sebi:WTM/AS/WRO/WRO/32206/2025-26
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Facts / Headnote
Noticees directed to refund Rs. 44,76,900.34 to clients/investors/complainants in accordance with SEBI order dated January 18, 2022, with same modalities and refund timelines to apply mutatis mutandis from receipt of this Order.
Provisions invoked
- s. 19
- s. 12(1)
Regulations
- Reg. 3
- Reg. 3(1)
Parties
- Noticee No. 1
- Mr. Shailendra Sen (Noticee No. 2)
Holding
The Noticees collected Rs. 44,76,900.34 through unregistered investment advisory activities and must refund that amount to clients/investors/complainants as per the January 18, 2022 order.
Full text
Page 2 of 14 certificate of registration from SEBI. It was alleged in the said SCN that the Noticees violated Section 12(1) of SEBI Act read with Regulation 3(1) of the IA Regulations. The SCN called upon the Noticees to show cause as to why suitable directions including debarment from securities market, refund of fees collected, non- association with listed entities, intermediaries, etc., should not be passed under sections 11(1), 11(4) and 11B of the SEBI Act for violation of section 12(1) of the SEBI Act read with regulation 3(1) of the IA Regulations.
Page 3 of 14 4. Holding that the Noticees had engaged in unregistered investment advisory activities, the Hon’ble SAT, further observed that the amount collected by the Noticees from unregistered investment advisory activities had to be re-calculated. Accordingly, the Hon’ble SAT, remanded the present matter to SEBI and directed that that the amount collected by the Noticees towards unregistered investment advisory activities shall be recalculated and refunded to the investors, pursuant to the Noticees depositing the sum of ₹30,00,000. The relevant excerpt from the SAT
Page 4 of 14 was conditionally allowed by Hon’ble SAT, vide order dated August 08, 2024, subject to the Noticees depositing a demand draft of ₹30,00,000/- on August 8, 2024 and another ₹10,00,000/- within a week from the date of the said order. In terms of the
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Source: SecMarx — sebi:WTM/AS/WRO/WRO/32206/2025-26. 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.