order in the matter of mishka finance and trading ltd

8/9/2019 Order in the matter of Mishka Finance and Trading Ltd.

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------------------------------------------------------------------------------------------------------------------------------------------------- Order in the matter of Mishka Finance and Trading Ltd. Page 1 of 68

WTM/RKA /ISD / 30 /2015

SECURITIES AND EXCHANGE BOARD OF INDIA

ORDER

UNDER SECTIONS 11(1), 11(4) AND 11B OF THE SECURITIES AND EXCHANGE

BOARD OF INDIA ACT, 1992 AND SECTION 12A OF THE SECURITIES

CONTRACTS (REGULATION) ACT, 1956

IN THE MATTER OF MISHKA FINANCE AND TRADING LIMITED

1. Pursuant to detection of a huge rise in the traded volume and price of the shares of Mishka

Finance and Trading Limited {formerly known as Pyramid Finance and Trading Limited and

hereinafter referred to as " Mishka "} on Bombay Stock Exchange Limited ("BSE") during the

period from February 14, 2013 to December 31, 2014 (hereinafter referred to as

"Examination Period"), Securities and Exchange Board of India ("SEBI") undertook

preliminary inquiry in the dealings in the said scrip.

2. On January 16, 2014, pursuant to a stock split, the face value of shares of Mishka reduced

from ₹10/- to ₹1/- per share. During the period from February 14, 2013 to February 14,

2014 ("Patch I"), the price of the scrip of Mishka opened at ₹5.50/, rose to a high of ₹499/-

(unadjusted and ₹49.90/- adjusted to Share Split) and closed at ₹499/- (unadjusted and

₹49.90/- adjusted to Share Split) with an average volume of 390 shares. During the period

February 17, 2014 to December 30, 2014 ("Patch II"), the price of the scrip moved between₹29.05/- to ₹57/- but the average volume in the scrip sharply jumped to 2,97,319 shares. An

illustration of price/volume movement in the scrip of Mishka during the Examination Period

is given below:

Brought to you by http://StockViz.biz


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3. It was noticed that trading in the scrip of Mishka was suspended from January 07, 2002 to

May 09, 2012 on account of non-payment of listing fees. Prior to that, on September 30,

2011, Mishka had a total share capital of ₹49,80,000/- comprising 4,98,000 shares of ₹10/-

each with a total of 7 shareholders (five promoters and two public). The five promoters, viz.

Embassy Finance and Consultants Pvt. Ltd., Sulab Impex Limited, Tohee Trading and Agencies Pvt. Ltd., Wave Inter Trade Pvt. Ltd. and Mr. Vijay Kumar Jain, and 2 other

entities, viz. Ms. Rashmi Jain and Mr. Ankit Jain sharing common address with Mr. Vijay

Kumar Jain at 701, Arcadia Building, Nariman Point, Mumbai 400021, are prima facie related

to each other. The entire share capital of Mishka was in physical form as on September 30,

2011. Thereafter, these 7 shareholders transferred 4,96,000 shares to 452 entities (hereinafter

referred to as "Promoter related entities ") directly / indirectly in physical form during the period

from December 11, 2011 to February 05, 2013. The list of all the Promoter related entities is

annexed as Part I of Annexure A. In the meantime, on September 24, 2012, Mishka made a

preferential allotment of 7,93,700 shares at a premium of ₹75/- per share to 46 entities (List

is annexed as Part II of Annexure A) including one promoter, viz. Pearl Arcade Trading

Private Limited. These shares allotted by Mishka were under a compulsory lock-in till

September 23, 2013. Thereafter, Mishka announced a bonus of 7 shares on every 1 share on

February 06, 2013. As a result thereof, the share capital of Mishka increased to

₹10,33,36,000/- comprising 1,03,33,600 shares of ₹10/- each. Thereafter, on January 16,

2014, Mishka split its shares from ₹10/- per shares to ₹1/- per share. Consequent to these

actions, the share capital of Mishka increased to 10,33,36,000 shares having the face value of

₹1/- each.

4. From the Annual Reports of Mishka for Financial Year ("FY") 2011-12 and FY 2012-2013, it

was observed that it is in the business of financing, investment and trading activities and it

had incurred a loss of ₹12 Lakh during FY 2011-12 and earned a profit of ₹12 Lakh during

FY 2012-13. Further, from the Annual Report of Mishka for FY 2012-2013, it is observed

that for FY ended 2012 the earning per shares ("EPS") of Mishka was ₹-2.4/- and for the FY

ended March 31, 2013, EPS was ₹0.12/-. During the Examination Period, no material

corporate announcement was made by Mishka which could support such price rise in its

scrip. Thus, the sharp rise in the price of the scrip of Mishka during the Examination Period was not supported by its fundamentals or any other genuine factor. It is interesting to note

that the shares of Mishka were suspended till May 09, 2012. Between May 10, 2012 and

September 23, 2012, there was no trading in the scrip of Mishka . Strangely, in spite of such

trifling fundamentals and tarnished track record of long period of suspension of trading and



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below par market price, Mishka was able to garner funds aggregating to ₹6,74,64,500/- from

aforesaid 46 entities through preferential allotment at a premium of ₹75/- per share within a

short span of four months of revocation of suspension. Investment in a company having

such poor and meagre fundamentals cannot prima facie be termed as a rational investment

behaviour. Such investments, as in this case, normally could be made only if the allottees hada nexus with Mishka and its directors/promoters and the issue of these shares was under a

prior arrangement between them.

5. It was observed that within a short period after the preferential allotment, a significant

increase in the price of the scrip took place which continued during and after the period of

lock in on the shares allotted to the preferential allotees. Considering the fact that prior to the

preferential allotments, no trading occurred in the scrip of Mishka , the increase in the traded

volume in the period after preferential allotment was found to be substantial and abnormal.

In light of the above, in order to observe the price volume behaviour of the scrip, the tradingin the scrip was analysed in two Patches with a focus on the following:-

The trading frequency;

The volume generated;

Contribution to price rise;

Buying behavior as observed from Last Traded Price ("LTP") data.

6. On analysis of trading activity in the scrip, it was observed that during the Examination

Period, two sets /groups of entities were mainly involved. While one group of entities was

primarily involved in pushing the price up during Patch-1 (when the volume in the scrip was

very low) by contributing to positive LTP through first trades with negligible order quantity,

the other group of entities was acting as buyer in Patch-2 in order to provide exit to

preferential allottees/Promoter related entities and in the process creating artificial volume. The

role/connection/relationship of these two groups is discussed in subsequent paragraphs.

Patch 1: February 14, 2013 to February 14, 2014:

7. During Patch 1 the scrip price opened at ₹5.50 and closed at ₹49.90/- (adjusted and ₹499/-

unadjusted). During this period, the scrip was traded with an average volume of 390 sharesper day and total volume of 73,760 shares in 189 trading days with an average of 1 trade per

day. It was observed that price of the scrip was influenced by certain entities primarily

through first trades during this period. These entities merely by putting 1 or 2 trades per day

with negligible/ very less quantity of buy order contributed significantly to the price rise.



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From LTP analysis, it was observed that price of the scrip increased from ₹5.50 to ₹49.90

(adjusted and ₹499/- unadjusted) mainly through first trades in 188 such instances.

8. It was observed that in Patch 1, out of a total of 188 instances of trades establishing new high

price in the scrip, four entities namely, Shyam Kanheyalal Vyas, Bharat Bagri, ManjulabenSukhdev Pandya and Jayesh Narendra Kesharia, established new high price on 99 instances.

The contribution of these four entities in establishing new high price was ₹251.61/- out of

total price rise of ₹339/-, which constitutes 74.23% of the total new high price. The details of

contribution to price rise by these four entities during Patch 1 are as under:

Table I : Contribution to price rise in Patch 1 by four entities.

PAN Name

Name reflected

in the InterimOrder

PositiveLTP

Contributionas a buyer

% to Total

Positive LTPContribution

ACTPV2787Q Shyam Kanheyalal Vyas First Financial Ltd 235.46 69.46

AADHB8488A Bharat Bagri BagriRadford, FirstFinancial Ltd 8.5 2.51

AAEHJ1610D Jayesh NarendraKesharia Radford 5.25 1.55

ALVPP7764JManjulaben SukhdevPandya Radford 2.4 0.71

Total 251.61 74.23

9.

It is observed that the entities named in the above Table were instrumental in contributing tothe price rise of the scrips of Radford Global Limited and First Financial Services Limited

and are already restrained from dealing in securities market in whatsoever manner vide

interim orders dated December 19, 2014 in the scrips of Radford Global Limited and First

Financial Services Limited for contributing to price rise in the respective scrips.

Patch 2: From February 17, 2014 to December 31, 2014:

10. During Patch 2, the price of the scrip opened at ₹50.85/-, touched a high of ₹57/- and

touched a low of and closed at₹

29.05/-. However, the average volume in the scrip jumpedsharply from 390 shares (as it was in Patch 1) to 2,97,319 shares per day.

11. On analysis of trading activity during Patch 2, certain related/connected entities to Mishka

were found to be net buyers to the preferential allottees / Promoter related entities and thereby

created artificial demand for the supply of shares from preferential allottees / Promoter related



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entities. During Patch 2, significant increase in the trading volume was observed and it appears

that most of the entities were acting as counterparty to the Preferential Allottees/ Promoter

related entities. Also on further examination direct/ indirect relationship was established among

these entities through Know Your Client ("KYC") details, bank statements, off-market

transactions amongst themselves, information available on the Ministry of Corporate Affairs("MCA") website, etc. List of these entities is annexed as Part III of Annexure - A and

hereinafter they shall be referred to as the " Exit Providers ". Since the Exit Providers , Preferential

Allottees and Promoter related entities have been prima facie found to be connected/related to

Mishka / its promoters, they shall hereinafter collectively be referred to as " Mishka Group".

12. Considering the large number of related/connected entities of Mishka Group, a set of 112

entities (hereinafter referred to as the "Shortlisted Group") were shortlisted on the basis of

following parameters, viz.

A.

All the Exit Providers ;B. All the Preferential Allottees who have sold Mishka's shares and;

C. All the Promoter related entities who have sold more than 2,00,000 shares.

13. The particulars of the members of the Shortlisted Group are given in the following table :

Table II: List of Shortlisted Entities:

Promoter related entities

S. No. PAN Name

1 ABBPR3992G ANIL SATYANARAYAN ROONGTA2 ACRPC4740L RITESHKUMAR AMITKUMAR CHATTERJEE

3 ACHPS7762G ATUL MORESHAWAR SAVE

4 AKKPP3508Q PARUL RUPESH PODDAR

5 AAOHS4973C SUNIL KUMAR JAIN & SONS HUF

6 AAGHR7451A RAVI KHANNA HUF

7 AAGPA3508D GAJANAND AGARWAL

8 AACPA9922H PANKAJ AGARWAL

9 AANPG3179K BHARAT GANDOTRA

10 AJVPK5048G AADIST KHANNA

11 ARIPK3181H BHAVYA KHANNA

12 AAIPK5106B JYOTI KHANNA

13 AFMPK8726N RAVI KHANNA

14 ACNPA1462H LALIT AGARWAL

15 AELPP0183N RUPESH KUMAR PODDAR



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16 AAEHD5856M DINDAYAL MALCHAND AGARWAL HUF

17 AACPA5733E KRISHAN AGARWAL

18 ACRPJ3552D SEEMA JAIN

19 BHKPS8506F JAY N SHAH

20 ABYPJ9937E SUNIL KUMAR JAIN

21 AAGPS9497R NAVINCHANDRA K SHAH

22 AAGPS9498A MALTI NAVINCHANDRA SHAH

23 AGLPP3159L ROHINI VIJAYSINGH PATWARDHAN

24 BEIPA7823N PRANIT AGARWAL

Preferential Allottees

25 AEFPS6298M BRIJ BHUSHAN SINGAL

26 AALFG1236F GOKULDHAM ENTERPRISES LLP

27 AACPD7055J NITIN KUMAR DIDWANIA

28 AAGPS6393C PRAKASH MANGILAL SURYA

29 AAAPZ1721B SHRENIK NALIN ZAVERI30 AADPK9309F MAHESH KUMAR KHATRY

31 AADPK1946Q PRAKASH CHAND KHATRY

32 ADGPC1107P TARUN KUMAR CHANDAK

33 ACAPS1025K KALAWATI SHARMA

34 AGMPS2776H PRAKASH CHAND SHARMA

35 ABYPV5751G CHIRAG MAHESHKUMAR VYAS

36 AAAPU2596F SHEETAL SANJAY UDESHI

37 ACUPJ1252F NARESH JALAN

38 AABHN4403P NARESH JALAN

39 ACFPJ2428J MAHABIR PRASAD JALAN

40 AACHM0965N MAHABIR PRASAD JALAN

41 AECPC7959J HARLEEN KAUR

42 AEJPB6903J SAVITA BANSAL

43 ABTPS0026N SMT RASHMI JAIN

44 AAJPA2349H JIGNESH M. AMIN

45 AADPJ5579L VIMAL JAIN

46 AJGPS8091J SARAD KUMAR B JAIN

47 AADPC6863A ASHOK KUMAR CHOWATIA

48 ABQPL6153L TARACHAND L SHAH49 AADPC6859J MADANLAL BABULAL CHOWATIA

50 ACSPB5838R SHANKAR BATRA

51 ABHPA9244J SADHNA RANI

52 AGEPA7936K RANIDEVI AGARWAL



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53 AADHR3405B RAVINDER KUMAR GUPTA (HUF)

Exit Providers

54 AAKPS3276J Manharlal Narottamdas Shah

55 AAACE2862P Esha Securities Ltd

56 AACCA3220D Amrit Sales Promotion Pvt Limited57 AADCS5411K Symphony Merchant Pvt Ltd

58 AABCB3052B Bazigar Trading Private Limited

59 AAGCR1715E Rangan Vincom Private Limited

60 AACCL3868N Ladios Trading Private Limited

61 AADCT8403C Topwell Properties Private Limited

62 AAMCS1712Q Signet Vinimay Private Limited

63 AAMCS1711P Sanklap Vincom P Ltd

64 AAECR0580M Runicha Merchants Private Limited

65 AAACW8004B Winall Vinimay Private Limited Ltd

66 AAPCS7492G Spice Merchants Private Limited67 AAJCA4459K Apex Commotrade Private Limited Ltd

68 AAICS0688K Skm Travels Private Limited

69 AAICS6023N Scope Vyapar Private Limited

70 AAACV8378B Vibgyor Financial Servicepvt Ltd

71 AACCH4303G Helpful Investment Advisory Private Limited

72 AABCF5486H Function Financial Consultants Private Limited

73 AAECK7329P Kapeeshwar Vintrade Private Limited

74 AAMCS8721P Sinjan Overseas Pvt Ltd

75 AABCW0317N Wonder Procon Private Limited Wppl76 AACCH8885R Helot Properties Pvt Ltd

77 AAECC9285A Cheroot Vanijya Pvt Ltd

78 AATCS3687H Sidhiman Vyapaar Private Limited

79 AAECV4988P Vishnudham Marketing Private Limited

80 AAECT5548F Triala Dealers Private Limited

81 AAICM4750C Mobixa Distributors Private Limited

82 AALCA7880J Antaryami Traders Private Limited

83 AAFCG2554B Gajgamini Merchandise Private Limited

84 AAICM6982C Muchmore Vincom Private Limited85 AAECD5782B Dreamlight Exim Private Limited

86 AAFCG4773J Goldensight Traders Private Limited87 AAACD9125E Dynamic Portfolio Management & Services Ltd

88 AABCR1974J Ritesh Commercial Holdings Limited

89 AADCR6224M Ritesh Projects Private Ltd.



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90 AAECS0352C Stardox Vinimoy Private Limited

91 AABCR3482R Raina Vyapaar Private Ltd

92 AABCR2904A R C Suppliers Private Lim Ited

93 AABCH2251E Hari Om Suppliers Pvt. Ltd.

94 AADCK9346B Kalakar Commercial Private Limited

95 AAFCB0211J Blue Horizon Commosales Private Limited

96 AAGCR8142P Rochak Vinimay Private Limited

97 AAGCR7017M Rochi Dealcom Private Limited

98 AAECD9323N Duari Marketing Private Limited

99 ACIPS8803M S N Srinivasan

100 BABPS7447D Amit Singh

101 AADCI5139E Indrawati Nirman Pvt Ltd

102 AAGCR4662J Reachsmart Construction Pvt Ltd

103 AABCO6950F Overload Financial Advisory Pvt Ltd

104 AARCS9144H Sebika Commodities Private Limited

105 AATCS4365E Samridhipurn Services Private Limited

106 AAFCR9881C Reachsmart Dealtrade Private Limited

107 AATCS6718D Swarnprakash Traders Private Limited

108 AAECD8010E Dhyaneshwar Dealers Pvt Ltd

109 AAECD8235D Dhlriti Traders Pvt Ltd

110 AAGCR6009M Ramya Mercantile Pvt Ltd

111 AAFCB4546A Badamisati Apartments Private Limited

112 ATIPM7500N Arunavo Mukherjee

14. It is observed that during Patch 2, the Preferential Allottees/Promoter related entities were the

net sellers and the Exit Providers were the net buyers, a snapshot of which is given below:-

Table III - Exit provided by Exit Providers to Preferential allottees/Promoter related entities

Category Sharessold

% of Totalallottedshares

Shares purchased from preferentialallottees/Promoter related

entities

% to ExitProviderGrossBought Volume

GrosssharesBoughtby ExitProviders

Shares boughtby ExitProviders as% to MarketBought

Volume

Preferential Allottee

18921835 61.00% - - - -



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Promoterrelatedentities

31838149 93.76% - - - -

Exit

Provider

- - 25476894 90.84% 28044592 46.47%

15.

It is observed from Table III that most of the trades were taking place between the

preferential allottees/Promoter related entities and Exit Providers . During this period, the

Preferential allottees/Promoter related entities were found to be selling and in the process

making a huge profit/gain. It was observed that Exit Providers contributed 46.47% to the

Gross buy trade during Patch 2. The details of counter parties for sale transactions by

preferential allottees/ Promoter related entities is given below:

Table - IV: Details of counter parties for sale transactions

Sr.No.

Client PAN Client Name GrossBuy inPatch 2

% toMark et Volume

Shares purchasedfrom preferentialallottes/PromtoerGroupentitiesduring post split period

% ofsharesboughtfrom preferentialallottesto thegrossBuy bytheclient

1 AAECD8235D Dhlriti Traders Pvt Ltd 8726858 14.46 8485818 97.24

2 AAGCR6009M Ramya Mercantile Pvt Ltd 5376722 8.91 5290081 98.39

3 AAPCS7492G Spice Merchants PrivateLimited

2872178 4.76 2100797 73.14

4 AAJCA4459K Apex CommotradePrivate Limited Ltd

2249188 3.73 1961565 87.21

5 AAACW8004B Winall Vinimay PrivateLimited Ltd

1090076 1.81 976671 89.6

6 AAECV4988P Vishnudham Marketing

Private Limited

666225 1.1 490025 73.55

7 AAECD5782B Dreamlight Exim PrivateLimited

579939 0.96 426525 73.55

8 AAMCS1712Q Signet Vinimay PrivateLimited

445464 0.74 361354 81.12

9 AAFCG2554B Gajgamini MerchandisePrivate Limited

408025 0.68 356151 87.29



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10 AAECD9323N Duari Marketing PrivateLimited

422360 0.7 347260 82.22

11 AAECR0580M Runicha MerchantsPrivate Limited

327650 0.54 204035 62.27

12 AATCS3687H Sidhiman Vyapaar Private

Limited

328890 0.54 313840 95.42

13 AAICS6023N Scope Vyapar PrivateLimited

310000 0.51 310000 100

14 AAACE2862P Esha Securities Ltd 295500 0.49 295500 100

15 AALCA7880J Antaryami Traders PrivateLimited

284385 0.47 260075 91.45

16 AAECC9285A Cheroot Vanijya Pvt Ltd 284250 0.47 269250 94.72

17 AAFCB4546A Badamisati ApartmentsPrivate Limited

195000 0.32 181160 92.9

18 AAECS0352C Stardox Vinimoy PrivateLimited

180000 0.3 180000 100


174260 0.29 174260 100

20 AABCR3482R Raina Vyapaar Private Ltd 166540 0.28 166540 100

21 AAMCS1711P Sanklap Vincom P Ltd 151049 0.25 131049 86.76

22 AACCH8885R Helot Properties Pvt Ltd 149650 0.25 128660 85.97

23 AAICM4750C Mobixa DistributorsPrivate Limited

137600 0.23 104250 75.76

24 AAICM6982C Muchmore VincomPrivate Limited

114400 0.19 104650 91.48

25 BABPS7447D Amit Singh 114320 0.19 114320 100

26 AAICS0688K Skm Travels PrivateLimited

111000 0.18 110900 99.91

27 AAGCR8142P Rochak Vinimay PrivateLimited

109000 0.18 90150 82.71

28 AAFCB0211J Blue HorizonCommosales Private Ltd

102570 0.17 79780 77.78

29 AABCF5486H Function FinancialConsultants PrivateLimited

87300 0.14 53300 61.05

30 AABCH2251E Hari Om Suppliers Pvt.Ltd.

81500 0.14 81450 99.94

31 ACIPS8803M S N Srinivasan 339000 0.56 296985 87.6132 AACCA3220D Amrit Sales Promotion

Pvt Limited70000 0.12 60000 85.71

33 AAACV8378B Vibgyor FinancialServicepvt Ltd

70000 0.12 0 0


71663 0.12 71663 100



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35 AAECT5548F Triala Dealers PrivateLimited

70000 0.12 69800 99.71

36 AADCR6224M Ritesh Projects PrivateLtd.

72195 0.12 72195 100

37 AAFCR9881C Reachsmart Dealtrade

Private Limited

57000 0.09 57000 100

38 AAMCS8721P Sinjan Overseas Pvt Ltd 56000 0.09 56000 100

39 AABCW0317N Wonder Procon PrivateLimited Wppl

50000 0.08 50000 100

40 AAGCR7017M Rochi Dealcom PrivateLimited

52500 0.09 52500 100

41 AABCR2904A R C Suppliers Private LimIted

45000 0.07 45000 100

42 AAFCG4773J Goldensight TradersPrivate Limited

38000 0.06 5000 13.16

43 AADCS5411K Symphony Merchant Pvt

Ltd

32500 0.05 32500 100

44 AABCB3052B Bazigar Trading PrivateLimited

29500 0.05 29500 100

45 AAECD8010E Dhyaneshwar Dealers PvtLtd

185500 0.31 165500 89.22

46 AACCL3868N Ladios Trading PrivateLimited

25000 0.04 25000 100

47 AADCT8403C Topwell PropertiesPrivate Limited

25000 0.04 25000 100

48 AADCK9346B Kalakar CommercialPrivate Limited

25000 0.04 25000 100

49 ATIPM7500N Arunavo Mukherjee 20000 0.03 20000 10050 AARCS9144H Sebika Commodities

Private Limited13785 0.02 13785 100

51 AATCS6718D Swarnprakash TradersPrivate Limited

15000 0.02 15000 100

52 AAACD9125E Dynamic PortfolioManagement & ServicesLtd

15955 0.03 15955 100

53 AADCI5139E Indrawati Nirman Pvt Ltd 72000 0.12 72000 100

54 AAKPS3276J Manharlal NarottamdasShah

11650 0.02 11650 100

55 AAGCR4662J Reachsmart ConstructionPvt Ltd

9900 0.02 9900 100

56 AABCR1974J Ritesh CommercialHoldings Limited

11545 0.02 11545 100

57 AAECK7329P Kapeeshwar VintradePrivate Limited

11000 0.02 11000 100



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58 AATCS4365E Samridhipurn ServicesPrivate Limited

6000 0.01 6000 100

59 AAGCR1715E Rangan Vincom PrivateLimited

2000 0 2000 100

Total 28044592 46.47 25476894 90.84

16. It is observed that 29 preferential allottees made a collective profit of ₹91.87 crore on their

total investment of ₹2.01 crore, a substantial return of approximately 4569% on their

investment in a period of 27 months (including the lock in period). It is evident from the

above analysis of trading in Patch 2 that the Exit Providers provided a hugely profitable exit to

the Preferential allottees, who also were related directly/indirectly to Mishka . The profit

earned by the allottees during Patch 2 is given below:-

Table V: Details of the trades carried out by allottees and profit calculation

S.No.

Name of Allottee

PAN of Allottee

No.ofShares Allotted

Adjustment toBonusandShareSplit

AdjustedPurchaseCost

No. ofSharessold

AverageSellingPrice

ProfitMadeon SoldShares

Sharesheld bytheentity

1

GOKULDHAMENTERPR ISES LLP

AALFG1236F

25000 2000000 1.0625 2000000 50.9599770176

0

2PRAKASHMANGILAL SURYA

AAGPS6393C

20000 1600000 1.0625 1306850 37.62 47777357

293150

3 JIGNESHM. AMIN

AAJPA2349H

11700 936000 1.0625 1066300 48.4550533906

-130300

4SHRENIKNALINZAVERI

AAAPZ1721B

12500 1000000 1.0625 1000000 52.7851717459

0

5MAHESHKUMARKHATRY

AADPK 9309F

12500 1000000 1.0625 1000000 54.9053833135

0

6 PRAKASHCHANDKHATRY

AADPK 1946Q

12500 1000000 1.0625 1000000 53.73 52664913

0

7

TARUNKUMARCHANDAK

ADGPC1107P

12500 1000000 1.0625 1000000 49.6848619650

0



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8KALAWA TISHARMA

ACAPS1025K

12500 1000000 1.0625 1000000 47.4546384450

0

9PRAKASHCHAND

SHARMA

AGMPS2776H

12500 1000000 1.0625 1000000 47.2046139608

0

10

CHIRAGMAHESHKUMAR VYAS

ABYPV 5751G

12500 1000000 1.0625 1000000 46.1845119625

0

11

NITINKUMARDIDWANI A

AACPD7055J

25000 2000000 1.0625 997385 39.5938430782

1002615

12SHEETALSANJAYUDESHI

AAAPU2596F

12500 1000000 1.0625 981850 52.1450145741

18150

13 VIMAL JAIN

AADPJ5579L

7500 600000 1.0625 600000 53.6031524600

0

14NARESH JALAN

ACUPJ1252F

12500 1000000 1.0625 592500 50.0529022944

407500

15NARESH JALAN

AABHN4403P

12500 1000000 1.0625 587500 50.1828859136

412500

16MAHABIRPRASAD JALAN

ACFPJ2428J

12500 1000000 1.0625 584000 54.2731071500

416000

17MAHABIRPRASAD

JALAN

AACHM

0965N

12500 1000000 1.0625 470000 54.89253007

25

530000

18SHANKAR BATRA

ACSPB5838R

5000 400000 1.0625 400000 50.4119739502

0

19HARLEENKAUR

AECPC7959J

12500 1000000 1.0625 356950 55.1619310416

643050

20SAVITABANSAL

AEJPB6903J

12500 1000000 1.0625 314000 55.0516950775

686000

21SARADKUMAR B JAIN

AJGPS8091J

7500 600000 1.0625 312500 51.1315645969

287500

22

SMT

RASHMI JAIN

ABTPS0026N 12500 1000000 1.0625 277500 55.07 14988106 722500

23

ASHOKKUMARCHOWATI A

AADPC6863A

7500 600000 1.0625 259500 51.5213092706

340500



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24 TARACHAND LSHAH

ABQPL6153L

7500 600000 1.0625 245500 52.6212657981

354500

25

MADANL AL

BABULALCHOWATI A

AADPC

6859J 7500 600000 1.0625 228500 51.38

114967

19 371500

26BRIJBHUSHAN SINGAL

AEFPS6298M

49000 3920000 1.0625 120000 55.006472580.8

3800000

27SADHNARANI

ABHPA9244J

12500 1000000 1.0625 100000 55.205413750

900000

28

RANIDEV I AGARWAL

AGEPA7936K

12500 1000000 1.0625 77000 48.743671437.5

923000

29RAVINDER KUMARGUPTA

AADHR 3405B

2000 160000 1.0625 44000 55.072376300

116000

17. The transactions wherein the entities of Exit Providers bought most of the shares sold by the

Preferential allottees and Promoter related entities cannot be just a coincidence particularly when

sellers are connected with Mishka / its promoters / directors by virtue of being Preferential

allottees/ Promoter related entities and other factors mentioned in Annexure A. It is interesting

to note that prior to Patch 1, the entire share capital of Mishka was with Preferential

Allottees, Promoters and the entities who received shares from the promoters. Hence, duringPatch 1 the entities related to Promoter Group sold the shares in very less quantity and

certain entities pushed up the price of the scrip by buying these shares from them. It is also

observed that during Patch 1 the shares of Mishka were not in demand by the general

investors of the market and saw a very low volume on most of the trading days and hence

could not have commanded the price as observed in Patch 2. In any market, a sudden supply,

if not matched by similar demand, leads to price fall. Considering the same, any rational

investor would not have dumped a large number of shares without facing the risk of a

significant price fall until and unless he was sure of the demand side absorbing the supply. In

this peculiar case, the Exit Providers created the demand against the supply from thepreferential allotters/Promoter related entities . In the whole process, the principle of price

discovery was kept aside and the market lost its purpose. It is evident from the above analysis

that the Exit Providers provided a hugely profitable exit to the Preferential allottees/ Promoter



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related entities . This could be possible only if the Preferential Allottees, Promoter related

entities, Exit Providers , Mishka and its promoter/ directors were hand in glove with each other.

18. From the above examination and factors as described in Annexure A, I am of the prima facie

view that the Preferential allottees, Promoter related entities , Mishka and Exit Providers are

connected to each other. In this regard, I note that the Hon'ble SAT has in many cases such

as Classic Credit Ltd. vs. SEBI (SAT Appeal no. 68/2003, Order dated December 8, 2006),

Classic Credit Ltd. vs. SEBI (SAT Appeal no. 76/ 2003, Order dated January 9, 2007) and

Veronica Financial Services Ltd. vs. SEBI (SAT Order dated August 24, 2012) has held that

connection/ relations can be established on the basis of factors including common addresses,

common directors/ shareholders, etc.

19. It is pertinent to mention that the key to the scheme of operations employed by Mishka Group

prima facie lies in the preferential allotment of shares made by Mishka . Due to a lock-in of one

year on shares any gains made on the sale of such shares makes the allottees eligible for long

term capital gains ("LTCG"). Further, the promoters of Mishka by offloading the shares to its

connected entities in physical form one year prior to resumption of trading in the scrip, have

also made the transferees eligible for LTCG. From the observations of the preliminary

inquiry it is inter alia noted that :-

As on September 30, 2011, Mishka had only 7 shareholders (5 under promoters and 2

under public category).

Thereafter, the aforesaid 7 shareholders transferred a total of 4,96,000 shares to 452

entities directly/indirectly during the period from December 11, 2011 to February 05,

2013.

In the meantime, Mishka also allotted 7,93,700 shares to 46 related/ associated entities

including 1 promoter, viz. Pearl Arcade Trading Private Limited, at an exorbitant

premium of ₹75/- per share on September 24, 2012.

Then, on February 06, 2013, Mishka announced bonus shares in the ratio of 7:1. As a

result, the share capital of Mishka increased to 1,03,33,600 shares.

Thereafter, suddenly trading started in the scrip of Mishka from February 14, 2013. In

Patch 1, i.e. from February 14, 2013 to February 14, 2014, the price of the scrip graduallyincreased from ₹5.50/- to ₹499/- (unadjusted) and ₹49.90/- (adjusted) with very low

volume.

Prior to February 14, 2013, the entire share capital of Mishka was with Promoters,

Promoter related entities and Preferential allottees.



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Once the price of the scrip increased exponentially, Mishka announced a stock-split in the

ratio of 1:10 on January 16, 2014 to make a passage for preferential allottees to exit since

the stock split would reduce the per share price and increase liquidity.

One month after the stock split, i.e. from February 17, 2014 the preferential allottees and

promoter related entities started selling the shares to entities connected / related, directly orindirectly, to Mishka , thereby making huge profits.

The said price movement was not backed by fundamentals of Mishka and its financials.

20. From the facts stated above, it can safely be assumed that the entire modus operandi of allotting

shares on a preferential basis at a premium, announcing a stock split and then bringing in

connected entities to provide exit was a scheme devised to make ill-gotten gains. Further, the

modus operandi of pumping the share price artificially and then dumping the price so that the

same cycle could be repeated, demonstrates the mala fide of the Mishka Group. Also the

mechanism is presumably being used to deceive the authorities by laundering black money

and making tax-free profits.

21. Further, from the copy of the special resolution passed under section 81(1A) of the

Companies Act, 1956 submitted by Mishka to BSE, it is noted that Mishka had disclosed to its

shareholders that the purpose of aforesaid fund raising through preferential allotment was to

meet requirements for:

a)

capital expenditure including acquisition of company/business;

b) funding long term working capital requirements;

c)

marketing;

d) setting up of offices abroad and;

e) for other approved corporate purposes.

22. As part of its inquiry, SEBI had advised the directors, Company Secretary and promoters of

Mishka vide emails/letters to appear for a meeting on December 05, 2014 and again on

December 12, 2014 at SEBI-Head Office. On both instances, Mishka's management failed to

appear for the meeting. Thereafter, SEBI by way of an email as well as letter dated January

16, 2015, advised Mishka to submit its bank account details highlighting the credit entries

pertaining to proceeds of preferential allotment and debit entries pertaining to utilisation of

preferential allotment along with documentary evidence. The said details were sought in order

to ascertain the genuineness of the preferential allotment made by Mishka . Mishka vide letter

dated January 22, 2015 submitted its reply. From the bank statement submitted by Mishka , it

is observed that out of the total amount i.e. ₹6,74,64,500 raised by Mishka through this



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allotment, ₹2,00,00,000 were given to the share broker CD Equisearch Pvt. Ltd, ₹2,21,21,221

to Esha Securities Limited and ₹2,00,00,000 to one Mr. Jitendra Dewoolkar. This amounted

to total ₹6,21,21,221 (almost 92% of the proceeds). The aforesaid utilisation of proceeds of

preferential allotment does not appear to be for any of the aforesaid purposes as Mishka did

not use them for either capital expenditure or acquisition of company/business or towards working capital or setting up office abroad or for marketing.

23. In view of the above, I note that the funds received as proceeds of preferential allotment

were transferred to various entities and were not used for the purposes as envisaged in the

special resolution passed under section 81(1A) of the Companies Act, 1956. Further, as per

the communication received from BSE vide email dated January 21, 2015, no corporate

announcement has been made by Mishka as required under Clause 43 (a) of listing agreement

indicating the non-utilisation of the proceeds from the preferential allotment for the purpose

they were raised. Thus, Mishka has prima facie failed to comply with Clause 43 (a) of listingagreement which reads as follows:

Clause 43 (a)

"The Company agrees that it will furnish on a quarterly basis a statement to the Exchange indicating the

variations between projected utilisation of funds and / or projected profitability statement made by it in its

prospectus or letter of offer or object /s stated in the explanatory statement to the notice for the general

meeting for considering preferential issue of securities and the actual utilisation of funds and/or actual

profitability"

24. In the facts and circumstances of this case, I am of the view that the preferential allotment

was used as a tool for implementation of the dubious plan, device and artifice of Exit

Providers, preferential allottees and Promoter related entities . One could argue that in order to

make LTCG, the preferential allottees in question could have bought in secondary market

and waited for a year before selling the shares. In the instant case, probably the preferential

allotment route was preferred over secondary market route because the share capital of

Mishka prior to preferential allotment was very small, i.e., 4,98,000 shares (Face Value: ₹10)

to accommodate the required fictitious LTCG of₹

254 crore approximately. As such thecapital expansion through preferential allotment and stock split provided much bigger source

to the persons involved in terms of volume and price manipulation to facilitate the whole

operation.



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25. From the above facts and circumstances it can reasonably be inferred that the preferential

allottees along with Promoter related entities acting in concert with Exit Providers have misused

the stock exchange system to generate fictitious LTCG. It is pertinent to note that LTCG is

tax exempt. Further, it appears that Mishka did not utilize the proceeds of preferential

allotment as per the resolution submitted by it to the exchange. It is noted that SEBI hasalready passed interim orders in the matters of Moryo Industries Limited, Radford Global

Limited and First Financial Services Limited where the modus operandi was that the price of the

scrip increased substantially only on account of the trading activity of the group/related

entities when substantial number of shares were locked in and non transferable/tradable.

Further, the preferential allottees acting in concert with the specified groups have misused the

stock exchange system to generate fictitious LTCG so as to convert their unaccounted

income into accounted one with no payment of taxes as LTCG is tax exempt, and funds

brought in by way of preferential allotment was invested in the shares of connected

companies and by way of purported loans to a group of entities connected with the aforesaidcompanies for the purpose other than those disclosed.

26. Since prior to the trading in its scrip during the Examination Period, Mishka did not have any

significant financial standing in the securities market, in my view, the only way it could have

increased its share value is by way of market manipulation. In this case, it is noted that the

traded volume and price of the scrip increased substantially only after Exit Providers,

Preferential Allottees and Promoter related entities started trading in the scrip. The average

volume increased by 762% during Patch 2. Exit Providers were trading in the scrip above the

LTP and their trades created artificial volumes and manipulated the price of the scrip during

the Examination Period. It is further noted that on the days when Mishka Group was not

trading, the trading volumes in the scrip were very low and the substantial increase in traded

volumes as observed in this case was mainly due to their trading. I further note that Exit

Providers, Preferential allottees and Promoter related entities traded amongst themselves as

substantiated by their matching contribution to net buy and net sell in Patch II. There was no

change in the beneficial ownership of the substantial number of traded shares as the buyers

and sellers both were part of the common group and were acting in concert to provide

LTCG benefits to the Preferential allottees and Promoter related entities. In view of the

above, I prima facie find that Exit Providers, Preferential allottees and Promoter related entities used

securities market system to artificially increase volume and price of the scrip for creating

bogus non taxable profits (i.e. LTCG).



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27. In addition to the above it is noted that prior to February 14, 2013, i.e. from when the trading

in the scrip started, the entire share capital of Mishka was with the promoters, Promoter related

entities and preferential allottees. During the period from February 14, 2013 to February 14,

2014, the price of the scrip increased by around 100 times with the trading volume as meager

as 390 shares per day. The trading volume suddenly increased to 2,97,319 shares per dayduring the period from February 17, 2014 to December 31, 2014, when Exit Providers ,

preferential allottees and Promoter related entities started trading in the scrip. The prima facie

modus operandi appears to be same as that used in the matter of Radford Global Limited where

the stock exchange mechanism was used for the purpose of availing LTCG tax benefit and

Mishka was found actively involved in the whole design to misuse stock exchange mechanism

to generate bogus LTCG.

28. I am of the considered view that the scheme, plan, device and artifice employed in this case,

apart from being a possible case of money laundering or tax evasion which could be seen bythe concerned law enforcement agencies separately, is prima facie also a fraud in the securities

market in as much as it involves manipulative transactions in securities and misuse of the

securities market. The manipulation in the traded volume and price of the scrip by a group of

connected entities has the potential to induce gullible and genuine investors to trade in the

scrip and harm them. As such the acts and omissions of Exit Providers, Preferential allottees and

Promoter related entities are ‘ fraudulent’ as defined under regulation 2(1)(c) of the SEBI

(Prohibition of Fraudulent and Unfair Trade Practices relating to Securities Market)

Regulations, 2003 (‘PFUTP Regulations’) and are in contravention of the provisions of

regulations 3(a), (b), (c) and (d) and 4(1), 4(2)(a), (b), (e) and (g) thereof and section 12A(a),

(b) and (c) of the SEBI Act, 1992. The said provisions are reproduced hereunder:-

SEBI ACT

Prohibition of manipulative and deceptive devices, insider trading and

substantial acquisition of securities or control.

"12A. No person shall directly or indirectly —

(a) use or employ, in connection with the issue, purchase or sale of any securities listed or proposed to be

listed on a recognized stock exchange, any manipulative or deceptive device or contrivance in

contravention of the provisions of this Act or the rules or the regulations made thereunder;

(b) employ any device, scheme or artifice to defraud in connection with issue or dealing in securities which

are listed or proposed to be listed on a recognised stock exchange;



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(c) engage in any act, practice, course of business which operates or would operate as fraud or deceit upon

any person, in connection with the issue, dealing in securities which are listed or proposed to be listed on a

recognised stock exchange, in contravention of the provisions of this Act or the rules or the regulations

made thereunder;"

PFUTP REGULATIONS, 2003

"Prohibition of certain dealings in securities

3. No person shall directly or indirectly —

(a) buy, sell or otherwise deal in securities in a fraudulent manner;

(b) use or employ, in connection with issue, purchase or sale of any security listed or proposed to be listed

in a recognized stock exchange, any manipulative or deceptive device or contrivance in contravention of the

provisions of the Act or the rules or the regulations made there under;

(c) employ any device, scheme or artifice to defraud in connection with dealing in or issue of securities

which are listed or proposed to be listed on a recognized stock exchange;

(d) engage in any act, practice, course of business which operates or would operate as fraud or deceit upon

any person in connection with any dealing in or issue of securities which are listed or proposed to be listed

on a recognized stock exchange in contravention of the provisions of the Act or the rules and the

regulations made there under.

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 a security;(f)…………………………………………………… ……………….

(g) entering into a transaction in securities without intention of performing it or without intention of

change of ownership of such security; "



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29. I note that the directors of Mishka during the relevant time (i.e. Ankit Garodia, Jugalkishore

P Sharma, Kumar Vasishtha and Rameshwar Manohar Wagh), being in control of the day to

day affairs of Mishka , had the knowledge of its acts and omissions. They were also under an

obligation to ensure that acts and transactions of Mishka were not in violation of any of the

applicable provisions of SEBI Regulations or other applicable laws. I, therefore, prima faciefind that these directors as well as Mishka were responsible for Mishka 's acts and omissions

in this case.

30. I am of the opinion that a detailed investigation of the entire scheme employed in this case is

necessary to find out the role of any other entity therein including LTP contributors,

connection amongst the concerned entities and the ultimate owners of funds used for

manipulating the price of the scrip. Therefore, while SEBI would investigate into the

probable violations of the securities laws, the matter may also be referred to other law

enforcement agencies such as Income Tax Department, Enforcement Directorate andFinancial Intelligence Unit for necessary action at their end as may be deemed appropriate by

them.

31. SEBI strives to safeguard the interests of a genuine investor in the Indian securities market.

The acts of artificially increasing the price of scrip mislead investors and the fundamental

tenets of market integrity get violated. Under the facts and circumstances of this case, I prima

facie find that the acts and omissions of Mishka Group as described above are inimical to the

interests of participants in the securities market. Therefore, allowing the entities that are prima

facie found to be involved in such fraudulent, unfair and manipulative transactions to continueto operate in the market would shake the confidence of the investors in the securities market.

32. I have considered the observations in the preliminary inquiry and noted that the shortlisted

entities as mentioned in Table II are connected directly/indirectly with Mishka / its promoters

on account of factors described in Annexure A. The five promoters who were holding the

shares in physical form had transferred their holding in off-market to certain entities as

mentioned in Table II. Further, Mishka also allotted shares under preferential allotment. Once

the shares were allotted/ transferred to the preferential allottees/promoter related group,

certain entities started moving the price of the scrip upwards by trading in very low volumes. The counter parties of these entities were those entities who received shares from the

promoters in physical form. After lock-in of 1 year on preferential shares was over, the Exit

Providers gave exit opportunity to the preferential allottees as well as promoter related entities.

From the bank statement of Mishka , I find that Mishka has transferred funds to some of the



22/68


Exit Providers . I also note that the shortlisted entities have contributed majorly to the market

volume both at buy and the sell side.

33. Further I note that, vide Interim Orders dated December 19, 2014, Mr. Shyam Kanhaiyalal

Vyas and Mr. Bharat Bagri have already been restrained from accessing securities market

directly or indirectly in whatsoever manner in the matter of First Financial Services Limited

and Mr. Bharat Bagri, Mr. Jayesh Narendra Kesharia and Ms. Manjulaben Sukhdev Pandya

have already been restrained from accessing securities market directly or indirectly in

whatsoever manner in the matter of Radford Global Limited for suspected price

manipulation in the respective scrips. Further, Mishka Finance and Trading Limited, Spice

Merchants Private Limited, Apex Commotrade Private Limited, Winall Vinimay Private

Limited and Signet Vinimay Private Limited have also been restrained from accessing

securities market directly or indirectly, in whatsoever manner, in the matter of Radford

Global Limited for suspected volume manipulation and for giving exit opportunity topreferential allottees of Radford Global Limited.

34. Based on the aforesaid findings and taking into consideration the similar modus operandi of

market manipulation adopted in similar matter of Radford Global Ltd, as observed by SEBI

in its Order, it prima facie appears that certain market manipulations are taking place in the

scrip of Mishka. I note that currently major portion of the shareholding (around 66.17%) lies

with the preferential allottees, promoter related entities, exit providers and the promoters of Mishka.

It is also pertinent to mention that vide SEBI's Order in the matter of Radford Global Ltd,

Mishka itself has been restrained from buying, selling or dealing in the securities market, tillfurther directions and the said restraint is in operation as on date. Considering the above, I

am of the view that as an interim, preventive and remedial measure and to maintain orderly

development in the securities market, in the interests of securities market and investors, it

would also be necessary to take immediate steps regarding trading in the scrip of Mishka on

the stock exchange.

35. Considering these facts and the indulgence of a listed company in such a fraudulent scheme,

plan, device and artifice as prima facie found in this case, I am convinced that this is a fit case

where, pending investigation, effective and expeditious preventive and remedial action isrequired to be taken by way of ad interim ex -parte in order to protect the interests of investors

and preserve the safety and integrity of the market.

36. In view of the foregoing, in order to protect the interests of investors and the integrity of the

securities market, I, in exercise of the powers conferred upon me in terms of section 19 read



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with sections 11(1), 11(4) and 11B of the SEBI Act, 1992, pending inquiry/investigation and

passing of final order in the matter, hereby issue the following directions:

a) Following persons/entities are restrained from accessing the securities market and

buying, selling or dealing in securities, either directly or indirectly, in any manner, till

further directions:-

S. No. PAN Name

1 AAACP2548R Mishka Finance and Trading Limited

Mishka's Promoters

2 AAACW0576A WAVE INTER TRADES PVT LTD

3 AAACE1313P EMBASSY FINANCE & CONSULTANTS P LTD

4 AAACT1354P TOHEE TRADING & AGENCIES PVT LTD

5 AAICS7362Q SULABH IMPEX LTD

6 AAFCP6925M PEARL ARCADE TRADING PRIVATE LIMITED

7 AAAPJ3197K VIJAY KUMAR JAINMishka's Directors

8 ARRPG4567A Ankit Garodia

9 ABLPS6840A Jugalkishore Pralhadrai Sharma

10 AKNPV5025B Amit Kumar Vasishtha

11 ABLPW8901G Rameshwar Manohar Wagh

Promoter related entities

12 ABBPR3992G ANIL SATYANARAYAN ROONGTA

13 ACRPC4740L RITESHKUMAR AMITKUMAR CHATTERJEE

14 ACHPS7762G ATUL MORESHAWAR SAVE

15 AKKPP3508Q PARUL RUPESH PODDAR

16 AAOHS4973C SUNIL KUMAR JAIN & SONS HUF

17 AAGHR7451A RAVI KHANNA HUF

18 AAGPA3508D GAJANAND AGARWAL

19 AACPA9922H PANKAJ AGARWAL

20 AANPG3179K BHARAT GANDOTRA

21 AJVPK5048G AADIST KHANNA

22 ARIPK3181H BHAVYA KHANNA

23 AAIPK5106B JYOTI KHANNA

24 AFMPK8726N RAVI KHANNA

25 ACNPA1462H LALIT AGARWAL

26 AELPP0183N RUPESH KUMAR PODDAR27 AAEHD5856M DINDAYAL MALCHAND AGARWAL HUF

28 AACPA5733E KRISHAN AGARWAL

29 ACRPJ3552D SEEMA JAIN

30 BHKPS8506F JAY N SHAH

31 ABYPJ9937E SUNIL KUMAR JAIN



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32 AAGPS9497R NAVINCHANDRA K SHAH

33 AAGPS9498A MALTI NAVINCHANDRA SHAH

34 AGLPP3159L ROHINI VIJAYSINGH PATWARDHAN

35 BEIPA7823N PRANIT AGARWAL

36 AABHA9528A ANIL SATYANARAYAN ROONGTA HUF

Preferential Allottees 37 AEFPS6298M BRIJ BHUSHAN SINGAL

38 AAAHB6923R BRIJ BHUSHAN SINGHAL (HUF)

39 AALFG1236F GOKULDHAM ENTERPRISES LLP

40 AACPD7055J NITIN KUMAR DIDWANIA

41 AAGPS6393C PRAKASH MANGILAL SURYA

42 AAAPZ1721B SHRENIK NALIN ZAVERI

43 AADPK9309F MAHESH KUMAR KHATRY

44 AADPK1946Q PRAKASH CHAND KHATRY

45 ADGPC1107P TARUN KUMAR CHANDAK

46 ACAPS1025K KALAWATI SHARMA47 AGMPS2776H PRAKASH CHAND SHARMA

48 ABYPV5751G CHIRAG MAHESHKUMAR VYAS

49 AAAPU2596F SHEETAL SANJAY UDESHI

50 ACUPJ1252F NARESH JALAN

51 AABHN4403P NARESH JALAN (HUF)

52 ACFPJ2428J MAHABIR PRASAD JALAN

53 AACHM0965N MAHABIR PRASAD JALAN (HUF)54 AECPC7959J HARLEEN KAUR

55 AEJPB6903J SAVITA BANSAL

56 ABTPS0026N SMT RASHMI JAIN

57 AAJPA2349H JIGNESH M. AMIN

58 AADPJ5579L VIMAL JAIN

59 AJGPS8091J SARAD KUMAR B JAIN

60 AADPC6863A ASHOK KUMAR CHOWATIA

61 ABQPL6153L TARACHAND L SHAH

62 AADPC6859J MADANLAL BABULAL CHOWATIA

63 ACSPB5838R SHANKAR BATRA

64 ABHPA9244J SADHNA RANI

65 AGEPA7936K RANIDEVI AGARWAL

66 AADHR3405B RAVINDER KUMAR GUPTA (HUF)

Exit Providers 67 AAKPS3276J Manharlal Narottamdas Shah

68 AAACE2862P Esha Securities Ltd

69 AACCA3220D Amrit Sales Promotion Pvt Limited

70 AADCS5411K Symphony Merchant Pvt Ltd

71 AABCB3052B Bazigar Trading Private Limited



25/68


72 AAGCR1715E Rangan Vincom Private Limited

73 AACCL3868N Ladios Trading Private Limited

74 AADCT8403C Topwell Properties Private Limited

75 AAMCS1712Q Signet Vinimay Private Limited

76 AAMCS1711P Sanklap Vincom P Ltd

77 AAECR0580M Runicha Merchants Private Limited78 AAACW8004B Winall Vinimay Private Limited Ltd

79 AAPCS7492G Spice Merchants Private Limited

80 AAJCA4459K Apex Commotrade Private Limited Ltd

81 AAICS0688K Skm Travels Private Limited

82 AAICS6023N Scope Vyapar Private Limited

83 AAACV8378B Vibgyor Financial Servicepvt Ltd


85 AABCF5486H Function Financial Consultants Private Limited

86 AAECK7329P Kapeeshwar Vintrade Private Limited

87 AAMCS8721P Sinjan Overseas Pvt Ltd88 AABCW0317N Wonder Procon Private Limited Wppl

89 AACCH8885R Helot Properties Pvt Ltd

90 AAECC9285A Cheroot Vanijya Pvt Ltd

91 AATCS3687H Sidhiman Vyapaar Private Limited

92 AAECV4988P Vishnudham Marketing Private Limited

93 AAECT5548F Triala Dealers Private Limited

94 AAICM4750C Mobixa Distributors Private Limited

95 AALCA7880J Antaryami Traders Private Limited

96 AAFCG2554B Gajgamini Merchandise Private Limited

97 AAICM6982C Muchmore Vincom Private Limited98 AAECD5782B Dreamlight Exim Private Limited

99 AAFCG4773J Goldensight Traders Private Limited

100 AAACD9125E Dynamic Portfolio Management & Services Ltd

101 AABCR1974J Ritesh Commercial Holdings Limited

102 AADCR6224M Ritesh Projects Private Ltd.

103 AAECS0352C Stardox Vinimoy Private Limited

104 AABCR3482R Raina Vyapaar Private Ltd

105 AABCR2904A R C Suppliers Private Lim Ited

106 AABCH2251E Hari Om Suppliers Pvt. Ltd.

107 AADCK9346B Kalakar Commercial Private Limited

108 AAFCB0211J Blue Horizon Commosales Private Limited

109 AAGCR8142P Rochak Vinimay Private Limited

110 AAGCR7017M Rochi Dealcom Private Limited

111 AAECD9323N Duari Marketing Private Limited

112 ACIPS8803M S N Srinivasan

113 BABPS7447D Amit Singh



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114 AADCI5139E Indrawati Nirman Pvt Ltd

115 AAGCR4662J Reachsmart Construction Pvt Ltd


117 AARCS9144H Sebika Commodities Private Limited

118 AATCS4365E Samridhipurn Services Private Limited

119 AAFCR9881C Reachsmart Dealtrade Private Limited120 AATCS6718D Swarnprakash Traders Private Limited

121 AAECD8010E Dhyaneshwar Dealers Pvt Ltd

122 AAECD8235D Dhlriti Traders Pvt Ltd

123 AAGCR6009M Ramya Mercantile Pvt Ltd

124 AAFCB4546A Badamisati Apartments Private Limited

125 ATIPM7500N Arunavo Mukherjee

LTP Contributors

126 ACTPV2787Q Shyam Kanheyalal Vyas

127 AADHB8488A Bharat Bagri (HUF)

128 AAEHJ1610D Jayesh Narendra Kesharia (HUF)129 ALVPP7764J Manjulaben Sukhdev Pandya

b) Trading in the securities of Mishka Finance and Trading Limited shall be suspended

till further directions.

37. This order shall come into force with immediate effect. The stock exchanges and the

depositories are directed to ensure that all the above directions are strictly enforced.

38. This order is without prejudice to the right of SEBI to take any other action that may be

initiated against the aforementioned entities in accordance with law. The persons/entities

against whom this order is passed may file their objections, if any, within twenty one days

from the date of this order and, if they so desire, avail themselves of an opportunity of

personal hearing before SEBI, on a date and time to be fixed on a specific request, received

from the said persons/entities.

Sd/-

Date: April 17th, 2015 RAJEEV KUMAR AGARWAL

Place: Mumbai WHOLE TIME MEMBER

SECURITIES AND EXCHANGE BOARD OF INDIA



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Annexure - A

Company Directors and its Promoter

S.No.

PAN Name Relationship

1 AAACP2548R Mishka Finance and Trading Limited

Mishka Finance Ltd ( Bank of Baroda: A/c No: 12920200000506 ) transferred funds to Pine Animation Ltd ( Allahbad Bank: A/c No:50103075412 ) who also has fund transaction withBlue Circle Services Ltd, who is observed to havefund transactions with Amrit Sales Promotion Pvt.Ltd.(HDFC Bank-A/c No: 00080340006392 ) .

2 AAACW0576A WAVE INTER TRADES PVT LTD

Promoter of Mishka as per share holding patternfor September 2011.

3 AAACE1313P EMBASSYFINANCE &

CONSULTANTS PLTD


4 AAACT1354P TOHEE TRADING& AGENCIES PVTLTD


5 AAICS7362Q SULABH IMPEXLTD


6 AAFCP6925M PEARL ARCADE TRADINGPRIVATE LIMITED

Promoter of Mishka as per Shareholding patternfor September 2012.

7 AAAPJ3197K VIJAY KUMAR

JAIN

Promoter of Mishka as per share holding pattern

for September 2011.8 AAGPJ3942C ANKIT JAIN Share Common Address with Mr. Vijay Kumar

Jain.

9 AAGPJ3943D RASHMI JAIN Share Common Address with Mr. Vijay Kumar Jain.

Part I-Promoter related entities

S.No.

PAN Name Relationship

10 AEPPS9885J ANJALI ATUL SAVE ANJALI ATUL SAVE received shares in physical

form from EMBASSY FINANCE &CONSULTANTS P LTD

11 ACHPS7762G ATULMORESHAWARSAVE

ATUL MORESHAWAR SAVE received shares inphysical form from EMBASSY FINANCE &CONSULTANTS P LTD



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12 ATLPM3500D CHANCHALMUNDHRA

CHANCHAL MUNDHRA received shares inphysical form from EMBASSY FINANCE &CONSULTANTS P LTD

13 AAEHD5856M

DINDAYALMALCHAND

AGARWAL HUF

DINDAYAL MALCHAND AGARWAL HUFreceived shares in physical form from EMBASSY

FINANCE & CONSULTANTS P LTD14 ABMPM7213N JAGDISH PRASAD

MUNDHRA JAGDISH PRASAD MUNDHRA received sharesin physical form from EMBASSY FINANCE &CONSULTANTS P LTD

15 AAHHM8275N

JAGDISH PRASADMUNDHRA HUF

JAGDISH PRASAD MUNDHRA HUF receivedshares in physical form from EMBASSYFINANCE & CONSULTANTS P LTD

16 AECPC0899M JITENDRAHIRALALCHHATRISHA

JITENDRA HIRALAL CHHATRISHA receivedshares in physical form from EMBASSYFINANCE & CONSULTANTS P LTD

17 AAIHK2913E KAILASH S

PARASRAMPURIAHUF

KAILASH S PARASRAMPURIA HUF received

shares in physical form from EMBASSYFINANCE & CONSULTANTS P LTD

18 ACNPA1462H LALIT AGARWAL LALIT AGARWAL received shares in physicalform from EMBASSY FINANCE &CONSULTANTS P LTD

19 AAAPW9319A MEGHA RAVI WATTAMWAR

MEGHA RAVI WATTAMWAR received sharesin physical form from EMBASSY FINANCE &CONSULTANTS P LTD

20 CBRPK3025K NIDHI N KEDIA NIDHI N KEDIA received shares in physicalform from EMBASSY FINANCE &

CONSULTANTS P LTD21 AACHN4765M

NIRMAL KUMAR VARUN KUMARHUF

NIRMAL KUMAR VARUN KUMAR HUFreceived shares in physical form from EMBASSYFINANCE & CONSULTANTS P LTD

22 ACQPM1847D NIRMALA DEVIMUNDRA

NIRMALA DEVI MUNDRA received shares inphysical form from EMBASSY FINANCE &CONSULTANTS P LTD

23 AHPPK4767L NITIN S KEDIA NITIN S KEDIA received shares in physical formfrom EMBASSY FINANCE & CONSULTANTSP LTD

24 AIDPC8188J PAVAN JITENDRA

CHHATRISHA

PAVAN JITENDRA CHHATRISHA received

shares in physical form from EMBASSYFINANCE & CONSULTANTS P LTD

25 AGLPP9975C PRAMOD KPARASRAMPURIA

PRAMOD K PARASRAMPURIA received sharesin physical form from EMBASSY FINANCE &CONSULTANTS P LTD



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26 BEIPA7823N PRANIT AGARWAL PRANIT AGARWAL received shares in physicalform from EMBASSY FINANCE &CONSULTANTS P LTD

27 ADUPC7841C PRASHANT JITENDRA

CHHATRISHA

PRASHANT JITENDRA CHHATRISHAreceived shares in physical form from EMBASSY

FINANCE & CONSULTANTS P LTD28 AALHR3103E RAVI B

WATTAMWAR HUFRAVI B WATTAMWAR HUF received shares inphysical form from EMBASSY FINANCE &CONSULTANTS P LTD

29 AACPW5728R RAVI BHASKAR WATTAMWAR

RAVI BHASKAR WATTAMWAR receivedshares in physical form from EMBASSYFINANCE & CONSULTANTS P LTD

30 ACRPC4740L RITESHKUMAR AMITKUMARCHATTERJEE

RITESHKUMAR AMITKUMARCHATTERJEE received shares in physical formfrom EMBASSY FINANCE & CONSULTANTSP LTD

31 AJRPP8338A RITU PPARASREAMPURIA

RITU P PARASREAMPURIA received shares inphysical form from EMBASSY FINANCE &CONSULTANTS P LTD

32 AJQPP3219D SEEMA PPARASRAMPURIA

SEEMA P PARASRAMPURIA received shares inphysical form from EMBASSY FINANCE &CONSULTANTS P LTD

33 AFGPC0469L TRIPTI PCHATTERJEE

TRIPTI P CHATTERJEE received shares inphysical form from EMBASSY FINANCE &CONSULTANTS P LTD

34 ATMPK6409J VEDANSHU N

KEDIA

VEDANSHU N KEDIA received shares in

physical form from EMBASSY FINANCE &CONSULTANTS P LTD

35 AABPA6690F AJAY AGARWAL AJAY AGARWAL received shares in physicalform from EMBASSY FINANCE &CONSULTANTS P LTD

36 AALHA0585K AJAY AGARWALHUF

AJAY AGARWAL HUF received shares inphysical form from EMBASSY FINANCE &CONSULTANTS P LTD

37 AGSPK0865D ASHISH KUMAR ASHISH KUMAR received shares in physicalform from EMBASSY FINANCE &CONSULTANTS P LTD

38 AMCPS6985L BASANT KUMARSARAWGI

BASANT KUMAR SARAWGI received shares inphysical form from EMBASSY FINANCE &CONSULTANTS P LTD

39 AACCG5437G GOLCHHAENTERTAINMENTPVT LTD

GOLCHHA ENTERTAINMENT PVT LTDreceived shares in physical form from EMBASSYFINANCE & CONSULTANTS P LTD



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40 AKGPG2899H HITESH GOLCHHA HITESH GOLCHHA received shares in physicalform from EMBASSY FINANCE &CONSULTANTS P LTD

41 AAVPN4041M M NAVEEN KUMAR M NAVEEN KUMAR received shares in physicalform from EMBASSY FINANCE &

CONSULTANTS P LTD42 ACDPJ5852G MITTALAL JAIN MITTALAL JAIN received shares in physical


43 AAHPB4095P RITU S SARAF RITU S SARAF received shares in physical formfrom EMBASSY FINANCE & CONSULTANTSP LTD

44 ANQPS5905F SANDEEP V SARAF SANDEEP V SARAF received shares in physicalform from EMBASSY FINANCE &CONSULTANTS P LTD

45 ACRPJ3552D SEEMA JAIN SEEMA JAIN received shares in physical formfrom EMBASSY FINANCE & CONSULTANTSP LTD

46 ACVPA2214M SHALU AGARWAL SHALU AGARWAL received shares in physicalform from EMBASSY FINANCE &CONSULTANTS P LTD

47 AJJPS0924R SHANTHA KUMARIM

SHANTHA KUMARI M received shares inphysical form from EMBASSY FINANCE &CONSULTANTS P LTD

48 AATPJ6081F ABHAY KUMAR JAIN

ABHAY KUMAR JAIN received shares inphysical form from EMBASSY FINANCE &

CONSULTANTS P LTD49 AACHA9181N ASHOK KUMAR

REDH HUF ASHOK KUMAR REDH HUF received shares inphysical form from EMBASSY FINANCE &CONSULTANTS P LTD

50 AABPP6520D MAHENDRAPARAKH

MAHENDRA PARAKH received shares inphysical form from EMBASSY FINANCE &CONSULTANTS P LTD

51 ALQPS1421G MAMTA SARAOGI MAMTA SARAOGI received shares in physicalform from EMBASSY FINANCE &CONSULTANTS P LTD

52 AFGPJ7251R MANJU JAIN MANJU JAIN received shares in physical formfrom EMBASSY FINANCE & CONSULTANTSP LTD

53 ALDPS1562M MANOJ KUMARSARAOGI

MANOJ KUMAR SARAOGI received shares inphysical form from EMBASSY FINANCE &CONSULTANTS P LTD



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54 ABEPJ7147G MOOLCHAND JAIN MOOLCHAND JAIN received shares in physicalform from EMBASSY FINANCE &CONSULTANTS P LTD

55 AYOPA2382B NIKUNJ S AGARWAL

NIKUNJ S AGARWAL received shares inphysical form from EMBASSY FINANCE &

CONSULTANTS P LTD56 ADCPJ9848A PUSHPADEVI JAIN PUSHPADEVI JAIN received shares in physical


57 ACWPM0498C PUSHPADEVI JAIN PUSHPADEVI JAIN received shares in physicalform from EMBASSY FINANCE &CONSULTANTS P LTD

58 AIQPJ7756E RASHMI JAIN RASHMI JAIN received shares in physical formfrom EMBASSY FINANCE & CONSULTANTSP LTD

59 AAXHS4963F SANDEEP REDH

HUF

SANDEEP REDH HUF received shares in

physical form from EMBASSY FINANCE &CONSULTANTS P LTD

60 ACOPJ2654F SAROJ JAIN SAROJ JAIN received shares in physical formfrom EMBASSY FINANCE & CONSULTANTSP LTD

61 AGBPJ8881F SUNAYANA JAIN SUNAYANA JAIN received shares in physicalform from EMBASSY FINANCE &CONSULTANTS P LTD

62 ARAPJ5108K SWETA JAIN SWETA JAIN received shares in physical formfrom EMBASSY FINANCE & CONSULTANTSP LTD

63 AFOPJ4431P VIKAS JAIN VIKAS JAIN received shares in physical formfrom EMBASSY FINANCE & CONSULTANTSP LTD

64 AJVPK5048G AADIST KHANNA AADIST KHANNA received shares in physicalform from EMBASSY FINANCE &CONSULTANTS P LTD

65 AAIPK5106B JYOTI KHANNA JYOTI KHANNA received shares in physicalform from EMBASSY FINANCE &CONSULTANTS P LTD

66 AFMPK8726N RAVI KHANNA RAVI KHANNA received shares in physical formfrom EMBASSY FINANCE & CONSULTANTSP LTD

67 AZAPG1972C TEJAS GALA TEJAS GALA received shares in physical formfrom TOHEE TRADING & AGENCIES PVTLTD

68 AAMPM6353N

KHYATI SHAH KHYATI SHAH received shares in physical formfrom TOHEE TRADING & AGENCIES PVT



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LTD

69 AAAPS5162P SACHIN V SHAH SACHIN V SHAH received shares in physicalform from TOHEE TRADING & AGENCIESPVT LTD

70 AAXPM9091Q DAYANAND

ASSARAM MODANI

DAYANAND ASSARAM MODANI received

shares in physical form from TOHEE TRADING& AGENCIES PVT LTD

71 AADPB1550B KAUSHALKANHAYALALBAGADIA

KAUSHAL KANHAYALAL BAGADIAreceived shares in physical form from TOHEE TRADING & AGENCIES PVT LTD

72 AGOPP6473A MADHU GOPALPODDAR

MADHU GOPAL PODDAR received shares inphysical form from TOHEE TRADING & AGENCIES PVT LTD

73 AAEPS7956D POONAMKAUSHALBAGADIA

POONAM KAUSHAL BAGADIA receivedshares in physical form from TOHEE TRADING& AGENCIES PVT LTD

74 BDNPS6529M PRAMILA SURESHSARDA

PRAMILA SURESH SARDA received shares inphysical form from TOHEE TRADING & AGENCIES PVT LTD

75 ABFPM2698Q PREMLATARAMANANDMODANI

PREMLATA RAMANAND MODANI receivedshares in physical form from TOHEE TRADING& AGENCIES PVT LTD

76 AFYPM3247A RAKESHSHASHIKANTMEHTA

RAKESH SHASHIKANT MEHTA receivedshares in physical form from TOHEE TRADING& AGENCIES PVT LTD

77 ABEPM0793M RAMANAND

GANESHLALJIMODANI

RAMANAND GANESHLALJI MODANI

received shares in physical form from TOHEE TRADING & AGENCIES PVT LTD

78 AABPM7263N SONAL RAKESHMEHTA

SONAL RAKESH MEHTA received shares inphysical form from TOHEE TRADING & AGENCIES PVT LTD

79 AYPPS3019L SURESHGIRDHARILALSARDA

SURESH GIRDHARILAL SARDA receivedshares in physical form from TOHEE TRADING& AGENCIES PVT LTD

80 ADAPT3696A MEGHNASANJAYKUMAR TIBREWAL

MEGHNA SANJAYKUMAR TIBREWALreceived shares in physical form from TOHEE TRADING & AGENCIES PVT LTD

81 AAUPT1451A SANJAYKUMARSAJJANKUMAR TIBREWAL

SANJAYKUMAR SAJJANKUMAR TIBREWALreceived shares in physical form from TOHEE TRADING & AGENCIES PVT LTD

82 AAAPG9125E GOPALDASGOENKA

GOPALDAS GOENKA received shares inphysical form from TOHEE TRADING & AGENCIES PVT LTD



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83 AAVPG4863E KESHAV GOENKA KESHAV GOENKA received shares in physicalform from TOHEE TRADING & AGENCIESPVT LTD

84 AADPG1423E SUDHA GOENKA SUDHA GOENKA received shares in physicalform from TOHEE TRADING & AGENCIES

PVT LTD85 AIUPR9150N ANAND RANEJA ANAND RANEJA received shares in physicalform from TOHEE TRADING & AGENCIESPVT LTD

86 AFOPR0263B HEMRAJ RANEJA HEMRAJ RANEJA received shares in physicalform from TOHEE TRADING & AGENCIESPVT LTD

87 BNNPK9250R KAVITA RANEJA KAVITA RANEJA received shares in physicalform from TOHEE TRADING & AGENCIESPVT LTD

88 AACPA9922H PANKAJ AGARWAL PANKAJ AGARWAL received shares in physicalform from TOHEE TRADING & AGENCIESPVT LTD

89 BHKPS8506F JAY N SHAH JAY N SHAH received shares in physical formfrom TOHEE TRADING & AGENCIES PVTLTD

90 AAGPS9498A MALTINAVINCHANDRASHAH

MALTI NAVINCHANDRA SHAH receivedshares in physical form from TOHEE TRADING& AGENCIES PVT LTD

91 AAGPS9497R NAVINCHANDRA KSHAH

NAVINCHANDRA K SHAH received shares inphysical form from TOHEE TRADING & AGENCIES PVT LTD

92 AGGPP5739B ANSHUPRAKASHCHANDR A PODDAR

ANSHU PRAKASHCHANDRA PODDARreceived shares in physical form from WAVEINTER TRADES PVT LTD

93 AAAHB0041C BALKISHAN JAJUHUF

BALKISHAN JAJU HUF received shares inphysical form from WAVE INTER TRADESPVT LTD

94 AABPJ5859P BALKISHANNATHMAL JAJU

BALKISHAN NATHMAL JAJU received sharesin physical form from WAVE INTER TRADESPVT LTD

95 ASLPA3561D GAURAV SANJAY AGARWAL

GAURAV SANJAY AGARWAL received sharesin physical form from WAVE INTER TRADES

PVT LTD96 AAJPJ4245M KANTABALKISHAN JAJU

KANTA BALKISHAN JAJU received shares inphysical form from WAVE INTER TRADESPVT LTD

97 APNPJ3353H KASTURI SANJAY JOSHI

KASTURI SANJAY JOSHI received shares inphysical form from WAVE INTER TRADESPVT LTD



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98 AKWPJ4412F KETKI SANJAY JOSHI

KETKI SANJAY JOSHI received shares inphysical form from WAVE INTER TRADESPVT LTD

99 AHGPJ3412J NIDHI ALKESHRAWKA

NIDHI ALKESH RAWKA received shares inphysical form from WAVE INTER TRADES

PVT LTD100 ASFPK9445C NIPUN N KEDIA NIPUN N KEDIA received shares in physicalform from WAVE INTER TRADES PVT LTD

101 AKKPP3508Q PARUL RUPESHPODDAR

PARUL RUPESH PODDAR received shares inphysical form from WAVE INTER TRADESPVT LTD

102 AAUPK7874L PRABHA B KEDIA PRABHA B KEDIA received shares in physicalform from WAVE INTER TRADES PVT LTD

103 ABEPA0559R RANJANA MANISH AGARWAL

RANJANA MANISH AGARWAL receivedshares in physical form from WAVE INTER TRADES PVT LTD

104 AGLPP3159L ROHINI VIJAYSINGHPATWARDHAN

ROHINI VIJAYSINGH PATWARDHANreceived shares in physical form from WAVEINTER TRADES PVT LTD

105 AELPP0183N RUPESH KUMARPODDAR

RUPESH KUMAR PODDAR received shares inphysical form from WAVE INTER TRADESPVT LTD

106 ABGPJ9472Q SANJAY AMBADAS JOSHI

SANJAY AMBADAS JOSHI received shares inphysical form from WAVE INTER TRADESPVT LTD

107 AJUPK3727B SHALINI NIRMALKEDIA

SHALINI NIRMAL KEDIA received shares inphysical form from WAVE INTER TRADES

PVT LTD108 AGLPP8828J VIJAYSINGHMADHAVRAOPATWARDHAN

VIJAYSINGH MADHAVRAOPATWARDHAN received shares in physical formfrom WAVE INTER TRADES PVT LTD

109 AAAHV1190E VIJAYSINGHPATWARDHANHUF

VIJAYSINGH PATWARDHAN HUF receivedshares in physical form from WAVE INTER TRADES PVT LTD

110 ABGPJ9502P VINITA SANJAY JOSHI

VINITA SANJAY JOSHI received shares inphysical form from WAVE INTER TRADESPVT LTD

111 AAAPD4655J BHARAT

BHAWARLALDAGLIYA

BHARAT BHAWARLAL DAGLIYA received

shares in physical form from WAVE INTER TRADES PVT LTD

112 AWAPS4811P DHAWAL C SHAH DHAWAL C SHAH received shares in physicalform from WAVE INTER TRADES PVT LTD

113 AFHPP7452H JULIE VINODPARMAR

JULIE VINOD PARMAR received shares inphysical form from WAVE INTER TRADESPVT LTD



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114 AAAPD4654K LALITA BHARATDAGLIYA

LALITA BHARAT DAGLIYA received shares inphysical form from WAVE INTER TRADESPVT LTD

115 AABPP6339E MANGIBAI HPARMAR

MANGIBAI H PARMAR received shares inphysical form from WAVE INTER TRADES

PVT LTD116 AABPJ5807D REKHA RAKESH JAIN

REKHA RAKESH JAIN received shares inphysical form from WAVE INTER TRADESPVT LTD

117 AFHPP7451E SHARDA KPARMAR

SHARDA K PARMAR received shares in physicalform from WAVE INTER TRADES PVT LTD

118 AFHPP7450F VINOD HASTIMALPARMAR

VINOD HASTIMAL PARMAR received sharesin physical form from WAVE INTER TRADESPVT LTD

119 AFIPP6863R ABHISEK KUMARPODDAR

ABHISEK KUMAR PODDAR received shares inphysical form from WAVE INTER TRADES

PVT LTD120 ABEPA0558Q ARCHANA SANJAY

AGARWAL ARCHANA SANJAY AGARWAL receivedshares in physical form from WAVE INTER TRADES PVT LTD

121 AFEPP5775J ASHISH KUMARPODDAR

ASHISH KUMAR PODDAR received shares inphysical form from WAVE INTER TRADESPVT LTD

122 AOZPB0748K KAVITA BAPNA KAVITA BAPNA received shares in physicalform from WAVE INTER TRADES PVT LTD

123 AMEPB5017G LAXMI K BAPNA LAXMI K BAPNA received shares in physicalform from WAVE INTER TRADES PVT LTD

124 AMIPP7763K

order in the matter of mishka finance and trading ltd

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