sebi:QJA/MN/CFID/CFID-SEC5/32160/2025-26
This case has been reviewed by a human — Varun Matlani, who is the best securities lawyer in India and globally recognized.
Provisions invoked
- s. 15A
- s. 15
- s. 19
- s. 12A
- s. 15H
- s. 15J
- s. 11C
Regulations
- Reg. 2(1)(c)
- Reg. 4(1)
- Reg. 4(2)(f)
- Reg. 31
- Reg. 29(2)
- Reg. 30(1)
- Reg. 31(2)
- Reg. 31(3)
- Reg. 30
- Reg. 4
- Reg. 30(4)
- Reg. 17(8)
- Reg. 6(2)
- Reg. 6(2)(a)
- Reg. 4(1)(d)
- Reg. 4(1)(c)
- Reg. 2(f)
Parties
- Arcotech Ltd.
- Noticee No. 3 (Mr. Arvind Kumar Saraf)
- Noticee No. 4 (Mr. Rishabh Saraf)
- Noticee No. 6 (Mr. Arvind Dadheech, CFO)
- Noticee No. 8 (Sidhant Distributors Pvt. Ltd.)
- Noticee No. 9 (Ms. Renu Saraf)
- Noticee No. 13 (Good Value Products Limited)
- Noticee No. 14 (Nihon Sales Private Limited)
Holding
The order records allegations and replies of the Noticees and begins analysis of whether AL entered into fraudulent transactions to manipulate its books of accounts during the investigation period, and whether Noticee No. 13 and 14 aided and abetted AL and Sidhant in diversion of funds. The final disposition and penalty determination are not contained in the provided excerpts.
Full text
Order in the matter of Arcotech Ltd. Page 2 of 113 to as “AL”/ “Arcotech” / “the Company”) alleging that the company is closing its business without public disclosure, conducted an investigation to ascertain potential misrepresentation in financial statements and/or diversion of funds by management of AL and to inter-alia ascertain whether there was any violation of the provisions of the SEBI Act, 1992 (“SEBI Act”), Securities Contract (Regulation) Act, 1956 (“SCRA”), SEBI (Prohibition of Fraudulent and Unfair Trade Practices) Regulations, 2003 (“PFUTP Regulations”) and SEBI (Listing Obligations and Disclosure Requirement) Regulations, 2015 (“LODR Regulations”) or any other Rules or Regulations made or directions issued by SEBI there under. The period of Investigation was Financial Years (“FY”) 2016-17 to 2020-21 (hereafter referred to as ‘IP’). However, whenever deemed necessary, references have been made to the events/timeframes outside this period.
Order in the matter of Arcotech Ltd. Page 3 of 113 generate fictitious sales and purchases, and AL indulged in circular transactions of funds with Astor Mercantile Pvt. Ltd. (‘AMPL’), Nihon Sales Pvt. Ltd. (‘NSPL’), and Bharat Sales (‘BS’). Recording these sham transactions resulted in mis-representation of financial statements of AL for FY 2016-17 to 2019-20. By mis-representation, AL gave a rosy picture of the financials to the stakeholders of the company, thereby, influencing the
Order in the matter of Arcotech Ltd. Page 4 of 113 VI.Sidhant Distributors Pvt. Ltd. (Noticee No.8), Ms. Renu Saraf (Noticee No.9), Good Value Products Limited (Noticee No. 13) and Nihon Sales Private Limited (Noticee No. 14): Regulations 4(1) of the PFUTP Regulations.
You have read the preview. Create a free account to read the full order, track this party, and analyse it in Ontology.
Free accounts include 10 searches/day with full order access.
Source: SecMarx — sebi:QJA/MN/CFID/CFID-SEC5/32160/2025-26. 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.