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Adjudication Order in the matter of M/s. Essen Supplements India Ltd (Square Four rojects India Ltd! a"e # of #$

BEFORE THE ADJUDICATING OFFICER
SECURITIES AND EXCHANGE BOARD OF INDIA
[ADJUDICATION ORDER NO. AK/AO-134/2014]
______________________________________________________________________________
UNDER SECTION 15-I OF SECURITIES AND EXCHANGE BOARD OF INDIA ACT 1!!2 READ "ITH
RU#E 5 OF SEBI $%ROCEDURE FOR HO#DING IN&UIR' AND I(%OSING %ENA#TIES B'
ADJUDICATING OFFICER) RU#ES 1!!5
In respect of
(/*. E**+, S-../+0+,1* I,234 #12 $,56 7,56, 4* S8-49+ F5-9 %95:+;1* I,234 #12)
(A% %o& AAA'E()#)!
In the matter of
M/s. Essen Supplements India Ltd (no* +no*n as Square Four rojects India Ltd!
______________________________________________________________________________

FACTS OF THE CASE

#. An offer document (letter of offer! *as filed ,- Mr. .anesh /umar Sin"hania and Ms.
Anita Sin"hania0 the promoters of the compan- (hereinafter referred to as the <T=+
A;8-39+9*/ T=+ %95051+9*>! to acquire $1.112 of the e3panded su,scri,ed equit- share
capital and $1.#$2 of the e3panded 4otin" share capital of M/s. Essen Supplements
India Ltd. (no* +no*n as Square Four rojects India Ltd.! $hereinafter referred to as
<T=+ C50.4,?/ T=+ N513;++>) at a price of 5s. #1/6 per full- paid6 up equit- shares 7 5s.
8/6 per partl- paid6up equit- shares pa-a,le in cash. 9he pu,lic announcement for the
same *as made on Octo,er $10 $1#1 and the shares of the compan- *ere listed on
:om,a- Stoc+ E3chan"e Ltd. $hereinafter referred to as ;BSE>) Ahmeda,ad Stoc+
E3chan"e Ltd. $hereinafter referred to as <ASE>! and 9he <-dera,ad Stoc+ E3chan"e Ltd.
$hereinafter referred to as <HSE>!.


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Adjudication Order in the matter of M/s. Essen Supplements India Ltd (Square Four rojects India Ltd! a"e $ of #$

$. On perusal of the letter of offer0 SE:I o,ser4ed that the %oticee in the past had failed to
compl- *ith pro4ision of re"ulation =(>! of SE:I (Su,stantial Acquisition of Shares and
9a+eo4ers! 5e"ulations0 #??( (hereinafter referred to as ;T47+5@+9 R+A-/4135,*>! *ithin
the stipulated time.

>. :ased on the aforesaid information *ith respect to the non6compliance of 9a+eo4er
5e"ulations0 Adjudication proceedin"s under 'hapter @I6A of Securities and E3chan"e
:oard of India Act0 #??$ (hereinafter referred to as <SEBI A;1>! *ere initiated a"ainst the
%oticees under Section #8A(,! of SE:I Act to inquire into and adjudicate the alle"ed
4iolation of the pro4ision of re"ulation =(>! of 9a+eo4er 5e"ulations.

A%%OINT(ENT OF ADJUDICATING OFFICER

). 9he undersi"ned *as appointed as the Adjudicatin" Officer0 4ide order dated Au"ust =0
$1#>0 under Section #86I of the SE:I Act read *ith section #? of the SE:I Act to inquire
into and adjud"e under Section #8A(,! of the SE:I Act for the alle"ed 4iolation of
re"ulation =(>! of the 9a+eo4er 5e"ulations committed ,- the %oticee.

SHO" CAUSE NOTICE RE%#' AND %ERSONA# HEARING

8. A Sho* 'ause %otice (hereinafter referred to as <SCN>! 5ef %o EAA6
B/A//@5/>1>#$/$1#> dated %o4em,er $?0 $1#> *as issued to the %oticee under rule
)(#! of SE:I 5ules communicatin" the alle"ed 4iolations of the 9a+eo4er 5e"ulations.
9he %oticee *as also called upon to sho* cause as to *h- an inquir- should not ,e
initiated a"ainst it and penalt- ,e not imposed under Section #8A (,! of the SE:I Act for
the alle"ed 4iolations. 9he cop- of rele4ant portion of the letter of offer *as also sent
alon" *ith the S'%.

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Adjudication Order in the matter of M/s. Essen Supplements India Ltd (Square Four rojects India Ltd! a"e > of #$

B. 9he details of such instances of 4iolation of 5e"ulation =(>! of 9a+eo4er 5e"ulation are
sho*n in the ta,ular form ,elo*&
Sl.
no
5e"ulatio
n/Su,6
5e"ulatio
n
Aue date of
compliance
Actual date for compliance Aela-
(no.da-s!
C
HSE ASE BSE HSE BSE
# =(>! >1.1).#??= 1>.1?.$11) %ot 'omplied 1#.1?.$11) $>#= $>#B
$ =(>! >1.1).#??? 1>.1?.$11) %ot 'omplied 1#.1?.$11) #?8> #?8#
> =(>! >1.1).$111 1>.1?.$11) %ot 'omplied 1#.1?.$11) #8=( #8=8
) =(>! >1.1).$11# 1>.1?.$11) %ot 'omplied 1#.1?.$11) #$$$ #$$1
8 =(>! >1.1).$11$ 1>.1?.$11) %ot 'omplied 1#.1?.$11) =8( =88
B =(>! >1.1).$11> 1>.1?.$11) %ot 'omplied 1#.1?.$11) )?$ )?1
( =(>! >1.1).$11) $1.#1.$11= $1.#1.$11= $1.#1.$11= #B>) #B>)
= =(>! >1.1).$118 $1.#1.$11= $1.#1.$11= $1.#1.$11= #$B? #$B?
? =(>! >1.1).$11B $1.#1.$11= $1.#1.$11= $1.#1.$11= ?1) ?1)
#1 =(>! >1.1).$11( $1.#1.$11= $1.#1.$11= $1.#1.$11= 8>? 8>?
## =(>! >1.1).$11= $1.#1.$11= $1.#1.$11= $1.#1.$11= #(> #(>
CInfo w.r.t. actual date of compliance on ASE not available

(. An opportunit- of personal hearin" *as "ranted to the %oticee on Danuar- $$0 $1#) 4ide
<earin" %otice dated Aecem,er #=0 $1#>. 9he %oticee 4ide letter dated Danuar- #10
$1#) su,mitted its repl- to the S'%0 inter alia0 as follo*s&
7.1. That there was a change in management of the Company in !1! when the
present management " promoters too# over this Company through open offer
from the previous promoters$
7.. That the Company%s financial position was very wea# and the functioning of the
Company was virtually inoperative$
7.&. That since the present promoters did not have any e'perience or #nowledge of
share mar#et( the entire process of transfer of the Company in a legali)ed(
systematic and smooth manner was more or less entrusted or done under the
advise of erstwhile promoters and the *erchant +an#er( ,egistrars and other
consultants( who were well versed and aware about the listing rules and
regulations of the e'changes$
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Adjudication Order in the matter of M/s. Essen Supplements India Ltd (Square Four rojects India Ltd! a"e ) of #$

7.-. That it was a well understood fact that all the past liabilities of the Company
even if they occur in future shall be borne by the erstwhile promoters only$
7... That the present promoters tried to contact the erstwhile promoters after getting
the notice( but( most of them were not contactable$
7./. That there is no production and no turnover in the Company and the Company is
incurring heavy losses( however( the present management is trying their best to
revive the Company by all means$
7.7. That it has been understood that there has been a delay in ma#ing compliance
under ,egulation 01&2 of the Ta#eover ,egulations for the years 1330 to !!0(
but( the compliance has already been made and that the present management
was not responsible for the delay( as such( ta#ing any action against the
Company run by the present management( would be 4uite un5ustified$
7.0. That the number of shareholders of the Company is very less and virtually there
is no trading in the shares of the Company at the e'changes( as such( the belated
information had hardly hampered or effected or 5eopardi)ed anybody%s interest.

=. 9he %oticee 4ide the said repl- dated Danuar- #10 $1#) also requested to schedule the
hearin" after Fe,ruar- 180 $1#). 9he said request *as acceded to. Accordin"l-0 another
opportunit- of personal hearin" *as "ranted to the %oticee on Fe,ruar- #>0 $1#) 4ide
hearin" %otice Danuar- $>0 $1#). 9he %oticee 4ide letter dated Danuar- $=0 $1#)
requested to prepone the personal hearin" to Fe,ruar- #$0 $1#)0 instead of Fe,ruar-
#>0 $1#)0 and the same too *as acceded to. Accordin"l- another opportunit- of
personal hearin" *as "ranted to the %oticee on Fe,ruar- #$0 $1#) 4ide hearin" %otice
dated Danuar- $?0 $1#). Mr. Atul /umar La,h0 racticin" 'ompan- Secretar- of M/s. A./.
La,h 7 'ompan-0 AuthoriEed 5epresentati4e (hereinafter referred to as the ;AR>!
appeared on ,ehalf of the compan-. 9he A5 reiterated the su,mission made 4ide letter
dated Danuar- #10 $1#) and su,mitted another repl- dated Fe,ruar- #$0 $1#)0 inter alia
reiteratin" the su,missions alread- made 4ide letter dated Danuar- #10 $1#). 9he copies
of the disclosures su,mitted ,- the %oticee to the E3chan"es and a cop- of Annual
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Adjudication Order in the matter of M/s. Essen Supplements India Ltd (Square Four rojects India Ltd! a"e 8 of #$

5eports for the -ears $1#16$1##0 $1##6$1#$ and $1#$6$1#> *ere also su,mitted durin"
the hearin".

?. Further to the same0 the %oticee 4ide letter dated Fe,ruar- $)0 $1#) su,mitted
additional su,missions0 inter alia0 as follo*s&
?.#. That the Company%s shares were suspended at +SE till *ay !/( !!3( hence delay
in ma#ing compliances and not furnishing information to the e'changes within
time had no impact on any of the shareholders( e'changes or public at large(
since all the compliances referred in the SC6 were made prior to that date$
?.$. That there has been no significant changes amongst the shareholding during the
period 13307!!0( and a very few nominal cases of share transfers amongst the
earlier promoters themselves( would not have any impact on the shareholders(
e'change or public at large$
?.>. that the Company was well regular in ma#ing the compliance of ,egulation 01&2
of the Ta#eover ,egulations for the rest of the years once it was ta#en over by
the new management$
3.-. that the compliance in terms of the said ,egulation 01&2 has been deleted in the
new SE+I 1Substantial Ac4uisition of Shares and Ta#eovers2 ,egulations( !11
1hereinafter referred to as 8Takeover Regulations, 20112 and accordingly the
obligations of every listed company to disclose to stoc# e'changes the holdings of
substantial shareholder( persons having control and promoters in the Company
have been omitted from the new Ta#eover ,egulations 1,egulation &! of new
Ta#eover ,egulations2. This in some other way also shows the less relevance of
the earlier compliance at present( as the said compliance is not re4uired at all in
the new Ta#eover ,egulations.

CONSIDERATION OF ISSUES
#1. I ha4e carefull- perused the *ritten su,missions of the %oticee and the documents
a4aila,le on record. It is o,ser4ed that the alle"ation a"ainst the %oticee is that the-
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Adjudication Order in the matter of M/s. Essen Supplements India Ltd (Square Four rojects India Ltd! a"e B of #$

ha4e failed to ma+e the rele4ant disclosure under the pro4isions of 5e"ulations =(>! of
9a+eo4er 5e"ulations.

##. 9he issue that0 therefore0 arises for consideration in the present case are&
##.#. Fhether the %oticee had 4iolated the pro4isions of 5e"ulation =(>! of 9a+eo4er
5e"ulations durin" the -ears #??(6?= to $11(61=G
##.$. Aoes the 4iolation0 if an-0 as aforesaid0 attract monetar- penalt- under Section
#8 A (,! of SE:I ActG
##.>. If so0 *hat *ould ,e the monetar- penalt- that can ,e imposed ta+in" into
consideration the factors mentioned in Section #8D of SE:I ActG

FINDINGS
#$. :efore mo4in" for*ard0 it is pertinent to refer to the pro4isions of 5e"ulations
re"ulation =(>! of 9a+eo4er 5e"ulations0 *hich reads as under&
8. Continual disclosures.
1129.
129.
1&2 Every company whose shares are listed on a stoc# e'change( shall within &! days
from the financial year ending *arch &1( as well as the record date of the company for
the purposes of declaration of dividend( ma#e yearly disclosures to all the stoc#
e'changes on which the shares of the company are listed( the changes( if any( in respect
of the holdings of the persons referred to under sub regulation 112 and also holdings of
promoters or person1s2 having control over the company as on &1st *arch.

#>. 9he issue for consideration is *hether the %oticee has failed to ma+e the rele4ant
disclosures under 5e"ulation =(>! of the 9a+eo4er 5e"ulations for the financial -ears
endin" March >#0 #??= to March >#0 $11= *ithin the stipulated time0 i.e. on ele4en (##!
occasions. As per 5e"ulation =(>! of the 9a+eo4er 5e"ulations0 %oticee *as required to
ma+e -earl- disclosure *ithin >1 da-s from the financial -ear endin" March >#0 to the
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Adjudication Order in the matter of M/s. Essen Supplements India Ltd (Square Four rojects India Ltd! a"e ( of #$

stoc+ e3chan"es on *hich the shares of the compan- *ere listed0 the chan"es0 if an-0 in
respect of the holdin"s of the persons referred to under su, re"ulation (#! and also
holdin"s of promoters or person(s! ha4in" control o4er the compan- as on >#st March.

#). Fith re"ard to the disclosures for the financial -ears endin" March >#0 #??= to March
>#0 $11=0 I find that the %oticee 4ide its repl- *hile inter alia admittin" that there has
,een a dela- in ma+in" compliances0 ho*e4er0 has su,mitted that it *as a *ell
understood fact that all the past lia,ilities of the 'ompan- e4en if the- occur in future
shall ,e ,orne ,- the erst*hile promoters onl-. I note her that *hen a compan- is
incorporated0 it ,ecomes a le"al personalit- *hich is separate from its promoters0
directors and its shareholders. 9his separate le"al personalit- has its o*n le"al ri"hts
and o,li"ations0 just as indi4iduals. Hnder 5e"ulation =(>! of the 9a+eo4er 5e"ulations0 it
*as the compan- *hich *as required to ma+e certain disclosures0 *hich it failed to
ma+e *ithin the stipulated time. 9hus0 it is esta,lished *ithout dou,t that the %oticee
has 4iolated the pro4isions of 5e"ulation =(>! of the 9a+eo4er 5e"ulations for the
financial -ears endin" March >#0 #??= to March >#0 $11=. 9he respecti4e num,er of
da-s of non6compliance in respect of each financial -ear has ,een enumerated in the
ta,le at ara (B! a,o4e.

#8. 9he <onI,le Supreme 'ourt of India in the matter of SE+I :s. Shri ,am *utual ;und
J$11BK B= S'L $#B(S'! 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
,egulations is established and hence the intention of the parties committing such
violation becomes wholly irrelevant9=. Further in the matter of 5anjan @ar"hese 4. SE:I
(Appeal %o. #(( of $11? and Order dated April 1=0 $1#1!0 the <onI,le SA9 had o,ser4ed
<>nce it is established that the mandatory provisions of Ta#eover Code was violated the
penalty must follow.L

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Adjudication Order in the matter of M/s. Essen Supplements India Ltd (Square Four rojects India Ltd! a"e = of #$

#B. In 4ie* of the fore"oin"0 I am con4inced that it is a fit case to impose monetar- penalt-
under Section #8A(,! of the SE:I Act0 *hich reads as under&
Section 15A(b a!ter S"#$ (A%end%ent Act, 2002 &.e.! 2'(10(2002
)enalt* !or !ailure to !urnis+ in!or%ation, return, etc.(
15.A(b To file any return or furnish any information( boo#s or other documents within
the time specified therefor in the regulations( fails to file return or furnish the same
within the time specified therefor in the regulations( he shall be liable to a penalty of one
la#h rupees for each day during which such failure continues or one crore rupees(
whichever is less.

Section 15A(b ,rior to S"#$ (A%end%ent Act, 2002
)enalt* !or !ailure to !urnis+ in!or%ation, return, etc.(
15.A(b To file any return or furnish any information( boo#s or other documents within
the time specified therefor in the regulations( fails to file return or furnish the same
within the time specified therefor in the regulations( he shall be liable to a penalty not
e'ceeding five thousand rupees for every day during which such failure continues.

#(. Fhile determinin" the quantum of monetar- penalt- under Section #8A(,!0 I ha4e
considered the factors stipulated in Section #86D of SE:I Act0 *hich reads as under&
B15J 6 F4;159* 15 C+ 147+, 3,15 4;;5-,1 C? 1=+ 42:-23;413,A 5DD3;+9
Fhile adjud"in" quantum of penalt- under Section #86I0 the adjudicatin" officer shall
ha4e due re"ard to the follo*in" factors0 namel-&
(a! the amount of disproportionate "ain or unfair ad4anta"e0 *here4er quantifia,le0
made as a result of the defaultM
(,! the amount of loss caused to an in4estor or "roup of in4estors as a result of the
defaultM
(c! the repetiti4e nature of the default.L

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Adjudication Order in the matter of M/s. Essen Supplements India Ltd (Square Four rojects India Ltd! a"e ? of #$

#=. In 4ie* of the char"es as esta,lished0 the facts and circumstances of the case and the
jud"ments referred to and mentioned hereina,o4e0 the quantum of penalt- *ould
depend on the factors referred in Section #86D of SE:I Act and stated as a,o4e. 9he main
o,jecti4e of the 9a+eo4er 5e"ulations is to afford fair treatment for shareholders *ho
are affected ,- the chan"e in control. 9he 5e"ulation see+s to achie4e fair treatment ,-
inter alia mandatin" disclosure of timel- and adequate information to ena,le
shareholders to ma+e an informed decision and ensurin" that there is a fair and
informed mar+et in the shares of companies affected ,- such chan"e in control. 'orrect
and timel- disclosures are also an essential part of the proper functionin" of the
securities mar+et and failure to do so results in pre4entin" in4estors from ta+in" *ell6
informed decisions 9hus0 the cornerstone of the 9a+eo4er re"ulations is in4estor
protection.

#?. As per Section #8A(,! of the SE:I Act0 *ith effect from $?.#1.$11$0 the %oticee is lia,le
to a penalt- of one la+h rupees for each da- durin" *hich such failure continues or one
crore rupees0 *hiche4er is less. rior to the same0 the %oticee is lia,le to a penalt- not
e3ceedin" fi4e thousand rupees for e4er- da- durin" *hich such failure continues.
Further0 under Section #86I of the SE:I Act0 the adjudicatin" officer has to "i4e due
re"ard to certain factors *hich ha4e ,een stated as a,o4e *hile adjud"in" the quantum
of penalt-. It is noted that no quantifia,le fi"ures are a4aila,le to assess the
disproportionate "ain or unfair ad4anta"e made as a result of such non6compliance ,-
the %oticee. Further from the material a4aila,le on record0 it is not possi,le to ascertain
the e3act monetar- loss to the in4estors on account of non6compliance ,- the %oticee.
<o*e4er0 I note that the <onN,le Securities Appellate 9ri,umal (SA9! in the matter of
/omal %ahata @s. SE:I (Aate of jud"ment6 Danuar- $(0 $1#)! has o,ser4ed that&

<Argument that no investor has suffered on account of non disclosure and that the A>
has not considered the mitigating factors set out under Section 1.? of SE+I Act( 133 is
without any merit because firstly penalty for non compliance of SAST ,egulations( 1337
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Adjudication Order in the matter of M/s. Essen Supplements India Ltd (Square Four rojects India Ltd! a"e #1 of #$

and @IT ,egulations( 133 is not dependent upon the investors actually suffering on
account of such non disclosure.=
In 4ie* of the same0 the ar"ument put forth ,- the %oticee that the dela-ed disclosure
had no impact on an- of the shareholders0 e3chan"es or pu,lic at lar"e is not rele4ant
for the "i4en case.

$1. In addition to the aforesaid0 I am also inclined to consider the follo*in" miti"atin"
factors *hile adjud"in" the quantum of penalt-& a! the share capital/ mar+et
capitaliEation of the compan- at the rele4ant point of timeM ,! the tradin" 4olumes of
%oticeeIs shares on :SE durin" the rele4ant periodM c! the chan"es in promoters
shareholdin"0 if an- durin" the rele4ant periodM and d! the num,er of occasions in the
instant proceedin" that the %oticee has 4iolated the rele4ant pro4isions of the 9a+eo4er
5e"ulations.

$#. From the :SE *e,site0 I note that the capital of the compan- *as >#01=0?11 equit-
share of 5s #1/6 each a""re"atin" 5s. >0#10=?0111/6. Further0 as per the :SE *e,site0
there *as no tradin" in the shares of the compan- durin" the rele4ant period. 9he
%oticee has su,mitted that the shares of the compan- *ere suspended at :SE till Ma-
1B0 $11?. 9he %oticee ha4e inter alia su,mitted that there has ,een no si"nificant
chan"es amon"st the shareholdin" durin" the period #??=6$11=0 e3cept a 4er- fe*
nominal cases of share transfers amon"st the earlier promoters themsel4es. I find that
the %oticee had not made the disclosure to the e3chan"e under the pro4isions of
5e"ulation =(>! of the 9a+eo4er 5e"ulations for ele4en (##! consecuti4e financial -ears
from #??(6?= to $11(61= *ithin the stipulated time.

$$. I find that the %oticee ha4e inter alia su,mitted that the compliance in terms of the said
5e"ulation =(>! has ,een deleted in the ne* 9a+eo4er 5e"ulations0 $1## and
accordin"l- the o,li"ations of e4er- listed compan- to disclose to stoc+ e3chan"es of
holdin"s of su,stantial shareholder0 persons ha4in" control and promoters in the
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Adjudication Order in the matter of M/s. Essen Supplements India Ltd (Square Four rojects India Ltd! a"e ## of #$


'ompan- ha4e ,een omitted from the ne* 9a+eo4er 5e"ulations (5e"ulation >1 of ne*
9a+eo4er 5e"ulations!0 *hich in some *a- sho*s less rele4ance of the earlier
compliance at present0 as the said compliance is not required at all in the ne* 9a+eo4er
5e"ulations. It is pertinent to note her that under the earlier 9a+eo4er 5e"ulations0
persons ha4in" control/ su,stantial holdin" and the promoters of the 'ompan- under
5e"ulation =(#! and =($! of the 9a+eo4er 5e"ulations *ere required to ma+e -earl-
disclosure to the compan-0 in respect of their holdin"s as on >#
st
March. 9he compan-0
in turn0 *as required to disclose the same to the stoc+ E3chan"es under 5e"ulation =(>!
of the 9a+eo4er 5e"ulations. On the other hand0 under the ne* 9a+eo4er 5e"ulations0
$1##0 the disclosure to the compan- and the stoc+ E3chan"e has to ,e done ,- the
persons ha4in" su,stantial holdin" and the promoters themsel4es under 5e"ulation >1.
<o*e4er0 irrespecti4e of *hether disclosure to the stoc+ E3chan"e is made ,- the
compan- or the promoters themsel4es0 under ,oth the old 9a+eo4er 5e"ulations and
ne* 9a+eo4er 5e"ulations0 $1##0 the intent of the la* remains the same0 to disseminate
to in4estors so as to enhance confidence and informed participation ,- in4estors in
secondar- securities mar+et. 9his0 in turn0 enhances the depth0 liquidit- and efficienc- of
the securities mar+ets. <ence the inference dra*n ,- the %oticee that the ne*
9a+eo4er 5e"ulations0 $1## in some *a- sho*s less rele4ance of the earlier compliance
under 5e"ulation =(>! of the 9a+eo4er 5e"ulations at present is incorrect.

$>. As a listed compan-0 the %oticee had a responsi,ilit- to compl- *ith the disclosure
requirements in accordance *ith their spirit0 intention and purpose so that the in4estors
could ta+e a decision *hether to ,u-0 sell0 or hold the %oticeeIs securities. %on6
compliance/ Aela-ed compliance *ith disclosure requirements ,- a listed compan-
undermines the re"ulator- o,jecti4es and jeopardiEes the achie4ement of the
underl-in" polic- "oals.


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Adjudication Order in the matter of M/s. Essen Supplements India Ltd (Square Four rojects India Ltd! a"e #$ of #$

ORDER

$). After ta+in" into consideration all the facts and circumstances of the case0 I impose a
penalt- of R* 550000/- $R-.++* F3@+ #47=* F3D1? T=5-*4,2 5,/?) under Section #8 A(,!
on the N513;++ (/*. E**+, S-../+0+,1* I,234 #12 $,56 7,56, 4* S8-49+ F5-9 %95:+;1*
I,234 #12) *hich *ill ,e commensurate *ith the 4iolations committed ,- the %oticee.

$8. 9he %oticee shall pa- the said amount of penalt- ,- *a- of demand draft in fa4our of
OSE:I 6 enalties 5emitta,le to .o4ernment of IndiaL0 pa-a,le at Mum,ai0 *ithin )8
da-s of receipt of this order. 9he said demand draft should ,e for*arded to Mr. @ S
Sundaresan0 'hief .eneral Mana"er0 'orporation Finance Aepartment0 SE:I :ha4an0
lot %o. ' P ) A0 O.L :loc+0 :andra /urla 'omple30 :andra (E!0 Mum,ai P )11 18#.

$B. In terms of rule B of the 5ules0 copies of this order are sent to the %oticee and also to
the Securities and E3chan"e :oard of India.


D41+E A-A-*1 2F 2014 A,314 K+,749+
%/4;+E (-0C43 A2:-23;413,A ODD3;+9

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