Adjudication Order in Respect of M/s Ishita Finstock Limited in The Matter of M/s Gangotri Textiles Limited

BEFORE THE ADJUDICATING OFFICER
SECURITIES AND EXCHANGE BOARD OF INDIA

[ADJUDICATION ORDER NO. JJ/AK/AO-177/2014]
UNDER SECTION 15-I OF SECURITIES AND EXCHANGE BOARD OF INDIA
ACT, 1992 READ WITH RULE 5 OF SEBI (PROCEDURE FOR HOLDING
INQUIRY AND IMPOSING PENALTIES BY ADJUDICATING OFFICER) RULES,
1995
In respect of
M/s Ishita Finstock Limited
(PAN No. AAACI4661A)
In the matter of Gangotri Textiles Limited
FACTS OF THE CASE IN BRIEF

1. Securities and Exchange Board of India (hereinafter referred to as SEBI)
conducted investigation in respect of buying, selling and dealing in the
shares
of
Gangotri
Textiles
Limited
(hereafter
referred
to
as
Gangotri/Company/scrip), during the period from April 07, 2006 to

May 31, 2006 (hereinafter referred to as Investigation Period). The
shares of Gangotri are listed on the BSE Limited (hereinafter referred to as
BSE), National Stock Exchange (hereinafter referred to as NSE),
Calcutta Stock Exchange, Madras Stock Exchange and Coimbatore Stock
Exchange, but during the investigation period the scrip was traded only at
NSE and BSE.
Price-Volume Analysis:
2. Before Investigation Period (January 2006 to April 6, 2006): It was observed
that the scrip of Gangotri was not listed in NSE during January 2006 to April
6, 2006 and it was only traded in BSE. The highest price during this period
Adjudication Order in respect of M/s Ishita Finstock Limited in the matter of M/s Gangotri Textiles Limited
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December 31, 2014
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was ` 52.25 (intra day high on February 6, 2006) and lowest price during
this period was ` 40.55 (intra day low on March 28, 2006). The average
daily traded quantity during this period was for 77,036 shares.
3. During Investigation Period (April 7, 2006 to May 31, 2006): The scrip of
Gangotri was traded in both NSE & BSE. Details of price volume data at
BSE & NSE for the period April 07, 2006 to May 31, 2006 are as follows:-
Exchange
Open
High
Low
Close
Volume
BSE
53.25
April 07, 2006
56.00
April 07, 2006
70.95
May 05, 2006
71.05
May 05, 2006
43.00
April 19, 2006
41.25
April 19, 2006
44.35
May 31, 2006
45.40
May 31, 2006
8941975
Average
Daily
Volume
241675
6816750
184236
NSE
It was observed that during investigation period the price of the scrip
went up by 33.24% in BSE and 26.88% in NSE while the Sensex
recorded a decrease of 12.21% (from 11845.13 on April 07, 2006 to
10398.61 on May 31, 2006) and Nifty recorded a decrease of 12.89%
(from 3525.6 on April 07, 2006 to 3071.05 on May 31, 2006).
The price of the scrip mainly increased from April 20, 2006 to May 05,
2006, i.e. during these 12 trading days, the price of the scrip has
increased from ` 41.2 / 43 (NSE/BSE) on April 19, 2006 to
`71.05/70.95 (NSE/BSE) on May 05, 2006 a rise of 72.45%/65%
(NSE/BSE) along with volume spurt.
As on March 06, 2013 the price of the scrip at NSE and BSE was
`2.55 and `2.24 respectively.
4. After Investigation Period (June 2006 to December 2006): The scrip of

Gangotri was opened at `45.95 / 45.2 (NSE/BSE) on June 1, 2006 and
closed at `27.35 / 26.7 (NSE/BSE) on December 29, 2006. The highest
price during this period was `46.25 in (intra day high on June 2, 2006) in
NSE and `46.65 (intra day high on June 5, 2006) in BSE. The lowest price
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December 31, 2014
during this period was `24 (intra day low on December 13, 2006) in both
NSE and BSE. The average daily traded quantity during this period was for
34,080 / 43,717 (NSE/BSE) shares.
5. The role of the entities who had traded in the scrip of Gangotri was
scrutinized. It was observed during the investigation period that certain
entities collectively referred to as Vishvas Group namely, Sunita Gupta
(hereinafter referred to as "Sunita"), Purshottam Khandelwal (hereinafter
referred to as "Purshottam") Cosmo Corporate Services Limited
(hereinafter referred to as "Cosmo"), Ishita Finstock Limited (hereinafter
referred to as "Ishita"), Master Finlease Limited (hereinafter referred to as
"Master"), Avisha Credit capital Limited (hereinafter referred to as
"Avisha"), Vishvas Projects Limited (hereinafter referred to as "VPL"),
Praveen Poddar (hereinafter referred to as "Praveen"), Quantum Global
Securities and Leasing Company Limited (hereinafter referred to as
Quantum), Mefcom Securities Limited (hereinafter referred to as
Mefcom ), ISF Securities Ltd (hereinafter referred to as ISF), Vishvas
Securities
Limited
(hereinafter
referred
to
as
VSL),
Anupama
Communications Private Limited (hereinafter referred to as Anupama)

and SIC Stock Brokers and Services Private Limited (hereinafter referred to
as SIC) had allegedly executed synchronized trades, circular trades and
reversal trades among themselves and traded in significant variation to the
Last Traded Price (LTP) in the shares of Gangotri.
6. It was alleged that one of the entity M/s Ishita Finstock Limited (hereinafter
referred to as "Ishita"/"Noticee") had violated the provisions of section
12A(a), 12A(b), 12A(c) of Securities and Exchange Board of India Act, 1992
(hereinafter referred to as "SEBI Act") and Regulations 3(a), 3(b), 3(c),
3(d), 4(1), 4(2)(a), 4(2)(e) and 4(2)(g) of SEBI (Prohibition of Fraudulent and
Unfair Trade Practices relating to Securities Markets) Regulations, 2003
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December 31, 2014
(hereinafter referred to as PFUTP Regulations) and therefore, liable for

monetary penalty under section 15HA of SEBI Act.
APPOINTMENT OF ADJUDICATING OFFICER

7. Shri Piyoosh Gupta was appointed as Adjudicating Officer, vide order dated
August 08, 2013 under section 15-I of Securities and Exchange Board of
India Act, 1992 (hereinafter referred to as SEBI Act) and rule 3 of SEBI
(Procedure for Holding Inquiry and Imposing Penalties by Adjudicating
Officer) Rules, 1995 (hereinafter referred to as Rules) to enquire into and
adjudge under section 15HA of the SEBI Act for the alleged violations of
provisions of section 12A(a), 12A(b), 12A(c) of SEBI Act and Regulations
3(a), 3(b), 3(c), 3(d), 4(1), 4(2)(a), 4(2)(e) and 4(2)(g) of PFUTP
Regulations by Ishita. Consequent, to the transfer of Shri Piyoosh Gupta,
the undersigned was appointed as Adjudicating Officer vide order dated
November 08, 2013 to enquire and adjudge the matter
SHOW CAUSE NOTICE, HEARING AND REPLY
8. Show
Cause
Notice
reference
no.
EAD/JJ/AK/32187/2013
dated
December 12, 2013 (hereinafter referred to as SCN) was issued to the

Noticee under rule 4(1) of the Rules to show cause as to why an inquiry
should not be held against the Noticee and penalty be not imposed under
section 15HA of SEBI Act for the alleged violations specified in the said
SCN. The said SCN was sent at the address of the Noticee i.e. at "16,
Kalyan Building, Kuvada Road, opposite Siddhi Vinayak Travels, Rajkot, Gujarat"
which was delivered as per the acknowledgement card received.
9. In the interest of natural justice and in order to conduct an inquiry as per
rule 4(3) of the Rules, the Noticee was granted an opportunity of personal
hearing on February 28, 2014 at SEBI, Head Office, Mumbai, vide notice
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December 31, 2014
dated February 11, 2014. The said Notice of hearing dated February 11,
2014 was delivered at the aforesaid address as per the acknowledgement
card received. However, it is observed that the Noticee have neither
submitted any reply nor did it avail the opportunity of personal hearing.
Further, in the interest of natural justice and in order to conduct an inquiry
as per rule 4(3) of the Rules, the Noticee was granted a final opportunity of
personal hearing on May 29, 2014 at SEBI, Head Office, Mumbai, vide
notice dated May 08, 2014. The said Notice of hearing dated May 08, 2014
was returned undelivered from the aforesaid address.
10. Thereafter, it was observed from Ministry of Corporate Affairs (MCA)
website that the registered address of the Noticee has changed to "135/136
Star Chamber Harihar Chowk, Rajkot, Gujarat - 360001". Thus, in order to
conduct an inquiry as per rule 4(3) of the Rules and in the interest of natural
justice, the Noticee was granted a final opportunity of personal hearing on
August 26, 2014 at SEBI, Head Office, Mumbai, vide notice dated August
07, 2014. A copy of SCN dated December 12, 2013 was also enclosed with
the notice dated August 07, 2014. The said Notice of hearing dated August
07, 2014 was sent at the new registered office of the Noticee i.e. at 135/136
Star Chamber Harihar Chowk, Rajkot, Gujarat - 360001, which was also
returned undelivered.
11. In the interest of natural justice and in order to conduct an inquiry as per
rule 4(3) of the Rules, the Noticee was again granted a final opportunity of
personal hearing on December 19, 2014 at SEBI, Head Office, Mumbai,
vide notice dated November 26, 2014. A copy of SCN dated December 12,
2013 was also enclosed with the notice dated November 26, 2014. As per
rule 7(c) of the Rules the said notice of hearing dated November 26, 2014
along with SCN dated December 12, 2013 was affixed at the old address of
the Noticee as well as at the new registered address of the Noticee
available with SEBI i.e. at "16, Kalyan Building, Kuvada Road, opposite Siddhi
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December 31, 2014
Vinayak Travels, Rajkot, Gujarat" and at "135/136 Star Chamber Harihar Chowk,
Rajkot, Gujarat - 360001", on December 01, 2014 (affixture report is present
on record). Form the documents available on record, it is observed that the
Noticee neither appeared on December 19, 2014 nor submitted any reply to
the SCN.
12. In view of the aforesaid steps taken, I am convinced that opportunities have
been given to the Noticee to explain its case. As per rule 4(7) of the Rules,
if any person fails, neglects or refuses to appear as required by sub-rule (3)
before the Adjudicating Officer, he may proceed with the inquiry in the
absence of such person after recording the reasons therefor. Despite
having been given the opportunity of being heard, the Noticee had failed to
avail of the same. I am, therefore, compelled to proceed with the matter exparte based on the material available on record.
CONSIDERATION OF ISSUES AND FINDINGS

13. After perusal of the material available on record, the issues that arise for
consideration in the present case are as under:
A. Whether the Noticee have violated the provisions of section 12A(a),
12A(b), 12A(c) of SEBI Act and Regulations 3(a), 3(b), 3(c), 3(d), 4(1),
4(2)(a), 4(2)(e) and 4(2)(g) of PFUTP Regulations?
B. Whether the Noticee is liable for monetary penalty under section 15HA
of the SEBI Act ?
C. What quantum of monetary penalty should be imposed on the Noticee
taking into consideration the factors mentioned in Section 15J of SEBI
Act ?
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December 31, 2014
FINDINGS
14. On perusal of the material available on record and giving regard to the facts
and circumstances of the case, I record my findings hereunder:
ISSUE 1: Whether the Noticee have violated the provisions of section

12A(a), 12A(b), 12A(c) of SEBI Act and Regulations 3(a), 3(b),
3(c), 3(d), 4(1), 4(2)(a), 4(2)(e) and 4(2)(g) of PFUTP
Regulations?
15. Before moving forward, it will be appropriate to refer to the relevant
provisions of SEBI Act and PFUTP Regulations, which read as under:
SEBI Act
Prohibition of manipulative and deceptive devices, insider trading and
substantial acquisition of securities or control.
Section 12A. No person shall directly or indirectly
(a) use or employ, in connection with the issue, purchase or sale of any
securities listed or proposed to be listed on a recognized stock
exchange, any manipulative or deceptive device or contrivance in
contravention of the provisions of this Act or the rules or the
regulations made thereunder;
(b) employ any device, scheme or artifice to defraud in connection with
issue or dealing in securities which are listed or proposed to be listed
on a recognised stock exchange;
(c) engage in any act, practice, course of business which operates or
would operate as fraud or deceit upon any person, in connection with
the issue, dealing in securities which are listed or proposed to be listed
on a recognised stock exchange, in contravention of the provisions of
this Act or the rules or the regulations made thereunder;
PFUTP Regulations
Regulation 3: - 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;
Page 7 of 28
December 31, 2014
(b) use or employ, in connection with issue, purchase or sale of any

security listed or proposed to be listed in a recognized stock exchange,
any manipulative or deceptive device or contrivance in contravention of
the provisions of the Act or the rules or the regulations made
thereunder;
(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 thereunder.
Regulation 4:-Prohibition of manipulative, fraudulent and unfair trade practices
(1) Without prejudice to the provisions of regulation 3, no person shall indulge in
a fraudulent or an unfair trade practice in securities.
(2) Dealing in securities shall be deemed to be a fraudulent or an unfair trade
practice if it involves fraud and may include all or any of the following,
namely:(a) indulging in an act which creates false or misleading appearance of
trading in the securities market;
(b) ..
(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;
Connections between Vishvas Group entities:

16. From the documents available on records, following details were observed
with respect to the connection between Vishvas Group entities:
Sr.
No
1
Entity Name
Connection with other entities of
(Brokers Name)
Group
Master Finlease Ltd.
Same address as Avisha Credit
(Integrated
Master
Capital & Vishvas Projects Ltd.
securities Pvt. Ltd.)
(Mefcom Agro. Industries Ltd.)
Share holder in Vishvas
Traded Qty. (During

Investigation Period)
BSE: Buy-38000
Sell-18386
NSE: Buy-20500
Sell-111400
Page 8 of 28
December 31, 2014
Purshottam Khandelwal
(SIC Stock and Services

Pvt. Ltd.)
Anupama Communications
Pvt. Ltd.
Cosmo Corporate Services

limited.
(Integrated
Master
securities Ltd.)
ISF Securities limited
(BSE:-Sam
Global
Securities Ltd.
NSE:-ISF Securities Ltd.)
Quantum Global Securities

and leasing company Ltd.
Ishita Finstock Ltd.

(Vishvas securities Ltd.)
Praveen Poddar
(TCP Stock Brokers Ltd)
Sunita Gupta
(Parasram Holdings)
10
Mefcom Securities limited

(Mefcom Securities limited)
securities
Ltd.
(Unlisted
Company
19.24%
shareholding as on 30.09.2006)
Off market transfers with
Vishvas Securities limited.
Off Market Transfers from
Anupama Communications Pvt.
Ltd.
Entered into Synchronized
trades with entities at sr. no. 8,
9.
Transferred shares off market
to Purshottam Khandewal.
Directors
of
Anupama
Communications Pvt. Ltd. (
Rakesh Mishra, Ram dutt joshi)
are also directors in Cosmo
corporate services Ltd.
Entered
into
Off
Market
Transfers with Master Finlease
Ltd.
trades with entities at sr. no.
6,7,8,9.
Off Market Transfers from
trades with entities at sr. no.
6,7,8,9.
trades with entities at sr. no. 4,
5, 7, 10, and 12.
Entered into large no. of
Synchronized
trades
with
entities at sr. no. 1, 4, 5, 6, and
10.
Synchronized
trades
with
entities at sr. no. 2, 4, 5, 9 and
10.
Synchronized
trades
with
entities at sr. no. 2, 4, 5, 8 and
10.
Same address, same e-mail Id,
same director (Vijay Mehta) as
of Mefcom infrastructure project
Limited. And director (vijay
mehta) belongs to promoter
BSE: Buy 2927835

Sell 2882486
NSE:-Buy-NIL
Sell-NIL
Nil Trading at BSE

and NSE
BSE:Buy-445643
Sell-320630
NSE:Buy-401520
Sell-471184
BSE:Buy-389748
Sell-338795
NSE:Buy-453396
Sell-368574
BSE: Buy-NIL
Sell-NIL
NSE:Buy-302095
Sell-286835
BSE: Buy-NIL
Sell-NIL
NSE:Buy1953803
Sell-1569204
BSE:Buy-460990
Sell-460990
NSE:-Buy-NIL
Sell-NIL
BSE:Buy-342246
Sell-342246
NSE:-Buy-NIL
Sell-NIL
BSE:Buy-443942
Sell-348370
NSE:Buy-610646
Sell-667122
Page 9 of 28
December 31, 2014
11
Avisha Credit capital Ltd.
(Shriram Insight Share

Brokers Ltd.)
12
Vishvas Securities Ltd.

(Vishvas Securities Ltd.)
13
14
Vishvas Projects limited

(Formerly
Known
as
Mefcom Agro Industries
Ltd.
(Mefcom Securities Ltd)
SIC Stocks and Services
Pvt. Ltd.
group of Vishvas Projects Ltd.

(Formerly Known as Mefcom
agro Industries Ltd.)
Holder of 25% stake in Vishvas
Sec Ltd. (Unlisted Co.) 337380
Shares as on 30.09.2006.
Same address as Vishvas
projects Ltd. (mefcom Agro
Industries Ltd.) & Master
Finlease Ltd.
Directors of Avisha Credit
Capital Ltd.( Shubha Jhindal,
Vijay Jhindal, & Rakesh
Agarwal) are also directors in
Old Address of Mefcom Agro
Industries Limited same as
address of Vishvas Securities
Ltd. i.e. 912, Kailash Building,
Kasturba Gandhi Marg, New
Delhi".
Off market transfer to Master
Finlease Ltd., SIC Stock and
Services Pvt. Ltd. (8/7/2006,
50000 shares) and Avisha
Credit Capital Ltd.
Avisha Credit capital Ltd. and
Master Finlease Ltd. were the
shareholders
of
Vishvas
Securities
Ltd.
as
on
30.9.2006.(Unlisted Co.)
Atul Joshi one of the director of
Vishvas Securities Ltd. is also
director in Mefcom Agro
Industries Ltd.
Same address as Avisha Credit
Capital & Master Finlease.
BSE: Buy-50000
Sell-NIL
NSE:-Buy-NIL
Sell-NIL
BSE: Buy-NIL
Sell-NIL
NSE:Buy-134460
Sell-118661
BSE:Buy-100000
Sell-NIL
NSE:-Buy-NIL
Sell-NIL
Received 50,000 shares from NIL Trading at BSE &

Vishvas Securities Ltd. through NSE
off market.
Holding 10.7% shares in
Mefcom Agro Industries Ltd.
(listed
company)
as
on
20/9/2006.
Transfer of substantial amount
to avisha credit capital Limited
as per bank statements.
Page 10 of 28
December 31, 2014
From the above table I find the following:
The members of Vishvas Group namely, Purshottam, Ishita, Cosmo,

Praveen, Sunita, Master, Quantum, VPL, Avisha, Mefcom, ISF, VSL,
Anupama and SIC are connected to each other.
Noticee had traded through broker Vishvas Securities Limited in the

scrip of Gangotri at NSE.
17. Traded quantity of Vishvas Group at BSE and NSE (During Investigation
Period) is as under:Traded quantity (During Investigation Period)
Sr.
No.
Members of
Vishvas Group
BSE
Buy
NSE
Sell
Buy
Sell
Master
Purshottam
Anupama
Cosmo
445643
320630
401520
471184
ISF
389748
338795
453396
368574
Quantum
302095
286835
Ishita
1953803
1569204
Praveen
460990
460990
Sunita
342246
342246
10
Mefcom
443942
348370
610646
667122
11
Avisha
50000
12
VSL
134460
118661
13
VPL
100000
14
SIC
5198404
4711903
3876420
3592980
Total
38000
18386
20500
111400
2927835
2882486
From the above table I find the following:
Nine members of Vishvas Group namely, Master, Purshottam,

Cosmo, ISF, Praveen, Sunita, Mefcom, Avisha and VPL had traded
in the scrip of Gangotri at BSE.
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December 31, 2014
Seven members of Vishvas Group namely, Master, Cosmo, ISF,

Quantum, Ishita, Mefcom and VSL had traded in the scrip of
Gangotri at NSE.
Total buy and sell quantity of the members of Vishvas Group at BSE
is 51,98,404 shares and 47,11,903 shares respectively.
Total buy and sell quantity of the members of Vishvas Group at NSE
is 38,76,420 shares and 35,92,980 shares respectively.
Noticee had bought 19,53,803 shares of Gangotri and sold

15,69,204 shares of Gangotri at NSE.
TRADE CONCENTRATION
AT NSE:
18. From the trade & order log and documents available on record, I find that
total traded volume of the scrip of Gangotri during investigation period was
68,16,750 shares. During the investigation period, the trading details of top
10 trading brokers were analyzed and found that they had contributed
72.8% (49,62,603 shares) and 69.4% (47,33,357 shares) of the gross buy
and gross sell respectively. Further, it is observed that the Noticee's broker
VSL appeared in top 10 trading brokers by gross buy and gross sell.
Noticee's broker VSL was the highest contributor to both gross buy and
gross sell with 36.3% (24,77,101 shares) and 26.6% (18,15,976 shares) of
total market quantity respectively.
19. During investigation period, the trading details of top 10 trading clients were
analyzed and found that they had contributed 67.42% (45,95,836 shares)
and 59.85% (40,80,121 shares) of the gross buy and gross sell
respectively. Further, it is observed that out of top 10 trading clients, six
members of Vishvas Group namely, Ishita, Mefcom, ISF, Cosmo, Quantum
Page 12 of 28
December 31, 2014
and VSL were appeared in gross buy with total contribution of 56.56% (
38,55,920 shares) and six members of Vishvas Group namely, Ishita,
Mefcom, ISF, Cosmo, Quantum and VSL were appeared in gross sell with
total contribution of 51.07% (34,81,580 shares). It is observed that the
Noticee was the highest contributor to both gross buy and gross sell with
28.66% (19,53,803 shares) and 23.02% (15,69,204 shares) of total market
quantity respectively.
20. During investigation period, the trading details of top 10 clients with net buy
and net sell position were also analyzed and found that 3 members of
Vishvas Group namely, Ishita, ISF and VSL appeared at net buy position
and 3 members of Vishvas Group namely, Master, Cosmo, Mefcom
appeared at net sell position. At the end of the investigation period the net
buy position of the Noticee was 3,84,599 shares.
SYNCHRONIZED TRADES
AT NSE
21. Upon perusal of data, trade & order log and documents available on record,
I find that during investigation period there were 21,451 trades for a traded
quantity of 68,16,750 shares at NSE. Out of these, there were 495 trades
for 14,48,679 shares (21.25% of the total traded quantity) were
synchronized trades i.e. the difference between buy order time and sell
order time was less than 60 seconds and there was no difference between
buy order rate and sell order rate as well as there was no difference
between buy order quantity and sell order quantity..
22. It was observed that there were 30 trading days (out of total 37 trading days
during the investigation period) when synchronized trading was being done
at NSE, out of which Vishvas Group appeared in 24 trading days. Out of
these 24 days, on 23 days, the matching of synchronized trades of
Page 13 of 28
December 31, 2014
members of Vishvas Group with total market synchronized trades was more
than 50% and on 15 days, the contribution of volumes through
synchronized trades by the members of Vishvas Group was more than 15%
to the total market volume. For e.g. on May 24, 2006 the total day traded
volume was 1,35,845 shares out of which 56,862 shares (41.86% shares)
were synchronized by Vishvas Group.
23. It is observed that the seven members of Vishvas Group namely, Ishita,
Cosmo, VSL, Quantum, Mefcom, ISF and Master, indulged in 312
synchronized trades for 12,01,751 shares (82.95% of total synchronized
quantity). The details of synchronized trade amongst the member of
Vishvas Group are as under:
Particulars
Seller Name
Buyer Name
Ishita
Quantum
VSL
Mefcom
Cosmo
ISF
Master
Total
Mefcom
122738
73820
5000
00
56927
53390
7000
318875
Ishita
00
73439
00
136008
42150
44444
00
296041
Cosmo
110657
4975
00
81341
00
32925
00
229898
Quantum
68063
00
27653
41787
29953
1000
00
168456
ISF
67724
18996
1992
35350
37300
00
00
161362
VSL
00
4975
00
16340
00
00
00
21315
Master
3804
00
00
00
00
2000
00
5804
Total
372986
176205
34645
310826
166330
133759
7000
1201751
From the above table, it is observed that:
Out of total shares bought (19,53,803 shares) by the Noticee at NSE

during investigation period, 2,96,041 shares were synchronized with
the members of the Vishvas Group i.e. Quantum, Mefcom, Cosmo
and ISF.
Out of total shares sold (15,69,204 shares) by the Noticee at NSE

during investigation period, 3,72,986 shares were synchronized with
the member of the Vishvas Group i.e. Mefcom, Cosmo, Quantum,
ISF and Master.
Page 14 of 28
December 31, 2014
one of the instances of the synchronized trade and reversal trade by

the Noticee with other members of Vishvas Group is that on May 19,
2006, Noticee sold 10,000 shares of Gangotri @ ` 55.50 to Mefcom
at 10:35:21. The sell order was placed by Noticee at 10:35:21 @
`55.50 for 10,000 shares and the buy order was placed by Mefcom
at 10:35:20 @ `55.50 for 10,000 shares. The order time difference
was 1 seconds. Noticee again bought 10,000 Gangotri shares back
from Mefcom @ ` 55.85 at 11:03:29 i.e. the trade was reversed
within 30 minutes. In the reverse trade the sell order was placed by
Mefcom at 11:03:11 @ ` 55.85 for 10,000 shares and the buy order
was placed by Noticee at 11:03:29 @ ` 55.85 for 10,000 shares. The
order time difference was 18 seconds. During investigation period,
similar trading patterns of synchronized trading were also observed
between Noticee and other members of Vishvas Group.
24. Details of total number of synchronized buy and sell orders, trades and
trade quantity by the members of Vishvas Group during investigation period
are as under:
Client Name
Ishita
Mefcom
ISF
Quantum
Cosmo
VSL
Master
Total
Buy
Sell
Total
Count
of Buy
Orders
Count
of Buy
Trades
Total
Buy Qty
Count
of Sell
Orders
Count
of Sell
Trades
Total
Sell Qty
Total
Orders
Total
Trades
Total
Qty
51
62
32
33
36
4
3
221
70
102
42
51
40
4
3
312
296041
318875
161362
168456
229898
21315
5804
1201751
65
58
23
31
31
8
2
218
92
68
23
40
68
19
2
312
372986
310826
133759
176205
166330
34645
7000
1201751
116
120
55
64
67
12
5
439
162
170
65
91
108
23
5
624
669027
629701
295121
344661
396228
55960
12804
2403502
From the above table, it is observed that out of total 624

synchronized trades (buy & sell) by Vishvas Group for 24,03,502
Page 15 of 28
December 31, 2014
shares, Noticee was indulged in 162 synchronized trades for

6,69,027 shares.
CIRCULAR TRADES and REVERSAL TRADES

25. Upon analysis of trade log in BSE & NSE, it is observed that there were
substantial number of trades in which parties and counterparties to the
trade were same entities which belong to Vishvas Group. They were
creating an artificial volume in the market by trading among themselves i.e.
by circular trading and reversal trading. Nine members of Vishvas Group
were doing circular trading and reversal trading in BSE and seven members
were doing in NSE.
At NSE
26. It is observed that seven members of Vishvas Group namely, Ishita,
Cosmo, VSL, Quantum, Mefcom, ISF and Master involved in circular trades
in 29 trading days out of 37 trading days during investigation period and
created artificial volume of 23,56,185 shares (34.56% of total market
volume) by buying and selling among themselves. These transactions took
place in 2419 trades. Out of the same, circular trades aggregating to
12,01,751 shares from 312 trades were synchronized.
27. It is also observed that members of Vishvas Group made large contribution
in circular and reversal trades as compared to the total market volume in
the scrip. The circular trades and reversal trades by seven members of
Vishvas Group resulted in significant proportion of volume to the total
market volume in the scrip. Out of 29 trading days, On 10 days, the
percentage of circular trade volume of seven entites of Vishvas Group to
the total market volume was more than 40% and on 5 days it was more
than 60%.
Page 16 of 28
December 31, 2014
28. The details of circular trades among the seven members of Vishvas Group
are as under:-
Circular
Trades
Sellers
Buyers
ISF
Mefcom
VSL
Cosmo
Ishita
Master
Quantum
Grand
Total
ISF
Mefcom
VSL
Cosmo
625
68254
26258
36925
110961
550
24142
123702
6552
5000
497
00
68158
102992
100
00
157108
231230
5022
143512
00
7040
00
00
33458
100574
14980
27975
376862
515640
70999
332114
Ishita
Master
Quantum
Grand
Total
157329
2000
2000
188865
00
76917
2570
00
48823
183095
00
59751
92185
7841
101533
29825
00
00
107776
00
60
761645
9841
289084
293391
525137
63442
414096
738431
36865
284823
2356185
From the above table, it is observed that:
Out of total shares bought (19,53,803 shares) by the Noticee during

investigation period, 7,61,645 shares were involved in circular
trading with the member of the Vishvas Group i.e. ISF, Mefcom,
VSL, Cosmo, Noticee, Master and Quantum.
Out of total shares sold (15,69,204 shares) by the Noticee during

investigation period, 7,38,431 shares were involved in circular
trading with the other members of the Vishvas Group i.e. ISF,
Mefcom, VSL, Cosmo, Noticee, Master and Quantum.
29. During investigation period, circular trading among Vishvas Group were
observed from April 21, 2006 till May 31, 2006. One of the instances of
circular trading are as follows
Page 17 of 28
December 31, 2014
Circular pattern observed on April 25, 2006 among the group is as

under:
Mefcom
(broker Mefcom)
Ishita
(broker VSL)
Trade Quantity = 9,500

Cosmo
(broker Integrated)
ISF
(broker ISF)
SELF TRADES
AT NSE
30. It is also observed that Noticee had also indulged in self trades during
investigation period. The summary of self trades done by the Noticee are
as under -
Name of the entity

Ishita Finstock Limited
Number of
trades
333
Traded
Qty
92,185
It is observed that 333 trades of the Noticee for 92,185 shares were
self trades i.e. where buyers and sellers are same person.
PRICE MANIPULATION:
31. Last Traded Price (LTP) analysis:- It is observed that during investigation
period, the price of the scrip has decreased in patch I & III and increased in
patch II as discussed below:
Page 18 of 28
December 31, 2014
Patch I (April 7, 2006 to April 20, 2006):
Exchange
Opening price
(April 07, 2006)
Closing price
(April 20, 2006)
Trading
days
BSE
53.25
44.75
8 Days
NSE
56.00
44.40
8 Days
% Change in
price of the
scrip
15.96%
(Decrease)
20.70%
(Decrease)
Average
Daily Traded
Volume
70713
68005
Patch II (April 21, 2006 to May 5, 2006):
Exchange
Opening price
(April 21, 2006)
Closing price
(May 05, 2006)
Trading
days
% Change in
price of the
scrip
BSE
46.00
66.55
11 Days
NSE
46.00
66.90
11 Days
44.70%
(Increase)
45.40%
(Increase)
Average
Daily
Traded
Volume
338391
213738
Patch III (May 8, 2006 to May 31, 2006):
Exchange
Opening price
(May 08, 2006)
Closing price
(May
31,
2006)
Trading
days
% Change in
price of the
scrip
BSE
64.50
44.35
18 Days
NSE
63.55
45.40
18 Days
31.20%
(Decrease)
28.60%
(Decrease)
Average
Daily
Traded
Volume
258554
217866
It is observed that, all the member of Vishvas Group started trading

on or after April 21, 2006 i.e. they had traded only during patch II
(Period of price rise) and patch III (Period of price fall).
It is also observed that the day from when the members of Vishvas
Group start trading, the average trading volume of the scrip at BSE /
NSE had gone up significantly from 70,713 / 68,005 shares (during
Page 19 of 28
December 31, 2014
April 07, 2006 to April 20, 2006) to 3,38,391 / 2,13,738shares (during

April 21, 2006 to May 05, 2006) and 2,58,554 / 2,17,866 shares
(during May 08, 2006 to May 31, 2006).
32. LTP contribution of Visvas Group entities at NSE: Total cumulative

positive and negative LTP contribution was `995.25 and `1007.25
respectively during investigation period in NSE, whereas it is observed that
seven members of Vishvas Group namely, Cosmo, Master, Ishita, Mefcom,
VSL, Quantum and ISF had contributed `489.05 to positive LTP and
`307.90 to negative LTP. The details of contribution of seven members of
Vishvas Group to cumulative Positive and Negative LTP variation are as
under
Sr.
No.
1
2
3
4
5
6
7
Client Name
Ishita
Mefcom
VSL
Cosmo
Quantum
ISF
Master
Total
Sum of Positive
LTP `
365.95
56.55
32.1
14.5
10.55
8.8
0.6
489.05
Sum of Negative
LTP `
-229.2
-45
-18.5
-6.7
-3.7
-4.6
-0.2
-307.90
Total positive
Cumulative LTP
136.75
11.55
13.6
7.8
6.85
4.2
0.4
181.15
Noticee was the highest and significant contributor to both positive

LTP and negative LTP i.e. Noticee had contributed ` 365.95 to total
cumulative positive LTP and ` 229.2 to total cumulative negative
LTP.
33. I find that at NSE during the investigation period, the Noticee had bought
19,53,803 shares and sold 15,69,204 shares (total traded volume of the
Noticee was 32,23,007 shares). Out of total trading volume of the Noticee,
6,69,027 shares of the Noticee were synchronized and 15,00,076 shares
were circular with other members of Vishvas Group. I also find that Noticee
had indulged in 333 self trades for 92,185 shares.
Page 20 of 28
December 31, 2014
34. The role of the Noticee in executing the larger game plan of creating
manipulation in the scrip of Gangotri in concert with the other entities of the
Vishvas Group cannot be overlooked i.e. the Noticee had mostly traded
with Mefcom, VSL, Comso, Quantum, ISF, Master, and Itself, who are the
contributors towards LTP variation. Further, most of the synchronized
trades and circular trades of the Noticee's were with Mefcom, VSL, Comso,
Quantum, ISF, Master, and Itself. It is not possible for a single entity to
manipulate the market and the role of the entire Vishvas group has to be
considered in a holistic manner to arrive at any conclusion.
35. I find that the patterns of circular trading among the Vishvas Group are in
the manner [ABCDA]. Almost same numbers of shares were
rotated in a circular manner among the Vishvas Group on daily basis and
the pattern depicts that the trades were planned with a manipulative intent.
Thus, the said circular trading was not just a co-incidence and the same
indicates their concerted effort and manipulative intent to increase the price
of the scrip by creating false and artificial volume in the scrip. Due to the
concerted effort of Vishvas Group the price of the scrip of Gangotri in NSE
had increased from ` 41.25 on April 19, 2006, touched the high to ` 71.05
on May 05, 2006 and then decreased to `45.40 on May 31, 2006 within a
period of one and half month. This gave an impression to other investors in
the market that the scrip of Gangotri was being actively traded at the
prevailing price but actually this was not the case.
36. The pattern of synchronized order placement and circular trading clearly
points out that the transactions were carried out with the intention that the
orders of particular entities should match and there was a prior
arrangement with respect to these transactions. These transactions
resulted in creation of artificial volume. The pattern of trading indicates
several instances where the time difference between buy and sell orders
was less than 20 seconds. No unknown person can trade continuously with
Page 21 of 28
December 31, 2014
same set of persons by putting orders in such pattern contributing

significantly to total volume in the market. The Noticee along with the other
members of Vishvas Group have transacted amongst themselves in the
shares of Gangotri through circular and synchronized order placement in a
contrived pricing pattern and it led to creation of artificial volumes in the
scrip as the trades were reversed in a short time. The increase in the
trading volume of Gangotri shares can be attributed to the trades done by
the Noticee in collusion with the other members of Vishvas Group. Thus,
these trades were fraudulent and manipulative in nature as Noticee have
misused the trading mechanism and also created artificial trading volume.
37. The fact is that had the trades of the members of Vishvas Group been
executed in the normal course of business, the possibility of such perfect
matching would not have been possible. The buy and sell prices of one
entity were close to the buy/sell rates of the other entity in all the
settlements, such that the trades of these entities were always matched. A
trade can be executed on the screen and still be manipulative in nature.
Considering the number of such trades, it is clear that there has been a
gross mis-use of the screen based trading system. It is also to be stated
that intention is inherent in all cases of synchronized trading involving
large scale price manipulation and the same was also brought out in the
case of Nirmal Bang Securities (P) Ltd. vs SEBI by the Honble SAT whereby it
was observed that Intention is reflected from the action of the Appellant.
Choosing selective time slots does not appear to be an involuntary action.
38. The trading pattern of the Noticee creates doubts about the genuineness of
its trades. I am of the view that the trades carried out were fraudulent and
manipulative in nature. However, in the present case, the records show that
most of the trading carried out by the Noticee was with a fixed set of entities
i.e. members of Vishvas Group namely, ISF, Mefcom, VSL, Cosmo,
Quantum, Master and Noticee.
Page 22 of 28
December 31, 2014
39. I am of the view that the trades of the Noitcee and Vishvas Group were with
the intention not to transfer the beneficial ownerships of the shares of
Gangotri but with an intention to operate only as a device to inflate, depress
or cause fluctuations in the price of shares of Gangotri for wrongful gains.
Thus the Noticee through collusion with the other members of the Vishvas
Group has transacted in the shares of Gangotri in such a manner that it led
to creation of artificial volumes in the scrip and a false market leading to
price movement in the scrip which lacked presence of any sort of
fundamentals.
40. It is evident from the trading pattern of the Noticee and other members of
Vishvas Group that through circular, reversal and synchronized trades, they
have manipulated the price of the scrip during the period under scrutiny. It
is also observed that there was no transfer of ownership of shares.
41. Honble Securities Appellate Tribunal (hereinafter referred as SAT), in
Ketan Parekh Vs. Securities & Exchange Board of India (Appeal No. 2 of
2004), observed that, A synchronized transaction even on the trading screen
between genuine parties who intend to transfer beneficial interest in the trading
stock and who undertake the transaction only for that purpose and not for rigging
the market is not illegal and cannot violate the regulations. As already observed
synchronisation or a negotiated deal ipso facto is not illegal. A synchronised
transaction will, however, be illegal or violative of the Regulations if it is executed
with a view to manipulate the market or if it results in circular trading or is
dubious in nature and is executed with a view to avoid regulatory detection or does
not involve change of beneficial ownership or is executed to create false volumes
resulting in upsetting the market equilibrium. Any transaction executed with the
intention to defeat the market mechanism whether negotiated or not would be
illegal. Whether a transaction has been executed with the intention to manipulate
the market or defeat its mechanism will depend upon the intention of the parties
Page 23 of 28
December 31, 2014
which could be inferred from the attending circumstances because direct evidence
in such cases may not be available. The nature of the transaction executed, the
frequency with which such transactions are undertaken, the value of the
transactions, whether they involve circular trading and whether there is real
change of beneficial ownership, the conditions then prevailing in the market are
some of the factors which go to show the intention of the parties. This list of
factors, in the very nature of things, cannot be exhaustive. Any one factor may or
may not be decisive and it is from the cumulative effect of these that an inference
will have to be drawn.
42. In my view, the Noticee in collusion with other members of Vishvas Group,
through the said artificial trades interfered with the market mechanism by
manipulating the price and volume of the said scrip. The trades executed by
the Noticee and Vishvas Group were not real trades as there was no
intention to change the beneficial ownership. When the trades were
inherently non genuine, I do not feel that it is necessary to prove that
investors had, in fact got induced and bought and/ or sold on the basis of
these trades. Similar views were expressed by Honble SAT in its order
dated 14.7.2006 in Ketan Parekh Vs. SEBI wherein it had observed that
When a person takes part in or enters into transactions in securities with the
intention to artificially raise or depress the price he thereby automatically induces
the innocent investors in the market to buy /sell their stocks. The buyer or the seller
is invariably influenced by the price of the stocks and if that is being manipulated
the person doing so is necessarily influencing the decision of the buyer / seller
thereby inducing him to buy or sell depending upon how the market has been
manipulated. We are therefore of the view that inducement to any person to buy or
sell securities is the necessary consequence of manipulation and flows therefrom.
In other words, if the factum of manipulation is established it will necessarily
follow that the investors in the market had been induced to buy or sell and that no
further proof in this regard is required. The market, as already observed, is so wide
spread that it may not be humanly possible for the Board to track the persons who
Page 24 of 28
December 31, 2014
were actually induced to buy or sell securities as a result of manipulation and law
can never impose on the Board a burden which is impossible to be discharged.
This, in our view, clearly flows from the plain language of Regulation 4(a) of the
Regulations.
43. Keeping in mind the dicta of the SAT as reproduced above, I see no reason
to take a different view in the present case.
44. As per regulation 2 (1) (c) of PFUTP Regulations, "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.
45. I find that the Noticee has failed to file any reply to the said SCN and has
not refuted the charges. The Honble Securities Appellate Tribunal (SAT) in
the matter of Classic Credit Ltd. v/s SEBI [2007] 76 SCL 51 (SAT MUM.) inter-alia held the appellants did not file any reply to the second showcause notice. This being so, it has to be presumed that the charges alleged against
them in the show-cause notice were admitted by them. The order passed by
Honble SAT is relied upon in this case for guidance. Therefore, I presumed
that the Noticee has admitted the charges alleged in the said SCN.
46. Therefore, I hold that the charges leveled against the Noticee are proved
and that the allegation of violation of provisions of section 12A(a), 12A(b),

12A(c) of SEBI Act and regulations 3(a), 3(b), 3(c), 3(d), 4(1), 4(2)(a),
4(2)(e) & 4(2)(g) of PFUTP Regulations by the Noticee stand established.
Page 25 of 28
December 31, 2014
ISSUE 2: Whether the Noticee is liable for monetary penalty under

section 15HA of the SEBI Act ?
47. The aforesaid violations of SEBI Act and PFUTP Regulations by the
Noticee make it liable for penalty under Section 15HA of SEBI Act which
reads as follows:
Section 15HA. Penalty for fraudulent and unfair trade practices.

If any person indulges in fraudulent and unfair trade practices relating to
securities, he shall be liable to a penalty of twenty-five crore rupees or three times
the amount of profits made out of such practices, whichever is higher.
48. In the matter of SEBI vs. Shri Ram Mutual Fund [2006] 68 SCL 216 (SC),
the Honble Supreme Court of India has held that In our considered opinion,
penalty is attracted as soon as the contravention of the statutory obligation as
contemplated by the Act and the regulation is established and hence the intention of
the parties committing such violation becomes wholly irrelevant.
49. As already observed that, Noticee have violated the provisions of sections
12A(a), 12A(b), 12A(c) of SEBI Act and regulations 3(a), 3(b), 3(c), 3(d),
4(1), 4(2)(a), 4(2)(e) & 4(2)(g) of PFUTP Regulations. Therefore, I find that
the Noticee is liable for monetary penalty under Section 15HA of the SEBI
Act.
ISSUE 3: What quantum of monetary penalty should be imposed on

the Noticee taking into consideration the factors mentioned
in Section 15J of SEBI Act ?
50. While determining the quantum of penalty under Section 15HA of SEBI Act,
it is important to consider the factors stipulated in section 15J of SEBI Act,
which reads as under:Adjudication Order in respect of M/s Ishita Finstock Limited in the matter of M/s Gangotri Textiles Limited
Page 26 of 28
December 31, 2014
15J - Factors to be taken into account by the adjudicating officer

While adjudging quantum of penalty under section 15-I, the adjudicating officer
shall have due regard to the following factors, namely:(a) the amount of disproportionate gain or unfair advantage, wherever
quantifiable, made as a result of the default;
(b) the amount of loss caused to an investor or group of investors as a result of the
default;
(c) the repetitive nature of the default.
51. I note that on the basis of data available on record, it is difficult, in cases of
such nature, to quantify exactly the disproportionate gain or unfair
advantage enjoyed by the Noticee and the consequent losses suffered by
the investors. Further the amount of loss to an investor or group of investors
also cannot be quantified on the basis of available facts and data. Even
though the monetary loss to the investors cannot be computed, any
manipulation in the volume or price of the stocks caused by vested interest
always erodes investor confidence in the market so that investors find
themselves at the receiving end of market manipulators. Hence, anyone
could have been carried away by the unusual fluctuations in the
volume/price and been induced into investing in the said scrip. Besides, this
kind of activity seriously affects the normal price discovery mechanism of
the securities market. People who indulge in manipulative, fraudulent and
deceptive transactions, or abet the carrying out of such transactions which
are fraudulent and deceptive, should be suitably penalized for the said acts
of omissions and commissions. Considering the continuous effort of the
Noticee in this aspect where the trading was carried out over a period of
time, it can safely be surmised that the nature of default was also repetitive.
52. In the forgoing paragraphs, it is now established that the Noticee have
violated the provisions of sections 12A(a), 12A(b), 12A(c) of SEBI Act and
Page 27 of 28
December 31, 2014
regulations 3(a), 3(b), 3(c), 3(d), 4(1), 4(2)(a), 4(2)(e) & 4(2)(g) of PFUTP
Regulations. In view of the above and considering the facts and
circumstances of the case and factors under Section 15J of the SEBI Act
and the violation committed by the Noticee, I find that imposing a penalty of
` 80,00,000/- (Rupees Eighty Lakhs only) on the Noticee would be
commensurate with the violations committed by it.
ORDER
53. In exercise of the powers conferred under Section 15-I of the SEBI Act and
in terms of the provisions of Section 15HA of the SEBI Act & Rule 5(1) of
the Rules, I hereby impose a penalty of ` 80,00,000/- (Rupees Eighty Lakhs
only) on M/s Ishita Finstock Limited for violation of provisions of sections
12A(a), 12A(b), 12A(c) of SEBI Act and regulations 3(a), 3(b), 3(c), 3(d),
4(1), 4(2)(a), 4(2)(e) & 4(2)(g) of PFUTP Regulations.
54. The Noticee shall pay the said amount of penalty by way of demand draft
drawn in favour of SEBI Penalties Remittable to Government of India
payable at Mumbai within 45 days of receipt of this Order. The said demand
draft shall be forwarded to the Division Chief, Enforcement Department
(EFD DRA-3), Securities and Exchange Board of India, Plot No. C4-A, G
Block, Bandra Kurla Complex, Bandra (E), Mumbai 400051.
55. In terms of rule 6 of the Rules, copies of this order are sent to the Noticee
and also to SEBI.
Date: December 31, 2014

Place: Mumbai
Jayanta Jash
Adjudicating Officer
Page 28 of 28
December 31, 2014

Adjudication Order in Respect of M/s Ishita Finstock Limited in The Matter of M/s Gangotri Textiles Limited

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Adjudication Order in Respect of M/s Ishita Finstock Limited in The Matter of M/s Gangotri Textiles Limited

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BEFORE THE ADJUDICATING OFFICER

SECURITIES AND EXCHANGE BOARD OF INDIA

FACTS OF THE CASE IN BRIEF

Gangotri/Company/scrip), during the period from April 07, 2006 to

4. After Investigation Period (June 2006 to December 2006): The scrip of

Communications Private Limited (hereinafter referred to as Anupama)

(hereinafter referred to as PFUTP Regulations) and therefore, liable for

APPOINTMENT OF ADJUDICATING OFFICER

December 12, 2013 (hereinafter referred to as SCN) was issued to the

CONSIDERATION OF ISSUES AND FINDINGS

ISSUE 1: Whether the Noticee have violated the provisions of section

(b) use or employ, in connection with issue, purchase or sale of any

Connections between Vishvas Group entities:

Traded Qty. (During

(SIC Stock and Services

Cosmo Corporate Services

ISF Securities limited

NSE:-ISF Securities Ltd.)

Quantum Global Securities

Ishita Finstock Ltd.

Mefcom Securities limited

BSE: Buy 2927835

Nil Trading at BSE

Avisha Credit capital Ltd.

(Shriram Insight Share

Vishvas Securities Ltd.

Vishvas Projects limited

group of Vishvas Projects Ltd.

Received 50,000 shares from NIL Trading at BSE &

From the above table I find the following:

The members of Vishvas Group namely, Purshottam, Ishita, Cosmo,

Noticee had traded through broker Vishvas Securities Limited in the

From the above table I find the following:

Nine members of Vishvas Group namely, Master, Purshottam,

Seven members of Vishvas Group namely, Master, Cosmo, ISF,

Noticee had bought 19,53,803 shares of Gangotri and sold

From the above table, it is observed that:

Out of total shares bought (19,53,803 shares) by the Noticee at NSE

Out of total shares sold (15,69,204 shares) by the Noticee at NSE

one of the instances of the synchronized trade and reversal trade by

From the above table, it is observed that out of total 624

shares, Noticee was indulged in 162 synchronized trades for

CIRCULAR TRADES and REVERSAL TRADES

From the above table, it is observed that:

Out of total shares bought (19,53,803 shares) by the Noticee during

Out of total shares sold (15,69,204 shares) by the Noticee during

Circular pattern observed on April 25, 2006 among the group is as

Trade Quantity = 9,500

Trade Quantity = 9,905

Trade Quantity = 10,577

Trade Quantity = 9,875

Name of the entity

Patch I (April 7, 2006 to April 20, 2006):

Patch II (April 21, 2006 to May 5, 2006):

Patch III (May 8, 2006 to May 31, 2006):

It is observed that, all the member of Vishvas Group started trading

April 07, 2006 to April 20, 2006) to 3,38,391 / 2,13,738shares (during

32. LTP contribution of Visvas Group entities at NSE: Total cumulative

Noticee was the highest and significant contributor to both positive

same set of persons by putting orders in such pattern contributing

and that the allegation of violation of provisions of section 12A(a), 12A(b),

ISSUE 2: Whether the Noticee is liable for monetary penalty under