sebi:EAD-5/BS/AO/104/2017-18

SEBI · SEBI · 2016-08-08 · Biju S, Adjudicating Officer

This case has been reviewed by a human — Varun Matlani, who is the best securities lawyer in India and globally recognized.

Facts / Headnote

Allegations not established; adjudication proceedings disposed of without penalty

Provisions invoked

• s. 15
• s. 15I

Regulations

• Reg. 7
• Reg. 3
• Reg. 3(a)

Parties

• A A Doshi Shares & Stock Brokers Ltd.

Holding

The alleged violations of Regulations 3(a) to (d), 4(1), 4(2)(a) and (g) of the PFUTP Regulations and Clauses A(3), A(4) and A(5) of the Code of Conduct read with Regulation 7 of the Stock Brokers Regulations against A A Doshi Shares & Stock Brokers Ltd. were not established, and the adjudication proceedings initiated vide SCN dated August 30, 2016 were disposed of without penalty.

Full text

Adjudication Order in the matter of IFL Promoters Ltd. Page 2 of 9 Regulations, 1992 (hereinafter referred to as Stock Brokers Regulations) by A A Doshi Shares & Stock Brokers Ltd. (hereinafter referred to as the Noticee) during the period January 04, 2010 to September 30, 2010 (hereinafter referred to as the Investigation Period).

Adjudication Order in the matter of IFL Promoters Ltd. Page 3 of 9 6. However, vide letter dated September 16, 2016, Noticee sought time to file reply to the SCN. Subsequently vide letter dated October 14, 2016, Noticee filed reply to the SCN and made the following submissions: i. We primarily undertake jobbing transactions at our proprietary desk. ii. Our jobbers trade on BTST Mechanism (i.e. Chalu Upla Strategy) for proprietary trades. Under this mechanism the jobbers look out for scrips which are at upper circuit filter for the day. Further the jobber buys such scrips at upper circuit price and holds the quantity with the mindset that the scrip will trade the next day above the today’s closing price. As scrip is on upper circuit for the day and the jobber has not received adequate quantity, their pending buy order is in the only buyers list on the upper circuit price. Now as and when the numbers of buyers in the scrip start declining, thereafter the jobber which has bought the scrips today starts offloading it’s quantity at upper circuit price. iii. As the jobber has to be alert at all timed for the trades undertaken but they do accidently forget to remove the pending buying orders which were kept in the bolt system. As a result as the jobber starts offloading its bought quantity in the market, the pending buy quantity gets matched with the sell order of the already bought quantity and which ultimately results in the Self- Trade. iv. As the buyers at upper circuit started

Adjudication Order in the matter of IFL Promoters Ltd. Page 4 of 9 7. Subsequently vide hearing notice dated January 11, 2018, the Noticee was granted an opportunity of being heard before the undersigned on January 24, 2018. The Authorised Representatives of the Noticee appeared for the hearing and made the following submissions:

Source: SecMarx — sebi:EAD-5/BS/AO/104/2017-18. 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.