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As discussed in preceding paragraphs, in matters of manipulation, each Order in the matter of Sulabh Engineers and Services Limited Connected Noticee, plays his / her part in the entire scheme. The submission of the Noticees that their trades have to be seen holistically, I note that the allegation against them is that they have contributed significantly to the positive LTP. Therefore, their trades over the LTP have to be analysed based on various parameters like volume, frequency, LTP variation etc. to arrive at a conclusion whether or not the said trades are manipulative in nature. Some of his trades will be at LTP or below LTP but that does not mean that his LTP contribution cannot be examined independently of his other trades, else all manipulation can be covered by other trades. One of the factors that attracts an investor to a scrip is the continuous increase in the price of the scrip.

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It has already been brought out earlier as to how majority of non-Promoter shares were controlled by PDs and their Connected Noticees and as to how the Noticees connected to the company had manipulated the scrip and had contributed to the price rise in the scrip. Therefore, it is concluded that the aforesaid elaborate dubious scheme / plan/ device could be successful only if the company, price manipulators and the preferential allottees were acting in a pre-determined 365trading manner and were hand in glove with each other. With repect to the aforesaid submissions of the Noticees, I note that the off market transfer based on which a connection is established between the Noticees, need not be the scrip which is under investigaton. It can be any scrip in Order in the matter of Sulabh Engineers and Services Limited which the Noticees have transacted in off line mode, irrespective of its volume on the Exchange on which it is traded.

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In view of the aforesaid discussions, it is held that the aforesaid 40 Connected Noticees have manipulated the price of the scrip by contributing to the LTP in patch 2 by their repeated buy trades and have also created a false and misleading appearance of trading in the scrip. Ltd. has submitted that acquisition of 14,400 shares from an erstwhile Promoter cannot be construed as a device or a scheme. Ltd. have then traded in minimum lot size consistently 365trading over a period of months while contributing positively to LTP and also used the said shares to meet their delivery obligation, demonstrates that the acquisition from the erstwhile Promoter was part of a device or a scheme. Ltd. has also made the same submissions as made by Mr. Raj Kumar Agarwal regarding off market transfer and that of price of the scrip was on an upward curve. The said submissions have already been considered above.

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The aforesaid demonstrates a nexus between the allottees and company and its PDs. The same is also substantiated by their conduct as they started selling shares within a short span of time when the lock-in period was over 365trading and when the price of the scrip had increased significantly. In view of the aforesaid, I do not find any merit in the contention of the Connected Noticees that their decision was based on the fundamentals of the company.

The Noticee has a common Director namely Biplab Guha with Mahamani Order in the matter of Sulabh Engineers and Services Limited Name of the Entity Basis of Connection Tradelink Pvt. Ltd. and Entact Equities Private Limited. Finding; It is noted from the order log trade log that the Noticee had last traded in the scrip during the investigation period on 28/5/2014.

Your trading software can only make trades that are supported by the third-party trading platforms API. The scheme not only operated as a fraud on the market but is also an unfair trade practice as it undermines the transparent and good faith dealings between the parties involved. Ordinarily, the trading would have taken place between anonymous parties and the price would have been determined by the market forces of demand and supply. In its submissions, the Noticee has not given how much of ` 14 crore received from second preferential allotment was deployed for new business. Moreover, the mutual fund investment details / investment details that the Noticee has submitted pertains to the financial period 2014 to 2016, hence not relevant to the extant proceedings. The details of land holdings submitted by the company pertains to the year 2018, hence they are not material to the present proceedings.

The aforesaid off market transfers took place post 14/7/2014. Finding; It is noted from the order log trade log that the Noticee had last traded in the scrip during the investigation period on 20/5/2014. Therefore, considering the off market transfers took place subsequent to Noticees trades, a benefit of doubt can be given for the aforesaid off market transfers and the same cannot be taken as an adequate basis of connection for the impugned trades. Libertex trading app kraken bitcoin exchange 10-k sec bittrex delete account a commodities trading platform demo https://topcoinsmarket.io/365trading-com-review-rating/ binary options broker review and only charges trading commissions. Visit the website to apply, or see if you will be eligible for a professional account.

But that does not take away the fact that the initial connection that was established based on off market transfer is erroneous. The submission of the Noticees that some of the entities through which their connection is established have not been charged, is also without any merit. Before levelling an allegation of price manipulation, host of factors have to be examined by the Competent Authority and unearthing 365trading of evidence of contribution of the said entity to the entire scheme on preponderance of probability basis. There may be cases when the interlinking entities have no evidence of acts of contribution to the original scheme. At times these interlinking entities only establishes the passive fact of relationship with the ultimate entity which plays its role as a contributory in the group for a PFUTP violation.

Further, it has also submitted that it is not connected with the Promoters of the company. I note that the allegation in the SCN is that the shares which were not directly owned by the PDs were indirectly controlled by them though connected entities.

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Therefore, considering the off market transfers took place while the Noticee was trading in the scrip, it can be held that the Noticee is connected with Anil Khemka. With respect to Connected Noticees submission that SEBI has not established collusion for the purpose of manipulation of price in the extant matter, I note that the said submission is also made by the preferential allottees. The same have been discussed in preceding http://xinhuanet.com/ paragraphs as to how, in the facts and circumstances of matter, there was a tacit understanding between the Order in the matter of Sulabh Engineers and Services Limited preferential allottees and the company. In the same vein, the submission of the Connected Noticees that merely selling shares when alleged Connected Noticees were also trading cannot lead to an adverse inference against them, is liable to be rejected.

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A single trade was executed on October 9, 2009. This coupled with the fact that the even when the Connected Noticees were traded, the scrip was traded infrequently. The order log trade log reflects that out of 181 trading days during the patch, the scrip traded on 119 trading days and in the said 119 trading days, single trade was executed on 116 trading days. In the given situation, there were considerable buy order quantity pending in the system which considering the history of trading in the scrip and that too over LTP, would make a prudent investor to sell the shares at the very first opportunity that he/she is coming across. The same as per SCN leads towards an inference that the shares Order in the matter of Sulabh Engineers and Services Limited acquired by the 14 entities and by Samtal Financial System Limited and Anant Fin Consultancy Pvt.

Paying a dividend of ` 0.6 does not mean that the company had strong financials. The aforesaid Connected Noticees are unable to demonstrate or provide any plausible reasons as to why any rational investor would like to invest in such a company that has neither any trading history nor have any financial or business youtube video presence/recognition in the market. I, further note that the Connected Noticees have failed to provide any material such as any communication between them and the company, Information Memorandum, etc. Order in the matter of Sulabh Engineers and Services Limited in order to substantiate their contention.

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Thus, the time taken to arrive at such decision / action is a subjective matter and depends on the complexity of the matter, its scale and modus operandi involved. I, therefore, do not find any substance in the contention of the noticees. The other contentions of the Noticees that there is no evidence that their trades had any impact on the trading activity of scrip and that their trades were negligible to have an impact on market equilibrium, stand no merit when totality of the picture is looked at. All of them together enabled launching of the major fraudulent scheme by using https://www.csdn.net/ a dormant, low capital base and low public float company, as noted above. In the facts of the case it is not material that when seen in isolation the Noticees have executed miniscule trades or have traded only for few days, as what is relevant is the role and conduct of each individual in effecting the scheme. For the aforesaid reason, the submission of the Noticees that they are still holding shares is also liable to be rejected. It is also noted from the IR that the Noticees have sold substantial shares at the inflated price with a total net sale value of ` 42.38 crore.

Mr. Raj Kumar Agarwal in his reply has made same submissions as that of Anant Fin Consultancy Ltd. of certain entities not being made part of extant proceedings and no allegation of wrong disclosure filed by Sulabh. The said submissions have been considered in the preceding paragraphs and have been rejected for reasons recorded therein. The Noticee has submitted that he has bought shares in off market on the advice of his acquantaince and off market transfers are not per se illegal. The Noticee has further submitted that he has executed very few sell trades with negligible volume which cannot influence the price of the scrip and when he started executing trades, the price of the scrip had already increased. The above table demonstrates that though there was huge demand for the shares, Order in the matter of Sulabh Engineers and Services Limited still the Connected Noticees were trading in minscule quantity / minimum lot. It is noted that before the beginning of Patch 1A, there was only 1 day when the shares of the company were traded.

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