sebi:Order/AK/BS/2023-24/28689-28691
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Facts / Headnote
Show cause notice Ref. No. EAD-6/AK/VV/20140/1/2023 dated May 19, 2023 disposed of without imposition of monetary penalty
Provisions invoked
- s. 15A
- s. 15
- s. 12A
- s. 15J
- s. 15E
Regulations
- Reg. 7
- Reg. 4
- Reg. 3
- Reg. 7(1)
- Reg. 2(1)(c)
- Reg. 16
- Reg. 9
- Reg. 10
- Reg. 17
- Reg. 25
- Reg. 8
- Reg. 15
- Reg. 5
- Reg. 3(a)
- Reg. 13(a)
- Reg. 23
- Reg. 3(b)
- Reg. 19
- Reg. 7(1)(a)
- Reg. 15(1)
Parties
- Money Capital Height Research Investment Advisers Pvt. Ltd.
- Ajay Kumar
- Sunil Singh Bhadauriya
Holding
The Adjudicating Officer disposed of the show cause notice dated May 19, 2023 against the three Noticees without imposing monetary penalty under Sections 15A(a), 15EB and 15HA of the SEBI Act.
Full text
Adjudication Order in respect of three entities in the matter of Money Capital Height Research Investment Advisers Pvt. Ltd. Page 2 of 45 APPOINTMENT OF ADJUDICATING OFFICER 2 Upon being satisfied that there are sufficient grounds to inquire into and adjudicate the alleged violations of provisions stated above by the Noticees, SEBI, in exercise of powers u/s 19 r/w sub-section (1) of section 15-I of the SEBI Act and rule 3 of the SEBI (Procedure for Holding Inquiry and Imposing Penalties) Rules, 1995 (hereinafter referred to as the “Adjudication Rules”) appointed me as Adjudicating Officer (AO), vide order dated January 13, 2023 to inquire into and adjudge u/s Section 15A(a), Section 15EB and 15HA of SEBI Act, the alleged violations by the Noticees.
Adjudication Order in respect of three entities in the matter of Money Capital Height Research Investment Advisers Pvt. Ltd. Page 3 of 45 5 In view of the above, it was alleged in the SCN that: 5.1 For the observations stated at para 4.1 above, Noticees have violated the provisions of Regulation 15(13) r/w Regulation 7 of IA Regulations and clause 1, 2 and 8 of Code of Conduct for Investment Advisers as specified under Third Schedule r/w Regulation 15(9) of IA Regulations and Paragraph 2(iv) of SEBI circular dated September 23, 2020. 5.2 For the observations stated at para 4.2 above, Noticees have violated the provisions of Regulation 15(12) of IA Regulations. 5.3 For the observations stated at para 4.3 above, Noticees have violated the provisions of Regulation 15A of IA Regulations r/w provisions prescribed for fees in paragraph 2(iii) of SEBI circular dated September 23, 2020 and Clauses 6 and 8 of Code of Conduct for Investment Advisers specified in Third Schedule of IA Regulations. 5.4 For the observations stated at para 4.4 above, Noticees have violated the provisions specified in paragraph 2(ii) of SEBI Circular dated September 23, 2020 and Clause 8 of Code of Conduct specified in Third Schedule of IA Regulations. 5.5 For the observations stated at para 4.5 above, Noticees have violated the provisions of Regulation 19(2), 25(1) and 25(2) of IA Regulations and Paragraph 2(vi) of SEBI circular dated September 23, 2020. 5.6 For the observations stated at para 4.6 above, No
Adjudication Order in respect of three entities in the matter of Money Capital Height Research Investment Advisers Pvt. Ltd. Page 4 of 45 III r/w Regulation 15(9) of IA Regulations, provisions of paragraph 1(i) of SEBI circular no. SEBI/HO/IMD/DF1/ CIR/P/2019/169, dated December 27, 2019.
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