sebi:WTM/AB/NRO/NRO/27876/2023-24
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Facts / Headnote
Noticee nos. 1, 2 and 3 held liable for unregistered investment advisory activities and directed to refund jointly and severally with market restraint; proceedings against Noticee no. 4 disposed of without any directions.
Provisions invoked
- s. 19
- s. 12(1)
Regulations
- Reg. 3(1)
- Reg. 2(1)(m)
Parties
- Indo Global Financial Services and Consultancy Pvt. Ltd.
- Noticee no. 2
- Noticee no. 3
- Noticee no. 4
Holding
Noticee no. 1, with Noticee nos. 2 and 3 jointly and severally, violated Section 12(1) of SEBI Act, 1992 read with Regulation 3(1) of the IA Regulations, 2013 by acting as an investment adviser without registration and must refund fees collected, while proceedings against Noticee no. 4 were disposed without directions.
Full text
Final Order in the matter of Indo Global Financial Services and Consultancy Pvt. Ltd. Page 2 of 13 2. The SCN alongwith the Annexures was served upon Noticee no. 2, 3 and 4 through Speed Post. The service of SCN to Noticee no. 1 either through Speed Post or through Affixture was not successful. Hence, paper publication was done in the Gurgaon edition of Gurgaon Mail (English) and Dainik Jagran (Hindi). I note that, none of the Noticees have filed their reply to the SCN. An opportunity of personal hearing was provided to all the Noticees on October 20, 2022. The Hearing Notice for the same was served upon Noticee no. 3 through Courier and upon Noticee no. 2 through email. The Hearing Notice could not be served upon Noticee no. 1. The Hearing Notice had provided three options for appearing at the hearing, namely, 1) Through CISCO WebEx, 2) Through visit at any SEBI RO/LO. 3) Through visit at SEBI HO. At the scheduled date of hearing on October 20, 2022, Noticee no. 2 had appeared for physical hearing at SEBI Head Office. I note that none other Noticee had appeared for the hearing. Noticee no. 2 claimed to represent himself and Noticee no. 1, 3 and
Final Order in the matter of Indo Global Financial Services and Consultancy Pvt. Ltd. Page 3 of 13 downloaded from ‘web.archive.org’ and available on record, I note that the following was disclosed on the website: “Home Welcome to Indo Global Financial Services & Consultancy Pvt. Ltd. We are the best equity research company in the market
Final Order in the matter of Indo Global Financial Services and Consultancy Pvt. Ltd. Page 4 of 13 4. From the copy of the Agreement dated September 7, 2017, which was executed by Noticee no. 1 (through Noticee no. 2) with Mr. Hemant Kohli (Complainant), the following can be noted:
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Source: SecMarx — sebi:WTM/AB/NRO/NRO/27876/2023-24. 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.