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BEFORE THE ADJUDICATING OFFICER

SECURITIES AND EXCHANGE BOARD OF INDIA


[ADJUDICATION ORDER NO. AK/AO-117/2015
------------------------------------------------------------------------------------------------------------------------------UNDER SECTION 15-I OF SECURITIES AND EXCHANGE BOARD OF INDIA ACT, 1992 READ
WITH RULE 5 OF SEBI (PROCEDURE FOR HOLDING INQUIRY AND IMPOSING PENALTIES
BY ADJUDICATING OFFICER) RULES, 1995
In respect of
Mr. Rajesh Sudhakar Prabhudesai (PAN: AKFPP6777N)
-------------------------------------------------------------------------------------------------------------------------------

1. Securities and Exchange Board of India (hereinafter referred to as SEBI) notified the SEBI
(Investment Advisers) Regulations, 2013 (hereinafter referred to as the IA Regulations) on January
21, 2013. Regulation 3 of the IA Regulations refers to Application for grant of certificate. Regulation
3(1) of the IA Regulations, in particular, states verbatim as follows:

"On and from the commencement of these regulations, no person shall act as an investment adviser
or hold itself out as an investment adviser unless he has obtained a certificate of registration from the
Board under these regulations:
Provided that a person acting as an investment adviser immediately before the commencement of
these regulations may continue to do so for a period of six months from such commencement or, if it
has made an application for a certificate under sub-regulation (2) within the said period of six months,
till the disposal of such application"

2. Further, Regulation 1(2) of the IA Regulations stated that the IA Regulations would come into force
on the ninetieth day from the date of their publication in the Official Gazette. Thus, the cutoff date to
file application for grant of certificate of registration under Regulation 3 of IA Regulations for
Investment Advisers who were offering Investment Advisory Services was October 21, 2013.

3. Further, SEBI vide its PR No. 53/2013 dated May 29, 2013 had advised that "In terms of the IA
Regulations, no person shall act as an investment adviser or hold itself out as an investment adviser
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unless he has obtained a certificate of registration from the Board or he is specifically exempt." Also
SEBI vide PR No. 77/2013 dated August 28, 2013 had further advised that "All the persons acting as
an investment adviser before the commencement of IA Regulations are advised to make their
application for grant of registration before October 21, 2013, to continue to do so and shall comply
with the requirement of obtaining a certificate of registration for acting as investment adviser under
the IA regulations."

4. An application for registration as Investment Adviser under Regulation 3 of the IA Regulations was
received by SEBI from Mr. Rajesh Sudhakar Prabhudesai (hereinafter referred to as the Noticee) on
November 11, 2014, i.e. after a year from the cut-off date for existing Investment Advisers to file the
application for registration, which was October 21, 2013. Accordingly, the services provided by the
Noticee after October 21, 2013 were allegedly deemed to be unauthorised Investment Advisory
Services.

APPOINTMENT OF ADJUDICATING OFFICER


5. In view of the same, the undersigned was appointed as the Adjudicating Officer vide Order dated
February 26, 2015 under section 15-I of Securities and Exchange Board of India Act, 1992 (hereinafter
referred to as SEBI Act) read with rule 3 of SEBI (Procedure for Holding Inquiry and Imposing
Penalties by Adjudicating Officer) Rules, 1995 (hereinafter referred to as Rules) to inquire into and
adjudge under Sections 15HB of the SEBI Act, the alleged violation by the Noticee of the provisions of
Section 12(1) of SEBI Act read with Regulation 3 of IA Regulations.

SHOW CAUSE NOTICE, HEARING AND REPLY


6. Accordingly, a show cause notice no. EAD-6/AK/SK/16250/2015 dated June 11, 2015
(hereinafter referred to as SCN) was issued to the Noticee under Rule 4 of the Rules. The
Noticee was called upon to show cause as to why an inquiry should not be held against him
in terms of Rule 4 of Rules read with Section 15I of SEBI Act and why penalty should not be
imposed on him under Section 15HB of the SEBI Act.

7. The Noticee vide letter dated June 28, 2015 in reply to the SCN, while admitting the delay in making
an application for registration has inter-alia submitted as follows:
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a. That he started his business in December 2010, and at the time of deadline of IA registration his
business was so weak that he was not sure whether he could afford to continue the business.
Also that if the business improves, he had plans to get himself registered as a Research Analyst;
b. That since the stock market started rallying from late 2013, he got boost in his business and
started planning for registration as Research Analyst;
c. That in his career he was never directly involved in compliance / SEBI and once he started
studying regulations (IA and RA), he realized that for his business he was required to register as
IA. Since IA registration was closed at that time, he thought to wait till the process opened
again. But he later thought that rather than waiting he should approach SEBI, and therefore, he
approached SEBI for IA registration;
d. That he had never had any intention to work outside the purview of SEBI and the delay was
because of circumstances explained above. He wished to be completely compliant with SEBI
Regulations and being a serious long term stock market professional, he was aware that he
cannot work outside purview of SEBI Rules and Regulations. There was no reasons/ benefits to
gain by working outside of SEBI ambit;
e. That fee charged by him is not transaction based, but, a combination of fixed fee per period plus
performance fee over a period of time. Further that even today, fixed fee per annum is small.
His income becomes meaningful only when his clients make capital gains and pay performance
based fee. In 2014 when market rallied and his clients made money, they paid performance fees
to him. But the stocks they were holding may have been recommended in 2014, 2013 or before.
So the fees generated in 2014 did not correspond to work done by him only in 2014, but, also
result of work done by him in past;
f.

That for same level of business, if market were to remain weak for a year and clients did not
make enough money, than his performance fees will also drop substantially. So given the
market /performance, fee based and non-transaction based nature of his fee/ income, his
income in 2014 should not be seen as normal income (it was an exceptional year), but, on multiyear average basis.

8. Thereafter, in accordance with the principle of natural justice, an opportunity of personal hearing
before me was accorded to the Noticee on August 17, 2015 and the Noticee was duly intimated of
the same vide hearing notice dated July 28, 2015. During the personal hearing, the Noticee reiterated
the submissions made vide reply dated June 28, 2015. The Noticee was inter alia advised to submit
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(i) the fee structure with respect to fees charged to clients since start of the business in December
2010 and subsequent changes made in the said fee structure (ii) the breakup of new clients
registered and fees collected (INR) (fee structure-wise) month-wise from October 21, 2013 along
with supporting IT Returns.

9.

The Noticee while submitting the copies of his Income Tax Return (ITR) filed for Assessment Year
2015-16 and 2014-15 along with supporting papers etc. vide his letters dated August 28, 2015 and
August 31, 2015 inter alia stated as follows:
a. That his clients had made significant capital gains based on his advice, and that most of the fee
income was the performance fees which was paid by the clients when they earned returns;
b. Further that most of his income during the period came from stock brokers;
c. That he had two types of clients, viz. Brokerages and Retail Investors. Brokerages do not pay him
any fixed fees, whereas they pay a percentage of profits made;
d. That retail clients pay fixed fees which vary from zero to 1% of Assets under Advice.
Performance fee is 10% of profits above return of 10% per annum;
e. That there has been no change in the fee structure in the period under consideration (December
2010 to March 2015).

CONSIDERATION OF ISSUES AND FINDINGS


10. I have carefully perused the written submissions of the Noticee, documents/ records/ supporting
papers submitted by the Noticee, submissions made at the hearing and thereafter and the other
material available on record. The issues that arise for consideration in the present case are:
a. Whether the services provided by the Noticee after October 21, 2013 were Unauthorized
Investment Advisory Services and hence in violation of Section 12(1) of SEBI Act read with
Regulation 3 of IA Regulations?
b. Does the violation, if any, on the part of the Noticee attract monetary penalty under Section
15HB of the SEBI Act?
c. If so, what would be the monetary penalty that can be imposed against the Noticee taking into
consideration the factors mentioned in section 15J of the SEBI Act?

11. Before moving forward, it will be appropriate to refer to the relevant provisions of Section 12(1) of
SEBI Act and Regulation 3 of the IA Regulations which reads as under:
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SEBI Act, 1992


Registration of stock brokers, sub-brokers, share transfer agents, etc.
12. (1) No stock broker, sub-broker, share transfer agent, banker to an issue, trustee of trust
deed, registrar to an issue, merchant banker, underwriter, portfolio manager, investment adviser
and such other intermediary who may be associated with securities market shall buy, sell or deal
in securities except under, and in accordance with, the conditions of a certificate of registration
obtained from the Board in accordance with the regulations made under this Act:
Provided that a person buying or selling securities or otherwise dealing with the securities
market as a stock broker, sub-broker, share transfer agent, banker to an issue, trustee of trust
deed, registrar to an issue, merchant banker, underwriter, portfolio manager, investment adviser
and such other intermediary who may be associated with securities market immediately before
the establishment of the Board for which no registration certificate was necessary prior to such
establishment, may continue to do so for a period of three months from such establishment or, if
he has made an application for such registration within the said period of three months, till the
disposal of such application:
Provided further that any certificate of registration, obtained immediately before the
commencement of the Securities Laws (Amendment) Act, 1995, shall be deemed to have been
obtained from the Board in accordance with the regulations providing for such registration.

IA Regulations (Notified on January 21, 2013)


Application for grant of certificate
3. (1) On and from the commencement of these regulations, no person shall act as an investment
adviser or hold itself out as an investment adviser unless he has obtained a certificate of
registration from the Board under these regulations:
Provided that a person acting as an investment adviser immediately before the commencement
of these regulations may continue to do so for a period of six months from such commencement
or, if it has made an application for a certificate under sub-regulation(2) within the said period of
six months, till the disposal of such application.

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12. We will first consider the issue of whether the services provided by the Noticee after October 21,
2013 were Unauthorized Investment Advisory Services and, hence, in violation of Section 12(1) of
SEBI Act read with Regulation 3 of IA Regulations.

13. As observed in preceding paragraphs, SEBI notified the IA Regulations on January 21, 2013.
Regulation 3 of the IA Regulations, which refers to Application for grant of certificate requires that
on commencement of the IA Regulations, no person shall act as an investment adviser unless he has
obtained a certificate of registration from the Board. Further, the Regulation provides that a person
who was acting as an investment adviser immediately before the commencement of these
regulations may continue to do so for a period of six months from such commencement or, if it has
made an application for a certificate within the said period of six months, till the disposal of such
application. The cutoff date to file application for grant of certificate of registration under Regulation
3 of IA Regulations for Investment Advisers who were offering Investment Advisory services was,
thus, October 21, 2013.

14. Further, SEBI vide Press Release (PR) No. 53/2013 dated May 29, 2013 had advised that "In terms of
the IA Regulations, no person shalll act as an investment adviser or hold itself out as an investment
adviser unless he has obtained a certificate of registration from the Board or he is specifically
exempt." Also SEBI vide PR No. 77/2013 dated August 28, 2013 had further advised that "All the
persons acting as an investment adviser before the commencement of IA Regulations are advised to
make their application for grant of registration before October 21, 2013 to continue to do so and shall
comply with the requirement of obtaining a certificate of registration for acting as investment adviser
under the IA regulations."

15. However despite the same, I note that the Noticee filed his application for registration as Investment
Adviser only on November 11, 2014, i.e. after a year from the cut-off date for existing Investment
Advisers to file the application for registration, which was October 21, 2013. Since the Noticee did
not apply within the prescribed time limit, the clause of continuation of business does not apply to
the Noticee. Accordingly, the services provided by the Noticee after October 21, 2013 are deemed to
be unauthorised Investment Advisory Services.

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16. SEBI vide email dated November 28, 2014, letter dated December 09, 2014 and email dated January
06, 2015 sought further details from the Noticee after receipt of his application. In response, based
on information submitted by the Noticee to SEBI, which has been received by SEBI on December 08,
2014, December 17, 2014 and January 19, 2015, it was observed that:
a. The Noticee had started his business of Investment Advisory since December 2010 and that he
catered to Brokers as well as Individual Investors;
b. That the Noticee recommends to his client brokers which stocks to buy, how much to invest in
each recommended stock and also advise them on selling of the stocks. Further that fees are
based on performance of his recommendations and this accounts for 75% of his revenue;
c. That to individual investors, the Noticee recommends which stocks to buy and how much to
buy. The clients execute the transactions through their own brokers and that fees are paid by
investors to him as per mutual understanding between the Noticee and the client. That this
represents large part of his business in terms of number of customers and 25% of the Noticees
revenues;
d. That the Noticee tries to understand how much risk a client is ready to take in equity markets
and client's investment objective from equity investment and recommends stocks to clients
taking into consideration the risk profile of the client, risk profile of the stock, risk profile of
clients existing equity investments, client's invested amount vis-a-vis total funds available for
equities, etc.

17. The Noticee submitted to SEBI that during the years 2011, 2012, 2013 and 2014, there were 9, 23, 27
and 48 clients respectively, fees collected during the years 2011, 2012, 2013 and 2014 were Rs.
55,000/-, Rs. 1,59,150/-, Rs. 4,97,835/- and Rs. 33,02,642/- respectively and assets under advice
during the years 2011, 2012, 2013 and 2014 were Rs. 4.07 crore, Rs. 7.83 crore, Rs. 10.47 crore and
Rs. 20.05 crore respectively.

18. I note that the IA Regulations, under Regulation 2 (l) defines investment advice and Regulation
2(m) defines investment adviser as follows:
2 (l) investment advice means advice relating to investing in, purchasing, selling or otherwise
dealing in securities or investment products, and advice on investment portfolio containing
securities or investment products, whether written, oral or through any other means of
communication for the benefit of the client and shall include financial planning:
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Provided that investment advice given through newspaper, magazines, any electronic or
broadcasting or telecommunications medium, which is widely available to the public shall not be
considered as investment advice for the purpose of these regulations;

2 (m) investment adviser means any person, who for consideration, is engaged in the business
of providing investment advice to clients or other persons or group of persons and includes any
person who holds out himself as an investment adviser, by whatever name called;

19. From the submissions of the Noticee, it is noted that the Noticee recommends to his client brokers
which stocks to buy, how much to invest in each recommended stock and also advises them on
selling of the stocks. Further, to individual investors the Noticee recommends which stocks to buy
and how much to buy. Hence, I note that the Noticee provides advice relating to investing in,
purchasing, selling or otherwise dealing in securities or investment products, and advice on
investment portfolio containing securities or investment products. Moreover, I note that since the
Noticee tries to analyze the risk appetite of each client, his services are personalized and not widely
available to the public. Thus, I find that the services provided by the Noticee, where he recommends
stocks to the clients based on risk profile of the client, risk profile of the stock, risk profile of existing
equity investments, etc., are in the nature of investment advice as defined under the IA
Regulations.

20. Further, as per details provided by the Noticee it is clear that the Noticee provides the investment
advice for a fee, i.e. for consideration. Hence, the Noticee was acting as an Investment Adviser as
defined under the IA Regulations. I note that the Noticee has also admitted to the same in his
submissions made. Moreover, Section 12 (1) of the SEBI Act mandates that no intermediary who may
be associated with securities market shall buy, sell or deal in securities except under, and in
accordance with, the conditions of a certificate of registration obtained from the Board in accordance
with the regulations made under this Act. Since the Noticee did not apply for a certificate of
registration within the prescribed time provided under the IA Regulations, I note that the services
provided by the Noticee after October 21, 2013 are deemed to be Unauthorized Investment
Advisory Services.

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21. I note from the submissions of the Noticee that he has neither denied acting as an investment
adviser, nor, has he claimed that the application was filed by him within the prescribed time. Rather,
the Noticee has stated that he wished he had registered on time. I find that the Noticee has stated
that due to some uncertainties in his business he was not sure whether he could afford to continue
his business. However, I note that SEBI in the IA Regulations had provided for a buffer period of six
months from the commencement of the IA Regulations for making an application under the said
regulations. Any person who had been acting as an investment adviser immediately before the
commencement of the IA Regulations was permitted to continue to do so for another six months,
and thereafter if they made an application for registration, they could further continue their
providing investment advice till disposal of such application. Furthermore, I note that the IA
Regulations commenced only after a period of ninety days from the notification of the same in the
Official Gazette. Hence, from the date of notification of the IA Regulations, any person who had been
acting as an investment adviser had nearly nine months to ascertain and decide whether they would
like to make an application for registration to SEBI or discontinue their business/ service of providing
investment advice. Thus, it was not as though SEBI had introduced the IA Regulations and not
provided any time to those who had been acting as investment advisers to decide which of the afore
stated two options was more feasible. On the contrary, SEBI had provided a long enough time period
of nearly nine months for filing an application for registration under the IA Regulations. However, I
find that even after the lapse of the said nine months period, the Noticee took another year to file his
application to be registered as an investment adviser. The argument made by the Noticee that he
was planning to get registered as Research Analyst too is devoid of merit, as from the submissions
made it is clear that the Noticee was carrying on investment advisory activities. Hence, I am unable to
accept the Noticees defense as above. Besides, to make an application for registration under IA
Regulations, I do not see any reason whereby the Noticee was required to be directly involved in
compliance/ SEBI, which the Noticee has claimed he was not.

22. Thus, I find from the above that the services provided by the Noticee after October 21, 2013 were
Unauthorized Investment Advisory Services and, hence, in violation of Section 12(1) of SEBI Act read
with Regulation 3 of IA Regulations.

23. The Honble Supreme Court of India in the matter of SEBI Vs. Shri Ram Mutual Fund [2006] 68 SCL
216(SC) held that In our considered opinion, penalty is attracted as soon as the contravention of the
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statutory obligation as contemplated by the Act and the Regulations is established and hence the
intention of the parties committing such violation becomes wholly irrelevant..

24. In view of the foregoing, I am convinced that it is a fit case to impose monetary penalty under section
15HB of the SEBI Act, which reads as under :
15HB:- Penalty for contravention where no separate penalty has been provided. Whoever fails
to comply with any provision of this Act, the rules or the regulations made or directions issued
by the Board there under for which no separate penalty has been provided, shall be liable to a
penalty which may extend to one crore rupees.
25. While determining the quantum of monetary penalty under section 15HB, I have considered the
factors stipulated in section 15J of SEBI Act, which reads as under:15J - Factors to be taken into account by the adjudicating officer
While adjudging quantum of penalty under section 15-I, the adjudicating officer shall have due
regard to the following factors, namely:(a) The amount of disproportionate gain or unfair advantage, wherever quantifiable, made as a
result of the default;
(b) The amount of loss caused to an investor or group of investors as a result of the default;
(c) The repetitive nature of the default.

26. I note that by his own admission, the Noticee worked as an Investment Adviser after October 21,
2013. I note from the details provided by the Noticee to SEBI that 20 clients were added by the
Noticee after October, 2013 and Assets under Advice in respect of these 20 clients was approx. Rs.
3.11 crore. I find further from the submissions made by the Noticee that total fee income earned by
the Noticee during FY 2014-15 was Rs. 30.70 lacs, of which Rs. 2.1 lac was fee income from research
activities. Further for FY 2013-14, the Noticee has stated that total fee income earned was Rs. 12.70
lacs and it was Rs. 8 lacs post October 21, 2013, of which Rs. 6.10 lacs was from Investment Advisory
activities and Rs. 1.85 lacs was fee income from research activities.

27. I note that the Noticee has also stated that fee charged by him is not transaction based, but, a
combination of fixed fee per period plus performance fee over a period of time. Further that most of
the fee income earned were the performance fees which were paid by clients when they earned
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returns, however, the Noticee may have made his recommendation in the earlier years. I find that
the Noticee has given some summary statement showing break-up of fees earned from October 2013
onwards. As per the said break-up provided, fixed fee earned by the Noticee from October 2013
onwards has been shown as approx. Rs. 3.90 lacs and Performance fee earned by the Noticee from
October 2013 onwards has been shown as approx. Rs. 30.82 lacs.
28. In the matter, I find that firstly no supporting documentation authenticating the self segregation
made by the Noticee into fixed and performance fee has been provided. Secondly, the Noticee could
not under the pretext of not being able to make up his mind as to whether to continue with
investment advisory activities or register as Research Analyst, continue to carry on with Investment
Advisory business and add new clients, without making an application for grant of certificate under
the IA Regulations within the time stipulated under the said Regulations. Besides, I find it pertinent to
mention here that Securities and Exchange Board of India (Research Analysts) Regulations, 2014

were notified only on September 01, 2014, whereas, IA Regulations were notified as early as on
January 21, 2013 and the cut-off date to file application for grant of certificate of registration
under IA Regulations was October 21, 2013 i.e. much before the Securities and Exchange Board
of India (Research Analysts) Regulations, 2014 were in place. Hence, I find no merit in the
argument advanced by the Noticee as aforesaid.
29. I note, thus, that the Noticee as per his submissions had earned approx. Rs. 34.70 lacs from

Investment Advisory activities subsequent to October 21, 2013. I find further that the Noticee had
not filed an application for registration under the IA Regulations within the time stipulated therein,
though not exempted from registration under the IA Regulations. Under the circumstances, the

Noticee could not have held himself out as an Investment Advisor to receive consideration, whether
by means of performance based fees or otherwise.

30. I note that in its Order in the matter of Saikala Associates Ltd. vs SEBI (Date of Judgment- 21 April,
2005) the Honble Securities Appellate Tribunal (SAT ) has opined that the violation of dealing as unregistered sub-broker and non-segregation of clients'
funds from own funds are serious in nature, since the interest of investors at large is
involved. (emphasis added)

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In the said matter, the Honble SAT has further also held that the appellant acted unauthorisedly as a sub-broker from 18.7.2000 to 18.1.2001 on
the NSE. The amount of commission the appellant would have earned would not be less
than Rs. 3 lakhs. This in our view, is unjust enrichment. We feel it appropriate that the
appellant should disgorge this commission.

12. This order is passed in public interest as a mere warning would not pinch the pocket
of the appellant and penal consequences would in our view, have a greater deterrent
effect on the appellant.
31. Similarly, in the present case too, though I find that there is no allegation of fraud or other illegal
conduct against the Noticee, the Noticees conduct of providing Unauthorized Investment Advisory
Services for a fee, continuing to receive consideration from clients, performance based or otherwise,
without making an application for grant of certificate of registration under the IA Regulations, was in
clear violation of the IA Regulations. I find it pertinent to mention here that registration is with the
objective of protecting the interests of the investors, as it casts accountability and responsibility upon
the registered Investment Advisor to comply with all regulatory requirements applicable to the
conduct of its business activity, so as to promote the best interests of clients and the integrity of the
market. I consider that the act of the Noticee of continuing to do investment advisory business,
continuing to add new clients and continuing to receive consideration from clients, without making
an application for registration under the IA Regulations within the period stipulated, was in reckless
disregard to the regulatory requirement in place, resulting in his unjust enrichment. And I note that
the Noticee has unjustly enriched himself by approx. Rs. 34.70 lacs.

ORDER
32. After taking into consideration all the facts and circumstances of the case, I impose a penalty of
Rs.35,00,000/- (Rupees Thirty Five lacs only) on the Noticee, Mr. Rajesh Sudhakar Prabhudesai,
under 15HB of the SEBI Act for the violation of the provisions of Section 12(1) of SEBI Act read with
Regulation 3 of IA Regulations which will be commensurate with the violations committed by him.

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33. The Noticee shall pay the said amount of penalty by way of demand draft in favour of SEBI Penalties Remittable to Government of India, payable at Mumbai, within 45 days of receipt of this
order. The said demand draft should be forwarded to Smt. Barnali Mukherjee, Chief General
Manager, Investment Management Department, SEBI Bhavan, Plot No. C 4 A, G Block, Bandra
Kurla Complex, Bandra (E), Mumbai 400 051.
34. In terms of rule 6 of the Rules, copies of this order are sent to the Noticee and also to the Securities
and Exchange Board of India.

Date: December 23, 2015


Place: Mumbai

Adjudication Order in the matter of Mr. Rajesh Sudhakar Prabhudesai

Anita Kenkare
Adjudicating Officer

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