sebi:Order/PM/PA/2021-22/14398

SEBI · SEBI · 2021-05-07 · Prasanta Mahapatra, Adjudicating Officer

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Facts / Headnote

Violations established under regulation 7(2)(a) of PIT Regulations and clause 6 of Code of Conduct read with regulation 9(1) of PIT Regulations; monetary penalty imposed as deterrent

Provisions invoked

Regulations

Parties

Holding

The Noticee violated regulation 7(2)(a) of the PIT Regulations by failing to make timely disclosures of seven transactions each exceeding Rs 10 lakhs, and violated clause 6 of the Code of Conduct read with regulation 9(1) of the PIT Regulations by not obtaining pre-clearance before executing those transactions.

Full text

Adjudication order in respect of Gulab Chand Agrawal Page 2 of 27 in the matter of Sanwariya Consumer Ltd. the transactions undertaken by him exceeded Rs 10 lakhs. Further, it was alleged that the Noticee had violated clause 6 of the Minimum Standards for Code of Conduct to Regulate, Monitor and Report Trading by Insiders specified in Schedule B (hereinafter referred to as “Code of Conduct”) read with regulation 9(1) of the PIT Regulations by not obtaining pre-clearance from the Company before carrying out the aforesaid transactions which was above the threshold prescribed by the Company. In view of the above, adjudication proceedings were initiated against the Noticee.

Adjudication order in respect of Gulab Chand Agrawal Page 3 of 27 in the matter of Sanwariya Consumer Ltd. (i) It was observed that the Noticee was a promoter of the company from the shareholding pattern available on the website of BSE Limited and the information received from the Company vide letter dated January 04,

Adjudication order in respect of Gulab Chand Agrawal Page 4 of 27 in the matter of Sanwariya Consumer Ltd. S. N o. Date Client name Counterparty name Debit (D) / Credit (C) Quantity Value in Rs and lakhs* 7. 14/12/20 17 Gulab Chand Agrawal Gulab Chand Agrawal (ADOM) D 60,20,000 1,140.79

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Source: SecMarx — sebi:Order/PM/PA/2021-22/14398. 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.