wtm/rka/ 103 /isd/2014 securities and … 1 of 55 wtm/rka/ 103 /isd/2014 securities and exchange...

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WTM/RKA/ 103 /ISD/2014

SECURITIES AND EXCHANGE BOARD OF INDIA

ORDER

UNDER SECTION 11(1), 11(4) AND 11B OF THE SEBI ACT, 1992 AND SECTION

12A OF THE SECURITIES CONTRACTS (REGULATION) ACT, 1956 - IN THE

MATTER OF KELVIN FINCAP LIMITED.

1. Pursuant to the detection of a huge rise in the traded volumes and price of the shares of

Kelvin Fincap Limited {formerly known as Dahyabhai Sons Limited and hereinafter referred

to as "Kelvin "} on the Bombay Stock Exchange Limited (BSE) during the period from June

18, 2013 to May 29, 2014 (hereinafter referred to as "Examination Period"), Securities and

Exchange Board of India (SEBI) undertook preliminary inquiry in the dealings in the scrip

during the said period.

2. It was noticed that during the period from June 18, 2013 to July 23, 2013 (Patch 1), the price

of the scrip rose from `151.55/- to `225/, i.e. an increase of 48% in 26 trading days. On

July 24, 2013, the shares of Kelvin were split in the ratio of 1:1 and from July 24, 2013 to

May 29, 2014 (Patch 2), the price of the scrip increased from `118/- to `535/-, i.e. an

increase of 353% in 205 trading days. An illustration of price/volume movement in the scrip

of Kelvin during the Examination Period is given below:

0

20000

40000

60000

80000

100000

120000

140000

160000

180000

200000

0

100

200

300

400

500

600

Total Volume Close Price

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3. Kelvin had a share capital of 9,96,000 shares of `10/- each as on December 31, 2011.From

the Annual Reports of Kelvin for FY 2011-12 and FY 2012-2013, it was observed that it is in

the business of financing and investing and it had earned a negligible profit of `25,869/-

during 2011-12 which marginally increased to `43,957.13/-, at the end of the FY 2012-13,

with negative reserves. Kelvin's financial statements for the quarters ending June 2013,

September 2013, December 2013 and March 2014 also indicated negligible profits earned by

it during the relevant period. It was further noted that during the Examination Period there

was no corporate announcement made by Kelvin which could support such price rise in its

scrip. Thus, the sharp rise in the price of the scrip of Kelvin during the Examination Period

was not supported by its fundamentals or any other genuine factor. It is interesting to note

that the shares of Kelvin were suspended on BSE till November 2011 and till March 29,

2012, there were no trades on BSE except a single trade of 50 shares at a price of `8.55/-.

Strangely, inspite of such poor fundamentals, Kelvin was able to raise `13,00,00,000/- by

issuing 1,30,00,000 shares in physical form to certain entities ( individuals and a few

corporate entities) at `10/- per share on March 20, 2012. To invest in a company having

such poor and meagre fundamentals at a price which is at a premium to the prevailing

market price cannot prima-facie be termed as rational buying behaviour. Such investments, as

in this case, normally could be made only if the allottees had nexus with directors/promoters

of Kelvin and the issue of these shares was under a pre- arrangement between them.

4. On analysis of the trading activity in the above scrip, it was observed that, during the

Examination Period, certain related/connected entities had substantially traded amongst

themselves in shares of Kelvin and created artificial volume and contributed to the artificial

price rise in the scrip. The list of those related/connected entities is given at Annexure - A

and they are hereinafter referred to as the "Kelvin Fincap Group". It was observed that prior to

the Examination Period, shares of Kelvin had low liquidity, which increased substantially

only after those related/connected entities commenced trading heavily in the scrip. Their

inter-relationship/connection were noted from the Know Your Client (KYC) details , their

bank statements, off-market transactions amongst themselves including the abovementioned

allotment of shares, and information available on the Ministry of Corporate Affairs

(hereinafter referred to as "MCA") website.

5. Considering the large number of related/connected entities of Kelvin Fincap Group, it was

deemed necessary to shortlist those entities who were closely connected to Kelvin and/or

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were instrumental in the rise in price /buy volume of Kelvin. A set of 22 (twenty two) such

entities (hereinafter referred to as the "Shortlisted Group") of Kelvin Fincap Group was

shortlisted on the basis of following parameters, viz.

A. Top 10 entities based on gross buy quantity;

B. Top 10 entities based on positive contribution in last traded price (hereinafter referred

to as "LTP");

C. Promoters/Directors of Kelvin who transacted with other members of Kelvin Fincap

Group by way of funds / securities or, had any other relationship with them.

6. The particulars of the members of the Shortlisted Group and the basis of their inter-se

relationship/connection are given in the following table :

Table 1: Basis of inter-se relationship/ connection amongst the Shortlisted Group.

Sl No PAN Name Basis of Relationship

1 AAACD1880G Dahyhabhai Shares and Stock Brokers Ltd.

1. The entity is the promoter of Kelvin as on June 30, 2014 as per BSE website.

2. The entity has received ` 25,000 from Cromakem Limited on 12/05/2012.

2. AAHPS4084K Keyur M Shah 1. The entity is the director of Dahyhabhai Shares and Stock Brokers Ltd as per MCA website and was a promoter of Kelvin as per shareholding pattern disclosed on BSE website for quarter ending December 2012.

2. The entity transferred shares to Mr. Narendra R Shah, Mr. Mahesh R Shah, Mr. Abhishek N Shah and Ms. Geeta N Shah in physical form.

3. AAAHK5034L Keyur M Shah (HUF)

1. The entity is HUF with Keyur M Shah as karta and was a promoter of Kelvin as per shareholding pattern disclosed on BSE website as on March 31, 2012.

2. The entity transferred shares to Narendra R Shah (HUF) in physical form on 07/04/2012.

4. AAYPS3458E Kavita K Shah 1. The entity is the director of Dahyhabhai Shares and Stock Brokers Ltd as per MCA website and a promoter of Kelvin as per shareholding pattern disclosed on BSE website for quarter ending December 2012. She also shares common address with Keyur M Shah viz, 22 / 23, Purab Apartment, 42, B. G. Kher Marg, Malbar Hill Mumbai 400006.

2. The entity transferred shares to Mr. Narendra R Shah, Mr. Abhishek N Shah and Ms. Geeta N Shah in physical form on 07/04/2012.

5. ALRPB9295L Bhavik Satish Badani 1. The entity is director of Kelvin as per BSE and MCA websites.

2. The entity is one of the directors of Cromakem Limited.

6. AIDPP3653M Bipin Bhikhabhai Patel

1. The entity is director of Kelvin as per BSE and MCA websites.

2. The entity shares common address, viz. 401 B-28, Shanti Nagar Co. Op. Hsg. Ltd. Shanti, Nagar, Sec - 7, Above Indra Hospital, Mira Road,, Mumbai - 401107 with Mr. Jitendra

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Patel, director of RFL International Limited and Fast Track Entertainment Limited.

7. BBPPE7839K Sushma Vimalkumar Raval

1. The entity is one of the directors of Kelvin as per MCA website.

2. The entity is also director of Millennum Cybertech Limited.

3. The entity shares common address, viz. 23 Shri Ram Vihar Rokadia Lane, Borivali West, Mumbai, 400092, with Mr. Vimalkumar Sureshchandra Raval, Ms. Padmaben Jagdish Jani, Ms. Jalpa Mitesh Jani, Mr. Jagdish Jani (Director of Sapan Chemical Limited, Surya Mangal Media and Entertainment Pvt. Ltd. and Acil Cotton Limited) and Mr. Mitesh Jagdish Jani (Director of Novagold Petro-Resources Limited).

8. AJMPS0962J Mahendrabhai Sakalchand Shah

1. The entity is one of the directors of Kelvin as per MCA Website.

2. The entity is also a director of Heema Infocom Limited and GFL Financial India Limited.

9. AYBPS0534J Vishal Kumar Shah 1. The entity is one of the directors of Kelvin as per BSE website.

2. The entity is one of the directors of Cornhill Trading Co. Pvt. Ltd., Earth Exim Limited and Do Max Steel Limited.

10. AAECC0841Q Cromakem Limited 1. Mr. Bhavik Satish Badani is one of the directors of

Kelvin and Cromakem Limited.

2. Narendra Ramanlal Shah and Cromakem Limited share common address, viz. 24, jalaram Nagar, opp.chamunda Circle, ganjawala Lane,Borivali(w), , Mumbai, Maharashtra - 400092.

3. Ms. Pallavi Chetan Pandit is one of the directors of Cornhill Trading Co. Pvt. Ltd, Cromakem Limited, Sonal International Limited, Stardom Trading Co. Pvt. Ltd. and IFSL Limited.

4. Mr. Jayshree Shankar Bhosle, Heema Infocom Limited,

Do Max Steel Limited, Suryamangal Media And Entertainment Limited, Cornhill Trading Company Pvt Ltd, Sapan Chemicals Limited, Ms. Padmaben Jagdish Jani, Ms. Jalpa Mitesh Jani, Cromakem Limited, Acil Cotton Industries Limited, Mr. Rupesh Balkrishna Bhoir, Mr. Chirag Dineshkumar Shah, Mr. Namdeo Shantaram Gole, Ms. Varsha Praful Trivedi, Mr. Mahesh Ramanlal Shah, Ms. Geeta Narendra Shah, Zimig Trading Company Private Limited and Mr. Parag Chandrkant Shah share common e-mail ID '[email protected]'.

5. The entity received/transfered funds from/to SDFC

Finance Limited and Kosha Cubidor Containers Limited.

11. AACCD7020L Do Max Steel Limited

1. The entity shares common director, Mr. Vishal Kumar Shah, with Kelvin, Cornhill Trading Co. Pvt. Ltd. and Earth Exim Limited.

2. Mr. Jayshree Shankar Bhosle, Heema Infocom Limited,

Do Max Steel Limited, Suryamangal Media And Entertainment Limited, Cornhill Trading Company Pvt

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Ltd, Sapan Chemicals Limited, Ms. Padmaben Jagdish Jani, Ms. Jalpa Mitesh Jani, Cromakem Limited, Acil Cotton Industries Limited, Mr. Rupesh Balkrishna Bhoir, Mr. Chirag Dineshkumar Shah, Mr. Namdeo Shantaram Gole, Ms. Varsha Praful Trivedi, Mr. Mahesh Ramanlal Shah, Ms. Geeta Narendra Shah, Zimig Trading Company Private Limited and Mr. Parag Chandrkant Shah share common e-mail ID '[email protected]'.

12. AAHCS1332H Stardom Trading Company Pvt. Ltd

1. Cornhill Trading Company Pvt Ltd, Stardom Trading Company Pvt Ltd and Acil Cotton Industries Limited share common address, viz. 38, Ganga Vihar, 3rd Floor, Rokadia Lane, Borivali (w), Mumbai - 400092.


3. Cornhill Trading Company Pvt Ltd, Earth Exim Ltd, Stardom Trading Company Pvt Ltd, Mr. Rupesh Balkrishna Bhoir, Fast Track Entertainment Limited and Mr. Chirag Dineshkumar Shah, share common e-mail ID '[email protected]'.

13. AAFCS2725Q Sapan Chemicals Limited

1. Earth Exim Ltd, Ms. Geeta N Shah, Sapan Chemicals Limited and Mr. Narendra Ramanlal Shah share common address, viz. 23 Jalaram Nagar Nr. Chamunda Circle Gajawala Lane Borivli West, , Mumbai, 400092.

2. Ms. Sushma Vimalkumar Raval (Director of Kelvin as per MCA website), Mr. Vimalkumar Sureshchandra Raval, Ms. Padmaben Jagdish Jani, Ms. Jalpa Mitesh Jani, Mr. Jagdish Jani (Director of Sapan Chemical Limited, Surya Mangal Media and Entertainment Pvt. Ltd. and Acil Cotton Limited) and Mr. Mitesh Jagdish Jani (Director of Novagold Petro-Resources Limited) share common address, viz. 23 Shri Ram Vihar Rokadia Lane, Borivali West, Mumbai, 400092.

3. Mr. Jayshree Shankar Bhosle, Heema Infocom Limited, Do Max Steel Limited, Suryamangal Media And Entertainment Limited, Cornhill Trading Company Pvt Ltd, Sapan Chemicals Limited, Ms. Padmaben Jagdish Jani, Ms. Jalpa Mitesh Jani, Cromakem Limited, Acil Cotton Industries Limited, Mr. Rupesh Balkrishna Bhoir, Mr. Chirag Dineshkumar Shah, Mr. Namdeo Shantaram Gole, Ms. Varsha Praful Trivedi, Mr. Mahesh Ramanlal Shah, Ms. Geeta Narendra Shah, Zimig Trading Company Private Limited and Mr. Parag Chandrkant Shah share common e-mail ID '[email protected]'.

4. Jaishree Shankar Bhosle is the promoter of Sapan Chemical Limited, as per BSE website.

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14. AAACF7961Q Fast Track Entertainment Limited

1. Director of Fast Track Entertainment Limited and RFL International Limited (Jitendra Patel) share same address with the Director of Kelvin, Mr. Bipin Patel, viz. 401 B-28, Shanti Nagar Co. Op. Hsg. Ltd. Shanti, Nagar, Sec - 7, Above Indra Hospital, Mira Road,, Mumbai, 401107

2. Acil Cotton Industries Limited and Fast Track Entertainment Limited share common address, viz. B-7/404 A, Natraj Township Part-ii,near Parshuram Nagar Society, Sayaji Ganj,, Vadodara, Gujarat, India, 390005.


15. AACCC0591P Cornhill Trading Company Pvt. Ltd

1. Mr. Vishal Kumar Shah is one of the directors of Kelvin, Cornhill Trading Co. Pvt. Ltd., Earth Exim Limited and Do Max Steel Limited.

2. Universal Credit and Securities Limited, Suryamangal Media And Entertainment Limited, Cornhill Trading Company Pvt Ltd and Gfl Financials India Limited share common address, viz. 15 Shriram Vihar, Rokadia Lane, Borivali (w), Mumbai, Maharashtra, India, 400092.

3. Cornhill Trading Company Pvt Ltd, Stardom Trading Company Pvt Ltd and Acil Cotton Industries Limited share common address, viz. 38, Ganga Vihar, 3rd Floor, Rokadia Lane, Borivali (w), Mumbai, Maharashtra, India, 400092.

4. Ms. Pallavi Chetan Pandit is one of the director of Cornhill Trading Co. Pvt. Ltd, Cromakem Limited, Sonal International Limited, Stardom Trading Co. Pvt. Ltd. and IFSL Limited.



16. AACCS1185R Sonal International Ltd


2. Sonal International Ltd and RFL International Limited share common address, viz. 304, Akruti Complex,nr.stadium Six Cross Road, Navrangpura,, Ahmedabad, Gujarat, India, 380009.

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17. AAACO2454R Nova Gold Petro Resources Limited

1. Ms. Sushma Vimalkumar Raval (Director of Kelvin as per MCA website), Mr. Vimalkumar Sureshchandra Raval, Ms. Padmaben Jagdish Jani, Ms. Jalpa Mitesh Jani, Mr. Jagdish Jani (Director of Sapan Chemical Limited, Surya Mangal Media and Entertainment Pvt. Ltd. and Acil Cotton Limited as per MCA website) and Mr. Mitesh Jagdish Jani (Director of Novagold Petro-Resources Limited) share common address, viz. 23 SHRI RAM VIHAR ROKADIA LANE, BORIVALI WEST, MUMBAI, 400092.

2. The entity received `25,00,000 from Cromakem Ltd on 20/11/2013.

18.

AABCA7788F Acil Cotton Industries Limited

1. Cornhill Trading Company Pvt Ltd, Stardom Trading Company Pvt Ltd and Acil Cotton Industries Limited share common address, viz. 38, Ganga Vihar, 3rd Floor, Rokadia Lane, Borivali (w), Mumbai, 400092.




5. Vimalkumar Raval is one of the directors of Zimig Trading Pvt. Ltd. and Acil Cotton Industries Limited.

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19. AAACZ6848C Zimig Trading Company Private Limited


1.1.1 Vimalkumar Raval is one of the directors of Zimig Trading Pvt. Ltd. and Acil Cotton Industries Limited.

20. AMVPJ5720H Jalpa Jani 1. Ms. Sushma Vimalkumar Raval (Director of Kelvin as per MCA website), Mr. Vimalkumar Sureshchandra Raval, Ms. Padmaben Jagdish Jani, Ms. Jalpa Mitesh Jani, Mr. Jagdish Jani (Director of Sapan Chemical Limited, Surya Mangal Media and Entertainment Pvt. Ltd. and Acil Cotton Limited) and Mr. Mitesh Jagdish Jani (Director of Novagold Petro-Resources Limited) share common address, viz. 23 SHRI RAM VIHAR ROKADIA LANE, BORIVALI WEST, MUMBAI, 400092.

2. Mr. Jayshree Shankar Bhosle, Heema Infocom Limited, Do Max Steel Limited, Suryamangal Media And Entertainment Limited, Cornhill Trading Company Pvt Ltd, Sapan Chemicals Limited, Ms. Padmaben Jagdish Jani, Ms. Jalpa Mitesh Jani, Cromakem Limited, Acil Cotton Industries Limited, Mr. Rupesh Balkrishna Bhoir, Mr. Chirag Dineshkumar Shah, Mr. Namdeo Shantaram Gole, Ms. Varsha Praful Trivedi, Mr. Mahesh Ramanlal Shah, Ms. Geeta Narendra Shah, Zimig Trading Company Private Limited and Mr. Parag Chandrkant Shah share common e-mail ID '[email protected]'

21. AKSPM3939N Kirti Mehta As per the bank Account No. 911010005936771 of Kirti Mehta with Axis Bank Limited, the entity received/transferred funds from/to Kelvin, Cromakem Limited, Stardom Trading Co. Pvt. Ltd., Fast Track Entertainment Limited, Earth Exim Limited, Cornhill Trading Co. Pvt. Ltd., IFSL Limited, GFL Financial India Limited, Inventure Finance Pvt. Ltd., Sonal International Limited, Kosha Cubidor Containers Limited and Acil Cotton Industries Limited.

22. AFMPB0449P Jayshree Shankar Bhosle


2. Jaishree Shankar Bhosle is the promoter of Sapan Chemical Limited as per BSE website.

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7. In addition, from the bank accounts of Kelvin (account No. 912020012135343) and

Cromakem Limited (account No. 910020027467767) with Axis Bank, inter se fund

transfers between Kelvin and certain entities of the Kelvin Fincap Group during January

01, 2012 to March 31, 2014, were observed. Instances of such inter se fund transfers

amongst the related/connected entities of Kelvin Fincap Group and Kelvin are as under:

Table 2: Funds Flow among the Kelvin Fincap Group

Date Transferer Name Transferee Name Amount (`)

9/3/2012 Kelvin Fincap Limited SDFC Finance Limited 5000000

10/3/2012 Kelvin Fincap Limited Universal Credit And Securities Ltd 1600000

13-03-2012 Kelvin Fincap Limited Keyur M Shah 3000000

19-03-2012 Kelvin Fincap Limited Millennium Cybertech Limited 10000000

19-03-2012 Kelvin Fincap Limited Stardom Trading Co.Pvt.Ltd. 10000000

21-03-2012 Kelvin Fincap Limited Novagold Petro-Resources Ltd 9000000

22-03-2012 Kelvin Fincap Limited Acil Cotton Indutries Limited 8000000

24-03-2012 Kelvin Fincap Limited Kirti Mehta 1200000

25-04-2012 Geeta Shah Kelvin Fincap Limited 500000

27/04/2012 Abhishek Narendra Shah Kelvin Fincap Limited 500000

13/09/2012 Cromakem Limited Kelvin Fincap Limited 500000

8/2/2013 Do Max Steel Limited Kelvin Fincap Limited 30000

20/02/2013 Earth Exim Ltd Kelvin Fincap Limited 300000

6/5/2013 Sapan Chemicals Ltd Kelvin Fincap Limited 20000

29/01/2014 Kelvin Fincap Limited Fast Track Entertainment Ltd 300000

3/1/2012 Cromakem Limited Sonal International Limited 400000

11/2/2012 Cromakem Limited Fast Track Entertainment Ltd 205000

11/2/2012 Cromakem Limited SDFC Finance Limited 210000

15/02/2012 Cromakem Limited RFL International Limited 15000

29/02/2012 Gfl Financials India Ltd Cromakem Limited 1000000

11/4/2012 Cromakem Limited Kirti Kantilal Mehta 2000000

16/04/2012 Cromakem Limited Chirag Dinesh Kumar Shah 1775000

20/04/2012 Cromakem Limited Namdeo Shantaram Gole 190000

2/5/2012 Kosha Cubidor Containers Ltd Cromakem Limited 2000000

5/5/2012 Cromakem Limited Millennium Cybertech Limited 200000

5/5/2012 Cromakem Limited IFSL Limited 200000

8/5/2012 Cromakem Limited Yogesh Bhogilal Chauhan 685000

9/5/2012 Stardom Trading Company Private Limited

Cromakem Limited 1000000

10/5/2012 Cromakem Limited Parag Chandrkant Shah 1000000

12/5/2012 Cromakem Limited Dahyabhai Sons Limited 25000

16/05/2012 Suryamangal Media And Entertainment Pvt Ltd.


2/7/2012 Cromakem Limited Universal Credit And Securities Ltd 25000

28/01/2013 Cromakem Limited Earth Exim Ltd 25000

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13/03/2013 Cromakem Limited Inventure Finance Pvt Ltd 2522400

14/03/2013 Cromakem Limited Do Max Steel Limited 2523000

15/03/2013 Cromakem Limited Cornhill Trading Company Private Limited 2522400

19/03/2013 Dahyhabhai Shares and Stock Brokers Ltd.


28/03/2013 Cromakem Limited Padmaben Jagdish Jani 510000

20/05/2013 Cromakem Limited Jalpa Jani 200000

18/07/2013 Cromakem Limited Rupesh Bhoir 500000

25/07/2013 Cromakem Limited Mahesh Ramanlal Shah 400000

6/8/2013 Cromakem Limited Varsha Trivedi 1000000

8/8/2013 Cromakem Limited Jayshree Shankar Bhosle 1000000

12/8/2013 Cromakem Limited Geeta Narendra Shah 65000

11/9/2013 Acil Cotton Industries Limited Cromakem Limited 500000

27/09/2013 Cromakem Limited Sapan Chemicals Limited 1500000

20/11/2013 Cromakem Limited Novagold Petro Resources Ltd 2500000

7/2/2014 Cromakem Limited Zimig Trading Co Pvt Ltd 365000

8/3/2014 Heema Infocom Limited Cromakem Limited 3890000

19/03/2014 Cromakem Limited Abhishek N Shah 115000

8. It is observed from the disclosures made on BSE website that prior to the allotment of

shares made in March 2012, Kelvin had a share capital of 9,96,000 shares with promoters'

holding 7,43,800 shares constituting 74.67% in the company. Pursuant to the issuance of

1,30,00,000 shares to certain entities, the promoter shareholding decreased to 5.31% and the

total number of shareholders in Kelvin increased from 176 to 225.

9. It was further observed that during the quarter ending June, 2012, the Kelvin Fincap Group

entities consolidated their holding in Kelvin which resulted in number of shareholders

decreasing to 64. During the same period, the promoters of Kelvin also transferred 7,11,050

shares in physical form to certain Kelvin Fincap Group entities through off- market

transactions. Thereafter, the Kelvin Fincap Group entities were observed to have transferred

shares in physical form as well as in dematerialised form within the group and started

trading heavily in the scrip pursuant to June 18, 2013.

Analysis of trading in the scrip of Kelvin

10. The analysis of the trading of entities of Kelvin Fincap Group during the aforesaid two (2)

patches was carried out with a focus on the following:-

The trading frequency;

The volume generated;

Contribution to price rise;

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Buying behaviour as observed from Last Traded Price (LTP) data;

Patch 1: June 18, 2013 to July 23, 2013 (prior to share split) 11. During the Patch 1, price of Kelvin rose from ` 151.55 to ` 225/-( i.e. 48% increase) and

was accompanied by rise in the traded volumes. The daily average volume in the scrip which

was merely 6 shares during January 1, 2013 to June 17, 2013( i.e. six months prior to Patch

1) increased to 22,237 shares during Patch 1. It was observed that during Patch 1, Kelvin

Fincap Group entities collectively bought 5,47,818 shares (94.75% of trade volume) and sold

5,64,913 shares (97.71% of trade volume), out of a total of 5,78,174 shares traded at BSE. As

high as 5,36,292 shares which constitute 92.76% of trade volume, were traded amongst the

group entities. As high as 97.90% of the total buy volume of the group matched with the sell

orders of one or the other group entity. Similarly, 94.93% of their sell volume matched with

the buy orders within the group.

12. It was observed that in Patch 1, out of a total of 17 instances of trades establishing new high

price in the scrip, the Kelvin Fincap Group established new high price on 4 instances. The

contribution of the Kelvin Fincap Group in establishing new high price was ` 19/- out of total

price rise of ` 82.40/-, which constitutes 23.06% of the total new high prices.

13. On LTP analysis during Patch 1, it was observed that out of the 24 instances of positive

contribution to the LTP, Kelvin Fincap Group contributed positively to the LTP in as many as

9 instances. By executing such trades above the LTP, Kelvin Fincap Group contributed to

positive LTP to the extent of `52.20/-, which was 41.04% of overall positive LTP

contribution of `127.20/- in the scrip. The details of contribution to price rise by Kelvin

Fincap Group during Patch 1 are as under:

Table 3: Contribution of Kelvin Fincap Group to price rise in Patch 1

PAN Name Contribution in positive

LTP (in `)

No. of Instances of positive LTP

Contribution to New High

Price (in `)

No. of Instances of New High Price

AAACF7961Q Fast Track Entertainment Limited

19.7 2 9 1

AMVPJ5720H Jalpa Jani 13.75 3 1.25 1

AAECC0841Q Cromakem Limited 8.55 1 8.55 1

AABCE3676Q Earth Exim Ltd 5 1 0 0

AKSPM3939N Kirti Mehta 5 1 0 0

ADQPJ5053P Padmaben Jagdish Jani 0.2 1 0.2 1

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14. It was observed that the Shortlisted Group contributed to the positive LTP to the extent of

`47/-, which was 90.04% of the contribution made by the Kelvin Fincap Group to the extent of

`52.20/-. It was further observed that the Shortlisted Group has contributed in establishing

new high price to the extent of `18.80/-, which is 98.95% of the Kelvin Fincap Group's overall

contribution of `19/-.

Patch 2: July 24, 2013 to May 29, 2014 (post share split) 15. During Patch 2, price of Kelvin rose from ` 118/- to ` 535/- and was accompanied by a

substantial rise in the traded volumes. The average volume in the scrip during Patch 2

increased to 40,974 shares from 22,237 shares in Patch 1. It was observed that during Patch

2, Kelvin Fincap Group collectively bought 81,99,511 shares (97.62% of traded volume) and

sold 81,12,737 shares (96.58% of traded volume) out of a total of 83,99,726 shares traded at

BSE . As high as 80,53,453 shares which constitute 95.88% of traded volume, were traded

amongst the Kelvin Fincap Group entities. As high as 98.22% of their total buy volume

matched with the sell orders of one or the other Kelvin Fincap Group entity. Similarly, 99.27%

of their sell volume matched with the buy orders within the Kelvin Fincap Group.

16. It was observed that during Patch 2, out of a total of 81 instances of trades establishing new

high price in the scrip, the Kelvin Fincap Group established new high price on as many as 64

instances. The contribution of the Kelvin Fincap Group in establishing new high price was `

328.10/-, which constitutes 77.75% of total new high price of ` 422/- in this Patch.

17. On LTP analysis during Patch 2, it was observed that out of the 472 instances of positive

contribution to the LTP, Kelvin Fincap Group contributed to positive LTP in as many as 414

instances. By executing such trades above the LTP, Kelvin Fincap Group contributed to the

positive LTP to the extent of `1,712.65/-, which was 86.25% of overall positive LTP

contribution of `1,985.65/-. in the scrip. The details of contribution to price rise by the

Kelvin Fincap Group during Patch 2 are as under:

Table 4: Contribution of Kelvin Fincap Group to price rise in Patch 2

PAN Name Contribution to Positive

LTP (in `)

No. of Instances to Positive LTP

Contribution to New High Price

(in `)

No. of Instances to New High Price

AAFCS2725Q Sapan Chemicals Limited 233.1 51 40.5 8

AACCD7020L Do Max Steel Limited 216.15 45 52.6 7

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AAECC0841Q Cromakem Limited 203.65 53 48.9 9

AACCC0591P Cornhill Trading Company Pvt Ltd 118.9 24 6.5 2

AACCS1185R Sonal International Ltd 94.4 21 34.1 6

AAHCS1332H Stardom Trading Company Pvt Ltd 91.75 26 19.5 4

AMVPJ5720H Jalpa Jani 90.3 26 5 1

AABCA7788F Acil Cotton Industries Limited 82.65 15 0 0

AAACO2454R Nova Gold Petro Resources Limited 78.8 17 34.5 6

AAHCS4914K Suryamangal Media & Entertainment Ltd

63.45 18 19 4

AAACZ6848C Zimig Trading Company Private Limited

54.2 12 2 1

AKSPM3939N Kirti Mehta 52.15 15 7 3

AAACI4383H IFSL Limited 51.05 9 0 0

AAACF7961Q Fast Track Entertainment Limited 49 11 11 3

AQQPG4855K Maruti Shankar Gaude 45 8 0 0

AFMPB0449P Jayshree Shankar Bhosle 38.2 16 8 2

ALZPB9604R Rupesh Balkrishna Bhoir 29.35 8 6 2

AHNPD1452H Vidyadhar Ramnaresh Dubey 26.85 9 5 1

ATRPK4534D Ramesh Krishna Kulaye 21.5 3 1 1

AOYPM7851H Madhuben H Modi 18.5 1 17.5 1

AIYPD1020H Vinod Gajanan Dhadave 14.95 4 0 0

AADCH2621N Heema Infocom Limited 11.05 6 0 0

ADQPJ5053P Padmaben Jagdish Jani 10.5 2 5 1

AEKPK6751Q Santosh Kumar 5 1 4 1

AAGCR4662J Reachsmart Construction Private Limited

3 1 0 0

AIOPG4980F Hiren Kirit Gandhi 2.6 4 0 0

ANIPR5608Q Vimalkumar Sureshchandra Raval 2.1 4 0 0

AAOPS2034A Mahesh Ramanlal Shah 2 1 0 0

AHAPP5916H Jaswant Kantilal Parmar 1.5 2 0 0

ABBPT1431A Varsha Trivedi 1 1 1 1

Total 1712.65 414 328.1 64

18. It was observed that the Shortlisted Group contributed to positive LTP to the extent of `

1,403.25/-, which is 81.93% of contribution (`1,712.65/-) made by Kelvin Fincap Group.

Further, the Shortlisted Group contributed ` 269.60/- in establishing new high price, which

is 82.17% of the Kelvin Fincap Group's overall contribution of `328.10/-.

19. From the above analysis, it was observed that the trades of Kelvin Fincap Group contributed

significantly to both traded volume and to price rise in the scrip during the Examination

Period.

20. It was observed that during the Examination Period the connected/related entities belonging

to Kelvin Fincap Group had traded amongst themselves in the scrip and their buy and sell

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orders placed in those trades persistently matched. An illustration of the trading patterns of

order placements followed by Kelvin Fincap Group entities are as under:-

One of the patterns of order placement by the Kelvin Fincap Group entities was

where a buy order placed by one group entity exactly matched with the sell order

placed by another group entity. For instance, on January 16, 2014, Jeetandra Janani

(HUF) placed a sell order at 11:22:56 AM for a quantity of 2,500 at a price of `

350/-. After 7 seconds, i.e. 11:23:03, Fast Track Entertainment Limited placed a

buy order of same quantity of 2500 shares at a price of `350/-, which immediately

matched. Similarly, Prameela Mohandas placed a sell order of 3,000 shares at a

price of `340/- at 13:50:53 on the same day, which matched with a buy order of

3,000 shares at a price of `340/- placed by Sapan Chemicals Limited at 13:51:11. In

the same manner, the buy and sell orders for 4,000 shares placed by Sapan

Chemicals Limited and Zubin K Shah, respectively within a gap of 3 seconds

matched at 13:52:13.

In another pattern, the order placed by one group entity matched with the orders

placed by more than one entity belonging to the Kelvin Fincap Group. For instance,

on January 16, 2014, Ashok Jasraj Jain (HUF) placed 2 sell orders of 5,000 and

2,000 shares at a price of `340/- at 14:44:10 and 14:44:42, respectively. The said sell

orders matched with the buy orders placed by the following 8 entities belonging to

Kelvin Fincap Group:

Table 5: Counterparties to Ashok Jasraj Jain(HUF)

Buyer Name Buy Order Time

Buy Order Quantity

Buy Order Price

Jayshree Shankar Bhosle 14:44:24 3750 340

Nova Gold Petro Resources Limited

14:48:36 1700 340

Stardom Trading Company Pvt Ltd

14:54:23 550 340

Fast Track Entertainment Limited 14:55:15 400 340

Cornhill Trading Company Pvt Ltd

14:57:22 300 340

Cromakem Limited 14:58:05 100 340

IFSL Limited 14:58:31 100 340

Stardom Trading Company Pvt Ltd

14:58:59 100 340

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Day wise Trading Analysis

21. The shares of Kelvin were traded on 231 days during the Examination Period. It was

observed that on the days when the Kelvin Fincap Group did not trade, the average

volume in the scrip was significantly low. The details of group’s concentration vis-a-vis

average volume in the scrip during the Examination Period are as under:

Table 6: Concentration of Kelvin Fincap Group

Group's Concentration No. of Days Average Market Volume

No Trading 1 25

Between 0% and 50% 10 5,743

Between 50% and 80% 13 13,705

Between 80% and 100% 152 44,370

100% 55 36,328

Total 231 38,865

22. Thus, the Kelvin Fincap Group’s concentration in the scrip was significant on the

majority of the days it traded and the average volume in the scrip increased with an

increase in group’s concentration. Also, on 55 out of 231 days, Kelvin Fincap Group was

present in all the trades, both on buy and sell sides and average volume of 36,328

shares was created on account of trades amongst the entities of Kelvin Fincap Group.

23. It was observed that out of the trades of Kelvin Fincap Group during the Examination

Period, the Shortlisted Group bought 72,83,765 shares, which constitutes 83.27% of

Kelvin Fincap Group's total purchase volume of 87,47,329 shares. Further, the Shortlisted

Group contributed to the positive LTP to the extent of `1,450.25/- which was 82.17%

of the contribution made by the Kelvin Fincap Group to the extent of `1,764.85/-. The

Shortlisted Group also contributed in establishing new high price to the extent of

`288.40/-, which is 83.09% of the Kelvin Fincap Group's overall contribution of

`347.10/-.

24. In view of the above analysis, it was observed that, in this case, the connected/related

entities of Kelvin Fincap Group continuously and persistently traded in substantial

volumes in the scrip of Kelvin which was an illiquid one. They traded among

themselves substantially and executed matched trades in very large number. In these

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matched trades amongst connected/ related entities of Kelvin Fincap Group there was no

change in beneficial ownership of the traded shares. Their trades created artificial

volumes and manipulated the price of the scrip during the Examination Period. Such

manipulation in the traded volume and price of any scrip by a group of connected

entities has the potential to induce gullible and genuine investors to trade in the scrip

and harm them.

25. Apart from the above, it was observed that Kelvin had disclosed to BSE on March 20,

2012 inter-alia stating that it had made a preferential allotment of 1,30,00,000 shares to

certain entities as described in the following table :

Table 7: List of Preferential Allottees disclosed by Kelvin on BSE website

Sr. No. Name of Allottees/Entities Number of Equity Shares Allotted

1 Mukesh N Desai 500000

2 Mukesh N Desai Huf 500000

3 Sunish B.Bhel/Kavita Sunish Behl 530000

4 Dinesh Jaiswal/Sunita D.Jaiswal/Santlal Jaiswal 345000

5 Subhash Tikamdas Mithawalla/Jignasa S.Mithawalla 150000

6 Tasneem Iqbal Syed/Krishna M.Dawda/Prem Agarwal 330000

7 Mukeshbhai Nanjibhai Moradiya 200000

8 Shehul Vallabhbhai Moradiya 200000

9 Dhanjibhai Shamjibhai Donda 200000

10 Hiren Tulsibhai Moradia 200000

11 Dharmesh Tulsibhai Moradia 200000

12 Bharatbhai Nanjibhai Moradia 200000

13 Vallabhbhai D Sachapara 200000

14 B D Sachpara 200000

15 Rajesh Haribhai Moradia 200000

16 Vasantben Dhanjibhai Donda 200000

17 Chhotubha Shivubha Saravaiya 200000

18 Shobhanaben Nareshbhai Mpradiya 200000

19 Ramniranjan C Jhunjhunwala 200000

20 Hasmukhlal R.Shah 200000

21 Ashok Jashraj Jain HUF 200000

22 Ketan Bhupendrkumar Shah 100000

23 Shantilal Dungarshi Maru HUF 200000

24 Kalpesh Shantilal Maru/Rachana Kalpesh Maru 600000

25 Saloni Ramniklal Maru 100000

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26 Manisha Pramesh Rambhia 200000

27 Nirmala Shantilal Maru 400000

28 Sejul Pratish Maru 100000

29 Mitesh Rajnikant Shah 150000

30 Bhavini B.Furia 250000

31 Rajesh Gopaldas Villaitramani 200000

32 Kamlesh Hari Thakur 200000

33 Jagdish Hari Thakur 200000

34 Ashok Gopaldas Kripalani 200000

35 Mrs Lajwanti Hari Thakur 200000

36 Zubin Kamlesh Shah/Zeenal Zubin Shah 400000

37 Prameela Mohandas 200000

38 Inventure Finance Private Limited 600000

39 Deepaben Trabakbhai Makwana 150000

40 Champaben Devjibhai Makwana 150000

41 MrsBhavani Bharatbhai Dangar 100000

42 Mithalal Manoharlal Sahlot 300000

43 Poonam Premsagar Pasricha/Premsagar L Pasricha 100000

44 M.V.R.S Prasad 300000

45 N.Satyanarayana 150000

46 Ravi Sancheti HUF 200000

47 Rakesh Agrawal/Trapti Agrawal 100000

48 GFL Financial India Ltd 898000

49 Suryamangal Media & Entertainment Ltd 897000

26. It is curious to note that the list of entities mentioned in the table above actually have

more than one entity clubbed together at serial nos. 3, 4, 5, 6, 24, 36, 43 and 47. On

inquiry from the Share Transfer Agent of Kelvin, i.e. Purva Sharegistry (India) Pvt.

Ltd. (hereinafter referred to as "Purva Sharegistry) it was observed that the shares were

issued to 56 entities and not 49 entities, as disclosed by Kelvin to BSE. It was observed

that different share certificates were issued to the following 56 entities and not to 49 as

disclosed by Kelvin:-

Table 8: List of Preferential Allottees provided by Purva Sharegistry

S. No.

PAN Name Share Certificate Number

Distinctive Number

1 AATPD0728R Mukesh N Desai 5001-5050 996001 1496000

2 AACHM2754B Mukesh N Desai HUF 5051-5100 1496001 1996000

3 AAAPB8093N Sunish B. Bhel 5101-5119 1996001 2186000

4 AAJPB7775N Kavita Sunish Behl 5120-5153 2186001 2526000

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5 AAQPJ0509B Shantilal Jaiswal 5154-5164 2526001 2636000

6 ABVPJ5592Q Sunita Dinesh Jaiswal 5165-5175 2636001 2746000

7 ABVPJ5571B Dinesh Jaiswal 5176-5188 2746001 2871000

8 AADPM3931D Subhash Tikamdas Mithawalla 5189-5195 2871001 2941000

9 AGKPM6963C Jignasa Subhash Mithawalla 5196-5203 2941001 3021000

10 AQQPS2059B Tasneem Iqbal Syed 5204-5213 3021001 3121000

11 ADPPD5068B Krishna M.Dawda 5214-5224 3121001 3231000

12 AETPA7958N Prem Agarwal 5225-5236 3231001 3351000

13 AIVPM3622K Mukeshbhai Moradiya 5237-5256 3351001 3551000

14 AIVPM3623J Shehul Vallabhbhai Moradiya 5257-5276 3551001 3751000

15 AEIPD5332A Dhanjibhai Shamjibhai Donda 5277-5296 3751001 3951000

16 AMTPM8714C Hiren Tulsibhai Moradia 5297-5316 3951001 4151000

17 ALEPM6311R Dharmesh Tulsibhai Moradia 5317-5336 4151001 4351000

18 AMTPM0749H Bharatbhai Nanjibhai Morada 5337-5356 4351001 4551000

19 ACXPP9026C Vallabhbhai D Sachapara 5357-5376 4551001 4751000

20 ACXPP9049B B.D.Sachpara 5377-5396 4751001 4951000

21 ACRPM4534E Rajesh Haribhai Moradia 5397-5416 4951001 5151000

22 AEGPD4889J Vasantben Dhanjibhai Donda 5417-5436 5151001 5351000

23 AGBPS6488F Chhotubha Shivubha Saravaiya 5437-5456 5351001 5551000

24 AIKPM4674N Shobhanaben Nareshbhai Mpradiya 5457-5476 5551001 5751000

25 AARPJ2757L Ramniranjan C Jhunjhunwala 5477-5496 5751001 5951000

26 AADPS8752L Hasmukhlal R.Shah 5497-5516 5951001 6151000

27 AAAHJ0191D Ashok Jashraj Jain HUF 5517-5536 6151001 6351000

28 AAFPS1767F Ketan Bhupendrakumar Shah 5537-5546 6351001 6451000

29 AAFHS8932L Shantilal Dungarshi Maru Huf 5547-5566 6451001 6651000

30 AAAPM8353N Kalpesh Shantilal Maru 5567-5568 6651001 6851000

31 AAOPS6468G Rachana Kalpesh Maru 5569-5572 6851001 7251000

32 AAAPM8349Q Saloni Ramniklal Maru 5627-5636 7251001 7351000

33 AAFPM7257G Manisha Pramesh Rambhia 5637-5656 7351001 7551000

34 AAFPM7256H Nirmala Shantilal Maru 5657-5696 7551001 7951000

35 AQWPM5566H Sejul Pratish Maru 5697-5706 7951001 8051000

36 AAJPS0851L Mitesh Rajnikant Shah 5707-5721 8051001 8201000

37 AAAPM8354M Bhavin B. Furia 5722-5746 8201001 8451000

38 AAAPV4085A Rajesh Gopaldas Villaitramani 5747-5766 8451001 8651000

39 AAAPT6038P Kamlesh Hari Thakur 5767-5786 8651001 8851000

40 AAAPT3253A Jagdish Hari Thakur 5787-5806 8851001 9051000

41 AABPK2469A Ashok Gopaldas Kripalani 5807-5826 9051001 9251000

42 AAEPT2433N Mrs Lajwanti Hari Thakur 5827-5846 9251001 9451000

43 AMIPS6846A Zubin Kamlesh Shah 5847-5886 9451001 9851000

44 ACJPN8415H Prameela Mohandas 5887-5906 9851001 10051000

45 AAACM0623J Inventure Finance Private Ltd 5907-5966 10051001 10651000

46 AZTPM3476A Deepaben Trabakbhai Makwana 5967-5981 10651001 10801000

47 ACKPM8513A Champaben Devjibhai Makwana 5982-5996 10801001 10951000

48 ADXPD6143K Mrs Bhavani Bharatbhai Danga 5997-6006 10951001 11051000

49 AAIPS9404N Mithalal Manoharlal Sahlot 6007-6036 11051001 11351000

50 AHCPP2686C Poonam Pramesagar Pasricha 6037-6046 11351001 11451000

51 AAZPM0394A M.V.R.S Prasad 6047-6084 11451001 11826000

52 ABEPN6198B N.Satyanarayana A6084-6091 11826001 11901000

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27. From the above, it is observed that Kelvin had prima facie given false information to the

BSE with regard to the number of allottees and had concealed the actual number of

allottees. The method of disclosure i.e. clubbing of one or more allottees under one

suggests that the Kelvin showed the false number so as to show such allotment as

private placement, which it actually was not. In this regard, it is relevant to mention

that Hon'ble Supreme Court in its judgement and order dated August 31, 2012 in

matter of Sahara India Real Estate Corporations Limited & Ors Vs SEBI & Anr. - Civil Appeal No.

9813 and 9833 of 2011 [(2013) 1 SCC 1 has held that an offer to fifty or more persons

becomes public issue by virtue of first proviso to section 67(3) of the Companies Act,

1956. Hence, it is prima-facie observed that the above allotment was not a preferential

allotment (private placement) but was a public issue. Thus, prima-facie, the said

allotment of shares by Kelvin was in violation of sections 56, 60 and 73 read with

section 67(3) of the Companies Act, 1956 and regulations 4(2), 5(1), 5(7), 6, 7, 25, 36,

37, 46 and 57 of SEBI (Issue of Capital and Disclosure Requirement) Regulation 2009

(hereinafter referred to as "ICDR Regulations").

28. As discussed above, Kelvin had disclosed that the above allotment was a preferential

allotment. Assuming it was so, in terms of regulation 78(2) of the ICDR Regulations,

the shares so allotted had to be locked- in for a period of one year from the date of

allotment on March 20, 2012. However, in this case, two of the allottees viz, Mr. Ravi

Sancheti (HUF) and GFL Financial India Limited sold a total of 6,00,000 shares of

Kelvin held by them to 4 other entities of Kelvin Fincap Group on September 29, 2012.

It was observed from the Annual Report of Kelvin for the FY 2012-13 that the

transfer of physical shares was looked after by Shareholders' Grievance and Share

Transfer Committee of Kelvin, which comprised three of its directors viz. Mansukh

Sanghvi, Bipin Patel and Bhavik Badani. Thus, Kelvin and its directors were under

obligation to ensure that the shares allotted under the purported preferential allotment

are not transferred within one year from the date of the allotment. Therefore, it was

observed that such transfer of shares in violation of regulation 78(2) of ICDR

Regulations was in connivance with Kelvin and its these three directors.

53 AAIHR3732E Ravi Sancheti HUF 6092-6111 11901001 12101000

54 ABYPA6388G Rakesh Agrawal 6112-6121 12101001 12201000

55 AABCG0597Q GFL Financial India Ltd 6122-6214 12201001 13099000

56 AAHCS4914K Suryamangal Media & Entertainment Ltd 6215-6306 13099001 13996000

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29. It was further observed from the shareholding pattern filed by Kelvin with BSE for

quarters ending June 30, 2012 and September 30, 2012, that the promoters of Kelvin

were holding 7,43,800 shares, i.e. 5.31% of its share capital, as on June 30, 2012, which

decreased to 0.01% of the share capital of Kelvin during the quarter ended September

30, 2012. However, from the data regarding transactions in Kelvin as shared by Purva

Sharegistry it was noted that three promoters of Kelvin viz. Keyur M. Shah , Kavita

Shah and Keyur M. Shah HUF transferred a total of 7,11,050 shares (5% of the share

capital of Kelvin) to five other entities of the Kelvin Fincap Group on April 07, 2012 and

April 14, 2012. Keyur M. Shah had further transferred 25,750 shares to Abhishek N

Shah on January 15, 2013. All such transfers were off- market transfers involving

shares in physical form. The details of such transfers are as under:

Table 9: Off-Market Transactions by the Promoters

Date Of Transaction

Transferor Name

Transferee Name Quantity Transferred

07/04/2012 Keyur M Shah HUF

Narendra R Shah HUF 50000

07/04/2012 Kavita K Shah Narendra R Shah 50000

07/04/2012 Kavita K Shah Geeta Narendra Shah 50000

07/04/2012 Kavita K Shah Abhishek N Shah 30000

07/04/2012 Keyur M Shah Narendra R Shah 200000

07/04/2012 Keyur M Shah Geeta Narendra Shah 50000

07/04/2012 Keyur M Shah Mahesh R Shah 70000

07/04/2012 Keyur M Shah Abhishek N Shah 40000


14/04/2012 Keyur M Shah Geeta Narendra Shah 50000

14/04/2012 Keyur M Shah Narendra R Shah 80000


30. However, the abovementioned transactions (for April 07, 2012 and April 14, 2012)

were not disclosed in the shareholding pattern filed by Kelvin with BSE for the quarter

ended June 30, 2012 as required under Clause 35 of the Listing Agreement. Further,

the aforesaid promoters failed to disclose the above changes in their shareholding

under the provisions of regulation 13(4A) of the SEBI (Prohibition of Insider Trading)

Regulations, 1992, (hereinafter referred to as "PIT Regulations").

31. Apart from the above irregularities by Kelvin, it was observed that details of the Board

of Directors of Kelvin as available on BSE and MCA websites are different. Mr.

Mansukh Sanghvi, who is shown as a Managing Director of Kelvin on BSE website, is

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not shown in the list of directors disclosed on MCA website by Kelvin. Mr Mansukh

Sanghvi is also the Authorized Signatory for Kelvin’s bank accounts with Axis Bank.

Similarly, Surekhaben K Shah is not shown as a director on MCA website. However,

as per annual report for FY 2011-12 , she was non-executive independent director of

Kelvin at the time of preferential allotment. The difference in details of directors as

observed from disclosures available at BSE and MCA websites are given below:

Table 10: Details of Directors on MCA and BSE websites

List of Directors (Source: MCA website as on April 25, 2014)

List of Directors (Source: BSE Website as on April 25, 2014)

Bhavik Satish Badani Mansukh Sanghvi

Bipin Bhikhabhai Patel Bhavik Satish Badani

Sushma Vimalkumar Raval Bipin Bhikhabhai Patel

Mahendrabhai Sakalchand Shah Vishal Kumar Shah

Surekhaben K Shah

32. Further, Kelvin has avoided SEBI's advices seeking information from it regarding its

board of directors and above mentioned allotment, vide email dated May 22, 2014 and

letter dated May 27, 2014. Therefore, all the above persons at Table 10 are considered

to be in charge of affairs of Kelvin.

33. Although none of the directors have traded on their own account during the

Examination Period, it is observed that most of them were not merely directors of

Kelvin but were deeply connected with entities belonging to the Kelvin Fincap Group,

who had traded in the scrip as described in preceding paragraphs. Details of their

connection with the entities belonging to the Kelvin Fincap Group are as follows:

Table 11: Connection with other Kelvin Fincap Group Entities

Name of Director Connection with other Kelvin Fincap Group Entities

Bhavik Satish Badani He is one of the directors of Cromakem Limited.

Bipin Bhikhabhai Patel He shares common address with Mr. Jitendra Patel, director of RFL International Limited and Fast Track Entertainment Limited.

Sushma Vimalkumar Raval

She is one of the directors of Millennum Cybertech Limited. She also shares common address with Mr. Vimalkumar Sureshchandra Raval, Ms. Padmaben Jagdish Jani, Ms. Jalpa Mitesh Jani, Mr. Jagdish Jani (Director of Sapan Chemical Limited, Surya Mangal Media and Entertainment Pvt. Ltd. and Acil Cotton Limited) and Mr. Mitesh Jagdish Jani (Director of Novagold Petro-Resources Limited).

Mahendrabhai Sakalchand Shah

He is one of the directors of Heema Infocom Limited and GFL Financial India Limited.

Vishal Kumar Shah He is one of the directors of Cornhill Trading Co. Pvt. Ltd., Earth Exim Limited and Do -Max Steel Limited.

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34. I note from the above examination and the factors mentioned at Annexure A, that the

entities belonging to the Kelvin Fincap Group are prima-facie related/connected with each

other and with Kelvin.

35. I also note that during the Examination Period, the traded volume and the liquidity in

the shares of Kelvin increased substantially only after the Kelvin Fincap Group started

trading in the said shares. The Kelvin Fincap Group entities brought up the share price

from ` 151.55 to almost ` 1070/- (adjusted)/ ` 535/- (unadjusted) through persistently

matched trades within the group during the Examination Period. Also, the Kelvin Fincap

Group entities continuously executed orders at a price above LTP leading to an artificial

price rise. In my view, such a pattern of trading by placing buy orders at a price higher

than the LTP is apparently against the accepted economic rationale that a buyer would

always wish to purchase shares at the lowest available price. The modus operandi used by

Kelvin Fincap Group to raise the price of the scrip and to create artificial volume is as

under:

A. Kelvin issued 1,30,00,000 shares in physical form to 56 related entities on March 20,

2012. It made false disclosure about number of allottees to camouflage the issuance

to more than 49 persons so as to avoid compliance of issuance of prospectus and

detailed disclosures therein. It concealed the actual number of allottees.

B. Thereafter, the shares of Kelvin were transferred among Kelvin Fincap Group entities

in physical as well as dematerialized form after April 01, 2012.

C. Suddenly after June 18, 2013, Kelvin Fincap Group entities started to trade heavily in

Kelvin with huge trading volume concentration on BSE.

D. Kelvin Fincap Group entities dealt amongst themselves in the market i.e. they were

observed to be buying and selling shares amongst each other thereby creating

artificial trading volume. Such artificial volume constituted almost 95.68% of the

total market volume during the Examination Period. Sans these entities, the volume

of trading in Kelvin was very low.

E. Kelvin Fincap Group also significantly exerted an upward pressure on the price, an act

inconsistent with normal buyer behaviour.

36. I further note that the sequence of events and pattern of transactions in this case prima

facie indicate that Kelvin issued new shares to certain entities, which were subsequently

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transferred by these allottees to other Kelvin Fincap Group entities. The promoters of

Kelvin viz. Keyur Shah, Kavita Shah and Keyur Shah HUF also transferred their

shares off-market in physical form to other entities belonging to the Kelvin Fincap

Group. Thereafter, the Kelvin Fincap Group entities by indulging in non- genuine trading

amongst themselves through repeated and continuous substantial matched transactions

in the illiquid scrip of Kelvin created artificial volumes in the scrip and manipulated its

price. Such transactions were prima facie carried out for the sole or dominant purpose

of creating artificial volumes in the scrip and manipulating its price by taking the scrip

to entice trading therein at artificial price. The acts, omissions and conduct of the

Kelvin Fincap Group as observed during preliminary examination prima facie fall in the

definition of "fraud' under regulation 2(1) (c) of the SEBI(Prohibition of Fraudulent

and Unfair Trade Practices Relating to Securities Market) Regulation 2003 (hereinafter

referred to as "PFUTP Regulations") which reads as under:-

“fraud” includes any act, expression, omission or concealment committed whether in a deceitful manner or not by a person or by any other person with his connivance or by his agent while dealing in securities in order to induce another person or his agent to deal in securities, whether or not there is any wrongful gain or avoidance of any loss, and shall also include— (1) a knowing misrepresentation of the truth or concealment of material fact in order that another person may act to his detriment; (2) a suggestion as to a fact which is not true by one who does not believe it to be true; (3) an active concealment of a fact by a person having knowledge or belief of the fact; (4) a promise made without any intention of performing it; (5) a representation made in a reckless and careless manner whether it be true or false; (6) any such act or omission as any other law specifically declares to be fraudulent, (7) deceptive behaviour by a person depriving another of informed consent or full participation, (8) a false statement made without reasonable ground for believing it to be true. (9) the act of an issuer of securities giving out misinformation that affects the market price of the security, resulting in investors being effectively misled even though they did not rely on the statement itself or anything derived from it other than the market price."

And “fraudulent” shall be construed accordingly;”

37. In view of the above , I am of the prima facie view that Kelvin Fincap Group entities

adopted fraudulent device and artifice to defraud the genuine shareholders of Kelvin

and have thus violated sections 12A (a) (b) and (c) of the SEBI Act, 1992 and

regulations 3(a), (b), (c), (d), 4(1) and 4(2)(a), (b), (e) and (g) of the PFUTP Regulations

which read as under:

SEBI Act, 1992 "Prohibition of manipulative and deceptive devices, insider trading and substantial acquisition of securities or control. 12A. No person shall directly or indirectly –

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(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; (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

there under;"

PFUTP Regulations "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 securities 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;

38. I further note that the shares of Kelvin were allotted to 56 entities. However, it

appears that Kelvin concealed the actual number of allottees and prima facie made false

disclosure in that regard to camouflage the issuance to more than 49 persons so as to

avoid compliance of issuance of prospectus and detailed disclosures therein. Such act

omission and conduct, prima facie, apart from being fraudulent and in violation of the

provisions of sections 12A (a) (b) and (c) of the SEBI Act, 1992, regulations 3(b), (c),

(d) and 4(1) of the PFUTP Regulations were also in contravention of the provisions of

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sections 56, 60 and 73 read with section 67(3) of the Companies Act, 1956 and

regulations 4(2), 5(1), 5(7), 6, 7, 25, 36, 37, 46, and 57 of ICDR Regulations. Even if

the allotment in this case was a preferential allotment the Kelvin and its directors prima

facie contravened the provisions of regulation 78(2) of the ICDR Regulations as they

connived and allowed transfer of shares during the lock- in period of one year.

Kelvin’s non-cooperative attitude during the Preliminary Examination further leads to

these preliminary findings against it.

39. In this case, as observed hereinabove, the shareholding pattern filed by Kelvin with

BSE for the quarter ended June 30, 2012 was incorrect. I am of the view that this act

and omission of Kelvin is prima facie in violation of clause 35 of the Listing Agreement

read with section 21 of the Securities Contracts (Regulation) Act, 1956 (hereinafter

referred to as “SCRA”). Further, Keyur M. Shah, Keyur M Shah (HUF) and Kavita K

Shah have failed to disclose changes in their shareholding to BSE and have thereby

prima facie violated provisions of regulation 13(4A) of the PIT Regulations.

40. It is trite to say that SEBI is mandated to regulate activities in the securities market

thereby encouraging transparent and fair practices by the market participants. The

entities of Kelvin Fincap Group as stated in this order are prima facie found to be

instrumental in manipulating trading in scrip of Kelvin by the intricate modus operandi.

The acts, omissions and conduct of Kelvin and entities of the Kelvin Fincap Group as

described above is prima facie inimical to the interests of participants in the securities

market. It is noted that the entities of Kelvin Fincap Group have continued with their

trading in the scrip in the same manner as discussed hereinabove even after the

Examination Period. The price of the scrip Kelvin has further increased from `535/-

to `599.50/- after the Examination Period (i.e. from May 30, 2014 to August 01, 2014)

with an average volume of 14,223 shares. The Kelvin Fincap Group is still actively trading

in the scrip by contributing 66% to gross market volume and 79.14% to total positive

LTP contribution in the price of the scrip. Such trading and price rise is neither

supported by fundamentals of Kelvin nor by any other factor including any corporate

announcement by it during the post Examination Period, which may justify the kind of

rise which the price of the scrip has gone through. If such concerted and prima facie

fraudulent dealings in securities of an illiquid scrip as in this case are allowed to

continue in the market, the same is fraught with danger of immense mischief and

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incalculable damage to the securities market besides undermining the confidence of the

investors in the fairness and integrity of the market.

41. In this case, it has been observed that out of total contribution of Kelvin Fincap Group to

the total purchase volume, positive LTP and new high price, Shortlisted Group of

Kelvin Fincap Group has been observed to have contributed 83.27%, 82.17% and

83.09% of the total purchase volume, positive LTP and new high price respectively.

Further, all directors including Mansukh Sanghvi and Surekhaben K Shah are prima

facie liable for the acts, omissions and conduct of Kelvin as prima facie found in this

case. I further note that promoters and some of the directors of Kelvin are part of the

Shortlisted Group.

42. Apart from the above, I note that, as on August 11, 2014, the following entities of

Kelvin Fincap Group which is prima facie found to have adopted fraudulent device and

artifice, are holding substantial quantity of shares in Kelvin ( more than 1% of its share

capital):-

Table 12: Kelvin Fincap Group Entities holding substantial shares in Kelvin

S.No. PAN Name Shareholding

No. %

1 AAACM0623J Inventure Finance Private Limited 1106112 3.95

2 ARYPS5993F Naresh Nagindas Shah 1009163 3.61

3 AAFCS2725Q Sapan Chemicals Limited 863281 3.08

4 AACCD7020L Do Max Steel Limited 757224 2.71

5 AATPD0728R Mukesh Nanubhai Desai 734527 2.62

6 AAACR9384B RFL International Limited 700602 2.50

7 ALZPB9604R Rupesh Balkrishna Bhoir 699902 2.50

8 AAJPB7775N Kavita Sunish Behl 675500 2.41

9 AMVPJ5720H Jalpa M Jani 630472 2.25

10 AKSPM3939N Kirti Kantilal Mehta 522345 1.87

11 AAOPS2033H Geeta Narendra Shah 400000 1.43

12 AADPS8752L Hasmukhlal Ramanlal Shah 391300 1.40

13 AIKPM4674N Shobhanaben N. Moradia 390750 1.40

14 AMTPM0749H Bharat N. Moradiya 390600 1.40

15 AEGPD4889J Vasantben Dhanjibhai Donda 385590 1.38

16 AIVPM3622K Mukesh N. Moradia 384160 1.37

17 AIVPM3623J Shehul V. Moradia 378377 1.35

18 ACXPP9049B Bhimjibhai D. Chanchapara 374950 1.34

19 AEIPD5332A Dhanjibhai S. Donda 366460 1.31

20 ACXPP9026C Vallabhbhai D. Sachapra 360900 1.29

21 AMTPM8714C Hiren Tulsibhai Moradia 339500 1.21

22 ACRPM4534E Rajesh Moradia 334900 1.20

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23 AFMPB0449P Jayshree Shankar Bhosle 325847 1.16

24 AACCC0591P Cornhill Trading Company Pvt Ltd 316521 1.13

25 ALEPM6311R Dharmesh Tulsibhai Moradia 300000 1.07

43. The entities mentioned in the above table have either been alloted shares by way of

further issue or have transacted in the scrip through off-market transfers amongst the

entities of the Group as discussed hereinabove. These entities, by virtue of having

sizeable holding (i.e. more than 1%) and being, prima facie, part of the scheme executed

by Kelvin Fincap Group, have the potential of not only disturbing the market equillibrium

but also inducing the gullible investors to buy their holding at the artificially raised

price.

44. Considering the above facts and circumstances, I am of the view that an urgent

preventive and remedial action needs to be taken by way of ad interim ex-parte order in

this case, during pendency of investigation in the matter.

45. I, therefore, in order to protect the interest of the investors and the integrity of the

securities market, in exercise of the powers conferred upon me in terms of section 19

read with section 11(1), section 11 (4) (b) and section 11B of the SEBI Act, 1992 and

section 12A of the SCRA, pending investigation and passing of final order, hereby

issue following directions, by way of this ad-interim ex-parte order:

a) The following entities are restrained from accessing the securities market and further

prohibited from buying, selling or dealing in the securities markets, either directly or

indirectly, in any manner whatsoever, till further directions:

Sl. No.

Name of the entity PAN

1 Kelvin Fincap Limited AAACD1881H

2 Keyur M Shah AAHPS4084K

3 Keyur M Shah (HUF) AAAHK5034L

4 Kavita K Shah AAYPS3458E

5 Dahyabhai Shares And Stock Brokers Ltd AAACD1880G

6 Bhavik Satish Badani ALRPB9295L

7 Bipin Bhikhabhai Patel AIDPP3653M

8 Sushma Vimalkumar Raval BBPPE7839K

9 Mahendrabhai Sakalchand Shah AJMPS0962J

10 Mansukh Sanghvi ABJPS8618E

11 Vishal Kumar Shah AYBPS0534J

12 Surekhaben K Shah BORPS0804Q

13 Cromakem Limited AAECC0841Q

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14 Do Max Steel Limited AACCD7020L

15 Stardom Trading Company Pvt Ltd AAHCS1332H

16 Sapan Chemicals Limited AAFCS2725Q

17 Fast Track Entertainment Limited AAACF7961Q

18 Cornhill Trading Company Pvt Ltd AACCC0591P

19 Sonal International Ltd AACCS1185R

20 Jalpa Jani AMVPJ5720H

21 Kirti Mehta AKSPM3939N

22 Jayshree Shankar Bhosle AFMPB0449P

23 Nova Gold Petro Resources Limited AAACO2454R

24 Acil Cotton Industries Limited AABCA7788F

25 Zimig Trading Company Private Limited AAACZ6848C

26 Inventure Finance Private Limited AAACM0623J

27 Naresh Nagindas Shah ARYPS5993F

28 Mukesh Nanubhai Desai AATPD0728R

29 RFL International Limited AAACR9384B

30 Rupesh Balkrishna Bhoir ALZPB9604R

31 Kavita Sunish Behl AAJPB7775N

32 Geeta Narendra Shah AAOPS2033H

33 Hasmukhlal Ramanlal Shah AADPS8752L

34 Shobhanaben N. Moradia AIKPM4674N

35 Bharat N. Moradiya AMTPM0749H

36 Vasantben Dhanjibhai Donda AEGPD4889J

37 Mukesh N. Moradia AIVPM3622K

38 Shehul V. Moradia AIVPM3623J

39 Bhimjibhai D. Chanchapara ACXPP9049B

40 Dhanjibhai S. Donda AEIPD5332A

41 Vallabhbhai D. Sachapra ACXPP9026C

42 Hiren Tulsibhai Moradia AMTPM8714C

43 Rajesh Moradia ACRPM4534E

44 Dharmesh Tulsibhai Moradia ALEPM6311R

b) Kelvin Fincap Limited (PAN: AAACD1881H) is restrained from raising further

capital, either directly or indirectly, in any manner whatsoever, till further directions.

46. SEBI reserves right to proceed against other entities of Kelvin Fincap Group at any stage

of the investigation or thereafter. The persons/entities against whom this order is

passed may file their replies, if any, to SEBI within 21 days from the date of receipt of

this order, if they so desire, avail an opportunity of personal hearing on a date, place

and time fixed in that regard by Securities and Exchange Board of India.

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47. This order is without prejudice to the right of SEBI to take any other action that may

be initiated against the aforementioned entities, mentioned in para 40 above, in

accordance with law.

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

DATE: AUGUST 14th , 2014 RAJEEV KUMAR AGARWAL

PLACE: MUMBAI WHOLE TIME MEMBER


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ANNEXURE - A

S. No.

PAN Name Basis of Relationship

1 AAACD1880G Dhayhabhai Shares and Stock Brokers Pvt. Ltd.

1. The entity is the promoter of Kelvin Fincap Limited ("Kelvin") as on June 30, 2014 as per BSE website.

2. The entity has received `25,000 from Cromakem Limited on 12/05/2012.

2 AAHPS4084K Keyur M Shah 1. The entity is director of Dhayhabhai Shares and Stock Brokers Pvt. Ltd and was promoter of Kelvin as per shareholding pattern on BSE website quarter ending December 31, 2012.

2. The entity transferred shares to Mr. Narendra R Shah, Mr. Mahesh R Shah, Mr. Abhishek N Shah and Ms. Geeta N Shah in physical form.

3 AAAHK5034L Keyur M Shah (HUF)

1. The entity is an HUF with Keyur M Shah as the karta and was the promoter of Kelvin as on March 31, 2012 as per BSE website.

2. The entity transferred 50,000 shares to Narendra R Shah (HUF) in physical form on 07/04/2012.

4 AAYPS3458E Kavita K Shah 1. The entity is director of Dhayhabhai Shares and Stock Brokers Pvt. Ltd and was promoter of Kelvin as per shareholding pattern on BSE website for quarter ending December 31, 2012. She also shares common address with Keyur M Shah viz, 22 / 23, Purab Apartment, 42, B. G. Kher Marg, Malbar Hill Mumbai 400006.

2. The entity transferred shares to Mr. Narendra R Shah, Mr. Abhishek N Shah and Ms. Geeta N Shah in physical form, on 07/04/2012.

5 ALRPB9295L Bhavik Satish Badani

1. The entity is director of Kelvin as per MCA and BSE websites

2. The entity is one of the directors of Cromakem Limited.

6 AIDPP3653M Bipin Bhikhabhai Patel

1. The entity is one of the directors of Kelvin as per MCA and BSE website.

2. The entity shares common address, viz. 401 B-28, Shanti Nagar Co. Op. Hsg. Ltd. Shanti, Nagar, Sec - 7, Above Indra Hospital, Mira Road, Mumbai, 401107, with Mr. Jitendra Patel (director of RFL International Limited and Fast Track Entertainment Limited).

7 BBPPE7839K Sushma Vimalkumar Raval

1. The entity is one of the directors of Kelvin as per MCA website.

2. The entity is also the director of Millennum Cybertech Limited.

3. The entity shares common address, viz. 23 Shri Ram Vihar

Rokadia Lane, Borivali West, Mumbai, 400092, with Mr. Vimalkumar Sureshchandra Raval, Ms. Padmaben Jagdish Jani, Ms. Jalpa Mitesh Jani, Mr. Jagdish Jani (Director of Sapan Chemical Limited, Surya Mangal Media and Entertainment Pvt. Ltd. and Acil Cotton Limited) and Mr. Mitesh Jagdish Jani (Director of Novagold Petro-Resources Limited).

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8 AJMPS0962J Mahendrabhai Sakalchand Shah

1. The entity one of the directors of Kelvin as per MCA Website.

2. The entity is also a director of Heema Infocom Limited and GFL Financial India Limited.

9 AYBPS0534J Vishal Kumar Shah 1. The entity is one of the directors of Kelvin as per BSE website.

2. The entity is one of the directors of Cornhill Trading Co. Pvt. Ltd., Earth Exim Limited and Do Max Steel Limited.

10 AAECC0841Q Cromakem Limited 1. Mr. Bhavik Satish Badani is one of the directors of Kelvin and Cromakem Limited.

2. Narendra Ramanlal Shah and Cromakem Limited share

common address, viz. 24, jalaram Nagar, opp.chamunda Circle, ganjawala Lane,Borivali(w), , Mumbai, Maharashtra - 400092.

3. Ms. Pallavi Chetan Pandit is one of the directors of Cornhill

Trading Co. Pvt. Ltd, Cromakem Limited, Sonal International Limited, Stardom Trading Co. Pvt. Ltd. and IFSL Limited


5. The entity received/transfered funds from/to SDFC Finance Limited and Kosha Cubidor Containers Limited.

11 AACCD7020L Do Max Steel Limited

1. The entity shares common director viz, Mr. Vishal Kumar Shah, with Kelvin, Cornhill Trading Co. Pvt. Ltd. and Earth Exim Limited.


12 AAHCS1332H Stardom Trading Company Pvt Ltd

1. Cornhill Trading Company Pvt Ltd, Stardom Trading Company Pvt Ltd and Acil Cotton Industries Limited share common address, viz. 38, Ganga Vihar, 3rd Floor, Rokadia Lane, Borivali (w), Mumbai, Maharashtra - 400092.


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13 AAFCS2725Q Sapan Chemicals Limited

1. Earth Exim Ltd, Ms. Geeta N Shah, Sapan Chemicals Limited and Mr. Narendra Ramanlal Shah share common address, viz. 23 Jalaram Nagar Nr. Chamunda Circle Gajawala Lane Borivli West, Mumbai, Maharashtra - 400092.

2. Ms.Sushma Vimalkumar Raval (Director of Kelvin as per

MCA website), Mr. Vimalkumar Sureshchandra Raval, Ms. Padmaben Jagdish Jani, Ms. Jalpa Mitesh Jani, Mr. Jagdish Jani (Director of Sapan Chemical Limited, Surya Mangal Media and Entertainment Pvt. Ltd. and Acil Cotton Limited) and Mr. Mitesh Jagdish Jani (Director of Novagold Petro-Resources Limited) share common address, viz. 23 Shri Ram Vihar Rokadia Lane, Borivali West, Mumbai, 400092.

3. Mr. Jayshree Shankar Bhosle, Heema Infocom Limited, Do

Max Steel Limited, Suryamangal Media And Entertainment Limited, Cornhill Trading Company Pvt Ltd, Sapan Chemicals Limited, Ms. Padmaben Jagdish Jani, Ms. Jalpa Mitesh Jani, Cromakem Limited, Acil Cotton Industries Limited, Mr. Rupesh Balkrishna Bhoir, Mr. Chirag Dineshkumar Shah, Mr. Namdeo Shantaram Gole, Ms. Varsha Praful Trivedi, Mr. Mahesh Ramanlal Shah, Ms. Geeta Narendra Shah, Zimig Trading Company Private Limited and Mr. Parag Chandrkant Shah share common e-mail ID '[email protected]'.

4. Jaishree Shankar Bhosle is the promoter of Sapan Chemical

Limited, as per BSE website.

14 AAACF7961Q Fast Track Entertainment Limited

1. Director of Fast Track Entertainment Limited and RFL International Limited (Jitendra Patel) share same address with the Director of Kelvin, Mr. Bipin Patel, viz. 401 B-28, Shanti Nagar Co. Op. Hsg. Ltd. Shanti, Nagar, Sec - 7,Above Indra Hospital, Mira Road,, Mumbai, 401107.

2. Acil Cotton Industries Limited and Fast Track Entertainment Limited share common address, viz. B-7/404 A, Natraj Township Part-ii, near Parshuram Nagar Society, Sayaji Ganj,, Vadodara, Gujarat - 390005.

3. Cornhill Trading Company Pvt Ltd, Earth Exim Ltd,

Stardom Trading Company Pvt Ltd, Mr. Rupesh Balkrishna Bhoir, Fast Track Entertainment Limited and Mr. Chirag Dineshkumar Shah, share common e-mail ID '[email protected]'.

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15 AACCC0591P Cornhill Trading Company Pvt Ltd

1. Mr. Vishal Kumar Shah is one of the director of Kelvin, Cornhill Trading Co. Pvt. Ltd., Earth Exim Limited and Do Max steel limited.

2. Universal Credit and Securities Limited, Suryamangal Media

And Entertainment Limited, Cornhill Trading Company Pvt Ltd and Gfl Financials India Limited share common address, viz. 15 Shriram Vihar, Rokadia Lane, Borivali (w), Mumbai, Maharashtra, India, 400092.


4. Ms. Pallavi Chetan Pandit is one of the directors of Cornhill

Trading Co. Pvt. Ltd, Cromakem Limited, Sonal International Limited, Stardom Trading Co. Pvt. Ltd. and IFSL Limited.



6. Cornhill Trading Company Pvt Ltd, Earth Exim Ltd,


16 AACCS1185R Sonal International Ltd



17 AAACO2454R Nova Gold Petro Resources Limited

1. Ms. Sushma Vimalkumar Raval (Director of Kelvin as per MCA website), Mr. Vimalkumar Sureshchandra Raval, Ms. Padmaben Jagdish Jani, Ms. Jalpa Mitesh Jani, Mr. Jagdish Jani (Director of Sapan Chemical Limited, Surya Mangal Media and Entertainment Pvt. Ltd. and Acil Cotton Limited) and Mr. Mitesh Jagdish Jani (Director of Novagold Petro-Resources Limited) share common address, viz. 23 Shri Ram Vihar Rokadia Lane, Borivali West, Mumbai, 400092, Maharashtra, India.

2. The entity received ` 25,00,000 from Cromakem Ltd on 20/11/2013

18 AAACI4383H IFSL Limited Ms. Pallavi Chetan Pandit is one of the directors of Cornhill Trading Co. Pvt. Ltd, Cromakem Limited, Sonal International Limited, Stardom Trading Co. Pvt. Ltd. and IFSL Limited

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19 AABCA7788F Acil Cotton Industries Limited



3. Ms. Sushma Vimalkumar Raval (Director of Kelvin as per

MCA website), Mr. Vimalkumar Sureshchandra Raval, Ms. Padmaben Jagdish Jani, Ms. Jalpa Mitesh Jani, Mr. Jagdish Jani (Director of Sapan Chemical Limited, Surya Mangal Media and Entertainment Pvt. Ltd. and Acil Cotton Limited) and Mr. Mitesh Jagdish Jani (Director of Novagold Petro-Resources Limited) share common address, viz. 23 Shri Ram Vihar Rokadia Lane, Borivali West, Mumbai, 400092.



5. Vimalkumar Raval is one of the directors of Zimig Trading

Pvt. Ltd. and Acil Cotton Industries Limited.

20 AAACZ6848C Zimig Trading Company Private Limited


2. Vimalkumar Raval is one of the directors of Zimig Trading

Pvt. Ltd. and Acil Cotton Industries Limited.

21 AAHCS4914K Suryamangal Media & Entertainment Ltd

1. The entity is one of the preferential allottees. 2. Universal Credit and Securities Limited, Suryamangal Media

And Entertainment Limited, Cornhill Trading Company Pvt Ltd and Gfl Financials India Limited share common address, viz. 15 Shriram Vihar, Rokadia Lane, Borivali (w), Mumbai, Maharashtra, India, 400092.

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22 AABCE3676Q Earth Exim Ltd 1. Mr. Vishal Kumar Shah is one of the directors of Kelvin, Cornhill Trading Co. Pvt. Ltd., Earth Exim Limited and Do Max Steel Limited.

2. Earth Exim Ltd, Ms. Geeta N Shah, Sapan Chemicals

Limited and Mr. Narendra Ramanlal Shah share common address, viz. 23 Jalaram Nagar Nr. Chamunda Circle Gajawala Lane Borivli West, , Mumbai, Maharashtra, India, 400092.

3. Mr. Narendra R Shah is one of the directors of Earth Exim

Limited and Universal Credit and Securities Limited. 4. Cornhill Trading Company Pvt Ltd, Earth Exim Ltd,


23 AADCH2621N Heema Infocom Limited

1. Mr. Mahendrabhai Sakalchand Shah is one of the directors of Kelvin, Heema Infocom Limited and GFL Financials India Limited.



24 AABCG0597Q GFL Financial India Ltd

1. The entity is one of preferential allottees of Kelvin.

2. Mr. Mahendrabhai Sakalchand Shah is one of the directors of Kelvin, Heema Infocom Limited and GFL Financials India Limited.

3. Universal Credit and Securities Limited, Suryamangal Media

And Entertainment Limited, Cornhill Trading Company Pvt Ltd and GFL Financials India Limited share common address, viz. 15 Shriram Vihar, Rokadia Lane, Borivali (w), Mumbai, Maharashtra, India, 400092.

25 AAACR9384B RFL International Limited .

1. Director of Fast Track Entertainment Limited and RFL International Limited (Jitendra Patel) share same address with the Director of Kelvin, Mr. Bipin Patel, viz. 401 B-28, Shanti Nagar Co. Op. Hsg. Ltd. Shanti, Nagar, Sec - 7,Above Indra Hospital, Mira Road,, Mumbai, 401107, Maharashtra, India.


26 AABCM8712D Millennum Cybertech Ltd

Ms. Sushma Vimalkumar Raval is one of the directors of Kelvin and Millennium Cybertech Limited.

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27 AAACU2627G Universal Credit And Securities Ltd

1. Mr. Narendra R Shah is one of the directors of Earth Exim Limited and Universal Credit and Securities Limited.

2. Universal Credit and Securities Limited, Suryamangal Media And Entertainment Limited, Cornhill Trading Company Pvt Ltd and Gfl Financials India Limited share common address, viz. 15 Shriram Vihar, Rokadia Lane, Borivali (w), Mumbai, Maharashtra, India, 400092.

28 AADCS2886E SDFC Finance Ltd The entity received/transferred funds from/to Kelvin and Cromakem.

29 AAACK6201G Kosha Cubidor Containers Ltd

The entity received/transferred funds from/to Cromakem.

30 AAOPS2034A Mahesh Ramanlal Shah

1. The entity is one of the directors of Sapan Chemical Limited. 2. The entity received shares from Keyur M Shah, promoter of

Kelvin till December 31, 2012, in physical form. 3. Ms. Geeta Narendra Shah, Mr. Narendra Ramanlal Shah, Mr.

Mahesh Ramanlal Shah and Mr. Abhishek Narendra Shah share common address, viz. D-28-205 Yogi Nagar Borivali West Mumbai.


31 ANIPR5608Q Vimalkumar Sureshchandra Raval


2. Vimalkumar Sureshchandra Raval is one of the directors of Zimig Trading Pvt. Ltd. and Acil Cotton Industries Limited.

32 ARYPS5993F Naresh Nagindas Shah

The entity is director of GFL Financial India Limited.

33 AAPPS6559P Narendra Shah 1. The entity received shares from Keyur M Shah and Kavita K Shah, promoters of Kelvin till December 31, 2012, in physical form.

2. Ms. Geeta Narendra Shah, Mr. Narendra Ramanlal Shah, Mr. Mahesh Ramanlal Shah and Mr. Abhishek Narendra Shah share common address, viz. D-28-205 Yogi Nagar Borivali West Mumbai.



4. Mr. Narendra R Shah is one of the directors of Earth Exim

Limited and Universal Credit and Securities Limited.

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5. Narendra Ramanlal Shah and Cromakem Limited share

common address, viz. 24,jalaram Nagar,opp.chamunda Circle,gemjawala Lane, Borivali(w), Mumbai Maharashtra, India, 400092.

34 AAAHN2023C Narendra R Shah (HUF)

1. The entity is HUF of Narendra R Shah.

2. The entity received 50,000 shares from Keyur M Shah (HUF), promoter of Kelvin, in physical form, on 07/04/2012.

35 AAOPS2033H Geeta Narendra Shah

1. The entity received shares from Keyur M Shah and Kavita K Shah, promoter of Kelvin till December 31, 2012, in physical form.

2. Ms. Geeta Narendra Shah, Mr. Narendra Ramanlal Shah, Mr.

Mahesh Ramanlal Shah and Mr. Abhishek Narendra Shah share common address, viz. D-28-205 Yogi Nagar Borivali West Mumbai.




36 BFVPS2543P Abhishek N Shah 1. The entity received shares from Keyur M Shah and Kavita K Shah, promoter of Kelvin till January 15, 2013, in physical form.

2. Ms. Geeta Narendra Shah, Mr. Narendra Ramanlal Shah, Mr. Mahesh Ramanlal Shah and Mr. Abhishek Narendra Shah share common address, viz. D-28-205 Yogi Nagar Borivali West Mumbai.

37 ADQPJ5053P Padmaben Jagdish Jani

1. Ms. Sushma Vimalkumar Raval (Director of Kelvin as per MCA website), Mr. Vimalkumar Sureshchandra Raval, Ms. Padmaben Jagdish Jani, Ms. Jalpa Mitesh Jani, Mr. Jagdish Jani (Director of Sapan Chemical Limited, Surya Mangal Media and Entertainment Pvt. Ltd. and Acil Cotton Limited) and Mr. Mitesh Jagdish Jani (Director of Novagold Petro-Resources Limited) share common address, viz. 23 Shri Ram Vihar Rokadia Lane, Borivali West, Mumbai, 400092, Maharashtra, India.

2. Mr. Jayshree Shankar Bhosle, Heema Infocom Limited, Do Max Steel Limited, Suryamangal Media And Entertainment Limited, Cornhill Trading Company Pvt Ltd, Sapan Chemicals Limited, Ms. Padmaben Jagdish Jani, Ms. Jalpa Mitesh Jani, Cromakem Limited, Acil Cotton Industries Limited, Mr. Rupesh Balkrishna Bhoir, Mr. Chirag

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Dineshkumar Shah, Mr. Namdeo Shantaram Gole, Ms. Varsha Praful Trivedi, Mr. Mahesh Ramanlal Shah, Ms. Geeta Narendra Shah, Zimig Trading Company Private Limited and Mr. Parag Chandrkant Shah share common e-mail ID '[email protected]'.

38 AMVPJ5720H Jalpa Jani 1. Ms. Sushma Vimalkumar Raval (Director of Kelvin as per MCA website), Mr. Vimalkumar Sureshchandra Raval, Ms. Padmaben Jagdish Jani, Ms. Jalpa Mitesh Jani, Mr. Jagdish Jani (Director of Sapan Chemical Limited, Surya Mangal Media and Entertainment Pvt. Ltd. and Acil Cotton Limited) and Mr. Mitesh Jagdish Jani (Director of Novagold Petro-Resources Limited) share common address, viz. 23 Shri Ram Vihar Rokadia Lane, Borivali West, Mumbai, 400092, Maharashtra, India.



39 AKSPM3939N Kirti Mehta As per the bank Account No. 911010005936771 of Kirti Mehta with Axis Bank Limited, the entity received/transferred funds from/to Kelvin, Cromakem Limited, Stardom Trading Co. Pvt. Ltd., Fast Track Entertainment Limited, Earth Exim Limited, Cornhill Trading Co. Pvt. Ltd., IFSL Limited, GFL Financial India Limited, Inventure Finance Pvt. Ltd., Sonal International Limited, Kosha Cubidor Containers Limited and Acil Cotton Industries Limited

40 AFMPB0449P Jayshree Shankar Bhosle


2. Jaishree Shankar Bhosle is the promoter of Sapan Chemical Limited, as per BSE website.

41 ALZPB9604R Rupesh Balkrishna Bhoir

Mr. Jayshree Shankar Bhosle, Heema Infocom Limited, Do Max Steel Limited, Suryamangal Media And Entertainment Limited, Cornhill Trading Company Pvt Ltd, Sapan Chemicals Limited, Ms. Padmaben Jagdish Jani, Ms. Jalpa Mitesh Jani, Cromakem Limited, Acil Cotton Industries Limited, Mr. Rupesh Balkrishna Bhoir, Mr. Chirag Dineshkumar Shah, Mr. Namdeo Shantaram Gole, Ms. Varsha Praful Trivedi, Mr. Mahesh Ramanlal Shah, Ms. Geeta Narendra Shah, Zimig Trading Company Private Limited and Mr. Parag Chandrkant Shah share common e-mail ID '[email protected]'.

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42 ARIPG5267E Gole Namdeo Shantaram


43 CFPPS4835H Chirag Dineshkumar Shah


44 ARRPS2518R Parag Chandrkant Shah


45 ABBPT1431A Varsha Trivedi Mr. Jayshree Shankar Bhosle, Heema Infocom Limited, Do Max Steel Limited, Suryamangal Media And Entertainment Limited, Cornhill Trading Company Pvt Ltd, Sapan Chemicals Limited, Ms. Padmaben Jagdish Jani, Ms. Jalpa Mitesh Jani, Cromakem Limited, Acil Cotton Industries Limited, Mr. Rupesh Balkrishna Bhoir, Mr. Chirag Dineshkumar Shah, Mr. Namdeo Shantaram Gole, Ms. Varsha Praful Trivedi, Mr. Mahesh Ramanlal Shah, Ms. Geeta Narendra Shah, Zimig Trading Company Private Limited and Mr. Parag Chandrkant Shah share common e-mail ID '[email protected]'.

46 AMIPS6846A Zubin Kamlesh Shah

The entity is one of the preferential allottees.

47 AAZPM0394A M.V.R.S Prasad The entity is one of the preferential allottees.

48 AAAHJ0191D Ashok Jashraj Jain HUF


49 AAIPS9404N Mithalal Manoharlal Sahlot


50 ACKPM8513A Champaben Devjibhai Makwana


51 AZTPM3476A Deepaben Trabakbhai Makwana


52 AAAPT3253A Jagdish Hari Thakur


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53 AATPD0728R Mukesh N Desai The entity is one of the preferential allottees.

54 AAAPV4085A Rajesh Gopaldas Villaitramani


55 AAAPT6038P Kamlesh Hari Thakur


56 ACJPN8415H Prameela Mohandas


57 AABPK2469A Ashok Gopaldas Kripalani


58 AAEPT2433N Mrs. Lajwanti Hari Thakur


59 AAJPS0851L Mitesh Rajnikant Shah


60 AARPJ2757L Ramniranjan C Jhunjhunwala


61 AETPA7958N Prem Aggarwal The entity is one of the preferential allottees.

62 AAFPS1767F Ketan Bhupendrakumar Shah


63 AACHM2754B Mukesh N Desai (HUF)


64 AHCPP2686C Poonam Pramesagar Pasricha


65 AAIHR3732E Ravi Sancheti (HUF)

1. The entity is one of the preferential allottees. 2. The entity transferred a total of 2,00,000 shares to Jitendra

Tejmal Dugar and Dhiraj Parasmal Dugar in physical form.

66 AQQPS2059B Tasneem Iqbal Syed


67 ABEPN6198B N.Satyanarayana The entity is one of the preferential allottees.

68 ADXPD6143K Mrs.Bhavani Bharatbhai Danga


69 AGKPM6963C Jignasa Subhash Mithawalla


70 ACXPP9026C Vallabhbhai D Sachapara


71 AADPM3931D Subhash Tikamdas Mithawalla


72 ACXPP9049B B.D.Sachpara The entity is one of the preferential allottees.

73 AAACM0623J Inventure Finance Private Ltd

1. The entity is one of the preferential allottees.

2. The entity received `25,22,400 from Cromakem Limited on 13/03/2013.

74 AIVPM3623J Shehul Vallabhbhai Moradiya


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75 AEIPD5332A Dhanjibhai Shamjibhai Donda


76 ACRPM4534E Rajesh Haribhai Moradia


77 AIVPM3622K Mukeshbhai Moradiya


78 AEGPD4889J Vasantben Dhanjibhai Donda


79 AMTPM8714C Hiren Tulsibhai Moradia


80 ADPPD5068B KRISHNA M.DAWDA


81 AIKPM4674N Shobhanaben Nareshbhai Mpradiya


82 AMTPM0749H Bharatbhai Nanjibhai Morada


83 AAJPB7775N Kavita Sunish Behl The entity is one of the preferential allottees.

84 AADPS8752L Hasmukhlal R.Shah The entity is one of the preferential allottees.

85 ABVPJ5592Q Sunita Dinesh Jaiswal

1. The entity is one of the preferential allottees of Kelvin.

2. The entity transferred 2,20,000 shares to Naresh Nagindas Shah on 12/8/2013 through off market transactions.

86 ABVPJ5571B Dinesh Gangaprasad Jaiswal

1. The entity is one of the preferential allottees of Kelvin.

2. The entity transferred 2,50,000 shares to Naresh Nagindas Shah on 12/8/2013 through off market transactions.

87 ALEPM6311R Dharmesh Tulsibhai Moradia


88 AFZPS4055B Falguni Ketan Shah 1. The entity shares common address with Ketan Shah, preferential allottee.

2. The entity received 1700 shares from Ketan Bhupendrakumar Shah on 6/11/2013 and transferred the same number of shares on 27/11/2013 through off market transactions

89 ABOPM3631N Banubibi Sarwar Mohid

The entity received 3000 shares from Cornhill Trading Company Pvt Ltd on 26/6/2013 through off market transactions

90 ABOPM3630P Sarwar Abdulkadir Mohid

The entity received 3000 shares from Cornhill Trading Company Pvt Ltd on 26/6/2013 through off market transactions

91 AABHM5423J Maheshwari Omprakash Basantilal (HUF)

The entity received 3000 shares and 5000 shares from Cornhill Trading Company Pvt Ltd on 8/7/2013 and 16/7/2013 respectively and 2000 shares from Dadima Capital (P) Ltd on 19/11/2013 through off market transactions

92 AKXPR4288E S Rajesh The entity received 5000 shares from Cornhill Trading Company Pvt Ltd on 15/7/2013 through off market transactions

93 ABOPC2448M Anilbhai Devjibhai Chauhan

The entity received 14000 shares from Cornhill Trading Company Pvt Ltd on 2/8/2013 and 5500 shares from Dadima Capital (P) Ltd on 4/9/2013 through off market transactions

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94 AAVPU3814B Bharati Bharat Upadhyay

The entity received 72600 shares from Cromakem Limited on 1/2/2014 through off market transactions and 67400 shares from Mukesh N Desai (HUF) on 16/11/2013 in physical form

95 AGSPD5628B Niranjanaben Ashwinkumar Desai

The entity received 4800 shares from Naresh Nagindas Shah on 5/3/2014 through off market transactions

96 AAVPS2772G Haresh Rajmal Shah


97 AABHS8946N Sanjay Madanlal Sanghvi (HUF)


98 AAAPI4645P Dinesh Dhanjibhai Italia


99 AAGCR4662J Reachsmart Construction Private Limited .


100 AEQPS7882A Priti Vipul Shah The entity received 17400 shares from Naresh Nagindas Shah from 3/12/2013 to 16/1/2014 through off market transactions

101 AADPT0508R Rekha Manoj Thakkar


102 AAVPS6090F Mamta Mahesh Sanghavi


103 ABWPT3678G Chhaya Deepak Thakker


104 AABPS8536Q Chandrika Dharmendra Sanghavi


105 AMVPS6299J Geeta Bharat Sanghvi


106 BMMPS8777F Rushabh Vipul Shah

The entity received 13200 shares from Naresh Nagindas Shah from 3/12/2013 to 21/1/2014 through off market transactions

107 ACQPS5671M Sanjay Madanlal Sanghvi


108 AXFPS1272E Seema Haresh Shah The entity received 9200 shares from Naresh Nagindas Shah on 5/11/2013 through off market transactions

109 ACNPS2202F Priti Sanjay Sanghvi The entity received 20000 shares from Naresh Nagindas Shah on 14/3/2014 through off market transactions

110 AFIPP4761L Dharmeshkumar Vinodchandra Patel

The entity received 3200 shares each from Sonal International Ltd and Dadima Capital (P) Ltd. on 30/8/2013 through off market transactions

111 AABCD2140E Dadima Capital (P) Ltd

Narendra R Shah is one of the directors of the entity. The entity received 1,50,000 shares from Stardom Trading Pvt. Ltd. On August 21, 2013 and 1,00,500 shares from Padmaben Jain on September 04, 2013 through off market transactions.

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112 AHAPP5916H Jaswant Kantilal Parmar

The entity transfered 11430 shares to Cornhill Trading Company Pvt Ltd from 7/4/2014 to 28/4/2014 and 5000 shares to Vijay Govindarajan on 11/4/2014 through off market transactions

113 AIOPG4980F Hiren Kirit Gandhi The entity transfered 2825 shares to Do Max Steel Limited on 30/4/2014 through off market transactions

114 AQQPG4855K Maruti Shankar Gaude

The entity transfered 2130 shares to Dadima Capital (P) Ltd on 9/1/2014 and 85025 shares to Earth Exim Ltd. From 9/1/2014 to 6/5/2014 through off market transactions

115 AHNPD1452H Vidyadhar Ramnaresh Dubey

The entity transfered 4100 shares to Narendra Shah on 2/11/2013, 5530 shares to Dadima Capital (P) Ltd on 9/1/2014 and 61460 shares to Sonal International Limited from 8/2/2014 to 5/3/2014 through off market transactions

116 BPLPR1372B Maheshbhai Chhanalal Raval

The entity transfered 39350 shares to Naresh Nagindas Shah on 2/1/2014 through off market transactions

117 BPPPR0616L Amitkumar Maheshbhai Raval

The entity transfered 29950 shares to Naresh Nagindas Shah on 2/1/2014 through off market transactions

118 AIYPD1020H Vinod Gajanan Dhadave

The entity transfered a total of 29925 shares to Naresh Nagindas Shah on 13/3/2014, 27/3/2014 and 30/4/2014 through off market transactions

119 BINPP6932L Bharatkumar Prahladbhai Prajapati

The entity transferred a total of 10,150 shares to Naresh Shah, Sonalben Dhirenkumar Patel, Minaben Ambalal Patel, Ambalal Ranchhodbhai Patel, Bhavika Jaykumar Patel And Keyur Babulal Patel during the period from 21/11/2013 to 6/3/2014.

120 AOYPM7851H Madhuben H Modi The entity transfered 2900 shares to Naresh Nagindas Shah on 5/3/2014 through off market transactions

121 AADPA1333M Hansaben Mahendra Amin

The entity received 200000 shares from GFL Financial India Ltd on 29/9/2012 in physical form

122 AABPA4050H Mahendra Dhanjibhai Amin


123 AABPD2576M Jitendra Tejmal Dugar

The entity received 100000 shares from Ravi Sancheti (HUF) on 29/9/2012 in physical form

124 ADXPD9319B Dhiraj Parasmal Dugar

The entity received 100000 shares from Ravi Sancheti (HUF) on 29/9/2012 in physical form

125 AAACU8715B Umang Projects Limited

The entity received 1,00,000 shares from Geeta Narendra Shah on 30/4/2012 in physical form

126 AADCS7899F Solex Commercial & Credit Pvt.Ltd.

The entity received 100000 shares from Narendra R Shah on 30/4/2012 in physical form

127 AAICS0162N Dukes Products (India) Limited

The entity received 10000 shares from Geeta Narendra Shah on 30/4/2012 in physical form

128 AADCV0856B Viren Shelters Limited

The entity received 30000 shares from Abhishek N Shah and 70,000 shares from Mahesh R Shah on 30/4/2012 in physical form

129 AABCA7142D Ankit Biscuits Pvt. Ltd.


130 AABCD4645E Dukes Consumer Care Limited

The entity received 50000 shares from Narendra R Shah (HUF) and 50,000 shares from Narendra R Shah on 30/4/2012 in physical form

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131 AAAHO2774F Omprakash Agarwal (HUF)

The entity received 40000 shares from Abhishek N Shah on 30/4/2012 in physical form

132 ACLPA3472F Omprakash Agarwal


133 AFCPJ6983L Ruchit Hiralal Jain The entity received 15000 shares from Mukesh N Desai (HUF) on 25/7/2013 in physical form

134 ADSPA1892P Ajay Shridhar Acharya

The entity received 15000 shares from Mukesh N Desai (HUF) on 25/7/2013 in physical form

135 AAAPJ9174C Champalal Mohanlalji Jain


136 ABOPG4132E Vikas Sarwankumar Gupta

The entity received 30000 shares from Suryamangal Media & Entertainment Ltd on 6/7/2013 in physical form

137 AAGHM2012J Gopi Krishna Manepally (HUF)


138 AAGHM2011M Muralikrishna Manepally


139 ABLPJ0975H Premchand Gainchand Jain


140 AGJPA1748G Ankit Agarwal The entity received 120000 shares from Suryamangal Media & Entertainment Ltd on 29/6/2013 in physical form

141 CAJPS1111F Madhu K Shyamsukha


142 AJGPK7846K Nitin K Kagzi The entity received 5000 shares from Cromakem Limited on 31/10/2012 and 5,000 shares from Millennum Cybertech Limited on 4/5/2013 in physical form

143 AGKPB1054B Suraj Prakash Bhalla


144 AFCPB9484J Naveen Bhalla The entity received 10000 shares from Poonam Premsagar Pasricha on 25/7/2013 in physical form

145 AMDPB7288C Garima Bhalla The entity received 10000 shares from Poonam Premsagar Pasricha on 25/7/2013 in physical form

146 ABHPM9092L Sonalben Vijaybhai Makwana


147 ABHPM9090J Rakshaben Arunbhai Makwana


148 AAPPM6446H Mohanbhai Ranchodlal Makwana


149 AAGPP4875J Jyoti D Parekh The entity received 12500 shares from Poonam Premsagar Pasricha on 25/7/2013 in physical form

150 AHMPP5481H Prakash Narayanbhai Prajapati


151 AAAPD5694H Vinod K Doshi The entity received 40000 shares from Mukesh N Desai (HUF) on 16/11/2013 in physical form

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152 ALZPP3198A Bhagwatilal Pagaria The entity received 17000 shares from Mukesh N Desai (HUF) on 25/7/2013 in physical form

153 ADGPD0192D Rakesh Dhariwal The entity received 8500 shares from Suryamangal Media & Entertainment Ltd on 25/7/2013 in physical form

154 AEEPG7912H Devibai Bhawarlal Gandhi


155 ABSPT8049H Sadhana Tolasariya The entity received 16000 shares from Mukesh N Desai (HUF) on 26/10/2013 in physical form

156 ABTPT0016D Laxmi Kanta Tolasariya


157 ADFPJ1887Q Krunal Ramesh Janani

The entity received 12000 shares from SDFC Finance Ltd on 14/7/2012 in physical form

158 AJSPP5881H Prachi Nitin Kagzi The entity received 7800 shares from Kosha Cubidor Containers Ltd on 31/10/2012 in physical form

159 AAEPP2449Q Shivali D Parekh The entity received 12500 shares from Poonam Premsagar Pasricha on 25/7/2013 in physical form

160 AHMPP6874C Rakesh Narayanbhai Prajapati


161 AQSPS3383G Karnesh Shyamsukha


162 ABCPN0097M Anand Kumar Nahar


163 ACTPR0863K Jaya Lalit Shah The entity received 6000 shares from Suryamangal Media & Entertainment Ltd on 25/7/2013 in physical form

164 AATPC3367M Bhavna Bharatbhai Chopra


165 AFYPB2359C Sweetydevi Hitesh Chopra


166 AAAHC6262J Nemichand B Chopra Huf


167 AAMPC2665F Bharatkumar Nemichand Chopra


168 AAQPC7475F Nemichand Baxiram Chopra


169 ADRPM4459K Mahendra K Mehta The entity received 8500 shares from GFL Financial India Ltd on 25/7/2013 in physical form

170 AEGPS6711Q Suman Rajesh Shah The entity received 6000 shares from Suryamangal Media & Entertainment Ltd on 25/7/2013 in physical form

171 AFZPG5363E Mamta Pravin Gandhi


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172 AAPPM6445E Vijaybhai Mohanbhai Makwana


173 AAJPJ4929L Babita Mahendra Jain


174 ACWPJ4028K Anjana Satish Jain The entity received 5500 shares from GFL Financial India Ltd on 25/7/2013 in physical form

175 AAJPJ8038L Rajashree Nitinkumar Jain


176 ALLPJ0145R Alka Ankit Jain The entity received 5500 shares from GFL Financial India Ltd on 25/7/2013 in physical form

177 AAJPJ4928M Sukhiben Sagarmal Jain


178 AADHJ2188K Satish Sagarmal Jain (HUF)


179 AAAHM8205M Mahendra Sagarmal Jain (HUF)


180 AAAHN4499J Nitin Sagarmal Jain (HUF)


181 AAKHA9197C Ankit Mahendra Jain Huf


182 AAUPS6522K Sailesh Pragji Shah The entity received 10000 shares from Suryamangal Media & Entertainment Ltd on 29/6/2013 in physical form

183 AAAHN3298K Nainesh G Jain Huf The entity received 8200 shares and 50 shares from Kosha Cubidor Containers Ltd on 14/7/2012 and 14/8/2012 respectively and 1000 shares from SDFC Finance Limited on 29/9/2012 in physical form

184 AAEPJ2561P Vaishali Nainesh Jain

The entity received 8300 shares from Kosha Cubidor Containers Ltd and 1200 shares from SDFC Finance Limited on 14/7/2012 in physical form

185 AACPP8181B Kalpesh D Parekh The entity received 12500 shares from Poonam Premsagar Pasricha on 25/7/2013 in physical form

186 ADVPD5950A Priti Dharewa The entity received 5000 shares from Suryamangal Media & Entertainment Ltd on 25/7/2013 in physical form

187 AEDPA7637Q Manish Agrawal The entity received 5000 shares from GFL Financial India Ltd on 25/7/2013 in physical form

188 ACKPS1326D Nitin K Shah The entity received 15000 shares from Suryamangal Media & Entertainment Ltd on 29/6/2013 in physical form

189 AFLPD0265J Kapilaben Umiyashankar Joshi


190 ACXPM5128N Sheetal S Mehta The entity received 8500 shares from GFL Financial India Ltd on 25/7/2013 in physical form

191 ABIPM7371D Chandrika M Mehta The entity received 8500 shares from GFL Financial India Ltd on 25/7/2013 in physical form

192 AACPP8180A Dhirajlal J Parekh The entity received 12500 shares from Poonam Premsagar Pasricha on 25/7/2013 in physical form

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193 AAPPM6035J Shardaben Mohanbhai Makwana


194 AFDPJ1441A Ankit N Janani The entity received 8000 shares from RFL International Limited and 4000 shares from SDFC Finance Limited on 14/7/2012 in physical form

195 ABOPP8114D Manish Porwal The entity received 10000 shares from Suryamangal Media & Entertainment Ltd on 25/7/2013 in physical form

196 AABHD3494G Pramod Kumar Dalmia (HUF)


197 AAAHR0144Q Ramesh C Janani Huf

The entity received 8000 shares from RFL International Limited and 2500 shares from SDFC Finance Limited on 14/7/2012 in physical form

198 AOQPJ6594N Manav J Janani The entity received 10500 shares from SDFC Finance Ltd on 14/7/2012 in physical form

199 AJCPD4157A Kunal Prabhakar Deshmukh


200 AAZPD5085B Hema Prabhakar Deshmukh


201 BMTPS0594M Shreya U Sanghavi The entity received 3500 shares from GFL Financial India Ltd on 25/7/2013 in physical form

202 CAQPK7555L Nimishaben A Kadia


203 AKSPK4046N Harshadkumar B Kadia


204 AFNPK8525J Alkeshkumar Babubhai Kadia


205 AGFPK2166G Shakuntala Karwa The entity received 6500 shares from Mukesh N Desai (HUF) on 14/12/2013 in physical form

206 AAFHP5115A Praveen Chand Amichand (HUF)


207 AGFPK2169K Kamal Kishore Karwa


208 AGFPK2167H Venu Gopal Karwa The entity received 6500 shares from Mukesh N Desai (HUF) on 14/12/2013 in physical form

209 AGFPK2155H Shrikant Karwa The entity received 6500 shares from Mukesh N Desai (HUF) on 14/12/2013 in physical form

210 AACHM6405R Makwana Arunbhai Mohanbhai (HUF)


211 AJCPD8627M Mayuri Prabhakar Deshmukh


212 AFJPR1610P Ramesh Chhallani The entity received 3000 shares from Suryamangal Media & Entertainment Ltd on 25/7/2013 in physical form

213 AAFHS8024K Sheetal S Mehta Huf


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214 AALHR9880C Ramesh Chhallani Huf


215 AAEHN0043C Narendra C Janani Huf

The entity received 8200 shares from RFL International Limited and 2300 shares from SDFC Finance Limited on 14/7/2012 in physical form

216 AAAHJ0488F Jitendra C Janani Huf

The entity received 8900 shares from Universal Credit And Securities Ltd and 1600 shares from SDFC Finance Limited on 14/7/2012 in physical form

217 AJEPB3408Q Shailesh Z Bhandari

The entity received 4000 shares from Poonam Premsagar Pasricha on 25/7/2013 in physical form

218 ANZPD8205A Anup Prabhakar Deshmukh


219 ALWPS7304N Rekha Manoj Shah The entity received 40000 shares from Mukesh N Desai (HUF) on 16/11/2013 in physical form

220 ADGPJ0194B Geetaben Rajeshkumar Jain


221 AEGPN6094P Urmila P Nemani The entity received 3000 shares from Suryamangal Media & Entertainment Ltd on 25/7/2013 in physical form

222 AIVPN2183N Prerak P Nemani The entity received 3000 shares from Suryamangal Media & Entertainment Ltd on 25/7/2013 in physical form

223 AEMPN1814R Nishant P Nemani The entity received 3000 shares from Suryamangal Media & Entertainment Ltd on 25/7/2013 in physical form

224 AKLPJ5402A Minal Krunal Janani

The entity received 8000 shares from Universal Credit And Securities Ltd on 14/7/2012 in physical form

225 AJZPP1664P Avinash Porwal The entity received 10000 shares from Suryamangal Media & Entertainment Ltd on 25/7/2013 in physical form

226 AABHU0096B U R Sanghvi Huf The entity received 3500 shares from GFL Financial India Ltd on 25/7/2013 in physical form

227 AAFHS1862M Srikant Karwa Huf The entity received 5000 shares from Mukesh N Desai (HUF) on 14/12/2013 in physical form

228 AMTPJ9069K Pooja Jain The entity received 2500 shares from Suryamangal Media & Entertainment Ltd on 25/7/2013 in physical form

229 AAEHP3764Q Pawan Kumar Nemani Huf


230 AAEHK3969C Manoj Z Khivsara Huf


231 ACAPS2670J Chaya Sailesh Shah The entity received 10000 shares from Suryamangal Media & Entertainment Ltd on 29/6/2013 in physical form

232 AACHK9840E Kamal Kishor Karwa Huf


233 AJHPK7359L Murari Ramnarayan Karwa


234 ALFPK4226Q Sulochana R Karwa The entity received 5000 shares from Mukesh N Desai (HUF) on 14/12/2013 in physical form

235 AABHV8959A Venu Gopal Karwa Huf


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236 AGFPK2158L Ramanarayan H Karawa


237 AUFPK2191R Archana G Karwa The entity received 5000 shares from Mukesh N Desai (HUF) on 14/12/2013 in physical form

238 AGCPK5348P Neelu Manoj Khivsara


239 AACHS8497K Suresh Rameshwarlal Kothari Huf


240 AFHPV9545F Vishal Jain The entity received 2500 shares from Suryamangal Media & Entertainment Ltd on 25/7/2013 in physical form

241 AAQPB9783P Zumberlal H Bhandari


242 AAFHB8657P Bhavin Chandulal Shah Huf


243 AMGPB6442B Anil Hiralal Bhandari


244 AAVPA0108L Rameshwarlal G Kothari


245 ACXPM5129P Meera Sheetal Mehta


246 DFHPS4978L Divyang Ramesh Sadhwani


247 AAMHR5898D Ramesh Morandmal Sadhwani (HUF)


248 AADPA6233E Sunita Rakesh Agarwal


249 AALHR9586F Rakesh R Agarwal Huf


250 AAPPB2953C Nilesh Vijay Bhatevara


251 ACVPA5077A Rakesh Agarwal The entity received 2000 shares from Suryamangal Media & Entertainment Ltd on 25/7/2013 in physical form

252 ATIPP5949C Saurabh N Patel The entity received 5000 shares from GFL Financial India Ltd on 25/7/2013 in physical form

253 BMDPP9341R Mittal P Patel The entity received 5000 shares from GFL Financial India Ltd on 25/7/2013 in physical form

254 AASPV1975F Ravi Vajawat The entity received 3000 shares from Suryamangal Media & Entertainment Ltd on 25/7/2013 in physical form

255 AABPS7373R Amita Parag Shah The entity received 15100 shares from Cromakem Limited and 1100 shares from Millennium Cybertech Limited on 14/7/2012 in physical form

256 AIGPP8081J Neha D Patel The entity received 5000 shares from GFL Financial India Ltd on 25/7/2013 in physical form

257 ADPPK8753Q Suresh Rameshwarlal Kothari


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258 BBZPB0749L Archana Rohit Bhandari


259 AADHR6147N Rameshwarlal Gulabchand Huf


260 AIGPP8011N Dinesh M Patel The entity received 5000 shares from GFL Financial India Ltd on 25/7/2013 in physical form

261 AVJPS3232Q Pallavi M Shirude The entity received 4000 shares from Poonam Premsagar Pasricha on 25/7/2013 in physical form

262 AAQHS5761J Shirude Milind R Huf


263 AGFPK2157F Ghanshyamdas Karwa


264 EFMPS7289C Yash Parag Shah The entity received 2000 shares from Millennium Cybertech Ltd and 8000 shares from Cromakem Limited on 31/7/2012 in physical form

265 AGLPK7190G Surinder Charansingh Kaur


266 ABMPK0516A Deepak Rameshwarlal Kothari


267 ACNPS1799P Milind R Shirude The entity received 3500 shares from GFL Financial India Ltd on 25/7/2013 in physical form

268 AEJPB4820Q Vandana Anil Bhandari


269 AAAPJ7220P Jayanthi Kumari The entity received 2500 shares from Mukesh N Desai (HUF) on 14/12/2013 in physical form

270 ABWPM8495Q Mangi Devi The entity received 2500 shares from Mukesh N Desai (HUF) on 14/12/2013 in physical form

271 AAIHM3818E Mahaveerkumar Praveenchand (HUF)


272 AAEHV8290D Vimalkumar Praveenchand (HUF)


273 AAFHV9245P Vikramkumar Praveenchand (HUF)


274 AABPS7371P Parag Anandlal Shah

The entity received 18400 shares from Millennum Cybertech Ltd on 14/7/2012 in physical form

275 AFAPD5513L Dinesh Kumar Jain The entity received 5000 shares from Mukesh N Desai (HUF) on 14/12/2013 in physical form

276 ABAPJ3319G Prakash Kumar Jain The entity received 2500 shares from Suryamangal Media & Entertainment Ltd on 25/7/2013 in physical form

277 AIMPB3417A Rohitkumar S Bhandari


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278 AJXPB9684M Rakesh S Bhandari The entity received 4000 shares from Poonam Premsagar Pasricha on 25/7/2013 in physical form

279 AIDPD8304R Pritesh G Deo The entity received 2000 shares from GFL Financial India Ltd on 25/7/2013 in physical form

280 AARPV3324P P Vimal Kumar The entity received 2500 shares from Mukesh N Desai (HUF) on 14/12/2013 in physical form

281 AONPB7989N Bhandari Kanchan Sumtilal


282 AAQPD5950Q Govind D Deo The entity received 2000 shares from GFL Financial India Ltd on 25/7/2013 in physical form

283 AACHV0256P Vijay F Sabadra Huf

The entity received 2000 shares from GFL Financial India LTD on 25/7/2013 in physical form

284 ANMPS8650B Vijay F Sabadra The entity received 2000 shares from GFL Financial India Ltd on 25/7/2013 in physical form

285 ACMPS2295K Sunanda Vijay Sabadra


286 BGWPS0440K Rashmi Vijay Sabadra


287 AACHM6406N Makwana Vijaybhai Mohanbhai Huf


288 BHXPS4067C Shilpa Bagreecha The entity received 2500 shares from Mukesh N Desai (HUF) on 14/12/2013 in physical form

289 AJLPJ2277L Vikas Kumar Jain The entity received 2500 shares from Mukesh N Desai (HUF) on 14/12/2013 in physical form

290 ABTPB2111P Sumtilal Pannalal Bhandari


291 ABWPM8494R P Mahaveer Kumar The entity received 2500 shares from Mukesh N Desai (HUF) on 14/12/2013 in physical form

292 AAFHN2519A Narendra M Agrawal Huf


293 AAPPV3421M Bindu Vajawat The entity received 3000 shares from Suryamangal Media & Entertainment Ltd on 25/7/2013 in physical form

294 AOFPV5904B Rohin Vajawat The entity received 3000 shares from Suryamangal Media & Entertainment Ltd on 25/7/2013 in physical form

295 AAQPD5949R Usha G Deo The entity received 2000 shares from GFL Financial India Ltd on 25/7/2013 in physical form

296 AABPY4151B Shashikant N Yeola The entity received 2000 shares from GFL Financial India Ltd on 25/7/2013 in physical form

297 ALJPS5991A Ramesh Morandmal Sadhwani


298 ANYPS3580Q Sunita Rameshchandra Sadhwani


299 AXDPK5755C Mohit Rajkumar Kothari


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300 ABNPK6901A Durga Rajkumar Kothari


301 AAEHR3848D Rajkumar Rameshwarlal Huf


302 AFAPB6534M Shweta Vivek Kothari


303 ABBPD8991K Padma Devi The entity received 2500 shares from Suryamangal Media & Entertainment Ltd on 25/7/2013 in physical form

304 AIDPD8303J Hitesh G Deo The entity received 2000 shares from GFL Financial India Ltd on 25/7/2013 in physical form

305 AAJHA8394Q Arvind M Agrawal Huf


306 AAAHB8392L Abhay P Bora Huf The entity received 2000 shares from GFL Financial India Ltd on 25/7/2013 in physical form

307 AASPA8019P Kiran Dineshkumar Agrawal


308 AARPV3323L P Vikram Kumar The entity received 2500 shares from Mukesh N Desai (HUF) on 14/12/2013 in physical form

309 AESPJ3783R Rupali Atul Jain The entity received 1500 shares from GFL Financial India Ltd on 25/7/2013 in physical form

310 AALPJ3459K Atul Satishchandra Jain


311 AAKPT6824H Nandkishor Kantilal Tated


312 AFSPB0852N Anita Abhay Bora The entity received 2000 shares from GFL Financial India Ltd on 25/7/2013 in physical form

313 AFRPB3527R Neena Tejpal Bora The entity received 2000 shares from GFL Financial India Ltd on 25/7/2013 in physical form

314 AABHT0453R Tejpal P Bora Huf The entity received 2000 shares from GFL Financial India Ltd on 25/7/2013 in physical form

315 ADHPB4828M Tejpal P Bora The entity received 2000 shares from GFL Financial India Ltd on 25/7/2013 in physical form

316 ADHPB4825G Abhaykumar P Bora


317 AFRPB3530L Suganbai P Bora The entity received 2000 shares from GFL Financial India Ltd on 25/7/2013 in physical form

318 AWNPB0219R Sailee A Bora The entity received 2000 shares from GFL Financial India Ltd on 25/7/2013 in physical form

319 AFQPA2808F Alka Jain The entity received 2500 shares from Mukesh N Desai (HUF) on 14/12/2013 in physical form

320 AANPA7734J Mithailal K Agarawal


321 AFQPA9253C Ranibai M Agarawal


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322 ADPPA4146F Arvind Mithailal Agrawal


323 AALHP4640Q Narayan P Panicker Huf


324 AMLPB2241H Piyush Sunil Bafna The entity received 1200 shares from Suryamangal Media & Entertainment Ltd on 25/7/2013 in physical form

325 ABGPA9107R Narendra M Agrawal


326 AFQPA9251A Swati Narendra Agrawal


327 AHGPB6587L Leena Sunil Bafna The entity received 1000 shares from Suryamangal Media & Entertainment Ltd on 25/7/2013 in physical form

328 AZXPB5572E Priyanka Sunil Bafna


329 AFQPA9252D Neelam Arvind Agrawal


330 AYUPK7834Q Sarthak Sureshkumar Kothari


331 ADVPG5413H Aniruddha R Gawade


332 AALPY6141M Vijaya Shashikant Yeola


333 AAEPC5128R Sampatraj Chhallani The entity received 3000 shares from Suryamangal Media & Entertainment Ltd on 25/7/2013 in physical form

334 AADHB8997E Balkishan Innani Huf


335 ATHPG7447B Akash A Gawade The entity received 2500 shares from GFL Financial India Ltd on 25/7/2013 in physical form

336 AAFHD8458Q Dineshkumar Jain Huf


337 AEXPK9060M Lalita Suresh Kothari


338 AABHG8591H Ghanshyamdas Harikishan Karwa Huf

The entity received 1950 shares from Ghanshyamdas Karwa on 27/3/2014 through off market transactions

339 AACHM6051K Mohanbhai R Makwana Huf


340 AAQPT4000M Namdeo Kisan Tajane

The entity received 80000 shares from Dadima Capital (P) Ltd on 30/8/2013 through off market transactions

341 AGSPT2723R Minal Namdeo Tajane


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342 ADKPP2023P Bharatbhai Zaverbhai Prajapati

The entity received 6000 shares and 4500 shares from Dadima Capital (P) Ltd on 11/9/2013 and 9/10/2013 respectively through off market transactions

343 ARGPA6417L Aishwarya Abhishek Agrawal


344 BHZPA3199P Esha Ankit Agrawal


345 AABHP8743A Gordhanbhai Narandas Patel


346 AOMPC0772K Komilkumar Anilbhai Chauhan


347 ACTPP7683H Dhanjibhai Ravjibhai Dholaria


348 AAEHD9550L Dhanjibhai Ravjibhai Dholaria (Huf)


349 ANPPP5555K Saritaben D Patel The entity received 6000 shares from Dadima Capital (P) Ltd on 27/9/2013 through off market transactions

350 AACCS6506N Siddhachal Tradelink Pvt Ltd


351 AFNPS9308B Vimlaben Kantilal Sanghvi


352 ATRPK4534D Ramesh Krishna Kulaye

The entity transfered a total of 32370 shares to Dadima Capital (P) Ltd from 7/4/2014 to 7/5/2014 through off market transactions

353 AEKPK6751Q Santosh Kumar The entity transfered 13000 shares to Dadima Capital (P) Ltd on 26/12/2013 through off market transactions

354 ABNPV8151B Vijay Govindarajan The entity received 5000 shares from Jaswant Kantilal Parmar on 11/4/2014 through off market transactions

355 ARCPP2280L Keyur Babulal Patel The entity received a total of 2100 shares from Bharatkumar Prahladbhai Prajapati on 21/11/2013 and 27/11/2013 through off market transactions and 5000 shares from Mukesh N Desai HUF on 26/10/2013 in physical form.

356 ACQPP0211N Minaben Ambalal Patel

The entity received a total of 1800 shares from Bharatkumar Prahladbhai Prajapati on 10/12/2013 and 11/12/2013 through off market transactions

357 APLPP4465J Sonalben Dhirenkumar Patel

The entity received a total of 1800 shares from Bharatkumar Prahladbhai Prajapati on 10/12/2013 and 11/12/2013 through off market transactions

358 AACHP4026P Ambalal Ranchhodbhai Patel -

The entity received 1800 shares from Bharatkumar Prahladbhai Prajapati on 11/12/2013 through off market transactions

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359 AXMPP3283D Bhavika Jaykumar Patel

The entity received 700 shares from Bharatkumar Prahladbhai Prajapati on 10/12/2013 through off market transactions

360 AEKPJ9968A Pawan Jain The entity received 6500 shares from Mukesh N Desai (HUF) on 14/12/2013 in physical form

361 AAHHV3712M Vikas Kumar Jain (HUF)


DATE: AUGUST 14th, 2014 RAJEEV KUMAR AGARWAL

PLACE: MUMBAI WHOLE TIME MEMBER


wtm/rka/ 103 /isd/2014 securities and … 1 of 55 wtm/rka/ 103 /isd/2014 securities and exchange...

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