Adjudication Order in The Matter of Harita Seating Systems Ltd.

BEFORE THE ADJUDICATING OFFICER
SECURITIES AND EXCHANGE BOARD OF INDIA

[ADJUDICATION ORDER NO.EAD-5/SVKM/RGA/AO/01-12/2015]
________________________________________________
UNDER SECTION 15-I OF SECURITIES AND EXCHANGE
BOARD OF INDIA ACT, 1992 READ WITH RULE 5 OF SEBI
(PROCEDURE
FOR
HOLDING
INQUIRY
AND
IMPOSING
PENALTIES BY ADJUDICATING OFFICER) RULES, 1995

In respect of
S.NO.
NAME OF THE ENTITY
Order No.
PAN No.
1.
Priya Dhaval Thakkar
EAD-5/SVKM/RGA/AO/01/2015
ACBPT1501C
Mahesh Dhanvantrai Mehta EAD-5/SVKM/RGA/AO/02/2015
AACPM3933C
2.
3.
Nikunj Dhanvantrai Mehta
AACPM3931A
4.
Amita Nitesh Thakkar
ACAPT2682B
5.
Fenil Nitesh Thakkar
AILPT1308D
6.
Nitesh Arjun Thakkar HUF
AACHN5060K
Adjudication Order in the matter of Harita Seating Systems Limited
Page 1 of 54
July 31, 2015
7.
Madhukanta Dhanvantrai
AAGPM7193Q
Mehta
8.
Nitesh Arjun Thakkar
AABPT3925E
9.
Dhaval Arjun Thakkar
AAAPT5706A
10.
Yogesh Rasiklal Doshi
AAEPD3360Q
11.
Darshana Yogesh Doshi
AEJPD8749N
12.
Mitali Yogesh Doshi
AJNPD6635Q
In the matter of M/s Harita Seating Systems Limited
FACTS OF THE CASE

1. Securities and Exchange Board of India (hereinafter referred to as
'SEBI') conducted an investigation into the alleged irregularities in
the trading in the shares of Harita Seating Systems Limited
(hereinafter referred to as 'HSSL/ scrip') for the period November
01, 2009 to March 31, 2010 (hereinafter referred to as the relevant
period) and into the possible violation of the provisions of the
Securities and Exchange Board of India Act, 1992 (hereinafter
referred to as 'SEBI Act, 1992') and various Rules and Regulations
made thereunder. The shares of HSSL are listed on BSE Limited
(BSE), National Stock Exchange of India Limited (NSE), Bangalore
Stock Exchange (BgSE) and Madras Stock Exchange(MSE).
Page 2 of 54
July 31, 2015
2. Pursuant to the said investigation, it was alleged that Priya Dhaval

Thakkar, Mahesh Dhanvantrai Mehta, Nikunj Dhanvantrai Mehta,
Amita Nitesh Thakkar, Fenil Nitesh Thakkar, Nitesh Arjun Thakkar
(HUF), Madhukanta Dhanvantrai Mehta, Nitesh Arjun Thakkar,
Dhaval Arjun Thakkar, Yogesh Rasiklal Doshi, Darshana Yogesh
Doshi, Mitali Yogesh Doshi (hereinafter referred to as 'Noticees')
while transacting through Aquarian Share Broking Co. Pvt. Ltd.
(hereinafter referred to as 'ASB') a sub- broker (SEBI Regn No
INS 012298431) of SVS Securities Limited, trading member BSE &
NSE
[SEBI
Regn.
No.
BSE-INB010995736,
INF010995736,
INB230995731 & INF230995731] (hereinafter referred to as 'SVS')

indulged in synchronized trades and cross deals that created
artificial volumes and rigged the price of the scrip. It was therefore,
alleged that Noticee No. 1 to Noticee No. 7 had violated Regulation
4(1), 4(2) (a) and (g) SEBI (Prohibition of Fraudulent and Unfair
Trade Practices) Regulations, 2003 (hereinafter referred to as
PFUTP Regulations, 2003), and Noticee No. 8 to Noticee No.10
had violated Regulation 4(1), 4(2) (a), (b),(e) and (g) of PFUTP
Regulations, 2003 and Noticee No. 11 & Noticee No.12
had
violated Regulation 4(1)(2)(e)of PFUTP Regulations, 2003 and liable

for monetary penalty under section 15HA of SEBI Act, 1992.
APPOINTMENT OF ADJUDICATING OFFICER

3.
SEBI vide December 11, 2012 appointed Shri P.K. Kuriachen as

the Adjudicating Officer under section 15 I of SEBI Act, 1992 read
with Rule 3 of SEBI (Procedure for Holding Inquiry and Imposing
Penalties by Adjudicating Officer) Rules, 1995 (hereinafter referred
to as Rules) to inquire into and adjudge under section 15HA of
SEBI Act, 1992 the aforesaid alleged violations. Consequent to the
transfer of Shri P.K. Kuriachen, Shri Piyoosh Gupta was appointed
Page 3 of 54
July 31, 2015
as the Adjudicating Officer vide order dated July 30, 2013.

Subsequent to the transfer of Shri Piyoosh Gupta, Shri A. Sunil
Kumar was appointed as Adjudicating Officer vide order dated
November 08, 2013. Pursuant to the transfer of Shri A. Sunil
Kumar, the undersigned has been appointed as the Adjudicating
Officer vide order dated June 22, 2015.
SHOW CAUSE NOTICE, REPLY AND PERSONAL HEARING
4. Show Cause Notice No. EAD-2/RGA/4721/2013 dated February 22,

2013 (hereinafter referred to as 'SCN') was issued to the Noticees
under Rule 4(1) of the Rules to show cause as to why an inquiry
should not be initiated and penalty be not imposed under section
15HA of SEBI Act, 1992 for the alleged violations specified in the
said SCN.
5. Noticees vide letters dated April 22, 2013/April 26, 2013/May 06,
2013 submitted their reply to the SCN. The Noticees also availed of
the opportunity of personal hearing and appeared before the
undersigned on June 30, 2015 and July 08, 2015. Written
submissions were also filed on behalf of the Noticees dated July 07,
2015. The salient submissions made by the Noticee No. 1, 4, 5, 6, 8
and 9 are as under:
We are retail investors in capital market for the last several years and have
been holding equity shares of HSSL for last three years i.e. 2010, 2011
and 2012.
Our transactions were normal, buy and/or sell in the said scrip. We
received deliveries of bought shares and tendered deliveries of sold shares
from our existing stock lying in our demat accounts.
We deny that we were involved in anyway in cross trades or artificial
volume in HSSL scrip as alleged or otherwise.BSE and NSE did not annul
the trades nor expunged the daily quotations of share prices of HSSL scrip
at the relevant time.
Page 4 of 54
July 31, 2015
Trading platforms are online, real time, computerized, price and time
priority matching trade systems for orders keyed in in different scrips
through a large number of terminals. The trading modules are therefore
anonymous and its algorithm not known to anyone. A family has to have a
separate trading/demat account for its different family members and who
may trade separatey, jointly and/or independently on selective occasion as
per strategy, conviction, and short/long term view on a scrip etc. factors.
Their trading on the same day does not mean anything adverse or
negative. Further, if a few orders get matched within family members
trading accounts when the scrip is illiquid, no wrongdoing can be
attributed to them.
Each of Thakkar family members' trading, buying, selling and dealing and
investing was separate, independent and stand alone and recorded in
individual UCC, accounted in individual ledger account/demat account
and fund flow was through upfront mapped bank account. We declared
our profit/loss through trading in our separate income tax returns.
Seen in a continuous/cumulative/comparative matrix, it is evident that
trading volume of some members (such as Shri Fenil ) was insignificant
and only on few days and some members trading was comparatively large
and on many days-there are vast differences in the style, pattern, method
and features of trading of members.
Considering our volume on both the exchanges on a net basis(i.e. buy
minus sell) all the members were buyers (except in one case) during the
investigation period and they took deliveries of shares of HSSL.
The basis viz trades and raisen detre for making the Thakkar family first
as group and connecting this group to other groups (of other families) and
making all such four groups into another big group of parties is not only
incorrect and improper but also perverse.
The Thakkar family members did not act in concert with anyone-inter se
or intra-se. They had no business relationship with any of the parties of the
purported big group with whom they are included, bunched, bundled,
clubbed, lumped and tied to. Had there been any prior meeting of minds,
the pattern of trading would have been different, without any disconnect
and involved other dealings by Thakkar family members such as offmarket, side deal, financing etc.
Thakkar family has six trading accounts. Alleged quantity of shares and
%( percentage) of manipulative buy trades and sell trades as a % of market
volume of each party is different. Assuming but without admitting some
orders were matched, they did not result into any manipulation of price
and or volume and no economic loss was caused to anyone. Transfer of
Page 5 of 54
July 31, 2015
beneficial holding by one family member to another family member

through market mechanism is a legitimate activity.
As Thakkar family wanted to keep and hold shares of HSSL and some
members wanted monies for temporary purpose (and as SEBI rules do not
permit intra-family adjustment of debits/credits in broker's office), a few
trades were done to shift holding from one member to another member
through market mechanism. Such cross trades which involved change of
beneficial ownership (and within the family) cannot be considered
objectionable.
As far as Doshi family is concerned, the cross deals involved mostly sale
of HSSL shares by Doshi family members and purchase by Thakkar
family as investment in the said scrip. In view of the scrip being illiquid,
whenever funds were required by Thakkar family, the Doshi family either
bought shares from them or arranged buyer from their own family/circle.
There is no relationship between Thakkar and Mehta family. Mehta
family members bought shares, paid for and took deliveries. Thakkar
family members bought and sold shares when price went up and they
booked some profit. Mehta family was incidentally a buyer at the relevant
time.
Alleged cross deals of Thakkar family members involved change of
beneficial ownership when they first sold and when they later bought from
Mehta family.
The purported cross deals did not cause any adverse/negative impact nor
any aberration as they were within market price range and delivery based.
Thakkar family has not caused any material or significant impact on price
of the said scrip. As desperate buyer may offer to buy at a higher price
than the ruling market price and a desperate seller may accept little lower
price than the prevailing price, the objective in both the cases being to
ensure execution of trade and not price manipulation.
6. The salient submissions made by the Noticee No. 2, 3 and 7 in

addition to the above submissions are as under:
Mehta's were not involved in anyway in cross trades or price rigging in

HSSL scrip as alleged or otherwise. The volume of trading of Mehta
family cannot be treated as cross and or synchronized.
Alleged manipulative trade is insignificant and number of trades are very
few.
Assuming but without accepting the trade as synchronized, no fault can be
found as there was change in beneficial ownership.
Page 6 of 54
July 31, 2015
No relationship with Thakkar family members. Commercial transactions

were separate and independent.
Each of Mehta family members' trading, buying, selling and dealing and
7. The salient submissions made by the Noticee No. 10, 11 and 12 in

addition to the above submissions are as under:
Each of Doshi family members' trading, buying, selling and dealing and
In illiquid scrip if an investor holding shares of a company sees spurt in
the price on account of any event, then he may chose to sell at a higher
price on one exchange and then he may try to acquire shares back on the
same exchange or another exchange on the same day or the next day. For
that purpose he may place order at a higher price than the last traded price
or at last closing price on another exchange. This way of selling/buying
activity result into lowering of cost of holding of the investment. Hence
no manipulative intent is involved.
8. In terms of Rule 4(3) of the Rules, Noticees were granted an

opportunity of personal hearing Mr. J.J. Bhatt, Senior Advocate,
Authorized Representative of the Noticees (hereinafter referred to as
'AR') appeared for hearing on June 20, 2013 reiterated the earlier
submissions made by the Noticees in their reply and sought
additional time to file written submissions. Noticees vide letter dated
July 08, 2013 reiterated the earlier submissions. Authorized
Representative appeared for hearing on August 19, 2013, May 13,
2014, June 30, 2015 and July 08, 2015.
Page 7 of 54
July 31, 2015
9. On July 08, 2015, Mr. Rajesh Shah, Chartered Accountant appeared

on behalf of the Noticees and filed written submissions dated July
07, 2015. The Noticees inter-alia submitted the following:
a) Noticee submitted that it has filed statement of trades
of
their dealings in scrips other than HSSL and that the clients
are long standing clients who have dealt in other scrips.
b) As regards trade details in Annexure VI to the SCN, it was
submitted that in all there were 16 clients including the

Noticees who dealt in the scrip. Out of the 16 clients, 4
clients were let off by SEBI with warning. Therefore, it was
submitted that the rest of the clients i.e. Noticees are
similarly situated and hence deserved to be viewed similarly.
While referring to Annexure VI to the SCN it was pointed out
that matching time of orders are as long as 45 minutes to
more than one hour in some of the trades which means that
the orders were exposed to the market as a whole and it
would not be correct to allege that these are synchronized
trades as alleged in the SCN. In all, there were 65 trades
executed in less than 10 seconds over a period of 5 months
with about 10-12 trades in a month. If there was any
manipulative intent on the part of the Noticees, higher
volumes could have been built by the Noticees in a short
span of time and the Noticees would have exited from the
scrip of HSSL. However, no such intention is shown by the
trading behavior over a period of 5 months and all 12 clients
are holding the scrip even as on today. Therefore, it is not
the case of rising the price by manipulation and then exiting
the scrip by making unjust profit. It was further submitted that
around 80 clients have traded in the HSSL scrip and majority
are still holding including 12 Noticees.
Page 8 of 54
July 31, 2015
c) Referring to page no. 4 of reply dated July 07, 2015, it was

submitted that over a period of four financial years
commencing from 2009-10 the clients were adding on to the
stock of HSSL thereby meaning that Noticees had a long
term view in the company which is reflected by their
incremental increase in the holdings over the years.
Referring to Annexure II to the reply dated July 07, 2015, it
was submitted that the general market index had risen by
nearly 80% between April 2009 and March 2010 and the
Auto Index rose nearly by 150%. Further, the individual
stocks within the Auto sector have also shown an upward
movement ranging from 131% in the case of Kennametal to
as high as 447% in the case of WABCO. In comparison, the
increase in the price of the shares of HSSL during this period
was 108%. It was thus submitted that the price increase in
the shares of HSSL was in tandem with the market, Auto
sector and peer group companies.
d) Further the company was coming out of the losses during
the said period and there was corporate announcement in
February, 2010 with regard to acquisition of shares of
subsidiary of HSSL by a German company which has led to
an increase in the price of the scrip. It is therefore contended
that rise in price of the scrip was due to the better
performance and the positive prospects of the company
rather than manipulative intent by the Noticees.
CONSIDERATION OF ISSUES AND FINDINGS
10. I have carefully perused the written and oral submissions of the
Noticees and the documents available on record. The issues that
arise for consideration in the present case are :
Page 9 of 54
July 31, 2015
a) Whether Noticee No. 1 to 7 have violated the provisions of

Regulation 4(1), 4(2) (a) and (g) of PFUTP Regulations, 2003?
b) Whether Noticee No. 8 to 10 have violated the provisions of
the Regulation 4(1), 4(2) (a), (b),(e) and (g) of PFUTP
Regulations, 2003?
c) Whether
Noticee No. 11 to 12 have violated provisions of
Regulation 4(1)(2)(e)of PFUTP Regulations, 2003?

d) Does the violation, if any, on the part of the Noticees attract
any penalty under section 15HA of the SEBI Act, 1992?
e) If yes, what should be the quantum of penalty?
11. The relevant regulations of PFUTP Regulations, 2003 are stated as

under:
PFUTP Regulations, 2003
4. Prohibition of manipulative, fraudulent and unfair trade practices
(1) Without prejudice to the provisions of regulation 3, no person shall indulge in
a fraudulent or an unfair trade practice in securities.
(2) Dealing in securities shall be deemed to be a fraudulent or an unfair trade
practice if it involves fraud and may include all or any of the following, namely:
(a) indulging in an act which creates false or misleading appearance of
trading in the securities market;
(b) dealing in a security not intended to effect transfer of beneficial
ownership but intended to operate only as a device to inflate, depress or
cause fluctuations in the price of such security for wrongful gain or
avoidance of loss;
(c) .
(d)
(e) any act or omission amounting to manipulation of the price of
security;
Page 10 of 54
July 31, 2015
(f) .
(g) entering into a transaction in securities without intention of performing it
or without intention of change of ownership of such security;
12. I find that the Noticees dealt significantly in the scrip of HSSL
through ASB, sub broker of SVS. All the Noticees were introduced
for trading by Mr. Yogesh R Doshi (Noticee No. 10) and Mr. Ballabh
Dagri, Directors of ASB. Noticee No. 10 besides being Director and
introducer has also traded in the scrip of HSSL.
13. The relevant period was divided into three phases: phase 1 from
November 03, 2009 to November 19, 2009, phase 2 from November
20, 2009 to February 18, 2010 and phase 3 from February 19, 2010
to March 31, 2010.
14. At BSE, during phase 1, the price of the scrip opened at ` 48.55 on
November 03, 2009 and closed at ` 76.3 on November 19, 2009 i.e.
an increase of 57.15% within a span of 17 days. During phase 2, the
price of the scrip opened at ` 75 on November 20, 2009 and closed
at ` 76.4 on February 18, 2010. Further, during phase 3, the price of
the scrip opened at ` 77.5 on February 19, 2010 and closed at `
100.05 on March 31, 2010 i.e. an increase of 29.09% within a span
of 41 days.
15. At NSE during phase 1 the price of the scrip opened at ` 51.9 on
November 03, 2009 and closed at ` 76.15 on November 19, 2009
i.e. an increase of 46.72% within a span of 17 days. During phase 2
the price of the scrip opened at ` 75 on November 20, 2009 and
closed at ` 76.35 on February 18, 2010. During the phase 3 the
price of the scrip opened at ` 74.4 on February 19, 2010 and closed
Page 11 of 54
July 31, 2015
at ` 108.95 on March 31, 2010 i.e. an increase of 46.43% within a

span of 41 days.
16. It was alleged that two trading members namely SVS and Pune E
Stock Broking Pvt. Ltd.( hereinafter referred to as PSB) contributed
significantly in the buy and sell side of the transaction at BSE in the
scrip of HSSL. The combined contribution of the two trading
members in the buy side was 5,36,223 shares accounting for
68.55% of the total volume traded during the relevant period. The
combined contribution of the two trading members in the sell side
was 4,68,538 shares accounting for 59.90% of the total volume
traded during the relevant period.
17. At NSE, the contribution of SVS in the buy side was 3,69,974 shares
accounting for 76.92% of the total volume traded during the relevant
period. The contribution of SVS in the sell side was 3,48,143 shares
accounting for 72.38% of the total volume traded during the relevant
period.
18. The Noticees belong to 3 families viz. Thakkar, Mehta & Doshi
families. All the 3 families reside in Ghatkopar area and traded
through the common sub broker ASB. Also the directors of the ASB,
Noticee No. 10 and Mr. Ballabh Dagri had introduced the Noticees
to the broker SVS. Further, Noticee No. 10 Director of ASB had also
traded in the scrip in the relevant period besides being the
introducer of all the remaining Noticees. The relationship among the
Noticees is given below:
Page 12 of 54
July 31, 2015
S.No.
1
Noticee
Introducer
Relationship
detail
with others
Floor
Nand Yogesh
R Priya
Dhaval
Priya
Dhaval 2nd
Thakkar (PDT)
Ashish,r.b.mehata
Doshi
Thakkar is the
Marg,ghatkopar(east),
wife of Dhaval
Mumbai, Maharashtra,
Arjun Thakkar
India, 400077
Mahesh
Dhanvantrai
Mehta (MDM)
Address of the Entity
A-3, Janak Kutir, Plot

No 92, Vallabhbaug
Lane, Ghatkopar (east),
India, 400077
Nikunj
A-3, Janak Kutir, Plot
Dhanvantrai
No 92, Vallabhbaug
Mehta (NDM)
India, 400077
Amita
Nitesh 1101
Kailash
Thakkar (ANT)
Palace,upashraya
Lane,ghatkopar(east),
India, 400077
Fenil
Nitesh
Thakkar (FNT)
Nitesh
Thakkar
(NTH)
Madhukanta
Dhanvantrai
Mehta (MD)
Nitesh
Arjun
Thakkar (NAT)
Arjun
Huf
Yogesh
Doshi
R Brother of Nikunj
and
son
of
Madhukanta
Yogesh
Doshi
R Brother
of
Mahesh and son
of Madhukanta
Yogesh
Doshi
R Nitesh
Arjun
Thakkar is the
husband of Amita
Nitesh Thakkar.
Fenil
Nitesh
Thakkar is the son
of
Amita
Thakkar.
1101
Kailash Ballabh Bagri
As
explained
Palace,upashraya
above
India, 400077
1101
Kailash Yogesh
R As
explained
Palace,upashraya
Doshi
above
India, 400077
A-3, Janak Kutir, Plot Yogesh
R Mother of Nikunj
No 92, Vallabhbaug Doshi
Dhanvantrai
Mehta
and
Mahesh
India, 400077
Dhanvantrai
Mehta
6,nilkanth,jethabhai
Yogesh
R Nitesh
Arjun
Lane,rajawadi.ghatkopar Doshi
Thakkar is the
(e),
Mumbai,
husband of Amita
Maharashtra,
India,
Nitesh Thakkar,
Page 13 of 54
July 31, 2015
400077
Dhaval
Arjun 2nd
Floor
Nand Yogesh
Thakkar (DAT)
Ashish,r.b.mehata
Doshi
Marg,ghatkopar(east),
India, 400077
10
4,anand
Kutir,,cama Sanjay Shah
Yogeshkumar
Rasiklal
Doshi Lane,,hansoti
(YRD)
Lane,ghatkopar(w),
India, 400086
11
Darshana Yogesh 4,anand

Kutir,,cama Yogesh
Doshi(DYD)
Lane,,hansoti
Doshi
Lane,ghatkopar(w),
India, 400086
12
Mitali
Yogesh 4,anand
Kutir,,cama Yogesh
Doshi (MYD)
Lane,,hansoti
Doshi
Lane,ghatkopar(w),
India, 400086
father of Fenil
Nitesh Thakkar
and brother of
Dhava
Arjun
Thakkar.
R Dhaval
ArjunThakkar is
the husband of
Priya
Arjun
Thakkar
and
brother of Nitesh
Thakkar
Director
of
Aquarian Share
Broking Co.Ltd. ,
sub-broker
and
common
introducer
of
other Noticees
R Wife of Yogesh R
Doshi and mother
of Mitali Yogesh
Doshi
R As
above
19. Noticee Nos. 1, 4, 5, 6, 8, 9 are from the same family. Further,

except Noticee No. 5 all other members of Thakkar family were
introduced to the broker SVS by Noticee No. 10, who was director of
ABSCPL. Noticee Nos. 10, 11 and 12 are from the same family.
Noticee Nos. 2, 3 and 7 are from the same family.
Trading at BSE
20. By dealing on behalf of the Noticees, ASB at BSE, purchased
320591 shares and sold 2,95,315 shares which constitutes 41% of
the total buy and 36% of the total sale volume in the scrip during the
Page 14 of 54
July 31, 2015
explained
relevant period.
Further, details of purchase and sale by the
Noticees is as follows:
Client
Total
Name
buy
Noticee
No.1
54736
Noticee
No.2
21985
Noticee
No.3
45997
Noticee
No.4
50472
Noticee
No.5
10035
Noticee
No.6
15503
Noticee
No.7
1036
Noticee
No.8
31217
Noticee
No.9
26139
Noticee
No.10
50567
Noticee
No.11
8017
Noticee
No,12
4887
Total
320591
%
traded
within
the
Total
Noticees sale
%of
total
volume
traded
sale
within
the
Noticees
%
traded
within
the
Noticees
75900
9.70
71226
93.84
94.13
7900
1.01
7900
100.00
44398
96.52
6500
0.83
6500
100.00
6.45
48350
95.80
38918
4.98
36156
92.90
1.28
10000
99.65
10200
1.30
10000
98.04
1.98
14040
90.56
22505
2.88
22505
100.00
0.13
550
53.09
20000
2.56
20000
100.00
3.99
22181
71.05
42981
5.49
38201
88.88
3.34
18856
72.14
19341
2.47
17864
92.36
6.46
10784
21.33
32257
4.12
14463
44.84
1.02
0.00
0.00
1950
0.25
1000
51.28
%of
total
volume
traded
buy
within
the
Noticees
7.00
52333
95.61
2.81
20695
5.88
0.62
40.98
0.00
242187
0.00
75.54
3444
281896
0.44
36.03
2454
248269
71.25
88.07
21. From the above table, it is observed that 242187 shares (75.54%)
constituted the total buy of the group and 281896 shares (88.07%)
of the total sale of the group were executed among the Noticees.
Out of the 110 trades entered into by the major clients for 69 trades
accounting for 1,82,747 shares (23.36% of the total volume traded)
the buy and sell orders were placed within time difference of less
than 1 minute. Further, there were 46 cross trades i.e. where the
buy and sell orders were executed by the same broker among the
Noticees which accounted for 1,20,091 shares during 20 days
Page 15 of 54
July 31, 2015
(15.35% of the total volume traded). The buy and sell orders were
placed in perfectly synchronized manner i.e. the quantity, price and
time were exactly the same.
22. On the 20 days during the relevant period i.e. November 04, 2009,
November 19, 2009, November 20, 2009. November 23, 2009,
December 15, 2009, December 21, 2009, December 29, 2009,
January 07, 2010, January 08, 2010, January 12, 2010, January 13,
2010, January 14, 2010, January 18, 2010, February 26, 2010,
March 09, 2010, March 10, 2010, March 11, 2010, March 15, 2010,
March 17, 2010 and March 18, 2010 when the Noticees entered into
synchronized trades among themselves, the percentage of the
group volume contribution to the volume traded of the day was upto
74%. The volume traded during the 20 trading days contributed by
the Noticees by entering into synchronized trading was 36.26%.
Moreover, 1,18,194 shares were traded among the Thakkar family
alone.
23. During the relevant period, SVS through sub-broker ASB dealing on
behalf of 71 clients purchased 3,84,823 shares (49.20% of the total
market volume) and sold 3,17,138 shares (40.54% of the total
market volume) respectively. Further, it was also observed that SVS
dealing for the aforesaid 71 clients executed 268 cross deals
contributing 2,78,836 shares, accounting for 35.64% of the total
market volume during the period. Further, for 118 out of 268 cross
deals contributing total volume of 1,82,991 shares accounting for
23.39% of the total volume traded during the period, the buy and sell
orders were placed within time difference of less than or equal to
one minute only. Out of the 118 cross deals mentioned above 61
cross deals contributing 1,22,864 shares accounting for 15.70% of
the total volume traded during the relevant period, the buy and sell
Page 16 of 54
July 31, 2015
orders were placed in synchronized manner wherein the order time,

quantity and price were matched.
24. During the first phase of relevant period the price of the scrip
opened at `48.55 and touched a high of ` 81.65, i.e. there was
increase of ` 33.10 which is about 68.1% of the price rise. It was
observed that on 13 trading days and on 22 occasions a new high
price was discovered. Further, out of 22 occasions, on 20 occasions
(on 10 out of 13 trading days), Noticees contributed to an increase
of ` 29.85 (out of ` 33.10) which is about 61.48% of the price rise.
Only on 2 occasions Noticees were counterparties contributing to a
price rise of ` 4.80. There was no significant change in the economic
fundamental of the scrip of HSSL during the
relevant period
justifying the price rise.

25. The dealings of the Noticees which influenced price of the scrip are
as follows:
Major
SVS
Client
Noticee
No.8
Noticee
No.10
Noticee
No.11
Noticee
No.12
Grand
Total
Noof
trades
above
LTP
Influence
onprice
Noof
trades
below
LTP
Influence
onprice
Net
impact
6.35
0.05
6.3
15
22.05
12.65
9.4
6.35
10.95
11
10.3
5
0
7.55
0
2.75
5.65
3.85
16.3
16.3
7.65
34.75
14
12
22.45
35
55 15
20.25
Noof
No
1st
influence of
Influence
trades onprice
NDP onprice
0
0
0
0
26. From the above table, it is observed that Noticee No. 10, 11 and 12
mainly influenced the price rise of the scrip at BSE during the first
phase of relevant period by placing buy orders at a price above LTP
thereby creating artificial volume and price hike. Noticees increased
the price by ` 92.3(resulted out of 29 cross deals cum synchronized
Page 17 of 54
July 31, 2015
trades) at BSE in the aforesaid manner.
Noticees have created
artificial demand for the scrip of HSSL by placing buy orders

successively at higher rates than the LTP which scrip was available
at lower prices.
Trading at NSE
27. By dealing on behalf of Noticees, ASB purchased 3,03,056 shares
and sold 3,23,200 shares at NSE which constituted 63% of the total
buy and 67.19% of the total sell volume. The details of purchase and
sale by the Noticees dealing through SVS are as follows:
Client
Name
Noticee
No.1
Noticee
No. 2
Noticee
No. 3
Noticee
No. 4
Noticee
No. 5
Noticee
No. 6
Noticee
No. 7
Noticee
No. 8
Noticee
No. 9
Noticee
No. 10
Noticee
No. 11
Noticee
No. 12
Total
% of
the
total
volume
Within
the
Noticees
%
trading
within
Noticees
% of
the
total
volume
sale
within
the
Noticees
%
trading
within
Noticees
75728
15.74
71700
94.68
53564
11.14
50406
94.10
25215
5.24
24547
97.35
37100
7.71
35758
96.38
1203
0.25
343
28.51
36500
7.59
36000
98.63
23529
4.89
22361
95.04
34489
7.17
32750
94.96
10165
2.11
10000
98.38
10000
2.08
10000
100.00
23102
4.80
23102
100.00
15800
3.28
15800
100.00
45964
9.56
43600
94.86
22800
4.74
22800
100.00
34509
7.17
31942
92.56
16495
3.43
13956
84.61
31950
6.64
20086
62.87
34945
7.26
25599
73.26
28724
5.97
17828
62.07
48730
10.13
32625
66.95
675
0.14
0.00
0.00
8992
1.87
6976
77.58
2292
303056
0.48
63
0.00
265509
0.00
87.6
3785
323200
0.79
67.19
3065
285735
80.98
88.4
Total
Buy
Total
sale
28. From the above table, it is observed that 265509 shares (87.6%)
constituted the total buy of the group and 285735 shares (88.4%) of
the total sale of the group were executed among the Noticees. Out
Page 18 of 54
July 31, 2015
of the 282 trades entered into by the major clients, for 134 trades
accounting for 2,31,142 shares (48.05% of the total volume) the buy
and sell orders were placed within time difference of less than 1
minute. Further, for 76 cross deals among the entities accounting for
1,89,549 shares resulting out of 76 buy orders and 76 sell orders
during 27 days (39.40% of the total volume) the buy and sell orders
were placed in a synchronized manner wherein the order time,
quantity and price were matched.
29. On the 27 days during the relevant period i.e. November 04, 2009,
November 05, 2009, November 06, 2009, November 16, 2009,
December 02, 2009, December 15, 2009, December 22, 2009,
December 29, 2009, January 06, 2010, January 11, 2010, January
13, 2010, January 15, 2010, January 18, 2010, February 03, 2010,
February 04, 2010, February 26, 2010, March 10, 2010, March 11,
2010, March 15, 2010, March 18, 2010, March 19, 2010 when the
Noticees entered into synchronized trades among themselves,
percentage of the group volume contribution to the total volume
traded of the day was upto 100% on some days. The volume traded
during the 27 trading days contributed by the Noticees by entering
into synchronized trading was as high as 57.49%. Moreover, 44,062
shares were traded among the Thakkar family during the relevant
period.
30. During the relevant period, SVS through sub-broker ASB dealing on
behalf of 58 clients purchased 3,69,974 shares (76.92% of the total
market volume) and sold 3,48,143 shares (72.38% of the total
market volume) respectively. Further, it was also observed that SVS
dealing for the aforesaid 58 clients executed 622 cross deals
Page 19 of 54
July 31, 2015
contributing 3,17,253 shares, accounting for 65.95% of the total

market volume during the period. Further, for 202 out of 622 cross
deals contributing total volume of 2,41,715 shares accounting for
50.25% of the total volume traded during the period, the buy and
sale orders were placed within time difference of less than or equal
to one minute only. Out of the 202 cross deals, for 98 cross deals
contributing 1,94,405 shares accounting for 40.41% of the total
volume traded during the relevant period, the buy and sale orders
were placed in perfectly synchronized manner wherein the order
time quantity and price were matched.
31. During the first phase of relevant period the price of the scrip
opened at ` 51.90 and touched a high of ` 83.25, i.e. there was
increase of ` 31.35 constituting 60.4% of the price rise. On 13
trading days and 20 occasions a new high price was discovered. On
all the 20 occasions (on 12 days out of 13 trading days), Noticees
contributed to an increase of ` 31.35 (out of ` 31.35) i.e. 100% of
the price rise.
32. The analysis of the tables given as trade log and order log reveals
the following about the trades in HSSL shares conducted through
sub broker ASB of broker SVS:
a.
Trades of Priya Dhaval Thakkar (PDT) Noticee 1

It is observed that at 10:00:19 on 21.12.2009, Priya Dhaval
Thakkar (PDT) put in a buy order at BSE for 10,000 shares
of HSSL @ ` 68.45. At 10:01:13 on 21.12.2009, PDT put in
another buy order for 4,000 shares of HSSL @ ` 68.45. At
10:01:25, her husband, Dhaval Arjun Thakkar (DAT) placed
a sell order for 14,000 HSSL shares @ ` 68.45 which was
matched and executed at 10:01:26 for 10,000 shares. The
time gap between purchase and sale order was 00:01:06
Page 20 of 54
July 31, 2015
and 00:00:12 respectively and can be considered as

synchronized. Further, this was a cross trade in the office of
ASB. The overall order quantity and price was matching
between the related buying and selling entities.
It is also observed that at 10:27:28 on 21.12.2009, PDT
placed a buy order at BSE for 4,800 shares @ ` 68.45. At
10:27:29, her husbands brother, Nitesh Arjun Thakkar
(NAT) entered a buy order for 4800 HSSL shares @ ` 68.45.
The said orders matched with each other and were executed
for 4800 shares. It was a synchronized trade as the time gap
between purchase and sale order was 2 seconds. The order
quantity and price was matching between the buying and
selling entities and it was a cross trade.
b.
Trades of Mahesh Dhanvantrai Mehta-MDM-Noticee-2

It is observed that at 09:14:26 on 07.01.2010, Dhaval Arjun
Thakkar placed a buy order at BSE for 7,900 shares @
` 71.70. At 09:14:27, MDM entered a sell order for 7900
shares @ ` 71.70. The said orders matched with each other
and were executed for 7,900 shares at 09:14:27. It was a
synchronized trade as the time gap between purchase and
sale order was 1 second. The order quantity and price was
matching between the buying and selling entities and it was
a cross trade.
c.
Trades of Nikunj Dhanvantrai Mehta-NDM-Noticee-3

It is observed that at 09:19:10 on January 12, 2010, PDT
placed a sell order at BSE for 25,000 shares @ ` 84.5. The
last traded price was ` 80.5. At 09:19:11 on January 12,
Page 21 of 54
July 31, 2015
2010, NDM placed a matching buy order at BSE for 25,000

shares @ `84.5. It was a synchronized trade as the time gap
between purchase and sale order was 1 second. The order
quantity and price was matching between the buying and
selling entities and it was a cross trade.
It is observed that at 09:15:31 on January 13, 2010, NAT
placed a buy order at BSE for 6,500 shares @ ` 73.05. At
09:15:32 on January 13, 2010, NDM placed a matching sell
order at BSE for 6500 shares @ ` 73.05. . It was a
sale order was 1 second. The order quantity and price was
a cross trade.
d.
Trades of Amita Nitesh Thakkar ANT-Noticee No. 4

It is observed that at 10:20:17 on December 21, 2009, ANT
placed a buy order at BSE of 4,000 shares @ ` 69. The last
traded price was ` 68.5.
At 10:20:19 on December 21,
2009, NAT placed a matching sell order of 4,000 shares @

` 69. It was a synchronized trade as the time gap between
purchase and sale order was 1second. The order quantity
and price was matching between the buying and selling
entities and it was a cross trade.
e.
Trades of Fenil Nitesh Thakkar-FNT-Noticee No.5

Further, FNT at 10:10:16 on December 29, 2009 placed a
sell order of 10,000 shares at BSE@ ` 71.95. At 10:10:21
on December 29, 2009, ANT placed a matching buy order of
10,000 shares @ ` 71.95. It was a synchronized trade as
the time gap between purchase and sale order was 5
seconds. The order quantity and price was matching
between the buying and selling entities and it was a cross
trade.
Page 22 of 54
July 31, 2015
f.
Trades of Nitesh Arjun Thakkar (HUF)-NTH-Noticee No.6

It is observed that at 14:25:47 on March 18, 2010, NTH
placed a buy order of 3,000 shares at BSE @ ` 105.95. The
last traded price was ` 104.05. At 14:25:48 on March 18,
2010, NAT placed a matching order @ ` 105.95. NAT is a
director of NTH. It was a synchronized trade as the time gap
between purchase and sale order was 10 seconds. The
order quantity and price was matching between the buying
and selling entities and it was a cross trade.
g.
Trades of Madhukanta Dhanvantrai Mehta MDMNoticee No. 7

It is observed that at 10:05:53 on December 29, 2009, FNT
placed a buy order of 10,000 shares at BSE @ ` 68. At
10:05:57 on December 29, 2009, MDM placed a sell order of
20,000 shares @ ` 68. It is observed that within a time gap
of 4 seconds the order for 10,000 shares were synchronized.
h.
Trades of Nitesh Arjun Thakkar NAT-Noticee No. 8

It is observed that at 10:41:16 on November 19, 2009,
Darshana Yogesh Doshi (DYD) placed a sell order of 250
shares at BSE @ ` 81.35.
The last traded price was
` 80.95. At 10:41:20 November 19, 2009, NAT placed a

matching buy order of 250 shares @ ` 81.35. It was a
sale order was 4 seconds. The order quantity and price was
a cross trade.
It is observed that at 10:20:17 on December 21, 2009 ANT
placed a buy order at BSE of 4,000 shares @ ` 69.
At
10:20:19 on December 21, 2009, NAT placed a matching

sell order of 4,000 shares @ ` 69. It was a synchronized
Page 23 of 54
July 31, 2015
trade as the time gap between purchase and sale order was
2 seconds. The order quantity and price was matching
trade.
i.
Trades of Dhaval Arjun Thakkar-DAT-Noticee No.9

It is observed that at 14:58:04 on November 05, 2009, a sell
order was placed at NSE by MYD for 500 shares@ ` 57. At
14:58:13 on November 05, 2009, a matching buy order of
500 shares @ ` 57 was placed by DAT. The LTP was `
51.75. It was a synchronized trade as the time gap between
purchase and sale order was 9 seconds. The order quantity
It is observed that at 11:18:52 on November 16, 2009, a sell
order was placed at NSE by YRD for 1225 shares @ ` 72.4.
At 11:19:02 on November 16, 2009, a matching buy order
was placed by DAT @ ` 72.4. The LTP was ` 69. It was a
sale order was 9 seconds. The order quantity and price was
a cross trade.
It is observed that at 09:01:32 on February 26, 2010, YRD
placed a buy order of 2,500 shares @ ` 80.55. At 09:01:35
on February 26, 2010 a matching sell order of 2,500 shares
@ ` 80.55 was placed by DAT. It was a synchronized trade
as the time gap between purchase and sale order was 3
seconds. The order quantity and price was matching
trade.
Page 24 of 54
July 31, 2015
It is observed that at 09:14:26 on January 07, 2010, DAT

placed buy order at BSE of 7,900 shares @ ` 71.7. At
09:14:27 on January 07, 2010 a matching sell order 7,900
shares @ ` 71.7 was placed by MDM. It was a synchronized
1 second. The order quantity and price was matching
trade.
j.
Trades of Yogesh Rasiklal Doshi-YRD-Noticee No. 10

It is observed that at 11:04:17 on December 15, 2009, DAT
placed a sell order at BSE of 1164 shares @ ` 73. At
11:04:23 on December 15, 2009, YRD placed a buy order
of 1164 shares @ ` 73. The Last Traded Price was ` 72. It
was a synchronized trade as the time gap between purchase
and sale order was 6 seconds. The order quantity and price
was matching between the buying and selling entities and it
was a cross trade.
It is observed that at 11:37:16 on November 23, 2009, YRD
placed a sell order at BSE of 100 shares @ ` 78.95. At
11:37:20 on November 23, 2009, NAT placed a matching
buy order of 100 shares @ ` 78.95. The Last Traded
Price was ` 76.5. It was a synchronized trade as the time
gap between purchase and sale order was 4 seconds. The
It is observed that at 13:22:33 on November 19, 2009, YRD
placed a sell order at NSE of 500 shares @ ` 83.15. At
13:22:39 NAT placed a buy order of 500 shares @` 83.15.
It was a synchronized trade as the time gap between
purchase and sale order was 6 seconds. The order quantity
Page 25 of 54
July 31, 2015

k.
Trades of Darshana Yogesh Doshi-DYD-Noticee No. 11

It is observed that at 10:41:04 on November 19, 2009, DYD
buy order of 250 shares @ ` 80.95. The LTP was ` 75. It
was a cross trade.
It is observed that at 10:10:22 on November 19, 2009, DYD
placed a sell order at NSE of 300 shares @` 82.95. At
buy order of 300 shares @` 82.95. It was a synchronized
5 seconds. The order quantity and price was matching
trade.
l.
Trades of Mitali Yogesh Doshi-MYD-Noticee No. 12

It is observed that at 13:01:58 on March 15, 2010, MYD
13:02:01 on March 15, 2010, NAT placed a matching buy
order of 100 shares @` 107.2. The LTP was ` 103.55. It
was a cross trade.
Page 26 of 54
July 31, 2015
It is observed that at 14:58:46 on November 05, 2009, MYD

placed a sell order at NSE of 500 shares @` 57. At 14:58:52
on November 05, 2009, NAT placed a matching buy order of
500 shares @ ` 57. It was a synchronized trade as the time
gap between purchase and sale order was 6 seconds. The
33. It is observed that 70 clients traded at BSE and 58 clients traded at

NSE. Out of 70 clients and 58 clients at BSE and NSE respectively,
the trades of 12 clients i.e. Noticees were synchronized in terms of
order, time, quantity and price.
34. I find that Noticee No. 1-6 contributed significantly to creation of

artificial volume by indulging in synchronized trades amongst
themselves at both BSE and NSE. Noticee No. 1-6 bought 1,30,806
shares at BSE. There were a total of 15 instances of cross deals
which were almost perfectly synchronized in terms of quantity, time
and price amongst the members of the group. Following are the
aforementioned instances:
Trade
Date
ClientName
CPClientName
LTP
23Nov09
21Dec09
21Dec09
21Dec09
21Dec09
AMITA
NITESH
THAKKAR
AMITA
NITESH
THAKKAR
AMITA
NITESH
THAKKAR
AMITA
NITESH
THAKKAR
PRIYA
DHAWAL
Diff
BuyOrd
Time
saleOrd
Time
time
Diff
buy
Ord
Price
sale
Ord
Price
buy
price ord
diff
Qty
sale
ord
qty
qty
diff
YOGESHKUMAR
RASIKLAL
75.80 0.00 DOSHI
15:49:16 15:49:10 0:00:06
75.8
75.8
NITESHARJUN
68.45 0.05 THAKKAR
10:01:46 10:02:15 0:00:28
68.45
68.5
NITESHARJUN
68.50 0.00 THAKKAR
10:02:31 10:02:36 0:00:05
68.5
68.5
4000
4000
10:20:17 10:20:19 0:00:01
69
69
4000
4000
10:27:28 10:27:29 0:00:02
68.45
68.45
4800
4800
NITESHARJUN
68.50 0.50 THAKKAR
NITESHARJUN
69.00 0.55 THAKKAR
37
0.05 20000 20000
Page 27 of 54
July 31, 2015
37
29Dec09
29Dec09
31Dec09
8Jan10
12Jan10
12Jan10
3Feb10
9Mar10
11Mar10
18Mar10
THAKKAR
AMITA
NITESH
THAKKAR
AMITA
NITESH
THAKKAR
PRIYA
DHAWAL
THAKKAR
PRIYA
DHAWAL
THAKKAR
NIKUNJ
DHANVANTR
AIMEHTA
NIKUNJ
DHANVANTR
AIMEHTA
PRIYA
DHAWAL
THAKKAR
AMITA
NITESH
THAKKAR
PRIYA
DHAWAL
THAKKAR
NITESH
ARJUN
THAKKAR
HUF
NITESHARJUN
68.00 3.95 THAKKARHUF
10:10:01 10:09:47 0:00:14
71.95
71.95
0 10000 10000
FENILNITESH
71.95 0.00 THAKKAR
10:10:21 10:10:16 0:00:05
71.95
71.95
0 10000 10000
AMITANITESH
74.00 0.50 THAKKAR
10:05:50
9:55:06 0:10:45
74.5
77
2.5 20000 20000
AMITANITESH
77.90 2.20 THAKKAR
13:49:38 13:49:47 0:00:09
75.7
75.7
0 11708 11708
PRIYADHAWAL
80.50 4.00 THAKKAR
9:19:11
9:19:10 0:00:01
84.5
84.5
0 25000 25000
9:19:40
9:19:40 0:00:01
84.5
84.5
0 18000 18000
10:19:35 12:17:15 1:57:40
76.75
PRIYADHAWAL
84.50 0.00 THAKKAR
YOGESHKUMAR
RASIKLAL
79.00 2.00 DOSHI
YOGESHKUMAR
RASIKLAL
105.75 0.00 DOSHI
81
4.25
250
250
13:38:24 13:38:20 0:00:04 105.75 105.75
MITALIYOGESH
106.00 1.90 DOSHI
13:50:19 13:50:12 0:00:07
107.9
NITESHARJUN
104.05 1.00 THAKKAR
14:24:48 14:24:58 0:00:10 103.05 103.05
3000
3000
107.9
35. Similarly Noticee No. 1-6 sold 1,19,039 shares at BSE . There were
a total of 13 instances of cross deals which were almost perfectly
synchronized in terms of quantity, time and price amongst the
members of the group. Following are the aforementioned instances:
Trade
Date
21
Dec
09
29
Dec
09
29
Dec
09
31
Dec
09
7
ClientName
NITESHARJUN
THAKKAR
CPClient
Name
LTP
Diff
PRIYA
DHAWAL
74.95 0.05 THAKKAR
BuyOrd
Time
saleOrd
Time
time
Diff
buy
Ord
Price
sale
Ord
Price
11:08:58 11:08:53 0:00:05
74.9
74.9
buy
price ord
diff
Qty
4000
sale
ord
qty
qty
diff
4000
AMITANITESH
THAKKAR
NITESHARJUN
10:10:01 10:09:47 0:00:14
71.95
71.95
0 10000 10000
AMITANITESH
THAKKAR
PRIYA
DHAWAL
THAKKAR
DHAWAL
FENILNITESH
71.95 0.00 THAKKAR
10:10:21 10:10:16 0:00:05
71.95
71.95
0 10000 10000
AMITANITESH
74.00 0.50 THAKKAR
72.05
MAHESH
10:05:50
9:14:26
74.5
71.7
77
71.7
2.5 20000 20000

0 7900 7900
0
0
9:55:06 0:10:45
9:14:27 0:00:01
Page 28 of 54
July 31, 2015
Jan
10
8
Jan
10
12
Jan
10
12
Jan
10
13
Jan
10
14
Jan
10
18
Jan
10
18
Mar
10
25
Mar
10
ARJUN
THAKKAR
PRIYA
DHAWAL
THAKKAR
NIKUNJ
DHANVANTRAI
MEHTA
NIKUNJ
DHANVANTRAI
MEHTA
NITESHARJUN
THAKKAR
YOGESHKUMAR
RASIKLAL
DOSHI
YOGESHKUMAR
RASIKLAL
DOSHI
NITESHARJUN
THAKKAR
DHAWAL
ARJUN
THAKKAR
0.35 DHANVANTRAI
MEHTA
AMITANITESH
77.90 2.20 THAKKAR
13:49:38 13:49:47 0:00:09
PRIYA
DHAWAL
80.50 4.00 THAKKAR
9:19:11
9:19:10 0:00:01
PRIYA
DHAWAL
84.50 0.00 THAKKAR
9:19:40
9:19:40 0:00:01
NIKUNJ
DHANVANTRAI
77.55 4.50 MEHTA
9:15:31
9:15:32 0:00:01
PRIYA
DHAWAL
74.10 0.90 THAKKAR
9:05:40
9:05:44 0:00:03
AMITANITESH
85.35 7.90 THAKKAR
NITESHARJUN
PRIYA
DHAWAL
105.00 0.80 THAKKAR
75.7
75.7
0 11708 11708
84.5
84.5
0 25000 25000
84.5
84.5
0 18000 18000
73.05
73.05
6500
6500
75
75
250
250
77.45
77.45
2500
2500
14:25:48 14:25:47 0:00:01 105.95 105.95
3000
3000
10:41:23 10:18:27 0:22:57
181
181
11:00:46 11:00:51
0:00:05
104.2
104.2
36. At NSE, Noticee No. 1-6 bought 97,222 shares. There were a total
of 26 instances of cross deals which were almost perfectly
members of the group. Some of the instances are mentioned below:
Trade
Date
Client
Name
29Dec09
29Dec09
29Dec09
6Jan10
6Jan10
6Jan10
CPClient
Name
LTP
NITESH
A.THAKKAR
PRIYA
DHAVAL
THAKKAR
PRIYA
DHAVAL
THAKKAR
PRIYA
DHAVAL
THAKKAR
PRIYA
DHAVAL
THAKKAR
PRIYA
Diff
BuyOrd
Time
saleOrd
Time
time
Diff
buy
Ord
Price
sale
Ord
Price
buy
price ord
diff
Qty
sale
ord
qty
qty
diff
MADHUKANTA
DHANVANTRAI
67.05 1.10 MEHTA
10:06:39 10:06:53 0:00:14 68.15 68.15
0.00
2800
NITESH
68.15 2.80 A.THAKKAR
10:08:54 10:08:46 0:00:08 70.95 70.95
0.00 12800 12800
70.95
0.00 10000 10000
71.70
0.00 10000 10000
71.70
71.70
0.00 10000 10000

0.00 10000 10000
0
0
FENILNITESH
70.95 0.00 THAKKAR
10:09:26 10:09:20 0:00:06 70.95
MAHESH
DHANVANTRAI
72.00 0.30 MEHTA
10:54:08 10:54:15 0:00:07 71.70
MAHESH
DHANVANTRAI
71.70 0.00 MEHTA
10:54:08 10:55:10 0:01:02 71.70
71.70 0.00 MAHESH
10:55:05 10:55:10 0:00:05 71.70
Page 29 of 54
July 31, 2015
2800
6Jan10
6Jan10
6Jan10
6Jan10
6Jan10
DHAVAL
THAKKAR
PRIYA
DHAVAL
THAKKAR
AMITA
NITESH
THAKKAR
AMITA
NITESH
THAKKAR
AMITA
NITESH
THAKKAR
AMITA
NITESH
THAKKAR
71.70 0.00
71.70 0.00
71.70 0.00
71.70 0.00
71.70 0.00
DHANVANTRAI
MEHTA
MAHESH
DHANVANTRAI
MEHTA
MAHESH
DHANVANTRAI
MEHTA
MAHESH
DHANVANTRAI
MEHTA
MAHESH
DHANVANTRAI
MEHTA
MAHESH
DHANVANTRAI
MEHTA
10:55:41 10:55:46 0:00:05 71.70 71.70
0.00
4000
4000
10:56:30 10:56:34 0:00:04 71.70 71.70
0.00
2500
2500
10:56:30 10:57:28 0:00:58 71.70 71.70
0.00
10:58:32 10:58:36 0:00:04 71.70 71.70
0.00
2500
2500
10:59:12 10:59:16 0:00:04 71.70 71.70
0.00
1500
1500
qty
diff
37. At NSE, Noticee No. 1-6 sold 1,50,677 shares. There were a total of
25 instances of cross deals which were almost perfectly
Trade
Date
ClientName
LTP
MADHUKANTA
22Dec DHANVANTRAI
09 MEHTA
MADHUKANTA
22Dec DHANVANTRAI
09 MEHTA
PRIYA
29Dec DHAVAL
09 THAKKAR
PRIYA
29Dec DHAVAL
09 THAKKAR
6Jan PRIYADHAVAL
10 THAKKAR
6Jan PRIYADHAVAL
10 THAKKAR
6Jan PRIYADHAVAL
10 THAKKAR
6Jan
10
6Jan
10
PRIYADHAVAL
THAKKAR
AMITANITESH
THAKKAR
Diff
CPClient
Name
BuyOrd
Time
saleOrd
Time
time
Diff
buy
Ord
Price
sale
Ord
Price
buy
price ord
diff
Qty
sale
ord
qty
AMITANITESH
72.55 4.40 THAKKAR
14:35:45 14:35:43
0:00:02
76.95
76.95
0.00
28000
28000
PRIYADHAVAL
76.95 0.00 THAKKAR
14:36:13 14:36:12
0:00:01
76.95
76.95
0.00
14800
14800
NITESH
68.15 2.80 A.THAKKAR
10:08:54 10:08:46 0:00:08
70.95
70.95
0.00
12800
12800
10:09:26 10:09:20 0:00:06
70.95
70.95
0.00
10000
10000
10:54:08 10:54:15
0:00:07
71.70
71.70
0.00
10000
10000
10:54:08 10:55:10
0:01:02
71.70
71.70
0.00
10000
10000
10:55:05 10:55:10
0:00:05
71.70
71.70
0.00
10000
10000
10:55:41 10:55:46
0:00:05
71.70
71.70
0.00
4000
4000
71.70
71.70
0.00
2500
2500
FENILNITESH
70.95 0.00 THAKKAR
MAHESH
DHANVANTRAI
72.00 0.30 MEHTA
MAHESH
DHANVANTRAI
71.70 0.00 MEHTA
MAHESH
DHANVANTRAI
71.70 0.00 MEHTA
MAHESH
DHANVANTRAI
71.70 0.00 MEHTA
MAHESH
71.70 0.00 DHANVANTRAI
10:56:30 10:56:34
Page 30 of 54
July 31, 2015
6Jan AMITANITESH
10 THAKKAR
6Jan AMITANITESH
10 THAKKAR
6Jan AMITANITESH
10 THAKKAR
MEHTA
MAHESH
DHANVANTRAI
71.70 0.00 MEHTA
10:56:30 10:57:28
MAHESH
DHANVANTRAI
71.70 0.00 MEHTA
10:58:32 10:58:36
MAHESH
DHANVANTRAI
71.70 0.00 MEHTA
10:59:12 10:59:16
71.70
71.70
0.00
71.70
71.70
0.00
2500
2500
71.70
71.70
0.00
1500
1500
38. From the above, it can be seen that substantial volume of trades
were synchronized by Noticee No. 1-6
both at BSE and NSE.
Hence, Noticee No. 1-6 created artificial volume in the scrip of

HSSL.
39. I find that at NSE, on December 22, 2009, Noticee No. 7 bought a
total of 42,800 shares which were almost perfectly synchronized in
terms of quantity, time and price amongst the members of the group.
Hence, Noticee No. 7 created artificial volume in the scrip of HSSL.
40. I find that Noticee No. 8 and 9 contributed significantly to creation of

artificial volume by indulging in synchronized trades within the group
at both NSE and BSE. At NSE, Noticee No. 8 and 9 bought 38,126
shares. There were a total of 50 instances of cross deals which
were almost perfectly synchronized in terms of quantity, time and
price amongst the members of the group. Some of the instances are
mentioned below:
TradeDate
Client
Name
DHAVAL
A.
5Nov09 THAKKAR
NITESH
A.
5Nov09 THAKKAR
NITESH
A.
5Nov09 THAKKAR
LTP
Diff
CPClient
Name
BuyOrd
Time
saleOrd
Time
time
Diff
buy
Ord
Price
sale
Ord
Price
buy
price ord
diff
Qty
qty
diff
MITALIY.
51.75 5.25 DOSHI
14:58:13 14:58:04 0:00:09 57.00 57.00
0.00
500
500
MITALIY.
57.00 0.00 DOSHI
14:58:52 14:58:46 0:00:06 57.00 57.00
0.00
500
500
MITALIY.
57.00 0.00 DOSHI
15:19:25 15:17:30 0:01:55 57.00 57.00
0.00
250
250
Page 31 of 54
sale
ord
qty
July 31, 2015
6Nov09
6Nov09
16Nov09
16Nov09
16Nov09
17Nov09
17Nov09
18Nov09
18Nov09
18Nov09
19Nov09
19Nov09
19Nov09
19Nov09
19Nov09
19Nov09
NITESH
A.
THAKKAR
NITESH
A.
THAKKAR
DHAVAL
A.
THAKKAR
DHAVAL
A.
THAKKAR
DHAVAL
A.
THAKKAR
DHAVAL
A.
THAKKAR
DHAVAL
A.
THAKKAR
DHAVAL
A.
THAKKAR
DHAVAL
A.
THAKKAR
DHAVAL
A.
THAKKAR
NITESH
A.
THAKKAR
NITESH
A.
THAKKAR
NITESH
A.
THAKKAR
NITESH
A.
THAKKAR
NITESH
A.
THAKKAR
NITESH
A.
THAKKAR
57.00 2.00
54.15 5.60
69.00 3.40
71.50 0.45
71.95 0.00
75.55 0.05
75.50 0.00
79.30 0.00
79.30 0.00
79.30 0.00
79.30 3.65
82.95 0.00
83.25 0.10
83.15 0.00
83.15 0.00
83.15 0.00
YOGESH
RATILAL
DOSHI
YOGESH
RATILAL
DOSHI
YOGESH
RATILAL
DOSHI
YOGESH
RATILAL
DOSHI
YOGESH
RATILAL
DOSHI
YOGESH
RATILAL
DOSHI
YOGESH
RATILAL
DOSHI
YOGESH
RATILAL
DOSHI
YOGESH
RATILAL
DOSHI
YOGESH
RATILAL
DOSHI
DARSHANA
YOGESH
DOSHI
DARSHANA
YOGESH
DOSHI
DARSHANA
YOGESH
DOSHI
DARSHANA
YOGESH
DOSHI
YOGESH
RATILAL
DOSHI
YOGESH
RATILAL
DOSHI
10:18:33 10:18:21 0:00:12 59.00 59.00
0.00 1000 1000
10:48:58 10:48:49 0:00:09 59.75 59.75
0.00
250
11:19:02 11:18:52 0:00:10 72.40 72.40
0.00 1225 1225
12:28:45
9:57:44 2:31:01 71.95 71.95
0.00
500
500
12:49:12 12:49:06 0:00:06 71.95 71.95
0.00
55
55
13:38:50 13:30:37 0:08:13 75.50 75.50
0.00
105
105
13:39:22 13:39:18 0:00:04 75.50 75.50
0.00
100
100
13:49:24 13:49:19 0:00:05 79.30 79.30
0.00
335
335
13:49:57 13:49:51 0:00:06 79.30 79.30
0.00
15
15
13:55:19 13:55:15 0:00:04 79.30 79.30
0.00
200
200
10:07:29 10:07:23 0:00:06 82.95 82.95
0.00
150
150
10:10:27 10:10:22 0:00:05 82.95 82.95
0.00
300
300
12:56:57
0.00 1000 1000
12:58:00 12:57:44 0:00:16 83.15 83.15
0.00
221
13:21:36 12:59:18 0:22:18 83.15 83.15
0.00 1000 1000
13:22:39 13:22:33 0:00:06 83.15 83.15
0.00
9:56:05 3:00:52 83.15 83.15
250
221
500
41. At NSE, Noticee No. 8 and 9 sold 20,590 shares. There were a
total of 19 instances cross deals which were almost perfectly
Page 32 of 54
July 31, 2015
500
TradeDate
Client
Name
CPClient
Name
LTP
Diff
PRIYA
DHAVAL
DHAVAL
A.
11Jan10 THAKKAR 77.50 8.15 THAKKAR
BuyOrd
Time
9:12:21
saleOrd
Time
time
Diff
buy
Ord
Price
sale
Ord
Price
buy
price ord
diff
Qty
sale
ord
qty
qty
diff
9:12:21 0:00:00 69.35 69.35
0.00 7900 7900
YOGESH
RATILAL
13Jan10 DOSHI
DHAVAL
A.
76.80 0.10 THAKKAR 13:06:56 13:07:11 0:00:15 76.70 76.70
0.00 1473 1473
YOGESH
RATILAL
18Jan10 DOSHI
DHAVAL
A.
79.40 0.60 THAKKAR 12:18:27 12:18:38 0:00:11 80.00 80.00
0.00
27
27
YOGESH
RATILAL
18Jan10 DOSHI
NITESH
A.
81.70 1.55 THAKKAR 14:38:21 12:27:21 2:11:00 80.15 80.15
0.00
500
500
YOGESH
RATILAL
26Feb10 DOSHI
NITESH
A.
81.05 0.25 THAKKAR
9:05:13
9:05:17 0:00:04 80.80 80.80
0.00
790
790
YOGESH
RATILAL
26Feb10 DOSHI
NITESH
A.
81.50 0.25 THAKKAR
9:05:13
9:06:10 0:00:57 81.25 81.25
0.00
500
500
YOGESH
RATILAL
26Feb10 DOSHI
DHAVAL
A.
81.25 0.30 THAKKAR
9:05:13
9:08:02 0:02:49 81.55 81.55
0.00
900
900
YOGESH
RATILAL
26Feb10 DOSHI
DHAVAL
A.
84.80 3.25 THAKKAR
9:09:07
9:09:12 0:00:05 81.55 81.55
0.00
350
350
42. From the above, it can be seen that substantial volume of trades
were synchronized by Noticee No. 8 and 9
during the relevant
period both at BSE and NSE. Hence, Noticee No. 8 and 9 created
artificial volume in the scrip of HSSL.
43. Noticee No. 8 and 9 also influenced the price of the scrip during the
first phase of investigation by placing buy orders at price more than
LTP and set new high prices both at BSE and NSE. Some of the
instances of influencing the price at BSE are mentioned below:
Page 33 of 54
July 31, 2015
TradeDate
Client
Name
CPClientName
LTP
Diff
BuyOrd
Time
saleOrd
Time
time
Diff
buy
Ord
Price
sale
Ord
Price
buy sale
price ord ord qty
diff
Qty qty diff
NITESH
ARJUN
19Nov09 THAKKAR
DARSHANA
75.00 5.95 YOGESHDOSHI
10:40:10 10:40:04 0:00:07
80.95
80.95
250
250
NITESH
ARJUN
19Nov09 THAKKAR
DARSHANA
80.95 0.40 YOGESHDOSHI
10:41:20 10:41:16 0:00:04
81.35
81.35
250
250
NITESH
ARJUN
20Nov09 THAKKAR
YOGESHKUMAR
RASIKLAL
75.00 4.95 DOSHI
10:06:51 10:06:45 0:00:06
79.95
79.95
250
250
NITESH
ARJUN
20Nov09 THAKKAR
YOGESHKUMAR
RASIKLAL
79.00 0.95 DOSHI
10:30:12 10:30:05 0:00:07
79.95
79.95
200
200
NITESH
ARJUN
20Nov09 THAKKAR
YOGESHKUMAR
RASIKLAL
76.05 3.70 DOSHI
14:48:50 14:48:42 0:00:08
79.8
79.75
0.05
50
50
NITESH
ARJUN
23Nov09 THAKKAR
YOGESHKUMAR
RASIKLAL
76.05 2.90 DOSHI
11:37:20 11:37:16 0:00:04
78.95
78.95
100
100
NITESH
ARJUN
23Nov09 THAKKAR
YOGESHKUMAR
RASIKLAL
76.00 1.45 DOSHI
12:38:49 12:38:45 0:00:04
77.45
77.45
100
100
NITESH
ARJUN
23Nov09 THAKKAR
YOGESHKUMAR
RASIKLAL
75.80 1.65 DOSHI
12:39:09 12:39:05 0:00:04
77.45
77.45
50
50
DHAWAL
YOGESHKUMAR
ARJUN
RASIKLAL
9Mar10 THAKKAR 103.55 1.25 DOSHI
15:05:37 15:05:33 0:00:04 104.85
104.8
0.05
50
50
DHAWAL
YOGESHKUMAR
ARJUN
RASIKLAL
15:18:46 15:18:43 0:00:03 104.85
104.8
0.05
50
50
Page 34 of 54
July 31, 2015
DHAWAL
YOGESHKUMAR
ARJUN
RASIKLAL
15:26:33 15:26:30 0:00:03 104.85
NITESH
YOGESHKUMAR
ARJUN
RASIKLAL
9:40:32
104.8
0.05
100
100
9:40:28 0:00:04 105.85 105.85
100
100
NITESH
YOGESHKUMAR
ARJUN
RASIKLAL
10:47:10 10:47:08 0:00:03 105.85
105.8
0.05
50
50
NITESH
YOGESHKUMAR
ARJUN
RASIKLAL
11:06:18 11:06:12 0:00:06
105.8
100
100
9:32:21 0:00:08 108.65 108.65
100
100
DHAWAL
YOGESHKUMAR
ARJUN
RASIKLAL
9:32:29
105.8
DHAWAL
YOGESHKUMAR
ARJUN
RASIKLAL
10:57:40 10:57:35 0:00:05
107.3
107.3
50
50
DHAWAL
YOGESHKUMAR
ARJUN
RASIKLAL
11:26:10 11:26:07 0:00:03
107.3 107.25
0.05
44. Some of the instances of influencing the price at NSE are mentioned
below:
TradeDate
Client
Name
CPClient
Name
LTP
Diff
DHAVAL
A.
MITALIY.
5Nov09 THAKKAR 51.75 5.25 DOSHI
BuyOrd
Time
saleOrd
Time
time
Diff
buy
Ord
Price
sale
Ord
Price
buy
price ord
diff
Qty
14:58:13
14:58:04
0:00:09
57.00
57.00
0.00
Page 35 of 54
July 31, 2015
500
sale
ord
qty
500
qty
diff
NITESH
YOGESH
A.
RATILAL
10:18:33
10:18:21
0:00:12
59.00
59.00
0.00
1000
1000
NITESH
YOGESH
A.
RATILAL
10:48:58
10:48:49
0:00:09
59.75
59.75
0.00
250
250
DHAVAL
YOGESH
A.
RATILAL
11:19:02
11:18:52
0:00:10
72.40
72.40
0.00
1225
1225
DHAVAL
YOGESH
A.
RATILAL
12:28:45
9:57:44
2:31:01
71.95
71.95
0.00
500
500
NITESH
DARSHANA
A.
YOGESH
10:07:29
10:07:23
0:00:06
82.95
82.95
0.00
150
150
45. It is evident from the instances mentioned in the table that Noticee
No. 8 and 9 mainly influenced the price of the scrip at BSE and NSE
during the first phase of relevant period by placing buy orders at a
price above LTP. On perusal of both the above tables, it is seen that
on a number of instances the aforesaid Noticees have placed buy
orders at a new high price than the LTP when shares were available
at lower prices and changed the course of the prices.
46. At NSE, Noticee No. 10 bought 13,666 shares. There were a total of
14 instances of cross deals which were almost perfectly
Page 36 of 54
July 31, 2015

Trade
Date
Client
Name
CPClient
Name
YOGESH
RATILAL
13Jan10 DOSHI
YOGESH
RATILAL
13Jan10 DOSHI
YOGESH
RATILAL
15Jan10 DOSHI
YOGESH
RATILAL
15Jan10 DOSHI
saleOrd
Time
time
Diff
buy
Ord
Price
sale
Ord
Price
price
diff
buy
ord
Qty
sale
ord
qty
LTP
Diff
BuyOrd
Time
qty
diff
76.80
DHAVALA.
0.10 THAKKAR
13:06:56
13:07:11
0:00:15
76.70
76.70
0.00
1473
1473
76.65
PRIYA
DHAVAL
0.05 THAKKAR
15:28:43
15:28:54
0:00:11
76.70
76.70
0.00
3250
3250
76.30
AMITA
NITESH
0.45 THAKKAR
9:37:11
9:37:19
0:00:08
76.75
76.75
0.00
2500
2500
77.05
PRIYA
DHAVAL
0.25 THAKKAR
9:37:39
9:37:46
0:00:07
76.80
76.80
0.00
2500
2500
47. At NSE, Noticee No. 10 sold 21,895 shares. There were a total of 38
instances cross deals which were almost perfectly synchronized in
terms of quantity, time and price amongst the members of the group.
Some of the instances are mentioned below:
TradeDate
ClientName
LTP
Diff
YOGESHR.
DOSHI
4Nov09 (HUF)
51.90
2.55
NITESHA.
6Nov09 THAKKAR
57.00
2.00
54.15
5.60
59.85
0.05
69.00
71.50
3.40
0.45
NITESHA.
6Nov09 THAKKAR
SHRUTI
SANJEEV
6Nov09 SHAH
DHAVALA.
16Nov09 THAKKAR
16Nov09 DHAVALA.
CPClient
Name
YOGESH
RATILAL
DOSHI
YOGESH
RATILAL
DOSHI
YOGESH
RATILAL
DOSHI
YOGESH
RATILAL
DOSHI
YOGESH
RATILAL
DOSHI
YOGESH
BuyOrd
Time
saleOrd
Time
time
Diff
buy
Ord
Price
sale
Ord
Price
buy
price ord
diff
Qty
qty
diff
14:00:28
14:00:19
0:00:09
54.45
54.45
0.00
50
50
10:18:33
10:18:21
0:00:12
59.00
59.00
0.00
1000
1000
10:48:58
10:48:49
0:00:09
59.75
59.75
0.00
250
250
12:21:12
12:21:07
0:00:05
59.80
59.80
0.00
900
900
11:19:02
12:28:45
11:18:52
9:57:44
0:00:10
2:31:01
72.40
71.95
72.40
71.95
0.00
0.00
1225
500
1225
500
0
0
Page 37 of 54
sale
ord
qty
July 31, 2015
THAKKAR
DHAVALA.
16Nov09 THAKKAR
71.95
0.00
DHAVALA.
17Nov09 THAKKAR
75.55
0.05
DHAVALA.
17Nov09 THAKKAR
75.50
0.00
DHAVALA.
18Nov09 THAKKAR
79.30
0.00
DHAVALA.
18Nov09 THAKKAR
79.30
0.00
DHAVALA.
18Nov09 THAKKAR
79.30
0.00
NITESHA.
19Nov09 THAKKAR
83.15
0.00
NITESHA.
19Nov09 THAKKAR
83.15
0.00
RATILAL
DOSHI
YOGESH
RATILAL
DOSHI
YOGESH
RATILAL
DOSHI
YOGESH
RATILAL
DOSHI
YOGESH
RATILAL
DOSHI
YOGESH
RATILAL
DOSHI
YOGESH
RATILAL
DOSHI
YOGESH
RATILAL
DOSHI
YOGESH
RATILAL
DOSHI
12:49:12
12:49:06
0:00:06
71.95
71.95
0.00
55
55
13:38:50
13:30:37
0:08:13
75.50
75.50
0.00
105
105
13:39:22
13:39:18
0:00:04
75.50
75.50
0.00
100
100
13:49:24
13:49:19
0:00:05
79.30
79.30
0.00
335
335
13:49:57
13:49:51
0:00:06
79.30
79.30
0.00
15
15
13:55:19
13:55:15
0:00:04
79.30
79.30
0.00
200
200
13:21:36
12:59:18
0:22:18
83.15
83.15
0.00
1000
1000
13:22:39
13:22:33
0:00:06
83.15
83.15
0.00
500
500
48. Noticee No. 10 also influenced the price of the scrip by purchasing
shares at price more than LTP and by synchronized trading in cross
deals that created a new high price at BSE. Some of the instances
of influencing the price at BSE are mentioned below:
TradeDate
ClientName
CPClient
Name
LTP
Diff
YOGESHKUMAR
DHAWAL
RASIKLAL
ARJUN
15Dec09 DOSHI
72.00 1.00 THAKKAR
YOGESHKUMAR
PRIYA
RASIKLAL
DHAWAL
14Jan10 DOSHI
74.10 0.90 THAKKAR
YOGESHKUMAR
YOGESH
RASIKLAL
RDOSHI
17Mar10 DOSHI
105.65 2.75 HUF
buy
Ord
Price
sale
Ord
Price
73
73
0 1164 1164
75
75
250
250
13:47:08 13:47:05 0:00:04 108.4 108.4
200
200
BuyOrd
Time
saleOrd
Time
time
Diff
11:04:23 11:04:17 0:00:06
9:05:40
9:05:44 0:00:03
buy
price ord
diff
Qty
49. It was alleged that Noticee No. 11 and 12 influenced the price of the
scrip by placing buy orders at price more than LTP and at new high
price at BSE. I find that there is data insufficiency with regard to the
buy orders placed by Noticee No. 11 and Noticee No.12 at BSE,
which is necessary for establishing such charge . In view of nonAdjudication Order in the matter of Harita Seating Systems Limited
Page 38 of 54
July 31, 2015
sale
ord
qty
qty
diff
existence of trades with other Noticees and also lack of evidence

with regard to pre-designed cross deals and synchronized trades
such as order time, quantity and price at which orders were placed.
The charges against Noticee No.11 and 12 for violation of regulation
4(1), 4(2) (e) of PFUTP Regulations, 2003 are not established.
50. The details of purchase and sale by Noticees on both the exchanges
is presented below:
Client
Name
Noticee
No. 1
Noticee
No. 2
Noticee
No. 3
Noticee
No. 4
Noticee
No. 5
Noticee
No. 6
Noticee
No.7
Noticee
No. 8
Noticee
No. 9
Noticee
No. 10
Noticee
No. 11
Noticee
No. 12
Total
NSE
Total
Buy
BSE
total
buy
total
buy
NSE
Total
sale
BSE
total
sale
total
sale
net
transactions
75728
54736
130464
53564
75900
129464
1000
25215
21985
47200
37100
7900
45000
2200
1203
45997
47200
36500
6500
43000
4200
23529
50472
74001
34489
38918
73407
594
10165
10035
20200
10000
10200
20200
23102
15503
38605
15800
22505
38305
300
45964
1036
47000
22800
20000
42800
4200
34509
31217
65726
16495
42981
59476
6250
31950
26139
58089
34945
19341
54286
3803
28724
50567
79291
48730
32257
80987
-1696
675
8017
8692
8992
1950
10942
-2250
2292
303056
4887
320591
7179
623647
3785
323200
3444
281896
7229
605096
-50
18551
From the above table, it is observed that the Noticees traded large
quantity of shares on each exchange.
Their overall purchases
were 623647 shares and sale was 605096 shares. Noticees

generated false trading volumes by indulging in synchronized
Page 39 of 54
July 31, 2015
trades within the family and amongst themselves wherein the price
quantity and time of orders were matched.
51. The individual details of such manipulative trades entered into by the
Noticees at BSE are as follows:
Client
Name
Total
buy
Manipul
ative
buy
manipul
ative
buy (%)
No of
manipul
ative
trades
Positive
LTP
dealing
on buy
side
Total
sale
Manipul
ative
sale
manipul
ative
sale (%)
30.18
manipul
ative
buy as
a % of
Market
Volume
2.11
62.25
manipul
ative
sale as
a % of
Market
Volume
6.04
Noticee
No. 1
Noticee
No. 2
Noticee
No. 3
Noticee
No. 4
Noticee
No. 5
Noticee
No. 6
Noticee
No. 7
Noticee
No. 8
Noticee
No. 9
Noticee
No. 10
Noticee
No. 11
Noticee
No. 12
TOTAL
54736
16517
-0.85
75900
47250
21985
0.00
0.00
7900
45997
43000
93.48
5.50
50472
28039
55.55
3.58
4.45
10035
0.00
0.00
15503
3000
19.35
0.38
1036
0.00
0.00
31217
15365
49.22
26139
8624
50567
7900
100.00
1.01
6500
6500
100.00
0.83
38918
14208
36.51
1.82
10200
10000
98.04
1.28
-1
22505
13000
57.76
1.66
20000
0.00
0.00
1.96
17
39.15
42981
15800
36.76
2.02
32.99
1.10
16.15
19341
1364
7.05
0.17
4314
8.53
0.55
-5.05
32257
2881
8.93
0.37
20
8017
0.00
0.00
1950
500
25.64
0.06
4887
0.00
0.00
3444
488
14.17
0.06
320591
118859
37.07
15.19
43
56.85
281896
119891
42.53
15.32
45
From the above details, it is observed that Noticees executed manipulative

trades at BSE by contributing to a manipulative buy of 118859 shares and a
manipulative sale of 119891 shares.
52. Similarly, the details of manipulative trades entered into by the

Noticees at NSE are as under:
Page 40 of 54
July 31, 2015
No of
Manipul
ative
trades
Client
Name
Noticee
No. 1
Noticee
No. 2
Noticee
No. 3
Noticee
No. 4
Noticee
No. 5
Noticee
No. 6
Noticee
No. 7
Noticee
No. 8
Noticee
No. 9
Noticee
No. 10
Noticee
No. 11
Noticee
No. 12
Total
Total
buy
Manip
ulative
buy
manip
ulative
buy
(%)
75728
70578
93.20
manip
ulative
buy as
a % of
Market
Value
14.67
No of
manip
ulativ
e
trades
Positiv
e LTP
dealing
on buy
side
Total
sale
11
-3.8
53564
23080
25215
0.00
0.00
3.3
37100
30496
82.20
6.34
1203
0.00
0.00
-0.05
36500
36000
98.63
7.48
23529
16540
70.30
3.44
4.55
34489
30500
88.43
6.34
10165
0.00
0.00
10000
10000
100.00
2.08
23102
10102
43.73
2.10
-7.8
15800
15800
100.00
3.28
45964
42800
93.12
8.90
4.4
22800
2800
12.28
0.58
34509
15979
46.30
3.32
23
59.1
16495
8468
51.34
1.76
31950
13945
43.65
2.90
11
24.1
34945
12474
35.70
2.59
28724
11559
40.24
2.40
-22.95
48730
11166
22.91
2.32
22
675
0.00
0.00
8992
2671
29.70
0.56
2292
0.00
0.00
3785
2519
66.55
0.52
10
303056
181503
59.89
37.73
323200
185974
57.54
38.66
74
70
60.85
Manipul
ative
sale
manip
43.09
manipu
lative
sale as
a % of
Market
Value
4.80
ulative
sale
(%)
No of
Manipul
ative
trades
From the above details it is observed that Noticees executed manipulative

trades at NSE by contributing to a manipulative buy of 181503 shares and a
manipulative sale of 185974 shares.
53. Approximately 40% of volume traded at NSE and 15% volume

traded at BSE was traded among the Noticees in synchronized
manner. These artificial trades distorted the market equilibrium in
the scrip of HSSL and presented a distorted view of trading in the
market.
54. At BSE, there were a total of 110 cross deals. In the entire relevant
period, there were 69 instances of cross deals which were executed
in less than one minute time difference. In the first phase of relevant
period, there were 3 instances of synchronized trades. In the second
Page 41 of 54
July 31, 2015
phase, there were 28 instances of synchronized trades and in the

third phase there were 37 instances of synchronized trades.
55. It is evident from the above that the Noticees followed a common
modus operandi of artificially inflating the price and creating artificial
volumes by executing synchronized transactions through their subbroker ASB. Some of the trades as discussed earlier were at a price
which is at much variance with the last traded price and resulting in
setting new prices. The transactions of the Noticees were
synchronized wherein the buy and sell orders were placed within
time difference of less than 1 minute. There are also cross trades
where the buyer and seller belong to the same sub-broker. The subbroker Noticee No. 10 was the introducer of all the Noticees who
traded in the scrip. Substantial quantities of orders were put
simultaneously or within close proximity of each other for same price
and quantity. Since the cross cum synchronized trades were
executed between a group of related/connected entities, effectively
there is no change in beneficial ownership.
56. In this context, reliance is placed on the order of The Honble SAT,
in Ketan Parekh Vs. Securities & Exchange Board of India (Appeal
No. 2 of 2004) dated July 14, 2006, observed that, A synchronized
transaction even on the trading screen between genuine parties who intend
to transfer beneficial interest in the trading stock and who undertake the
transaction only for that purpose and not for rigging the market is not
illegal and cannot violate the regulations. As already observed
synchronisation or a negotiated deal ipso facto is not illegal. A
synchronised transaction will, however, be illegal or violative of the
Regulations if it is executed with a view to manipulate the market or if it
results in circular trading or is dubious in nature and is executed with a
view to avoid regulatory detection or does not involve change of beneficial
Page 42 of 54
July 31, 2015
ownership or is executed to create false volumes resulting in upsetting the

market equilibrium. Any transaction executed with the intention to defeat
the market mechanism whether negotiated or not would be illegal. Whether
a transaction has been executed with the intention to manipulate the
market or defeat its mechanism will depend upon the intention of the
parties which could be inferred from the attending circumstances because
direct evidence in such cases may not be available. The nature of the
transaction executed, the frequency with which such transactions are
undertaken, the value of the transactions, whether they involve circular
trading and whether there is real change of beneficial ownership, the
conditions then prevailing in the market are some of the factors which go to
show the intention of the parties. This list of factors, in the very nature of
things, cannot be exhaustive. Any one factor may or may not be decisive
and it is from the cumulative effect of these that an inference will have to be
drawn.
57. The Honble SAT, in Nirmal Bang Securities Pvt. Ltd Vs SEBI
(Appeal no. 54-57/2001), observed as follows: - BEB has been
charged for synchronized deals with First Global. I have examined the data
provided by the parties on this issue. I find many transactions between
BEB and FGSB. There are many instances of such transactions. I find the
scrip; quantity and price for these orders had been synchronized by the
counter party brokers. Such transactions undoubtedly create an artificial
market to mislead the genuine investors. Synchronized trading is violative
of all prudential and transparent norms of trading in securities.
Synchronized trading on a large scale can create false volumes. The
argument that the parties had no means of knowing whether any entity
controlled by the client is simultaneously entering any contra order
elsewhere for the reason that in the online trading system, confidentiality of
counter parties is ensured, is untenable. It was submitted by the Appellants
Page 43 of 54
July 31, 2015
that it was not possible for the broker to know who the counter party broker
is and that trades were not synchronized but it was only a coincidence in
some cases. Theoretically this is OK. But when parties decide to
synchronize the transaction the story is different. There are many
transactions giving an impression that these were all synchronized,
otherwise there was no possibility of such perfect matching of quantity
price etc. As the Respondent rightly stated it is too much of a coincidence
over too long a period in too many transactions when both parties to the
transaction had entered buy and sell orders for the same quantity of shares
almost simultaneously. The data furnished in the show cause notice
certainly goes to prove the synchronized nature of the transaction which is
in violation of regulation 4 of the FUTP Regulations. The facts on record
categorically establish that BEB had indulged in synchronized trading in
violation of regulation 47 of the FUTP Regulations. In a synchronized
trading intention is implicit.
58. Keeping in mind the dicta of the SAT as reproduced above; I see no
reason to take a different view in the present case where the facts
are similar.
59. The method and the manner in which the trades were executed are
the most important factors to be considered in these circumstances.
The motive, can be inferred from the trading pattern. Clearly in the
present case, large number of cross deals, the orders were placed
so as to ensure a matching of the buy and the sell quantity and the
buy and the sell price with the pre-selected counter party amongst
the Noticees, with whom a prior tacit understanding exists. The buy
and the sell orders were placed at almost the same time between
the Noticees, through the same sub-broker, with just a difference of
a few seconds. This proximity in the inputting of orders at the same
Page 44 of 54
July 31, 2015
price and for the same quantity, results in getting them matched,
such that there is almost perfect matching in all the trades, with all
the three parameters, viz., quantity, price and most importantly, the
time required to conclude the trades, which to a large extent
indicates synchronization in the logging in of the orders.
60. This trend was not noted in a solitary incident or two. Instead, a
large number of synchronized trades got matched regularly, that too
only between the same sub-broker and the same set of clients in the
same scrip, during the same period. The phenomenal regularity with
which the trades are matched amongst the Noticees with the same
sub-broker, leads one to conclude, that these transactions were
effectively meant to be synchronized.
61. The buy and sell orders of one entity were close to the buy/sell
orders of the other entity in all the settlements, in terms of order,
quantity, price and time such that the trades of these entities were
always matched. Greater the number of synchronized trades, the
larger is the chances of trades not being genuine in nature, which
adversely affects the market integrity and equilibrium. A trade can
be executed on the screen and still be manipulative in nature.
Considering the number of such
matching trades, amongst the
Noticees there has been a gross mis-use of the screen based

trading system. It is also to be stated that intention in such cases of
synchronized trading involving large scale price manipulation has to
be drawn from the trading pattern and attendant circumstances and
the same was also brought out in the earlier cited case of Nirmal
Bang Securities (P) Ltd. vs SEBI by the Honble SAT wherein it was
observed that Intention is reflected from the action of the Appellant.
Choosing selective time slots does not appear to be an involuntary action.
Page 45 of 54
July 31, 2015
62. When the trading pattern amongst the Noticees reveal a clear and
set pattern/behavior, such as, execution of a large number of trades,
on the same day, in the same scrip, consistently throughout a longer
period in cross deals for 27 days at NSE and 20 days at BSE with
the same broker/sub-broker, it is indicative of a concerted level of
activity due to prior understanding. The acts of the entities trading
behaviour and attendant circumstances speak of their intentions.
Furthermore, manipulation does not only involve manipulation in the
prices of the scrip but also includes building up of artificial volumes.
63. In order to establish the fraudulent nature of trades indulged in by

the Noticees through ASB reference may also be made to the
definition of fraud laid down in regulation 2 (1) (c) of the PFUTP
Regulations, 2003, which reads as follows:
"2 (1)(c) "fraud" includes any act, expression, omission or
concealment committed whether in a deceitful manner or not by a
person or by any other person with his connivance or by his agent
to deal in securities, whether or not there is any wrongful gain or
avoidance of any loss,
64. Regulation 4(2)(a) of PFUTP Regulations, 2003 prohibits a person

from indulging in an act which creates false or misleading
appearance of trading in the securities market. Regulation 4(2)(b) of
PFUTP Regulations, 2003 prohibits dealings in a security intended
to operate as a device to inflate, depress or cause fluctuations in the
price of such security for wrongful gains. Regulation 4(2)(e) of
PFUTP Regulations, 2003 prohibits any act or omission amounting
to manipulation of the price of a security; Regulation 4(2)(g) of
PFUTP Regulations, 2003 prohibits from entering into a transaction
in securities without intention of performing it or without intention of
change of ownership of such security. As detailed above, the acts of
Page 46 of 54
July 31, 2015
the Noticees created false and misleading appearance of trading in

the shares of HSSL and these are bonafide trades. The facts of the
case highlight the Noticees involvement, by execution of continuous
synchronized and cross trades in a substantial manner, over a long
period of time in both exchanges, the manipulation of price/volume
of the shares of HSSL led to creation of artificial volumes, prices and
misleading appearance of trading, as the transactions executed by
the Noticees through ASB in HSSL were synchronized in terms of
price, quantity and order time and in violation of the provisions of
regulations 4(1), 4(2) (a), (b) (e) and (g) of the PFUTP Regulations,
2003.
65. Keeping in mind the dicta of SAT in Ketan Parekh Vs. Securities
& Exchange Board of India (Appeal No. 2 of 2004) and Nirmal Bang
Securities Pvt. Ltd Vs SEBI (Appeal no. 54-57/2001), I am unable to
accept the contention of the Noticees that the trading platforms are
online, real time, computerized, price and time priority matching
trade systems for orders keyed and that there is nothing wrong in
the cross trades as they are not prohibited. In Nirmal Bang
Securities Pvt. Ltd Vs SEBI (Appeal no. 54-57/2001) Hon'ble SAT
observed that ".......... Theoretically this is OK. But when parties decide
to synchronize the transaction the story is different. There are many
transactions giving an impression that these were all synchronized,
otherwise there was no possibility of such perfect matching of quantity
price etc. As the Respondent rightly stated it is too much of a coincidence
over too long a period in too many transactions when both parties to the
transaction had entered buy and sell orders for the same quantity of shares
almost simultaneously." Also, I do not find any merit in the contention
of the Noticees that the three families are not related and therefore
there is no intention to manipulate. Besides the execution of
synchronized trades in a series of transactions over a period of time
Page 47 of 54
July 31, 2015
in cross deals, their trading pattern, behavior and the attendant

circumstances, it may be noted that Noticee Nos. 1,4,5,6,8 and 9
have vide their common reply dated May 06, 2013 have themselves
admitted the nexus amongst themselves by stating that "in view of
the scrip being illiquid, whenever funds were required by Thakkar
family, the Doshi family either bought shares from them or arranged
buyer from their own family/circle." Further, intention has to be
inferred by the trading pattern and behavior over a period of time
and attendant circumstances. One cannot find a 'smoking gun'. But
as observed by SAT in Nirmal Bang Securities Pvt. Ltd Vs SEBI
(Appeal no. 54-57/2001), case referred to earlier, "there are too
many transactions over too long a period amongst the Noticees
which is not a matter of chance." Thakkar's Doshi's and Mehta's
trading pattern shows their intention to manipulate the scrip of HSSL
in a concerted manner.
66. Noticees have contended that there was a corporate announcement

in February 25, 2010 with regard to acquisition of shares of
subsidiary of HSSL by a German company which has led to an
increase in the price of the scrip. It is observed that the irregular
and manipulative trades have commenced much prior to the
aforesaid corporate announcement. Infact the price rise was much
higher between November 03, 2009 and November 19, 2009 when
price rose from ` 48.55 to ` 76.3 at BSE i.e. an increase of 57.7%
and from ` 51.9 to ` 76.15 at NSE i.e. an increase of 46.72%.
During the said period, there was significant
contribution by the
Noticees to the total volumes. At BSE Noticees bought 40.98% of

the total traded volume and sold 36.03% of the total traded volume.
At NSE, Noticees bought 63% of the total traded volume and sold
67.19% of the total traded volume. Even after making allowance for
some price rise was due to the corporate announcements, the
Page 48 of 54
July 31, 2015
method and manner of manipulative trades cannot be purged by the

contention that a corporate announcement was made which had
caused the price rise. It is noted that Noticee No. 8 and 9 influenced
the price of the scrip of HSSL during the first phase of
by
purchasing shares at price more than LTP and at new high price
both at BSE and NSE and Noticee No. 10 influenced the price of
the scrip of HSSL by purchasing shares at price more than LTP and
at new high price at BSE. Further, the allegations include creation of
artificial volumes also besides price rise and the Noticees did create
artificial volumes by trading amongst themselves and within the
families in many cases so as to create an illusion of trading in the
market.
Approximately 40% of volume traded at NSE and 15%
volume traded at BSE was traded among the Noticees in

synchronized manner.
67. In N. Narayanan vs Adjudicating Officer, SEBI
Civil Appeal No.
4112-4113 of 2013, the Hon'ble Supreme Court has observed that

market abuse has now become a common practice in the India
security market and, if not properly curbed, the same would result in
defeating the very object and purpose of SEBI Act which is intended
to protect the interests of investors in securities and to promote the
development of securities market".
68. In view of the foregoing, I am of the considered view that the facts of
the present case clearly bring out an element of market manipulation
by irregular trades indulged in by the Noticees trading through ASB,
wherein, Noticee No. 10 who is Director of ASB, himself introduced
all the Noticees besides executing trades for himself in the scrip as
discussed in the preceding paragraphs. Therefore, Noticee No. 1 to
Noticee No. 7 contributed significantly to creation of artificial volume
by indulging in synchronized trades within the group at both NSE
Page 49 of 54
July 31, 2015
and BSE and thereby violated Regulation 4(1), 4(2) (a) and (g) of
PFUTP Regulations, 2003 Noticee No. 8 and 9 contributed
significantly to creation of artificial volume by indulging in
synchronized trades within the group at both BSE and NSE. Also,
they influenced the price of the scrip of HSSL during the first phase
of by purchasing shares at price more than LTP and at new high
price both at BSE and NSE. Noticee No. 10 contributed significantly
to creation of artificial volume by indulging in synchronized trades
within the group at BSE. Also, he influenced the price of the scrip of
HSSL by purchasing shares at price more than LTP and at new high
price at BSE and thereby violated Regulation 4(1), 4(2) (a), (b), (e)
and (g) of PFUTP Regulations, 2003 stands established.
69. The Honble Supreme Court of India in the matter of SEBI Vs. Shri
Ram Mutual Fund [2006] 68 SCL 216(SC) held that once the
violation of statutory regulations is established, imposition of penalty
becomes sine qua non of violation and the intention of parties committing
such violation becomes totally irrelevant.
Once the contravention is
established, then the penalty is to follow.
70. Thus, the aforesaid violations by the Noticee make it liable for
penalty under Section 15HA of SEBI Act, 1992 which read as
follows:
Penalty for fraudulent and unfair trade practices
15HA. If any person indulges in fraudulent and unfair trade
practices relating to securities, he shall be liable to a penalty of
twenty-five crore rupees or three times the amount of profits made
out of such practices, whichever is higher.
Page 50 of 54
July 31, 2015
71. The practices indulged in by the Noticees in the scrip of HSSL

resulted in creation of artificial volumes and liquidity besides price
manipulation
and impediments in time price discovery as prices at
variance with last traded prices were put. Such irregular practices
adversely affects the market integrity. Besides, this kind of
fraudulent activity seriously affects the normal price discovery
mechanism of the securities market. People who indulge in
manipulative, fraudulent and deceptive transactions, or abet the
carrying out of such transactions which are fraudulent and
deceptive, should be suitably penalized for the said acts of
omissions and commissions. Considering the continuous effort of
the Noticees, while dealing through the sub-broker, whose Director
being Noticee No. 10 has introduced all the other Noticees who
traded in the scrip where the irregular cross deals and synchronized
trades were carried out over a period of time in a large number of
transactions, it can also be considered that the nature of default was
also repetitive.
ORDER
72. After taking into consideration the nature and gravity of the charges
established, having regard to section 15J of the SEBI Act, 1992,
and in exercise of the powers conferred upon me under Section 15-I
of the SEBI Act, 1992 read with Rule 5 of the Adjudication Rules, I
hereby impose monetary penalties on the basis number of
manipulative and irregular synchronized trades executed by the
Noticees, artificial volumes created, their contribution to price rise,
and number of days of irregular trades as shown in the table below:
Page 51 of 54
July 31, 2015
S.No. Name of Noticee
Regulation
Penal
Penalty
Violated
Provisions
(Amount
in
Rupees)
1.
Priya
Dhaval Regulation
Thakkar
` 5,00,000/-
15HA
4(1),
(Rupees Five Lakh
4(2) (a)
Only)
and (g) of
PFUTP
Regulations,
2003.
2.
Mahesh
Dhanvantrai Mehta
3.
Nikunj Dhanvantrai
Mehta
4.
Amita
Nitesh
Thakkar
5.
Fenil
Nitesh
Thakkar
6.
Nitesh
Thakkar (HUF)
Arjun
Regulation
4(1),
4(2) (a)
and (g) of
PFUTP
Regulations,
2003.
Regulation
4(1), 4(2)
(a) and (g)
of PFUTP
Regulations,
2003.
Regulation
4(1), 4(2)
(a) and (g)
of PFUTP
Regulations,
2003.
Regulation
4(1), 4(2)
(a) and (g)
of PFUTP
Regulations,
2003.
Regulation
4(1), 4(2)
(a) and (g)
of PFUTP
Regulations,
` 5,00,000/-
15HA
(Rupees Five Lakh

Only
` 5,00,000/-
15HA
(Rupees Five Lakh

Only)
` 5,00,000/-
15HA
(Rupees Five Lakh

Only)
` 5,00,000/-
15HA
(Rupees Five Lakh

Only)
` 5,00,000/-
15HA
(Rupees Five Lakh

Only
Page 52 of 54
July 31, 2015
7.
8.
9.
10.
2003.
Madhukanta
Regulation
4(1), 4(2)
Dhanvantrai Mehta
(a) and (g)
of PFUTP
Regulations,
2003.
Nitesh
Arjun Regulation
4(1), 4(2)
Thakkar
(a), (b), (e)
and (g) of
PFUTP
Regulations,
2003
Dhaval
Arjun Regulation
4(1), 4(2)
Thakkar
(a), (b), (e)
and (g) of
PFUTP
Regulations,
2003
Yogesh
Rasiklal Regulation
4(1), 4(2)
Doshi
(a), (b), (e)
and (g) of
PFUTP
Regulations,
2003
Total
` 5,00,000/-
15HA
(Rupees Five Lakh

Only)
` 8,00,000/-
15HA
(Rupees Eight Lakh

Only
` 8,00,000/-
15HA
(Rupees Eight Lakh

Only)
` 8,00,000/-
15HA
(Rupees Eight Lakh

Only)
` 59,00,000/(Rupees Fifty Nine

Lakh Only)
73. For the reasons stated at para 49, the allegations against Noticee
Nos. 11 and 12 are not established. Hence, no penalty is imposed
on the aforesaid Noticees.
74. The Noticees on whom the penalty is imposed as per table at para
73 shall pay the said amount of penalty by way of demand draft in
favour of SEBI - Penalties Remittable to Government of India,
payable at Mumbai, within 45 days of receipt of this order. The said
Page 53 of 54
July 31, 2015
demand draft should be forwarded to The Division Chief,

Enforcement Department-EFD-DRA-II, SEBI Bhavan, Plot No. C 4
A, G Block, Bandra Kurla Complex, Bandra (E), Mumbai
400 051.
75. In terms of rule 6 of the Rules, copies of this order are sent to the
Noticee and also to the Securities and Exchange Board of India.
DATE: JULY 31, 2015
S.V. KRISHNAMOHAN
PLACE: MUMBAI
CHIEF GENERAL MANAGER

& ADJUDICATING OFFICER
Page 54 of 54
July 31, 2015

Adjudication Order in The Matter of Harita Seating Systems Ltd.

Uploaded by

Document Information

Original Description:

Original Title

Copyright

Available Formats

Share this document

Share or Embed Document

Sharing Options

Did you find this document useful?

Is this content inappropriate?

Copyright:

Available Formats

Adjudication Order in The Matter of Harita Seating Systems Ltd.

Uploaded by

Copyright:

Available Formats

BEFORE THE ADJUDICATING OFFICER

SECURITIES AND EXCHANGE BOARD OF INDIA

PENALTIES BY ADJUDICATING OFFICER) RULES, 1995

NAME OF THE ENTITY

Priya Dhaval Thakkar

Mahesh Dhanvantrai Mehta EAD-5/SVKM/RGA/AO/02/2015

Nikunj Dhanvantrai Mehta

Amita Nitesh Thakkar

Fenil Nitesh Thakkar

Nitesh Arjun Thakkar HUF

Adjudication Order in the matter of Harita Seating Systems Limited

July 31, 2015

Nitesh Arjun Thakkar

Dhaval Arjun Thakkar

Yogesh Rasiklal Doshi

Darshana Yogesh Doshi

Mitali Yogesh Doshi

In the matter of M/s Harita Seating Systems Limited

FACTS OF THE CASE

July 31, 2015

2. Pursuant to the said investigation, it was alleged that Priya Dhaval

INB230995731 & INF230995731] (hereinafter referred to as 'SVS')

violated Regulation 4(1)(2)(e)of PFUTP Regulations, 2003 and liable

APPOINTMENT OF ADJUDICATING OFFICER

SEBI vide December 11, 2012 appointed Shri P.K. Kuriachen as

July 31, 2015

as the Adjudicating Officer vide order dated July 30, 2013.

SHOW CAUSE NOTICE, REPLY AND PERSONAL HEARING

4. Show Cause Notice No. EAD-2/RGA/4721/2013 dated February 22,

July 31, 2015

July 31, 2015

beneficial holding by one family member to another family member

6. The salient submissions made by the Noticee No. 2, 3 and 7 in

Mehta's were not involved in anyway in cross trades or price rigging in

July 31, 2015

No relationship with Thakkar family members. Commercial transactions

7. The salient submissions made by the Noticee No. 10, 11 and 12 in

8. In terms of Rule 4(3) of the Rules, Noticees were granted an

Adjudication Order in the matter of Harita Seating Systems Limited

July 31, 2015

9. On July 08, 2015, Mr. Rajesh Shah, Chartered Accountant appeared

submitted that in all there were 16 clients including the

July 31, 2015

c) Referring to page no. 4 of reply dated July 07, 2015, it was

July 31, 2015

a) Whether Noticee No. 1 to 7 have violated the provisions of

Noticee No. 11 to 12 have violated provisions of

Regulation 4(1)(2)(e)of PFUTP Regulations, 2003?

11. The relevant regulations of PFUTP Regulations, 2003 are stated as

July 31, 2015

July 31, 2015

at ` 108.95 on March 31, 2010 i.e. an increase of 46.43% within a

Adjudication Order in the matter of Harita Seating Systems Limited

July 31, 2015

Address of the Entity

A-3, Janak Kutir, Plot

Adjudication Order in the matter of Harita Seating Systems Limited

July 31, 2015

Darshana Yogesh 4,anand

19. Noticee Nos. 1, 4, 5, 6, 8, 9 are from the same family. Further,

July 31, 2015

Further, details of purchase and sale by the