sebi:SO/AS/PSD/2025-26/8316
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Facts / Headnote
Settled
Provisions invoked
- s. 19
- s. 15J
Regulations
- Reg. 25
- Reg. 28
- Reg. 31
- Reg. 23
- Reg. 20(1)
- Reg. 15(1)(d)
Parties
- Applicant no. 1
- Applicant no. 2
- Applicant no. 3
- Applicant no. 4
- Applicant no. 5
- Applicant no. 6
Holding
Any proceedings that may be initiated for the violations mentioned at paragraph 1 are settled in respect of the Applicants upon payment of Rs. 29,25,000 by Applicant no. 2 on behalf of all Applicants, and SEBI shall not initiate any enforcement action for the said violations.
Full text
2 proceedings that may be initiated against them for the following alleged violations of the provisions of law: a. Applicant no. 1: Regulation 15(1)(d) of the SEBI (Alternative Investment Funds) Regulations, 2012 (hereinafter referred to as “AIF Regulations”). b. Applicant no. 2: Regulation 20(1), 20(5) and Clause 2(a), 2(c) of Code of Conduct read with Regulation 15(1)(d) of the AIF Regulations. c. Applicants nos. 3 to 6: Regulation 20(1) and Clause 2(a), 2(c) of Code of Conduct read with Regulation 15(1)(d) of the AIF Regulations.
3 (d) It was observed from the June 2023 Quarterly Activity Report (hereinafter referred to as “QAR”) that Iroha Emerging India Fund – I had invested Rs. 276.44 crore in listed equity of Kotak Mahindra Bank Limited (hereinafter referred to as “KMBL”) against an investible fund of Rs. 2478.05 crore. This implies that the scheme had an investment of 11.15% of its investible funds in KMBL as on June 2023. It was observed from the details of the scheme’s investment in KMBL as on September 20, 2023 that the 10% concentration limit was breached on November 01, 2022. It was further observed from its QAR for June 2024 that it had reported investment of Rs. 377.37 crore in KMBL (viz. 15.5% of investible funds of Rs. 2420.02 crore) as on June 30, 2024, thereby once again breaching the concentration limit. (e) It was observed from the Compliance Test Report (hereinafter referred to as “CTR”) for FY 2022-23 that Applicant no. 2 has inaccurately submitted to the trustee that it is in compliance with Regulation 15(1)(d) of the AIF Regulations, during that year.
4 6. Vide email dated February 7, 2025, the applicants filed their Revised Settlement Terms proposing to pay ₹29,25,000/- (Rupees Twenty-nine lakh twenty-five thousand only) as the settlement amount payable by Applicant no. 2 on behalf of all the Applicants. The High Powered Advisory Committee (hereinafter referred to as “HPAC”) in its meeting held on March 13, 2025, considered the settlement terms proposed by the Applicant and recommended that the case may be settled upon payment of ₹29,25,000/- (Rupees Twenty-nine lakh twenty-five thousand only) as settlement amount payable by Applicant no. 2 on behalf of all the Applicants.
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Source: SecMarx — sebi:SO/AS/PSD/2025-26/8316. 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.