sebi:WTM/KV/SRO/SRO/29753/2023-24
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Facts / Headnote
Application allowed in part; advisory fee for refund purposes modified to INR 52,99,303
Provisions invoked
- s. 19
Parties
- Vusa Ravi
- Global Advisors
Holding
The amount of advisory fee for the purpose of making refund to the investors of Global Advisors shall be treated as INR 52,99,303, modifying the earlier figure of INR 73,87,303 by excluding self-transfers of INR 6,68,900, loans from friends/relatives of INR 7,78,100, and rental payment of INR 6,39,000.
Full text
Order in the matter of Vusa Ravi Proprietor Global Advisors Page 2 of 7 within three weeks from today giving details of the credit entries of the three bank accounts and indicate with precision as to which amount relates to advisory services and which amount does not relate to advisory services. The authority will consider each and every entry and thereafter crystalize the amount to be refunded within two months thereafter.”
Order in the matter of Vusa Ravi Proprietor Global Advisors Page 3 of 7 17,50,206) held to be the amount collected by Global Advisors by way of subscription towards its unauthorized investment advisory service.
Order in the matter of Vusa Ravi Proprietor Global Advisors Page 4 of 7 from the statements of bank accounts that, there is a slight mismatch in dates of one entry (i.e. for the debit of INR 90,100 from the ICICI Bank account on July 27, 2020, the credit in the Axis Bank is reflected in the statement on July 25, 2020). Nonetheless, I am of the view that benefit of doubt needs to be extended to the Applicant as the transaction numbers mentioned in both (Debit/Credit) entries are the same and moreover, no other infirmity in the other self transfer transactions has been noticed. It is also noted that the narration of the entry of cash deposit of INR 1,25,000 on December 03, 2019 reads as: SAKASH DEPSAK 15781378260 SELF. The said narration, in the absence of any evidence to the contrary, supports the claim of the Applicant that the amount of INR 1,25,000 was deposited by the Applicant in the bank account of Global Advisory, a proprietorship firm of the Applicant. Under the circumstances, I observe that the Applicant has furnished evidences to demonstrate that the amount of INR 6,68,900 is required to be excluded from the amount of INR 73,87,303/- calculated as amount of subscription towards unauthorized investment advisory services on account to double counting (INR 5,43,900) and self- deposit (INR 1,25,000).
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Source: SecMarx — sebi:WTM/KV/SRO/SRO/29753/2023-24. 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.