Professional Documents
Culture Documents
Interim Order in The Matter of Suvidha Farming and Allied Limited
Interim Order in The Matter of Suvidha Farming and Allied Limited
/02 /2015
in
the
matter
of
Suvidha
Farming
and
Allied
Limited
PAN:AJAPR9252L),
Shri
Pardeshi
Ram
(DIN:03118992;
PAN:AVGPS2415J), Shri Jagdish Bisvas (DIN:03119157) and Shri Rajneesh Dutta (DIN:
06736734; PAN:ALEPD7075R)
___________________________________________________________________________
1. Securities and Exchange Board of India (hereinafter referred to as "SEBI") received a
complaint
on October 07, 2013 alleging that Suvidha Farming & Allied Limited has
mobilized Rs.600 crores from public by violating CIS Regulations of SEBI. The complainant
provided certain documents in respect of Suvidha Farming & Allied Limited (hereinafter
referred to as "SFAL") and its group company Suvidha Land Developers India Limited and
requested for investigation by SEBI. The case of Suvidha Land Developers India Limited is
being examined separately by SEBI.
2. SEBI, vide letters dated October 24, 2013, sought the following information / documents
from SFAL and its Directors in order to ascertain whether or not SFAL is carrying on
'Collective Investment Schemes' in terms of Section 11 AA of the SEBI Act, 1992 (hereinafter
referred to as "SEBI Act") :
a. Memorandum and Articles of Association of the Company as filed with the
concerned Registrar of Companies ("RoC");
b. Details of the past and present directors of the company;
c. Brochures pertaining to SFAL's schemes/ offers which were made available to the
public.
Page 1 of 21
Copy of Income Tax Return filed by SFAL for the last three years.
j.
k. Details of any other similar scheme(s), if any, floated by SFAL or its group/associates
company.
3. As the aforesaid letters sent to the registered office, regional office and head office of SFAL
were returned undelivered, a SEBI official visited the registered office address of SFAL on
December 18, 2013 when SEBI's letter dated October 24, 2013 was received by SFAL.
During the visit, the following information was gathered:
a. SFAL's office was operational and Shri.R. Sarothia was in-charge.
b.
Page 2 of 21
a. Name, address of each investor and amount deposited by each of them with plan
details & date of investment (from start of company till date);
b. Details of how many persons have been refunded the amount after expiry of
agreement;
c. In case amount taken from investor, details for amount appropriated by SFAL with
reasons;
d. Amount outstanding to each investor;
e. Address of all branches operating in India;
f. Copies of duly filled in application form, registration certificate, agreement executed
in respect of any two investors of each plan offered by SFAL;
g. Details of all the assets purchased from the funds mobilized from public;
h. List of all the bank accounts of SFAL (including name of branch of bank) from start
till date;
i.
j.
k. Provide list of all group companies/companies under same management and inform
about the activities performed by them with their addresses;
5. SFAL, vide fax letter dated February 04, 2014 sought additional time till February 18, 2014 to
submit the information/documents. Subsequently, vide letters dated February 17, 2014,
March 24, 2014 and March 31,2014, SFAL inter alia provided copies of Memorandum and
Articles of Association, list of past and present Directors, addresses of branches operating in
India, copies of application forms and certificates issued to Joint Venturers, list of bank
accounts, details of scheme-wise amount mobilized by the company, details of refund after
expiry of agreement, brief note on utilisation of amount received from the investors, details
of investments, copies of audited financial statement for the financial years 2009-10, 2010-11,
2011-12, 2012-13, copies of income tax return for financial year 2010-11, 2011-12, brief note
on accidental help provided to investors, list of group companies, and some data on
investors.
6. On perusal of the documents submitted by SFAL, SEBI, vide letter dated July 08, 2014,
sought clarifications /documents from SFAL with regard to the following observations :
a. The names of investors indicated in the copies of application forms and certificates
were not reflected in the data on investors.
Page 3 of 21
b. The details of year-wise amount mobilized did not tally with the total amount paid
by investors as per the data on investors. SFAL later advised that the difference is
on account of some deposits repaid on maturity.
c. The Customer Service Centre (CSC) address indicated in certificates issued to two
investors were not reflected in the list of nine branches submitted by SFAL.
d. SFAL had submitted details of repayments made to investors on maturity. SFAL
was advised to provide a certificate from the management as well as auditor
certifying the repayments to investors as per the list provided to SEBI. This has not
been done till now.
e. As per the audited financial statements as on March 31, 2013 submitted by SFAL,
an amount of `3,53,04,947/-was indicated as expenses towards "ORC Commission".
SFAL was advised to provide the list of all its agents (with their designation &
address) along with year-wise commission paid from start till date.
f. SFAL was also advised to provide copy of documents evidencing their submission
of investments (in land, gold and FDRs) made from funds mobilized from public.
7. In response, SFAL vide letter dated July 16, 2014 enclosed one CD containing scanned copy
of their reply, copies of few registries towards land purchase and sought a week's time to
provide comprehensive details with respect to agents and commission paid. In addition,
SFAL also made the following submissions:
"
a) The figures reported to you vide our letter dated March 24,2014 were the actual amounts collected.
b) As regards the discrepancies pointed out by you we would like to present to you that they were the result
of honest omissions and commissions which occurred because of the fact that the information presented was
culled out of a very large database within a very short span of time resulting in the inaccuracies pointed
out by you. ........... We are in the process to settle all maturity month wise after taking mandate from our
client individually...
c) As regards the certificates issued by us to......... the address which is printed on the certificates, is an old
branch address of the company which was shifted in June 2013 to the current address ...."
SFAL vide emails dated July 19, 2014 also provided copy of documents to show that they
have 4 properties in Dehradun, Uttrakhand.
Page 4 of 21
Shri
02444466;PAN:AJAPR9252L)
PAN:ALEPD7075R).
Rajendra
and
Further,
Shri
Shri
Karn
Rajpoot
(DIN:
Rajneesh
Dutta
(DIN:06736734;
Pardeshi
Ram
(DIN:03118992;
PAN:AVGPS2415J) was director from 16/7/2010 till 01/12/2013 and Shri Jagdish
Bisvas (DIN:03119157) was director from 16/7/2010 till 24/6/2011).
c) As per the MoA of SFAL, its main object is "to carry on in India or else where the business
to own, lease, manage, run, establish and develop dairy and dairy farms and for this purpose to buy,
sell, trade breed, provide financial assistance, import, export, grow, produce, keep and deal in all
types of cattle including cows, buffaloes, she goats, sheep and to nourish, cherish and nurse them to
extract milk and also to act as dairyman, gardener, breeder, milk collector, milk vendor and use the
milk for manufacturing various dairy products. "
d) A perusal of the various brochures submitted by the complainant provides the
following details:
One brochure, inter alia, provides details of various "Joint Venture Plans" for
purchase of cattle/ goat (of quantity 1 to 10), expected sum payable on expiry of
Page 5 of 21
term and Accidental Help (A/H) provided by SFAL to investor's nominee. The
plans indicated are :
i.
various plans in this category are S-1 for 12 months, S-2 for 24 months, S-3 for
36 months, S4 for 48 months, S-5 for 60 months, S-6 for 75 months, S-7 for 84
months, S-8 for 96 months, S-9 for 120 months, S-10 for 84 months, Plan SFM2
for 180 months having return value after 3 years, 6 years, 9 years, 12 years.
ii.
Lumpsum Payment Plan: The various plans in this category are S-F1 for 3
years, S-F2 for 6 years, S-F3 for 6 years, S-F4 for 8 years, S-F5 for 10 1/2 years,
SFM-1 MIS for 6 years, SF-6 for 6 years, SF-7 for 8 years, SFM3 MIS for 6 years.
The sample plan table for one Installment Payment Plan and Lumpsum Payment
Plan is given below:Installment Payment Plan No. S-4 for 4 Years or 48 Months:
No. of
Cost of
Installment No.
Cattle
Cattle/ MLY
QLY
/ Goat
Goat
48
16
HLY
8
Expected Sum
A/H
YLY
payable on
(Accidental
expiry of term
Help)
cattle
2
4800
100
295
580
1150
7250
4800
9600
200
590
1160
2300
14500
9600
14400
300
885
1740
3450
21750
14400
19200
400
1180
2320
4600
29000
19200
10
24000
500
1475
2900
5750
36250
24000
12
28800
600
1770
3480
6900
43500
28800
14
33600
700
2065
4060
8050
50750
33600
16
38400
800
2360
4640
9200
58000
38400
18
43200
900
2655
5220
10350
65250
43200
20
48000
1000
2950
5800
11500
72500
48000
Page 6 of 21
Cattle/
Cow
Sum
payable on expiry of
Cow
A/H
(Accidental
Help)
6000
12300
6000
12000
24600
12000
18000
36900
18000
24000
49200
24000
30000
61500
30000
36000
73800
36000
42000
86100
42000
48000
98400
48000
54000
110700
54000
10
60000
123000
60000
ii.
SFAL has various plans for Joint Ventures in LumpSum Payment and
Installment Payment Plans and as per these plans, the investor
chooses the cattle and after all formalities are completed, SFAL issues
the allotment letter for cattle to the investor (investor termed as 'Joint
Venturer'). After completion of the stipulated time frame, the investor
can either opt to get the cattle in his name or the specified money as
per the plan opted. As per these plans, the rearing of cattle takes
place in SFAL's farm houses.
iii.
The investor also has the option of emergency loan service after 12
months on 60% of amount paid.
iv.
Page 7 of 21
The terms and conditions of the application form inter alia states:
"Joint Venture must be an Indian National.......
The company shall issue Certificate on the basis of Application Form.....
Joint Venture shall be repaid on Maturity of Term only.....
Minors can apply through their parents/guardian. Application in the name of minor must
be signed by his/her/their natural parent(s)...."
The General Terms and Conditions in the Certificate issued by SFAL inter
alia states:
"Special Provisions for refund in case of natural Death: In case of natural death of a Joint
Venture or the Nominee of legal Representative /Successor may have the refund as specified
in Rule Book, as amended from time to time.
Accidental Death Compensation: The Joint Venture (s) shall be eligible for compensation
in the event of accidental death as per Rule Book, as amended from time to time."
SFAL has branches in 9 locations and 21 bank accounts with HDFC Bank,
Axis Bank, ICICI Bank, Yes Bank, Bank of India and Vijaya Bank.
Page 8 of 21
ii.
iii.
As per the plan-wise amount mobilized by SFAL, detailed below, SFAL has
mobilized an amount of approximately `28.22 crores from 2,69,905 investors
during the financial years 2010-11 to 2013-14 :
Page 9 of 21
2010-11
Plan Code
No. of investor
S1
2970
10
S10
44552
63
S2
1682
10
S3
44856
151
S4
34195
111
S5
3483177
6646
S6
484852
672
S7
40271
34
S8
63490
72
S9
16597
40
SF1
65679
SF2
145577
13
SF3
575395
23
SF4
943680
36
SF5
543605
19
SF6
1128210
42
SF7
1318415
58
SFM2
19989
10
SFM3
1889505
21
10846697
8034
Grand Total
Page 10 of 21
2011-12
Plan Code
S1
No. of investors
9523
33
S10
132164
192
S2
52631
57
S3
713101
1314
S4
308470
625
S5
12019671
33230
S6
4551888
5219
S7
269006
259
S8
160781
452
S9
115121
134
SF1
553105
29
SF2
789002
106
SF3
2002745
109
SF4
1621100
100
SF5
5128620
192
SF6
8442490
258
SF7
6194365
298
SF8
1432170
39
SFM1
112810
SFM2
330162
100
SFM3
8479275
95
53418200
42843
Grand Total
Page 11 of 21
2012-13
Plan Code
No. of Investors
S1
140548
220
S10
235160
317
S2
168443
275
S3
1971105
3885
S4
595020
962
S5
35856561
57665
S6
11124827
15296
S7
655172
550
S8
242898
416
S9
311552
310
SF1
1237965
57
SF2
1219065
165
SF3
1999335
123
SF4
3788315
223
SF5
4968600
216
SF6
15091495
519
SF7
19849415
733
SF8
6065725
260
SFM2
567739
232
SFM3
10843560
132
116932500
82556
Grand Total
Page 12 of 21
No. of Investors
S1
969213
1094
S10
522140
586
S2
255788
415
S3
2970417
5603
S4
597788
1120
S5
51654215
102300
S6
14699508
22212
S7
998060
924
S8
234144
419
S9
314494
343
SF1
530338
26
SF2
137439
27
SF3
212745
21
SF4
2077895
79
SF5
775945
41
SF6
5315130
226
SF7
9409815
613
SF8
1892560
107
SFM2
578726
228
SFM3
6896240
88
101042600
136472
Grand Total
iv.
As per the audited financial statement as on March 31, 2010, March 31, 2011,
March 31, 2012 and March 31, 2013 submitted, it is observed as follows:
The details of fund mobilization and their utilization (as apparent from the
audited financial statements) are as under:
Page 13 of 21
As on March 31,
2011
(`)
Major Liabilities
Advance received from
customers
Major Assets
1,08,46,697.00
6,41,06,191.00
17,77,21,932.00
Tangible Assets
13,77,496.00
2,00,83,102.00
2,91,09,536.00
Bank balance
51,13,327.32
2,02,04,395.13
2,45,95,387.53
Cash in hand
5,63,047.00
11,21,508.00
12,03,513.00
4,23,86,546.31
5,21,200.00
23,47,115.00
76,24,711.92
Investments
Other current assets (mainly
loan & advances)
14,64,637.00
Commission payable
Total Commission
14,64,637.00
2012-13 (`)
2011-12 (`)
2,04,94,871.00
3,53,04,947.00
41,63,249.00
4,59,992.00
2,46,58,120.00
3,57,64,939.00
2012-13 (`)
22,01,500.00
23,56,200.00
Trading in Goatry
21,20,050.00
20,51,850.00
43,21,550.00
44,08,050.00
v.
Page 14 of 21
vi.
SFAL has also provided a list of its group companies comprising eleven
entities and M/s Suvidha Land Developers India Limited is one of the group
entities. It is noted that the Shri Vinod Kumar Shankhwar and Shri Rajendra
Karn Rajpoot are the Directors in ten of these entities.
g) It is pertinent to mention here that the group entity of SFAL, viz. M/s Suvidha Land
Developers India Limited, against which a complaint has been received, have vide
their letter dated March 21, 2014, inter alia submitted: "M/s Suvidha Farming & Allied
Limited is one of the group company, which is raising funds from the Public...."
10. The aforementioned details of the Plans towards purchase of agricultural, barren lands,
cows, goats and sheep and of developing farms wherein the cows, goats and sheep are
reared and taken care ("Schemes") offered by SFAL to investors (termed as 'Joint Venturer')
have to be considered in light of the provisions of Section 11AA of the SEBI Act. The
aforesaid Section 11AA, which provides for the conditions to determine whether a scheme
or arrangement is a 'collective investment scheme', reads as under :
"(1) Any scheme or arrangement which satisfies the conditions referred to in sub-section (2) shall be a
collective investment scheme.
[Provided that any pooling of funds under any scheme or arrangement, which is not registered with the
Board or is not covered under the exemptions from CIS sub-section (3), involving a corpus amount of
one hundred Crore rupees or more shall be deemed to be a collective investment scheme.]
(2) Any scheme or arrangement made or offered by any person under which,
(i)
the contributions, or payments made by the investors, by whatever name called, are pooled and
utilized solely for the purposes of the scheme or arrangement;
(ii)
the contributions or payments are made to such scheme or arrangement by the investors with a view
to receive profits, income, produce or property, whether movable or immovable from such scheme or
arrangement;
(iii)
the property, contribution or investment forming part of scheme or arrangement, whether identifiable
or not, is managed on behalf of the investors;
(iv)
the investors do not have day to day control over the management and operation of the scheme or
arrangement.
Page 15 of 21
11. In the context of the abovementioned Section 11AA of the SEBI Act, the 'Schemes' offered
by SFAL is examined as under:
(i)
SFAL has
in their submissions stated that ".......The Company accept the advance from customer against the
product i.e. cattle and assured them certain returns.
Company purchases cattle, takes care of them and whatever the benefits accrue out of the cattle farming,
it will be shared to the customers.
an amount of `17,77,21,932/- has been received as "Advance from the Customers". From
a reading of SFAL's submissions, it is apparent that these "Advances from the Customers"
are later pooled and utilized for purchasing and rearing cattle. As the contributions
received from the investors under SFAL's various Plans are pooled for the purpose of
the 'Schemes', prima facie it is clear that the instant 'Schemes' satisfies the first condition
stipulated in Section 11AA(2) of the SEBI Act.
(ii) The contributions or payments are made to such scheme or arrangement by the
Plan No.S-4 for 4 years which is detailed in Point 9 on page 6 of this order, prima facie
for an investor paying an amount of Rs.100/- per month for 48 months for cattle/goat
Page 16 of 21
costing Rs.4,800/-, the expected sum payable on expiry of term is Rs.7,250/. The
investor can either opt to get the cattle or is assured of receiving a specified amount at
the expiry of term.
As stated in the brochure, SFAL provides Accidental Help (A/H) upto Rs.1,50,000/to the nominees and the investor also has the option of emergency loan service after 12
months on 60% of amount paid. Further, as per SFAL's submissions, ".....The A/H is
the financial assistance to the family/dependant... The said financial assistance is in nature of help and
Co. is not charging any extra / additional money for this..... ".
SFAL has also in their submissions stated that "....... The Company accept the advance from
customer against the product i.e. cattle and assured them certain returns. After getting advance from the
customer, the Company purchases cattle, takes care of them and whatever the benefits accrue out of the
cattle farming, it will be shared to the customers.
In light of the aforesaid, prima facie the nature of benefits receivable by the investor at
the expiry of term indicates an element of return for which money has been provided by
the investors to SFAL.
Page 17 of 21
the investor has no say in the purchase of land/cattle and SFAL collects the amount as
per the Plan opted by the investor in the application form.
Further, as stated in the brochure, the rearing of cattle takes place in SFAL's farm
houses and at the end of term of the Plan, the investor can either opt for the cattle or
the money assured. There is no clause in the terms and condition of the application
form/ registration certificate to show that the investor has any say in the management
of these Plans or towards purchase of land/cattle and rearing of cattle. In these facts
and circumstances, it is clear that the 'Schemes' are managed by SFAL on behalf of the
investors.
In view of above, it is clear that the investors do not have day to day control over the
management and operation of the 'Schemes.' I, therefore, find that the instant 'Schemes'
satisfies the third and fourth condition stipulated in Section 11AA(2) of the SEBI Act.
12. In the context of the 'Schemes' being in the nature of a ''Joint Venture', it may be relevant to
refer to the observations of the Honble Supreme Court of India in New Horizons Ltd. vs.
Union of India [1995(1) SCC 478] regarding the nature of a joint venture that:The expression joint venture. connotes a legal entity in the nature of a partnership engaged in the
joint undertaking of a particular transaction for mutual profit or an association of persons or
companies jointly undertaking some commercial enterprise wherein all contribute assets and share risks.
It requires a community of interest in the performance of subject matter, a right to direct and govern the
policy in connection therewith, and duty, which may be altered by agreement, to share both in profit and
losses. (Blacks law dictionary, sixth edition, p. 839).
13. It has further been illustrated by Honble Supreme Court in Faqir Chand Gulati vs. Uppal
Agencies Pvt. Ltd. {(2008)10SCC345} that An illustration of joint venture may be of some
assistance. An agreement between the owner of a land and a builder, for construction of apartments and sale
of those of apartments so as to share the profits in a particular ratio may be a joint venture, if the agreement
discloses an intent that both parties shall exercise joint control over the construction/ development and be
accountable to each other for their respective acts with reference to the project.
Page 18 of 21
14. Thus, it implies that the joint venture arrangement should be a genuine joint undertaking of a
particular transaction with share of both parties in profit and losses arising thereof.
Irrespective of the nomenclature the present 'Schemes', do not fall within the meaning of
Joint Venture since SFAL offers assured returns to investors irrespective of profit and
losses. Also, the element of joint control over the plans/cattle does not exist.
15. In view of the above analysis, it is apparent that the 'Schemes' offered by SFAL having
nomenclature Joint Venture is not a joint venture in accordance with law but rather such
term has been used by SFAL to camouflage its fund mobilizing activity which is in the nature
of a ''CIS' in order to mislead and attract investment from general public.
16. It is also disconcerting that the total "Commission paid/payable to agents" viz.,`6.19 Crores is
approximately 35% of the amount of `.17.77 Crores collected in three years indicated as
"Advance received from customers" as on March 31,2013 (details in page 14 above of this order).
Prima facie, it appears that a significant portion of the moneys collected as "Advance received
from customers" is utilized for payment of Commission to agents for their role in attracting
investors to invest in the various Schemes/ Plans offered by SFAL.
17. In this context, it may be relevant to refer to the observations made by the Honble Supreme
Court of India in P.G.F. Limited & Ors. Vs. UOI & Anr. (MANU/SC.0247/2013),
wherein it was stated: ...sub-section (2) of Section 11AA, which defines a collective investment scheme
disclose that it is not restricted to any particular commercial activity such as in a shop or any other commercial
establishment or even agricultural operation or transportation or shipping or entertainment industry etc. The
definition only seeks to ascertain and identify any scheme or arrangement, irrespective of the nature of business,
which attracts investors to invest their funds at the instance of someone else who comes forward to promote such
scheme or arrangement in any field and such scheme or arrangement provides for the various consequences to
result therefrom.
18. In the light of the above analysis and examination, it is clear that the activity of fund
mobilization by SFAL with a promise of returns prima facie satisfies all four conditions
specified in Section 11AA (2) of the SEBI Act and hence falls within the ambit of 'Collective
Investment Schemes' as defined under Section 11AA of the SEBI Act.
Page 19 of 21
19. I note that in terms of Section 12(1B) of the SEBI Act, "no person shall sponsor or cause to be
sponsored or cause to be carried on a 'collective investment scheme' unless he obtains a certificate of registration
from the Board in accordance with the regulations. Regulation 3 of the SEBI (Collective Investment
Schemes) Regulations, 1999 (hereinafter referred to as "CIS Regulations") also prohibits
carrying on CIS activities without obtaining registration from SEBI. Therefore, the
launching/ floating/ sponsoring/causing to sponsor any 'collective investment scheme' by any
'person' without obtaining the certificate of registration in terms of the provisions of the CIS
Regulations is in contravention of Section 12(1B) of the SEBI Act and Regulation 3 of the
CIS Regulations. In this regard, I note that SFAL has not obtained any certificate of
registration from SEBI under the CIS Regulations for its fund mobilizing activity from the
public, under the instant 'Schemes' offered by it.
20. I also find that the fund mobilizing activity of SFAL prima facie, amounts to a fraudulent
practice in terms of Regulation 4(2)(t) of the SEBI (Prohibition of Fraudulent and Unfair
Trade Practices Relating to Securities Market) Regulations, 2003 ("PFUTP Regulations").
21. Protecting the interests of investors is the first and foremost mandate for SEBI and
therefore, steps have to be taken to ensure that SFAL does not collect further funds under its
'Schemes' and no investors are defrauded. Further, in order to safeguard the assets/property,
acquired by SFAL and its Directors using the funds collected from the investing public until
full facts and materials are brought on record and a final decision is taken in the matter, it is
incumbent on SEBI to take preventive action by way of an immediate measure. In the light
of the same, I find no other alternative but to take recourse through an interim order against
SFAL and its Directors for preventing them from further carrying on with its existing fund
mobilizing activity by launching collective investment scheme without registration from SEBI in
accordance with law.
22. In view of the foregoing, I, in exercise of the powers conferred upon me under Sections
11(1), 11B and 11(4) of the SEBI Act, 1992 read with Regulation 65 of CIS Regulations and
PFUTP Regulations, hereby direct SFAL and its Directors viz., Shri Vinod Kumar
Shankhwar
(DIN:
02444432;
PAN:ATNPS4287P),
Shri
Rajendra
Karn
Rajpoot
Page 20 of 21
not to collect any fresh money from investors under its existing schemes;
not to launch any new schemes or plans or float any new companies to raise fresh moneys;
not to dispose of or alienate any of the properties/ assets including land/gold acquired directly or
indirectly through the money raised by SFAL;
not to divert any funds raised from public at large, kept in bank account(s) and/or in the custody of
SFAL;
to furnish all the information/details sought by SEBI within 15 days from the date of receipt of this
order.
23. The above directions shall take effect immediately and shall be in force until further orders.
24. This order is without prejudice to the right of SEBI to take any other action that is deemed
fit to be initiated against SFAL and its Directors in accordance with law.
25. The prima facie observations contained in this Order are made on the basis of the material
available on record. In this context, SFAL and its abovementioned Directors may, within 15
days from the date of receipt of this Order, file their reply, if any, to this Order and may also
indicate whether they desire to avail themselves an opportunity of personal hearing on a date
and time to be fixed on a specific request made in that regard.
Place: Mumbai
Date: February 12, 2015
S. RAMAN
WHOLE TIME MEMBER
SECURITIES AND EXCHANGE BOARD OF INDIA
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