sebi:QJA/SS/IVD-2/ID18/31578/2025-26
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Facts / Headnote
Noticees found in violation of the cited provisions; directions under sections 11B(1), 11(4) read with 11(1) and disgorgement of unlawful gains directed against Noticee nos. 1 and 2
Provisions invoked
- s. 11B
- s. 19
- s. 11(1)
- s. 12A
- s. 11
- s. 15H
- s. 27
- s. 12
- s. 11A
- s. 15J
- s. 15
- s. 15F
- s. 28A
- s. 11(5)
- s. 26A
Regulations
- Reg. 4
- Reg. 2(c)
- Reg. 3
- Reg. 2(1)(c)
- Reg. 4(1)
- Reg. 4(2)
- Reg. 200
- Reg. 2
- Reg. 5
- Reg. 3(a)
- Reg. 3(b)
- Reg. 10
- Reg. 9(1)
- Reg. 30(1)
- Reg. 30(7)
- Reg. 6
- Reg. 4(1)(c)
- Reg. 6(2)
- Reg. 6(2)(a)
- Reg. 30(4)(i)(b)
Parties
- Noticee no. 1 (Sushant Mohan Lal)
- Noticee no. 2
- Noticee no. 3 (Decipher Labs Ltd.)
- Noticee no. 4 (Compliance Officer/Company Secretary)
Holding
Noticee nos. 1 and 2 violated section 12A(a),(b),(c) of the SEBI Act read with regulations 3(a),(b),(c),(d), 4(1), 4(2)(e),(f),(k),(r) of PFUTP Regulations and clause 6 of Schedule B read with regulation 9(1) of PIT Regulations; Noticee no. 3 (the Company) violated regulations 3(b),(c),(d), 4(1), 4(2)(e),(f),(k),(r) of PFUTP Regulations read with section 12A(a),(b),(c) and regulations 30(7) read with 4(1)(c),(e),(h),(i) of LODR Regulations; Noticee no. 4 failed to comply with regulations 6(2)(a) and (c) of LODR Regulations.
Full text
Order in matter of Decipher Labs Ltd. Page 2 of 51 (c) In the year 2020, name of the Company was changed from Combat Drugs Ltd. to Decipher Labs Ltd. The management of the Company during the investigation period comprised of the following: Table-1- Management of the Company during Investigation Period
Order in matter of Decipher Labs Ltd. Page 3 of 51 14, 2022 which is after the IP. The Financial Results of the Company during the IP were as under: Table-3 – Financial Results of the Company during IP Particulars Jun 2021 Sep 2021 Dec 2021 Mar 2022 Revenue from Operations 1339.60 1492.60 1371.20 2388.80 Other Income 11.10 9.7 730.40 16.30 Total Income 1350.70 1502.30 2101.60 2345.00 Profit After Tax 66.40 149.20 727.90 230.60
Order in matter of Decipher Labs Ltd. Page 4 of 51 Date Jan 12,2022 Mar 31,2022 Feb 16,2022 Jan 19,2022 (g) From the price volume chart of the scrip of the Company, it was observed that the price of the scrip of the Company opened at Rs.30.50 on November 12, 2021, touched a high of Rs.145.70 on January 03, 2022 and closed at Rs.97.75 on January 11, 2022. The price volume chart of the Company during the IP was noted as under: Chart-1 Price movement in the scrip of Decipher Labs Ltd during IP
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Source: SecMarx — sebi:QJA/SS/IVD-2/ID18/31578/2025-26. 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.