sebi:ORDER/JS/RJ/2025-26/31611-31613
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Facts / Headnote
Penalties imposed jointly on three Noticees under section 15EA of SEBI Act for breach of concentration limit
Provisions invoked
- s. 15
- s. 15J
- s. 15E
Regulations
- Reg. 3
- Reg. 15(1)(c)
- Reg. 201
- Reg. 20(1)
- Reg. 20(5)
- Reg. 8
Parties
- Landmark Opportunity Fund
- Landmark Capital Advisors Pvt. Ltd.
- Mr. Ashish Joshi
Holding
Noticee No.1, its Manager Noticee No.2 and KMP Noticee No.3 violated Regulation 15(1)(c) and related Code of Conduct obligations by investing up to 60% of investable funds in Sai Krishna Warehousing Pvt. Ltd. Penalties of Rs.5,00,000, Rs.3,00,000 and Rs.2,00,000 respectively were imposed under section 15EA.
Full text
Adjudication Order in the matter of Landmark Opportunity Fund Page 2 of 22 3. Noticee No. 1 had submitted the Private Placement Memorandum (hereinafter referred to as “PPM”) Audit Report for its scheme, Landmark Return Multiplier Fund for the financial year 2022-23 to SEBI. In the said PPM Audit Report, Kaytes Business and Tax Consultants (hereinafter referred to as “Auditors”) had, inter alia, made adverse observations on the breach of concentration limits by the Fund.
Adjudication Order in the matter of Landmark Opportunity Fund Page 3 of 22 SHOW CAUSE NOTICE, REPLY AND HEARING 7. Show Cause Notice (hereinafter referred to as “SCN”) Ref. No. SEBI/EAD2/NH/RJ/2024/17692 dated May 24, 2024, was issued to the Noticees under rule 4 of the Rules to show cause as to why an inquiry should not be held and why penalty, if any, should not be imposed against the Noticees under section 15EA of the SEBI Act for the aforesaid alleged violations.
Adjudication Order in the matter of Landmark Opportunity Fund Page 4 of 22 Based on the response provided by the Investment Manager, we understand that despite various efforts made by the them to liquidate the investment, the same is yet pending for disposal due to various constraints. The Investment Manager is expecting to divest Sai Krishna Warehousing Private Limited tentatively at the earliest and tentatively within next 45-60 working days. …”
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