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WTM/RKA /ISD / 30 /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 AND SECTION 12A OF THE SECURITIES
CONTRACTS (REGULATION) ACT, 1956
IN THE MATTER OF MISHKA FINANCE AND TRADING LIMITED
1. Pursuant to detection of a huge rise in the traded volume and price of the shares of Mishka
Finance and Trading Limited {formerly known as Pyramid Finance and Trading Limited and
hereinafter referred to as " Mishka "} on Bombay Stock Exchange Limited ("BSE") during the
period from February 14, 2013 to December 31, 2014 (hereinafter referred to as
"Examination Period"), Securities and Exchange Board of India ("SEBI") undertook
preliminary inquiry in the dealings in the said scrip.
2. On January 16, 2014, pursuant to a stock split, the face value of shares of Mishka reduced
from ₹10/- to ₹1/- per share. During the period from February 14, 2013 to February 14,
2014 ("Patch I"), the price of the scrip of Mishka opened at ₹5.50/, rose to a high of ₹499/-
(unadjusted and ₹49.90/- adjusted to Share Split) and closed at ₹499/- (unadjusted and
₹49.90/- adjusted to Share Split) with an average volume of 390 shares. During the period
February 17, 2014 to December 30, 2014 ("Patch II"), the price of the scrip moved between₹29.05/- to ₹57/- but the average volume in the scrip sharply jumped to 2,97,319 shares. An
illustration of price/volume movement in the scrip of Mishka during the Examination Period
is given below:
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3. It was noticed that trading in the scrip of Mishka was suspended from January 07, 2002 to
May 09, 2012 on account of non-payment of listing fees. Prior to that, on September 30,
2011, Mishka had a total share capital of ₹49,80,000/- comprising 4,98,000 shares of ₹10/-
each with a total of 7 shareholders (five promoters and two public). The five promoters, viz.
Embassy Finance and Consultants Pvt. Ltd., Sulab Impex Limited, Tohee Trading and Agencies Pvt. Ltd., Wave Inter Trade Pvt. Ltd. and Mr. Vijay Kumar Jain, and 2 other
entities, viz. Ms. Rashmi Jain and Mr. Ankit Jain sharing common address with Mr. Vijay
Kumar Jain at 701, Arcadia Building, Nariman Point, Mumbai 400021, are prima facie related
to each other. The entire share capital of Mishka was in physical form as on September 30,
2011. Thereafter, these 7 shareholders transferred 4,96,000 shares to 452 entities (hereinafter
referred to as "Promoter related entities ") directly / indirectly in physical form during the period
from December 11, 2011 to February 05, 2013. The list of all the Promoter related entities is
annexed as Part I of Annexure A. In the meantime, on September 24, 2012, Mishka made a
preferential allotment of 7,93,700 shares at a premium of ₹75/- per share to 46 entities (List
is annexed as Part II of Annexure A) including one promoter, viz. Pearl Arcade Trading
Private Limited. These shares allotted by Mishka were under a compulsory lock-in till
September 23, 2013. Thereafter, Mishka announced a bonus of 7 shares on every 1 share on
February 06, 2013. As a result thereof, the share capital of Mishka increased to
₹10,33,36,000/- comprising 1,03,33,600 shares of ₹10/- each. Thereafter, on January 16,
2014, Mishka split its shares from ₹10/- per shares to ₹1/- per share. Consequent to these
actions, the share capital of Mishka increased to 10,33,36,000 shares having the face value of
₹1/- each.
4. From the Annual Reports of Mishka for Financial Year ("FY") 2011-12 and FY 2012-2013, it
was observed that it is in the business of financing, investment and trading activities and it
had incurred a loss of ₹12 Lakh during FY 2011-12 and earned a profit of ₹12 Lakh during
FY 2012-13. Further, from the Annual Report of Mishka for FY 2012-2013, it is observed
that for FY ended 2012 the earning per shares ("EPS") of Mishka was ₹-2.4/- and for the FY
ended March 31, 2013, EPS was ₹0.12/-. During the Examination Period, no material
corporate announcement was made by Mishka which could support such price rise in its
scrip. Thus, the sharp rise in the price of the scrip of Mishka during the Examination Period was not supported by its fundamentals or any other genuine factor. It is interesting to note
that the shares of Mishka were suspended till May 09, 2012. Between May 10, 2012 and
September 23, 2012, there was no trading in the scrip of Mishka . Strangely, in spite of such
trifling fundamentals and tarnished track record of long period of suspension of trading and
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below par market price, Mishka was able to garner funds aggregating to ₹6,74,64,500/- from
aforesaid 46 entities through preferential allotment at a premium of ₹75/- per share within a
short span of four months of revocation of suspension. Investment in a company having
such poor and meagre fundamentals cannot prima facie be termed as a rational investment
behaviour. Such investments, as in this case, normally could be made only if the allottees hada nexus with Mishka and its directors/promoters and the issue of these shares was under a
prior arrangement between them.
5. It was observed that within a short period after the preferential allotment, a significant
increase in the price of the scrip took place which continued during and after the period of
lock in on the shares allotted to the preferential allotees. Considering the fact that prior to the
preferential allotments, no trading occurred in the scrip of Mishka , the increase in the traded
volume in the period after preferential allotment was found to be substantial and abnormal.
In light of the above, in order to observe the price volume behaviour of the scrip, the tradingin the scrip was analysed in two Patches with a focus on the following:-
The trading frequency;
The volume generated;
Contribution to price rise;
Buying behavior as observed from Last Traded Price ("LTP") data.
6. On analysis of trading activity in the scrip, it was observed that during the Examination
Period, two sets /groups of entities were mainly involved. While one group of entities was
primarily involved in pushing the price up during Patch-1 (when the volume in the scrip was
very low) by contributing to positive LTP through first trades with negligible order quantity,
the other group of entities was acting as buyer in Patch-2 in order to provide exit to
preferential allottees/Promoter related entities and in the process creating artificial volume. The
role/connection/relationship of these two groups is discussed in subsequent paragraphs.
Patch 1: February 14, 2013 to February 14, 2014:
7. During Patch 1 the scrip price opened at ₹5.50 and closed at ₹49.90/- (adjusted and ₹499/-
unadjusted). During this period, the scrip was traded with an average volume of 390 sharesper day and total volume of 73,760 shares in 189 trading days with an average of 1 trade per
day. It was observed that price of the scrip was influenced by certain entities primarily
through first trades during this period. These entities merely by putting 1 or 2 trades per day
with negligible/ very less quantity of buy order contributed significantly to the price rise.
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From LTP analysis, it was observed that price of the scrip increased from ₹5.50 to ₹49.90
(adjusted and ₹499/- unadjusted) mainly through first trades in 188 such instances.
8. It was observed that in Patch 1, out of a total of 188 instances of trades establishing new high
price in the scrip, four entities namely, Shyam Kanheyalal Vyas, Bharat Bagri, ManjulabenSukhdev Pandya and Jayesh Narendra Kesharia, established new high price on 99 instances.
The contribution of these four entities in establishing new high price was ₹251.61/- out of
total price rise of ₹339/-, which constitutes 74.23% of the total new high price. The details of
contribution to price rise by these four entities during Patch 1 are as under:
Table I : Contribution to price rise in Patch 1 by four entities.
PAN Name
Name reflected
in the InterimOrder
PositiveLTP
Contributionas a buyer
% to Total
Positive LTPContribution
ACTPV2787Q Shyam Kanheyalal Vyas First Financial Ltd 235.46 69.46
AADHB8488A Bharat Bagri BagriRadford, FirstFinancial Ltd 8.5 2.51
AAEHJ1610D Jayesh NarendraKesharia Radford 5.25 1.55
ALVPP7764JManjulaben SukhdevPandya Radford 2.4 0.71
Total 251.61 74.23
9.
It is observed that the entities named in the above Table were instrumental in contributing tothe price rise of the scrips of Radford Global Limited and First Financial Services Limited
and are already restrained from dealing in securities market in whatsoever manner vide
interim orders dated December 19, 2014 in the scrips of Radford Global Limited and First
Financial Services Limited for contributing to price rise in the respective scrips.
Patch 2: From February 17, 2014 to December 31, 2014:
10. During Patch 2, the price of the scrip opened at ₹50.85/-, touched a high of ₹57/- and
touched a low of and closed at₹
29.05/-. However, the average volume in the scrip jumpedsharply from 390 shares (as it was in Patch 1) to 2,97,319 shares per day.
11. On analysis of trading activity during Patch 2, certain related/connected entities to Mishka
were found to be net buyers to the preferential allottees / Promoter related entities and thereby
created artificial demand for the supply of shares from preferential allottees / Promoter related
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entities. During Patch 2, significant increase in the trading volume was observed and it appears
that most of the entities were acting as counterparty to the Preferential Allottees/ Promoter
related entities. Also on further examination direct/ indirect relationship was established among
these entities through Know Your Client ("KYC") details, bank statements, off-market
transactions amongst themselves, information available on the Ministry of Corporate Affairs("MCA") website, etc. List of these entities is annexed as Part III of Annexure - A and
hereinafter they shall be referred to as the " Exit Providers ". Since the Exit Providers , Preferential
Allottees and Promoter related entities have been prima facie found to be connected/related to
Mishka / its promoters, they shall hereinafter collectively be referred to as " Mishka Group".
12. Considering the large number of related/connected entities of Mishka Group, a set of 112
entities (hereinafter referred to as the "Shortlisted Group") were shortlisted on the basis of
following parameters, viz.
A.
All the Exit Providers ;B. All the Preferential Allottees who have sold Mishka's shares and;
C. All the Promoter related entities who have sold more than 2,00,000 shares.
13. The particulars of the members of the Shortlisted Group are given in the following table :
Table II: List of Shortlisted Entities:
Promoter related entities
S. No. PAN Name
1 ABBPR3992G ANIL SATYANARAYAN ROONGTA2 ACRPC4740L RITESHKUMAR AMITKUMAR CHATTERJEE
3 ACHPS7762G ATUL MORESHAWAR SAVE
4 AKKPP3508Q PARUL RUPESH PODDAR
5 AAOHS4973C SUNIL KUMAR JAIN & SONS HUF
6 AAGHR7451A RAVI KHANNA HUF
7 AAGPA3508D GAJANAND AGARWAL
8 AACPA9922H PANKAJ AGARWAL
9 AANPG3179K BHARAT GANDOTRA
10 AJVPK5048G AADIST KHANNA
11 ARIPK3181H BHAVYA KHANNA
12 AAIPK5106B JYOTI KHANNA
13 AFMPK8726N RAVI KHANNA
14 ACNPA1462H LALIT AGARWAL
15 AELPP0183N RUPESH KUMAR PODDAR
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16 AAEHD5856M DINDAYAL MALCHAND AGARWAL HUF
17 AACPA5733E KRISHAN AGARWAL
18 ACRPJ3552D SEEMA JAIN
19 BHKPS8506F JAY N SHAH
20 ABYPJ9937E SUNIL KUMAR JAIN
21 AAGPS9497R NAVINCHANDRA K SHAH
22 AAGPS9498A MALTI NAVINCHANDRA SHAH
23 AGLPP3159L ROHINI VIJAYSINGH PATWARDHAN
24 BEIPA7823N PRANIT AGARWAL
Preferential Allottees
25 AEFPS6298M BRIJ BHUSHAN SINGAL
26 AALFG1236F GOKULDHAM ENTERPRISES LLP
27 AACPD7055J NITIN KUMAR DIDWANIA
28 AAGPS6393C PRAKASH MANGILAL SURYA
29 AAAPZ1721B SHRENIK NALIN ZAVERI30 AADPK9309F MAHESH KUMAR KHATRY
31 AADPK1946Q PRAKASH CHAND KHATRY
32 ADGPC1107P TARUN KUMAR CHANDAK
33 ACAPS1025K KALAWATI SHARMA
34 AGMPS2776H PRAKASH CHAND SHARMA
35 ABYPV5751G CHIRAG MAHESHKUMAR VYAS
36 AAAPU2596F SHEETAL SANJAY UDESHI
37 ACUPJ1252F NARESH JALAN
38 AABHN4403P NARESH JALAN
39 ACFPJ2428J MAHABIR PRASAD JALAN
40 AACHM0965N MAHABIR PRASAD JALAN
41 AECPC7959J HARLEEN KAUR
42 AEJPB6903J SAVITA BANSAL
43 ABTPS0026N SMT RASHMI JAIN
44 AAJPA2349H JIGNESH M. AMIN
45 AADPJ5579L VIMAL JAIN
46 AJGPS8091J SARAD KUMAR B JAIN
47 AADPC6863A ASHOK KUMAR CHOWATIA
48 ABQPL6153L TARACHAND L SHAH49 AADPC6859J MADANLAL BABULAL CHOWATIA
50 ACSPB5838R SHANKAR BATRA
51 ABHPA9244J SADHNA RANI
52 AGEPA7936K RANIDEVI AGARWAL
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53 AADHR3405B RAVINDER KUMAR GUPTA (HUF)
Exit Providers
54 AAKPS3276J Manharlal Narottamdas Shah
55 AAACE2862P Esha Securities Ltd
56 AACCA3220D Amrit Sales Promotion Pvt Limited57 AADCS5411K Symphony Merchant Pvt Ltd
58 AABCB3052B Bazigar Trading Private Limited
59 AAGCR1715E Rangan Vincom Private Limited
60 AACCL3868N Ladios Trading Private Limited
61 AADCT8403C Topwell Properties Private Limited
62 AAMCS1712Q Signet Vinimay Private Limited
63 AAMCS1711P Sanklap Vincom P Ltd
64 AAECR0580M Runicha Merchants Private Limited
65 AAACW8004B Winall Vinimay Private Limited Ltd
66 AAPCS7492G Spice Merchants Private Limited67 AAJCA4459K Apex Commotrade Private Limited Ltd
68 AAICS0688K Skm Travels Private Limited
69 AAICS6023N Scope Vyapar Private Limited
70 AAACV8378B Vibgyor Financial Servicepvt Ltd
71 AACCH4303G Helpful Investment Advisory Private Limited
72 AABCF5486H Function Financial Consultants Private Limited
73 AAECK7329P Kapeeshwar Vintrade Private Limited
74 AAMCS8721P Sinjan Overseas Pvt Ltd
75 AABCW0317N Wonder Procon Private Limited Wppl76 AACCH8885R Helot Properties Pvt Ltd
77 AAECC9285A Cheroot Vanijya Pvt Ltd
78 AATCS3687H Sidhiman Vyapaar Private Limited
79 AAECV4988P Vishnudham Marketing Private Limited
80 AAECT5548F Triala Dealers Private Limited
81 AAICM4750C Mobixa Distributors Private Limited
82 AALCA7880J Antaryami Traders Private Limited
83 AAFCG2554B Gajgamini Merchandise Private Limited
84 AAICM6982C Muchmore Vincom Private Limited85 AAECD5782B Dreamlight Exim Private Limited
86 AAFCG4773J Goldensight Traders Private Limited87 AAACD9125E Dynamic Portfolio Management & Services Ltd
88 AABCR1974J Ritesh Commercial Holdings Limited
89 AADCR6224M Ritesh Projects Private Ltd.
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90 AAECS0352C Stardox Vinimoy Private Limited
91 AABCR3482R Raina Vyapaar Private Ltd
92 AABCR2904A R C Suppliers Private Lim Ited
93 AABCH2251E Hari Om Suppliers Pvt. Ltd.
94 AADCK9346B Kalakar Commercial Private Limited
95 AAFCB0211J Blue Horizon Commosales Private Limited
96 AAGCR8142P Rochak Vinimay Private Limited
97 AAGCR7017M Rochi Dealcom Private Limited
98 AAECD9323N Duari Marketing Private Limited
99 ACIPS8803M S N Srinivasan
100 BABPS7447D Amit Singh
101 AADCI5139E Indrawati Nirman Pvt Ltd
102 AAGCR4662J Reachsmart Construction Pvt Ltd
103 AABCO6950F Overload Financial Advisory Pvt Ltd
104 AARCS9144H Sebika Commodities Private Limited
105 AATCS4365E Samridhipurn Services Private Limited
106 AAFCR9881C Reachsmart Dealtrade Private Limited
107 AATCS6718D Swarnprakash Traders Private Limited
108 AAECD8010E Dhyaneshwar Dealers Pvt Ltd
109 AAECD8235D Dhlriti Traders Pvt Ltd
110 AAGCR6009M Ramya Mercantile Pvt Ltd
111 AAFCB4546A Badamisati Apartments Private Limited
112 ATIPM7500N Arunavo Mukherjee
14. It is observed that during Patch 2, the Preferential Allottees/Promoter related entities were the
net sellers and the Exit Providers were the net buyers, a snapshot of which is given below:-
Table III - Exit provided by Exit Providers to Preferential allottees/Promoter related entities
Category Sharessold
% of Totalallottedshares
Shares purchased from preferentialallottees/Promoter related
entities
% to ExitProviderGrossBought Volume
GrosssharesBoughtby ExitProviders
Shares boughtby ExitProviders as% to MarketBought
Volume
Preferential Allottee
18921835 61.00% - - - -
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Promoterrelatedentities
31838149 93.76% - - - -
Exit
Provider
- - 25476894 90.84% 28044592 46.47%
15.
It is observed from Table III that most of the trades were taking place between the
preferential allottees/Promoter related entities and Exit Providers . During this period, the
Preferential allottees/Promoter related entities were found to be selling and in the process
making a huge profit/gain. It was observed that Exit Providers contributed 46.47% to the
Gross buy trade during Patch 2. The details of counter parties for sale transactions by
preferential allottees/ Promoter related entities is given below:
Table - IV: Details of counter parties for sale transactions
Sr.No.
Client PAN Client Name GrossBuy inPatch 2
% toMark et Volume
Shares purchasedfrom preferentialallottes/PromtoerGroupentitiesduring post split period
% ofsharesboughtfrom preferentialallottesto thegrossBuy bytheclient
1 AAECD8235D Dhlriti Traders Pvt Ltd 8726858 14.46 8485818 97.24
2 AAGCR6009M Ramya Mercantile Pvt Ltd 5376722 8.91 5290081 98.39
3 AAPCS7492G Spice Merchants PrivateLimited
2872178 4.76 2100797 73.14
4 AAJCA4459K Apex CommotradePrivate Limited Ltd
2249188 3.73 1961565 87.21
5 AAACW8004B Winall Vinimay PrivateLimited Ltd
1090076 1.81 976671 89.6
6 AAECV4988P Vishnudham Marketing
Private Limited
666225 1.1 490025 73.55
7 AAECD5782B Dreamlight Exim PrivateLimited
579939 0.96 426525 73.55
8 AAMCS1712Q Signet Vinimay PrivateLimited
445464 0.74 361354 81.12
9 AAFCG2554B Gajgamini MerchandisePrivate Limited
408025 0.68 356151 87.29
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10 AAECD9323N Duari Marketing PrivateLimited
422360 0.7 347260 82.22
11 AAECR0580M Runicha MerchantsPrivate Limited
327650 0.54 204035 62.27
12 AATCS3687H Sidhiman Vyapaar Private
Limited
328890 0.54 313840 95.42
13 AAICS6023N Scope Vyapar PrivateLimited
310000 0.51 310000 100
14 AAACE2862P Esha Securities Ltd 295500 0.49 295500 100
15 AALCA7880J Antaryami Traders PrivateLimited
284385 0.47 260075 91.45
16 AAECC9285A Cheroot Vanijya Pvt Ltd 284250 0.47 269250 94.72
17 AAFCB4546A Badamisati ApartmentsPrivate Limited
195000 0.32 181160 92.9
18 AAECS0352C Stardox Vinimoy PrivateLimited
180000 0.3 180000 100
19 AABCO6950F Overload Financial Advisory Pvt Ltd
174260 0.29 174260 100
20 AABCR3482R Raina Vyapaar Private Ltd 166540 0.28 166540 100
21 AAMCS1711P Sanklap Vincom P Ltd 151049 0.25 131049 86.76
22 AACCH8885R Helot Properties Pvt Ltd 149650 0.25 128660 85.97
23 AAICM4750C Mobixa DistributorsPrivate Limited
137600 0.23 104250 75.76
24 AAICM6982C Muchmore VincomPrivate Limited
114400 0.19 104650 91.48
25 BABPS7447D Amit Singh 114320 0.19 114320 100
26 AAICS0688K Skm Travels PrivateLimited
111000 0.18 110900 99.91
27 AAGCR8142P Rochak Vinimay PrivateLimited
109000 0.18 90150 82.71
28 AAFCB0211J Blue HorizonCommosales Private Ltd
102570 0.17 79780 77.78
29 AABCF5486H Function FinancialConsultants PrivateLimited
87300 0.14 53300 61.05
30 AABCH2251E Hari Om Suppliers Pvt.Ltd.
81500 0.14 81450 99.94
31 ACIPS8803M S N Srinivasan 339000 0.56 296985 87.6132 AACCA3220D Amrit Sales Promotion
Pvt Limited70000 0.12 60000 85.71
33 AAACV8378B Vibgyor FinancialServicepvt Ltd
70000 0.12 0 0
34 AACCH4303G Helpful Investment Advisory Private Limited
71663 0.12 71663 100
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35 AAECT5548F Triala Dealers PrivateLimited
70000 0.12 69800 99.71
36 AADCR6224M Ritesh Projects PrivateLtd.
72195 0.12 72195 100
37 AAFCR9881C Reachsmart Dealtrade
Private Limited
57000 0.09 57000 100
38 AAMCS8721P Sinjan Overseas Pvt Ltd 56000 0.09 56000 100
39 AABCW0317N Wonder Procon PrivateLimited Wppl
50000 0.08 50000 100
40 AAGCR7017M Rochi Dealcom PrivateLimited
52500 0.09 52500 100
41 AABCR2904A R C Suppliers Private LimIted
45000 0.07 45000 100
42 AAFCG4773J Goldensight TradersPrivate Limited
38000 0.06 5000 13.16
43 AADCS5411K Symphony Merchant Pvt
Ltd
32500 0.05 32500 100
44 AABCB3052B Bazigar Trading PrivateLimited
29500 0.05 29500 100
45 AAECD8010E Dhyaneshwar Dealers PvtLtd
185500 0.31 165500 89.22
46 AACCL3868N Ladios Trading PrivateLimited
25000 0.04 25000 100
47 AADCT8403C Topwell PropertiesPrivate Limited
25000 0.04 25000 100
48 AADCK9346B Kalakar CommercialPrivate Limited
25000 0.04 25000 100
49 ATIPM7500N Arunavo Mukherjee 20000 0.03 20000 10050 AARCS9144H Sebika Commodities
Private Limited13785 0.02 13785 100
51 AATCS6718D Swarnprakash TradersPrivate Limited
15000 0.02 15000 100
52 AAACD9125E Dynamic PortfolioManagement & ServicesLtd
15955 0.03 15955 100
53 AADCI5139E Indrawati Nirman Pvt Ltd 72000 0.12 72000 100
54 AAKPS3276J Manharlal NarottamdasShah
11650 0.02 11650 100
55 AAGCR4662J Reachsmart ConstructionPvt Ltd
9900 0.02 9900 100
56 AABCR1974J Ritesh CommercialHoldings Limited
11545 0.02 11545 100
57 AAECK7329P Kapeeshwar VintradePrivate Limited
11000 0.02 11000 100
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58 AATCS4365E Samridhipurn ServicesPrivate Limited
6000 0.01 6000 100
59 AAGCR1715E Rangan Vincom PrivateLimited
2000 0 2000 100
Total 28044592 46.47 25476894 90.84
16. It is observed that 29 preferential allottees made a collective profit of ₹91.87 crore on their
total investment of ₹2.01 crore, a substantial return of approximately 4569% on their
investment in a period of 27 months (including the lock in period). It is evident from the
above analysis of trading in Patch 2 that the Exit Providers provided a hugely profitable exit to
the Preferential allottees, who also were related directly/indirectly to Mishka . The profit
earned by the allottees during Patch 2 is given below:-
Table V: Details of the trades carried out by allottees and profit calculation
S.No.
Name of Allottee
PAN of Allottee
No.ofShares Allotted
Adjustment toBonusandShareSplit
AdjustedPurchaseCost
No. ofSharessold
AverageSellingPrice
ProfitMadeon SoldShares
Sharesheld bytheentity
1
GOKULDHAMENTERPR ISES LLP
AALFG1236F
25000 2000000 1.0625 2000000 50.9599770176
0
2PRAKASHMANGILAL SURYA
AAGPS6393C
20000 1600000 1.0625 1306850 37.62 47777357
293150
3 JIGNESHM. AMIN
AAJPA2349H
11700 936000 1.0625 1066300 48.4550533906
-130300
4SHRENIKNALINZAVERI
AAAPZ1721B
12500 1000000 1.0625 1000000 52.7851717459
0
5MAHESHKUMARKHATRY
AADPK 9309F
12500 1000000 1.0625 1000000 54.9053833135
0
6 PRAKASHCHANDKHATRY
AADPK 1946Q
12500 1000000 1.0625 1000000 53.73 52664913
0
7
TARUNKUMARCHANDAK
ADGPC1107P
12500 1000000 1.0625 1000000 49.6848619650
0
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8KALAWA TISHARMA
ACAPS1025K
12500 1000000 1.0625 1000000 47.4546384450
0
9PRAKASHCHAND
SHARMA
AGMPS2776H
12500 1000000 1.0625 1000000 47.2046139608
0
10
CHIRAGMAHESHKUMAR VYAS
ABYPV 5751G
12500 1000000 1.0625 1000000 46.1845119625
0
11
NITINKUMARDIDWANI A
AACPD7055J
25000 2000000 1.0625 997385 39.5938430782
1002615
12SHEETALSANJAYUDESHI
AAAPU2596F
12500 1000000 1.0625 981850 52.1450145741
18150
13 VIMAL JAIN
AADPJ5579L
7500 600000 1.0625 600000 53.6031524600
0
14NARESH JALAN
ACUPJ1252F
12500 1000000 1.0625 592500 50.0529022944
407500
15NARESH JALAN
AABHN4403P
12500 1000000 1.0625 587500 50.1828859136
412500
16MAHABIRPRASAD JALAN
ACFPJ2428J
12500 1000000 1.0625 584000 54.2731071500
416000
17MAHABIRPRASAD
JALAN
AACHM
0965N
12500 1000000 1.0625 470000 54.89253007
25
530000
18SHANKAR BATRA
ACSPB5838R
5000 400000 1.0625 400000 50.4119739502
0
19HARLEENKAUR
AECPC7959J
12500 1000000 1.0625 356950 55.1619310416
643050
20SAVITABANSAL
AEJPB6903J
12500 1000000 1.0625 314000 55.0516950775
686000
21SARADKUMAR B JAIN
AJGPS8091J
7500 600000 1.0625 312500 51.1315645969
287500
22
SMT
RASHMI JAIN
ABTPS0026N 12500 1000000 1.0625 277500 55.07 14988106 722500
23
ASHOKKUMARCHOWATI A
AADPC6863A
7500 600000 1.0625 259500 51.5213092706
340500
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24 TARACHAND LSHAH
ABQPL6153L
7500 600000 1.0625 245500 52.6212657981
354500
25
MADANL AL
BABULALCHOWATI A
AADPC
6859J 7500 600000 1.0625 228500 51.38
114967
19 371500
26BRIJBHUSHAN SINGAL
AEFPS6298M
49000 3920000 1.0625 120000 55.006472580.8
3800000
27SADHNARANI
ABHPA9244J
12500 1000000 1.0625 100000 55.205413750
900000
28
RANIDEV I AGARWAL
AGEPA7936K
12500 1000000 1.0625 77000 48.743671437.5
923000
29RAVINDER KUMARGUPTA
AADHR 3405B
2000 160000 1.0625 44000 55.072376300
116000
17. The transactions wherein the entities of Exit Providers bought most of the shares sold by the
Preferential allottees and Promoter related entities cannot be just a coincidence particularly when
sellers are connected with Mishka / its promoters / directors by virtue of being Preferential
allottees/ Promoter related entities and other factors mentioned in Annexure A. It is interesting
to note that prior to Patch 1, the entire share capital of Mishka was with Preferential
Allottees, Promoters and the entities who received shares from the promoters. Hence, duringPatch 1 the entities related to Promoter Group sold the shares in very less quantity and
certain entities pushed up the price of the scrip by buying these shares from them. It is also
observed that during Patch 1 the shares of Mishka were not in demand by the general
investors of the market and saw a very low volume on most of the trading days and hence
could not have commanded the price as observed in Patch 2. In any market, a sudden supply,
if not matched by similar demand, leads to price fall. Considering the same, any rational
investor would not have dumped a large number of shares without facing the risk of a
significant price fall until and unless he was sure of the demand side absorbing the supply. In
this peculiar case, the Exit Providers created the demand against the supply from thepreferential allotters/Promoter related entities . In the whole process, the principle of price
discovery was kept aside and the market lost its purpose. It is evident from the above analysis
that the Exit Providers provided a hugely profitable exit to the Preferential allottees/ Promoter
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related entities . This could be possible only if the Preferential Allottees, Promoter related
entities, Exit Providers , Mishka and its promoter/ directors were hand in glove with each other.
18. From the above examination and factors as described in Annexure A, I am of the prima facie
view that the Preferential allottees, Promoter related entities , Mishka and Exit Providers are
connected to each other. In this regard, I note that the Hon'ble SAT has in many cases such
as Classic Credit Ltd. vs. SEBI (SAT Appeal no. 68/2003, Order dated December 8, 2006),
Classic Credit Ltd. vs. SEBI (SAT Appeal no. 76/ 2003, Order dated January 9, 2007) and
Veronica Financial Services Ltd. vs. SEBI (SAT Order dated August 24, 2012) has held that
connection/ relations can be established on the basis of factors including common addresses,
common directors/ shareholders, etc.
19. It is pertinent to mention that the key to the scheme of operations employed by Mishka Group
prima facie lies in the preferential allotment of shares made by Mishka . Due to a lock-in of one
year on shares any gains made on the sale of such shares makes the allottees eligible for long
term capital gains ("LTCG"). Further, the promoters of Mishka by offloading the shares to its
connected entities in physical form one year prior to resumption of trading in the scrip, have
also made the transferees eligible for LTCG. From the observations of the preliminary
inquiry it is inter alia noted that :-
As on September 30, 2011, Mishka had only 7 shareholders (5 under promoters and 2
under public category).
Thereafter, the aforesaid 7 shareholders transferred a total of 4,96,000 shares to 452
entities directly/indirectly during the period from December 11, 2011 to February 05,
2013.
In the meantime, Mishka also allotted 7,93,700 shares to 46 related/ associated entities
including 1 promoter, viz. Pearl Arcade Trading Private Limited, at an exorbitant
premium of ₹75/- per share on September 24, 2012.
Then, on February 06, 2013, Mishka announced bonus shares in the ratio of 7:1. As a
result, the share capital of Mishka increased to 1,03,33,600 shares.
Thereafter, suddenly trading started in the scrip of Mishka from February 14, 2013. In
Patch 1, i.e. from February 14, 2013 to February 14, 2014, the price of the scrip graduallyincreased from ₹5.50/- to ₹499/- (unadjusted) and ₹49.90/- (adjusted) with very low
volume.
Prior to February 14, 2013, the entire share capital of Mishka was with Promoters,
Promoter related entities and Preferential allottees.
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Once the price of the scrip increased exponentially, Mishka announced a stock-split in the
ratio of 1:10 on January 16, 2014 to make a passage for preferential allottees to exit since
the stock split would reduce the per share price and increase liquidity.
One month after the stock split, i.e. from February 17, 2014 the preferential allottees and
promoter related entities started selling the shares to entities connected / related, directly orindirectly, to Mishka , thereby making huge profits.
The said price movement was not backed by fundamentals of Mishka and its financials.
20. From the facts stated above, it can safely be assumed that the entire modus operandi of allotting
shares on a preferential basis at a premium, announcing a stock split and then bringing in
connected entities to provide exit was a scheme devised to make ill-gotten gains. Further, the
modus operandi of pumping the share price artificially and then dumping the price so that the
same cycle could be repeated, demonstrates the mala fide of the Mishka Group. Also the
mechanism is presumably being used to deceive the authorities by laundering black money
and making tax-free profits.
21. Further, from the copy of the special resolution passed under section 81(1A) of the
Companies Act, 1956 submitted by Mishka to BSE, it is noted that Mishka had disclosed to its
shareholders that the purpose of aforesaid fund raising through preferential allotment was to
meet requirements for:
a)
capital expenditure including acquisition of company/business;
b) funding long term working capital requirements;
c)
marketing;
d) setting up of offices abroad and;
e) for other approved corporate purposes.
22. As part of its inquiry, SEBI had advised the directors, Company Secretary and promoters of
Mishka vide emails/letters to appear for a meeting on December 05, 2014 and again on
December 12, 2014 at SEBI-Head Office. On both instances, Mishka's management failed to
appear for the meeting. Thereafter, SEBI by way of an email as well as letter dated January
16, 2015, advised Mishka to submit its bank account details highlighting the credit entries
pertaining to proceeds of preferential allotment and debit entries pertaining to utilisation of
preferential allotment along with documentary evidence. The said details were sought in order
to ascertain the genuineness of the preferential allotment made by Mishka . Mishka vide letter
dated January 22, 2015 submitted its reply. From the bank statement submitted by Mishka , it
is observed that out of the total amount i.e. ₹6,74,64,500 raised by Mishka through this
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allotment, ₹2,00,00,000 were given to the share broker CD Equisearch Pvt. Ltd, ₹2,21,21,221
to Esha Securities Limited and ₹2,00,00,000 to one Mr. Jitendra Dewoolkar. This amounted
to total ₹6,21,21,221 (almost 92% of the proceeds). The aforesaid utilisation of proceeds of
preferential allotment does not appear to be for any of the aforesaid purposes as Mishka did
not use them for either capital expenditure or acquisition of company/business or towards working capital or setting up office abroad or for marketing.
23. In view of the above, I note that the funds received as proceeds of preferential allotment
were transferred to various entities and were not used for the purposes as envisaged in the
special resolution passed under section 81(1A) of the Companies Act, 1956. Further, as per
the communication received from BSE vide email dated January 21, 2015, no corporate
announcement has been made by Mishka as required under Clause 43 (a) of listing agreement
indicating the non-utilisation of the proceeds from the preferential allotment for the purpose
they were raised. Thus, Mishka has prima facie failed to comply with Clause 43 (a) of listingagreement which reads as follows:
Clause 43 (a)
"The Company agrees that it will furnish on a quarterly basis a statement to the Exchange indicating the
variations between projected utilisation of funds and / or projected profitability statement made by it in its
prospectus or letter of offer or object /s stated in the explanatory statement to the notice for the general
meeting for considering preferential issue of securities and the actual utilisation of funds and/or actual
profitability"
24. In the facts and circumstances of this case, I am of the view that the preferential allotment
was used as a tool for implementation of the dubious plan, device and artifice of Exit
Providers, preferential allottees and Promoter related entities . One could argue that in order to
make LTCG, the preferential allottees in question could have bought in secondary market
and waited for a year before selling the shares. In the instant case, probably the preferential
allotment route was preferred over secondary market route because the share capital of
Mishka prior to preferential allotment was very small, i.e., 4,98,000 shares (Face Value: ₹10)
to accommodate the required fictitious LTCG of₹
254 crore approximately. As such thecapital expansion through preferential allotment and stock split provided much bigger source
to the persons involved in terms of volume and price manipulation to facilitate the whole
operation.
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25. From the above facts and circumstances it can reasonably be inferred that the preferential
allottees along with Promoter related entities acting in concert with Exit Providers have misused
the stock exchange system to generate fictitious LTCG. It is pertinent to note that LTCG is
tax exempt. Further, it appears that Mishka did not utilize the proceeds of preferential
allotment as per the resolution submitted by it to the exchange. It is noted that SEBI hasalready passed interim orders in the matters of Moryo Industries Limited, Radford Global
Limited and First Financial Services Limited where the modus operandi was that the price of the
scrip increased substantially only on account of the trading activity of the group/related
entities when substantial number of shares were locked in and non transferable/tradable.
Further, the preferential allottees acting in concert with the specified groups have misused the
stock exchange system to generate fictitious LTCG so as to convert their unaccounted
income into accounted one with no payment of taxes as LTCG is tax exempt, and funds
brought in by way of preferential allotment was invested in the shares of connected
companies and by way of purported loans to a group of entities connected with the aforesaidcompanies for the purpose other than those disclosed.
26. Since prior to the trading in its scrip during the Examination Period, Mishka did not have any
significant financial standing in the securities market, in my view, the only way it could have
increased its share value is by way of market manipulation. In this case, it is noted that the
traded volume and price of the scrip increased substantially only after Exit Providers,
Preferential Allottees and Promoter related entities started trading in the scrip. The average
volume increased by 762% during Patch 2. Exit Providers were trading in the scrip above the
LTP and their trades created artificial volumes and manipulated the price of the scrip during
the Examination Period. It is further noted that on the days when Mishka Group was not
trading, the trading volumes in the scrip were very low and the substantial increase in traded
volumes as observed in this case was mainly due to their trading. I further note that Exit
Providers, Preferential allottees and Promoter related entities traded amongst themselves as
substantiated by their matching contribution to net buy and net sell in Patch II. There was no
change in the beneficial ownership of the substantial number of traded shares as the buyers
and sellers both were part of the common group and were acting in concert to provide
LTCG benefits to the Preferential allottees and Promoter related entities. In view of the
above, I prima facie find that Exit Providers, Preferential allottees and Promoter related entities used
securities market system to artificially increase volume and price of the scrip for creating
bogus non taxable profits (i.e. LTCG).
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27. In addition to the above it is noted that prior to February 14, 2013, i.e. from when the trading
in the scrip started, the entire share capital of Mishka was with the promoters, Promoter related
entities and preferential allottees. During the period from February 14, 2013 to February 14,
2014, the price of the scrip increased by around 100 times with the trading volume as meager
as 390 shares per day. The trading volume suddenly increased to 2,97,319 shares per dayduring the period from February 17, 2014 to December 31, 2014, when Exit Providers ,
preferential allottees and Promoter related entities started trading in the scrip. The prima facie
modus operandi appears to be same as that used in the matter of Radford Global Limited where
the stock exchange mechanism was used for the purpose of availing LTCG tax benefit and
Mishka was found actively involved in the whole design to misuse stock exchange mechanism
to generate bogus LTCG.
28. I am of the considered view that the scheme, plan, device and artifice employed in this case,
apart from being a possible case of money laundering or tax evasion which could be seen bythe concerned law enforcement agencies separately, is prima facie also a fraud in the securities
market in as much as it involves manipulative transactions in securities and misuse of the
securities market. The manipulation in the traded volume and price of the scrip by a group of
connected entities has the potential to induce gullible and genuine investors to trade in the
scrip and harm them. As such the acts and omissions of Exit Providers, Preferential allottees and
Promoter related entities are ‘ fraudulent’ as defined under regulation 2(1)(c) of the SEBI
(Prohibition of Fraudulent and Unfair Trade Practices relating to Securities Market)
Regulations, 2003 (‘PFUTP Regulations’) and are in contravention of the provisions of
regulations 3(a), (b), (c) and (d) and 4(1), 4(2)(a), (b), (e) and (g) thereof and section 12A(a),
(b) and (c) of the SEBI Act, 1992. The said provisions are reproduced hereunder:-
SEBI ACT
Prohibition of manipulative and deceptive devices, insider trading and
substantial acquisition of securities or control.
"12A. No person shall directly or indirectly —
(a) use or employ, in connection with the issue, purchase or sale of any securities listed or proposed to be
listed on a recognized stock exchange, any manipulative or deceptive device or contrivance in
contravention of the provisions of this Act or the rules or the regulations made thereunder;
(b) employ any device, scheme or artifice to defraud in connection with issue or dealing in securities which
are listed or proposed to be listed on a recognised stock exchange;
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(c) engage in any act, practice, course of business which operates or would operate as fraud or deceit upon
any person, in connection with the issue, dealing in securities which are listed or proposed to be listed on a
recognised stock exchange, in contravention of the provisions of this Act or the rules or the regulations
made thereunder;"
PFUTP REGULATIONS, 2003
"Prohibition of certain dealings in securities
3. No person shall directly or indirectly —
(a) buy, sell or otherwise deal in securities in a fraudulent manner;
(b) use or employ, in connection with issue, purchase or sale of any security listed or proposed to be listed
in a recognized stock exchange, any manipulative or deceptive device or contrivance in contravention of the
provisions of the Act or the rules or the regulations made there under;
(c) employ any device, scheme or artifice to defraud in connection with dealing in or issue of securities
which are listed or proposed to be listed on a recognized stock exchange;
(d) engage in any act, practice, course of business which operates or would operate as fraud or deceit upon
any person in connection with any dealing in or issue of securities which are listed or proposed to be listed
on a recognized stock exchange in contravention of the provisions of the Act or the rules and the
regulations made there under.
4. Prohibition of manipulative, fraudulent and unfair trade practices
(1) Without prejudice to the provisions of regulation 3, no person shall indulge in a fraudulent or an
unfair trade practice in securities.
(2) Dealing in securities shall be deemed to be a fraudulent or an unfair trade practice if it involves fraud
and may include all or any of the following, namely:-
(a) indulging in an act which creates false or misleading appearance of trading in the securities market;
(b) dealing in a security not intended to effect transfer of beneficial ownership but intended to operate only
as a device to inflate, depress or cause fluctuations in the price of such security for wrongful gain or
avoidance of loss;
(c)………………………………………………………………
(d)…………………………………………………… ……………
(e)any act or omission amounting to manipulation of the price of a security;(f)…………………………………………………… ……………….
(g) entering into a transaction in securities without intention of performing it or without intention of
change of ownership of such security; "
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29. I note that the directors of Mishka during the relevant time (i.e. Ankit Garodia, Jugalkishore
P Sharma, Kumar Vasishtha and Rameshwar Manohar Wagh), being in control of the day to
day affairs of Mishka , had the knowledge of its acts and omissions. They were also under an
obligation to ensure that acts and transactions of Mishka were not in violation of any of the
applicable provisions of SEBI Regulations or other applicable laws. I, therefore, prima faciefind that these directors as well as Mishka were responsible for Mishka 's acts and omissions
in this case.
30. I am of the opinion that a detailed investigation of the entire scheme employed in this case is
necessary to find out the role of any other entity therein including LTP contributors,
connection amongst the concerned entities and the ultimate owners of funds used for
manipulating the price of the scrip. Therefore, while SEBI would investigate into the
probable violations of the securities laws, the matter may also be referred to other law
enforcement agencies such as Income Tax Department, Enforcement Directorate andFinancial Intelligence Unit for necessary action at their end as may be deemed appropriate by
them.
31. SEBI strives to safeguard the interests of a genuine investor in the Indian securities market.
The acts of artificially increasing the price of scrip mislead investors and the fundamental
tenets of market integrity get violated. Under the facts and circumstances of this case, I prima
facie find that the acts and omissions of Mishka Group as described above are inimical to the
interests of participants in the securities market. Therefore, allowing the entities that are prima
facie found to be involved in such fraudulent, unfair and manipulative transactions to continueto operate in the market would shake the confidence of the investors in the securities market.
32. I have considered the observations in the preliminary inquiry and noted that the shortlisted
entities as mentioned in Table II are connected directly/indirectly with Mishka / its promoters
on account of factors described in Annexure A. The five promoters who were holding the
shares in physical form had transferred their holding in off-market to certain entities as
mentioned in Table II. Further, Mishka also allotted shares under preferential allotment. Once
the shares were allotted/ transferred to the preferential allottees/promoter related group,
certain entities started moving the price of the scrip upwards by trading in very low volumes. The counter parties of these entities were those entities who received shares from the
promoters in physical form. After lock-in of 1 year on preferential shares was over, the Exit
Providers gave exit opportunity to the preferential allottees as well as promoter related entities.
From the bank statement of Mishka , I find that Mishka has transferred funds to some of the
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Exit Providers . I also note that the shortlisted entities have contributed majorly to the market
volume both at buy and the sell side.
33. Further I note that, vide Interim Orders dated December 19, 2014, Mr. Shyam Kanhaiyalal
Vyas and Mr. Bharat Bagri have already been restrained from accessing securities market
directly or indirectly in whatsoever manner in the matter of First Financial Services Limited
and Mr. Bharat Bagri, Mr. Jayesh Narendra Kesharia and Ms. Manjulaben Sukhdev Pandya
have already been restrained from accessing securities market directly or indirectly in
whatsoever manner in the matter of Radford Global Limited for suspected price
manipulation in the respective scrips. Further, Mishka Finance and Trading Limited, Spice
Merchants Private Limited, Apex Commotrade Private Limited, Winall Vinimay Private
Limited and Signet Vinimay Private Limited have also been restrained from accessing
securities market directly or indirectly, in whatsoever manner, in the matter of Radford
Global Limited for suspected volume manipulation and for giving exit opportunity topreferential allottees of Radford Global Limited.
34. Based on the aforesaid findings and taking into consideration the similar modus operandi of
market manipulation adopted in similar matter of Radford Global Ltd, as observed by SEBI
in its Order, it prima facie appears that certain market manipulations are taking place in the
scrip of Mishka. I note that currently major portion of the shareholding (around 66.17%) lies
with the preferential allottees, promoter related entities, exit providers and the promoters of Mishka.
It is also pertinent to mention that vide SEBI's Order in the matter of Radford Global Ltd,
Mishka itself has been restrained from buying, selling or dealing in the securities market, tillfurther directions and the said restraint is in operation as on date. Considering the above, I
am of the view that as an interim, preventive and remedial measure and to maintain orderly
development in the securities market, in the interests of securities market and investors, it
would also be necessary to take immediate steps regarding trading in the scrip of Mishka on
the stock exchange.
35. Considering these facts and the indulgence of a listed company in such a fraudulent scheme,
plan, device and artifice as prima facie found in this case, I am convinced that this is a fit case
where, pending investigation, effective and expeditious preventive and remedial action isrequired to be taken by way of ad interim ex -parte in order to protect the interests of investors
and preserve the safety and integrity of the market.
36. In view of the foregoing, in order to protect the interests of investors and the integrity of the
securities market, I, in exercise of the powers conferred upon me in terms of section 19 read
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with sections 11(1), 11(4) and 11B of the SEBI Act, 1992, pending inquiry/investigation and
passing of final order in the matter, hereby issue the following directions:
a) Following persons/entities are restrained from accessing the securities market and
buying, selling or dealing in securities, either directly or indirectly, in any manner, till
further directions:-
S. No. PAN Name
1 AAACP2548R Mishka Finance and Trading Limited
Mishka's Promoters
2 AAACW0576A WAVE INTER TRADES PVT LTD
3 AAACE1313P EMBASSY FINANCE & CONSULTANTS P LTD
4 AAACT1354P TOHEE TRADING & AGENCIES PVT LTD
5 AAICS7362Q SULABH IMPEX LTD
6 AAFCP6925M PEARL ARCADE TRADING PRIVATE LIMITED
7 AAAPJ3197K VIJAY KUMAR JAINMishka's Directors
8 ARRPG4567A Ankit Garodia
9 ABLPS6840A Jugalkishore Pralhadrai Sharma
10 AKNPV5025B Amit Kumar Vasishtha
11 ABLPW8901G Rameshwar Manohar Wagh
Promoter related entities
12 ABBPR3992G ANIL SATYANARAYAN ROONGTA
13 ACRPC4740L RITESHKUMAR AMITKUMAR CHATTERJEE
14 ACHPS7762G ATUL MORESHAWAR SAVE
15 AKKPP3508Q PARUL RUPESH PODDAR
16 AAOHS4973C SUNIL KUMAR JAIN & SONS HUF
17 AAGHR7451A RAVI KHANNA HUF
18 AAGPA3508D GAJANAND AGARWAL
19 AACPA9922H PANKAJ AGARWAL
20 AANPG3179K BHARAT GANDOTRA
21 AJVPK5048G AADIST KHANNA
22 ARIPK3181H BHAVYA KHANNA
23 AAIPK5106B JYOTI KHANNA
24 AFMPK8726N RAVI KHANNA
25 ACNPA1462H LALIT AGARWAL
26 AELPP0183N RUPESH KUMAR PODDAR27 AAEHD5856M DINDAYAL MALCHAND AGARWAL HUF
28 AACPA5733E KRISHAN AGARWAL
29 ACRPJ3552D SEEMA JAIN
30 BHKPS8506F JAY N SHAH
31 ABYPJ9937E SUNIL KUMAR JAIN
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32 AAGPS9497R NAVINCHANDRA K SHAH
33 AAGPS9498A MALTI NAVINCHANDRA SHAH
34 AGLPP3159L ROHINI VIJAYSINGH PATWARDHAN
35 BEIPA7823N PRANIT AGARWAL
36 AABHA9528A ANIL SATYANARAYAN ROONGTA HUF
Preferential Allottees 37 AEFPS6298M BRIJ BHUSHAN SINGAL
38 AAAHB6923R BRIJ BHUSHAN SINGHAL (HUF)
39 AALFG1236F GOKULDHAM ENTERPRISES LLP
40 AACPD7055J NITIN KUMAR DIDWANIA
41 AAGPS6393C PRAKASH MANGILAL SURYA
42 AAAPZ1721B SHRENIK NALIN ZAVERI
43 AADPK9309F MAHESH KUMAR KHATRY
44 AADPK1946Q PRAKASH CHAND KHATRY
45 ADGPC1107P TARUN KUMAR CHANDAK
46 ACAPS1025K KALAWATI SHARMA47 AGMPS2776H PRAKASH CHAND SHARMA
48 ABYPV5751G CHIRAG MAHESHKUMAR VYAS
49 AAAPU2596F SHEETAL SANJAY UDESHI
50 ACUPJ1252F NARESH JALAN
51 AABHN4403P NARESH JALAN (HUF)
52 ACFPJ2428J MAHABIR PRASAD JALAN
53 AACHM0965N MAHABIR PRASAD JALAN (HUF)54 AECPC7959J HARLEEN KAUR
55 AEJPB6903J SAVITA BANSAL
56 ABTPS0026N SMT RASHMI JAIN
57 AAJPA2349H JIGNESH M. AMIN
58 AADPJ5579L VIMAL JAIN
59 AJGPS8091J SARAD KUMAR B JAIN
60 AADPC6863A ASHOK KUMAR CHOWATIA
61 ABQPL6153L TARACHAND L SHAH
62 AADPC6859J MADANLAL BABULAL CHOWATIA
63 ACSPB5838R SHANKAR BATRA
64 ABHPA9244J SADHNA RANI
65 AGEPA7936K RANIDEVI AGARWAL
66 AADHR3405B RAVINDER KUMAR GUPTA (HUF)
Exit Providers 67 AAKPS3276J Manharlal Narottamdas Shah
68 AAACE2862P Esha Securities Ltd
69 AACCA3220D Amrit Sales Promotion Pvt Limited
70 AADCS5411K Symphony Merchant Pvt Ltd
71 AABCB3052B Bazigar Trading Private Limited
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72 AAGCR1715E Rangan Vincom Private Limited
73 AACCL3868N Ladios Trading Private Limited
74 AADCT8403C Topwell Properties Private Limited
75 AAMCS1712Q Signet Vinimay Private Limited
76 AAMCS1711P Sanklap Vincom P Ltd
77 AAECR0580M Runicha Merchants Private Limited78 AAACW8004B Winall Vinimay Private Limited Ltd
79 AAPCS7492G Spice Merchants Private Limited
80 AAJCA4459K Apex Commotrade Private Limited Ltd
81 AAICS0688K Skm Travels Private Limited
82 AAICS6023N Scope Vyapar Private Limited
83 AAACV8378B Vibgyor Financial Servicepvt Ltd
84 AACCH4303G Helpful Investment Advisory Private Limited
85 AABCF5486H Function Financial Consultants Private Limited
86 AAECK7329P Kapeeshwar Vintrade Private Limited
87 AAMCS8721P Sinjan Overseas Pvt Ltd88 AABCW0317N Wonder Procon Private Limited Wppl
89 AACCH8885R Helot Properties Pvt Ltd
90 AAECC9285A Cheroot Vanijya Pvt Ltd
91 AATCS3687H Sidhiman Vyapaar Private Limited
92 AAECV4988P Vishnudham Marketing Private Limited
93 AAECT5548F Triala Dealers Private Limited
94 AAICM4750C Mobixa Distributors Private Limited
95 AALCA7880J Antaryami Traders Private Limited
96 AAFCG2554B Gajgamini Merchandise Private Limited
97 AAICM6982C Muchmore Vincom Private Limited98 AAECD5782B Dreamlight Exim Private Limited
99 AAFCG4773J Goldensight Traders Private Limited
100 AAACD9125E Dynamic Portfolio Management & Services Ltd
101 AABCR1974J Ritesh Commercial Holdings Limited
102 AADCR6224M Ritesh Projects Private Ltd.
103 AAECS0352C Stardox Vinimoy Private Limited
104 AABCR3482R Raina Vyapaar Private Ltd
105 AABCR2904A R C Suppliers Private Lim Ited
106 AABCH2251E Hari Om Suppliers Pvt. Ltd.
107 AADCK9346B Kalakar Commercial Private Limited
108 AAFCB0211J Blue Horizon Commosales Private Limited
109 AAGCR8142P Rochak Vinimay Private Limited
110 AAGCR7017M Rochi Dealcom Private Limited
111 AAECD9323N Duari Marketing Private Limited
112 ACIPS8803M S N Srinivasan
113 BABPS7447D Amit Singh
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114 AADCI5139E Indrawati Nirman Pvt Ltd
115 AAGCR4662J Reachsmart Construction Pvt Ltd
116 AABCO6950F Overload Financial Advisory Pvt Ltd
117 AARCS9144H Sebika Commodities Private Limited
118 AATCS4365E Samridhipurn Services Private Limited
119 AAFCR9881C Reachsmart Dealtrade Private Limited120 AATCS6718D Swarnprakash Traders Private Limited
121 AAECD8010E Dhyaneshwar Dealers Pvt Ltd
122 AAECD8235D Dhlriti Traders Pvt Ltd
123 AAGCR6009M Ramya Mercantile Pvt Ltd
124 AAFCB4546A Badamisati Apartments Private Limited
125 ATIPM7500N Arunavo Mukherjee
LTP Contributors
126 ACTPV2787Q Shyam Kanheyalal Vyas
127 AADHB8488A Bharat Bagri (HUF)
128 AAEHJ1610D Jayesh Narendra Kesharia (HUF)129 ALVPP7764J Manjulaben Sukhdev Pandya
b) Trading in the securities of Mishka Finance and Trading Limited shall be suspended
till further directions.
37. This order shall come into force with immediate effect. The stock exchanges and the
depositories are directed to ensure that all the above directions are strictly enforced.
38. This order is without prejudice to the right of SEBI to take any other action that may be
initiated against the aforementioned entities in accordance with law. The persons/entities
against whom this order is passed may file their objections, if any, within twenty one days
from the date of this order and, if they so desire, avail themselves of an opportunity of
personal hearing before SEBI, on a date and time to be fixed on a specific request, received
from the said persons/entities.
Sd/-
Date: April 17th, 2015 RAJEEV KUMAR AGARWAL
Place: Mumbai WHOLE TIME MEMBER
SECURITIES AND EXCHANGE BOARD OF INDIA
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Annexure - A
Company Directors and its Promoter
S.No.
PAN Name Relationship
1 AAACP2548R Mishka Finance and Trading Limited
Mishka Finance Ltd ( Bank of Baroda: A/c No: 12920200000506 ) transferred funds to Pine Animation Ltd ( Allahbad Bank: A/c No:50103075412 ) who also has fund transaction withBlue Circle Services Ltd, who is observed to havefund transactions with Amrit Sales Promotion Pvt.Ltd.(HDFC Bank-A/c No: 00080340006392 ) .
2 AAACW0576A WAVE INTER TRADES PVT LTD
Promoter of Mishka as per share holding patternfor September 2011.
3 AAACE1313P EMBASSYFINANCE &
CONSULTANTS PLTD
Promoter of Mishka as per share holding patternfor September 2011.
4 AAACT1354P TOHEE TRADING& AGENCIES PVTLTD
Promoter of Mishka as per share holding patternfor September 2011.
5 AAICS7362Q SULABH IMPEXLTD
Promoter of Mishka as per share holding patternfor September 2011.
6 AAFCP6925M PEARL ARCADE TRADINGPRIVATE LIMITED
Promoter of Mishka as per Shareholding patternfor September 2012.
7 AAAPJ3197K VIJAY KUMAR
JAIN
Promoter of Mishka as per share holding pattern
for September 2011.8 AAGPJ3942C ANKIT JAIN Share Common Address with Mr. Vijay Kumar
Jain.
9 AAGPJ3943D RASHMI JAIN Share Common Address with Mr. Vijay Kumar Jain.
Part I-Promoter related entities
S.No.
PAN Name Relationship
10 AEPPS9885J ANJALI ATUL SAVE ANJALI ATUL SAVE received shares in physical
form from EMBASSY FINANCE &CONSULTANTS P LTD
11 ACHPS7762G ATULMORESHAWARSAVE
ATUL MORESHAWAR SAVE received shares inphysical form from EMBASSY FINANCE &CONSULTANTS P LTD
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12 ATLPM3500D CHANCHALMUNDHRA
CHANCHAL MUNDHRA received shares inphysical form from EMBASSY FINANCE &CONSULTANTS P LTD
13 AAEHD5856M
DINDAYALMALCHAND
AGARWAL HUF
DINDAYAL MALCHAND AGARWAL HUFreceived shares in physical form from EMBASSY
FINANCE & CONSULTANTS P LTD14 ABMPM7213N JAGDISH PRASAD
MUNDHRA JAGDISH PRASAD MUNDHRA received sharesin physical form from EMBASSY FINANCE &CONSULTANTS P LTD
15 AAHHM8275N
JAGDISH PRASADMUNDHRA HUF
JAGDISH PRASAD MUNDHRA HUF receivedshares in physical form from EMBASSYFINANCE & CONSULTANTS P LTD
16 AECPC0899M JITENDRAHIRALALCHHATRISHA
JITENDRA HIRALAL CHHATRISHA receivedshares in physical form from EMBASSYFINANCE & CONSULTANTS P LTD
17 AAIHK2913E KAILASH S
PARASRAMPURIAHUF
KAILASH S PARASRAMPURIA HUF received
shares in physical form from EMBASSYFINANCE & CONSULTANTS P LTD
18 ACNPA1462H LALIT AGARWAL LALIT AGARWAL received shares in physicalform from EMBASSY FINANCE &CONSULTANTS P LTD
19 AAAPW9319A MEGHA RAVI WATTAMWAR
MEGHA RAVI WATTAMWAR received sharesin physical form from EMBASSY FINANCE &CONSULTANTS P LTD
20 CBRPK3025K NIDHI N KEDIA NIDHI N KEDIA received shares in physicalform from EMBASSY FINANCE &
CONSULTANTS P LTD21 AACHN4765M
NIRMAL KUMAR VARUN KUMARHUF
NIRMAL KUMAR VARUN KUMAR HUFreceived shares in physical form from EMBASSYFINANCE & CONSULTANTS P LTD
22 ACQPM1847D NIRMALA DEVIMUNDRA
NIRMALA DEVI MUNDRA received shares inphysical form from EMBASSY FINANCE &CONSULTANTS P LTD
23 AHPPK4767L NITIN S KEDIA NITIN S KEDIA received shares in physical formfrom EMBASSY FINANCE & CONSULTANTSP LTD
24 AIDPC8188J PAVAN JITENDRA
CHHATRISHA
PAVAN JITENDRA CHHATRISHA received
shares in physical form from EMBASSYFINANCE & CONSULTANTS P LTD
25 AGLPP9975C PRAMOD KPARASRAMPURIA
PRAMOD K PARASRAMPURIA received sharesin physical form from EMBASSY FINANCE &CONSULTANTS P LTD
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26 BEIPA7823N PRANIT AGARWAL PRANIT AGARWAL received shares in physicalform from EMBASSY FINANCE &CONSULTANTS P LTD
27 ADUPC7841C PRASHANT JITENDRA
CHHATRISHA
PRASHANT JITENDRA CHHATRISHAreceived shares in physical form from EMBASSY
FINANCE & CONSULTANTS P LTD28 AALHR3103E RAVI B
WATTAMWAR HUFRAVI B WATTAMWAR HUF received shares inphysical form from EMBASSY FINANCE &CONSULTANTS P LTD
29 AACPW5728R RAVI BHASKAR WATTAMWAR
RAVI BHASKAR WATTAMWAR receivedshares in physical form from EMBASSYFINANCE & CONSULTANTS P LTD
30 ACRPC4740L RITESHKUMAR AMITKUMARCHATTERJEE
RITESHKUMAR AMITKUMARCHATTERJEE received shares in physical formfrom EMBASSY FINANCE & CONSULTANTSP LTD
31 AJRPP8338A RITU PPARASREAMPURIA
RITU P PARASREAMPURIA received shares inphysical form from EMBASSY FINANCE &CONSULTANTS P LTD
32 AJQPP3219D SEEMA PPARASRAMPURIA
SEEMA P PARASRAMPURIA received shares inphysical form from EMBASSY FINANCE &CONSULTANTS P LTD
33 AFGPC0469L TRIPTI PCHATTERJEE
TRIPTI P CHATTERJEE received shares inphysical form from EMBASSY FINANCE &CONSULTANTS P LTD
34 ATMPK6409J VEDANSHU N
KEDIA
VEDANSHU N KEDIA received shares in
physical form from EMBASSY FINANCE &CONSULTANTS P LTD
35 AABPA6690F AJAY AGARWAL AJAY AGARWAL received shares in physicalform from EMBASSY FINANCE &CONSULTANTS P LTD
36 AALHA0585K AJAY AGARWALHUF
AJAY AGARWAL HUF received shares inphysical form from EMBASSY FINANCE &CONSULTANTS P LTD
37 AGSPK0865D ASHISH KUMAR ASHISH KUMAR received shares in physicalform from EMBASSY FINANCE &CONSULTANTS P LTD
38 AMCPS6985L BASANT KUMARSARAWGI
BASANT KUMAR SARAWGI received shares inphysical form from EMBASSY FINANCE &CONSULTANTS P LTD
39 AACCG5437G GOLCHHAENTERTAINMENTPVT LTD
GOLCHHA ENTERTAINMENT PVT LTDreceived shares in physical form from EMBASSYFINANCE & CONSULTANTS P LTD
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40 AKGPG2899H HITESH GOLCHHA HITESH GOLCHHA received shares in physicalform from EMBASSY FINANCE &CONSULTANTS P LTD
41 AAVPN4041M M NAVEEN KUMAR M NAVEEN KUMAR received shares in physicalform from EMBASSY FINANCE &
CONSULTANTS P LTD42 ACDPJ5852G MITTALAL JAIN MITTALAL JAIN received shares in physical
form from EMBASSY FINANCE &CONSULTANTS P LTD
43 AAHPB4095P RITU S SARAF RITU S SARAF received shares in physical formfrom EMBASSY FINANCE & CONSULTANTSP LTD
44 ANQPS5905F SANDEEP V SARAF SANDEEP V SARAF received shares in physicalform from EMBASSY FINANCE &CONSULTANTS P LTD
45 ACRPJ3552D SEEMA JAIN SEEMA JAIN received shares in physical formfrom EMBASSY FINANCE & CONSULTANTSP LTD
46 ACVPA2214M SHALU AGARWAL SHALU AGARWAL received shares in physicalform from EMBASSY FINANCE &CONSULTANTS P LTD
47 AJJPS0924R SHANTHA KUMARIM
SHANTHA KUMARI M received shares inphysical form from EMBASSY FINANCE &CONSULTANTS P LTD
48 AATPJ6081F ABHAY KUMAR JAIN
ABHAY KUMAR JAIN received shares inphysical form from EMBASSY FINANCE &
CONSULTANTS P LTD49 AACHA9181N ASHOK KUMAR
REDH HUF ASHOK KUMAR REDH HUF received shares inphysical form from EMBASSY FINANCE &CONSULTANTS P LTD
50 AABPP6520D MAHENDRAPARAKH
MAHENDRA PARAKH received shares inphysical form from EMBASSY FINANCE &CONSULTANTS P LTD
51 ALQPS1421G MAMTA SARAOGI MAMTA SARAOGI received shares in physicalform from EMBASSY FINANCE &CONSULTANTS P LTD
52 AFGPJ7251R MANJU JAIN MANJU JAIN received shares in physical formfrom EMBASSY FINANCE & CONSULTANTSP LTD
53 ALDPS1562M MANOJ KUMARSARAOGI
MANOJ KUMAR SARAOGI received shares inphysical form from EMBASSY FINANCE &CONSULTANTS P LTD
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54 ABEPJ7147G MOOLCHAND JAIN MOOLCHAND JAIN received shares in physicalform from EMBASSY FINANCE &CONSULTANTS P LTD
55 AYOPA2382B NIKUNJ S AGARWAL
NIKUNJ S AGARWAL received shares inphysical form from EMBASSY FINANCE &
CONSULTANTS P LTD56 ADCPJ9848A PUSHPADEVI JAIN PUSHPADEVI JAIN received shares in physical
form from EMBASSY FINANCE &CONSULTANTS P LTD
57 ACWPM0498C PUSHPADEVI JAIN PUSHPADEVI JAIN received shares in physicalform from EMBASSY FINANCE &CONSULTANTS P LTD
58 AIQPJ7756E RASHMI JAIN RASHMI JAIN received shares in physical formfrom EMBASSY FINANCE & CONSULTANTSP LTD
59 AAXHS4963F SANDEEP REDH
HUF
SANDEEP REDH HUF received shares in
physical form from EMBASSY FINANCE &CONSULTANTS P LTD
60 ACOPJ2654F SAROJ JAIN SAROJ JAIN received shares in physical formfrom EMBASSY FINANCE & CONSULTANTSP LTD
61 AGBPJ8881F SUNAYANA JAIN SUNAYANA JAIN received shares in physicalform from EMBASSY FINANCE &CONSULTANTS P LTD
62 ARAPJ5108K SWETA JAIN SWETA JAIN received shares in physical formfrom EMBASSY FINANCE & CONSULTANTSP LTD
63 AFOPJ4431P VIKAS JAIN VIKAS JAIN received shares in physical formfrom EMBASSY FINANCE & CONSULTANTSP LTD
64 AJVPK5048G AADIST KHANNA AADIST KHANNA received shares in physicalform from EMBASSY FINANCE &CONSULTANTS P LTD
65 AAIPK5106B JYOTI KHANNA JYOTI KHANNA received shares in physicalform from EMBASSY FINANCE &CONSULTANTS P LTD
66 AFMPK8726N RAVI KHANNA RAVI KHANNA received shares in physical formfrom EMBASSY FINANCE & CONSULTANTSP LTD
67 AZAPG1972C TEJAS GALA TEJAS GALA received shares in physical formfrom TOHEE TRADING & AGENCIES PVTLTD
68 AAMPM6353N
KHYATI SHAH KHYATI SHAH received shares in physical formfrom TOHEE TRADING & AGENCIES PVT
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LTD
69 AAAPS5162P SACHIN V SHAH SACHIN V SHAH received shares in physicalform from TOHEE TRADING & AGENCIESPVT LTD
70 AAXPM9091Q DAYANAND
ASSARAM MODANI
DAYANAND ASSARAM MODANI received
shares in physical form from TOHEE TRADING& AGENCIES PVT LTD
71 AADPB1550B KAUSHALKANHAYALALBAGADIA
KAUSHAL KANHAYALAL BAGADIAreceived shares in physical form from TOHEE TRADING & AGENCIES PVT LTD
72 AGOPP6473A MADHU GOPALPODDAR
MADHU GOPAL PODDAR received shares inphysical form from TOHEE TRADING & AGENCIES PVT LTD
73 AAEPS7956D POONAMKAUSHALBAGADIA
POONAM KAUSHAL BAGADIA receivedshares in physical form from TOHEE TRADING& AGENCIES PVT LTD
74 BDNPS6529M PRAMILA SURESHSARDA
PRAMILA SURESH SARDA received shares inphysical form from TOHEE TRADING & AGENCIES PVT LTD
75 ABFPM2698Q PREMLATARAMANANDMODANI
PREMLATA RAMANAND MODANI receivedshares in physical form from TOHEE TRADING& AGENCIES PVT LTD
76 AFYPM3247A RAKESHSHASHIKANTMEHTA
RAKESH SHASHIKANT MEHTA receivedshares in physical form from TOHEE TRADING& AGENCIES PVT LTD
77 ABEPM0793M RAMANAND
GANESHLALJIMODANI
RAMANAND GANESHLALJI MODANI
received shares in physical form from TOHEE TRADING & AGENCIES PVT LTD
78 AABPM7263N SONAL RAKESHMEHTA
SONAL RAKESH MEHTA received shares inphysical form from TOHEE TRADING & AGENCIES PVT LTD
79 AYPPS3019L SURESHGIRDHARILALSARDA
SURESH GIRDHARILAL SARDA receivedshares in physical form from TOHEE TRADING& AGENCIES PVT LTD
80 ADAPT3696A MEGHNASANJAYKUMAR TIBREWAL
MEGHNA SANJAYKUMAR TIBREWALreceived shares in physical form from TOHEE TRADING & AGENCIES PVT LTD
81 AAUPT1451A SANJAYKUMARSAJJANKUMAR TIBREWAL
SANJAYKUMAR SAJJANKUMAR TIBREWALreceived shares in physical form from TOHEE TRADING & AGENCIES PVT LTD
82 AAAPG9125E GOPALDASGOENKA
GOPALDAS GOENKA received shares inphysical form from TOHEE TRADING & AGENCIES PVT LTD
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83 AAVPG4863E KESHAV GOENKA KESHAV GOENKA received shares in physicalform from TOHEE TRADING & AGENCIESPVT LTD
84 AADPG1423E SUDHA GOENKA SUDHA GOENKA received shares in physicalform from TOHEE TRADING & AGENCIES
PVT LTD85 AIUPR9150N ANAND RANEJA ANAND RANEJA received shares in physicalform from TOHEE TRADING & AGENCIESPVT LTD
86 AFOPR0263B HEMRAJ RANEJA HEMRAJ RANEJA received shares in physicalform from TOHEE TRADING & AGENCIESPVT LTD
87 BNNPK9250R KAVITA RANEJA KAVITA RANEJA received shares in physicalform from TOHEE TRADING & AGENCIESPVT LTD
88 AACPA9922H PANKAJ AGARWAL PANKAJ AGARWAL received shares in physicalform from TOHEE TRADING & AGENCIESPVT LTD
89 BHKPS8506F JAY N SHAH JAY N SHAH received shares in physical formfrom TOHEE TRADING & AGENCIES PVTLTD
90 AAGPS9498A MALTINAVINCHANDRASHAH
MALTI NAVINCHANDRA SHAH receivedshares in physical form from TOHEE TRADING& AGENCIES PVT LTD
91 AAGPS9497R NAVINCHANDRA KSHAH
NAVINCHANDRA K SHAH received shares inphysical form from TOHEE TRADING & AGENCIES PVT LTD
92 AGGPP5739B ANSHUPRAKASHCHANDR A PODDAR
ANSHU PRAKASHCHANDRA PODDARreceived shares in physical form from WAVEINTER TRADES PVT LTD
93 AAAHB0041C BALKISHAN JAJUHUF
BALKISHAN JAJU HUF received shares inphysical form from WAVE INTER TRADESPVT LTD
94 AABPJ5859P BALKISHANNATHMAL JAJU
BALKISHAN NATHMAL JAJU received sharesin physical form from WAVE INTER TRADESPVT LTD
95 ASLPA3561D GAURAV SANJAY AGARWAL
GAURAV SANJAY AGARWAL received sharesin physical form from WAVE INTER TRADES
PVT LTD96 AAJPJ4245M KANTABALKISHAN JAJU
KANTA BALKISHAN JAJU received shares inphysical form from WAVE INTER TRADESPVT LTD
97 APNPJ3353H KASTURI SANJAY JOSHI
KASTURI SANJAY JOSHI received shares inphysical form from WAVE INTER TRADESPVT LTD
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98 AKWPJ4412F KETKI SANJAY JOSHI
KETKI SANJAY JOSHI received shares inphysical form from WAVE INTER TRADESPVT LTD
99 AHGPJ3412J NIDHI ALKESHRAWKA
NIDHI ALKESH RAWKA received shares inphysical form from WAVE INTER TRADES
PVT LTD100 ASFPK9445C NIPUN N KEDIA NIPUN N KEDIA received shares in physicalform from WAVE INTER TRADES PVT LTD
101 AKKPP3508Q PARUL RUPESHPODDAR
PARUL RUPESH PODDAR received shares inphysical form from WAVE INTER TRADESPVT LTD
102 AAUPK7874L PRABHA B KEDIA PRABHA B KEDIA received shares in physicalform from WAVE INTER TRADES PVT LTD
103 ABEPA0559R RANJANA MANISH AGARWAL
RANJANA MANISH AGARWAL receivedshares in physical form from WAVE INTER TRADES PVT LTD
104 AGLPP3159L ROHINI VIJAYSINGHPATWARDHAN
ROHINI VIJAYSINGH PATWARDHANreceived shares in physical form from WAVEINTER TRADES PVT LTD
105 AELPP0183N RUPESH KUMARPODDAR
RUPESH KUMAR PODDAR received shares inphysical form from WAVE INTER TRADESPVT LTD
106 ABGPJ9472Q SANJAY AMBADAS JOSHI
SANJAY AMBADAS JOSHI received shares inphysical form from WAVE INTER TRADESPVT LTD
107 AJUPK3727B SHALINI NIRMALKEDIA
SHALINI NIRMAL KEDIA received shares inphysical form from WAVE INTER TRADES
PVT LTD108 AGLPP8828J VIJAYSINGHMADHAVRAOPATWARDHAN
VIJAYSINGH MADHAVRAOPATWARDHAN received shares in physical formfrom WAVE INTER TRADES PVT LTD
109 AAAHV1190E VIJAYSINGHPATWARDHANHUF
VIJAYSINGH PATWARDHAN HUF receivedshares in physical form from WAVE INTER TRADES PVT LTD
110 ABGPJ9502P VINITA SANJAY JOSHI
VINITA SANJAY JOSHI received shares inphysical form from WAVE INTER TRADESPVT LTD
111 AAAPD4655J BHARAT
BHAWARLALDAGLIYA
BHARAT BHAWARLAL DAGLIYA received
shares in physical form from WAVE INTER TRADES PVT LTD
112 AWAPS4811P DHAWAL C SHAH DHAWAL C SHAH received shares in physicalform from WAVE INTER TRADES PVT LTD
113 AFHPP7452H JULIE VINODPARMAR
JULIE VINOD PARMAR received shares inphysical form from WAVE INTER TRADESPVT LTD
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114 AAAPD4654K LALITA BHARATDAGLIYA
LALITA BHARAT DAGLIYA received shares inphysical form from WAVE INTER TRADESPVT LTD
115 AABPP6339E MANGIBAI HPARMAR
MANGIBAI H PARMAR received shares inphysical form from WAVE INTER TRADES
PVT LTD116 AABPJ5807D REKHA RAKESH JAIN
REKHA RAKESH JAIN received shares inphysical form from WAVE INTER TRADESPVT LTD
117 AFHPP7451E SHARDA KPARMAR
SHARDA K PARMAR received shares in physicalform from WAVE INTER TRADES PVT LTD
118 AFHPP7450F VINOD HASTIMALPARMAR
VINOD HASTIMAL PARMAR received sharesin physical form from WAVE INTER TRADESPVT LTD
119 AFIPP6863R ABHISEK KUMARPODDAR
ABHISEK KUMAR PODDAR received shares inphysical form from WAVE INTER TRADES
PVT LTD120 ABEPA0558Q ARCHANA SANJAY
AGARWAL ARCHANA SANJAY AGARWAL receivedshares in physical form from WAVE INTER TRADES PVT LTD
121 AFEPP5775J ASHISH KUMARPODDAR
ASHISH KUMAR PODDAR received shares inphysical form from WAVE INTER TRADESPVT LTD
122 AOZPB0748K KAVITA BAPNA KAVITA BAPNA received shares in physicalform from WAVE INTER TRADES PVT LTD
123 AMEPB5017G LAXMI K BAPNA LAXMI K BAPNA received shares in physicalform from WAVE INTER TRADES PVT LTD
124 AMIPP7763K