WTM/PS/47/IVD/JUNE/2016

SECURITIES AND EXCHANGE BOARD OF INDIA

ORDER
Under Sections 11(1), 11(4) and 11B of the Securities and Exchange Board of India Act,
1992
In the matter of Exelon Infrastructure Limited
In respect of S. No.

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31

Name

Permanent Account Number

Exelon Infrastructure Limited

Cementex (India) Pvt. Limited
Mr. Srinivasa Rao Marupudi
Mr. Gadde B. Tirupati Rao
Mr. Ravi Chakravati
Mr. M.Vishnuvardhan Rao
Mr. P R K Venkatamurthi
Mr. Srinivas Yadav Sher
Mr. Shaik Ameer Basha
Mr. Sree Lakshmi Marupudi
Mr. Hiten Vallabhji Haria
A. K. Investments
Mr. Narendra O. Dogra
Mr. Kanta Anantrai Desai
Mr. Anjali Tukaram Sogam
Mr. Jitendra L. Gandhi
Mr. Amrit L. Gandhi (HUF)
Mr. Gangadhara Rao Ilaparti
Mr. Hussain M. Shaikh
Mr. Jigna Manish Shah
Mr. Sneha Pankaj Desai
Mr. Nishita D. Merchant
Dhana Energy P. Limited
Mr. Srikrishna Vadlamudi
Mr. Kantilal Lakshmichand
Mr. Gudimetla H Sunder
Mr. Shivangi J. Singh
Ms. Dimple Pankaj Desai
Mr. PVS Gangadhara Rao
Mr. Sunil Kumar H. Pal
Mr. Venkata Subbarao Yarra

AAACM2862M
AAACC9265A
ACQPM0876L, BCDPM3124P
AHUPG9920A
AJXPR4789F
ABYPM0993M
AFQPP6066G
AUAPS8547G
AEZPB3408A
ALYPM2964Q
AAAPH6890H
AANFA6009Q
AJMPD8729N
AAEPD6006F
CGNPS1443N
AACPG6473H
AAJHA4701R
AANPI9650F
BSSPS2832P
ANQPS6789P
AIBPD1454A
AMHPM8133B
AACCV7693M
ADNPV5504C
ADSPK7577K
BMLPS9664N
AOSPS5911E
AUQPD3909F
AKYPP5600M
BKSPP6938B
AAPPY4270P

Page 1 of 22

32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
1.

Mr. Amrit L. Gandhi

Mr. Bhavnaben N. Mistry
Mr. Yentrapati Ravi
Ms. Parul Anupam Khanna
Mr. Hiten P. Shah
Ms. Parvathaneni Mounisha
Ms. Swapna Sri Tummala
Mr. Satya S. Jonnavithula
Mr. Piyush Naresh Kothari
Mr. Nrupini Jayesh Mehta
Mr. Mahendra Bhikaji Chile
Mr. Elubandi Satyanarayana
Mr. Rama Krishna Makkena
Ms. Anitha Yarlagadda
Ms. Salma Sharafat Khan
Ms. Seema Gandhi
Mr. Ronak Ashwin Choksi
Mr. Veerabhadra D.
Mr. Divyesh Harish Surana
Mr. Jayesh H. Mehta
Mr. Shivcharan S. Kashyap

AACPG5265H
ALIPM5347B
ABWPY6767F
BCUPK8420R
AHAPS0889A
BAOPP1399G
ALDPT7720Q
ACRPJ9665R
AEOPK1882L
BDTPM2261E
AHNPC8127G
DGCPS7022F
BCKPK1101P
ACAPY5774B
BVSPK9348F
AAEPG0960B
ADDPC2938D
ABVPD6656R
DALPS0578H
AIFPM2216D
ATOPK6636K

Securities and Exchange Board of India (hereinafter referred to as SEBI), conducted

an investigation into the scrip of Exelon Infrastructure Limited (hereinafter referred
to as Exelon or the company) for the period of December 08, 2010 to January 20,
2012 (hereinafter referred to as the investigation period), to ascertain the possible
violation of the provisions of the SEBI Act, 1992 (hereinafter referred to as SEBI
Act), the SEBI (Prohibition of Fraudulent and Unfair Trade Practices Relating to
Securities Market) Regulations, 2003, the SEBI (Prohibition of Insider Trading)
Regulations, 1992 (hereinafter referred to as PIT Regulations) and other disclosure
requirements.

2.

Exelon was incorporated as a Private Limited Company on February 21, 1979, which
became a deemed Public Limited Company on July 18, 1989. The Company was
converted into a Public Limited Company on December 05, 1992. The Company is
engaged in development of power and infrastructure projects. The scrip of Exelon is
listed on Bombay Stock Exchange (hereinafter referred to as BSE).

Page 2 of 22

3.

The investigation alleged that the Company, its promoter (Cementex India Pvt.
Limited), its 6 directors and 44 other entities (hereinafter collectively referred to as
group/ connected entities) were prima facie connected to each other. The details of
their connections as found in the investigation are as under:
TABLE - A
S.No.
1
2

4
5
6
7
8

10

Name

Exelon
Company
Cementex (India) Pvt. Ltd. - Cementex is promoter entity of Exelon,
(Cementex)
- Cementex and Exelon have common directors (i.e. persons at S.no. 4,
5 and 8 in the table),
- Cementex and Dhana Energy Pvt. Ltd. (entity at S.no. 10) have a
common director namely Srikrishna Vadlamui (person at S.no. 9),
- The Company had off market transfers with persons at S.no. 8 and 31,
- Director of Cementex, Hiten Pravinchandra Shah (person at S.no. 32)
is the introducer to the persons at S.no. 3, 8, 28, 30 and 31 (in the table)
with Networth Stock Broking Limited.
Srinvasa Rao Marupudi
- Director and CEO of Exelon.
- He had off market transfers with persons at S.no. 11, 13, 27 and 30.
- He has common address and mobile no. with entity at S.no. 11.
- He also has common address, mobile no. and bank a/c no. with entity
at S.no. 9.
Gadde B. Tirupati Rao
Director in Exelon
Ravi Chakravati
Director in Exelon
M.Vishnuvardhan Rao
Director in Exelon
P. R. K. Venkatamurthi
Director in Exelon
Srinivas Yadav Sher
- Director in Exelon and Cementex (entity at S.no. 2),
- He had off market transfers with entities at S.no. 2, 16, 17, 30, 31,
- He has been mentioned as reference in the KYC for entity at S.no. 30
at Networth Stock Broking Limited.
Srikrishna Vadlamudi
- Director of Cementex (S.no. 2) and Dhana (S.no. 10),
- He had off-market transactions with entity at S.no. 14,
- He has common e-mail ID i.e. vsrik2000@yahoo.com with entities at
S.no. 2, 13 and 19,
- He had banking transactions with entities at S.no. 19.
Dhana Energy Pvt. Ltd.
- Entities at S.no. 9 and 11 are the directors of Dhana,
(Dhana)
- It had off market transfers with entity at S.no. 15 and 27.

11

Marupudi Sree Lakshmi

12
13

Rama Krishna Makkena

Anitha Yarlagadda

14

Satya Suryanarayana
Jonnavithula
Swapna Sri Tummala
Mahendra Bhikaji Chile
Gangadhara Rao Ilaparti
PVS Gangadhara Rao

15
16
17
18

Connection with Exelon / other entities of Group

- Director of Dhana (entity at S.no. 10),

- He has common address and mobile no. with entity at S.no. 3,
- He had off market transfers with entities at S.no. 3 and 19.
He had off-market transfers with entities at S.no. 27 and 32.
- She had off market transfers with entity at S.no. 3.
- She shares the e-mail ID i.e. vsrik2000@yahoo.com with entities at
S.no. 2, 9 and 19.
He had off-market transfers with entity at S.no. 9.
She had off-market transfers with entity at S.no. 10.
He had off-market transfers with entity at S.no. 8.
He had off-market transfers with entities at S.no. 8, 18, 20 and 21.
He had off-market transfers with entities at S.no. 19 and 49.

Page 3 of 22

19

36

- He had off-market transfers with entities at S.no. 11 and 18.

- He shares same e-mail ID i.e. vsrik2000@yahoo.com with entities at
S.no. 2, 9 and 13.
- He had banking transactions with entity at S.no. 9.
Elubandi Satyanarayana
He had off-market connections with entity at S.no. 17.
Yentrapati Ravi
He had off-market connections with entity at S.no. 17.
Dimple Pankaj Desai
- She had off-market connections with entity at S.no. 8 prior to the
investigation period,
- She had off-market connections with one I.K. Projects Pvt. Ltd. in
which the entities at S.no. 8, 11 and 12 were the directors.
Kanta Anantrai Desai
- She had off-market connections with entity at S.no. 8 prior to the
investigation period.
- She had off-market connections with one I.K. Projects Pvt. Ltd. in
which entities at S.no. 8, 11 and 12 were the directors.
Sneha Pankaj Desai
- She had off-market connections with entity at S.no. 25.
- She had off-market connections with one I.K. Projects Pvt. Ltd. in
which entities at S.no. 8, 11 and 12 were the directors.
Anjali Tukaram Sogam
She had off-market connections with entity at S.no. 24.
Gudimetla H. Sunder
He had off-market connections with one I.K. Projects Pvt. Ltd. in which
entities at S.no. 8, 11 and 12 were the directors.
Shivcharan Shreedhar
- He had off-market transfers with entities at S.no. 10, 12 and 32.
Kashyap
- In KYC documents submitted at TM Sanghavi, his introducer is
Kamlesh Maisheri, a director of A.K. Investments (S.no. 35).
Jayesh Himmatlal Mehta
- He has common address with entity at S.no. 29.
- As per KYC, Ronak Choksi (S.no. 30) is his reference.
Nrupini Jayesh Mehta
- Wife of entity at S.no. 28 and share common address with him.
- As per KYC, Ronak Choksi (S.no. 30) is her reference.
Ronak Ashwin Choksi
- He had off-market transfers with entities at S.no. 3, 8, 31 and 32.
- He has been mentioned as reference in the KYC while opening
accounts of entities at S.no. 3, 28, 29 and 31.
Salma Sharafat Khan
- She had off-market transfers with entities at S.no. 2 and 30.
- As per KYC, Ronak Choksi (S.no. 30) is her reference.
Hiten Pravinchandra Shah - Director of Cementex (S.no. 2) (appointment on July 18, 2012)
- He had off-market transfers with entities at S.no. 12, 27 and 30.
- He has appeared as witness to entities at S.no. 3, 8, 28, 30, 31 in the
KYC submitted by Networth Stock Broking Limited.
Sunil Kumar Hariprasad
As per KYC, Ronak Choksi (S.no. 30) is his reference.
Pal
Hiten Vallabhji Haria
As per KYC submitted by Networth Broking Limited, Hiten Shah (S.no.
32) is his reference.
A.K. Investments (Kamlesh As per KYC submitted by TM Sanghavi Brothers Brokerage Limited,
Maisheri)
entities at S.no. 35, 36, 37 and 38 have common address B-35, Mahavir
Apt., Ratan Nagar, Borivali (E), Mumbai.
Amrit L. Gandhi (HUF)
Introduced by Kamlesh Maisheri, director of A.K. Investments (S.no. 35)

37

Amrit L. Gandhi

38

Seema Gandhi

39

Narendra Omprakash
Dogra

20
21
22

23

24
25
26
27
28
29
30
31
32

33
34
35

Veerabhadra Rao
Dandamudi

- Spouse of S.no. 38 as per ration card copy

- He shares common phone no. 9892526271 with entities at S.no. 38, 42
and 47.
- Spouse of S.no. 37 as per ration card copy.
- She shares common phone no. 9892526271 with entities at S.no. 37, 42
and 47.
- He had off-market transfers with entities at S.no. 27 and 43.
- In KYC documents submitted at TM Sanghavi, his introducer is
Kamlesh Maisheri,
- He is the director of A.K. Investments (S.no. 35).

Page 4 of 22

40

Jitendra Laxmichandji
Gandhi

41

Kantilal Lakshmichand

42

Shivangi Jagmohan Singh

43

Divyesh Harish Surana

44
45

Hussain Mohammed
Shaikh
Parul Anupam Khanna

46

Jigna Manish Shah

47
48

Bhavnaben Nimeshbhai
Mistry Mewada
Nishita Danish Merchant

49
50
51
52

Venkata Subbarao Yarra

Shaik Ameer Basha
Parvathaneni Mounisha
Piyush Naresh Kothari

- In KYC documents submitted at TM Sanghavi, introducer is Kamlesh

Maisheri,
- He is the director of A.K. Investments (S.no. 35).
- In KYC documents submitted at TM Sanghavi, introducer is Kamlesh
Maisheri.
- He is the director of A.K. Investments (S.no. 35).
- In KYC documents submitted at TM Sanghavi, introducer is Kamlesh
Maisheri,
- He is the director of A.K. Investments (S.no. 35),
- He shares common phone no. 9892526271 with entities at S.no. 37, 38
and 47.
- In KYC documents submitted at TM Sanghavi, introducer is Kamlesh
Maisheri,
- He is the director of A.K. Investments (S.no. 35),
- He had off-market transfers with entity at S.no. 38.
In KYC documents submitted at TM Sanghavi, introducer is Kamlesh
Maisheri, director of A.K. Investments (S.no. 35).
In KYC documents submitted at TM Sanghavi, introducer is Kamlesh
Maisheri, director of A.K. Investments (S.no. 35).
- In KYC documents submitted at TM Sanghavi, introducer is Kamlesh
Maisheri, director of A.K. Investments (S.no. 35).
- He shares common address with entity at S.no. 47.
As per UCC details uploaded at BSE by TM Sanghavi, Bhavnaben shares
common contact no. 9892526271 with entities at S.no. 37, 38 and 42.
As per UCC details uploaded at BSE by TM Sanghavi, Nishita shares
common contact no. 9619191999 with entities at S.no. 37 and 41.
He had off market transfers with entity at S.no. 18.
He is director in Exelon appointed on October 21, 2011.
He had off-market transfers with entity at S.no. 26.
He had off-market connections with entity at S.no. 8.

The promoters/ directors of Exelon along with the group entities are prima facie found
to have devised a manipulative scheme, by using two pronged approach, i.e.:
a. The Company and its six directors, during the period of February 10, 2011 to March
07, 2011, had issued corporate announcement of positive nature to the exchange,
without any intention of implementing, which led to an increase in the price of the
scrip.
b. The group entities connected to the promoters/ directors of the Company had
increased the price of the scrip by establishing new high price mainly through first
trades at repeated instances.
4.

The details of the corporate announcements made by the Company during the period
of investigation are as under:

Page 5 of 22

TABLE - B
S.No. Date and time of
announcement

2
3

Details of announcement at BSE

February 10, 2011 a. To issue upto 10 crore equity shares of `10/- each to the
(7:14:35 pm)
promoters and others by way of follow on public issue, rights
issue, preferential allotment, etc.
b.To issue GDR and/or ADR convertible into equity shares,
FCCBs, warrants, convertible into depository receipts on
preferential basis upto `100 crores.
c. To issue shares on QIP basis.
February 23, 2011 Proposal for setting up coal based thermal power plant.
(3:01:17 pm)
March 07, 2011 a. To sub-divide the equity shares from 1 equity share of `10/- each
(1:56:02 pm)
into 2(two) equity shares of `5/- each.
b.To issue upto 20 crores equity shares for the purpose of
preferential allotment, public issue, rights issue, preferential
allotment, etc.
c. To issue GDR and/or ADR convertible into equity shares, QIBs,
FCCBs, warrants convertible into depository receipts on
preferential basis upto ` 200 crores.

During the period of these announcements, the directors of the Company were Mr.
Srinivasa Rao Marupudi, Mr. Gadde Butchi Tirupati Rao, Mr. Ravi Chakravarti, Mr.
M. Vishnuvardhana Rao, Mr. P.R.K. Venkatamurthi and Mr. Srinivas Yadav Sher. A
perusal of the share capital of the Company, revealed that the announcement
pertaining to the sub-division of share capital was implemented by the Company.
As regards the other announcements, the Company has not provided any information
relating to their implementation.
The corporate announcements mentioned at serial number 1 and 3 in the Table B
above were in the nature of issue of fresh securities (except the announcement of stock
split). However, the balance sheet of the Company as well as the shareholding pattern
of the Company for the financial years ending 2010-11 and 2011-12 (available at the
website maintained by BSE), revealed that the shareholding of the Company had not
changed during the investigation period, except for the change after the stock split
during March 2011. Further, the Company/ its directors have also not informed BSE
about the non-implementation of the decisions taken in the aforesaid two meetings
(held on February 10, 2011 and on March 07, 2011). These facts suggests that the
Company had not implemented all the corporate announcements.
Page 6 of 22

5.

I note that the Company made positive corporate announcements to BSE during the
period of February 10, 2011 to March 07, 2011 and the price of the scrip during this
period had increased from `58.75 as on February 10, 2011 to `108.85 as on March 18,
2011 (i.e. an increase of 85.28% in 26 trading days). During the period when such
announcements were made, the group/ connected entities had traded in the scrip of
Exelon. Instances of synchronized, reversal and self-trades among the group entities
were also found during the investigation.

6.

I note that the stock split of the scrip of the Company (in the ratio of 1:2) had happened
on March 23, 2011. During the period of December 08, 2010 to June 13, 2011, the
scrip had opened at `19.50 as on December 08, 2010, reached a high of `112.85 as on
March 18, 2011 and had closed at `103.60 as on March 23, 2011. On March 24, 2011
(i.e. after stock split), the scrip had opened at `49.25 and closed at `83.80 on June 13,
2011. Considering the stock split on March 23, 2011, the price movement in the scrip
was analyzed in 2 patches as detailed hereunder. The table below also discusses, the
price movements as well as trading volume in the scrip in both the patches:
TABLE - C
Period

Patch 1: Pre
split patch
(08/12/10 to
23/03/11)
Patch 2: Post
split patch
(24/03/11 to
13/06/11)

No. of Price &

Tradin Vol.
g days

Opening price Closing price Lowest price Highest price

Total Volume
(volume) on (volume) on
(volume)
(volume)
(Avg. no. of shares
first day of the last day of
during the
during the traded daily during
period
the period
period
period
the period)

73

`19.50
(08/12/10)
32,694
(08/12/10)
`49.25
(24/03/11)
33,944
(24/03/11)

Price
Volume

55

Price
Volume

`103.60
(23/03/11)
1,80,401
(23/03/11)
`83.80
(13/06/11)
67,669
(13/06/11)

`18.75
(09/12/10)
7,923
(22/12/10)
`46.40
(30/03/11)
15,360
(27/05/11)

`112.85
(18/03/11)
4,31,913
(02/02/11)
`87.50
(13/06/11)
3,21,290
(19/04/11)

77,01,534
(1,05,501)

57,09,027
(1,03,982)

The investigation revealed that during patch 1 and patch 2 of the price rise, the
group/ connected entities had traded on all 73 and 55 days respectively.
7.

The investigation analyzed the trading of the connected entities and the findings
thereof relating to last traded price (LTP), new high price (NHP) and first trade
(FT) in the respective patches, are as under:
Page 7 of 22

A. Patch 1 (i.e. 08/12/10 to 23/03/11)

i.

LTP Analysis: During this patch, the price of the scrip had moved from `19.50
as on December 08, 2010 to a high of `112.85 as on March 18, 2011 and closed at
`103.60 as on March 23, 2011. The top 10 group entities contributing to positive
LTP is tabulated in the table below:
TABLE - D

Name of Buy clients

Above LTP
% of +ve LTP
LTP Impact Sum of Qty. No. of Trades to mkt. +ve LTP
Shivcharan S. Kashyap
75.15
65931
126
6.40%
Jayesh Himmatlal Mehta
72.1
52426
124
6.14%
Divyesh Harish Surana
58.6
42633
149
4.99%
A.K. Investments
32.55
77265
140
2.77%
Gangadhara Rao Ilaparti
24.85
54981
92
2.12%
Kantilal Lakshmichand
17.9
11266
23
1.53%
Amrit L.Gandhi(HUF)
15.35
50282
76
1.31%
Srinvasa Rao Marupudi
14.75
89942
39
1.26%
Nishita Danish Merchant
11.85
7240
38
1.01%
Salma Sharafat Khan
11.4
102571
26
0.97%
Top 10 group entities based on positive LTP
334.5
554537
833
28.50%
Total LTP contribution of connected group
417.45
1081524
1115
35.56%
Total LTP market wide contribution.
1173.6
2189767
3507
100.00%

From the above table, it is observed that the group entities had contributed to
`417.45 in positive LTP (i.e. 35.57% of total market positive LTP) through 1,115
trades.
Out of the said 1,115 trades of the group entities, counterparty to 907 trades (by
36 entities) were unconnected entities which contributed to positive LTP of `
349.65 (i.e. 29.79% of total market positive LTP). Further, the counterparty to
remaining 208 trades (by 25 group entities) were the group/ connected entities
which contributed to the positive LTP of `67.80 (5.78% of the total market
positive

LTP).

Out

of

these

25

group

entities,

persons

namely

Mr. Shivcharan S. Kashyap, Mr. Jayesh H. Mehta and Mr. Divyesh H. Surana
contributed `32.75 to the positive LTP (i.e. 2.79% of total market positive LTP)
and the counterparties to such trades were the group/ connected entities.

Page 8 of 22

ii.

New High Price (NHP) Analysis: In this patch, on 55 trading days and 208
occasions a NHP was discovered. Out of the 208 trades establishing NHP, 13
entities of the group were found to have been responsible for establishing NHP
in as many as 107 instances. The contribution of the group/ connected entities in
establishing NHP was `71.05 (i.e. 76.11%) out of the total price of `93.35. A
summary of the buy trades by group/ connected entities during Patch 1, that
contributed to NHP are as under:
TABLE - E
Name of clients

Shivcharan S.Kashyap
Kantilal Laxmichand
Jayesh Himatlal Mehta
Divyesh Harish Surana
A.K. Investments
Top 5 contributors to NHP
Total of connected group as Buyers
Total market

No. of
instances
Estb.
NHP
36
4
11
15
13
79
107
208

% to
total
NHP
17.31%
1.92%
5.29%
7.21%
6.25%
37.98
51.44%
100.00%

Total
Contri. of
client to
NHP (`)
33.05
7
6.8
6.25
4.75
57.85
71.05
93.35

% to Traded % to
total
vol.by total vol.
Contri. client
35.40%
7.50%
7.28%
6.70%
5.09%
61.97%
76.11%
100.00%

7054
6.12%
2503
2.17%
67
0.06%
3819
3.31%
29551 25.64%
42994
37.3%
67454 58.53%
115240 100.00%

An order book analysis of above clients revealed as under:

-

Mr. Shivcharan S. Kashyap was the top NHP contributor i.e. `33.05 (35.40%
of total market NHP) in 36 trades. Out of these 36 trades, in 29 trades
contributing `26.95 (28.87% to the total market NHP), the counterparties
were found scattered. Out of the remaining 7 trades, in 6 trades the
counterparty was Mr. Jayesh H. Mehta which contributed to NHP of `6.05
(6.48% to total market NHP) and the traded quantity was only a single share.
An order log analysis for the trades of Mr. Shivcharan S. Kashyap with Mr.
Jayesh H. Mehta where Shivcharan is bidder (purchaser) and Jayesh Mehta is
seller is reproduced below:
TABLE - F

Date

Order No.

Add Buy Order Sell order

Time
time
Upd

Trade
Time

Buy Sell Trade Buy Sell LTP LTP NHP Trade High
Order Order Qty. Order Order at contri Contri Price /Low
Qty. Qty.
Price Price order bution
for the
entry
day

Del
16/02/11 15000064000170 add

09:15:00.8 09:15:00.3 09:15:01.3

25

66.95

66

63.8

2.2

2.2

18/02/11 18000067004028 add

09:15:01.8 09:15:00.8 09:15:03.0

450

70

69.75

67

2.75

1.5

Page 9 of 22

66

64-66
64.169.75
69.75

25/02/11 18000077000099 add

09:15:00.1 09:15:00.3 09:15:00.6

450

77.9

21/02/11 23000088002554 Add 09:15:02.4 09:15:01.0 09:15:10.9

450

70

21/02/11 23000088002974 Add 09:16:05.4 09:16:43.2 09:16:43.2

450

200

200

17/03/11 19000083063080 Add 14:58:32.2 09:15:02.3 14:58:32.3 17565

75.7

2.2

1.15

70.75 68.05

2.7

71.45 71.45 71.35

0.1

0.1

0.1

0.1

108

77

107 106.9

72.7577.9
72.7570.75
77.9
72.7571.45
77.9
62.4107
68.25
77.9

From the above, it can be observed that Mr. Jayesh H. Mehta was entering sell
order at a price higher than LTP and Shivcharan was matching the sell orders
with his buy orders in order to establish NHP with single share. The repeated
trades for one share with the same entity cannot be just a mere coincidence
and the same hints that these two had indulged in increasing the price of the
scrip by establishing the base price for further trades, at a higher price.
-

Mr. Divyesh H. Surana was a contributor to NHP for a total of `6.25 in 15

trades. Out of these 15 trades, in 11 trades contributing `3.55 (3.80% to total
market NHP) the counterparties were scattered. In three of the remaining 4
trades, the counterparty was Mr. Jayesh H. Mehta and the contribution to NHP
was `2.50 (i.e. 2.68% to total market NHP). From the same, it can be said that
Mr. Divyesh H. Surana and Mr. Jayesh H. Mehta had indulged in increasing
the price of the scrip of the Company by establishing the base price for further
trades in the scrip, at a higher price.

An analysis of the trades of Mr. Jayesh H. Mehta, revealed that he had

contributed `6.8 to the NHP in 11 trades out of which, 7 trades contributing
`4.45 (4.76% of total market NHP) were with unconnected and scattered
entities. For the remaining 4 trades, the counterparty to 1 trade was Jayesh H.
Mehta himself contributing `1.45 (1.55% to total market NHP) (self-trade)
and counterparty to the rest of 3 entities were 3 different group entities.

iii.

First Trade (FT) Analysis: The details of the first trades in the scrip are as
follows:
TABLE - G

Page 10 of 22

No of
First
trades in
Market

Market
Volume
of FT

No of FT
buy
Trades by
Group

Group
Purchase
volume
by FT

Group
FT % to
Market
FT (vol.)

No. of
FT Sell
trades by
Group

Group
Sell
volume
by FT

Group
FT % to
Market
FT (vol)

No. of First
Trade
within
Group

Volume

% vol.to
Market
vol. FT

73

10099

50

5841

57.84%

15

1225

12.13%

11

73

0.72%

From the table above, it can be observed that the group entities had purchased
5,841 shares and sold 1,225 shares respectively through first trades. Following
are the LTP and NHP contribution details for all the first trades:
TABLE - H
Sum of market LTP
(buyer) of FT in `

Sum of market NHP

(buyer) of FT in `

LTP of FT trades of
Group (buyer) in `

NHP Contri of the Group

(buyer) of FT trades in `

83.45

68.9

87.8

59.95

From the above, it is observed that there was a positive impact on the price of
the scrip by first trade carried out by the entities of group entities and the same
had a total NHP contribution of `59.95 through first trades (i.e. 87.01% of the
markets NHP). The details of the first trades carried out by the group/
connected entities contributing to the positive LTP, is as follows:
TABLE - I
Name of client

No. of
first
trades
Shivcharan Shreedhar Kashyap 17
Jayesh Himmatlal Mehta
8
Divyesh Harish Surana
7
A.K. Investments
4
Kantilal Lakshmichand
3
Jitendra Laxmichandji Gandhi 2
Jigna Manish Shah
2
Narendra Omprakash Dogra
1
Bhavnaben Nimeshbhai Mistry 1
Connected group buyer total
45
Total market wide
56

First
trade
volume
66
37
56
5551
3
11
2
1
1
5728
7732

% of FT
to market
FT (Vol.)
0.85%
0.48%
0.72%
71.79%
0.04%
0.14%
0.03%
0.01%
0.01%
74.08%
100.00%

First trade
positive LTP
Sum (in `)
42.25
9.8
13.15
4.35
8.7
5.25
3.5
4
2
93
106.4

NHP
of
FT
29.25
4.55
4.65
3.85
6.95
3.45
3.5
2.85
0.9
59.95
68.9

Out of above 9 persons/ entities, two persons namely Mr. Narendra

Omprakash Dogra and Ms. Bhavnaben Nimeshbhai Mistry had executed the
first trades in only one instance. Out of the remaining 43 first trades by 7
group/ connected entities, counterparty to 35 trades were scattered and the
buy orders of the group entities got matched with the sell orders that were
already available in the system for 29 trades contributing `33.85 to NHP (i.e.
49.13% of market NHP through first trades). For the remaining 6 trades, 2

Page 11 of 22

group entities namely Mr. Shivcharan S. Kashyap and Mr. Divyesh H. Surana
had placed 4 buy orders for 1 share each and the NHP contribution thereby
was `8.05 (i.e. 11.68% to market NHP through first trades). In view of the
same, it can be said that Mr. Shivcharan S. Kashyap and Mr. Divyesh H. Surana
had entered buy orders with an intention of establishing a new base price, in
the scrip during the first trade of the day and manipulated the price of the
scrip.
-

Further, the counterparty to 8 first trades were found to be the group entities
contributing `9.55 to NHP (13.86% to market NHP through first trades) and
contributing `15.1 to the positive LTP (14.19% to the market positive LTP
through first trades). The details of these 8 trades, is given in the table below:
TABLE - J
Name of Buy client

Name of Sell Client

No. of
First
trades
Shivcharan Shreedhar Kashyap Jayesh Himmatlal Mehta 4
Divyesh Harish Surana
Jayesh Himmatlal Mehta 1
Jayesh Himmatlal Mehta
Jayesh Himmatlal Mehta 1
Jayesh Himmatlal Mehta
Divyesh Harish Surana 1
A K Investments
Jayesh Himmatlal Mehta 1
Total of above 5 entities
8
Connected group buyer total
45
Total market wide
56

First
trade
volume
4
1
10
5
50
70
5728
7732

First trade NHP of

positive LTP FT
Sum (in `)
9.85
5.85
3.8
2.25
1.45
1.45
1.5
0
0.25
0
16.85
9.55
93
59.95
106.4
68.9

From the above, it can be observed that 3 persons namely Mr. Jayesh H.
Mehta, Mr. Shivcharan S. Kashyap and Mr. Divyesh H. Surana had together
contributed `9.55 to the market NHP (i.e. 13.86% of market NHP through
first trades) through 7 first trades by indulging in increasing the price of the
scrip and establishing the base price for further trades in the scrip at a higher
price through first trades of the day.
B. Patch 2: (i.e. 24/03/11 to 13/06/11)
i.

NHP Analysis: During this patch, the price of the scrip had opened at `49.25
and closed at `83.80 on June 13, 2011 after reaching a high of `87.50 on June 13,

Page 12 of 22

2011 (i.e. an increase of `38.25). On 56 occasions, in 15 trading days NHP was

discovered. Out of these 56 trades establishing NHP, 4 group entities are found
to have been responsible for establishing NHP in 13 instances. The contribution
of group entities in establishing new high prices was `17.40 (45.49%) out of the
total price of `38.25. Details of the same are given below:
TABLE - K
Name of clients

No. of
instances
estb. NHP
Shivcharan Shreedhar Kashyap 8
Seema Gandhi
1
Jitendra Laxmichandji Gandhi 2
Kantilal Lakshmichand
2
Total of connected group as 13
Buyers
Total market
56

% to
total
NHP
14.29%
1.79%
3.57%
3.57%
23.21%

Total Contri.
of client to
NHP (`)
13.5
2.7
1
0.2
17.4

100.00% 38.25

% to
total
Contri.
35.29%
7.06%
2.61%
0.52%
45.49%

Traded
vol.by
client
9
44
700
165
918

100.00% 16246

% to
total vol.
0.06%
0.27%
4.31%
1.02%
5.65%
100.00%

The order book analysis of the above mentioned entities revealed as under:
-

Mr. Shivcharan S. Kashyap had contributed `13.50 (i.e. 35.29% to market

NHP) in 8 trades for a quantity of 9 shares. Out of 8 trades, buy orders of Mr.
Shivcharan Kashyap got executed with sell orders which were already existing
in the system in 3 trades contributing `1.95 to market NHP (i.e. 5.1% of total
market NHP). The remaining 5 trades in which the buy orders were entered
first at NHP contributed `11.55 to the market NHP (i.e. 30.20% of market
NHP). All these trades were found to be first trades of the day and quantity
traded in these trades was only 1 share except in one trade wherein 2 shares
were traded. The repeated trades for just single share at NHP cannot be just a
mere coincidence and suggests that Mr. Shivcharan S. Kashyap had indulged
in increasing the price of the scrip by establishing the base price for further
trades in the scrip at higher price.

Trades of other 3 group entities contributing to NHP during Patch 2 were

also analyzed and it was revealed that counterparty to 4 out of 5 trades were
scattered and the buy orders of group entities got executed with those sell
orders which had already existed in the system.

Page 13 of 22

ii.

First Trade (FT) Analysis: The details of the first trades in the scrip during this
patch are as under:
TABLE - L

No of
First
trades in
market

Market
volume
of FT

No of
FT buy
trades
by
Group

Group
purchase
volume
by FT

55

10725

20

3564

Group No. of Group Group

FT % FT sell
sell
FT %
to
trades volume
to
market
by
by FT Market
FT
Group
FT
(vol.)
(vol.)
33.23% 3
611
5.70%
1

No. of
First
Trade
within
group

Vol.

%
vol.to
Market
vol. FT

0.72%

From the above table it can be seen that the group entities had purchased 3,564
shares and sold 611 shares, respectively through first trades. The LTP and
NHP contribution details for all the first trades is as under:
TABLE - M

Sum of market LTP

(buyer) of FT in (`)
27.8

Sum of market NHP

(buyer) of FT in (`)
28.85

LTP of FT trades of NHP Contri of the Group (buyer)

Group (buyer) in (`)
of FT trades in (`)
30.25
16

From the above, it can be seen that there was a positive impact on the price
through first trades carried out by the group entities and had a total NHP
contribution of `16 through first trades which is 52.89% of the markets NHP
through first trade. The details of the first trades carried out by group/
connected entities who had contributed to the positive LTP variation, is as
follows:
TABLE - N
Name of client
Shivcharan Shreedhar Kashyap
Seema Gandhi
Divyesh Harish Surana
Narendra Omprakash Dogra
Elubandi Satyanarayana
Connected group buyer total
Total market wide

No. of
First
trades
13
1
1
1
1
17
32

First
trade
volume
2017
44
1
500
1
2563
6191

% of FT
to market
FT (vol.)
32.58%
0.71%
0.02%
8.08%
0.02%
41.40%
100.00%

First trade
NHP
positive LTP of FT
Sum (in `)
25.45
13.3
2.7
2.7
3
0
1.1
0
0.7
0
32.95
16
62.65 28.85

From the above table, it can be observed that Mr. Shivcharan Kashyap had
contributed to NHP through first trades repeatedly. He had contributed to
positive LTP of `25.45 and NHP of `13.30 in 13 trades.
Page 14 of 22

Out of the 13 trades, counterparty to 1 trade was a group entity namely Mr.
Jayesh Mehta and the LTP contribution for such trade was `0.95. Out of
remaining 12 first trades, the buy orders of Mr. Shivcharan Kashyap got
executed with sell orders which were pending in the system in 5 trades
contributing `8.85 to market positive LTP and `1.75 to market NHP.
The remaining 7 first trades in which the buy orders were entered first had
contributed `15.65 to LTP (i.e. 24.98% of market positive LTP through first
trades) and `11.55 to NHP (i.e. 40.03% of market NHP through first trades).
Further, other 4 entities of the group have executed first trades for 1 day each.

8.

Considering the discussion above, it can be said that during the period when the
Company and its directors had made misleading advertisements of positive nature, the
group/ connected entities had traded in the scrip of the Company. The group entities
connected to the promoters/ directors of the Company had manipulated the price of
the scrip by contributing `71.05 to NHP out of total market NHP of `93.35 (i.e.
76.11% of market NHP) during the period of December 08, 2010 to March 23, 2011
(i.e. the period of price rise before stock split) by trading in 67,454 shares (i.e. 0.87%
of market volume during that period). Further, these entities had manipulated the price
of the scrip even after the stock split and contributed `17.40 to NHP out of the total
market NHP of `38.25 (i.e. 45.49% of market NHP), during the period of March 24,
2011 to June 13, 2011 (the period of price rise after stock split) by trading in 918 shares
(0.02% of market volume during that period).
The trading pattern in the scrip hints that the announcements made by the Company
were dissemination to the public with an intention to distort the market equilibrium
and the same was a scheme to make illegal gains and defraud the genuine investors.
The investigation has alleged that the promoter of the Company (Cementex), directors
of the Company and the group/ connected entities have violated the provisions of
Regulation 3(a) (b) (c) (d), 4(1), 4(2) (a) of the SEBI (Prohibition of Fraudulent and

Page 15 of 22

Unfair Trade Practices Relating to Securities Market) Regulations, 2003 and made
unlawful gains.
9.

Gains: Based on the analysis discussed above, it can be said that during the period
when the misleading announcements were made by the Company, the directors and
other connected entities, had manipulated the price of the scrip of the Company
upwards. The unlawful gains made in the scrip has been calculated and given
hereunder:
-

Profit/ Loss calculation during Patch 1: During this patch, the price of the scrip
had opened at `19.50 and had closed at `103.60. Further, 41 group entities have made
profit including the promoter Cementex. Details of the same are mentioned below:
TABLE - O

S.
Name
No.

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29

Hiten Vallabhji Haria

Cementex (India) P.Ltd.
Ronak Ashwin Choksi
A.K. Investments
Divyesh Harish Surana
Salma Sharafat Khan
Jayesh Himmatlal Mehta
Narendra O. Dogra
Kanta Anantrai Desai
Anjali Tukaram Sogam
Jitendra L. Gandhi
Amrit L.Gandhi (HUF)
Seema Gandhi
Anitha Yarlagadda
Gangadhara Rao Ilaparti
Hussain M. Shaikh
Veerabhadra Dandamudi
Shivcharan S. Kashyap
Jigna Manish Shah
Sneha Pankaj Desai
Nishita Danish Merchant
Dhana Energy P.Ltd.
Srikrishna Vadlamudi
Kantilal Lakshmichand
Gudimetla H Sunder
Shivangi J. Singh
Dimple Pankaj Desai
PVS Gangadhara Rao
Sunil Kumar H. Pal

Buy
Buy Value
Quantity (in `)

187,000
40,000
174,008
353,356
243,660
367,428
229,151
96,560
6,819
12,971
100,000
168,294
181,250
20,000
147,820
50,000
0
172,417
22,065
11,000
57,473
0
0
38,295
110,318
34,394
5,000
9,400
15,000

10,030,100
1,388,000
11,270,032
13,682,681
13,872,464
22,283,901
14,890,412
5,646,179
319,549
572,897
7,834,052
8,720,599
9,477,907
495,925
9,498,062
1,033,135
0
14,293,367
910,689
533,793
2,038,736
0
0
2,022,405
7,485,900
1,144,596
175,735
310,440
1,255,217

Sell
Quantity

29,769
363,000
32,800
353,216
178,932
302,427
145,162
87,117
32,568
57,971
99,990
142,843
170,250
72,935
137,046
50,000
107,086
92,833
12,065
56,000
57,473
14,000
45,200
38,295
117,167
34,394
6,683
12,603
0

Sell Value Quantity of

shares remained
(in `)
at end of this
period ( ) /
Shares held prior
to this period
3,055,179
(157,231)
14,464,335
323,000
2,435,565
(141,208)
18,696,287
(140)
11,423,155
(64,728)
19,453,905
(65,001)
8,668,800
(83,989)
6,667,731
(9,443)
2,621,420
25,749
2,908,446
45,000
9,267,739
(10)
7,441,573
(25,451)
9,685,935
(11,000)
2,690,527
52,935
9,485,745
(10,774)
2,124,938
0
3,034,762
107,086
6,882,162
(79,584)
667,086
(10,000)
2,159,657
45,000
2,755,578
0
943,900
14,000
1,430,048
45,200
2,503,361
0
8,071,902
6,849
1,527,321
0
589,110
1,683
686,341
3,203
0
(15,000)

Page 16 of 22

Value of shares Profit

remaining at the (in `)
end of this
period / held
prior to this
period (in `)
(16,289,132) 9,314,211
6,298,500 6,777,835
(14,629,149) 5,794,682
(14,504) 5,028,110
(6,705,821) 4,256,512
(6,734,104) 3,904,108
(8,701,260) 2,479,648
(978,295) 1,999,847
502,106 1,799,766
877,500 1,458,049
(1,036) 1,434,723
(2,636,724) 1,357,698
(1,139,600) 1,347,628
1,032,233 1,162,370
(1,116,186) 1,103,869
0 1,091,803
2,088,177
946,585
(8,244,902)
833,697
(1,036,000)
792,397
877,500
748,364
0
716,842
273,000
670,900
881,400
548,648
0
480,956
133,556
452,447
0
382,725
32,819
380,557
62,459
313,443
(1,554,000)
298,783

30
Venkata Subbarao Yarra
31
Amrit L.Gandhi
32
Bhavnaben N. Mistry
33
Yentrapati Ravi
34
Parul Anupam Khanna
35
Hiten P. Shah
36
Parvathaneni Mounisha
37
Marupudi Sree Lakshmi
38
Swapna Sri Tummala
39
Satya S. Jonnavithula
40
Piyush Naresh Kothari
41
Shaik Ameer Basha
TOTAL

1,925
61,254
39,861
1,509,742
20,601
684,706
4,944
169,025
20,000
599,439
2,800
192,277
725
27,500
900
39,195
0
0
10,143
443,817
0
0
500
36,748
2,956,078 164,950,476

5,460
286,016
39,861 1,646,513
20,601
812,052
10,004
392,000
20,000
701,000
2,800
287,896
1,725
112,176
0
0
40,244
830,249
10,143
453,503
2,039
44,374
500
37,750
3,003,202 167,946,037

3,535
0
0
5,060
0
0
1,000
(900)
40,244
0
2,039
0
47,124

68,933
155,830
0
136,771
0
127,346
98,670
124,305
0
101,561
0
95,619
19,500
65,176
(93,240)
54,045
784,758
45,491
0
9,686
39,761
4,614
0
1,002
-55,803,081 58,798,649

Profit / Loss calculation during Patch 2- During this patch, the price of the scrip
had opened at `49.25 and closed at ` 83.8. Further, 31 group entities have made profit
including the promoter Cementex. Details of such trades are summarised below:
TABLE - P

S. Name
No.

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

Ronak Ashwin Choksi

Amrit L.Gandhi(HUF)
Hiten P. Shah
Divyesh Harish Surana
Jitendra L. Gandhi
Dhana Energy P.Ltd.
Shivcharan S. Kashyap
Cementex (India) P.Ltd.
Hiten Vallabhji Haria
Jigna Manish Shah
Srinivas Yadav Sher
Gudimetla H Sunder
Rama K. Makkena
Nrupini Jayesh Mehta
Srinvasa Rao Marupudi
Seema Gandhi
Jayesh H. Mehta
Mahendra Bhikaji Chile
Sunil Kumar H. Pal
Kantilal Lakshmichand
Srikrishna Vadlamudi
Anitha Yarlagadda
Elubandi Satyanarayana
Veerabhadra R.
Dandamudi
Hussain M. Shaikh

Buy
Buy Value
Quantity (in `)

382,701
60,140
170,430
53,992
89,372
0
303,057
0
0
15,000
25,000
12,600
0
52,857
67,000
137,962
190,130
0
94,503
13,046
0
5,000
46,037
7,500

24,938,997
2,915,963
12,846,922
3,951,026
5,338,088
0
20,762,242
0
0
719,329
1,673,800
722,500
0
3,624,180
5,145,483
9,486,462
12,967,843
0
7,281,109
689,503
0
245,000
3,010,189
439,872

6,962

507,243

Sell
Quantity

Sell Value Quantity of shares

remained at end of
(in `)
this period ( ) /
Shares held prior to
this period

411,308 29,740,198
111,042 7,614,827
6,753
564,270
132,466 9,240,479
49,392 3,333,504
47,000 3,515,500
195,693 12,860,191
41,000 3,034,000
75,669 4,580,720
29,000 2,101,483
40,299 3,005,110
43,808 2,821,993
20,000 1,522,272
28,865 2,137,841
85,000 6,495,500
124,765 8,810,176
197,306 13,697,039
12,500
967,375
47,102 3,553,393
13,046
896,447
6,000
458,100
3,200
253,920
50,437 3,381,358
5,526
426,190
0

Page 17 of 22

28,607
50,902
(163,677)
78,474
(39,980)
47,000
(107,364)
41,000
75,669
14,000
15,299
31,208
20,000
(23,992)
18,000
(13,197)
7,176
12,500
(47,401)
0
6,000
(1,800)
4,400
(1,974)
(6,962)

Value of shares Profit

remaining at the (in `)
end of this
period / held
prior to this
period (in `)
1,408,895 3,392,306
2,506,924 2,191,941
(13,716,133) 1,433,481
3,864,845 1,424,609
(3,350,324) 1,345,740
2,314,750 1,200,750
(8,997,103) 1,095,052
2,019,250 1,014,750
3,726,698
854,022
689,500
692,654
753,476
577,834
1,536,994
562,499
985,000
537,272
(2,010,530)
524,191
886,500
463,517
(1,105,909)
429,623
353,418
375,778
615,625
351,750
(3,972,204)
244,488
0
206,944
295,500
162,600
(150,840)
159,760
216,700
154,469
(165,421)
151,739
(583,416)

76,173

26 Gangadhara Rao Ilaparti

27 PVS Gangadhara Rao
28 Bhavnaben N. Mistry
29 A.K. Investments
30 Venkata S. Yarra
31 Amrit L.Gandhi
TOTAL

45,538
3,039,351
0
0
1,000
55,250
10,000
531,261
475
31,666
835
44,923
1,791,137 120,968,202

54,306 3,545,537
2,700
195,261
0
0
10,000
554,000
750
50,953
835
50,088
1,845,768 129,407,725

8,768
2,700
(1,000)
0
275
0
54,631

431,824
74,362
132,975
62,286
(83,800)
28,550
0
22,739
13,544
5,743
0
5,165
-11,383,262 19,822,787

Note Calculation of unlawful gains under various scenarios is as under:

i)
ii)

When sell quantity = Buy quantity during the period, Profits made = Sell Value - Buy value
When sell quantity > Buy quantity during the period, Profits made = Sell Value - Buy value - Value of shares held
prior to this period.
iii) When sell quantity < Buy quantity during the period, Profits made = Sell Value - Buy value + Value of shares
remaining at the end of this period.

From the above tables, it is observed that by manipulating the price of the scrip,
establishing NHP through first trades alongwith the corporate announcements of
positive nature, the promoter/ director connected entities have made a profit of about
`7.86 crore (i.e. `5.88 crore + `1.98 crore).
10.

As the alleged gains were made during December 2010 to June 2011, it becomes
reasonable and necessary to levy an interest at the rate of 12% simple interest per
annum. The gains along with the interest are calculated as follows:
TABLE Q: Summary of the profits made by the group entities

S. No.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21

Name of Entity
Hiten Vallabhji Haria
Cementex (India) P.Ltd.
Ronak Ashwin Choksi
A.K. Investments
Divyesh Harish Surana
Salma Sharafat Khan
Jayesh Himmatlal Mehta
Narendra Omprakash Dogra
Kanta Anantrai Desai
Anjali Tukaram Sogam
Jitendra Laxmichandji Gandhi
Amrit L.Gandhi(HUF)
Seema Gandhi
Anitha Yarlagadda
Gangadhara Rao Ilaparti
Hussain Mohammed Shaikh
Veerabhadra Rao Dandamudi
Shivcharan Shreedhar Kashyap
Jigna Manish Shah
Sneha Pankaj Desai
Nishita Danish Merchant

PAN No.
AAAPH6890H
AAACC9265A
ADDPC2938D
AANFA6009Q
DALPS0578H
BVSPK9348F
AIFPM2216D
AJMPD8729N
AAEPD6006F
CGNPS1443N
AACPG6473H
AAJHA4701R
AAEPG0960B
ACAPY5774B
AANPI9650F
BSSPS2832P
ABVPD6656R
ATOPK6636K
ANQPS6789P
AIBPD1454A
AMHPM8133B

Profit (`)
10,168,233
7,792,585
9,186,988
5,050,849
5,681,121
3,904,108
2,855,426
1,999,847
1,799,766
1,458,049
2,780,463
3,549,639
1,777,251
1,322,130
1,178,231
1,167,976
1,098,324
1,928,749
1,485,051
748,364
716,842

Page 18 of 22

Interest @12%p.a.*
6,060,824
4,644,808
5,475,948
3,010,583
3,386,259
2,327,062
1,701,990
1,192,018
1,072,759
869,077
1,657,308
2,115,779
1,059,339
788,062
702,290
696,178
654,661
1,149,640
885,172
446,066
427,277

Total (`)
16,229,057
12,437,393
14,662,936
8,061,432
9,067,380
6,231,170
4,557,416
3,191,865
2,872,525
2,327,126
4,437,771
5,665,418
2,836,590
2,110,192
1,880,521
1,864,154
1,752,985
3,078,389
2,370,223
1,194,430
1,144,119

22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45

Dhana Energy P.Ltd.

Srikrishna Vadlamudi
Kantilal Lakshmichand
Gudimetla H Sunder
Shivangi Jagmohan Singh
Dimple Pankaj Desai
PVS Gangadhara Rao
Sunil Kumar Hariprasad Pal
Venkata Subbarao Yarra
Amrit L.Gandhi
Bhavnaben Nimeshbhai Mistry
Mewada
Yentrapati Ravi
Parul Anupam Khanna
Hiten Pravinchandra Shah
Parvathaneni Mounisha
Marupudi Sree Lakshmi
Swapna Sri Tummala
Satya Suryanarayana Jonnavithula
Piyush Naresh Kothari
Shaik Ameer Basha
Srinivas Yadav Sher
Rama Krishna Makkena
Nrupini Jayesh Mehta
Srinvasa Rao Marupudi

46 Mahendra Bhikaji Chile

47 Elubandi Satyanarayana
TOTAL

AACCV7693M
ADNPV5504C
ADSPK7577K
BMLPS9664N
AOSPS5911E
AUQPD3909F
AKYPP5600M
BKSPP6938B
AAPPY4270P
AACPG5265H
ALIPM5347B

1,871,650
711,248
687,900
1,014,946
382,725
380,557
375,729
543,271
161,573
141,936
155,896

1,115,606
423,943
410,026
604,963
228,125
226,833
223,955
323,819
96,306
84,602
92,923

2,987,256
1,135,191
1,097,926
1,619,909
610,850
607,390
599,684
867,090
257,879
226,538
248,819

ABWPY6767F
BCUPK8420R
AHAPS0889A
BAOPP1399G
ALYPM2964Q
ALDPT7720Q
ACRPJ9665R
AEOPK1882L
AEZPB3408A
AUAPS8547G
BCKPK1101P
BDTPM2261E
ACQPM0876L &
BCDPM3124P
AHNPC8127G
DGCPS7022F

124,305
101,561
1,529,100
65,176
54,045
45,491
9,686
4,614
1,002
577,834
537,272
524,191
463,517

74,093
60,536
911,427
38,848
32,214
27,115
5,773
2,750
597
344,421
320,244
312,447
276,282

198,398
162,097
2,440,527
104,024
86,259
72,606
15,459
7,364
1,599
922,255
857,516
836,638
739,799

351,750
154,469
78,621,436

209,662
92,072
46,862,682

561,412
246,541
12,54,84,118

* Interest calculated on illegal gains from 14/06/2011 till 01/06/2016

From the above table, it can be observed that the above persons/ entities had made
alleged illegal profits to the tune of `12.54 crore in aggregate including interest through
trading in the scrip of Exelon.
11.

I note that the persons/entities are aware of the investigations as also the likely findings
of the investigation, in the light of the evidences gathered during the investigation. All
these factors point to the possibility that the persons/ entities involved may divert the
unlawful gains. Therefore, in order to prevent such persons/ entities from diverting
the funds and to safeguard the interests of securities market, it becomes necessary for
SEBI to take urgent preventive steps of impounding and retaining the proceeds by
way of an interim measure.

Page 19 of 22

12.

Accordingly, as an interim measure, an ad-interim ex-parte Order for impounding such

alleged profits under Section 11(4)(d) of the Securities and Exchange Board of India
Act, 1992 needs to be issued against
TABLE R
S. No.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41

Name
Exelon Infrastructure Limited
Cementex (India) Pvt. Limited
Srinivasa Rao Marupudi
Gadde B. Tirupati Rao
Ravi Chakravati
M. Vishnuvardhan Rao
P R K Venkatamurthi
Srinivas Yadav Sher
Shaik Ameer Basha
Sree Lakshmi Marupudi
Hiten Vallabhji Haria
A.K. Investments
Narendra O. Dogra
Kanta Anantrai Desai
Anjali Tukaram Sogam
Jitendra L. Gandhi
Amrit L.Gandhi(HUF)
Gangadhara Rao Ilaparti
Hussain M. Shaikh
Jigna Manish Shah
Sneha Pankaj Desai
Nishita D. Merchant
Dhana Energy P.Ltd.
Srikrishna Vadlamudi
Kantilal Lakshmichand
Gudimetla H Sunder
Shivangi J. Singh
Dimple Pankaj Desai
PVS Gangadhara Rao
Sunil Kumar H. Pal
Venkata Subbarao Yarra
Amrit L.Gandhi
Bhavnaben N. Mistry
Yentrapati Ravi
Parul Anupam Khanna
Hiten P. Shah
Parvathaneni Mounisha
Swapna Sri Tummala
Satya S. Jonnavithula
Piyush Naresh Kothari
Nrupini Jayesh Mehta

Page 20 of 22

Permanent Account Number

AAACM2862M
AAACC9265A
ACQPM0876L, BCDPM3124P
AHUPG9920A
AJXPR4789F
ABYPM0993M
AFQPP6066G
AUAPS8547G
AEZPB3408A
ALYPM2964Q
AAAPH6890H
AANFA6009Q
AJMPD8729N
AAEPD6006F
CGNPS1443N
AACPG6473H
AAJHA4701R
AANPI9650F
BSSPS2832P
ANQPS6789P
AIBPD1454A
AMHPM8133B
AACCV7693M
ADNPV5504C
ADSPK7577K
BMLPS9664N
AOSPS5911E
AUQPD3909F
AKYPP5600M
BKSPP6938B
AAPPY4270P
AACPG5265H
ALIPM5347B
ABWPY6767F
BCUPK8420R
AHAPS0889A
BAOPP1399G
ALDPT7720Q
ACRPJ9665R
AEOPK1882L
BDTPM2261E

42
43
44
45
46
47
48
49
50
51
52

13.

Mahendra Bhikaji Chile

Elubandi Satyanarayana
Rama Krishna Makkena
Anitha Yarlagadda
Salma Sharafat Khan
Seema Gandhi
Ronak Ashwin Choksi
Veerabhadra D.
Divyesh Harish Surana
Jayesh H. Mehta
Shivcharan S. Kashyap

AHNPC8127G
DGCPS7022F
BCKPK1101P
ACAPY5774B
BVSPK9348F
AAEPG0960B
ADDPC2938D
ABVPD6656R
DALPS0578H
AIFPM2216D
ATOPK6636K

In view of the foregoing, in order to protect the interest of the investors and the
integrity of the securities market, I, in exercise of the powers conferred upon me by
virtue of section 19 read with sections 11(1), 11(4)(d) and 11B of the SEBI Act, 1992,
hereby impound the alleged unlawful gains of a sum of `12,54,84,118 (alleged gain
of `7,86,21,436 + interest of `4,68,62,682 (from 14/06/2011 to 01/06/2016),
jointly and severally from persons/entities tabulated in the paragraph 12 above.

14.

The Banks are directed that no debits shall be made, without permission of SEBI, in
respect of the bank accounts held by all the persons/entities tabulated in paragraph 12
above, except for the purposes of transfer of funds to the escrow account as directed
in paragraph 13 above. Further, the Depositories are also directed that no debit shall
be made, without permission of SEBI, in respect of the demat accounts held by the
above said persons. However, credits, if any, into the accounts maybe allowed. The
Banks and the Depositories are directed to ensure that all the above directions are
strictly enforced. Further, debits may also be allowed for amounts available in the
account in excess of the amount to be impounded. Banks are allowed to debit the
accounts for the purpose of complying with this Order.

15.

The persons/ entities tabulated in paragraph 12 above are also directed not to dispose
off or alienate any of their assets/properties/securities, till such time the amounts
mentioned in paragraph 13 are credited to an escrow account {Escrow Account in
Compliance with SEBI Order dated June 07, 2016 A/c (in the name of the
respective persons/entities)} created specifically for the purpose in a Nationalized
Bank. The escrow account/s shall create a lien in favour of SEBI and the monies kept
Page 21 of 22

therein shall not be released without permission from SEBI. On production of proof
by any of the persons, mentioned in paragraph 14, that the said money is deposited in
the escrow account, SEBI shall communicate to the Banks and Depositories to
defreeze the accounts.
16.

Further, the persons/ entities tabulated in paragraph 12 above are directed to provide,
within 7 days of this order, a full inventory of all their assets and properties and details
of all their bank accounts, demat accounts and holdings of shares/ securities, if held
in physical form and details of companies in which they hold substantial or controlling
interest.

17.

The above direction shall come into force with immediate effect.

18.

This Order is without prejudice to the right of SEBI to take any other action that may
be initiated against the 52 persons/entities covered under this Order, in accordance
with law. The persons/ entities against whom this Order has been passed may file their
replies to SEBI within 21 days from the date of receipt of this order, if they so desire.
They may also indicate in their replies whether they wish to avail an opportunity of
personal hearing in the matter.

Date: June 07, 2016

Place: Mumbai

PRASHANT SARAN
WHOLE TIME MEMBER
SECURITIES AND EXCHANGE BOARD OF INDIA

Page 22 of 22