sebi:WTM/AN/MIRSD/MIRSD-SEC-6/31402/2025-26
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Facts / Headnote
Regulatory censure issued against the Noticee
Provisions invoked
- s. 19
- s. 12
- s. 12(3)
Regulations
- Reg. 4
- Reg. 2(c)
- Reg. 3
- Reg. 2(1)(c)
- Reg. 4(1)
- Reg. 24
- Reg. 8
- Reg. 2(b)
- Reg. 4(2)(k)
- Reg. 4(2)(o)
- Reg. 25
- Reg. 27
- Reg. 26
- Reg. 24(2)
- Reg. 27(1)
Parties
- Sameer Pande - Research Analyst (Proprietor of Niftypro Trading Research)
Holding
The Noticee violated RA Regulations, SEBI Advertisement Circular and PFUTP Regulations by using prohibited terms, misleading testimonials, citing accuracy, and implying/assuring returns, and a regulatory censure was issued against him.
Full text
Final Order in the matter of Sameer Pande – Research Analyst (Proprietor of Niftypro Trading Research) Page 2 of 23 Regulations”), SEBI (Prohibition of Fraudulent and Unfair Trade Practices relating to Securities Market) Regulations, 2003 (hereinafter referred to as “PFUTP Regulations”) and SEBI Circular.
Final Order in the matter of Sameer Pande – Research Analyst (Proprietor of Niftypro Trading Research) Page 3 of 23 4. Pursuant to the transfer of DA, another DA was appointed on July 22, 2024. In response to the show cause notice issued by the DA, the Noticee filed its reply vide email/ letter dated July 09, 2024. Further, an opportunity of personal hearing was granted by the DA on August 13, 2024, which was availed of by the Noticee.
Final Order in the matter of Sameer Pande – Research Analyst (Proprietor of Niftypro Trading Research) Page 4 of 23 anywhere. As per clause (c)(x) of the said circular, RAs are not allowed to state accuracy of their levels till it is achieved. The accuracy levels stated by the noticee over a website is only after the achievement of target returns. Moreover, the Noticee has not shown past performance or result of any specific security or his research rather he has just stated the accuracy of his research and all the requisite disclaimers as required under the said circular are mentioned upon his website. The testimonials mentioned upon the website were not fake as it were received from the Noticee’s clients. Further, post the inspection, the Noticee immediately removed such contents from its website. 8.3. The contention of SEBI in paragraphs 18 and 19 of the Enquiry report (profit calculation provided to the clients by sales representatives) are denied in its entirety as the sheet upon which the SEBI has relied upon is an internal lead generation sheet, not a client facing document, which is maintained by the Noticee’s employees and hence the said allegation lacks merit as it is unsupported by any credible evidence and also it does not constitute any actual promise or assurance of guaranteed returns. 8.4. The Noticee has reiterated that he has not assured/ guaranteed returns rather he has demonstrated that the clients can earn from their trading activities in the securities ma
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Source: SecMarx — sebi:WTM/AN/MIRSD/MIRSD-SEC-6/31402/2025-26. 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.