Adjudication Order in Respect of Precise Consulting & Engineering Private Limited in The Matter of Onelife Capital Advisors Limited.

BEFORE THE ADJUDICATING OFFICER
SECURITIES AND EXCHANGE BOARD OF INDIA

ADJUDICATION ORDER NO. ASK/AO/SPV/113/2014-15
___________________________________________________________
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:
Precise Consulting & Engineering Private Limited
(PAN AAECP8434E)
In the matter of:
Onelife Capital Advisors Limited
___________________________________________________________
BACKGROUND
1. On noticing suspicious transfers of the proceeds of Initial Public
Offer (IPO) to certain entities, Securities and Exchange Board of
India (SEBI) conducted investigation into the matter of IPO of
Onelife Capital Advisors Limited (OCAL/company). In order to
ascertain the exact role played by Precise Consulting &
Engineering Private Limited (Noticee), certain details/information
was sought from the Noticee by the Investigating Authority (IA). The
investigation revealed that the Noticee, in response to the
summons
issued
by
the
IA,
furnished
false/forged
documents/information, thereby failed to comply with the said

summons.
Adjudication Order dated December 23, 2014 in respect of Precise Consulting & Engineering
Private Limited in the matter of Onelife Capital Advisors Limited.
Page 1 of 16
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2. Therefore, SEBI initiated adjudication proceedings against the

Noticee, under Section 15A(a) of the SEBI Act, 1992 (SEBI Act) for
violation of the provisions of Section 11C(2) & 11C(3) of SEBI Act.
APPOINTMENT OF ADJUDICATING OFFICER
3.
Shri Piyoosh Gupta was appointed as Adjudication Officer (AO),

vide order dated November 12, 2012 under section 15-I of the SEBI
Act to inquire into and adjudge under Section 15A(a) of the SEBI
Act the alleged violations of provisions of section 11C(2) & (3) of
SEBI Act by the Noticee. Consequent upon the transfer of Shri
Piyoosh Gupta, the undersigned was appointed as the AO vide
order dated November 08, 2013.
SHOW CAUSE NOTICE, HEARING & REPLY
4.
Show Cause Notice dated October 25, 2013 (SCN), in terms of the
provisions of Rule 4 of SEBI (Procedure for Holding Inquiry and
Imposing
Penalties
by
Adjudicating
Officer)
Rules,
1995
(Adjudication Rules), was issued to the Noticee, calling upon the

Noticee to show cause why an inquiry should not be held against it
for the alleged violations.
5.
The aforesaid SCN was returned undelivered with endorsement

"party left". The same was later sent through S.P.A.D to the director
of the Noticee, Shri Daxesh Chandrakant Patel. There was no
response from the Shri Patel either. In the absence of any reply to
the SCN received from the Noticee/director, it was decided to
conduct inquiry in the matter and an opportunity of personal hearing
was granted to the Noticee on February 07, 2014. Simultaneously,
Notice dated January 16, 2014 was sent to Shri Daxesh
Page 2 of 16
Chandrakant Patel also intimating the personal hearing scheduled

for February 07, 2014.
6.
In response to the said letter, Shri Daxesh Chandrakant Patel, vide

letter dated February 03, 2014 and vide e-mail dated February 05,
2014, intimated that he was not in receipt of SCN as stated in the
letter dated January 16, 2014. Vide letter dated February 21, 2014,
copy of the SCN along with Annexure was sent to Shri Daxesh
Chandrakant Patel which was duly served on him. Soft copy of the
SCN was also sent to Shri Daxesh Chandrakant Patel at
pateldcin@gmail.com. Again, there was no response from the
Noticee nor from Shri. Patel. One more opportunity was given to
the Noticee by affixing SCN/Hearing Notice at the last known
address of the Noticee i.e,
"Precise Consulting & Engineering
Private Limited, E-2, Sainath Wadi, Nari Seva Sadan Road,

Ghatkoper (W), Mumbai - 4000084". As a matter of abundant
caution, a copy of the SCN was sent to the Noticee through
Registered Post Acknowledgement Due and the same was also
returned undelivered.
7.
In the meanwhile, vide letter dated July 03, 2014, Shri Daxesh
Chandrakant Patel, again informed that the he was not in receipt of
the SCN and requested for a copy of the SCN. In response, vide
letter dated July 14, 2014, copy of the SCN along with Annexure
was once again forwarded to him and soft copy of the SCN was
sent to pateldcin@gmail.com. Here again, the Noticee/Director
failed to respond. In order to proceed further in the matter,
opportunity of personal hearing was once again granted to the
Noticee and the hearing was scheduled for September 10, 2014
when Shri S.L Jain, Chartered Account appeared as Authorised
Representative (AR) on behalf of the Noticee. The AR submitted
Page 3 of 16
that the Noticee was not in receipt of the SCN. A copy of the SCN
was made available to the AR during the personal hearing and it
was advised that reply if any, to the SCN, be filed positively within
14 days. Vide letter dated September 24, 2014, the Noticee filed
reply to the SCN.
8.
Pursuant to the reply to the SCN, copies of certain additional

documents were furnished to the Noticee vide letter dated
November 10, 2014. The Noticee was given 14 days time to file
additional submissions, if any. Vide the said letter, the Noticee was
also granted an opportunity of personal hearing on November 25,
2014 when Shri S.L Jain, Chartered Account appeared as AR and
re-iterated the submissions already made vide letter dated
September 24, 2014. The AR also made a request for crossexamination of the Additional Controller of Stamps, Mumbai, whose
letter dated March 22, 2014 was relied upon in the instant
proceedings.
ISSUES FOR CONSIDERATION
9.
I have carefully perused the material available on record, written

and oral submissions made by the Noticee. The issues that arise
for consideration in the instant case are:
a) Whether the Noticee has violated provisions of Section 11C(2)

and 11C(3) of the SEBI Act?
b) Whether the Noticee is liable for monetary penalty under

Section 15A(a) of the SEBI Act?
Page 4 of 16
c) What quantum of monetary penalty should be imposed on the

Noticee taking into consideration the factors mentioned in
Section 15J of the SEBI Act?
10.
The relevant provisions of SEBI Act are as under:

Section 11C(2) and Section 11C(3) of the SEBI Act.
Section 11C(2): Without prejudice to the provisions of sections 235 to 241
of the Companies Act, 1956 (1 of 1956), it shall be the duty of every
manager, managing director, officer and other employee of the company
and every intermediary referred to in section 12 or every person associated
with the securities market to preserve and to produce to the Investigating
Authority or any person authorised by it in this behalf, all the books,
registers, other documents and record of, or relating to, the company or, as
the case may be, of or relating to, the intermediary or such person, which
are in their custody or power.
Section
11C(3):
The
Investigating
Authority
may
require
any
intermediary or any person associated with securities market in any

manner to furnish such information to, or produce such books, or
registers, or other documents, or record before him or any person
authorised by it in this behalf as it may consider necessary if the
furnishing of such information or the production of such books, or
registers, or other documents, or record is relevant or necessary for the
purposes of its investigation.
11.
I note that the company came out with an IPO of its shares to raise
`. 36,85,00,000 through the issue of 33,50,000 equity shares of
`.10 with a premium of `. 100/- through 100% book building route.
The IPO opened for subscription on September 28, 2011 and
closed on October 04, 2011 The shares of the company were listed
Page 5 of 16
on October 17, 2011 on the Bombay Stock Exchange Limited

(BSE) and the National Stock Exchange Limited (NSE).
12.
On noticing suspicious transfer of the proceeds of IPO of the

company to certain entities including the Noticee herein, SEBI
conducted investigation into the matter of IPO. During the fact
finding process of the IA, summons dated February 01, 2012
(summons) was issued to the Noticee under section 11C(2) & (3)
of the SEBI Act summoning it to furnish following documents:
I.
AGM/EGM meeting minutes for 2010 and 2011
II.
Board meeting minutes for 2010 and 2011
III.
Annual reports for the last three years i.e. 2009, 2010 and
2011
IV.
Details of major clients/customers, give complete contact

details for all of them
V.
Shareholding pattern for the last three years;
VI.
Leave and license agreements for the last three years if the
office property is leased
VII.
Details of all bank account statement of the Noticee for the

last two years
VIII.
IX.
Change in directorship across the years

Copies of telephone bills for the last three years and copies
of income tax returns for the last three years.
13.
The investigation had brought out that certain documents submitted

by the Noticee in response to the summons were false/forged. It
was, therefore, alleged in the SCN that the "leave and license
agreement" furnished by the Noticee in response to the summons
was false /forged. It was also stated in the SCN that the stamp
paper on which the said "leave and license agreement" was
Page 6 of 16
entered/executed was issued by General Stamps Office in

September 2011 only, whereas, the said agreement was allegedly
executed/entered in 2009.
14.
In response to the allegation leveled in the SCN, the Noticee made

the following main submissions:
I.
It is denied that the leave and license agreement furnished

by the Noticee was false/forged.
II.
It is incomprehensible as to on what basis it has been

contended that the stamp papers used in the execution of
agreement were issued by the General Stamps Office in
September, 2011.
III.
The allegations in the SCN are bald and sweeping and in

this regard the Noticee has cited judgments namely (i)
Canara Bank and Others vs Debasis Das and others (2003)
4 SCC 557(ii) Swaraganaga Trading private Limited vs SEBI
(SAT Appeal no. 74 of 2009) (ii) Commissioner of Central
Excise, Bangalore vs Brindavan Beverages (P) Limited and
Others 5 SCC 388 and (iv) Dilip Pendse vs SEBI (SAT
Appeal No. 80 of 2009)
I also note that during the personal hearing held on

November 25, 2014, the AR of the Noticee has made a
request for cross - examination of
Addl. Controller of
Stamps, Mumbai.
15.
On a careful analysis of the allegations in the SCN viz-a-viz the

submissions of the Noticee, I note that the issue for consideration is
Page 7 of 16
to determine as to whether the "leave and license agreement"

submitted by the Noticee in response to the summons issued by
the IA was forged/false and as to whether the same amounted to
non-furnishing of required information and thereby non-compliance
of the summons issued by the IA.
16.
I note that summons dated February 01, 2012 was issued to the
Noticee by IA seeking information/documents as mentioned herein
above at paragraph 12. Also, it is on record that the Noticee did
respond to the summons vide letter dated February 10, 2012 and
submitted certain documents to the IA which includes the "leave
and license agreement" dated December 01, 2009.
17.
I note that, as mentioned above, it was alleged in the SCN that the
"leave and license agreement" was dated December 01, 2009
where as the stamp paper on which the said agreement executed
was issued by General Stamps Office in September, 2011 only.
The said allegation was based on the letter dated March 22, 2012
received by the IA from Addl. Controller of Stamps, Mumbai.
18.
In response to the allegations, the Noticee has contended that the

allegations in the SCN were baseless and were without any
supporting evidence. In this regard, I note that the allegation that
the "leave and license agreement" dated December 01, 2009
submitted by the Noticee in response to the summons issued by
the IA was forged/false, was based on the letter dated march 22,
2014 received by the IA from the Add. Controller of Stamps. The
said letter of Addl. Controller of Stamps was duly made available to
the Noticee. Therefore, I do not find any merit in the argument that
the allegations in the SCN is baseless and were without any
supporting documents. I have also perused the judgments cited by
Page 8 of 16
the Noticee in this regard. I find that the judgments cited by the
Noticee would be of no assistance to it since the SCN in the instant
matter is a self contained document and all the supporting material
has also been made available to the Noticee.
19.
Further, the Noticee has made a request for cross -examination of

Addl. Controller of Stamps, whose letter dated March 22, 2012 was
relied upon in the SCN. The right to cross examine a 'witness' is
part of "right to hear", one of the corner stones of principles of
natural justice. However, I note that the said right is not an absolute
right and the same should not be granted routinely or for the
asking, without making out a case by the Noticee concerned as to
why cross-examination of a witness was required. In other words,
the prejudice caused to a Noticee by not having cross-examined a
witness should be clearly brought out. In this regard reliance is
placed on the observation of the Apex Court, in the matter of
Transmission Corporation of A. P. Ltd. and others vs. Shri Rama
Krishnan Rice Mill (2006) 3 SCC wherein it is stated that:"...........In
order to establish that the cross-examination is necessary, the
consumer has to make out a case for the same. Merely stating that
the statement of an officer is being utilized for the purpose of
adjudication would not be sufficient in all cases". In the instant
case, I note that the contents of the letter dated March 22, 2012 of
the Addl. Controller of Stamps has not been disputed by the
Noticee. The Noticee has only made a request for cross
examination of the office and that too only to ascertain the series
nos. of stamp papers issued in 2009.
20.
In this regard, I find that letter dated March 22, 2012 clearly
mentions the following two dates with specific reference to stamp
Page 9 of 16
paper referring serial no. EW 671450 on which the "leave and

license agreement" in question was executed:
September 14, 2011 as the date when the stamp paper

came from Nasik Printing Press.
September 21, 2011 as the date of supply of stamp paper,

by the office of Controller of Stamps to the
local stamp
vendor.
Thus, the letter dated March 22, 2012 clearly mentions the
date of issuance of stamp paper in question which is much
later than the alleged date of execution. Further, the Noticee
has not made it clear as to what purpose would be served,
by knowing the series nos. of stamp papers issued in 2009
through cross examination of the concerned officer. Hence,
I am of the view that the Noticee had not made out case as
to why the cross examination is required and how it is
prejudiced by not having the officer concerned cross
examined.
21.
Further, in common parlance, cross - examination is granted when

the statement of a witness is recorded during investigation or a
person has been called as a witness. In the instant case, I note that
reliance has been placed only on the letter issued by the Addl.
Controller of Stamps and no statement of the said officer has been
recorded. Nor has the said officer been called as a witness during
the investigation.
22.
Therefore, I find that the request of the Noticee for cross

examination, is devoid of merit and is nothing but a tactic used by it
to dodge the proceedings which have already been delayed due to
Page 10 of 16
the non-cooperative attitude of the Noticee to respond to the SCN

on time as discussed in the preceding paragraphs.
23.
Now, I deal with issue as to whether the Noticee has furnished the
required information in compliance with the summons issued by the
IA. Admittedly, summons had been issued to the Noticee for
furnishing certain information/documents as per the details
contained in Annexure to the summons which has been reproduced
hereinabove at para no. 12 above. As mentioned above, the
Noticee had submitted, in response to the summons, certain
documents, vide letter dated February 10, 2012. In this regard, I
note that the allegation in the SCN was that the "leave and license
agreement" submitted by the Noticee was false and forged. The
stamp paper on which the said "leave and license agreement" was
allegedly executed on December 01, 2009, was actually printed
and issued in September 2011. It is certainly not possible to
enter/execute any agreement/document in 2009 on a stamp paper
which was in fact issued in 2011 i.e almost 22 months after the
execution/entering of the agreement. Such a document is
undoubtedly a forged/false document. In general parlance, a false
document is one of which a material portion is purported to have
been made or authorized by someone who did not do so or a
document that is falsely dated or which has allegedly been made by
or on behalf of someone who did not in fact exist. Moreover, I have
no reason to disbelieve the contents of letter dated March 22, 2012
issued by Addl. Controller of Stamps. Thus, I am of the view that
the 'leave and license agreement furnished by the Noticee to the IA
in response to the summons dated February 01, 2012 was indeed a
false and forged information.
Page 11 of 16
24.
Having concluded that the 'leave and license agreement' submitted

by the Noticee was false/ forged, now the question that arises as to
whether the information/documents as furnished by the Noticee
would amount to 'furnishing of required information' in compliance
with the summons issued by the IA. I note that seeking of
information from various individuals / entities during investigation is
of great importance in the fact finding process of investigation and
furnishing of false/forged/complete information serve no purpose on
the one hand and on the other, it would frustrate the entire process
of investigation. Further, such false/forged/incomplete information
would not only lead to misleading conclusions by the IA which
would ruin the entire investigation but also delay the process by
acting as a severe handicap in arriving at just and reasonable
conclusion within a reasonable period of time. In this regard,
reliance is being placed on the order of Hon'ble Securities Appellate
Tribunal (SAT) in the matter of M/s Bubna Stock Broking Services
Limited vs SEBI (decided on 04.11.2009) wherein it was stated
thus: "............ incomplete information furnished by the appellant amounts
to non-furnishing of the information within the meaning of section 15A(a)
of the Act and it thwarted the investigations. This is, indeed, a serious
matter. Market intermediaries and market players cannot be allowed to
hinder the investigations by not furnishing the necessary information
asked for. The Board as a market regulator cannot perform its statutory
functions if market players do not co-operate with it in the matter of
investigations and it is for this reason that the Parliament in wisdom
amended the provisions of the Act and enhanced the penalties
considerably for non c-operation. Since the appellant did not co-operate
in the investigations in, as much as, it failed to furnish the requisite
information/documents, the adjudicating officer was justified in imposing
the monetary penalty". I also rely on the observation of Hon'ble SAT
in the matter of Siddhartha Agarwal vs. Adjudicating Officer, SEBI;
Page 12 of 16
decided on 26-11-2008 wherein it observed that Making a

false statement would amount to failure to furnish the information sought
and would attract section 15A(a) of the Act.. Therefore, furnishing
of 'false/ forged information' clearly amounts
'not furnishing the
required information' and is in fact more serious than 'nonfurnishing' of information.
In view of the above, I find that the
Noticee, by furnishing false and forged information/documents in

response to the summons issued by IA, has failed to comply with
the summons.
25.
In the instant matter, investigation was conducted on noticing

suspicious transfers of IPO proceeds to certain entities including
the Noticee. I note that the company had diverted a sum of `.12
crore i.e, 32% of the IPO proceeds to the Noticee. The information
which was sought from the Noticee was very crucial for the IA to
know the exact role played by the Noticee in the said diversion of
IPO proceeds. Had complete and correct information been provided
at the relevant time i.e, during investigation, then it would have
been possible for the IA to dig out and bring into light more facts
relevant to the investigation. I find that furnishing of false and
forged documents in response to the summons has hampered the
investigation to a great extent. In this context, reliance is placed on
the observations of Hon'ble SAT in its Order dated January 07,
2009 in the matter of DKG Buildcon Private Limited Vs SEBI
wherein it stated that "..... It is of utmost importance that every person
from whom information is sought should fully co-operate with the
investigating officer and promptly produce all documents, records,
information as may be necessary for the investigations. If persons are
allowed to flout the summons issued to them during the course of the
investigations, the Board as the watchdog of the securities market will not
be able to perform its duties in protecting the interests of the investors and
Page 13 of 16
safeguarding the integrity of the securities market". Further, Regarding

the importance of compliance of summons issued by IA, SAT has,
in the matter of Brijlaxmi Leasing & Finance Ltd. vs. SEBI, decided
on 07-06-2010, observed that if the required information had
been furnished, it is possible that many more things could have been
revealed. Since the information was withheld, we are satisfied that the
appellants did not cooperate with the investigating officer and hampered
the investigations".
26.
In view of the discussions above, I conclude that the act of

furnishing false/forged/incomplete documents by the Noticee in
response to the summons issued to it by the IA, resulted in nonfurnishing of information which tantamount to non-compliance of
the summons issued by the IA.
The Noticee has, therefore,
violated the provisions of Section 11C(2) & (3) of SEBI Act.
Whether the Noticee is liable for monetary penalty under

Section 15A(a) of the SEBI Act?
27.
In the matter of SEBI Vs. Shri Ram Mutual Fund [2006] 68 SCL 216
(SC), the Honble Supreme Court of India has held that In our
considered opinion, penalty is attracted as soon as the contravention of
the statutory obligation as contemplated by the Act and the regulation is
established......"
28.
As the violation as mentioned above has been established, I am

convinced that it is a fit case for imposing monetary penalty under
section 15A(a) of the SEBI Act which reads as under:
Page 14 of 16
SEBI Act
Penalty for failure to furnish information, return, etc.:
Section 15A If any person, who is required under this Act or any rules or
regulations made there under,
(a) to furnish any document, return or report to the Board, fails to furnish the
same, he shall be liable to a penalty of one lakh rupees for each day during
which such failure continues or one crore rupees, whichever is less.
What quantum of monetary penalty should be imposed on the

Noticee taking into consideration the factors mentioned in
Section 15J of the SEBI Act?
29.
While imposing monetary penalty it is important to consider the

factors stipulated in Section 15J of the SEBI Act, which are:
Factors to be taken into account by the adjudicating officer

(a) the amount of disproportionate gain or unfair advantage, wherever
quantifiable, made as a result of the default;
(b) the amount of loss caused to an investor or group of investors as a result
of the default;
(c) the repetitive nature of the default.
30.
In
the
absence
of
material
on
record,
the
amount
of
disproportionate gain or unfair advantage made as a result of the

default and the amount of loss caused to the investors due to the
said default cannot be quantified. However, the Noticee has, by
submitting false and forged information, willfully and deliberately
failed to cooperate with the IA which hampered the investigation.
The same deserves to be viewed seriously.
Page 15 of 16
ORDER
31.
After taking into consideration all the facts and circumstances of the
case, I, in exercise of the powers conferred upon me under section
15-I(2) of the SEBI Act, hereby impose a penalty of ` 10,00,000/(Rupees Ten Lakh only) under Section 15A(a) of SEBI Act for
violation of Section 11C(2) & (3) of the SEBI Act on the Noticee,
Precise Consulting & Engineering Private Limited.
32.
The penalty shall be paid by way of demand draft drawn in favour

of SEBI Penalties Remittable to Government of India payable at
Mumbai within 45 days of receipt of this Order. The said demand
draft shall be forwarded to the Division Chief, Enforcement
Department - DRA- IV, Securities and Exchange Board of India,
Plot No. C4-A, G Block, Bandra Kurla Complex, Bandra (E),
Mumbai 400051.
33.
In terms of the provisions of Rule 6 of the Rules, copies of this

order are being sent to the Noticee and also to SEBI.
DATE: December 23, 2014

PLACE: Mumbai
A SUNIL KUMAR
ADJUDICATING OFFICER
Page 16 of 16

Adjudication Order in Respect of Precise Consulting & Engineering Private Limited in The Matter of Onelife Capital Advisors Limited.

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BEFORE THE ADJUDICATING OFFICER

SECURITIES AND EXCHANGE BOARD OF INDIA

documents/information, thereby failed to comply with the said

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2. Therefore, SEBI initiated adjudication proceedings against the

APPOINTMENT OF ADJUDICATING OFFICER

Shri Piyoosh Gupta was appointed as Adjudication Officer (AO),

SHOW CAUSE NOTICE, HEARING & REPLY

(Adjudication Rules), was issued to the Noticee, calling upon the

The aforesaid SCN was returned undelivered with endorsement

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Chandrakant Patel also intimating the personal hearing scheduled

In response to the said letter, Shri Daxesh Chandrakant Patel, vide

"Precise Consulting & Engineering

Private Limited, E-2, Sainath Wadi, Nari Seva Sadan Road,

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Pursuant to the reply to the SCN, copies of certain additional

ISSUES FOR CONSIDERATION

I have carefully perused the material available on record, written

a) Whether the Noticee has violated provisions of Section 11C(2)

b) Whether the Noticee is liable for monetary penalty under

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c) What quantum of monetary penalty should be imposed on the

The relevant provisions of SEBI Act are as under:

intermediary or any person associated with securities market in any

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on October 17, 2011 on the Bombay Stock Exchange Limited

On noticing suspicious transfer of the proceeds of IPO of the

AGM/EGM meeting minutes for 2010 and 2011

Board meeting minutes for 2010 and 2011

Details of major clients/customers, give complete contact

Shareholding pattern for the last three years;

Details of all bank account statement of the Noticee for the

Change in directorship across the years

The investigation had brought out that certain documents submitted

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entered/executed was issued by General Stamps Office in

In response to the allegation leveled in the SCN, the Noticee made

It is denied that the leave and license agreement furnished

It is incomprehensible as to on what basis it has been

The allegations in the SCN are bald and sweeping and in

I also note that during the personal hearing held on

On a careful analysis of the allegations in the SCN viz-a-viz the

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to determine as to whether the "leave and license agreement"

In response to the allegations, the Noticee has contended that the

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Further, the Noticee has made a request for cross -examination of

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paper referring serial no. EW 671450 on which the "leave and

September 14, 2011 as the date when the stamp paper

September 21, 2011 as the date of supply of stamp paper,

Further, in common parlance, cross - examination is granted when

Therefore, I find that the request of the Noticee for cross

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the non-cooperative attitude of the Noticee to respond to the SCN

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Having concluded that the 'leave and license agreement' submitted

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decided on 26-11-2008 wherein it observed that Making a

'not furnishing the

required information' and is in fact more serious than 'nonfurnishing' of information.