sebi:WTM/SM/IVD/ID13/24880/2022-23
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Facts / Headnote
Noticees found liable for insider trading; directions for disgorgement of loss avoided and penalty under Section 15G of the SEBI Act
Provisions invoked
- s. 11B
- s. 15
- s. 19
- s. 12A
- s. 12
- s. 15G
- s. 15J
- s. 11(5)
Regulations
- Reg. 3
- Reg. 4(1)
- Reg. 4
- Reg. 2
- Reg. 2(1)(l)
- Reg. 3(1)
- Reg. 2(1)(d)(i)
- Reg. 30
- Reg. 2(1)
- Reg. 2(1)(g)
- Reg. 2(1)(n)
Parties
- Mr. Rashesh Purohit (Noticee no. 1)
- Keynote Enterprises Private Limited (Noticee no. 2)
- Noticee no. 3
- Ms. Chitra Deshmukh (Noticee no. 4)
Holding
The Noticees were held to have indulged in insider trading in violation of Section 12A(d) and (e) of the SEBI Act, 1992 read with Regulation 4(1) of the PIT Regulations by trading in TVVL shares during the UPSI period of September 01, 2017 to September 21, 2017. Noticee no. 1 was additionally held liable for communicating UPSI to his brother Mr. Ram Purohit in violation of Regulation 3(1).
Full text
Order in the matter of TV Vision Limited Page 2 of 65 of India (Prohibition of Insider Trading) Regulations, 2015 (hereinafter referred to as the “PIT Regulations”).
Order in the matter of TV Vision Limited Page 3 of 65 iii. After the aforesaid announcement was made by the Company, the price of its scrip decreased by around 4.99%, and it closed at INR 119.85. Further, the scrip witnessed a fall of 65.62% in its price in the next 22 trading days, as it closed at INR 41.20 on October 31, 2017. iv. Vide SEBI’s Circular no. SEBI/HO/MIRSD/MIRSD4/CIR/P/2017/71 dated June 30, 2017, issued with respect to Monitoring and Review of Ratings by Credit Rating Agencies, it has been inter alia prescribed that a Credit Rating Agency (hereinafter referred to as the “CRA”) shall seek a ‘No Default Statement (NDS)’ from the listed company at the end of each month, which shall be provided to the CRA by the listed company on the first working day of the next month. Such a NDS has to be issued with respect to the servicing of the debt obligation by such listed company. v. The NDS for the month of July, 2017 in terms of the aforesaid Circular dated June 30, 2017, was submitted to CARE by the Company under the signatures of Mr. Markand Adhikari, in the capacity of the Managing Director of the Company. vi. Further, the Company was required to submit the NDS for the month of August, 2017, on September 01, 2017, to CARE (the concerned Credit Rating Agency). However, as the Company did not furnish the requisite NDS pertaining to the month of August, 2017, CARE started issuing emails from September 01, 2017 to September 19, 2017 to the Company seeking the aforesaid N
Order in the matter of TV Vision Limited Page 4 of 65 Bank Facilities - Term Loan for INR 24.39 Crore’, and revised the ratings from ‘CARE BBB- (SO)’ to ‘CARE D’. ix. The aforesaid revision of rating was also intimated by CARE to the Company vide its email dated September 21, 2017, but the Company finally disclosed it to the Stock Exchanges only on September 27, 2017.
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Source: SecMarx — sebi:WTM/SM/IVD/ID13/24880/2022-23. 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.