Noticee No Sample Clauses

Noticee No. 4 vide letter dated February 17, 2020, Noticee No. 5 to 9 vide common letter dated February 17, 2020 and Noticee No. 4 to 9 vide common letter / email dated July 15, 2020 submitted their reply / written submissions in the matter. Their submission in brief are as under: 9.1. Noticee No. 4 to 9 denied the allegation mentioned in the SCN. 9.2. Sayaridevi does not have any connection with RSGBL. Xxxxxxxxxx neither holds any shares in RSGBL nor had anything to do with the delisting process or in the book building process of delisting of shares of RSGBL. Xxxxxxxxxx was part of the family arrangement / separation and not part of the promoter group. 9.3. Xxxxxxxxxx transferred the fund of Rs. 31,25,000/- to her son Motit out of her love and affection for him to utilise the fund in usual course of his business. Xxxxx utilised the funds to acquire the shares of Vital. The said acquisition of Vital was not on the instruction of Xxxxxxxxx. The acquisition of Vital was an independent decision of Xxxxx and was carried out in the ordinary course of business for the purpose of carrying on the business of advisory and consultancy in finance and management.
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Noticee No. 36 vide letters dated January 23, 2020 and June 24, 2020 denied all the allegation contained in the SCN and submitted that SCN have been issued to him being an independent director of RSGBL. There is no allegation in the SCN against him in person. He exercised his roles and responsibilities in professional capacity in bona fide manner on the basis information and documents presented before Board by RSGBL.
Noticee No. 13 stated that the funds received from Noticee No. 3 are in respect of consideration of shares tendered by him in the buy-back process of Noticee No.
Noticee No. Period Gross Buy quantity Gross Sell quantity Total Gross Buy and Sell Quantity % to total gross buy and sell quantity compared to total gross buy and sell quantity during IP 1, 2 ,3 and 14 to 33 01.12.2015 - 30.11.2016 79,520 75,750 1,55,270 9.08 01.12.2016 - 30.11.2017 8,50,669 8,59,545 17,10,214 100.00 01.12.2017 - 30.11.2018 1,06,047 1,54,133 2,60,180 15.21
Noticee No. 31 stated that her father is Xx. Xxxxxxxxxx X. Chaudhary and after the wedding of the daughter, the parents will not interfere in the married life of the daughter. The relationship with her father is purely personal and has no business or professional relationship with him. Shri Xxxxxxxxxx Xxxxxx Xxxx (Karta of Noticee No. 32) is her husband. That her husband’s email id is for convenience sake and was inserted when the trading account and the demat accounts were opened
Noticee NoBuyer Name Noticee No. Seller Name Traded quantity 14 Oswal Shares Securities Ltd. 16 Javerilal Gopilal Jain HUF 300 17 Javerilal Gopilal Oswal 5,000 18 Tankidevi Javerilal Oswal 1,300 19 Kalpesh Javerilal Oswal 2,000 23 Ravikumar Javerilal Oswal 8,000 15 Javerilal Oswal Commodities Pvt Ltd 17 Kalpesh Javerilal Oswal 1,000 17 Javerilal Gopilal Oswal 15 Javerilal Oswal Commodities Pvt Ltd 1,000 17 Javerilal Gopilal Jain HUF 16,990 27 Varshadevi Rajendrakumar Jain 5,500 28 Akshay Rajendrabhai Oswal 6,700 18 Tankidevi Javerilal Oswal 23 Ravikumar Javerilal Oswal 2,000 19 Kalpesh Javerilal Oswal 23 Ravikumar Javerilal Oswal 3,000 28 Akshay Rajendrabhai Oswal 500 20 Vanita Kalpesh Oswal 23 Ravikumar Javerilal Oswal 1,950 22 Kavita Javerilal Oswal 23 Ravikumar Javerilal Oswal 600 23 Ravikumar Javerilal Oswal 18 Tankidevi Javerilal Oswal 4,450 19 Kalpesh Javerilal Oswal 1,000 20 Vanita Kalpesh Oswal 3,950 24 Monika Dharmendra Abbani 20 Vanita Kalpesh Oswal 50 23 Ravikumar Javerilal Oswal 1,450 25 Sangeeta Dinesh Abbani 27 Varshadevi Rajendrakumar Jain 1,000 26 Rajendrakumar Gopilal Jain 15 Javerilal Oswal Commodities Pvt Ltd 900 23 Ravikumar Javerilal Oswal 8,932 27 Varshadevi Rajendrakumar Jain 17 Javerilal Gopilal Oswal 1,500 19 Kalpesh Javerilal Oswal 1,000 22 Kavita Javerilal Oswal 1,000 26 Rajendrakumar Gopilal Jain 1,000 28 Akshay Rajendrabhai Oswal 15 Javerilal Oswal Commodities Pvt Ltd 150 18 Tankidevi Javerilal Oswal 500 20 Vanita Kalpesh Oswal 581 22 Kavita Javerilal Oswal 350 29 Akshita Rajendra Shah 18 Tankidevi Javerilal Oswal 500 23 Ravikumar Javerilal Oswal 5,000 30 Sneha Lalitkumar Shah 16 Javerilal Gopilal Jain HUF 459 33 Metroglobal Limited 1,629 31 Shobha Lalitkumar Shah 17 Javerilal Gopilal Oswal 55 Noticee No. Buyer Name Noticee No. Seller Name Traded quantity 27 Varshadevi Rajendrakumar Jain 73 33 Metroglobal Limited 215 32 Lalitkumar Ranmal HUF 33 Metroglobal Limited 6,204 33 Metroglobal Limited 30 Sneha Lalitkumar Shah 4,549 31 Shobha Lalitkumar Shah 8,229 32 Lalitkumar Ranmal HUF 5,061
Noticee No. 37 vide letter dated January 20, 2020 and email dated June 24, 2020 submitted that SCN have been issued to him being an independent director of RSGBL from September 16, 2016 to August 08, 2018. There is no allegation in the SCN against him in his personal capacity. All actions and decision taken during his tenure as an independent director were based on the facts and figure presented to the board of directors of RSGBL. He was not involved in day to day working of RSGBL. The promoter and RSGBL will submit detailed response in the matter.
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Noticee No. 34 vide letter dated February 17, 2020 submitted that RSGBL is a body corporate distinct from its promoters and management and SCN has been issued to RSGBL as the delisting process relates to RSGBL and there is no other allegation against RSGBL in the SCN. Thus, the allegations contained in the SCN are denied and untrue.
Noticee No. 4 to 9 is neither “promoter group” nor “persons acting in concert”. There was no shared common objective of committing any fraud or deception or illegality by any of the Noticee No. 4 to 9 with any of the promoter of RSGBL. A finding of fraud, deception etc. cannot be based on suspicion and conjecture and must be proved beyond reasonable doubt
Noticee No. 14 to 33 submitted that they were trading in the shares of RSGBL even prior to the investigation period and was in their normal and ordinary course of business / investment and as per their investment strategy. Their trading in the shares of RSGBL vis-a-vis overall trading was miniscule. The trading in the shares of RSGBL was done out of their own funds.
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