Order in The Matter of Mishka Finance and Trading Ltd.

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:
------------------------------------------------------------------------------------------------------------------------------------------------Order in the matter of Mishka Finance and Trading Ltd.

Page 1 of 68
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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
Page 2 of 68
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 had
a 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 trading
in 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 shares
per 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.
Page 3 of 68
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, Manjulaben
Sukhdev 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.
Name reflected
in the Interim
Order
First Financial Ltd
Radford,
First
Financial Ltd
PAN
ACTPV2787Q
Name
Shyam Kanheyalal Vyas
AADHB8488A
Bharat Bagri Bagri

Jayesh
Narendra
Kesharia
Radford
Manjulaben
Sukhdev
Pandya
Radford
AAEHJ1610D
ALVPP7764J
Total
Positive
LTP
Contribution
as a buyer
235.46
% to Total
Positive LTP
Contribution
69.46
8.5
2.51
5.25
1.55
2.4
251.61
0.71
74.23
9. It is observed that the entities named in the above Table were instrumental in contributing to
the 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 jumped
sharply 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
Page 4 of 68
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:
S. No.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
PAN
ABBPR3992G
ACRPC4740L
ACHPS7762G
AKKPP3508Q
AAOHS4973C
AAGHR7451A
AAGPA3508D
AACPA9922H
AANPG3179K
AJVPK5048G
ARIPK3181H
AAIPK5106B
AFMPK8726N
ACNPA1462H
AELPP0183N
Promoter related entities

Name
ANIL SATYANARAYAN ROONGTA
RITESHKUMAR AMITKUMAR CHATTERJEE
ATUL MORESHAWAR SAVE
PARUL RUPESH PODDAR
SUNIL KUMAR JAIN & SONS HUF
RAVI KHANNA HUF
GAJANAND AGARWAL
PANKAJ AGARWAL
BHARAT GANDOTRA
AADIST KHANNA
BHAVYA KHANNA
JYOTI KHANNA
RAVI KHANNA
LALIT AGARWAL
RUPESH KUMAR PODDAR

Page 5 of 68
16
17
18
19
20
21
22
23
24
AAEHD5856M
AACPA5733E
ACRPJ3552D
BHKPS8506F
ABYPJ9937E
AAGPS9497R
AAGPS9498A
AGLPP3159L
BEIPA7823N
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
AEFPS6298M
AALFG1236F
AACPD7055J
AAGPS6393C
AAAPZ1721B
AADPK9309F
AADPK1946Q
ADGPC1107P
ACAPS1025K
AGMPS2776H
ABYPV5751G
AAAPU2596F
ACUPJ1252F
AABHN4403P
ACFPJ2428J
AACHM0965N
AECPC7959J
AEJPB6903J
ABTPS0026N
AAJPA2349H
AADPJ5579L
AJGPS8091J
AADPC6863A
ABQPL6153L
AADPC6859J
ACSPB5838R
ABHPA9244J
AGEPA7936K
DINDAYAL MALCHAND AGARWAL HUF

KRISHAN AGARWAL
SEEMA JAIN
JAY N SHAH
SUNIL KUMAR JAIN
NAVINCHANDRA K SHAH
MALTI NAVINCHANDRA SHAH
ROHINI VIJAYSINGH PATWARDHAN
PRANIT AGARWAL
Preferential Allottees
BRIJ BHUSHAN SINGAL
GOKULDHAM ENTERPRISES LLP
NITIN KUMAR DIDWANIA
PRAKASH MANGILAL SURYA
SHRENIK NALIN ZAVERI
MAHESH KUMAR KHATRY
PRAKASH CHAND KHATRY
TARUN KUMAR CHANDAK
KALAWATI SHARMA
PRAKASH CHAND SHARMA
CHIRAG MAHESHKUMAR VYAS
SHEETAL SANJAY UDESHI
NARESH JALAN
NARESH JALAN
MAHABIR PRASAD JALAN
HARLEEN KAUR
SAVITA BANSAL
SMT RASHMI JAIN
JIGNESH M. AMIN
VIMAL JAIN
SARAD KUMAR B JAIN
ASHOK KUMAR CHOWATIA
TARACHAND L SHAH
MADANLAL BABULAL CHOWATIA
SHANKAR BATRA
SADHNA RANI
RANIDEVI AGARWAL

Page 6 of 68
53
AADHR3405B
RAVINDER KUMAR GUPTA (HUF)
Exit Providers
54
55
56
57
58
59
60
61
62
63
64
65
66
67
68
69
70
71
72
73
74
75
AAKPS3276J
AAACE2862P
AACCA3220D
AADCS5411K
AABCB3052B
AAGCR1715E
AACCL3868N
AADCT8403C
AAMCS1712Q
AAMCS1711P
AAECR0580M
AAACW8004B
AAPCS7492G
AAJCA4459K
AAICS0688K
AAICS6023N
AAACV8378B
AACCH4303G
AABCF5486H
AAECK7329P
AAMCS8721P
AABCW0317N
Manharlal Narottamdas Shah

Esha Securities Ltd
Amrit Sales Promotion Pvt Limited
Symphony Merchant Pvt Ltd
Bazigar Trading Private Limited
Rangan Vincom Private Limited
Ladios Trading Private Limited
Topwell Properties Private Limited
Signet Vinimay Private Limited
Sanklap Vincom P Ltd
Runicha Merchants Private Limited
Winall Vinimay Private Limited Ltd
Spice Merchants Private Limited
Apex Commotrade Private Limited Ltd
Skm Travels Private Limited
Scope Vyapar Private Limited
Vibgyor Financial Servicepvt Ltd
Helpful Investment Advisory Private Limited
Function Financial Consultants Private Limited
Kapeeshwar Vintrade Private Limited
Sinjan Overseas Pvt Ltd
Wonder Procon Private Limited Wppl
76
77
78
AACCH8885R
AAECC9285A
AATCS3687H
Helot Properties Pvt Ltd

Cheroot Vanijya Pvt Ltd
Sidhiman Vyapaar Private Limited
79
AAECV4988P
Vishnudham Marketing Private Limited
80
AAECT5548F
Triala Dealers Private Limited
81
AAICM4750C
Mobixa Distributors Private Limited
82
83
84
85
86
87
88
AALCA7880J
AAFCG2554B
AAICM6982C
AAECD5782B
AAFCG4773J
AAACD9125E
AABCR1974J
Antaryami Traders Private Limited

Gajgamini Merchandise Private Limited
Muchmore Vincom Private Limited
Dreamlight Exim Private Limited
Goldensight Traders Private Limited
Dynamic Portfolio Management & Services Ltd
Ritesh Commercial Holdings Limited
89
AADCR6224M
Ritesh Projects Private Ltd.

Page 7 of 68
90
91
92
93
94
95
96
97
98
99
100
101
102
103
104
105
106
107
108
109
110
111
112
AAECS0352C
AABCR3482R
AABCR2904A
AABCH2251E
AADCK9346B
AAFCB0211J
AAGCR8142P
AAGCR7017M
AAECD9323N
ACIPS8803M
BABPS7447D
AADCI5139E
AAGCR4662J
AABCO6950F
AARCS9144H
AATCS4365E
AAFCR9881C
AATCS6718D
AAECD8010E
AAECD8235D
AAGCR6009M
AAFCB4546A
ATIPM7500N
Stardox Vinimoy Private Limited

Raina Vyapaar Private Ltd
R C Suppliers Private Lim Ited
Hari Om Suppliers Pvt. Ltd.
Kalakar Commercial Private Limited
Blue Horizon Commosales Private Limited
Rochak Vinimay Private Limited
Rochi Dealcom Private Limited
Duari Marketing Private Limited
S N Srinivasan
Amit Singh
Indrawati Nirman Pvt Ltd
Reachsmart Construction Pvt Ltd
Overload Financial Advisory Pvt Ltd
Sebika Commodities Private Limited
Samridhipurn Services Private Limited
Reachsmart Dealtrade Private Limited
Swarnprakash Traders Private Limited
Dhyaneshwar Dealers Pvt Ltd
Dhlriti Traders Pvt Ltd
Ramya Mercantile Pvt Ltd
Badamisati Apartments Private Limited
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
Shares
sold
% of
Total
allotted
shares
Preferential 18921835 61.00%

Allottee
Shares
purchased from
preferential
allottees/Prom
oter related
entities
% to Exit
Provider
Gross
Bought
Volume
Gross
shares
Bought
by Exit
Shares bought
by Exit
Providers as
% to Market
Providers Bought
Volume

Page 8 of 68
Promoter
related
entities
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.
Client PAN
No.
Client Name
Gross
% to
Buy in Mark
Patch 2
et
Volu
me
14.46
8.91
4.76
Shares
purchased
from
preferenti
al
allottes/P
romtoer
Group
entities
during
post split
period
8485818
5290081
2100797
%
of
shares
bought
from
preferent
ial
allottes
to
the
gross
Buy by
the
client
97.24
98.39
73.14
1
2
3
AAECD8235D
AAGCR6009M
AAPCS7492G
8726858
5376722
2872178
AAJCA4459K
AAACW8004B
AAECV4988P
AAECD5782B
AAMCS1712Q
AAFCG2554B

Spice Merchants Private
Limited
Apex
Commotrade
Private Limited Ltd
Winall Vinimay Private
Limited Ltd
Vishnudham Marketing
Private Limited
Dreamlight Exim Private
Limited
Signet Vinimay Private
Limited
Gajgamini Merchandise
Private Limited
2249188
3.73
1961565
87.21
1090076
1.81
976671
89.6
666225
1.1
490025
73.55
579939
0.96
426525
73.55
445464
0.74
361354
81.12
408025
0.68
356151
87.29

Page 9 of 68
10
AAECD9323N
11
AAECR0580M
12
AATCS3687H
13
AAICS6023N
14
15
AAACE2862P
AALCA7880J
16
17
AAECC9285A
AAFCB4546A
18
AAECS0352C
19
AABCO6950F
20
21
22
23
AABCR3482R
AAMCS1711P
AACCH8885R
AAICM4750C
24
AAICM6982C
25
26
BABPS7447D
AAICS0688K
27
AAGCR8142P
28
AAFCB0211J
29
AABCF5486H
30
AABCH2251E
31
32
ACIPS8803M
AACCA3220D
33
AAACV8378B
34
AACCH4303G
Duari Marketing Private

Limited
Runicha
Merchants
Private Limited
Sidhiman Vyapaar Private
Limited
Scope Vyapar Private
Limited
Esha Securities Ltd
Antaryami Traders Private
Limited
Badamisati
Apartments
Private Limited
Stardox Vinimoy Private
Limited
Overload
Financial
Advisory Pvt Ltd
Mobixa
Distributors
Private Limited
Muchmore
Vincom
Private Limited
Amit Singh
Skm
Travels
Private
Limited
Rochak Vinimay Private
Limited
Blue
Horizon
Commosales Private Ltd
Function
Financial
Consultants
Private
Limited
Hari Om Suppliers Pvt.
Ltd.
S N Srinivasan
Amrit Sales Promotion
Pvt Limited
Vibgyor
Financial
Servicepvt Ltd
Helpful
Investment
Advisory Private Limited
422360
0.7
347260
82.22
327650
0.54
204035
62.27
328890
0.54
313840
95.42
310000
0.51
310000
100
295500
284385
0.49
0.47
295500
260075
100
91.45
284250
195000
0.47
0.32
269250
181160
94.72
92.9
180000
0.3
180000
100
174260
0.29
174260
100
166540
151049
149650
137600
0.28
0.25
0.25
0.23
166540
131049
128660
104250
100
86.76
85.97
75.76
114400
0.19
104650
91.48
114320
111000
0.19
0.18
114320
110900
100
99.91
109000
0.18
90150
82.71
102570
0.17
79780
77.78
87300
0.14
53300
61.05
81500
0.14
81450
99.94
339000
70000
0.56
0.12
296985
60000
87.61
85.71
70000
0.12
71663
0.12
71663
100

Page 10 of 68
35
AAECT5548F
36
AADCR6224M
37
AAFCR9881C
38
39
AAMCS8721P
AABCW0317N
40
AAGCR7017M
41
AABCR2904A
42
AAFCG4773J
43
AADCS5411K
44
AABCB3052B
45
AAECD8010E
46
AACCL3868N
47
AADCT8403C
48
AADCK9346B
49
50
ATIPM7500N
AARCS9144H
51
AATCS6718D
52
AAACD9125E
53
54
AADCI5139E
AAKPS3276J
55
AAGCR4662J
56
AABCR1974J
57
AAECK7329P
Triala Dealers Private

Limited
Ritesh Projects Private
Ltd.
Reachsmart
Dealtrade
Private Limited
Wonder Procon Private
Limited Wppl
Rochi Dealcom Private
Limited
R C Suppliers Private Lim
Ited
Goldensight
Traders
Private Limited
Symphony Merchant Pvt
Ltd
Bazigar Trading Private
Limited
Dhyaneshwar Dealers Pvt
Ltd
Ladios Trading Private
Limited
Topwell
Properties
Private Limited
Kalakar
Commercial
Private Limited
Arunavo Mukherjee
Sebika
Commodities
Private Limited
Swarnprakash
Traders
Private Limited
Dynamic
Portfolio
Management & Services
Ltd
Manharlal Narottamdas
Shah
Reachsmart Construction
Pvt Ltd
Ritesh
Commercial
Holdings Limited
Kapeeshwar
Vintrade
Private Limited
70000
0.12
69800
99.71
72195
0.12
72195
100
57000
0.09
57000
100
56000
50000
0.09
0.08
56000
50000
100
100
52500
0.09
52500
100
45000
0.07
45000
100
38000
0.06
5000
13.16
32500
0.05
32500
100
29500
0.05
29500
100
185500
0.31
165500
89.22
25000
0.04
25000
100
25000
0.04
25000
100
25000
0.04
25000
100
20000
13785
0.03
0.02
20000
13785
100
100
15000
0.02
15000
100
15955
0.03
15955
100
72000
11650
0.12
0.02
72000
11650
100
100
9900
0.02
9900
100
11545
0.02
11545
100
11000
0.02
11000
100

Page 11 of 68
58
AATCS4365E
59
AAGCR1715E
Total
Samridhipurn
Services 6000
0.01
Private Limited
Rangan Vincom Private 2000
0
Limited
28044592 46.47
6000
100
2000
100
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
No.
of
S.
Name of PAN of Share
No. Allottee
Allottee s
Allott
ed
GOKULD
HAM
AALFG
1
25000
ENTERPR 1236F
ISES LLP
PRAKASH
AAGPS
2
MANGILA
20000
6393C
L SURYA
JIGNESH
AAJPA2
3
11700
M. AMIN
349H
SHRENIK
AAAPZ
4
NALIN
12500
1721B
ZAVERI
MAHESH
AADPK
5
KUMAR
12500
9309F
KHATRY
PRAKASH
AADPK
6
CHAND
12500
1946Q
KHATRY
TARUN
KUMAR
ADGPC
7
12500
CHANDA 1107P
K
Adjustm
ent to
Bonus
and
Share
Split
Adjus
ted
Purch
ase
Cost
2000000
Avera
No. of ge
Shares
Sellin
sold
g
Price
Profit
Made
on Sold
Shares
Shares
held by
the
entity
1.0625 2000000 50.95
997701
76
1600000
1.0625 1306850 37.62
477773
57
293150
936000
1.0625 1066300 48.45
505339
06
-130300
1000000
1.0625 1000000 52.78
517174
59
1000000
1.0625 1000000 54.90
538331
35
1000000
1.0625 1000000 53.73
526649
13
1000000
1.0625 1000000 49.68
486196
50

Page 12 of 68
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
KALAWA
TI
SHARMA
PRAKASH
CHAND
SHARMA
CHIRAG
MAHESH
KUMAR
VYAS
NITIN
KUMAR
DIDWANI
A
SHEETAL
SANJAY
UDESHI
VIMAL
JAIN
NARESH
JALAN
NARESH
JALAN
MAHABIR
PRASAD
JALAN
MAHABIR
PRASAD
JALAN
SHANKA
R BATRA
HARLEEN
KAUR
SAVITA
BANSAL
SARAD
KUMAR B
JAIN
SMT
RASHMI
JAIN
ASHOK
KUMAR
CHOWATI
A
ACAPS1
12500
025K
1000000
1.0625 1000000 47.45
463844
50
AGMPS
2776H
12500
1000000
1.0625 1000000 47.20
461396
08
ABYPV
5751G
12500
1000000
1.0625 1000000 46.18
451196
25
AACPD
7055J
25000
2000000
1.0625 997385
39.59
384307
82
100261
5
AAAPU
2596F
12500
1000000
1.0625 981850
52.14
501457
41
18150
7500
600000
1.0625 600000
53.60
12500
1000000
1.0625 592500
50.05
12500
1000000
1.0625 587500
50.18
12500
1000000
1.0625 584000
54.27
310715
00
416000
AACHM
12500
0965N
1000000
1.0625 470000
54.89
253007
25
530000
5000
400000
1.0625 400000
50.41
12500
1000000
1.0625 356950
55.16
12500
1000000
1.0625 314000
55.05
AJGPS8
091J
7500
600000
1.0625 312500
51.13
156459
69
287500
ABTPS0
026N
12500
1000000
1.0625 277500
55.07
149881
06
722500
AADPC
6863A
7500
600000
1.0625 259500
51.52
130927
06
340500
AADPJ5
579L
ACUPJ1
252F
AABHN
4403P
ACFPJ2
428J
ACSPB5
838R
AECPC
7959J
AEJPB6
903J
315246
00
290229
44
288591
36
197395
02
193104
16
169507
75
0
407500
412500
0
643050
686000

Page 13 of 68
24
25
26
27
28
29
TARACHA
ND
L
SHAH
MADANL
AL
BABULAL
CHOWATI
A
BRIJ
BHUSHA
N SINGAL
SADHNA
RANI
RANIDEV
I
AGARWA
L
RAVINDE
R KUMAR
GUPTA
ABQPL
6153L
7500
600000
1.0625 245500
52.62
126579
81
354500
AADPC
6859J
7500
600000
1.0625 228500
51.38
114967
19
371500
AEFPS6
298M
49000
3920000
1.0625 120000
55.00
647258
0.8
380000
0
ABHPA
9244J
12500
1000000
1.0625 100000
55.20
541375
0
900000
AGEPA
7936K
12500
1000000
1.0625 77000
48.74
367143
7.5
923000
160000
1.0625 44000
55.07
237630
0
116000
AADHR
2000
3405B
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, during
Patch 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 the
preferential 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

Page 14 of 68
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 gradually
increased 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.

Page 15 of 68
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 or
indirectly, 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
Page 16 of 68
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 listing
agreement 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 the
capital 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.

Page 17 of 68
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 has
already 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 aforesaid
companies 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).

Page 18 of 68
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 day
during 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 by
the 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;

Page 19 of 68
(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; "

Page 20 of 68
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 facie
find 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 and
Financial 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 continue
to 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
Page 21 of 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 to
preferential 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, till
further 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 is
required 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
Page 22 of 68
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 JAIN
Mishka'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 PODDAR
27
AAEHD5856M DINDAYAL MALCHAND AGARWAL HUF
28
AACPA5733E KRISHAN AGARWAL
29
ACRPJ3552D
SEEMA JAIN
30
BHKPS8506F
JAY N SHAH
31
ABYPJ9937E
SUNIL KUMAR JAIN
Page 23 of 68
32
33
34
35
36
AAGPS9497R
AAGPS9498A
AGLPP3159L
BEIPA7823N
AABHA9528A
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
59
60
61
62
63
64
65
66
AEFPS6298M
AAAHB6923R
AALFG1236F
AACPD7055J
AAGPS6393C
AAAPZ1721B
AADPK9309F
AADPK1946Q
ADGPC1107P
ACAPS1025K
AGMPS2776H
ABYPV5751G
AAAPU2596F
ACUPJ1252F
AABHN4403P
ACFPJ2428J
AACHM0965N
AECPC7959J
AEJPB6903J
ABTPS0026N
AAJPA2349H
AADPJ5579L
AJGPS8091J
AADPC6863A
ABQPL6153L
AADPC6859J
ACSPB5838R
ABHPA9244J
AGEPA7936K
AADHR3405B
67
68
69
70
71
AAKPS3276J
AAACE2862P
AACCA3220D
AADCS5411K
AABCB3052B
NAVINCHANDRA K SHAH
MALTI NAVINCHANDRA SHAH
PRANIT AGARWAL
ANIL SATYANARAYAN ROONGTA HUF
Preferential Allottees
BRIJ BHUSHAN SINGAL
BRIJ BHUSHAN SINGHAL (HUF)
GOKULDHAM ENTERPRISES LLP
NITIN KUMAR DIDWANIA
PRAKASH MANGILAL SURYA
SHRENIK NALIN ZAVERI
MAHESH KUMAR KHATRY
PRAKASH CHAND KHATRY
TARUN KUMAR CHANDAK
KALAWATI SHARMA
PRAKASH CHAND SHARMA
CHIRAG MAHESHKUMAR VYAS
SHEETAL SANJAY UDESHI
NARESH JALAN
NARESH JALAN (HUF)
MAHABIR PRASAD JALAN (HUF)
HARLEEN KAUR
SAVITA BANSAL
SMT RASHMI JAIN
JIGNESH M. AMIN
VIMAL JAIN
SARAD KUMAR B JAIN
ASHOK KUMAR CHOWATIA
TARACHAND L SHAH
MADANLAL BABULAL CHOWATIA
SHANKAR BATRA
SADHNA RANI
RANIDEVI AGARWAL
RAVINDER KUMAR GUPTA (HUF)
Exit Providers
Manharlal Narottamdas Shah
Esha Securities Ltd
Amrit Sales Promotion Pvt Limited
Symphony Merchant Pvt Ltd
Bazigar Trading Private Limited

Page 24 of 68
72
73
74
75
76
77
78
79
80
81
82
83
84
85
86
87
88
89
90
91
92
93
94
95
96
97
98
99
100
101
102
103
104
105
106
107
108
109
110
111
112
113
AAGCR1715E
AACCL3868N
AADCT8403C
AAMCS1712Q
AAMCS1711P
AAECR0580M
AAACW8004B
AAPCS7492G
AAJCA4459K
AAICS0688K
AAICS6023N
AAACV8378B
AACCH4303G
AABCF5486H
AAECK7329P
AAMCS8721P
AABCW0317N
AACCH8885R
AAECC9285A
AATCS3687H
AAECV4988P
AAECT5548F
AAICM4750C
AALCA7880J
AAFCG2554B
AAICM6982C
AAECD5782B
AAFCG4773J
AAACD9125E
AABCR1974J
AADCR6224M
AAECS0352C
AABCR3482R
AABCR2904A
AABCH2251E
AADCK9346B
AAFCB0211J
AAGCR8142P
AAGCR7017M
AAECD9323N
ACIPS8803M
BABPS7447D
Rangan Vincom Private Limited

Topwell Properties Private Limited
Signet Vinimay Private Limited
Runicha Merchants Private Limited
Winall Vinimay Private Limited Ltd
Spice Merchants Private Limited
Apex Commotrade Private Limited Ltd
Skm Travels Private Limited
Scope Vyapar Private Limited
Vibgyor Financial Servicepvt Ltd
Helpful Investment Advisory Private Limited
Function Financial Consultants Private Limited
Kapeeshwar Vintrade Private Limited
Wonder Procon Private Limited Wppl
Sidhiman Vyapaar Private Limited
Vishnudham Marketing Private Limited
Triala Dealers Private Limited
Mobixa Distributors Private Limited
Antaryami Traders Private Limited
Gajgamini Merchandise Private Limited
Muchmore Vincom Private Limited
Dreamlight Exim Private Limited
Goldensight Traders Private Limited
Ritesh Commercial Holdings Limited
Ritesh Projects Private Ltd.
R C Suppliers Private Lim Ited
Hari Om Suppliers Pvt. Ltd.
Kalakar Commercial Private Limited
Blue Horizon Commosales Private Limited
Rochak Vinimay Private Limited
Rochi Dealcom Private Limited
Duari Marketing Private Limited
S N Srinivasan
Amit Singh

Page 25 of 68
114
115
116
117
118
119
120
121
122
123
124
125
AADCI5139E
AAGCR4662J
AABCO6950F
AARCS9144H
AATCS4365E
AAFCR9881C
AATCS6718D
AAECD8010E
AAECD8235D
AAGCR6009M
AAFCB4546A
ATIPM7500N
126
127
128
129
ACTPV2787Q
AADHB8488A
AAEHJ1610D
ALVPP7764J

Reachsmart Construction Pvt Ltd
Overload Financial Advisory Pvt Ltd
Sebika Commodities Private Limited
Samridhipurn Services Private Limited
Reachsmart Dealtrade Private Limited
Swarnprakash Traders Private Limited
Dhyaneshwar Dealers Pvt Ltd
Arunavo Mukherjee
LTP Contributors
Shyam Kanheyalal Vyas
Bharat Bagri (HUF)
Jayesh Narendra Kesharia (HUF)
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

Place: Mumbai
RAJEEV KUMAR AGARWAL

WHOLE TIME MEMBER

Page 26 of 68
Annexure - A
Company Directors and its Promoter
S.
PAN
Name
No.
1
AAACP2548R
Mishka Finance and
Trading Limited
AAACW0576A
AAACE1313P
AAACT1354P
AAICS7362Q
AAFCP6925M
AAAPJ3197K
AAGPJ3942C
WAVE INTER
TRADES PVT LTD
EMBASSY
FINANCE &
CONSULTANTS P
LTD
TOHEE TRADING
& AGENCIES PVT
LTD
SULABH IMPEX
LTD
PEARL ARCADE
TRADING
PRIVATE LIMITED
VIJAY KUMAR
JAIN
ANKIT JAIN
AAGPJ3943D
RASHMI JAIN
Relationship
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 with
Blue Circle Services Ltd, who is observed to have
fund transactions with Amrit Sales Promotion Pvt.
Ltd.(HDFC Bank-A/c No: 00080340006392) .
Promoter of Mishka as per share holding pattern
for September 2011.
for September 2011.
for September 2011.
for September 2011.
Promoter of Mishka as per Shareholding pattern
for September 2012.
for September 2011.
Share Common Address with Mr. Vijay Kumar
Jain.
Share Common Address with Mr. Vijay Kumar
Jain.
Part I-Promoter related entities

S.
No.
10
PAN
Name
Relationship
AEPPS9885J
ANJALI ATUL SAVE
11
ACHPS7762G
ATUL
MORESHAWAR
SAVE
ANJALI ATUL SAVE received shares in physical

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

Page 27 of 68
12
ATLPM3500D
13
AAEHD5856
M
14
CHANCHAL
MUNDHRA
DINDAYAL
MALCHAND
AGARWAL HUF
ABMPM7213N JAGDISH PRASAD
MUNDHRA
15
AAHHM8275
N
JAGDISH PRASAD
MUNDHRA HUF
16
AECPC0899M
17
AAIHK2913E
18
ACNPA1462H
JITENDRA
HIRALAL
CHHATRISHA
KAILASH S
PARASRAMPURIA
HUF
LALIT AGARWAL
19
AAAPW9319A
MEGHA RAVI
WATTAMWAR
20
CBRPK3025K
NIDHI N KEDIA
21
AACHN4765
M
22
NIRMAL KUMAR
VARUN KUMAR
HUF
ACQPM1847D NIRMALA DEVI
MUNDRA
23
AHPPK4767L
NITIN S KEDIA
24
AIDPC8188J
PAVAN JITENDRA
CHHATRISHA
25
AGLPP9975C
PRAMOD K
PARASRAMPURIA
CHANCHAL MUNDHRA received shares in

CONSULTANTS P LTD
DINDAYAL MALCHAND AGARWAL HUF
received shares in physical form from EMBASSY
FINANCE & CONSULTANTS P LTD
JAGDISH PRASAD MUNDHRA received shares
in physical form from EMBASSY FINANCE &
CONSULTANTS P LTD
JAGDISH PRASAD MUNDHRA HUF received
shares in physical form from EMBASSY
JITENDRA HIRALAL CHHATRISHA received
KAILASH S PARASRAMPURIA HUF received
LALIT AGARWAL received shares in physical
CONSULTANTS P LTD
MEGHA RAVI WATTAMWAR received shares
CONSULTANTS P LTD
NIDHI N KEDIA received shares in physical
CONSULTANTS P LTD
NIRMAL KUMAR VARUN KUMAR HUF
NIRMALA DEVI MUNDRA received shares in
CONSULTANTS P LTD
NITIN S KEDIA received shares in physical form
from EMBASSY FINANCE & CONSULTANTS
P LTD
PAVAN JITENDRA CHHATRISHA received
PRAMOD K PARASRAMPURIA received shares
CONSULTANTS P LTD

Page 28 of 68
26
BEIPA7823N
PRANIT AGARWAL
27
ADUPC7841C
28
AALHR3103E
PRASHANT
JITENDRA
CHHATRISHA
RAVI B
WATTAMWAR HUF
29
AACPW5728R
RAVI BHASKAR
WATTAMWAR
30
ACRPC4740L
RITESHKUMAR
AMITKUMAR
CHATTERJEE
31
AJRPP8338A
RITU P
PARASREAMPURIA
32
AJQPP3219D
SEEMA P
PARASRAMPURIA
33
AFGPC0469L
TRIPTI P
CHATTERJEE
34
ATMPK6409J
VEDANSHU N
KEDIA
35
AABPA6690F
AJAY AGARWAL
36
AALHA0585K
AJAY AGARWAL
HUF
37
AGSPK0865D
ASHISH KUMAR
38
AMCPS6985L
BASANT KUMAR
SARAWGI
39
AACCG5437G
GOLCHHA
ENTERTAINMENT
PVT LTD
PRANIT AGARWAL received shares in physical

CONSULTANTS P LTD
PRASHANT JITENDRA CHHATRISHA
RAVI B WATTAMWAR HUF received shares in
CONSULTANTS P LTD
RAVI BHASKAR WATTAMWAR received
RITESHKUMAR AMITKUMAR
CHATTERJEE received shares in physical form
P LTD
RITU P PARASREAMPURIA received shares in
CONSULTANTS P LTD
SEEMA P PARASRAMPURIA received shares in
CONSULTANTS P LTD
TRIPTI P CHATTERJEE received shares in
CONSULTANTS P LTD
VEDANSHU N KEDIA received shares in
CONSULTANTS P LTD
AJAY AGARWAL received shares in physical
CONSULTANTS P LTD
AJAY AGARWAL HUF received shares in
CONSULTANTS P LTD
ASHISH KUMAR received shares in physical
CONSULTANTS P LTD
BASANT KUMAR SARAWGI received shares in
CONSULTANTS P LTD
GOLCHHA ENTERTAINMENT PVT LTD

Page 29 of 68
40
AKGPG2899H HITESH GOLCHHA
41
AAVPN4041M
M NAVEEN KUMAR
42
ACDPJ5852G
MITTALAL JAIN
43
AAHPB4095P
RITU S SARAF
44
ANQPS5905F
SANDEEP V SARAF
45
ACRPJ3552D
SEEMA JAIN
46
ACVPA2214M
SHALU AGARWAL
47
AJJPS0924R
SHANTHA KUMARI
M
48
AATPJ6081F
ABHAY KUMAR
JAIN
49
AACHA9181N
ASHOK KUMAR
REDH HUF
50
AABPP6520D
MAHENDRA
PARAKH
51
ALQPS1421G
MAMTA SARAOGI
52
AFGPJ7251R
MANJU JAIN
53
ALDPS1562M
MANOJ KUMAR
SARAOGI
HITESH GOLCHHA received shares in physical

CONSULTANTS P LTD
M NAVEEN KUMAR received shares in physical
CONSULTANTS P LTD
MITTALAL JAIN received shares in physical
CONSULTANTS P LTD
RITU S SARAF received shares in physical form
P LTD
SANDEEP V SARAF received shares in physical
CONSULTANTS P LTD
SEEMA JAIN received shares in physical form
P LTD
SHALU AGARWAL received shares in physical
CONSULTANTS P LTD
SHANTHA KUMARI M received shares in
CONSULTANTS P LTD
ABHAY KUMAR JAIN received shares in
CONSULTANTS P LTD
ASHOK KUMAR REDH HUF received shares in
CONSULTANTS P LTD
MAHENDRA PARAKH received shares in
CONSULTANTS P LTD
MAMTA SARAOGI received shares in physical
CONSULTANTS P LTD
MANJU JAIN received shares in physical form
P LTD
MANOJ KUMAR SARAOGI received shares in
CONSULTANTS P LTD

Page 30 of 68
54
ABEPJ7147G
MOOLCHAND JAIN
55
AYOPA2382B
NIKUNJ S
AGARWAL
56
ADCPJ9848A
PUSHPADEVI JAIN
57
ACWPM0498C
PUSHPADEVI JAIN
58
AIQPJ7756E
RASHMI JAIN
59
AAXHS4963F
SANDEEP REDH
HUF
60
ACOPJ2654F
SAROJ JAIN
61
AGBPJ8881F
SUNAYANA JAIN
62
ARAPJ5108K
SWETA JAIN
63
AFOPJ4431P
VIKAS JAIN
64
AJVPK5048G
AADIST KHANNA
65
AAIPK5106B
JYOTI KHANNA
66
AFMPK8726N
RAVI KHANNA
67
AZAPG1972C
TEJAS GALA
68
AAMPM6353
N
KHYATI SHAH
MOOLCHAND JAIN received shares in physical

CONSULTANTS P LTD
NIKUNJ S AGARWAL received shares in
CONSULTANTS P LTD
PUSHPADEVI JAIN received shares in physical
CONSULTANTS P LTD
PUSHPADEVI JAIN received shares in physical
CONSULTANTS P LTD
RASHMI JAIN received shares in physical form
P LTD
SANDEEP REDH HUF received shares in
CONSULTANTS P LTD
SAROJ JAIN received shares in physical form
P LTD
SUNAYANA JAIN received shares in physical
CONSULTANTS P LTD
SWETA JAIN received shares in physical form
P LTD
VIKAS JAIN received shares in physical form
P LTD
AADIST KHANNA received shares in physical
CONSULTANTS P LTD
JYOTI KHANNA received shares in physical
CONSULTANTS P LTD
RAVI KHANNA received shares in physical form
P LTD
TEJAS GALA received shares in physical form
from TOHEE TRADING & AGENCIES PVT
LTD
KHYATI SHAH received shares in physical form

Page 31 of 68
LTD
69
AAAPS5162P
SACHIN V SHAH
70
AAXPM9091Q
DAYANAND
ASSARAM MODANI
71
AADPB1550B
72
AGOPP6473A
KAUSHAL
KANHAYALAL
BAGADIA
MADHU GOPAL
PODDAR
73
AAEPS7956D
74
BDNPS6529M
75
ABFPM2698Q
76
AFYPM3247A
77
ABEPM0793M
78
AABPM7263N
79
AYPPS3019L
80
ADAPT3696A
81
AAUPT1451A
82
AAAPG9125E
POONAM
KAUSHAL
BAGADIA
PRAMILA SURESH
SARDA
PREMLATA
RAMANAND
MODANI
RAKESH
SHASHIKANT
MEHTA
RAMANAND
GANESHLALJI
MODANI
SONAL RAKESH
MEHTA
SURESH
GIRDHARILAL
SARDA
MEGHNA
SANJAYKUMAR
TIBREWAL
SANJAYKUMAR
SAJJANKUMAR
TIBREWAL
GOPALDAS
GOENKA
SACHIN V SHAH received shares in physical

form from TOHEE TRADING & AGENCIES
PVT LTD
DAYANAND ASSARAM MODANI received
shares in physical form from TOHEE TRADING
& AGENCIES PVT LTD
KAUSHAL KANHAYALAL BAGADIA
received shares in physical form from TOHEE
TRADING & AGENCIES PVT LTD
MADHU GOPAL PODDAR received shares in
physical form from TOHEE TRADING &
AGENCIES PVT LTD
POONAM KAUSHAL BAGADIA received
& AGENCIES PVT LTD
PRAMILA SURESH SARDA received shares in
AGENCIES PVT LTD
PREMLATA RAMANAND MODANI received
& AGENCIES PVT LTD
RAKESH SHASHIKANT MEHTA received
& AGENCIES PVT LTD
RAMANAND GANESHLALJI MODANI
SONAL RAKESH MEHTA received shares in
AGENCIES PVT LTD
SURESH GIRDHARILAL SARDA received
& AGENCIES PVT LTD
MEGHNA SANJAYKUMAR TIBREWAL
SANJAYKUMAR SAJJANKUMAR TIBREWAL
GOPALDAS GOENKA received shares in
AGENCIES PVT LTD

Page 32 of 68
83
AAVPG4863E
84
AADPG1423E
85
AIUPR9150N
86
AFOPR0263B
87
BNNPK9250R
88
AACPA9922H
89
BHKPS8506F
90
AAGPS9498A
91
AAGPS9497R
92
AGGPP5739B
93
AAAHB0041C
94
AABPJ5859P
95
ASLPA3561D
96
AAJPJ4245M
97
APNPJ3353H
KESHAV GOENKA
KESHAV GOENKA received shares in physical

PVT LTD
SUDHA GOENKA
SUDHA GOENKA received shares in physical
PVT LTD
ANAND RANEJA
ANAND RANEJA received shares in physical
PVT LTD
HEMRAJ RANEJA
HEMRAJ RANEJA received shares in physical
PVT LTD
KAVITA RANEJA
KAVITA RANEJA received shares in physical
PVT LTD
PANKAJ AGARWAL PANKAJ AGARWAL received shares in physical
PVT LTD
JAY N SHAH
JAY N SHAH received shares in physical form
LTD
MALTI
MALTI NAVINCHANDRA SHAH received
NAVINCHANDRA
SHAH
& AGENCIES PVT LTD
NAVINCHANDRA K NAVINCHANDRA K SHAH received shares in
SHAH
AGENCIES PVT LTD
ANSHU
ANSHU PRAKASHCHANDRA PODDAR
PRAKASHCHANDR received shares in physical form from WAVE
A PODDAR
INTER TRADES PVT LTD
BALKISHAN JAJU
BALKISHAN JAJU HUF received shares in
HUF
physical form from WAVE INTER TRADES
PVT LTD
BALKISHAN
BALKISHAN NATHMAL JAJU received shares
NATHMAL JAJU
in physical form from WAVE INTER TRADES
PVT LTD
GAURAV SANJAY
GAURAV SANJAY AGARWAL received shares
AGARWAL
PVT LTD
KANTA
KANTA BALKISHAN JAJU received shares in
BALKISHAN JAJU
PVT LTD
KASTURI SANJAY
KASTURI SANJAY JOSHI received shares in
JOSHI
PVT LTD

Page 33 of 68
98
AKWPJ4412F
KETKI SANJAY
JOSHI
99
AHGPJ3412J
NIDHI ALKESH
RAWKA
100
ASFPK9445C
NIPUN N KEDIA
101
AKKPP3508Q
PARUL RUPESH
PODDAR
102
AAUPK7874L
PRABHA B KEDIA
103
ABEPA0559R
RANJANA MANISH
AGARWAL
104
AGLPP3159L
105
AELPP0183N
ROHINI
VIJAYSINGH
PATWARDHAN
RUPESH KUMAR
PODDAR
106
ABGPJ9472Q
SANJAY AMBADAS
JOSHI
107
AJUPK3727B
SHALINI NIRMAL
KEDIA
108
AGLPP8828J
109
AAAHV1190E
110
ABGPJ9502P
VIJAYSINGH
MADHAVRAO
PATWARDHAN
VIJAYSINGH
PATWARDHAN
HUF
VINITA SANJAY
JOSHI
111
AAAPD4655J
112
AWAPS4811P
113
AFHPP7452H
BHARAT
BHAWARLAL
DAGLIYA
DHAWAL C SHAH
JULIE VINOD
PARMAR
KETKI SANJAY JOSHI received shares in

PVT LTD
NIDHI ALKESH RAWKA received shares in
PVT LTD
NIPUN N KEDIA received shares in physical
form from WAVE INTER TRADES PVT LTD
PARUL RUPESH PODDAR received shares in
PVT LTD
PRABHA B KEDIA received shares in physical
RANJANA MANISH AGARWAL received
shares in physical form from WAVE INTER
TRADES PVT LTD
received shares in physical form from WAVE
RUPESH KUMAR PODDAR received shares in
PVT LTD
SANJAY AMBADAS JOSHI received shares in
PVT LTD
SHALINI NIRMAL KEDIA received shares in
PVT LTD
VIJAYSINGH MADHAVRAO
PATWARDHAN received shares in physical form
from WAVE INTER TRADES PVT LTD
VIJAYSINGH PATWARDHAN HUF received
TRADES PVT LTD
VINITA SANJAY JOSHI received shares in
PVT LTD
BHARAT BHAWARLAL DAGLIYA received
TRADES PVT LTD
DHAWAL C SHAH received shares in physical
JULIE VINOD PARMAR received shares in
PVT LTD

Page 34 of 68
114
AAAPD4654K
LALITA BHARAT
DAGLIYA
115
AABPP6339E
MANGIBAI H
PARMAR
116
AABPJ5807D
REKHA RAKESH
JAIN
117
AFHPP7451E
SHARDA K
PARMAR
118
AFHPP7450F
VINOD HASTIMAL
PARMAR
119
AFIPP6863R
ABHISEK KUMAR
PODDAR
120
ABEPA0558Q
ARCHANA SANJAY
AGARWAL
121
AFEPP5775J
ASHISH KUMAR
PODDAR
122
AOZPB0748K
KAVITA BAPNA
123
AMEPB5017G
LAXMI K BAPNA
124
AMIPP7763K
PALVE DEEPAK
SHIVRAM
125
AELPP0173Q
SORABH KUMAR
PODDAR
126
ABKPR1132P
AJAY ARVIND RAI
127
AAUPK7882Q
SUMAN NITIN
KEDIA
128
AHHPD9724C
AASHISH SHRIRAM
DIDWANIA
129
AAEPD5183B
PREMLATA S
DIDWANIA
LALITA BHARAT DAGLIYA received shares in

PVT LTD
MANGIBAI H PARMAR received shares in
PVT LTD
REKHA RAKESH JAIN received shares in
PVT LTD
SHARDA K PARMAR received shares in physical
VINOD HASTIMAL PARMAR received shares
PVT LTD
ABHISEK KUMAR PODDAR received shares in
PVT LTD
ARCHANA SANJAY AGARWAL received
TRADES PVT LTD
ASHISH KUMAR PODDAR received shares in
PVT LTD
KAVITA BAPNA received shares in physical
LAXMI K BAPNA received shares in physical
PALVE DEEPAK SHIVRAM received shares in
PVT LTD
SORABH KUMAR PODDAR received shares in
PVT LTD
AJAY ARVIND RAI received shares in physical
SUMAN NITIN KEDIA received shares in
PVT LTD
AASHISH SHRIRAM DIDWANIA received
TRADES PVT LTD
PREMLATA S DIDWANIA received shares in
PVT LTD

Page 35 of 68
130
APIPD2551A
RISHABH S
DIDWANIA
RISHABH S DIDWANIA received shares in

PVT LTD
SAJJAN KUMAR NANDLAL DIDWANIA
SHRIRAM NANDLAL DIDWANIA received
TRADES PVT LTD
SUSHILA DEVI SAJJANKUMAR DIDWANIA
ANNAPURNA CHOUDHARY received shares
PVT LTD
ARCHANA V AGARWAL received shares in
PVT LTD
BEENA SANJAY BIST received shares in
PVT LTD
BIMAL KANTILAL MEHTA received shares in
PVT LTD
CHIRAG TEJPRAKASH DANGI received
TRADES PVT LTD
DILIP B DANGI received shares in physical form
GAJANAND AGARWAL received shares in
PVT LTD
JITENDRA B DANGI received shares in physical
131
AABPD4579L
132
AABPD4578M
133
AAEPD5185H
134
AALPC5337M
SAJJAN KUMAR
NANDLAL
DIDWANIA
SHRIRAM
NANDLAL
DIDWANIA
SUSHILA DEVI
SAJJANKUMAR
DIDWANIA
ANNAPURNA
CHOUDHARY
135
ACOPA1761G
ARCHANA V
AGARWAL
136
AKGPB7520G
BEENA SANJAY
BIST
137
ACMPM8325L
BIMAL KANTILAL
MEHTA
138
AJYPD2884J
139
AJHPD1534E
CHIRAG
TEJPRAKASH
DANGI
DILIP B DANGI
140
AAGPA3508D
GAJANAND
AGARWAL
141
AHYPD8272G
JITENDRA B
DANGI
142
AJHPD1533D
KAMLESH B DANGI KAMLESH B DANGI received shares in physical

143
AAEHM2522F
MANSUKH M JAIN
HUF
MANSUKH M JAIN HUF received shares in

PVT LTD

Page 36 of 68
144
AAKPJ0506E
MANSUKHLAL M
JAIN
145
AHRPM3467H
NEEPA BIMAL
MEHTA
146
ADBPA0585E
RAMOD KUMAR
AGRAWAL
147
ABEPJ1031B
148
AAAHT8952Q
SAROJBALA
PRAVINKUMAR
JASANI
TEJ PRAKASH
DANGI HUF
149
ABVPJ0280B
VIMLA M JAIN
150
AAHPJ9625M
VINODKUMAR M
JAIN
151
AEJPD5096A
YASHWANT
KUMAR DANGI
152
AQCPC3996P
AASHISH
CHHAPARWAL
153
AACHM3646J
154
AANPG3179K
ANILKUMAR
PURANMAL
MAHANSARIA HUF
BHARAT
GANDOTRA
155
AAVPB0093K
DHIRENDRA
CHAND BHURAT
156
AGEPC1149C
LALITA
CHHAPARWAL
157
AAVPP8191Q
MANJU PATWA
158
ADBPM2707Q
NEELU
MAHANSARIA
MANSUKHLAL M JAIN received shares in

PVT LTD
NEEPA BIMAL MEHTA received shares in
PVT LTD
RAMOD KUMAR AGRAWAL received shares
PVT LTD
SAROJBALA PRAVINKUMAR JASANI
TEJ PRAKASH DANGI HUF received shares in
PVT LTD
VIMLA M JAIN received shares in physical form
VINODKUMAR M JAIN received shares in
PVT LTD
YASHWANT KUMAR DANGI received shares
PVT LTD
AASHISH CHHAPARWAL received shares in
PVT LTD
ANILKUMAR PURANMAL MAHANSARIA
HUF received shares in physical form from
WAVE INTER TRADES PVT LTD
BHARAT GANDOTRA received shares in
PVT LTD
DHIRENDRA CHAND BHURAT received
TRADES PVT LTD
LALITA CHHAPARWAL received shares in
PVT LTD
MANJU PATWA received shares in physical form
NEELU MAHANSARIA received shares in
PVT LTD

Page 37 of 68
159
AAEPS7952H
NITIN SARAF
160
AAVPA9660P
161
ALGPC9277N
PREMKUMAR
MADANLAL
AGARWAL
PRIYANKA
CHHAPARWAL
162
AFNPA4015R
RAHUL KUMAR
AGRAWAL
163
AATPC6839L
RAM KUMAR
CHHAPARWAL
164
ALGPC9276P
RITIKA
CHHAPARWAL
165
AFIPB5455P
RITU PATWA
166
ANOPS5467Q
167
ABLPA9728M
SAROJ
TEJPRAKASH
DONGI
SUMITRA DEVI
AGRAWAL
168
ABYPJ9937E
SUNIL KUMAR JAIN
169
AAOHS4973C
SUNIL KUMAR JAIN

& SONS HUF
170
AEEPD3015Q
TEJ PRAKASH
DANGI
171
AAAHU6298L
UMESH P
MAHANSARIA HUF
172
AARPM4362J
UMESH PURANMAL
MAHANSARIA
173
ABAPT9648J
ABHISHEK
RAJKUMAR
TULSIAN
NITIN SARAF received shares in physical form

PREMKUMAR MADANLAL AGARWAL
PRIYANKA CHHAPARWAL received shares in
PVT LTD
RAHUL KUMAR AGRAWAL received shares in
PVT LTD
RAM KUMAR CHHAPARWAL received shares
PVT LTD
RITIKA CHHAPARWAL received shares in
PVT LTD
RITU PATWA received shares in physical form
SAROJ TEJPRAKASH DONGI received shares
PVT LTD
SUMITRA DEVI AGRAWAL received shares in
PVT LTD
SUNIL KUMAR JAIN received shares in physical
SUNIL KUMAR JAIN & SONS HUF received
TRADES PVT LTD
TEJ PRAKASH DANGI received shares in
PVT LTD
UMESH P MAHANSARIA HUF received shares
PVT LTD
UMESH PURANMAL MAHANSARIA received
TRADES PVT LTD
ABHISHEK RAJKUMAR TULSIAN received
TRADES PVT LTD

Page 38 of 68
174
ACSPT0816H
ANITA ABHISHEK
TULSIAN
175
ADCPJ8138P
ANURADHA JALAN
176
AACPA5733E
KRISHAN
AGARWAL
177
AAKPB8853A
178
ABUPT4393C
179
ABYPJ9823B
180
ADCPJ3766F
181
BBVPM8911M
182
ACTPB4037B
183
AAEHS1739Q
184
AOJPS5377K
185
AEDPG1656D
186
AAHHA7175B
187
ADDPA5447P
188
AEDPS1231C
189
AAEHA1812N
ANITA ABHISHEK TULSIAN received shares

PVT LTD
ANURADHA JALAN received shares in physical
KRISHAN AGARWAL received shares in

PVT LTD
MANJU BADIALA
MANJU BADIALA received shares in physical
NIRMALA
NIRMALA RAJKUMAR TULSIAN received
RAJKUMAR
TULSIAN
TRADES PVT LTD
SAINIK KUMAR
SAINIK KUMAR JAIN received shares in
JAIN
PVT LTD
SAPNA JALAN
SAPNA JALAN received shares in physical form
SHYAM BIMAL
SHYAM BIMAL MEHTA received shares in
MEHTA
PVT LTD
SURENDER KUMAR SURENDER KUMAR BADIALA received
BADIALA
TRADES PVT LTD
SURESHCHANDRA SURESHCHANDRA SHYAMLAL GOYAL
SHYAMLAL GOYAL received shares in physical form from VIJAY
KUMAR JAIN
VIJAY KUMAR SONI VIJAY KUMAR SONI received shares in physical
form from VIJAY KUMAR JAIN
ABHISHEK
ABHISHEK ASHOKKUMAR GOYAL received
ASHOKKUMAR
shares in physical form from VIJAY KUMAR
GOYAL
JAIN
ABHISHEK
ABHISHEK ASHOKKUMAR GOYAL HUF
ASHOKKUMAR
received shares in physical form from VIJAY
GOYAL HUF
KUMAR JAIN
ADITI DEVI
ADITI DEVI AGARWAL received shares in
AGARWAL
physical form from VIJAY KUMAR JAIN
AMRUTLAL
AMRUTLAL NARSHIBHAI SHAH received
NARSHIBHAI SHAH shares in physical form from VIJAY KUMAR
JAIN
ANIL KUMAR BAID ANIL KUMAR BAID HUF received shares in
HUF

Page 39 of 68
190
ALGPT8234L
ANKIT TULSIYAN
191
CIEPK3618L
192
AABHA8457J
APURV
MAHENDRAKUMA
R KANOI
ASHOK SHYAMLAL
GOYAL HUF
193
AFAPA2731F
194
ABHPA2985J
195
AAFHK8698K
196
ACAPK2091F
197
AEUPS5402C
198
AAPHS9224M
199
ABEPG7761R
200
AABHB7315L
201
AKZPR8054J
202
AMRPK8497J
203
AACPA8225F
204
AABHD7828L
DEVKI NANDAN
AGGARWAL HUF
205
ABBPB8007G
DIMPLE BAID
BABITA DEVI
AGARWAL
BHAGWATI DEVI
AGARWAL
BHAILALBHAI K
KANANI HUF
BHAILALBHAI
KHODABHAI
KANANI
BHARATBHAI
SAMBUBHAI
SAVALIYA
BHARATBHAI
SAMBUBHAI
SAVALIYA HUF
BHARATKUMAR
SHYAMLAL GOYAL
BHARATKUMAR
SHYAMLAL GOYAL
HUF
BHAWNA
RAKHECHA
BIMALBHAI B
KANANI
DEOKI NANDAN
AGGARWAL
ANKIT TULSIYAN received shares in physical

APURV MAHENDRAKUMAR KANOI
KUMAR JAIN
ASHOK SHYAMLAL GOYAL HUF received
JAIN
BABITA DEVI AGARWAL received shares in
BHAGWATI DEVI AGARWAL received shares
in physical form from VIJAY KUMAR JAIN
BHAILALBHAI K KANANI HUF received
JAIN
BHAILALBHAI KHODABHAI KANANI
KUMAR JAIN
BHARATBHAI SAMBUBHAI SAVALIYA
KUMAR JAIN
BHARATBHAI SAMBUBHAI SAVALIYA HUF
KUMAR JAIN
BHARATKUMAR SHYAMLAL GOYAL
KUMAR JAIN
BHARATKUMAR SHYAMLAL GOYAL HUF
KUMAR JAIN
BHAWNA RAKHECHA received shares in
BIMALBHAI B KANANI received shares in
DEOKI NANDAN AGGARWAL received
JAIN
DEVKI NANDAN AGGARWAL HUF received
JAIN
DIMPLE BAID received shares in physical form
from VIJAY KUMAR JAIN

Page 40 of 68
206
AACHD5953R
207
ADAPS6476K
208
ATRPG2117L
209
CNMPS9107H
210
AAUPN3949H
211
BVFPS6604D
212
AABHJ6271K
213
AAOPN6145P
214
AARPJ5433D
215
AMHPS7164C
216
ABAPK9374J
217
ACBPD1930D
218
ALTPS2510B
219
AAKPN8618D
220
BEYPS1405N
221
ACLPG5668H
222
AHYPG2037Q
DINESHKUMAR
RAMCHANDRA
TULSYAN HUF
HASMUKH
LALJIBHAI SOJITRA
DINESHKUMAR RAMCHANDRA TULSYAN

VIJAY KUMAR JAIN
HASMUKH LALJIBHAI SOJITRA received
JAIN
HIREN GODHKA
HIREN GODHKA received shares in physical
HIREN NAVINBHAI HIREN NAVINBHAI SAVALIYA received
SAVALIYA
JAIN
HITESH AMRUTLAL HITESH AMRUTLAL SHAH received shares in
SHAH
JAHANVI
JAHANVI MANSUKHBHAI SHEKHDA
MANSUKHBHAI
SHEKHDA
KUMAR JAIN
JAI NARAIN
JAI NARAIN AGGARWAL HUF received
AGGARWAL HUF
JAIN
JAYESH SHAH
JAYESH SHAH received shares in physical form
JEEVAN BALA
JEEVAN BALA JINDAL received shares in
JINDAL
JIGNA JAYESH
JIGNA JAYESH SHAH received shares in
SHAH
JIGNESH RATILAL
JIGNESH RATILAL KARIA received shares in
KARIA
JUGAL RAMESH
JUGAL RAMESH DEORAH received shares in
DEORAH
JYOTIBEN
JYOTIBEN MANSUKHBHAI SHEKHDA
MANSUKHBHAI
SHEKHDA
KUMAR JAIN
KALPA H SHAH
KALPA H SHAH received shares in physical
KAMAL M
KAMAL M SHEKHDA received shares in
SHEKHDA
KAMLADEVI
KAMLADEVI ASHOKMUMAR GOYAL
ASHOKMUMAR
GOYAL
KUMAR JAIN
KAPILKUMAR
KAPILKUMAR PRAKASHCHAND GOYAL
PRAKASHCHAND
GOYAL
KUMAR JAIN

Page 41 of 68
223
AAJHK0915K
224
ASUPG0646A
225
ACQPB0192E
226
BDAPG2619H
227
AHVPP9220H
228
BGUPK7332J
229
AEOPK4934P
230
ABQPK7961B
231
AAFHM1534C
232
AHBPS2529N
233
234
235
KAPILKUMAR
PRAKASHCHAND
GOYAL HUF
KEVAL
MANSUKHLAL
GUDHKA
KIRAN DEVI BAID
KUNJ NITIN
GUDHKA
KUNVARBEN
SHAMBHUBHAI
PATEL
MADHURI B
KANANI
MAHENDRA
CHIRANJILAL
KANOI
MANJULABEN
BHAILALBHAI
KANANI
MANSUKHBHAI N
SHEKHDA HUF
MANSUKHBHAI
NANJIBHAI
SHEKHDA
AAOPN6144N MILAN AMRUTLAL
SHAH
AAAHN3389K NARESH TULSIYAN
HUF
ADSPP6395A
NAVINBHAI
SAMBUBHAI PATEL
236
AWQPG6666A NEAL MOTICHAND

GUDHKA
237
AJGPG8807N
238
AIZPP2199N
NIKITA
BHARATKUMAR
GOYAL
NIMISHABEN
BHARTKUMAR
PATEL
KAPILKUMAR PRAKASHCHAND GOYAL

VIJAY KUMAR JAIN
KEVAL MANSUKHLAL GUDHKA received
JAIN
KIRAN DEVI BAID received shares in physical
KUNJ NITIN GUDHKA received shares in
KUNVARBEN SHAMBHUBHAI PATEL
KUMAR JAIN
MADHURI B KANANI received shares in
MAHENDRA CHIRANJILAL KANOI received
JAIN
MANJULABEN BHAILALBHAI KANANI
KUMAR JAIN
MANSUKHBHAI N SHEKHDA HUF received
JAIN
MANSUKHBHAI NANJIBHAI SHEKHDA
KUMAR JAIN
MILAN AMRUTLAL SHAH received shares in
NARESH TULSIYAN HUF received shares in
NAVINBHAI SAMBUBHAI PATEL received
JAIN
NEAL MOTICHAND GUDHKA received
JAIN
NIKITA BHARATKUMAR GOYAL received
JAIN
NIMISHABEN BHARTKUMAR PATEL
KUMAR JAIN

Page 42 of 68
239
APDPS4227F
240
AAEHP5936N
241
AKLPA5010D
242
AFZPG4725L
243
AAKHP8192E
244
AFCPA6128G
245
AAKHP5648H
246
AFEPJ2623K
247
AAFHP4955A
248
ACJPG7038F
249
AEVPA6331H
250
ADIPA3030D
251
AALHR2786R
252
AMKPS8249K
253
ABRPG1203D
254
AHKPA4663N
255
AAKHS0691B
256
ABHPA2983Q
PANNABEN
RAJESHKUMAR
SHAH
PANNALAL BAID
HUF
PAYAL
KAPILKUMAR
GOYAL
PIYUSH ASHOK
GOYAL
PIYUSH GOYAL
HUF
PRAFFUL
AGGARWAL
PRAFFUL
AGGARWAL HUF
PRAGYA
ABHISHEK GOYAL
PRAKASHCHAND
SHYAMLAL GOYAL
HUF
PRAKASHCHANDR
A SHYAMLAL
GOYAL
PRERNA GOYAL
RAVEESH
AGGARWAL
RAVEESH
AGGARWAL HUF
REENA MILAN
SHAH
REENA RITESH
JINDAL
RUCHI AGARWAL
SAMBUBHAI
LAXMANBHAI
SAVLIYA HUF
SANJAY KUMAR
AGARWAL
PANNABEN RAJESHKUMAR SHAH received

JAIN
PANNALAL BAID HUF received shares in
PAYAL KAPILKUMAR GOYAL received shares
PIYUSH ASHOK GOYAL received shares in
PIYUSH GOYAL HUF received shares in
PRAFFUL AGGARWAL received shares in
PRAFFUL AGGARWAL HUF received shares in
PRAGYA ABHISHEK GOYAL received shares
PRAKASHCHAND SHYAMLAL GOYAL HUF
KUMAR JAIN
PRAKASHCHANDRA SHYAMLAL GOYAL
KUMAR JAIN
PRERNA GOYAL received shares in physical
RAVEESH AGGARWAL received shares in
RAVEESH AGGARWAL HUF received shares
REENA MILAN SHAH received shares in
REENA RITESH JINDAL received shares in
RUCHI AGARWAL received shares in physical
SAMBUBHAI LAXMANBHAI SAVLIYA HUF
KUMAR JAIN
SANJAY KUMAR AGARWAL received shares in

Page 43 of 68
257
ABRPG1070C
SANTOSHDEVI
PRAKASHCHNADR
A GOYAL
SAROJINI DEVI
SUMANDEVI
DINESHKUMAR
TULSYAN
SUSHEELA DEVI
ROKHECHA
SANTOSHDEVI PRAKASHCHNADRA
GOYAL received shares in physical form from
VIJAY KUMAR JAIN
SAROJINI DEVI received shares in physical form
SAT NARAIN AGGARWAL HUF received
JAIN
SAVALIYA KRUNALKUMAR N received
JAIN
SAVALIYA NAVINBHAI SAMBUBHAI HUF
KUMAR JAIN
SHAMBHUBHAI LAXAMANBHAI PATEL
KUMAR JAIN
SHRI SHIV NARAIN AGGARWAL HUF
KUMAR JAIN
SONAL HASMUKHBHAI SOJITRA received
JAIN
SONAL JUGAL DEORAH received shares in
SRI NARAIN AGGARWAL HUF received
JAIN
SUMANDEVI DINESHKUMAR TULSYAN
KUMAR JAIN
SUSHEELA DEVI ROKHECHA received shares
258
AADPD9042L
259
AAFHS5780N
SAT NARAIN
AGGARWAL HUF
260
CFEPS6250M
SAVALIYA
KRUNALKUMAR N
261
AAPHS9225L
262
ACFPP2999G
263
AAFHS5782Q
SAVALIYA
NAVINBHAI
SAMBUBHAI HUF
SHAMBHUBHAI
LAXAMANBHAI
PATEL
SHRI SHIV NARAIN
AGGARWAL HUF
264
ADAPS6477J
265
AGZPD3263D
266
AAFHS5918G
267
ACKPT1322Q
268
AAXPR9487R
269
270
AOXPM4701
M
ADVPG8469R
SWATI SHAILESH
MUSALE
USHADEVI
BHARATKUMAR
GOYAL
VIJAY KUMAR SONI
HUF
SWATI SHAILESH MUSALE received shares in

USHADEVI BHARATKUMAR GOYAL
KUMAR JAIN
VIJAY KUMAR SONI HUF received shares in
271
AAGHV5661L
SONAL
HASMUKHBHAI
SOJITRA
SONAL JUGAL
DEORAH
SRI NARAIN
AGGARWAL HUF

Page 44 of 68
272
273
274
275
276
277
278
279
280
281
282
283
284
285
286
287
288
AIIPP8587D
VIJAYABEN
NAVINBHAI PATEL
VIJAYABEN NAVINBHAI PATEL received

JAIN
AOVPT4612C YASH TULSIAN
YASH TULSIAN received shares in physical form
BDFPM3662K KOMAL PARAG
KOMAL PARAG MANDHANA received shares
MANDHANA
in physical form from ANKIT JAIN
ABZPM6627M MADHUMALTI
MADHUMALTI MOHANLAL MANDHANA
MOHANLAL
received shares in physical form from ANKIT
MANDHANA
JAIN
ABHPM5789J MOHANLAL
MOHANLAL RAMAVTAR MANDHANA
RAMAVTAR
MANDHANA
JAIN
ANZPT6807C NEHA NARAYAN
NEHA NARAYAN TOSHNIWAL received
TOSHNIWAL
shares in physical form from ANKIT JAIN
AADHN9636
NIRANJAN D
NIRANJAN D AGARWAL HUF received shares
G
AGARWAL HUF
AHGPM4268B PARAG MOHANLAL PARAG MOHANLAL MANDHANA received
MANDHANA
ABZPM6596M SARJUDEVI
SARJUDEVI RAMAVTAR MANDHANA
RAMAVTAR
MANDHANA
JAIN
ASZPS1277J
SAVITA SONI
SAVITA SONI received shares in physical form
from ANKIT JAIN
ABBPR3992G ANIL
ANIL SATYANARAYAN ROONGTA received
SATYANARAYAN
ROONGTA
AABHA9528A ANIL
ANIL SATYANARAYAN ROONGTA HUF
SATYANARAYAN
ROONGTA HUF
JAIN
ATWPR2744M ANKIT ANIL
ANKIT ANIL ROONGTA received shares in
ROONGTA
physical form from ANKIT JAIN
ACNPA1459Q DHANRAJ N
DHANRAJ N AGARWAL received shares in
AGARWAL
AADHD9195A DHANRAJ N
DHANRAJ N AGARWAL HUF received shares
AGARWAL HUF
ABBPA3613M DINDAYAL
DINDAYAL MALLHAND AGARWAL received
MALLHAND
AGARWAL
ABHPT5940L KIRAN
KIRAN NARAYANPRASAD TOSHNIWAL
NARAYANPRASAD received shares in physical form from ANKIT
TOSHNIWAL
JAIN

Page 45 of 68
289
AAHHM0834R MANDHANA
MOHANLAL
RAMAVTAR HUF
AAEHM6895
MANDHANA
D
RAMAUTAR
RAMSWROOP HUF
ACHPM9038P MEENU
MAHESHWARI
AAPPT4897B
NARAYAN
BALKRISHAN
TOSHNIWAL
AAAHT8290F NARAYAN
BALKRISHAN
TOSHNIWAL HUF
ABVPK6554F RAMAKANT
RAMNIWAS KASAT
AJUPG0025G SANGEETA AMIT
GOENKA
ACNPA1457A SHILPA LALIT
AGRAWAL
ARPPG3574K SHILPA SUMIT
GOENKA
AAQPR4466F SUDHA ANIL
ROONGTA
ACHPM9037C VINOD KUMAR
MAHESHWARI
AEGPP6553F PRAKASHCHANDR
A PODDAR
AAGHP4951F PRAKASHCHANDR
A PODDAR HUF
MANDHANA MOHANLAL RAMAVTAR

ANKIT JAIN
MANDHANA RAMAUTAR RAMSWROOP
ANKIT JAIN
MEENU MAHESHWARI received shares in
NARAYAN BALKRISHAN TOSHNIWAL
JAIN
NARAYAN BALKRISHAN TOSHNIWAL
ANKIT JAIN
RAMAKANT RAMNIWAS KASAT received
SANGEETA AMIT GOENKA received shares
SHILPA LALIT AGRAWAL received shares in
SHILPA SUMIT GOENKA received shares in
SUDHA ANIL ROONGTA received shares in
VINOD KUMAR MAHESHWARI received
PRAKASHCHANDRA PODDAR received
shares in physical form from RASHMI JAIN
PRAKASHCHANDRA PODDAR HUF received
shares in physical form from RASHMI JAIN
302
AKDPP0442N
303
ABEPA0553F
304
AAEHD2136C
305
AAKHP5465L
PREMLATA DEVI PODDAR received shares in

physical form from RASHMI JAIN
RANI AGARWAL received shares in physical
form from RASHMI JAIN
DINESH P ABICHANDANI HUF received
PRAMOD K PARASRAMPURIA HUF received
290
291
292
293
294
295
296
297
298
299
300
301
PREMLATA DEVI
PODDAR
RANI AGARWAL
DINESH P
ABICHANDANI
HUF
PRAMOD K
PARASRAMPURIA
HUF

Page 46 of 68
306
ANTPG6476G
SHRUTI GUPTA
307
ABAPB3124F
KUSUM DEVI
BUDHIA
308
AAKHP5466K
309
AAMPB8912G
PANKAJ K
PARASRAMPURIA
HUF
SANTOSH KUMAR
BUDHIA
310
AAEHS1018L
SANTOSH KUMAR
BUDHIA HUF
311
AHGPB8311C
SUDARSHAN
BUDHIA
312
AASHS6909J
SUDARSHAN
BUDHIA HUF
313
AHSPP9930B
SHYAMPYARI
PODDAR
314
AABHC9880K
SHYAMSUNDER
CHOUDHARY HUF
315
ABSPT6576H
PRASHANT
TIBREWAL
316
AASHS1867H
SANJAYKUMAR
TIBREWAL HUF
317
ARIPK3181H
BHAVYA KHANNA
318
AAGHR7451A
RAVI KHANNA
HUF
319
ATWPK6701D ARTI KANSARA
SHRUTI GUPTA received shares in physical

CONSULTANTS P LTD
KUSUM DEVI BUDHIA received shares in
CONSULTANTS P LTD
PANKAJ K PARASRAMPURIA HUF received
SANTOSH KUMAR BUDHIA received shares in
CONSULTANTS P LTD
SANTOSH KUMAR BUDHIA HUF received
SUDARSHAN BUDHIA received shares in
CONSULTANTS P LTD
SUDARSHAN BUDHIA HUF received shares in
CONSULTANTS P LTD
SHYAMPYARI PODDAR received shares in
CONSULTANTS P LTD
SHYAMSUNDER CHOUDHARY HUF
PRASHANT TIBREWAL received shares in
CONSULTANTS P LTD
SANJAYKUMAR TIBREWAL HUF received
BHAVYA KHANNA received shares in physical
CONSULTANTS P LTD
RAVI KHANNA HUF received shares in physical
CONSULTANTS P LTD
ARTI KANSARA received shares in physical
PVT LTD

Page 47 of 68
320
321
BGBPS8182H
JANARDAN
RAMSAKAL
SHARMA
BAWPD8427K JAYESH
DEVGHARKAR
322
ABUPS6101K
JAYESH SHAH
323
AOBPS1451C
MANISHA SHAH
324
ADAPY7887N
PRADIP YADAV
325
AIGPR2085J
PRAKASH G
REVALE
326
AAHPZ4371J
SANJAY ZENDE
327
ARPPM6797A
SARITA DEVI MALL
328
BHCPP9503P
SHAILESH PANDYA
329
AMWPB8358C
SOMNATH
BOMBLE
330
AVDPG8761E
SUKRIT GHOSH
331
ANFPK3652G
SUNIL MOHAN
KANSARA
332
ADFPB8311F
333
AKYPP3061C
AMARJITSINGH
TRILOCHANSINGH
BHASIN
CHANDRAKALA
PANDURANG PAI
JANARDAN RAMSAKAL SHARMA received

& AGENCIES PVT LTD
JAYESH DEVGHARKAR received shares in
AGENCIES PVT LTD
JAYESH SHAH received shares in physical form
LTD
MANISHA SHAH received shares in physical
PVT LTD
PRADIP YADAV received shares in physical
PVT LTD
PRAKASH G REVALE received shares in
AGENCIES PVT LTD
SANJAY ZENDE received shares in physical
PVT LTD
SARITA DEVI MALL received shares in physical
PVT LTD
SHAILESH PANDYA received shares in physical
PVT LTD
SOMNATH BOMBLE received shares in physical
PVT LTD
SUKRIT GHOSH received shares in physical
PVT LTD
SUNIL MOHAN KANSARA received shares in
AGENCIES PVT LTD
AMARJITSINGH TRILOCHANSINGH
BHASIN received shares in physical form from
TOHEE TRADING & AGENCIES PVT LTD
CHANDRAKALA PANDURANG PAI received
& AGENCIES PVT LTD

Page 48 of 68
334
ARVPM0328D
ABHISHEK
RAMANAND
MODANI
GOPAL SITARAM
PODDAR HUF
335
AAHHP5235K
336
ACBPH7392B
IMTIAZ ABDUL
RAZAK HINGORA
337
AABHC1088H
KAILASHCHAND
CHOUDHARY HUF
338
AADHC4883J
339
AHVPH9629Q
KAPIL
KAILASHCHAND
CHOUDHARY HUF
SAFIYA ARIF
HINGORA
340
AHUPH8833M SHABEENA IRFAN

HINGORA
341
ACKPH1199M
ARIF ABDUL
RAZAK HINGORA
342
AHUPH6034N
ASMA PARVEZ
HINGORA
343
ACBPH7385J
IRFAN ABDUL
RAZAK HINGORA
344
ABVPT0963H
345
ADGPT6659M
PAWANKUMAR
RANGLAL
TIBREWAL
PRAVINKUMAR
TIBREWAL
346
AAGHS3599N
SAJJANKUMAR
MOHANLAL HUF
347
ABEPT2749L
SAJJANKUMAR
MOHANLAL
TIBREWAL
ABHISHEK RAMANAND MODANI received

& AGENCIES PVT LTD
GOPAL SITARAM PODDAR HUF received
& AGENCIES PVT LTD
IMTIAZ ABDUL RAZAK HINGORA received
& AGENCIES PVT LTD
KAILASHCHAND CHOUDHARY HUF
KAPIL KAILASHCHAND CHOUDHARY
TOHEE TRADING & AGENCIES PVT LTD
SAFIYA ARIF HINGORA received shares in
AGENCIES PVT LTD
SHABEENA IRFAN HINGORA received shares
in physical form from TOHEE TRADING &
AGENCIES PVT LTD
ARIF ABDUL RAZAK HINGORA received
& AGENCIES PVT LTD
ASMA PARVEZ HINGORA received shares in
AGENCIES PVT LTD
IRFAN ABDUL RAZAK HINGORA received
& AGENCIES PVT LTD
PAWANKUMAR RANGLAL TIBREWAL
PRAVINKUMAR TIBREWAL received shares in
AGENCIES PVT LTD
SAJJANKUMAR MOHANLAL HUF received
& AGENCIES PVT LTD
SAJJANKUMAR MOHANLAL TIBREWAL

Page 49 of 68
348
ABWPT3974F
SANTOSHDEVI
SAJJANKUMAR
TIBREWAL
PARVEZ ABDUL
RAZAK HINGORA
349
AASPH3972Q
350
AJCPM1320N
351
AHUPH6035P
352
AAFHV7238A
VINAY KUMAR
TIBREWAL HUF
353
AAUPT1452D
VINAY S TIBREWAL
354
ACHPS7727F
355
APTPS1496L
JAGDISH
GIRDHARILAL
SARDA
SHRUTI JAGDISH
SARDA
356
AAACH9471P
ROONGTA RISING
STOCK PVT LTD
357
BTUPS3359E
SANJEEV SINGH
358
AAFPP9437R
359
AGHPR7535G
360
AAIPP3129R
PURNIMA
VIJAYSINGH
PATWARDHAN
SHAILESH
ZUMBERLAL
RAWKA
VINOD HIRALAL
PODDAR
361
AEYPD8501M
RAMKANYA
DAYANAND
MODANI
SHAMIM IMTIAZ
HINGORA
AMBIKADEVI
SHIVSHANKAR
DHANUKA
SANTOSHDEVI SAJJANKUMAR TIBREWAL

PARVEZ ABDUL RAZAK HINGORA received
& AGENCIES PVT LTD
RAMKANYA DAYANAND MODANI received
& AGENCIES PVT LTD
SHAMIM IMTIAZ HINGORA received shares
in physical form from TOHEE TRADING &
AGENCIES PVT LTD
VINAY KUMAR TIBREWAL HUF received
& AGENCIES PVT LTD
VINAY S TIBREWAL received shares in physical
PVT LTD
JAGDISH GIRDHARILAL SARDA received
& AGENCIES PVT LTD
SHRUTI JAGDISH SARDA received shares in
AGENCIES PVT LTD
ROONGTA RISING STOCK PVT LTD
SANJEEV SINGH received shares in physical
PVT LTD
PURNIMA VIJAYSINGH PATWARDHAN
SHAILESH ZUMBERLAL RAWKA received
TRADES PVT LTD
VINOD HIRALAL PODDAR received shares in
PVT LTD
AMBIKADEVI SHIVSHANKAR DHANUKA

Page 50 of 68
362
363
364
365
366
367
368
369
370
371
372
373
374
375
376
377
378
379
380
381
ACAPA0171C
ATIMA SARAF
ATIMA SARAF received shares in physical form

ACJPM9326L
DEVKINANDAN
DEVKINANDAN BHAVARLAL MITTAL
BHAVARLAL
MITTAL
AJYPD2885K
JIGAR T DANGI
JIGAR T DANGI received shares in physical
AAHPM5792N NEELAM MITTAL
NEELAM MITTAL received shares in physical
AARPM4361M ANILKUMAR
ANILKUMAR PURANMAL MAHANSARIA
PURANMAL
MAHANSARIA
AEHPM4809A KIRAN
KIRAN MAHANSARIA received shares in
MAHANSARIA
PVT LTD
AACPA8580B AMITA AGGARWAL AMITA AGGARWAL received shares in physical
ARIPA1855E
AYUSH AGGARWAL AYUSH AGGARWAL received shares in physical
AAEPA2909E JAI NARAIN
JAI NARAIN AGGARWAL received shares in
AGGARWAL
AIFPK3342L
NIDHI AGGARWAL NIDHI AGGARWAL received shares in physical
AGIPA7767N RICHA AGGARWAL RICHA AGGARWAL received shares in physical
AACPA8581A SANGEETA
SANGEETA AGGARWAL received shares in
AGGARWAL
AAEPA5870C SHIV NARAIN
SHIV NARAIN AGGARWAL received shares in
AGGARWAL
AACPA8578M SRI NARAIN
SRI NARAIN AGGARWAL received shares in
AGGARWAL
AACPA8579L SUMAN
SUMAN AGGARWAL received shares in
AGGARWAL
AGZPA9299C VARUN
VARUN AGGARWAL received shares in
AGGARWAL
AAGPP4827L ALKA PODDAR
ALKA PODDAR received shares in physical form
from ANKIT JAIN
AELPP0174K RAJESH PANNALAL RAJESH PANNALAL PODDAR received shares
PODDAR
AIZPG7081J
CHANDRIDEVI B
CHANDRIDEVI B GARODIYA received shares
GARODIYA
ACNPA1460F KAILASH D
KAILASH D AGARWAL received shares in
AGARWAL

Page 51 of 68
382
AADHK9463J
KAILESH D
AGARWAL HUF
KAMLESHDEVI
PAWANKUMAR
TIBERWAL
PAWANKUMAR
RANGLAL
TIBERWAL HUF
PRATIKSH
AGARWAL
RAJKUMAR
BHAGIRATH
GARODIA
RAKESH MALPANI
383
ABHPD6250D
384
AABHT3939E
385
AKHPA9714E
386
AAOPG8552B
387
AENPM9216K
388
ACNPA1461E
389
AABPT4736H
390
ACEPT8218R
391
AHOPA8973F
SWETA
VINAYKUMAR
TIBREWAL
ANAND AGARWAL
392
AIZPG7099Q
REKHA GARODIA
393
APPPB5638F
MANISH KUMAR
BHATI
394
AJFPR5740L
MANSI MANOJ
RANE
395
BAPPK2160M
MUKESH KUMAR
396
BQFPS5917N
OMPRAKASH
SHARMA
397
BPXPS8075L
ASHISH
ISHWARLAL SHAH
SANGEETA
AGARWAL
SAROJ TULSIYAN
KAILESH D AGARWAL HUF received shares

KAMLESHDEVI PAWANKUMAR
TIBERWAL received shares in physical form
from ANKIT JAIN
PAWANKUMAR RANGLAL TIBERWAL HUF
JAIN
PRATIKSH AGARWAL received shares in
RAJKUMAR BHAGIRATH GARODIA received
RAKESH MALPANI received shares in physical
form from ANKIT JAIN
SANGEETA AGARWAL received shares in
SAROJ TULSIYAN received shares in physical
form from ANKIT JAIN
SWETA VINAYKUMAR TIBREWAL received
ANAND AGARWAL received shares in physical
REKHA GARODIA received shares in physical
MANISH KUMAR BHATI received shares in
physical form from ROONGTA RISING
STOCK PVT LTD
MANSI MANOJ RANE received shares in
STOCK PVT LTD
MUKESH KUMAR received shares in physical
form from ROONGTA RISING STOCK PVT
LTD
OMPRAKASH SHARMA received shares in
STOCK PVT LTD
ASHISH ISHWARLAL SHAH received shares in
STOCK PVT LTD

Page 52 of 68
398
CNAPS8962G
ASIFATANVEER M
SHAIKH
399
AYQPK5002J
ATUL SUMATILAL
KANKARIYA
400
AAMHA5122
M
ATUL SUMATILAL
KANKARIYA HUF
401
AAKPS3275M
CHANDRAVATI M
SHAH
402
AYDPK2960J
HARSHAL ASHOK
KUMAT
403
BRSPS2170K
JAY KETAN
SOMAIYA
404
CAPPK0809Q
405
406
407
KAJALKIRAN
SUMATILAL
KANKARIYA
AMHPM0156A KETAN
JUMAKHLAL
MEHTA
AHXPM6863F KIRITKUMAR
RAMNIKLAL
MEHTA
AAKPS3276J
MANHARLAL N
SHAH
408
CLAPK0633E
PRIYANKA ATUL
KANKARIYA
409
ATRPM4285D
410
ABQPM1056P
PRIYANKA
PRAMOD
MHAPSEKAR
TEJAL PIYUSH
MEHTA
411
AFZPT5149K
TUSHAR ASHOK
THAKUR
ASIFATANVEER M SHAIKH received shares in

STOCK PVT LTD
ATUL SUMATILAL KANKARIYA received
shares in physical form from ROONGTA
RISING STOCK PVT LTD
ATUL SUMATILAL KANKARIYA HUF
received shares in physical form from
CHANDRAVATI M SHAH received shares in
STOCK PVT LTD
HARSHAL ASHOK KUMAT received shares in
STOCK PVT LTD
JAY KETAN SOMAIYA received shares in
STOCK PVT LTD
KAJALKIRAN SUMATILAL KANKARIYA
KETAN JUMAKHLAL MEHTA received shares
in physical form from ROONGTA RISING
STOCK PVT LTD
KIRITKUMAR RAMNIKLAL MEHTA received
MANHARLAL N SHAH received shares in
STOCK PVT LTD
PRIYANKA ATUL KANKARIYA received
PRIYANKA PRAMOD MHAPSEKAR received
TEJAL PIYUSH MEHTA received shares in
STOCK PVT LTD
TUSHAR ASHOK THAKUR received shares in
STOCK PVT LTD

Page 53 of 68
412
AMYPD3165F
USHA
RAKESHKUMAR
DIXIT
VIKRAM
NAVINCHANRA
SHAH
JAMUNADEVI
DARAK
413
AKCPS7427B
414
ACKPD3134C
415
ACQPL8917P
PARULMANOJ
LAKHOTIA
416
AAAPD9261A
PAWAN DARAK
417
AANPT7118D
SUNITA
TOSHNIWAL
418
AAWPA0033F
419
AACHR3530G
420
ADEPS9002P
421
ADWPC8603J
422
CMDPS8866F
423
AENPC4695Q
424
AEOPC1172P
425
AAPPC8401Q
426
ADNPC5472G
DINDAYAL SRIRAM
AGARWAL
RAJENDRA KUMAR
SARAF HUF
RAJENDRAKUMAR
MAHESHKUMAR
SARAF
SUBHASH
MANOHARLAL
CHAPLOT
VIDHIBEN
AMARKUMAR
SHAH
CHANDABEN
SUBHASHKUMAR
CHAPLOT
MADHUBEN
NIRMALKUMAR
CHAPLOT
SANJAY
KESHRIMAL
CHANDALIYA
SHAKUNTALA
SURESH CHAPLOT
USHA RAKESHKUMAR DIXIT received shares

in physical form from ROONGTA RISING
STOCK PVT LTD
VIKRAM NAVINCHANRA SHAH received
JAMUNADEVI DARAK received shares in
STOCK PVT LTD
PARULMANOJ LAKHOTIA received shares in
STOCK PVT LTD
PAWAN DARAK received shares in physical
form from ROONGTA RISING STOCK PVT
LTD
SUNITA TOSHNIWAL received shares in
STOCK PVT LTD
DINDAYAL SRIRAM AGARWAL received
shares in physical form from SANJAY ZENDE
RAJENDRA KUMAR SARAF HUF received
RAJENDRAKUMAR MAHESHKUMAR
SARAF received shares in physical form from
SANJAY ZENDE
SUBHASH MANOHARLAL CHAPLOT
received shares in physical form from SANJAY
ZENDE
VIDHIBEN AMARKUMAR SHAH received
shares in physical form from JAYESH SHAH
CHANDABEN SUBHASHKUMAR CHAPLOT
received shares in physical form from PRADIP
YADAV
MADHUBEN NIRMALKUMAR CHAPLOT
YADAV
SANJAY KESHRIMAL CHANDALIYA
YADAV
SHAKUNTALA SURESH CHAPLOT received
shares in physical form from PRADIP YADAV

Page 54 of 68
427
AAVPC8778N
SUNILKUMAR
WAZIRCHAND
CHOPRA
DINDAYAL SRIRAM
AGARWAL HUF
428
AACHA2135G
429
AAPPC8400R
ANIL KESHRIMAL
CHANDALIYA
430
ACUPC3378B
SUNIL KESHRIMAL
CHANDALIYA
431
AFQPS0828B
432
AARPC5810B
433
ABGPK4422R
434
AENPC4697N
435
AEZPB9208A
436
AYQPS8578K
TAJAL
MAHENDRABHAI
SHAH
SURESH
MANOHARLAL
CHAPLOT
ANOOPKUMAR
SHIVKARAN
KABRA
LALITA
SUNILKUMAR
CHANDALIYA
PRATIK VINOD
BIYANI
AMITKUMAR
RAJKUMAR SARAF
437
BCOPS8401G
438
ADEPS9003N
439
AEIPG5809D
440
AEDPG1655A
441
ACXPC0575H
ARPITKUMAR
MAHENDRABHAI
SHAH
MANJUDEVI
RAJENDRAKUMAR
SARAF
MUKESHKUMAR
GUPTA
SANDEEP
JAIBHAGAWAN
GUPTA
SUSHILA
ANILKUMAR
CHANDALIYA
SUNILKUMAR WAZIRCHAND CHOPRA

YADAV
DINDAYAL SRIRAM AGARWAL HUF
received shares in physical form from PRAKASH
G REVALE
ANIL KESHRIMAL CHANDALIYA received
shares in physical form from SOMNATH
BOMBLE
SUNIL KESHRIMAL CHANDALIYA received
BOMBLE
TAJAL MAHENDRABHAI SHAH received
BOMBLE
SURESH MANOHARLAL CHAPLOT received
shares in physical form from SUNIL MOHAN
KANSARA
ANOOPKUMAR SHIVKARAN KABRA
received shares in physical form from MANISH
SHAH
LALITA SUNILKUMAR CHANDALIYA
received shares in physical form from MANISH
SHAH
PRATIK VINOD BIYANI received shares in
physical form from MANISH SHAH
AMITKUMAR RAJKUMAR SARAF received
shares in physical form from SARITA DEVI
MALL
ARPITKUMAR MAHENDRABHAI SHAH
received shares in physical form from SARITA
DEVI MALL
MANJUDEVI RAJENDRAKUMAR SARAF
received shares in physical form from SARITA
DEVI MALL
MUKESHKUMAR GUPTA received shares in
physical form from SUKRIT GHOSH
SANDEEP JAIBHAGAWAN GUPTA received
shares in physical form from SUKRIT GHOSH
SUSHILA ANILKUMAR CHANDALIYA
received shares in physical form from SUKRIT
GHOSH

Page 55 of 68
442
ACXPC0574G
443
AAPPC1942G
444
AHTPA2405P
445
AASPA3156D
446
BAXPS8140P
447
ALSPG5391D
448
AAWPG3006C
449
450
451
PUSHPA
SANJAYKUMAR
CHANDALIYA
NIRMALKUMAR
MANOHARLAL
CHAPLOT
GHANSHYAM
DINDAYAL
AGARWAL
KANTADEVI
DINDAYAL
AGRAWAL
RAVI RAJKUMAR
SARAF
SHANU SARAF
ANITA ARVIND
GOYAL
AFXPS0334P
HIMMATBHAI
JIVRAJBHAI
SAVANI
ACSPA6502F
ANUPA JIGNESH
AMIN
ADOPN8097K ASHOKKUMAR
PANNALAL NAHAR
452
BFSPB3292M
SEEMA PRAKASH
BIYANI
453
ACRPC1929M
454
CUSPS9955G
455
AGEPB5746L
456
AAUPB0993K
457
ACNPC3759K
SANTOSH K
CHOUDHARY
NIKUNJ
HIMMATLAL
SAVANI
BINDU VINOD
BIYANI
GOPAL
NARAYANDAS
BAPECHA
KAILASHCHAND S
CHOUDHARY
PUSHPA SANJAYKUMAR CHANDALIYA

received shares in physical form from TEJAL
GALA
NIRMALKUMAR MANOHARLAL CHAPLOT
received shares in physical form from JAYESH
DEVGHARKAR
GHANSHYAM DINDAYAL AGARWAL
JANARDAN RAMSAKAL SHARMA
KANTADEVI DINDAYAL AGRAWAL
JANARDAN RAMSAKAL SHARMA
RAVI RAJKUMAR SARAF received shares in
physical form from JANARDAN RAMSAKAL
SHARMA
SHANU SARAF received shares in physical form
from JANARDAN RAMSAKAL SHARMA
ANITA ARVIND GOYAL received shares in
physical form from SAILESH PANDYA
HIMMATBHAI JIVRAJBHAI SAVANI received
shares in physical form from SAILESH PANDYA
ANUPA JIGNESH AMIN received shares in
physical form from SANJEEV SINGH
ASHOKKUMAR PANNALAL NAHAR
received shares in physical form from SANJEEV
SINGH
SEEMA PRAKASH BIYANI received shares in
STOCK PVT LTD
SANTOSH K CHOUDHARY received shares in
physical form from NEELAM MITTAL
NIKUNJ HIMMATLAL SAVANI received
BINDU VINOD BIYANI received shares in
physical form from JAYESH SHAH
GOPAL NARAYANDAS BAPECHA received
shares in physical form from JAYESH SHAH
KAILASHCHAND S CHOUDHARY received
shares in physical form from DEVKINANDAN
BHAVARLAL MITTAL

Page 56 of 68
458
AEDPA1268H
459
AAEHJ2523H
460
AAJPA2349H
461
AZRPS8654E
MAHENDRA
POORANMAL
AGARWAL
JIGNESH M AMIN
HUF
MAHENDRA POORANMAL AGARWAL

AMBIKADEVI SHIVSHANKAR DHANUKA
JIGNESH M AMIN HUF received shares in
physical form from SUNIL MOHAN KANSARA
JIGNESH MAHESH
AMIN
SAVITABEN
HIMMATBHAI
SAVANI
JIGNESH MAHESH AMIN received shares in

physical form from TEJAL GALA
SAVITABEN HIMMATBHAI SAVANI received
shares in physical form from JAYESH
DEVGHARKAR
Part II- List of Preferential Allottees

S.
No.
462
PAN
Name
No. of Shares Allotted
AALFG1236F
64000
463
AAAPZ1721B
464
AADPK9309F
465
AADPK1946Q
466
AAAPU2596F
467
ADGPC1107P
468
ACFPJ2428J
469
470
471
472
AADPJ5579L
AABHN4403P
ACUPJ1252F
ACAPS1025K
473
AGMPS2776H
474
475
AAJPA2349H
AACHM0965
N
ACSPB5838R
AECPC7959J
AEJPB6903J
GOKULDHAM
ENTERPRISES LLP
SHRENIK NALIN
ZAVERI
MAHESH KUMAR
KHATRY
PRAKASH CHAND
KHATRY
SHEETAL SANJAY
UDESHI
TARUN KUMAR
CHANDAK
MAHABIR PRASAD
JALAN
VIMAL JAIN
NARESH JALAN
NARESH JALAN
KALAWATI
SHARMA
PRAKASH CHAND
SHARMA
JIGNESH M. AMIN
MAHABIR PRASAD
JALAN
SHANKAR BATRA
HARLEEN KAUR
SAVITA BANSAL
476
477
478
7500
7500
2000
7500
7500
7500
12500
7500
12500
12500
12500
25000
25000
12500
12500
11700

Page 57 of 68
479
ABYPV5751G
480
481
ABTPS0026N
AJGPS8091J
482
ABQPL6153L
483
AADPC6863A
484
AADPC6859J
485
AEFPS6298M
486
487
ABHPA9244J
AADHR3405B
488
AGEPA7936K
489
AAFCP6925M
490
AJJPA7131N
491
AAIHK7794R
492
BBUPS3358D
493
494
AAAPU3996P
AABPK6317K
495
AADHP1700R
496
AAAPU3998D
497
AFOPP0215K
498
499
AFYPP8051P
AAFHS4851J
500
AJYPP3841M
CHIRAG
MAHESHKUMAR
VYAS
SMT RASHMI JAIN
SARAD KUMAR B
JAIN
TARACHAND L
SHAH
ASHOK KUMAR
CHOWATIA
MADANLAL
BABULAL
CHOWATIA
BRIJ BHUSHAN
SINGAL
SADHNA RANI
RAVINDER KUMAR
GUPTA
RANIDEVI
AGARWAL
PEARL ARCADE
TRADING PRIVATE
LIMITED
AMIT MADANLAL
AGARWAL
KAMAL KISHORE
GUPTA HUF
RAJESH
RAMANATH
SHETTY
MANISH UPPAL
VASANTLAL
NYALCHAND
KIKAVAT
PAVAN KUMAR
GUPTA
BUSHAN KUMAR
UPPAL
SHYAM SUNDAR
PATODIA
MANJU PATODIA
SHYAM SUNDAR
PATODIA
VIJAY KUMAR
12500
12500
2000
2000
12500
12500
12500
12500
12500
7500
12500
12500
12500
12500
25000
25000
25000
25000
25000
49000
49000
49000

Page 58 of 68
501
502
503
504
ACVPJ7655H
ABHPS3711N
ANRPS7986B
AAAHB6923R
505
506
AAEHN4557P
AAGPS6393C
507
AACPD7055J
PATODIA
DIVYA PATODIA
RITU SINGAL
NEERAJ SINGAL
BRIJ BHUSHAN
SINGHAL
NEERAJ SINGHAL
PRAKASH
MANGILAL SURYA
NITIN KUMAR
DIDWANIA
25000
25000
20000
25000
5000
12500
12500
Part III-List of Exit Providers

S.
No.
508
PAN
Name
AAKPS3276J
Manharlal
Narottamdas Shah
509
AAACE2862P
510
AACCA3220D
511
AADCS5411K
512
AABCB3052B
513
AAGCR1715E
Relationship
Manharlal Narottamdas Shah received 50 shares

from ROONGTA RISING STOCK PVT LTD in
Physical Form on 30-Jul-13
Esha Securities Ltd
On analyzing the bank statement submitted by the
trading member C.D Equisearch Pvt Ltd for its
client Pyramid Trading and Finance Limited, it
was observed that the client has transferred funds
to Esha Securities Private Limited.
Amrit Sales Promotion From the analysis of bank statement of Amrit
Pvt Limited
Sales Promotion Pvt. Ltd.(HDFC Bank-A/c No:
00080340006392) , it was observed that funds
were received from Blue Circle Services Ltd who
is observed to have fund transaction with Pine
Animation Ltd ( Allahbad Bank: A/c No:
50103075412)who is also observed to have fund
transaction with Mishka Finance Ltd ( Bank of
Baroda: A/c No: 12920200000506)
Symphony Merchant
As per bank statement of the client 'Amrit Sales
Pvt Ltd
Promotion Pvt Limited' (HDFC Bank-A/c No:
00080340006392), it has received / transferred
funds from / to 'Burlington Finance Limited' and
'Symphony Merchant Pvt Ltd'.
Bazigar Trading
The client 'Bazigar Trading Private Limited' and
Private Limited
the client 'Amrit Sales Promotion Pvt Limited'
have common email-id viz, naloo.kol@gmail.com'.
Rangan Vincom
Rangan Vincom Private Limited' has transferred
Private Limited
shares of Radford to 'Devatma Distributors
Private Limited' in the off market. Devatma
Distributors Private Limited shares common

Page 59 of 68
address with Blue Circle Services Limited.

514
AACCL3868N
Ladios Trading Private

Limited
515
AADCT8403C
Topwell Properties
Private Limited
516
AAMCS1712Q
Signet Vinimay Private

Limited
517
AAMCS1711P
Sanklap Vincom P
Ltd
Rangan Vincom Private Limited', 'Ladios Trading

Private Limited', 'Avlokan Dealcom Private
Limited' has common phone number viz,
'9831432937'.
On analyzing bank statement of the Topwell
Properties Private Limited (Axis Bank, Kolkata
branch having account no. - 911020032366261), it
was observed that funds were received/transferred
among Esquire Enclave Private Limited, Radison
Properties Private Limited, Kingfisher Properties
Private Limited, Shivkhori Construction Pvt. Ltd.
Natural Housing Private Limited, Limestone
Properties Private Limited. Funds were also
transferred to Signet Vinimay Pvt. Ltd.and Sankalp
Vincom Pvt. Ltd. Kingfisher Properties Private
Limited (Axis Bank, Kolkata branch having
account no. - 911020032345837) has received /
transferred funds from / to 'Esquire Enclave
Private Limited, Fairlink Housing Pvt Ltd. On
analyzing the bank statement received from the
trading member Korp Securities Ltd for its client
Fairlink Housing Private Limited, it was observed
that the said entity has received funds from an
entity viz, Venkatesh Sales Pvt Ltd which as per
the MCA website has the common address as that
of one of the director viz, Dhruv Narayan Jha of
the company Blue Circle Services Limited viz, P27, Princep Street, 3rd Floor, Kolkata, West
Bengal 700072. Further, as per MCA website
the email address of Venkatesh Sales Pvt Ltd and
Blue Circle Services Ltd is common viz,
dhruvonarayan.jha@rediffmail.com.
Properties Private Limited, it was observed that
funds were also transferred to Signet Vinimay Pvt.
Ltd.and Sankalp Vincom Pvt. Ltd.
Properties Private Limited, it was observed that
funds were also transferred to Signet Vinimay Pvt.
Ltd.and Sankalp Vincom Pvt. Ltd.

Page 60 of 68
518
AAECR0580M
519
AAACW8004B
520
AAPCS7492G
521
AAJCA4459K
Runicha Merchants
Private Limited
As per the KYC submitted by the trading member

'The Calcutta Stock Exchange Ltd' for its clients
'Runicha Merchants Private Limited', 'Signet
Vinimay Private Limited', 'Winall Vinimay Private
Limited' and 'Sanklap Vincom P Ltd' and Gateway
Financial Services Limited for its clients, 'Scope
Vyapar Private Limited' and 'SKM Travels Private
Limited' have common address viz, '23/1,
Principal Khudiram Bose Road, Kolkata, West
Bengal 700006. Further, as per MCA website,
Limited' and 'Sanklap Vincom P Ltd' have
common directors viz, Abhiset Basu and Pradip
Dey.
Winall Vinimay Private As per the KYC submitted by the trading member
Limited Ltd
Limited' and 'Sanklap Vincom P Ltd' have
common directors viz, Abhiset Basu and Pradip
Dey.
Spice Merchants
Private Limited
Limited', 'Spice Merchants Private Limited' and
'Apex Commotrade Private Limited Ltd', all clients
have common email id viz,
limited_kol@yahoo.in.
Apex Commotrade
Private Limited Ltd
Limited', 'Spice Merchants Private Limited' and
'Apex Commotrade Private Limited Ltd', all clients
have common email id viz,
limited_kol@yahoo.in.

Page 61 of 68
522
AAICS0688K
Skm Travels Private

Limited
523
AAICS6023N
Scope Vyapar Private

Limited
524
AAACV8378B
Vibgyor Financial
Servicepvt Ltd
525
AACCH4303G
Helpful Investment
Advisory Private
Limited
526
AABCF5486H
Function Financial
Consultants Private
Limited
527
AAECK7329P
Kapeeshwar Vintrade
Private Limited

the company 'Winall Vinimay Private Limited and
'SKM Travels Private Limited' have common
director viz, 'Abhiset Basu.
Bengal 700006.
The client Vibgyor Financial Service Pvt Ltd has
received shares in off market from Scope Vyapar
Private Limited.
As per MCA website 'DEBI PRASAD PAL' is
one of the directors of 'Helpful Investment
Advisories Pvt. Ltd., Function Financial
Consultants Private Limited and Topwell
Properties Private Limited
As per MCA website 'DEBI PRASAD PAL' is
one of the directors of 'Helpful Investment
Advisories Pvt. Ltd., Function Financial
Consultants Private Limited and Topwell
Properties Private Limited
Kapeeshwar Vintrade Private Limited have offmarket transactions with Apex Commotrade Pvt.
Ltd. and Helot Properties Private Limited in the
scrips of Rander Corporation Limited and Kelvin
Fincap Limited respectively. As per MCA website
Biplab Guha is one of the directors of
Kapeeshwar Vintrade Private Limited , Sinjan
Overseas Pvt Ltd and Wonder Procon Private
Limited.

Page 62 of 68
528
AAMCS8721P
Sinjan Overseas Pvt

Ltd
529
AABCW0317N
Wonder Procon
Private Limited Wppl
530
AACCH8885R
Helot Properties Pvt

Ltd
531
AAECC9285A
Cheroot Vanijya Pvt

Ltd
532
AATCS3687H
Sidhiman Vyapaar
Private Limited
533
AAECV4988P
Vishnudham
Marketing Private
Limited
534
AAECT5548F
Triala Dealers Private

Limited
535
AAICM4750C
Mobixa Distributors
Private Limited
536
AALCA7880J
Antaryami Traders
Private Limited
As per MCA website Biplab Guha is one of the

directors of Kapeeshwar Vintrade Private Limited
, Sinjan Overseas Pvt Ltd and Wonder Procon
Private Limited.
As per MCA website Biplab Guha is one of the
directors of Kapeeshwar Vintrade Private
Limited, Sinjan Overseas Pvt Ltd and Wonder
Procon Private Limited.
Helot Properties Private Limited has off-market
transactions with Kapeeshwar Vintrade Private
Limited in the scrip of Kelvin Fincap Limited. As
per MCA website NEWTON SARKAR is one of
the directors of Cheroot Vanijya Pvt Ltd and
As per MCA website NEWTON SARKAR is one
of the directors of Cheroot Vanijya Pvt Ltd and
Helot Properties Pvt Ltd. Further, as per MCA
website SUKUMAR GHOSH is one of the
directors of Cheroot Vanijya Pvt Ltd, Sidhiman
Vyapaar Private Limited, Vishnudham Marketing
Private Limited, Triala Dealers Private Limited
and Mobixa Distributors Private Limited
As per MCA website SUKUMAR GHOSH is one
of the directors of Cheroot Vanijya Pvt Ltd,
Sidhiman Vyapaar Private Limited, Vishnudham
Marketing Private Limited, Triala Dealers Private
Limited and Mobixa Distributors Private Limited
As per MCA website RAM KRISHNA
BHATTACHERJEE is one of the directors of
Triala Dealers Private Limited, Antaryami Traders
Private Limited, Gajgamini Merchandise Private

Page 63 of 68
Limited and Muchmore Vincom Private Limited

537
AAFCG2554B
Gajgamini
Merchandise Private
Limited
538
AAICM6982C
Muchmore Vincom
Private Limited
539
AAECD5782B
Dreamlight Exim
Private Limited
540
AAFCG4773J
Goldensight Traders
Private Limited
541
AAACD9125E
542
AABCR1974J
Dynamic Portfolio
Management &
Services Ltd
Ritesh Commercial
Holdings Limited
543
AADCR6224M
Ritesh Projects Private

Ltd.
544
AAECS0352C
Stardox Vinimoy
Private Limited
545
AABCR3482R
Raina Vyapaar Private

Ltd

Pintu Sardar, one of the directors of Dreamlight
Exim Private Limited and Bapi Naskar, one of the
directors of Antaryami Traders Private Limited
share common address, viz. 132, Mahendra Nagar
Panihati, Khardah North 24 Parganas, Kolkata,
700113, West Bengal, India
Pratap Chakraborty is one of the directors of
Dhyaneshwar Dealers Pvt Ltd and Goldensight
Traders Private Limited
Ashok Bothra was the common director in
and Blue circle Services Ltd.
Ravi Kumar Newatia is one of the directors of
Ritesh Projects Private and Ritesh Commercial
Holdings Limited
Ravi Kumar Newatia is one of the directors of
Ritesh Projects Private and Ritesh Commercial
Holdings Limited
Ritesh Commercial Holdings Limited, Ritesh
Projects Private Ltd., Stardox Vinimoy Private
Limited , Raina Vyapaar Private Ltd, R C
Suppliers Private Lim Ited , Hari Om Suppliers
Pvt. Ltd. and Kalakar Commercial Private
Limited are the shareholders of Surbhika vyapaar
pvt Ltd.
Biswanath Basak is one of the directors of
Stardox Vinimoy Private Limited R C Suppliers
Private Lim Ited
and Raina Vyapaar
Private Ltd
Ritesh Commercial Holdings Limited , Ritesh
Limited , Raina Vyapaar Private Ltd , R C

Page 64 of 68
546
AABCR2904A
R C Suppliers Private
Lim Ited
547
AABCH2251E
Hari Om Suppliers
Pvt. Ltd.
548
AADCK9346B
Kalakar Commercial
Private Limited
549
AAFCB0211J
550
AAGCR8142P
Blue Horizon
Commosales Private
Limited
Rochak Vinimay
Private Limited
Suppliers Private Limited, Hari Om Suppliers Pvt.

Ltd. and Kalakar Commercial Private Limited
are the shareholders of Surbhika vyapaar pvt Ltd.
R C Suppliers Private Lim Ited and Raina
Vyapaar Private Ltd
Suppliers Private Lim Ited , Hari Om Suppliers
pvt Ltd.
Stardox Vinimoy Private Limited R C Suppliers
Private Lim Ited and Raina Vyapaar Private Ltd
Suppliers Private Limited , Hari Om Suppliers
pvt Ltd.
Bishwanath Agarwal is one of the directors of
Hari Om Suppliers Pvt. Ltd. and Kalakar
Commercial Private Limited
Ritesh Commercial Holdings Limited,Ritesh
Limited, Raina Vyapaar Private Ltd , R C
Suppliers Private Lim Ited, Hari Om Suppliers
Pvt. Ltd. and Kalakar Commercial Private Limited
are the shareholders of Surbhika vyapaar pvt Ltd.
Bishwanath Agarwal is one of the directors of
Hari Om Suppliers Pvt. Ltd. and Kalakar
Commercial Private Limited
Blue Horizon Commosales Private Limited has
off market transactions with Kapeeshwar Vintrade
Private Limited in different scrips.
Rochak Vinimay Pvt Ltd and Rochi Dealcom Pvt
Ltd received shares of Splash Mediaworks Limited
from Muchmore Vincom Private Limited and
Sidhiman Vyapaar Private Limited through offmarket transactions.As per MCA website Rohit
Agarwal is one of the directors of Rochak
Vinimay Private Limited and Rochi Dealcom

Page 65 of 68
551
AAGCR7017M
Rochi Dealcom
Private Limited
552
AAECD9323N
Duari Marketing
Private Limited
553
ACIPS8803M
S N Srinivasan
554
BABPS7447D
Amit Singh
555
AADCI5139E
Indrawati Nirman Pvt

Ltd
556
AAGCR4662J
Reachsmart
Construction Pvt Ltd
557
AABCO6950F
Overload Financial
Advisory Pvt Ltd
558
AARCS9144H
Sebika Commodities
Private Limited
Private Limited
Rochak Vinimay Pvt Ltd and Rochi Dealcom Pvt
Ltd received shares of Splash Mediaworks Limited
from Muchmore Vincom Private Limited and
Sidhiman Vyapaar Private Limited through offmarket transactions.As per MCA website Rohit
Agarwal is one of the directors of Rochak
Vinimay Private Limited and Rochi Dealcom
Private Limited
Duari Marketing Private Limited . received shares
of Splash Mediaworks Limited from Mobixa
Distributors Private Limited, Antaryami Traders
Private Limited and Muchmore Vincom Private
Limited through off-market transactions
S N Srinivasan transferred shares of Anukaran
Commercial Enterprises Limited to Sanklap
Vincom Pvt. Ltd. through off-market transactions
Amit Singh has off market transactions in various
scrips with Scope Vyapar Pvt. Ltd., Sanklap
Vincom Pvt. Ltd., Signet Vinimay Pvt. Ltd. and
Runicha Merchants Pvt. Ltd.
Indrawati Nirman Private Limited has off-market
transactions with Gajgamini Merchandise Private
Limited, Rochak Vinimay Pvt Ltd, Sebika
Commodities Private Limited, Reachsmart
Construction Private Limited, Reachsmart
Dealtrade Private Limited and Rangan Vincom
Private Limited in different scrips.
Reachsmart Constructions Pvt. Ltd. Has off
market transactions with Indrawati Nirman Private
Limited in the scrip of SRK Industries Limited.
Further, Reachsmart Constructions Private
Limited Has received/transferred funds from/to
As per MCA website RAJIB RAJBANGSHI is
one of the directors of Reachsmart Constructions
Private Limited, Overload Financial Advisory Pvt
Ltd and Sebika Commodities Private Limited
As per MCA website RAJIB RAJBANGSHI is
one of the directors of Reachsmart Constructions
Private Limited, Overload Financial Advisory Pvt
Ltd and Sebika Commodities Private Limited

Page 66 of 68
559
AATCS4365E
Samridhipurn Services
Private Limited
560
AAFCR9881C
Reachsmart Dealtrade
Private Limited
561
AATCS6718D
Swarnprakash Traders
Private Limited
562
AAECD8010E
Dhyaneshwar Dealers
Pvt Ltd
563
AAECD8235D
Dhlriti Traders Pvt

Ltd
564
AAGCR6009M
Ramya Mercantile Pvt

Ltd
565
AAFCB4546A
Badamisati
Apartments Private
Limited
As per MCA website PROMOD BARIK is one of

the directors of Sebika Commodities Private
Limited, Samridhipurn Services Private Limited
and Reachsmart Dealtrade Private Limited
As per MCA website PROMOD BARIK is one of
the directors of Sebika Commodities Private
Limited, Samridhipurn Services Private Limited
As per MCA website TAPAS MONDAL is one of
the directors of Swarnprakash Traders Private
Limited and Samridhipurn Services Private
Limited
As per MCA website NIRAJ KUMAR RAY is one
of the directors of Dhyaneshwar Dealers Pvt Ltd
There are numerous fund transactions between
Dhlriti Traders Pvt.Ltd (The Ratnakar Bank : A/c
no: 409000125799) and Ramya Mercantile Pvt. Ltd
( The Ratnakar Bank : A/c no: 409000115428).
There are numerous fund transactions between
Dhlriti Traders Pvt.Ltd (The Ratnakar Bank : A/c
no: 409000125799) and Ramya Mercantile Pvt. Ltd
( The Ratnakar Bank : A/c no: 409000115428).
Further Ramya Mercantile Pvt Ltd has also
transferrd funds from this account to Badamisati
Apartments Private Limited
Badamisati Apartments (P) Ltd. transferred shares
of Kailash Auto Finance Limited and Surabhi
Chemicals and Investments Limited to Saktimata
Marketing Private Limited and Eversafe
Promoters Private Limited through off-market
transactions.
Saktimata Marketing Private Limited received
shares of Sunshine Realty Development Limited
from Rochak Vinimay Pvt Ltd, Rochi Dealcom
Pvt Ltd and Duari Marketing Private Limited.
Eversafe Promoters Private Limited received
shares of Kailash Auto Finance Limited from
Sinjan Overseas Pvt Ltd . through off market
transactions. Further Ramya Mercantile Pvt Ltd (
The Ratnakar Bank : A/c no: 409000115428) has
also transferrd funds from this account to

Page 67 of 68
566
ATIPM7500N
Arunavo Mukherjee
Arunavo Mukherjee transfered 20000 shares to

CAMELLIA VINIMAY PVT LTD in Off Market
on 27-May-14. CAMELLIA VINIMAY PVT
LTD received 11,000 shares from Heliot
Properties through off market transactions.
Sd/Date: April 17th, 2015

Place: Mumbai
RAJEEV KUMAR AGARWAL

WHOLE TIME MEMBER

Page 68 of 68

Order in The Matter of Mishka Finance and Trading Ltd.

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Order in The Matter of Mishka Finance and Trading Ltd.

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WTM/RKA /ISD / 30 /2015

SECURITIES AND EXCHANGE BOARD OF INDIA

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

Brought to you by http://StockViz.biz

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Bharat Bagri Bagri

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Promoter related entities

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

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DINDAYAL MALCHAND AGARWAL HUF

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

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RAVINDER KUMAR GUPTA (HUF)

Manharlal Narottamdas Shah

Helot Properties Pvt Ltd

Vishnudham Marketing Private Limited

Triala Dealers Private Limited

Mobixa Distributors Private Limited

Antaryami Traders Private Limited

Ritesh Projects Private Ltd.

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

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Stardox Vinimoy Private Limited

Preferential 18921835 61.00%

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

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Dhlriti Traders Pvt Ltd

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

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Duari Marketing Private

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

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Triala Dealers Private

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

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1.0625 2000000 50.95

1.0625 1306850 37.62

1.0625 1066300 48.45

1.0625 1000000 52.78

1.0625 1000000 54.90

1.0625 1000000 53.73

1.0625 1000000 49.68

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

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1.0625 1000000 47.45

1.0625 1000000 47.20

1.0625 1000000 46.18

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

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

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

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

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Prohibition of manipulative and deceptive devices, insider trading and