sebi:Order/MC/VS/2020-21/9946-9959

SEBI · SEBI · Maninder Cheema, 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 of PFUTP violations (including against Noticee 14) not established; violations of PIT Regulations established against Noticees 1, 2, 3, 8 and 12; violations of SAST Regulations established against Noticees 1-4, 7, 9, 10, 12 and 13; penalties imposed under Section 15A(b) of the SEBI Act.

Provisions invoked

• s. 15A
• s. 15
• s. 12A
• s. 15H
• s. 15J

Regulations

• Reg. 7
• Reg. 3
• Reg. 13
• Reg. 4(1)
• Reg. 17
• Reg. 199
• Reg. 13(1)
• Reg. 29(1)
• Reg. 29
• Reg. 18
• Reg. 3(a)
• Reg. 9
• Reg. 201
• Reg. 2(1)(q)(2)

Holding

The alleged PFUTP violations by Noticees 1-11 and Noticee 14 were not established, but Noticees 1, 2, 3, 8 and 12 were found to have violated PIT Regulations 13(1) and 13(3) read with 13(5), and Noticees 1-4, 7, 9, 10, 12 and 13 were found to have violated SAST Regulations 29(1) and 29(2) read with 29(3). Penalties of Rs. 2,00,000 each were imposed on Noticees 1, 2, 3, 8 and 12 for PIT violations, and Rs. 5,00,000 jointly and severally on Noticees 1-4, 7 and 9-13 for SAST violations.

Full text

Adjudication Order in respect of Bharat Patel and Others in the matter of Super Sales India Ltd. Page 2 of 45 8. Hridaynath Consultancy Pvt. Ltd. (PAN AACCH52585R) having address at 103, Thackers Apartment, Juhu Lane, Andheri West, Mumbai – 400058, B 906, 9h Floor, New Sarvottam CHS, Irla Bridge, Andheri West, Mumbai – 400058, and 3/4, Shankar Smruti Chawl, Shivaji Nagar, Tembhi Pada Road, Mumbai – 400078

Adjudication Order in respect of Bharat Patel and Others in the matter of Super Sales India Ltd. Page 3 of 45 Pasha Finance Pvt. Ltd. (“Noticee 10”), Moneybee Realty Pvt. Ltd. (“Noticee 11”), Prashant Jayantilal Patel (“Noticee 12”), Superior Financial Services Consultancy Pvt. Ltd. (“Noticee 13”), Finquest Securities Pvt. Ltd. (“Noticee No. 14”) (hereinafter together referred to as “the Noticees”) as follows – (a) Under Sections 15 HA of the SEBI Act, 1992 (“SEBI Act”) for alleged violation of Section 12A (a), (b) and (c) of the SEBI Act, and Regulations 3 (a), (b), (c) & (d), 4 (1) and 4(2) (a) & (g) of the SEBI (Prohibition of Fraudulent and Unfair Trade Practices) Regulations, 2003 (hereinafter referred to as the “PFUTP Regulations”) by Noticees 1 to 11 (b) Under Section 15A (b) of the SEBI Act for alleged violation of Regulations 13 (1) and 13 (3) read with 13 (5) of the SEBI (Prohibition of Insider Trading) Regulations, 1992 (“PIT Regulations 1992”) by Noticee Nos.1, 2, 3, 8 and 12. (c) Under Section 15A(b) of the SEBI Act for alleged violation of Regulations 29 (1) and 29 (2) read with 29 (3) of the SEBI (Substantial Acquisition of Shares and Takeovers) Regulations, 1992 (“SAST Regulations 2011”) by Noticee Nos.1, 2, 3, 4, 7, 8, 9, 10, 12 and 13. (d) Under Section 15HA and 15HB of the SEBI Act for alleged violation of Section 12A (a), (b) and (c) of the SEBI Act, and Regulations 3 (a), (b), (c) & (d), 4 (1) and 4(2) (a) & (g) of the PFUTP Regulations and of Clause A (2

Adjudication Order in respect of Bharat Patel and Others in the matter of Super Sales India Ltd. Page 4 of 45 “Adjudication Rules”), vide order dated July 17, 2019, to inquire into, and adjudge under Section 15HA and Section 15HB of the SEBI Act the aforesaid alleged violations.

Source: SecMarx — sebi:Order/MC/VS/2020-21/9946-9959. 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.