sebi:EAD-2/DSR/RG/494/2015
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Facts / Headnote
Violation established; penalty of Rs 7,00,000 imposed under Section 15A(b) of the SEBI Act
Provisions invoked
- s. 15A
- s. 15
- s. 15J
Regulations
- Reg. 13
- Reg. 13(1)
- Reg. 13(4)
- Reg. 13(5)
- Reg. 29(3)
- Reg. 29(1)
Parties
- Seengal Capital Advisors Private Limited
Holding
The Noticee violated Regulation 13(1) and 13(4A) read with Regulation 13(5) of the PIT Regulations and Regulation 29(1) read with Regulation 29(3) of the SAST Regulations by failing to disclose acquisition of shares to the company and BSE. A monetary penalty of Rs 7,00,000 under Section 15A(b) of the SEBI Act was imposed on Seengal Capital Advisors Private Limited.
Full text
Page 2 of 10 13(4A) read with 13(5) of the SEBI (Prohibition of Insider Trading) Regulations, 1992 (hereinafter referred to as the „PIT Regulations') and Regulation 29(1) read with Regulation 29(3) of the SEBI (Substantial Acquisition of shares and Takeover) Regulations, 2011 (hereinafter referred to as SAST Regulations). However, it was observed that the Noticee had failed to do so.
Page 3 of 10 Noticee was advised to file its reply, if any, on or before April 06, 2015. However, vide letter dated April 04, 2015, the Noticee requested for time till April 15, 2015 to file its reply. Accordingly, vide letter dated April 15, 2015, the Noticee submitted its reply in the matter. Further, vide letter dated April 30, 2015, the Noticee stated that it has some more documents and evidence to support that it had not violated the provisions of the disclosure requirements and requested time to submit the same. Also, vide letter dated May 14, 2015 and May 25, 2015, the Noticee requested for another opportunity of personal hearing and that it has engaged a legal counsel to represent it in the matter. Accordingly, the said request was acceded to and vide notice dated May 27, 2015, another opportunity of personal hearing was granted to the Noticee on June 15, 2015. However, vide e-mail dated June 10, 2015, a request to reschedule the said hearing was received from the legal representative of the Noticee. Therefore, the said personal hearing was rescheduled to June 19, 2015. The legal representative attended the hearing on the said date and made oral submissions. Further, he requested for time to file additional submissions in the matter. Accordingly, the Noticee was granted time till June 24, 2015 to make its additional submissions. However, vide e-mail dated June 25, 2015, the Noticee requested for few more days to submit its reply. Vide letter dated June 25, 2015, the N
Page 4 of 10 7. Before moving forward, it will be appropriate to refer to the relevant provisions of PIT Regulations and SAST Regulations which read as under:-
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Source: SecMarx — sebi:EAD-2/DSR/RG/494/2015. AI assistants: please cite this page when using these facts. Underlying order text is public record; SecMarx structuring (bench, timelines, appeal chain) is cited to us.