drawn. 19. In the instant matter, in view of the findings that have been gathered from various circumstances for instance the average no. of shares and average no. of trades in the scrip when the Noticee was trading, volatility in the scrip when he was trading, particulars of his buy orders and sell orders in the market, the period of persistence in trading in the scrip, and his trading behavior in other scrips, the totality of the picture that emerges, warrants that the Noticee be given the benefit of doubt.

Therefore, considering the material made available on record, I am of the view that the Noticee cannot be said to have manipulated the price in the scrip of GTAL and cannot be said to have created a misleading appearance of trading in the scrip during the period February 26, 2015 to March 13, 2015. However, I hasten to add that it is not in every case where the trades have been executed below the LTP that can be assessed as not resulting in manipulative trades. 20. In view of the aforesaid finding, issues no. 2 and 3 does not require any consideration. ORDER 21. In the facts and circumstances of the case, I, in exercise of the powers conferred upon me in terms of Section 19 of the Securities and Exchange Board of India Act, 1992, hereby dispose of the show cause notice dated August 7, 2017 served on Mr. Jayendra Chandulal Sheth (PAN: AEUPS9690E) without any directions. 22. The order shall come into force with immediate effect.

-Sd- DATE: February 27, 2019 MADHABI PURI BUCH PLACE: Mumbai WHOLE TIME MEMBER SECURITIES AND EXCHANGE BOARD OF INDIA