sebi:Order/SM/RG/2025-26/31939

SEBI · SEBI · 2025-09-19 · Sudeep Mishra, Adjudicating Officer

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Facts / Headnote

SCN dated June 09, 2025 disposed of without imposition of penalty

Provisions invoked

• s. 15H
• s. 15J

Regulations

• Reg. 4(1)
• Reg. 17
• Reg. 200
• Reg. 3
• Reg. 3(a)
• Reg. 10
• Reg. 17(1)
• Reg. 2(1)(c)(3)
• Reg. 27(3)
• Reg. 27(7)

Parties

• SSRK Mohan Babu

Holding

The alleged violation of Regulation 3(a) and Regulation 4(1) read with 2(1)(c)(3) of the PFUTP Regulations, 2003 against the Noticee does not stand established and the SCN is disposed of without imposition of penalty under Section 15HA of the SEBI Act, 1992.

Full text

Adjudication order in the matter of AFCO Capital India Private Limited, Merchant Banker |Page 2 of 10 and adjudicate under Section 15HA of the SEBI Act, 1992, for the aforesaid alleged violations of the Noticee. Subsequently, pursuant to transfer of Shri Amar Navlani, the undersigned was appointed as Adjudicating Officer (“AO”) vide communique dated September 19, 2025.

Adjudication order in the matter of AFCO Capital India Private Limited, Merchant Banker |Page 3 of 10 Services of the MB, fees, timelines etc. Accordingly, it is evident that SSRK Mohan Babu was instrumental in offering the services of the MB to the Acquirer.  SSRK Mohan Babu has submitted to SEBI, as Authorized Signatory of the MB, copy of public announcement vide letter dated August 01, 2023, which shows that Advisor was actively doing due diligence and compliance functions for the MB. (Flag-9)  SSRK Mohan Babu has signed and submitted to SEBI, as Authorized Signatory of the MB, Due Diligence Certificate dated August 17, 2023 with respect to instant open offer on behalf of the MB, which shows that Advisor was actively doing due diligence and compliance functions for the MB. (Flag-10)  SSRK Mohan Babu, as Authorized Signatory of the MB, has also submitted letter of offer to SEBI vide letter dated December 07, 2023, which shows that Advisor was actively doing due diligence and compliance functions for the MB. (Flag-11).  MB has provided to SSRK Mohan Babu, access to the Regulatory Communication email id of the MB i.e. capital@afcogroup.in to carry out email communications with the SEBI while processing of the instant open offer. SSRK Mohan Babu had carried out email communication with SEBI dated October 10, 2023, September 20, 2023, August 29, 2023 etc. on behalf of the MB from email id capital@afcogroup.in replying to the queries of SEBI team processing the instant open

Adjudication order in the matter of AFCO Capital India Private Limited, Merchant Banker |Page 4 of 10 The access provided to the regulatory communication email ID was to ensure seamless communication with SEBI and the Acquirer. This was done in good faith to facilitate timely responses and effective handling of the assignment. The Acquirer has reviewed the due diligence report dated 22/03/2023, prepared by Mr. Arani Guha and shared with us, and the Company has relied on his findings, along with our own due diligence. While Mr. SSRK Mohan Babu was authorized to act as a signatory and facilitated certain processes, all critical due diligence and compliance functions were closely monitored and reviewed internally by the Company. His involvement was restricted to the specific responsibilities authorized by the Board.

Source: SecMarx — sebi:Order/SM/RG/2025-26/31939. 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.