Adjudication order in respect of nine entities in the matter of 20 Microns Ltd

Adjudication order in the matter of 20 Microns Ltd BEFORE THE ADJUDICATING OFFICER SECURITIES AND EXCHANGE BOARD OF INDIA [ADJUDICATION ORDER NO. Order/KS/AS/2021-22/13187-13195] __________________________________________________________________ UNDER SECTION 15-I OF THE SECURITIES AND EXCHANGE BOARD OF INDIA ACT, 1992 READ WITH RULE 5 OF SEBI (PROCEDURE FOR HOLDING INQUIRY AND IMPOSING PENALTIES) RULES, 1995 In respect of S no Name of entity PAN

1 Viking Industries Pvt. Ltd. AACCV3221B

2 Anand Honwadkar AGNPH7773A

3 Rohit Kiritkumar H. AUXPR0807K

4 Bhavana P. Bhatt ANAPB4318D

5 Minu Nileshkumar Doshi ABQPD8086L

6 Nilesh A. Doshi HUF AAFHN5097K

7 Nileshkumar A. Doshi ABJPD0467E

8 Jignesh I. Shah AJOPS2389D

9 Leena J. Shah FJJPS0065L In the matter of 20 Microns Ltd __________________________________________________________________ BACKGROUND

1. Securities and Exchange Board of India (hereinafter referred to as SEBI) conducted investigation interalia in respect of manipulation of the scrip price of 20 Microns Ltd (hereinafter referred to as 20 Microns) during the period July 01, 2014 to October 31, 2015 (hereinafter referred to as IP). Pursuant to the investigation, SEBI interalia noted that entities M/s Viking Industries Pvt. Ltd., Anand Honwadker, Rohit Kiritkumar H., Bhavana P. Bhatt, Minu N. Doshi, M/s Nilesh A. Doshi HUF, Adjudication order in the matter of 20 Microns Ltd Nileshkumar A. Doshi, Jignesh I. Shah and Leena J. Shah violated the provisions of Regulations 3(a)(b)(c)(d), 4(1), 4(2)(a), (e) and (g) of SEBI (Prohibition of Fraudulent and Unfair Trade Practices) Regulations, 2003 (hereinafter referred to as PFUTP Regulations, 2003). APPOINTMENT OF ADJUDICATING OFFICER

2. In this regard, SEBI initiated Adjudication Proceedings against the Noticees and appointed the undersigned as Adjudicating Officer, conveyed vide communique dated May 08, 2018, under Section 15-I of the SEBI Act, 1992 and Rule 3 of the SEBI (Procedure for Holding Inquiry and Imposing Penalties) Rules, 1995 (hereinafter referred to as Adjudication Rules, 1995) to inquire into and adjudge under Section 15HA of the SEBI Act, 1992, the alleged violations of provisions of Regulations 3(a)(b)(c)(d), 4(1), 4(2)(a),(e) and (g) of PFUTP Regulation, 2003 by the Noticees. SHOW CAUSE NOTICE, REPLY AND PERSONAL HEARING

3. A common Show Cause Notice dated April 16, 2019 (hereinafter referred to as SCN) was issued interalia to the Noticees in terms of Section 15-I of the SEBI Act, 1992 read with Rule 4 of the Adjudication Rules, 1995 to show cause as to why an inquiry should not be held against them and why penalty, if any, under Section 15HA of the SEBI Act, 1992 be not imposed on the Noticees. The allegations in SCN are reproduced below: Thereafter, SEBI distinguished certain entities, who had traded in the scrip of

20 Microns during the investigation period, on the basis of common phone number, email ids and off-market transactions. Further, SEBI also observed that Noticee 1 was connected to the Company. In this regard, SEBI alleged connections among the entities, identified by it, on the basis of Unique client code (UCC) database updated by the brokers, MCA website (for common directors), off-market transfers/transactions, information available on Adjudication order in the matter of 20 Microns Ltd exchange website and bank account statements. After examining the said connections, SEBI identified a group of 12 suspected entities including the Company 20 Microns & its promoter M/s Eriez Finance & Investment Ltd. and the Noticees 1 to 9 (hereinafter referred to as the group). The names, PANs and basis of connections between the group entities are as under: Name PAN Basis of connection

1. Viking Industries Pvt. Ltd. AACCV3221B As per UCC details (Annexure 4) Entity no. 1, 2, 3, 4,9,10,12 have common phone no. 9429896070, Entity no. 1,2,3,4,12 common email id- acmeshare@gmail.com, Entity no. 1,5,8 & 9 have common email id nileshdoshi40@gmail.com, Entity no. 5, 7 & 8 share common address : A-1, 1st Floor, Anugrah Appt, Opp. Bank Of Rajasthan, Kalavad Road, Rajkot, Gujarat, & 330 Silver Chambers 3rd Floor Tagore Road, Rajkot, Gujarat, Entity no. 3 & 10 have common email ID bhavanabhatt@64@yahoo.in, Entity no.2 & 9 have common email ID anand.honwadker@yahoo.in, Entity no. 2 & 3 have common email ID 20diacentre@gmail.com Entity no.9 & 10 have common email ID jigneshshah286@gmail.com & address - Entity no. 8 is the Karta of entity at sr. no.5 As per information available on BSE website, entity no.12 is the promoter of entity no.11. Off market transfer in the scrip of 20 Microns Ltd. between the following (Annexure 5): Entity no.3 & 4 on August 13, 2014 Entity no.1 & 6 on April 16, 2015 Entity no.2 & 9 on August 18, 2015 As per data on MCA website (Annexure 6), entity no. 11 & 12 have common directors Chandresh Shantilal Parikh, Rajesh Chandreshbhai Parikh, Sudhir Rameshkant Parikh. As per UCO Bank a/c no. 01560100004831 (Annexure 7) held jointly by entity no.9 & 10, financial transactions observed with entity no. 1 & with Sudhir R. Parikh - Director of entity no. 11 & As per IDBI Bank a/c no.0021104000282031 (Annexure 8) held by entity no.3, financial transactions observed with entity no. 1. As per ICICI bank a/c no.624801517576 (Annexure

9) held by entity no.7, financial transactions observed with entity no.1 & 8. As per Axis bank a/c no.013010200002846 (Annexure 10) held by entity no.12, financial transactions observed with entity no.1 & 8 As per Axis bank a/c no.013010200059422 (Annexure 11) held by entity no. 1, financial transactions observed with entity no.4, 9, 10,11, 12

2. Anand Honwadker AGNPH7773A

3. Bhavana P Bhatt ANAPB4318D

4. Kiritkumar Hiralal Rohit AUXPR0807K

5. Nilesh A Doshi AAFHN5097K

6. Shishir Jayantilal Khandwala ADIPK8614M

7. Minu Nileshkumar Doshi ABQPD8086L

8. Nileshkumar Amrutlal Doshi ABJPD0467E

9. Jigneshkumar Indravadanbhai Shah AJOPS2389D

10. Leena Jigneshkumarsh FJJPS0065L

11. 20 Microns Ltd. AAACZ0580B

12. Eriez Finance & Investment Ltd. (now known as Eriez Industries Pvt. Ltd.) AAACZ0643B Adjudication order in the matter of 20 Microns Ltd It is observed that 20 Microns is the Company and Eriez Finance & Investment Ltd. did not trade in the scrip of 20 Microns on BSE and NSE during the investigation period. The details of trades of the rest of the group entities are as under: (a) Details of trading by the remaining 10 suspected entities of the group on BSE during the IP are as under: Client Name Gross Buy Gross Sale Net trade Gross Buy % to total Buy Vol Gross Sell% to total Sell

1 Viking Industries Private Limited 2533961 2319787 214174 14.01 12.83

2 Anand Honwadker 1617680 1779133 -161453 8.95 9.84

3 Kiritkumar Hiralal Rohit 1091680 1066902 24778 6.04 5.90

4 Minu Nileshkumar Doshi 743441 711209 32232 4.11 3.93

5 Nilesh A Doshi HUF 663068 641971 21097 3.67 3.55

6 Bhavana P Bhatt 645937 1029919 -383982 3.57 5.70

7 Nileshkumar Amrutlal Doshi 627023 595252 31771 3.47 3.29

8 Jigneshkumar Indravadanbhai Shah 468338 417604 50734 2.59 2.31

9 Leena Jigneshkumar Shah 439830 358047 81783 2.43 1.98

10 Shishir Jayantilal Khandwala 0 18800 -18800 0.00 0.10 Grand Total 8830958 8938624 -107666 48.84 49.44 Market total 18081148 18081148 As seen from above table, the above 10 suspected entities on BSE had purchased 88,30,958 shares (48.84% of total market volume) and sold 89,38,624 shares (49.44% of total market volume) during investigation period. (b) Details of trading by the following 10 suspected entities of the group on NSE during the IP are as under: Client Name Gross Gross Sale Net trade Gross Buy % to total Buy Vol Gross Sell% to total Sell

1 Anand Honwadker 2114824 1965250 149574 9.63 8.95 Viking Industries Private Limited 2114461 2199384 -84923 9.63 10.02

3 Bhavana P Bhatt 1123121 877052 246069 5.12 4.00 Adjudication order in the matter of 20 Microns Ltd

4 Minu Nileshkumar Doshi 598164 635896 -37732 2.72 2.90

5 Kiritkumar Hiralal Rohit 562563 701091 -138528 2.56 3.19

6 Nilesh A Doshi(Huf) 554905 560502 -5597 2.53 2.55

7 Nileshkumar Amrutlal Doshi 516438 556209 -39771 2.35 2.53 Jigneshkumar Indravadanbhai Shah 463351 524457 -61106 2.11 2.39

9 Leena Jigneshkumar Shah 398437 464800 -66363 1.82 2.12 Shishir Jayantilal Khandwala 0 13700 -13700 0.00 0.06 Grand Total 8446264 8498341 -52077 38.48 38.71 Market total 21952189 21952189 As seen from above table, the above 10 suspected entities on NSE have purchased 84,46,264 shares (38.48% of total market volume) and sold 84,98,341 shares (38.71% of total market volume) during investigation period. It was further observed that, out of total 328 trading days on BSE during the investigation period, the group had traded on 326 trading days and purchased 88,30,958 shares and sold 89,38,624 shares. At the same time, on NSE, the group had traded on 323 trading days and purchased 84,46,264 shares and sold 84,98,341 shares. The group was also trading amongst themselves contributing to the total traded volume in the scrip. The following observations are made from the analysis of such trades by the group entities: Exchange Market volume Total no. of shares bought by the group Total no. of shares sold by the group Total traded qty among the group entities Traded qty among the group as a % of mkt.vol. Traded Qty. among the group as a % of total no. shares bought Traded Qty. among the group as a % of total no. shares sold A B C D E F G H BSE 18081148 8830958 8938624 7611462 42.10% 86.19% 84.20% NSE 21952189 8446264 8498341 7070044 32.21% 83.71% 83.19% Synchronized Trades: It is alleged that artificial volume was created during the investigation period by suspected entities of the group by executing synchronized trades among themselves for 40,85,007 shares at BSE which amounted to 22.60% of total Adjudication order in the matter of 20 Microns Ltd market volume of trades in the scrip of 20 Microns on BSE and 33,68,758 shares at NSE which amounted to 15.35% of total market volume on NSE. In this regard, it is observed by SEBI that synchronized trades are those trades where the buy and sell order quantity and rate are identical and orders for these transactions are placed within a time gap of one minute. It is further observed that synchronized trades create artificial/fictitious volume in the market and give a false and misleading appearance of trading in the scrip at the exchange. (a) Details of alleged synchronized trades by the group entities on BSE & NSE are given in the following table: Exchange Market volume Gross Buy Qty of suspected entities Gross Sell Qty of suspected entities Total traded qty among suspected entities Synchroniz ed traded qty by suspected entities Sync Trades as % of total traded qty among the suspected entities Sync Trades as % of Total market volume Sum of LTP at sync trades (Rs.) A B B C D E F G H BSE 18081148 8830958 8938624 7611461 4085007 53.67% 22.60% -28.7 NSE 21952189 8446264 8498341 7070044 3368758 47.65% 15.35% -0.40 (b) In view of the above, it is alleged that Noticee 1 to 9 had executed synchronized trades amongst themselves in repetitive manner on 260 days on BSE and on 264 days on NSE which resulted in creation of artificial volume in the market. In this regard, the summary & day-wise trade details of the trades carried out by Noticee 1 to 9 on BSE and NSE, which are alleged to be synchronized trade, are placed at Annexure 12 & 13. (c) Analysis of synchronized trades of suspected entities at BSE who contributed more than 1% of the market volume as an individual was carried out by SEBI. Summary of the synchronized trades executed by 9 of the suspected entities at BSE is given hereunder: Adjudication order in the matter of 20 Microns Ltd No. Particulars Buy Side Sell Side Qty of Synch Trade % of Synch Vol. to Mkt. Vol. No of days No. of Trades Qty of Synch Trade % of Synch Vol. to Mkt. Vol. No of days No. of Trades

1 Viking Industries Pvt. Ltd. 1155565 6.39 173 524 1012777 5.60 162 512

2 Rohit Kiritkumar Hiralal 613923 3.40 46 147 477072 2.64 40 123

3 Honwadker Anand 579490 3.21 78 220 704276 3.90 86 289

4 Bhavana Pareshkumar Bhatt 413646 2.29 36 103 510440 2.82 41 124

5 Minu Nileshkumar Doshi 346576 1.92 181 244 342709 1.90 177 218

6 Nilesh A Doshi HUF 282017 1.56 166 200 336377 1.86 170 200

7 Nileshkumar Amrutlal Doshi 254983 1.41 154 168 282757 1.56 158 170

8 Jigneshkumar Indravadanbhai Shah 227041 1.26 18 61 191172 1.06 15 36

9 Leena Jigneshkumar Shah 211766 1.17 15 49 227427 1.26 14 44 Grand Total 4085007 22.60 1716 4085007 22.60 1716 (d) SEBI had carried out an analysis of trades, alleged to be synchronized trades, of Noticee 1 to 9 on NSE who contributed more than 1% of the market volume as an individual. Summary of such trades executed by Noticee 1 to 9 at NSE is given hereunder: No. Particulars Buy Side Sell Side Qty of Synch Trade % of Synch Vol. to Mkt. Vol. days No. of Trades Qty of Synch Trade % of Synch Vol. to Mkt. Vol. No of days No. of Trades Viking Industries Pvt. Ltd. 901589 4.11 155 491 860850 3.92 145 449

2 Honwadker Anand 696677 3.17 94 322 632811 2.88 99 254 Bhavana Pareshkumar Bhatt 475951 2.17 38 117 392746 1.79 38 88 Minu Nileshkumar Doshi 259566 1.18 144 203 306090 1.40 175 225

5 Rohit Kiritkumar Hiralal 251819 1.15 28 70 198745 0.91 29 52 Adjudication order in the matter of 20 Microns Ltd Jigneshkumar Indravadanbhai Shah 249766 1.14 16 72 265782 1.21 18 72 Nileshkumar Amrutlal Doshi 202046 0.92 135 148 261641 1.19 163 179

8 Nilesh A Doshi HUF 187052 0.85 115 128 257510 1.17 164 187 Leena Jigneshkumar Shah 144292 0.66 12 33 192583 0.88 19 78 Grand Total 3368758 15.35 1584 3368758 15.35 1584 In view of this, it is alleged that, by indulging in trades that were in alleged to be synchronized trades, Noticee 1 to 9 created artificial/ fictitious volume in the market and gave a false and misleading appearance of trading in the scrip of 20 Microns at BSE and NSE. In view of the same, it is alleged that Noticees

1 to 9 have violated the provisions of Regulations 3 (a), (b), (c), (d), 4 (1), 4 (2)(a) & (g) of PFUTP Regulations. Circular/Reversal of trade: Circular trades are trades done by a group of connected entities among themselves. Reversal trades are the trades where the buyer and seller reverse their position with each other on same day. It is alleged by SEBI that Noticee 1 to 9 had executed circular trades among themselves at BSE and NSE which resulted in creation of artificial volume in the market. Summary of the trades executed by Noticee 1 to 9, alleged to be circular trades, is as under: Sr. No. Exchange Total traded qty among the group entities Circular quantity % of circular qty to market volume Total no. of trades

1 BSE 7611461 7545252 41.73 4585

2 NSE 7070044 6863390 31.27 4841 (a) Summary of the trades carried out by the group entities on BSE, which are alleged to be circular trades, is tabulated as follows: Adjudication order in the matter of 20 Microns Ltd No. Particulars Exchange - BSE Buy Side Sell Side Qty of circular trade % of Circular trade Vol. to Mkt. Vol. No. of Trades Qty of circular trade % of Circular trade Vol. to Mkt. Vol. No. of Trades

1 Viking Industries Private Limited 1769925 9.79 1216 1894471 10.48 1162

2 Nilesh A Doshi Huf 598117 3.31 403 580196 3.21 496

3 Nileshkumar Amrutlal Doshi 541136 2.99 375 564384 3.12 465

4 Minu Nileshkumar Doshi 625832 3.46 442 623058 3.45 494

5 Shishir Jayantilal Khandwala 6050 0.03 3 0 0 0

6 Anand Honwadker 1501543 8.30 908 1361307 7.53 864

7 Jigneshkumar Indravadanbhai Shah 409731 2.27 188 432236 2.39 201

8 Bhatt Bhavana Pareshkumar 830566 4.59 462 618111 3.42 264

9 Rohit Kiritkumar Hiralal 948639 5.25 460 1034465 5.72 438

10 Leena Jigneshkumar Shah 313713 1.74 128 437024 2.42 201 Grand Total 7545252 41.73 4585 7545252 41.73 4585 (b) Summary of the trades carried out by the group entities on NSE, which are alleged to be circular trades, is tabulated as follows: No. Particulars Exchange - NSE Buy Side Sell Side Qty of circular trade % of Circular trade Vol. to Mkt. Vol. No. of Trades Qty of circular trade % of Circular trade Vol. to Mkt. Vol. No. of Trades

1 Viking Industries Private Limited 1368852 6.24 1057 1603860 7.31 1306

2 Nilesh A Doshi Huf 534268 2.43 516 532689 2.43 438

3 Nileshkumar Amrutlal Doshi 501439 2.28 517 485314 2.21 427

4 Minu Nileshkumar Doshi 570684 2.60 559 570654 2.60 484

5 Anand Honwadker 1618887 7.37 1103 1497483 6.82 1110

6 Jigneshkumar Indravadanbhai Shah 430537 1.96 180 486180 2.21 229

7 Bhatt Bhavana Pareshkumar 997186 4.54 463 717073 3.27 340

8 Rohit Kiritkumar Hiralal 486804 2.22 283 541538 2.47 264

9 Leena Jigneshkumar Shah 354733 1.62 163 428599 1.95 243 Grand Total 6863390 31.27 4841 6863390 31.27 4841 (c) In this regard, a sample of certain transactions carried out by Nilesh HUF, Nilesh, Minu and Anand on July 01, 2014 on BSE, which were allegedly in the form of circular trades, are depicted in the following table: Adjudication order in the matter of 20 Microns Ltd Date Seller Client Name Buyer Client Name Total Traded Qty. Total No. of Trades 01.07.2014 Nilesh A Doshi HUF Anand Honwadker 1500 2 01.07.2014 Minu Nileshkumar Doshi Anand Honwadker 1500 2 01.07.2014 Anand Honwadker Nileshkumar Amrutlal Doshi 1500 1 01.07.2014 Nileshkumar Amrutlal Doshi Anand Honwadker 1500 1 01.07.2014 Anand Honwadker Nilesh A Doshi HUF 1500 1 01.07.2014 Anand Honwadker Minu Nileshkumar Doshi 1500 1 (d) Pictorial representation of the above transactions carried out on July 01, 2014 on BSE are as follows: (e) Further, the transactions carried out by the above entities on July 02, 2014 on BSE are as follows: Date Seller Client Name Buyer Client Name Total Traded Qty. Total No. of Trades 02.07.2014 Anand Honwadker Nilesh A Doshi HUF 1500 2 02.07.2014 Anand Honwadker Minu Nileshkumar Doshi 1500 2 02.07.2014 Nilesh A Doshi HUF Anand Honwadker 1500 2 02.07.2014 Anand Honwadker Nileshkumar Amrutlal Doshi 1500 2 02.07.2014 Minu Nileshkumar Doshi Anand Honwadker 1500 2 02.07.2014 Nileshkumar Amrutlal Doshi Anand Honwadker 1500 1 (f) Pictorial representation of the above transactions carried out on July 02, 2014 on BSE are as follows: Adjudication order in the matter of 20 Microns Ltd (g) In view of all the transactions and sample trades given above, it is alleged that Noticee 1 to 9, by indulging in circular trades repeatedly during the investigation period, had created artificial/fictitious volume in the scrip of 20 Microns and gave a false and misleading appearance of trading in the scrip of the Company at BSE and NSE. The details of such trades amongst the Noticee 1 to 9, which are allegedly circular trades in nature, are placed as Annexure 14. It is also alleged that Noticee 1 to 9 contributed significantly to the market volume by executing reversal trades amongst themselves at BSE and NSE which resulted in creation of artificial volume in the market. Summary of the trades executed by the group, which are allegedly reversal trades in nature, are as under: BSE NSE Sum. of Reversal % of Reversal Qty to mkt. Vol. Sum of No. of Reversal Trades No. of days of reversal Trades Sum. of Reversal % of Reversal Qty to mkt. Vol. Sum of No. of Reversal Trades No. of days of reversal Trades 1527660 8.44 2721 306 1430347 6.52 2873 300 Adjudication order in the matter of 20 Microns Ltd (a) On analyzing the trades, it was observed that 5 entities of the group viz. Noticee 1 (Viking), Noticee 5 (Minu), Noticee 7 (Nilesh), Noticee 6 (Nilesh HUF) and Noticee 2 (Anand) entered into such trades, which were allegedly reversal trades, on more than one occasion and contributed around 1% of the market volume. Following table shows the entity-wise contribution by Noticee

1 (Viking), Noticee 5 (Minu), Noticee 7 (Nilesh), Noticee 6 (Nilesh HUF) and Noticee 2 (Anand) in such trades, which were allegedly reversal trades, at BSE and NSE: Client Name (A) Counterparty Client Name (B) No. of shares bought by client B from client No. of shares bought by client A from client Reversal Qty. % of reversal Qty to volume No. of Reversal trades No. of days of Reversal trades Viking Industries Private Limited Minu Nileshkumar Doshi 325437 340182 315912 1.7 472 171 Viking Industries Private Limited Nilesh A Doshi 279266 272956 260203 1.4 414 160 Viking Industries Private Limited Nileshkumar Amrutlal Doshi 256545 262332 236845 1.3 402 155 Nilesh A Doshi Honwadker Anand 234165 221250 217630 1.2 341 119 Minu Nileshkumar Doshi Honwadker Anand 233631 206800 204752 1.1 336 119 Nileshkumar Amrutlal Doshi Honwadker Anand 203450 199654 190624 1.1 322 118 Total of 5 entities 1532494 1503174 1425966 7.9 2287 Viking Industries Private Limited Minu Nileshkumar Doshi 292787 270286 267891 1.2 538 153 Viking Industries Private Limited Nileshkumar Amrutlal Doshi 244420 240113 219880 1.0 468 147 Viking Industries Private Limited Nilesh A Doshi 218207 221195 211229 1.0 421 130 Nilesh A Doshi Anand Honwadker 218238 214340 209998 1.0 373 119 Minu Nileshkumar Doshi Anand Honwadker 212044 211544 207157 0.9 414 125 Nileshkumar Amrutlal Doshi Anand Honwadker 197893 206892 196583 0.9 394 126 Total 1383589 1364370 1312738 6.0 2608 800 Adjudication order in the matter of 20 Microns Ltd (b) It is observed from above that the trades of Noticee 1 (Viking), Noticee 5 (Minu), Noticee 7 (Nilesh), Noticee 6 (Nilesh HUF) and Noticee 2 (Anand), which are allegedly reversal trades in nature, contributed 7.9% & 6% of the total market volume at BSE & NSE respectively out of 8.44% & 6.52% of total group contribution through such trades which are alleged to be reversal trades. (c) Therefore, it is alleged that the above 5 Noticees (viz. Noticee 1, 2, 5, 6 and

7) have entered into repetitive reversal of trades i.e., 2287 and 2608 reversal trades for 1425966 and 1312738 shares (i.e. 7.9% and 6% of the total market volume) on BSE and NSE. (d) In view of this, it is alleged that Noticee 1, 2, 5, 6 and 7, by executing reversal trades repeatedly amongst themselves at BSE and NSE, had created artificial/fictitious volume in the market and gave a false and misleading appearance of trading in the scrip at BSE and NSE. Details of all such trades which are alleged to be reversal trades in nature are placed at Annexure 15. In view of the above allegations of Circular and reversal trades, it is alleged that the Noticees 1 to 9 have violated the provisions of Regulations 3(a), (b), (c), (d), 4(1) and 4(2) (a) and (g) of PFUTP Regulations. Further, the aforesaid alleged violations of PFUTP Regulations by Noticees 1 to 9 as brought out above, if proved, make the Noticees liable for penalty under the provisions of Section 15HA of the SEBI Act. Self-Trades: Self-trades are trades in which both the buyer and the seller are the same entity and the same are executed without any intention of change of ownership of the traded shares. Self-trades create artificial/ fictitious volume in the market and give a false and misleading appearance of trading in the scrip at the exchange. Adjudication order in the matter of 20 Microns Ltd It is alleged that Noticee 1 had executed the following self-trades on BSE and NSE during the investigation period: Particulars BSE NSE Self- Trade Qty. No. of Self Trades No. of days % to mkt Self-Trade Qty. No. of Self Trades No. of days % to mkt vol Viking Industries Pvt. Ltd 52658 54 29 0.29 110836 109 37 0.50 In this regard, it is alleged that Noticee 1 had entered into substantial number of self-trades as well as percentage of shares traded through self-trades to market volume was of substantial quantity. Therefore, it is alleged that Noticee

1 had indulged in self-trades on BSE & NSE without intention of change of ownership and thereby created misleading appearance in trading. Extracts of the trade log for the above trades which are alleged to be self-trades are given in Annexure 16. As brought out in the earlier paras, it has already been alleged that Noticee 1 was also indulged in synchronised, circular and reversal of trades and created artificial/fictitious volume in the market and gave a false and misleading appearance of trading in the scrip at BSE and NSE. In view of that, it is alleged that there was a manipulative intent in the pattern of trades carried out by Noticee 1 which also included the above mentioned self-trades. In view of above, it is alleged that Noticee 1 has violated the provisions of Regulation 3 (a), (b), (c), (d) and 4 (1), 4 (2) (a) & (g) of PFUTP Regulations. The alleged violations of PFUTP Regulations by Noticee 1, if proved, makes it liable for monetary penalty under the provisions of Section 15HA of the SEBI Act. LTP analysis of trades during the investigation period on BSE: SEBI had also carried out an analysis of Last Trade Price (LTP) to ascertain whether any entity(ies) manipulated the price of the scrip of a company in contravention of the provisions of PFUTP Regulations. For the purpose of LTP Adjudication order in the matter of 20 Microns Ltd analysis, the investigation period was divided in 3 patches according to the price movement: (a) Price/volume of the scrip on BSE during the above mentioned three patches of the IP is given below: Patch Period Open High Low Close Volume Price (Rs.) Vol. Price (Rs.) Vol. Price (Rs.) Vol. Price (Rs.) Vol. Total Vol. Avg. Vol. (Price Fall) 01/07/2014 11/01/2015 36.9 78136 40 241686 26.5 13403 30.5 22478 8067139 63024 01/07/2014 09/07/2014 30/07/2014 01/12/2014 10/12/2014 09/01/2015 (Price Rise) 12/01/2015 15/01/2015 30.9 115977 47.6 337866 30.4 89311 45.8 89311 752708 188177 12/01/2015 15/01/2015 13/01/2015 12/01/2015 15/01/2015 15/01/2015 (Price Fall) 16/01/2015 31/10/2015

46 38629 46.1 670264 25 9401 29.85 388909 9261301 47251 16/01/2015 16/01/2015 14/10/2015 25/08/2015 18/05/2015 30/10/2015 Patch 1 July 01, 2014 to January 11, 2015 (Price fall): It is observed from the investigation report that during patch-1, the Noticees contributed Rs.-44.05 to net LTP and Rs.-114.1 to negative LTP which is 19.42% to market negative LTP. Details of the analysis of the trades carried out by the Noticees as sellers during this patch is as follows: Name All trades LTP Diff. >0 LTP Diff. < 0 LTP Diff. =0 % of negative LTP to Total Market negative of LTP diff traded No of trades Sum of LTP diff traded No of trades Sum of diff traded No of trades traded No of trades

1 Viking Industries Private Limited -30.15 1122795 1037 13.8 245079 127 -43.95 297534 233 580182 677 7.48

2 Anand Honwadker -26.75 923449 858 11.55 240399 94 -38.3 244462 218 438588 546 6.52

3 Bhavana Pareshkumar Bhatt -2.75 470786 325 2.5 89497 26 -5.25 112282 42 269007 257 0.89

4 Rohit Kiritkumar Hiralal -2.65 503315 322 2.75 108653 28 -5.4 97306 46 297356 248 0.92

5 Leena Jigneshkumar Shah -1.55 240205 81 0.95 44131 6 -2.5 13855 13 182219 62 0.43

6 Jigneshkumar I. Shah -0.55 200009 94 1.4 56096 12 -1.95 44264 20 99649 62 0.33

7 Minu Nileshkumar Doshi -0.55 236001 166 5.6 59828 39 -6.15 65950 43 110223 84 1.05 Adjudication order in the matter of 20 Microns Ltd

8 Nileshkumar Amrutlal Doshi 3.85 216800 175 7.3 44893 31 -3.45 56998 38 114909 106 0.59

9 Nilesh A Doshi HUF 17.05 245903 170 24.2 127941 82 -7.15 48842 36 69120 52 1.21 Total -44.05 4159263 3228 70.05 1016517 445 -114.1 981493 689 2161253 2094 19.42 Market Total -6.4 8067139 21190 581.25 2006777 4038 -587.6 1980235 4352 4080127 12800 (a) It is observed that the trades carried out by Noticee 1 (Viking) contributed Rs. -43.95 to negative LTP (i.e. 7.48% to market negative LTP) through 233 trades. It was further observed that the counterparty entities in 143 of those

233 trades were other Noticees (viz. Nilesh HUF, Viking, Anand, Minu, Nilesh, Rohit, Jignesh, Leena and Bhavana) which contributed Rs. -28 to negative LTP (i.e. 4.76% to market negative LTP). (b) Further, the trades carried out by Noticee 2 (Anand) contributed Rs. -38.3 to negative LTP (i.e. 6.52% to market negative LTP) through 218 trades. Counterparty entities to 96 of those 218 trades were observed to be the Noticees (viz.,Nilesh HUF, Viking, Anand, Minu, Nilesh, Rohit, Jignesh, Leena and Bhavana) which contributed Rs. -20.2 to negative LTP (i.e. 3.44% to market negative LTP). In view of the above analysis, it is alleged that the trades carried out by Noticee

1 (Viking) and Noticee 2 (Anand) with other entities of the Group as counterparty entities (viz. Nilesh HUF, Viking, Anand, Minu, Nilesh, Rohit, Jignesh, Leena and Bhavana) together contributed to the price fall during Patch 1. Therefore, it is alleged that, by executing such trades, the connected counterparties viz. the Noticees matched the price of prevailing buy/ sell orders which were placed at a price lower than the LTP and thus contributed to the price fall with each of their trades. Patch 3 January 16, 2015 to October 31, 2015 (price fall): During the patch-3 wherein a price fall in the scrip of the Company was noticed, 10 entities of the group contributed Rs. -96.9 to net LTP and Rs. - 270.4 to negative LTP which is 25.59% to market negative LTP. Details of the analysis of trades carried out by the entities of the group during this patch is as follows: Adjudication order in the matter of 20 Microns Ltd Name All trades LTP Diff. >0 LTP Diff. < 0 LTP Diff. =0 % of negative LTP to Total Market negative Sum of diff traded No of trades of LTP diff traded No of trades Sum of LTP diff traded No of trades traded No of trades

1 Viking Industries Private Limited -68.15 1168299 2152 53.6 207320 476 -121.75 318779 502 642200 1174 11.52

2 Honwadker Anand -39.35 855684 945 23.2 223138 171 -62.55 270965 320 361581 454 5.92

3 Rohit Kiritkumar Hiralal -7.2 563587 373 12.7 173732 63 -19.9 189191 130 200664 180 1.88

4 Jigneshkumar Indravadanbhai Shah -5.3 217593 129 1.05 45772 12 -6.35 44080 36 127741 81 0.6

5 Bhavana Pareshkumar Bhatt -1.65 543304 307 9.7 170746 61 -11.35 122173 59 250385 187 1.07

6 Shishir Jayantilal Khandwala -0.8 18800 5 0.3 12500 1 -1.1 2750 2 3550 2 0.1

7 Minu Nileshkumar Doshi -0.25 473708 387 19 112803 64 -19.25 185562 148 175343 175 1.82

8 Leena Jigneshkumar Shah 0.1 117742 70 2.05 31549 13 -1.95 34298 14 51895 43 0.18

9 Nilesh A Doshi Huf 2.9 394568 277 14.2 92951 59 -11.3 176419 102 125198 116 1.07

10 Nileshkumar Amrutlal Doshi 22.8 376952 308 37.7 182547 109 -14.9 88412 69 105993 130 1.41 Total -96.9 4730237 4953 173.50 1253058 1029 -270.4 1432629 1382 2044550 2542 25.59 Market Total -16.15 9261301 29743 1040.8 2378682 5909 -1056.75 2553564 7072 4329055 16762 From the analysis of the above trades, the following was observed: (a) The trades carried out by Noticee 1 (Viking) contributed Rs. -121.75 to negative LTP (i.e. 11.52% to market negative LTP) through 502 trades. Further, the counterparty entities to 171 trades out of those 502 trades were observed to be suspected entities of the group (viz., Nilesh HUF, Viking, Anand, Minu, Nilesh, Rohit, Jignesh, Leena & Bhavana) which contributed Rs.-55.5 to negative LTP (i.e. 5.25% to market negative LTP). (b) Trades carried out by Noticee 2 (Anand) contributed Rs. -62.55 to negative LTP (i.e. 5.92% to market negative LTP) through 320 trades. Further, the counterparty entities in 138 trades out of those 320 trades were observed to be suspected entities of the group (viz.,Nilesh HUF, Viking, Anand, Minu, Nilesh, Rohit, Jignesh, Leena & Bhavana) which contributed Rs. -39.6 to negative LTP (i.e. 3.75% to market negative LTP). In view of the above analysis, it is alleged that the trades carried out by Noticee

1 (Viking) and Noticee 2 (Anand) with Noticees (viz.,Nilesh HUF, Viking, Adjudication order in the matter of 20 Microns Ltd Anand, Minu, Nilesh, Rohit, Jignesh, Leena & Bhavana) together contributed to the price fall during Patch 3. In this regard, it is further alleged that, by executing such trades, the Noticees matched the price of prevailing buy/sell orders which were placed at a price lower than the LTP and thus contributed to the price fall during Patch 3. LTP analysis of trades during the investigation period on NSE: Price/volume data related to the scrip of 20 Microns, during the above mentioned three patches of the IP, is given below: Patch Period Open High Low Close Volume Price (Rs.) Vol. Price (Rs.) Vol. Price (Rs.) Vol. Price (Rs.) Vol. Total Vol. Avg. Vol. (Price Fall) 01/07/2014 11/01/2015 (Price Fall) 36.5 115064 36.95 265657 27.8 14082 30.6 20967 8946758 69896 01/07/2014 01/07/2014 28/08/2014 17/12/2014 03/07/2014 09/01/2015 (Price Rise) 12/01/2015 15/01/2015 (Price rise) 30.75 255207 47.5 792926 30.35 103198 45.9 103198 1471293 367823 12/01/2015 15/01/2015 13/01/2015 12/01/2015 15/01/2015 15/01/2015 (Price Fall) 16/01/2015 31/10/2015 (Price Fall) 46.6 57398 46.6 706206 24.5 10373 30.2 706206 11534138 58847 16/01/2015 16/01/2015 30/10/2015 23/09/2015 16/03/2015 30/10/2015 Patch 1 July 01, 2014 to January 11, 2015 (Price fall): During the patch-1, the Noticees contributed Rs. -35.2 to net LTP and Rs. - 93.25 to negative LTP, which is 11.92% to market negative LTP. Details of the analysis of trades carried out by the Noticees as sellers during this patch is as follows: Adjudication order in the matter of 20 Microns Ltd Name All trades LTP Diff. >0 LTP Diff. < 0 LTP Diff. =0 % of negative LTP to Total Market negative Sum of diff traded No of trade Sum of diff traded No of trade Sum of diff traded No of trades traded No of trade

1 Viking Industries Private Limited -26.1 1252206 1531 11.15 195444 135 -37.25 260912 272 795850 1124 4.76

2 Honwadker Anand Trambakrao -22.3 910332 1431 12.95 184533 130 -35.25 209819 252 515980 1049 4.5

3 Bhatt Bhavana Pareshkumar -1.45 510247 297 2.1 129464 35 -3.55 124648 32 256135 230 0.45

4 Jigneshkumar Indravadanbhai Shah -1.15 206917 161 0.95 46293 14 -2.1 37932 31 122692 116 0.27

5 Leena Jigneshkumar Shah -0.6 242400 132 1.05 51070 13 -1.65 59942 22 131388 97 0.21

6 H Rohit Kiritkumar -0.4 423460 241 2 87515 27 -2.4 109782 25 226163 189 0.31

7 Nileshkumar Amrutlal Doshi 0.3 187100 188 3.8 28395 29 -3.5 43407 34 115298 125 0.45

8 Minu Nileshkumar Doshi 0.95 221874 246 5.95 61694 50 -5 50908 41 109272 155 0.64

9 Nilesh A Doshi(HUF) 15.55 216361 199 18.1 108427 86 -2.55 43346 31 64588 82 0.33 Total -35.2 4170897 4426 58.05 892835 519 -93.25 940696 740 2337366 3167 11.92 Market Total -5.9 8946758 57072 776.85 1583787 6474 -782.75 1737759 6942 5625212 43656 (a) The trades carried out by Noticee 1 (Viking) contributed Rs. -37.25 to negative LTP (i.e. 4.76% to market negative LTP) through 272 trades. Further, the counterparty entities in 131 trades out of those 272 trades were observed to be the Noticees (viz. Nilesh HUF, Viking, Anand, Minu, Nilesh, Rohit, Jignesh, Leena & Bhavana), which contributed Rs. -17.2 to negative LTP (i.e. 2.20% to market negative LTP). (b) Trades carried out by Noticee 2 (Anand) contributed Rs. -35.25 to negative LTP (i.e. 4.5% to market negative LTP) through 252 trades. Out of these 252 trades, counterparty entities in 89 trades were observed to be the Noticees (viz.,Nilesh HUF, Viking, Anand, Minu, Nilesh, Rohit, Jignesh, Leena and Bhavana) which contributed Rs. -13 to negative LTP (i.e. 1.66% to market negative LTP). Patch 3 January 16, 2015 to October 31, 2015 (price fall): During the patch-3, 10 suspected entities of the group contributed Rs. -79.75 to net LTP and Rs. -199.25 to negative LTP, which is 11.33% to market Adjudication order in the matter of 20 Microns Ltd negative LTP. Details of the analysis of trades carried out by the said entities of the group as sellers during this patch are as follows: Name All trades LTP Diff. >0 LTP Diff. < 0 LTP Diff. =0 % of negative LTP to Total Market negative diff traded No of trades Sum of LTP diff traded No of trades Sum of LTP diff traded No of trades traded No of trades

1 Anand Honwadker -47.2 1054918 1950 20.2 182873 235 -67.4 231678 549 640367 1166 3.83

2 Viking Industries Private Limited -38.5 941320 1996 35.05 197868 356 -73.55 246976 413 496476 1227 4.18

3 Kiritkumar Hiralal Rohit -6 257831 283 4.45 37408 36 -10.45 56177 82 164246 165 0.6

4 Jigneshkumar Indravadanbhai Shah -2.7 316540 205 3 80829 27 -5.7 131870 65 103841 113 0.32

5 Bhavana P Bhatt -0.45 366635 251 6.5 88012 49 -6.95 91205 54 187418 148 0.4

6 Nilesh A Doshi(Huf) -0.1 342641 416 10.1 90332 75 -10.2 114054 106 138255 235 0.58

7 Khandwala Shishir Jayantilal 0.15 13700 5 0.2 1250 1 -0.05 1165 1 11285 3 0

8 Leena Jigneshkumar Shah 0.55 199100 117 2.8 59852 22 -2.25 58212 21 81036 74 0.13

9 Minu Nileshkumar Doshi 4.1 412522 579 15.3 86009 90 -11.2 141899 130 184614 359 0.64

10 Nileshkumar Amrutlal Doshi 10.4 367609 462 21.9 132960 112 -11.5 102630 93 132019 257 0.65 Total -79.75 4272816 6264 119.5 957393 1003 -199.25 1175866 1514 2139557 3747 11.33 Market Total -16.4 11534138 62003 1743.2 2278085 11626 -1759.6 2691944 13699 6564109 36679 (a) Trades carried out by Noticee 2 (Anand) contributed Rs. -67.4 to negative LTP (i.e. 3.83% to market negative LTP) through 549 trades. Further, out of those

549 trades, the counterparty entities to 158 trades were observed to be other Noticees (viz. Nilesh HUF, Viking, Minu, Nilesh, Rohit, Jignesh, Leena and Bhavana). These 158 trades contributed Rs. -16.6 to negative LTP (i.e. 0.94% to market negative LTP). (b) Trades carried out by Noticee 1 (Viking) contributed Rs. -73.55 to negative LTP (i.e. 4.18% to market negative LTP) through 413 trades. Out of those 413 trades, the counterparty entities to 152 trades were observed to be the Noticees (viz. Nilesh HUF, Viking, Anand, Minu, Nilesh, Rohit, Jignesh, Leena Adjudication order in the matter of 20 Microns Ltd and Bhavana) which contributed Rs. -23.4 to negative LTP (i.e. 1.33% to market negative LTP). In view of the above LTP analysis of trades by the group entities on BSE & NSE, it is alleged that the trades carried out by Noticee 1 (Viking) and Noticee

2 (Anand) with the Noticees as counterparty entities (viz. Nilesh HUF, Viking, Anand, Minu, Nilesh, Rohit, Jignesh, Leena and Bhavana) together contributed significantly to the price fall during Patch 1 & Patch 3. The Percentage of LTP contribution by Noticee 1 (Viking) & Noticee 2 (Anand) with the Noticees as counterparty entities in Patch 1 & Patch 3 on BSE & NSE is given below: Name of the entity BSE (in%) NSE (in%) Patch 1 Patch 3 Patch 1 Patch 3 Viking Industries Ltd. 4.76 5.25 2.20 1.33 Anand Honwadker 3.44 3.75 1.66 0.94 By executing such trades, it is alleged that Noticee 1 (Viking) and Noticee 2 (Anand) with other Noticees as counterparty entities (viz. Nilesh HUF, Viking, Anand, Minu, Nilesh, Rohit, Jignesh, Leena and Bhavana) together created a misleading appearance of trading in the scrip and manipulated the scrip price. In view of the same, it is alleged that the Noticees 1 to 9 have violated the provisions of Regulations 3 (a), (b), (c), (d) and 4 (1), 4(2)(a) & (e) of PFUTP Regulations. It is also observed from the investigation report that SEBI had initiated adjudication proceedings in the past against Noticee 1 (Viking) in respect of its dealings in the scrip of 20 Microns.

4. The details of delivery of SCNs and further communication with Noticees are as follows: 4.1. Viking Industries Pvt Ltd The common SCN was served on the Noticee via Speed Post with Acknowledgement Due (SPAD). The Acknowledgement receipt duly signed Adjudication order in the matter of 20 Microns Ltd by Noticee is on record. Vide letter dated May 09, 2019, Noticee requested for extension of time for submitting reply to the SCN. Vide letter dated May 17, 2019, Noticee was granted time till June 10, 2019 to submit reply to the SCN and was granted an opportunity of personal hearing on June 17, 2019. Vide letters dated June 13 and June 14, 2021, Noticee submitted the following: It denied all the allegations made in the SCN No grievance by any investor, broker etc was registered against the Noticee in the matter. The SCN has been issued after a delay of more than 4 years which has caused prejudice to Noticee. Noticee requested for inspection of certain documents in the matter. Noticee requested for additional time for submitting reply to the SCN and also for adjournment of personal hearing in the matter scheduled on June 17, 2019. Vide letter dated June 19, 2019, Noticee was intimated that its request for inspection of documents was forwarded to Enforcement Department of SEBI. Vide letter dated June 29, 2019, Noticee intimated appointment of Prakash Shah & Associated as Authorized Representatives in the matter. Vide letter dated September 24, 2019, Noticee intimated that vide inspection dated September 24, 2019, it inspected all the documents provided as Annexures to the SCN and also requested for inspection of certain additional documents as regards the matter. Vide letter dated October 10, 2019, Noticee was intimated that inspection of documents was provided to it by Enforcement Department of SEBI, and Noticee was granted opportunity of personal hearing on November 04, 2019. Vide letter dated October 30, 2019, Noticee again reiterated its request for inspection of additional documents as requested vide its letter dated September 24, 2019 and further, requested for adjournment of personal hearing in the matter. Vide email dated November 01, 2019, Noticee was intimated that personal hearing dated November 04, 2019 in the matter was postponed till further notice. Vide letter dated December 02, 2019 and email dated December 04, Adjudication order in the matter of 20 Microns Ltd 2019, Noticee was informed that inspection of documents relied upon in the SCN was already provided to the Noticee and further, was granted opportunity of personal hearing on December 12, 2019. Vide letter dated December 07, 2019, Notice reiterated its request for inspection of certain additional documents in the matter and requested for postponement of personal hearing scheduled on December 12, 2019. Vide letter and email dated January 17, 2020, Noticee was intimated that copies of documents relied upon in the SCN were already provided to it Annexures to the SCN and had been inspected by the Noticee. Further, Noticee was granted final opportunity of personal hearing on January 24, 2020 and was informed that in case of absence at hearing, matter will be proceeded upon based on material available on record. However, Noticee did not attend the personal hearing scheduled in the matter. Vide letter dated June 02, 2021 Noticee submitted the following: Noticee had requested for certain additional documents which were not provided to it. SCN is based on surmised, conjectures, probabilities and hypothesis. Noticee did not received any query from any entity connected to its transactions in the scrip. Noticees transactions were independent and carried out in isolation to transactions carried out by other entities in the scrip of 20 Microns. No alert was generated by any regulatory authority when the scrip was being traded in the market. Connections alleged The mobile number and email IDs attributed to Noticee in the SCN do not belong to it. Financial transactions with other entities were in the course of business. Financial transaction with Minu Doshi was in nature of rent paid by Noticee. Off market transfer of shares to Shishir Jayantilal Khandwala was in nature of loan given by Noticee which was subsequently returned. Adjudication order in the matter of 20 Microns Ltd Trading decisions were taken on the basis of news and rumors only The trades of Noticee matched with other allegedly connected entities by coincidence. Transactions were executed on autonomous screen based trading system. Value and volume of alleged impugned trades, as regards allegation of synchronized trades, circular trades, reversal trades and self-trades was insignificant to total volume in scrip during IP. Reversal trades resulted by coincidence as on many days Noticee did intraday trading. As regards alleged LTP trades, none of the trades resulted in new high or new low price. Further, complete date with respect to LTP violations was not given in the SCN. For establishing fraud, compelling evidence should be brought on record. 4.2. Anand Honwadkar The common SCN dated April 16, 2019 was served on the Noticee via Speed Post with Acknowledgement Due (SPAD). Vide letter dated June 12, 2019, Noticee requested for additional time for submitting reply to the SCN. Vide letter dated June 19, 2019, Noticee was granted time till July 01, 2019 to submit reply to the SCN and was granted opportunity of personal hearing on July 10, 2019. Vide letter dated June 29, 2019, Noticee further requested for additional time for submitting reply to the SCN and requested for data/ details relevant to the Noticee as regards the SCN. Vide letter dated September 18, 2019, Noticee was informed that all relevant data has already been provided to the Noticee and further, Noticee was granted opportunity of personal hearing in the matter on October 07, 2019. Vide letter dated October 03, 2019, Noticee submitted the following: Noticees broker did not caution it as regards any fraudulent activity carried out in the scrip of 20 Microns. Adjudication order in the matter of 20 Microns Ltd Noticee never indulged in synchronized trades, reversal trades, circular trades or LTP trades. Noticee did not attend the personal hearing scheduled on October 07, 2021. Vide letter dated May 25, 2021, Noticee submitted the following: The impugned trades carried out by Noticee were insignificant compared to total market volume in the IP. Complete data with regard to LTP violations is not provided in the SCN. Noticee carried out trades in scrip of 20 Microns at a price which was already determined on the stock exchange platform. Noticee did not have information about the counterparty while executing the trades. There was no major change in price of scrip of 20 Microns during the Connections alleged: The mobile number and one of the email IDs attributed to Noticee in the SCN does not belong to it. Noticee had no idea how his email ID anand.honwadker@yahoo.in was used by Jignesh Shah. Noticee sold 28,000 shares in off market to Jignesh Shah on advice of its dealer, for which it received consideration. 4.3. Rohit Kiritkumar H. The common SCN was served on the Noticee via SPAD. The acknowledgement receipt duly signed by the Noticee is on record. Vide letter dated May 09, 2019, Noticee requested for additional time for submitting reply to the SCN. Vide letter dated May 17, 2019, Noticee was granted time till June 10, 2019 to submit reply to the SCN and was granted opportunity of personal hearing on June 17, 2019. Vide letter dated June 14, 2019, Noticee further requested for additional time for submitting reply to the SCN. Vide letter dated September 18, 2019, Noticee was granted another opportunity of personal hearing on October 07, 2019. Vide letter dated October 03, 2019, Noticee Adjudication order in the matter of 20 Microns Ltd intimated that he was not aware of any manipulation in the scrip of 20 Microns going on in the market. Noticee further stated that the data provided with the SCN contains details of all the people who trades in the scrip, and sought details of only his trades which were alleged to be manipulative. Vide letter dated May 31, 2015, Noticee made submissions as regards the SCN. The main contentions therein are summarized below. Further, the contentions which are common to that raised by Noticees in preceding paragraphs are not being reiterated for the sake of brevity: The LTP contributed by Noticee was insignificant vis--vis total market LTP. Connections alleged: Noticee denied the mobile number and email ID attributed to him in the SCN. Noticee does not know Bhavana Bhatt as alleged in the SCN, and purchased shares from her on advice of a friend. 4.4. Bhavana P. Bhatt The common SCN was served on the Noticee via SPAD. The acknowledgement receipt duly signed by Noticee is on record. Vide letter dated May 09, 2021, Noticee requested for additional time for submitting reply to the SCN. Vide letter dated May 17, 2019, Noticee was granted time till June 10, 2019 to submit reply to the SCN and was granted opportunity of personal hearing on June 17, 2019. Said hearing notice could not be delivered to the Noticee via SPAD. Vide letter dated June 13, 2019, Noticee further requested for additional time for submitting reply to the SCN. Vide letter dated June 19, 2019, Noticee was granted time till July 05, 2019 to submit reply to the SCN and was granted opportunity of personal hearing on July 10, 2019. Vide letter dated July 02, 2019, Noticee requested for documents pertaining specifically to her in the matter and also requested for adjournment of personal hearing scheduled on July 10, 2019. Vide letter dated September 18, 2019 Noticee was informed that though she had requested for data/details relevant to her in the matter, same had been already provided to her along with the Adjudication order in the matter of 20 Microns Ltd SCN. Further, vide aforesaid letter, Noticee was granted opportunity of personal hearing on October 07, 2019. Vide letter dated October 04, 2019, Noticee reiterated her request to provide details of trades pertaining to her alleged to be manipulative. Vide letter dated May 27, 2015, Noticee made submissions as regards the SCN. The main contentions therein are summarized below. Further, the contentions which are common to that raised by Noticees in preceding paragraphs are not being reiterated for the sake of brevity: Noticee had not received any query or enquiry from any entity and no alert was generated by any agency, including the Stock Exchanges, before the receipt of impugned SCN from SEBI. Noticee does not know meaning of words mentioned in the SCN. Noticee traded in the scrip of 20 Microns on advice of other persons. Noticee does not have any relation with the counterparties to her trades. Connections alleged: Except email ID viz. bhavanabhatt@64@yahoo.in, none of the email ID/ mobile number mentioned in the SCN belong to her. Noticee had borrowed funds from Viking Industries Pvt Ltd due to personal emergency. Noticee transferred shares to Rohit Kiritkumar H. only on advice of certain dealer. 4.5. Jignesh I. Shah and Leena J. Shah The common SCN was served on the Noticees via SPAD. The acknowledgement receipts duly signed by Noticees are on record. Vide letter dated May 17, 2019 by Jignesh I. Shah and letter dated May 09, 2019 by Leena J. Shah, they requested for additional time for submitting reply to the SCN. Vide letters dated May 17, 2019, Noticees were granted time till June 10, 2019 to submit reply to the SCN and were granted opportunity of personal hearing on June 17, 2019. Vide letters dated June 14, 2019, Noticees further Adjudication order in the matter of 20 Microns Ltd requested for additional time for submitting reply to the SCN. Vide letter dated June 19, 2019, Noticees were granted time till July 05, 2019 to submit reply to the SCN and were granted opportunity of personal hearing on July 10, 2019. Vide letter dated June 29, 2019, Leena J. Shah requested for additional time for submitting reply to the SCN. Vide letters dated September 18, 2021, Noticees were granted final opportunity of hearing on October 07, 2019. Vide letters dated October 05, 2019, Noticees contended that they did not understand meaning of terms in the SCN, and requested for exact details of trades alleged to be manipulative. Vide letter dated May 25, 2015, Noticees made submissions as regards the SCN. The main contentions therein are summarized below. Further, the contentions which are common to that raised by Noticees in preceding paragraphs are not being reiterated for the sake of brevity: Noticees bought and sold shares on only few days in the IP. Jignesh I. Shah, for instance, bought shares only on 22 days on BSE/ 24 days on NSE and sold shares on 32 days on BSE/ 29 days on NSE out of 328 trading days in the IP, and also, his transactions were not concentrated but spread over 16 months. Similarly, alleged synchronized, circular, reversal and LTP trades were carried out on small number of days. Connections alleged: Email IDs and mobile number attributed to Noticees do not belong to them, except jigneshshah286@gmail.com which belonged to Jignesh I. Shah. Financial transactions with Viking Industries Pvt Ltd and Sudhir R Parikh were in the form of amounts borrowed for personal reasons. Off market transfer of shares with Anand Honwadkar by Jignesh I. Shah were undertaken on advice of his dealer. 4.6. Nilesh A. Doshi HUF, Nilesh A. Doshi and Minu Nileshkumar Doshi The common SCN was served on the Noticees via SPAD. Vide letters dated June 19, 2019, Noticees were granted time till July 05, 2019 to submit reply to Adjudication order in the matter of 20 Microns Ltd the SCN and were granted opportunity of personal hearing on July 10, 2019. Vide common letter dated June 27, 2019, Noticees submitted the following: Noticees had not received SCN in the matter. Noticee also sought certain additional documents interalia including copy of appointment letter wherein Whole Time Member of SEBI had been appointed to form an opinion as regards adjudication proceedings in the present case, opinion report of Adjudication Officer indicating that enquiry should be held against the Noticees. Vide letter dated September 18, 2019, Noticees were intimated that as per the records SCN had been duly delivered to them. Nonetheless, a copy of SCN along with the Annexures was being provided to the Noticee along with the hearing notice. Further, vide aforesaid letter, Noticee was granted opportunity of personal hearing on October 07, 2019. Vide letters dated October 01, 2019, Noticees submitted the following: SCN was issued to the Noticees after a delay of 5 years which had caused prejudice to them. Noticees dealt in the scrip in a fair manner, and no grievance was raised by any investor, broker etc. Noticees carried out only small volume of trades which were within the circuit filter prescribed by the Stock Exchange. The alleged manipulative trades carried out by Noticees were insignificant compared to total trades carried out during the IP. Noticee also requested for exact details of their manipulative trades. Noticees requested for inspection of documents relied upon in the matter. Vide letter dated October 10, 2019, Noticees were intimated that their request for inspection of documents had been forwarded to Enforcement Department of SEBI. Vide email dated September 21, 2020, it was informed by the Enforcement Department that inspection in the matter was completed vide email dated September 21, 2020 to the Noticees, on account of prevailing COVID pandemic. Adjudication order in the matter of 20 Microns Ltd Vide email dated October 08, 2020, Noticees were informed that inspection of documents in the matter was complete and Noticees were further granted opportunity of personal hearing on October 19, 2020. Vide email dated October 17, 2020, Noticees contended that inspection in the matter was not complete and requested for another opportunity of inspection after the constraints due to COVID pandemic eased. Further, Noticees requested for postponement of personal hearing scheduled on October 19, 2020. Vide emails dated October 22, 2020 and December 01, 2020, Enforcement Department of SEBI was requested to ascertain whether inspection of documents in the matter was complete. Vide email dated January 19, 2021, Enforcement Department intimated that inspection of documents in the matter was completed on January 18, 2021, and the minutes therefor were on record. Noticees vide letter dated January 19, 2021, addressed to Enforcement Department, stated that data as regards reversal trades of Noticees were not provided and requested for copy of complaint regarding price rigging in the matter. Vide email dated February 26, 2021, Noticees were informed that inspection of documents was complete as per the records. Further, Noticees were intimated in response to their letter dated January 19, 2021 to Enforcement Department that data regarding reversal trades of Noticees, was provided as Annexure 17 to the SCN (NSE trade log), and that no complaint as contended by Noticees was relied upon in the SCN. Further, vide aforesaid email, Noticees were granted opportunity of personal hearing on March 10, 2021. Vide email dated March 06, 2021, Noticees submitted reply to the SCN. The contentions mentioned therein were along the same lines as made by other Noticees and as stated in the preceding paragraphs. Therefore, they are not being repeated for the sake of brevity. Vide email dated March 10, 2021, AR of the Noticees requested for postponement of personal hearing in the matter. Vide email dated March 10, 2021, request of the AR was acceded to and another opportunity of personal Adjudication order in the matter of 20 Microns Ltd hearing was granted to AR on March 12, 2021. Personal hearing in the matter was conducted on March 12, 2021. AR reiterated the submissions made by the Noticees vide letters dated October 01, 2019 and March 06, 2021. Further, AR acknowledged receipt of copies of all documents sought by Noticees and inspection availed of in the matter. Also, acceding to request made by AR, time till March 31, 2021 was granted to make post hearing submissions in the matter. Vide emails dated April 01, 2021 and April 16, 2021, AR requested for additional time for making post hearing submissions. Vide email dated May 08, 2021 and letter dated May 07, 2021, AR made post hearing submissions, which are summarized below. Further, the contentions which are common to that raised by Noticees in preceding paragraphs are not being reiterated for the sake of brevity: The price movement in the scrip of 20 Microns was consistent before, during and after the IP. Sum of LTP contributed in Patch 1 and 2 of the IP is positive, so that it cannot be alleged that their trading in the scrip contributed to price fall. Negative LTP contributed in Patch 2 by Nilesh Doshi and Nilesh Doshi Huf, and in Patch 1 by Minu Nileshkumar Doshi is negligible. CONSIDERATION OF ISSUES AND FINDINGS

5. Considering the findings of Investigation, the allegations made out in the SCN and the submissions made by the Noticees, I find that following issues require consideration in the present case: (a) Whether the Noticees are connected entities and whether trades carried out by them in IP have resulted in violation of the provisions of Regulation 3(a)(b)(c)(d), 4(1), 4(2)(a) and 4(2)(g) of the PFUTP Regulations, 2003? (b) Whether the trades carried out by Noticees in IP have resulted in violation of the provisions of Regulation 3(a)(b)(c)(d), 4(1), 4(2)(a) and 4(2)(e) of the PFUTP Regulations, 2003? Adjudication order in the matter of 20 Microns Ltd (c) Do the violations, if any, attract penalty under Section 15HA of the SEBI Act, 1992? (d) If so, what would be the monetary penalty that can be imposed taking into consideration the factors mentioned in Section 15J of SEBI Act, 1992?

6. The relevant extracts of the provisions of law, allegedly violated by the Noticees, are mentioned as under: PFUTP Regulations, 2003

3. Prohibition of certain dealings in securities 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; (e) any act or omission amounting to manipulation of the price of a security; (g) entering into a transaction in securities without intention of performing it or without intention of change of ownership of such security Adjudication order in the matter of 20 Microns Ltd Now I proceed to examine the issues raised above. Issue (a) Whether the Noticees are connected entities and whether trades carried out by them in IP have resulted in violation of the provisions of Regulation 3(a)(b)(c)(d), 4(1), 4(2)(a) and 4(2)(g) of the PFUTP Regulations, 2003?

7. I note that SEBI interalia received a complaint alleging price rigging by an entity in the scrip of 20 Microns. Thereafter, SEBI conducted investigation for the period of July 01, 2014 to October 31, 2015 as regards interalia manipulation of the scrip price of 20 Microns. The details of price volume data in the scrip of 20 Microns during IP on BSE is as follows: Period Dates Opening Price (volume) on first day of the period (Rs) Closing price (volume) on last day of the period (Rs.) price(volum

e) during the period (Rs.) High Price(volum

e) during the period (Rs.) Total no. of shares traded during the period (avg. daily vol.) Before Investigation period 01/04/2014 - 30/06/2014 Price 31.5 36.2 30.45 42 5359192 (89319) Date 01/04/14 30/06/14 09/04/14 10/06/14 Vol 67166 63560 14554 383372 Date 01/04/14 30/06/14 07/04/14 15/04/14 During Investigation Period 01/07/2014 - 31/10/2015 Price 36.9 29.85 25 47.6 18081148 (55125) Date 01/07/14 30/10/15 28/09/15 15/01/15 Vol 78136 388909 9401 670264 Date 01/07/14 30/10/15 18/05/15 14/10/15 After investigation period (01/11/2015 - 31/01/2016) Price 29.85 27.1 25.3 39 3088696 (50634) Date 02/11/15 29/01/16 21/01/15 12/01/16 Vol 163434 18013 659 234517 Date 02/11/15 29/01/16 27/11/15 30/12/15

8. Further, details of price volume data in the scrip of 20 Microns on NSE is as follows: Period Dates Opening Price (volume) on first day of the period (Rs) Closing price (volume) on last day of the period (Rs.) Low price (volume) during the period (Rs.) High Price (volume) during the period (Rs.) No. of shares traded daily during the period (avg.) Before Investigation period 01/04/2014 - 30/06/2014 Price 31.8 36.3 30.45 42 6651491 (110858) Date 01/04/14 30/06/14 16/04/14 26/06/14 Vol 76530 80306 29888 490250 Date 01/04/14 30/06/14 02/06/14 23/04/14 During Investigation Period 01/07/2014 - 31/10/2015 Price 36 30.2 24.5 47.5 21952189 (66927) Date 01/07/14 30/10/15 23/09/15 15/01/15 Vol 115064 706206 10373 792926 Adjudication order in the matter of 20 Microns Ltd Date 01/07/14 30/10/15 16/03/15 13/01/15 After investigation period (01/11/2015 - 31/01/2016) Price 29.3 27.3 39.3 39 7277057 (119296) Date 02/11/15 29/01/16 12/01/16 12/01/16 Vol 209622 16716 7570 784559 Date 02/11/15 29/01/16 11/11/15 30/12/15

9. It is alleged that Noticees were connected to each other interalia on the basis of common email IDs, phone numbers, off market transfers etc, and further that, by carrying out synchronized trades, circular trades, reversal trades and self trades, they contributed to artificial/ fictitious volume in the market and gave a false and misleading appearance of trading in the scrip of 20 Microns at BSE and NSE, allegedly violating Regulations 3(a), (b), (c), (d) and 4(1)(a) and (g) of the PFUTP Regulations, 2003.

10. Noticees have interalia contended that the SCN was issued after an inordinate delay, which caused prejudice to them. I note that there are no timelines prescribed in the SEBI Act, 1992 for initiating the adjudication proceedings. Further, I note that the Honble SAT in the matter of Pooja Vinay Jain vs SEBI held that, The record would show that all the documents concerning the defense of the appellant were filed by her before the AO. Therefore, for want of any prejudice the proceedings cannot be quashed simply on the ground of delay in launching the same I also note that the Honble SAT in the matter of Bipin R Vora vs SEBI held that, As regards the plea of delay and latches and submission that the show cause notice is barred by limitation, I do not find any merit in these contentions as the time and efforts involved in an investigation though may vary from case to case, generally investigations per-se is a time consuming process which invariably involve collection, scrutiny and careful examination of voluminous records/ order- trade details of all the concerned including the exchanges/recording of statements etc. and therefore no time limit can be fixed in this regard to enable a regulator to take appropriate disciplinary action for the safeguard and improvement of the system/market. Therefore, I note that contentions of Noticees in this regard are without merits. Adjudication order in the matter of 20 Microns Ltd

11. Noticees have also contended that the complete data as regards violations alleged in the SCN were not provided to them. I note that the documents relied upon in the SCN were provided to Noticees as Annexures to the SCN. In this regard, I note that the Honble SAT, in its order dated February 12, 2020, in the matter of Shruti Vora vs. SEBI held that "A bare reading of the provisions of the Act and the Rules as referred to above do not provide supply of documents upon which no reliance has been placed by the AO, nor even the principles of natural justice require supply of such documents which has not been relied upon by the AO. We are of the opinion that we cannot compel the AO to deviate from the prescribed procedure and supply of such documents which is not warranted in law. In our view, on a reading of the Act and the Rules we find that there is no duty cast upon the AO to disclose or provide all the documents in his possession especially when such documents are not being relied upon. Further, the Honble SAT in the matter of Anant R Sathe Vs SEBI (Appeal No.

150 of 2020) vide Order dated July 17, 2020 has reaffirmed the principle elucidated in the judgment of Shruti Voras case, which was reproduced herein above and ruled that the Authority is required to supply the documents that they rely upon while serving the show cause notice which in the instant case has been done and which is sufficient for the purpose of filing an efficacious reply in his defence. Therefore, I hold that contentions of Noticees in this regard are without merits. I now proceed to consider the matter on merits. Connections alleged

12. I note that Noticees are alleged to be part of group of 12 connected entities, on the basis of details obtained from Unique client code (UCC) database updated by the brokers, MCA website (for common directors), off-market transfers, information available on exchange website and bank account statements. The details of connections alleged are as follows: Table 1 Name PAN Basis of connection

1. Viking Industries Pvt. Ltd. AACCV3221B As per UCC details (provided as Annexure 4 to SCN) Adjudication order in the matter of 20 Microns Ltd Name PAN Basis of connection

2. Anand Honwadker AGNPH7773A Entity no. 1, 2, 3, 4,9,10,12 have common phone no. 9429896070, Entity no. 1,2,3,4,12 common email id- acmeshare@gmail.com, Entity no. 1,5,8 & 9 have common email id nileshdoshi40@gmail.com, Entity no. 5, 7 & 8 share common address : A-1, 1st Floor, Anugrah Appt, Opp. Bank Of Rajasthan, Kalavad Road, Rajkot, Gujarat, & 330 Silver Chambers 3rd Floor Tagore Road, Rajkot, Gujarat, Entity no. 3 & 10 have common email ID bhavanabhatt@64@yahoo.in, Entity no.2 & 9 have common email ID anand.honwadker@yahoo.in, Entity no. 2 & 3 have common email ID 20diacentre@gmail.com Entity no.9 & 10 have common email ID jigneshshah286@gmail.com & address Entity no. 8 is the Karta of entity at sr. no.5 As per information available on BSE website, entity no.12 is the promoter of entity no.11. Off market transfer in the scrip of 20 Microns Ltd. between the following (provided as Annexure 5 to SCN): Entity no.3 & 4 on August 13, 2014 Entity no.1 & 6 on April 16, 2015 Entity no.2 & 9 on August 18, 2015 As per data on MCA website (provided as Annexure 6 to SCN), entity no. 11 & 12 have common directors Chandresh Shantilal Parikh, Rajesh Chandreshbhai Parikh, Sudhir Rameshkant Parikh. As per UCO Bank a/c no. 01560100004831 (provided as Annexure 7 to SCN) held jointly by entity no.9 & 10, financial transactions observed with entity no. 1 & with Sudhir R. Parikh - Director of entity no. 11 & 12

3. Bhavana P Bhatt ANAPB4318D

4. Kiritkumar Hiralal Rohit AUXPR0807K

5. Nilesh A Doshi AAFHN5097K

6. Shishir Jayantilal Khandwala ADIPK8614M

7. Minu Nileshkumar Doshi ABQPD8086L

8. Nileshkumar Amrutlal Doshi ABJPD0467E

9. Jigneshkumar Indravadanbhai Shah AJOPS2389D

10. Leena Jigneshkumarsh FJJPS0065L

11. 20 Microns Ltd. AAACZ0580B

12. Eriez Finance & Investment Ltd. (now known as Eriez Industries Pvt. Ltd.) AAACZ0643B Adjudication order in the matter of 20 Microns Ltd Name PAN Basis of connection As per IDBI Bank a/c no.0021104000282031 (provided as Annexure 8 to SCN) held by entity no.3, financial transactions observed with entity no. 1. As per ICICI bank a/c no.624801517576 (provided as Annexure 9 to SCN) held by entity no.7, financial transactions observed with entity no.1 & 8. As per Axis bank a/c no.013010200002846 (provided as Annexure 10 to SCN) held by entity no.12, financial transactions observed with entity no.1 & 8 As per Axis bank a/c no.013010200059422 (provided as Annexure 11 to SCN) held by entity no. 1, financial transactions observed with entity no.4, 9, 10,11, 12

13. Noticees have interalia contended that email IDs/ mobile numbers attributed to them by the SCN, as mentioned in the above table do not belong to them. I note that the aforesaid details have been obtained from Unique Client Codes (UCC) allotted to the respective Noticees by brokers. Such information is based on submissions made by Noticees themselves at the time of opening the demat account, so that I reject the contentions made by Noticees in this regard.

14. Further, Noticees have contended that off market transfers or other such transactions, which have been relied for alleging connections, were undertaken by them for commercial purposes. For instances, Anand Honwadker has submitted interalia that he sold 28,000 shares in off market to Jignesh I. Shah on advice of his dealer and received consideration for the same. I note that impugned off market transfers conclusively establish relations/ connections among such Noticees, and that the motive or rationale of off market transfers is irrelevant as regards instant considerations. Therefore, I note that as alleged in Table 1 basis the evidences conveyed to Noticees vide Annexures 4 to 11, the material on record is sufficient to reasonably conclude that Noticees in the instant matter were connected to each other directly or indirectly. Adjudication order in the matter of 20 Microns Ltd

15. I further note that Noticees are alleged to have created artificial volume and misleading appearance of trading, basis the trading patterns exhibited by them which include synchronized trades, circular trades, reversal trades and self-trades. I now proceed to consider allegations basis such patterns in paragraphs that follow. Synchronized trades

16. It has been alleged that Noticees as a group carried out synchronized trades in the scrip of 20 Microns on both, BSE and NSE, contributing substantially to the market volume during the IP. I note that on BSE, Noticees carried out such trades contributing more than 1% individually, as per the following details: No. Particulars Buy Side Sell Side Qty of Synch Trade % of Synch Vol. to Mkt. Vol. No of days No. of Trades Qty of Synch Trade % of Synch Vol. to Mkt. Vol. No of days No. of Trades

1 Viking Industries Pvt. Ltd. 1155565 6.39 173 524 1012777 5.60 162 512

2 Rohit Kiritkumar Hiralal 613923 3.40 46 147 477072 2.64 40 123

3 Honwadker Anand 579490 3.21 78 220 704276 3.90 86 289

4 Bhavana Pareshkumar Bhatt 413646 2.29 36 103 510440 2.82 41 124

5 Minu Nileshkumar Doshi 346576 1.92 181 244 342709 1.90 177 218

6 Nilesh A Doshi HUF 282017 1.56 166 200 336377 1.86 170 200

7 Nileshkumar Amrutlal Doshi 254983 1.41 154 168 282757 1.56 158 170

8 Jigneshkumar Indravadanbhai Shah 227041 1.26 18 61 191172 1.06 15 36

9 Leena Jigneshkumar Shah 211766 1.17 15 49 227427 1.26 14 44 Grand Total 4085007 22.60 1716 4085007 22.60 1716 Noticees are alleged to have carried out such trades on 260 days on BSE, with details regarding contribution to artificial volume being as follows: Adjudication order in the matter of 20 Microns Ltd Exchange Market volume Gross Buy Qty of suspected entities Gross Sell Qty of suspected entities Total traded qty among suspected entities Synchroniz ed traded qty by suspected entities Sync Trades as % of total traded qty among the suspected entities Sync Trades as % of Total market volume BSE 18081148 8830958 8938624 7611461 4085007 53.67% 22.60%

17. Similarly, it was observed that on NSE, Noticees carried out synchronized trades contributing more than 1% individually, as per the following details: No. Particulars Buy Side Sell Side Qty of Synch Trade % of Synch Vol. to Mkt. Vol. days No. of Trades Qty of Synch Trade % of Synch Vol. to Mkt. Vol. No of days No. of Trades

1 Viking Industries Pvt. Ltd. 901589 4.11 155 491 860850 3.92 145 449

2 Honwadker Anand 696677 3.17 94 322 632811 2.88 99 254

3 Bhavana Pareshkumar Bhatt 475951 2.17 38 117 392746 1.79 38 88

4 Minu Nileshkumar Doshi 259566 1.18 144 203 306090 1.40 175 225

5 Rohit Kiritkumar Hiralal 251819 1.15 28 70 198745 0.91 29 52

6 Jigneshkumar Indravadanbhai Shah 249766 1.14 16 72 265782 1.21 18 72

7 Nileshkumar Amrutlal Doshi 202046 0.92 135 148 261641 1.19 163 179

8 Nilesh A Doshi HUF 187052 0.85 115 128 257510 1.17 164 187

9 Leena Jigneshkumar Shah 144292 0.66 12 33 192583 0.88 19 78 Grand Total 3368758 15.35 1584 3368758 15.35 1584 Noticees are alleged to have carried out such trades on 264 days on NSE, with details regarding contribution to artificial volume being as follows: Exchange Market volume Gross Buy Qty of suspected entities Gross Sell Qty of suspected entities Total traded qty among suspected entities Synchroniz ed traded qty by suspected entities Sync Trades as % of total traded qty among the suspected entities Sync Trades as % of Total market volume NSE 21952189 8446264 8498341 7070044 3368758 47.65% 15.35%

18. It was alleged that by carrying out synchronized trades as discussed above, Noticees contributed to 22.60% of total market volume of trades in the scrip of 20 Microns on BSE and to 15.35% of total market volume on NSE, thereby violating Adjudication order in the matter of 20 Microns Ltd provisions of regulations 3 (a), (b), (c), (d), 4 (1), 4 (2)(a) & (g) of PFUTP Regulations, 2003.

19. I note that synchronized trades involve matching of buy and sell orders, which are placed within an interval of one minute from each other, among connected entities. In the instant matter, I note that Noticees contributed to substantial market volume on both BSE and NSE during the IP, and that each Noticee contributed to such trades on both the exchanges.

20. Noticees have interalia contended that the contribution made by them individually to alleged artificial volume is insignificant vis--vis total market volume, and that they traded on small number of days only out of total trading days in the IP. For instance, Jignesh I. Shah, bought shares only on 22 days on BSE/ 24 days on NSE and sold shares on 32 days on BSE/ 29 days on NSE out of 328 trading days in the IP, and also, his transactions were not concentrated but spread over 16 months. I note that Noticees are connected to each other as held above, so that the trades executed by them as a group is relevant as regards instant considerations. The trades carried out by Noticees individually has to be seen as part of the overall trading pattern exhibited by Noticees as a group, so that I reject contentions of Noticees in this regard.

21. I hold that Noticees together traded as group, and carried out synchronized trades which created artificial volume in the market and misleading appearance of trading, without the intention of genuine transfer of shares. Therefore, Noticees violated provisions of regulations 3 (a), (b), (c), (d), 4 (1), 4 (2)(a) & (g) of PFUTP Regulations, 2003. Circular / Reversal trades

22. It was alleged that Noticees carried out Circular trades and reversal trades among themselves, which resulted in creation of artificial volume in the market, thereby leading to alleged violation of provisions of regulations 3(a),(b),(c),(d), 4(1)(a) and (g) of the PFUTP Regulations, 2003.

23. I note that Noticees executed circular trades as per the following details on BSE and NSE: Adjudication order in the matter of 20 Microns Ltd Sr. No. Exchange Total traded qty among the group entities Circular quantity % of circular qty to market volume Total no. of trades

1 BSE 7611461 7545252 41.73 4585

2 NSE 7070044 6863390 31.27 4841 Further, details of alleged circular trades carried out by Noticees on BSE are as follows as per the record: No. Particulars Exchange - BSE Buy Side Sell Side Qty of circular trade % of Circular trade Vol. to Mkt. Vol. No. of Trades Qty of circular trade % of Circular trade Vol. to Mkt. Vol. No. of Trades

1 Viking Industries Private Limited 1769925 9.79 1216 1894471 10.48 1162

2 Nilesh A Doshi Huf 598117 3.31 403 580196 3.21 496

3 Nileshkumar Amrutlal Doshi 541136 2.99 375 564384 3.12 465

4 Minu Nileshkumar Doshi 625832 3.46 442 623058 3.45 494

5 Shishir Jayantilal Khandwala 6050 0.03 3 0 0 0

6 Anand Honwadker 1501543 8.30 908 1361307 7.53 864

7 Jigneshkumar Indravadanbhai Shah 409731 2.27 188 432236 2.39 201

8 Bhatt Bhavana Pareshkumar 830566 4.59 462 618111 3.42 264

9 Rohit Kiritkumar Hiralal 948639 5.25 460 1034465 5.72 438

10 Leena Jigneshkumar Shah 313713 1.74 128 437024 2.42 201 Grand Total 7545252 41.73 4585 7545252 41.73 4585

24. Similarly, summary of the alleged circular trades carried out by Noticees on NSE is as follows: No. Particulars Exchange - NSE Buy Side Sell Side Qty of circular trade % of Circular trade Vol. to Mkt. Vol. No. of Trades Qty of circular trade % of Circular trade Vol. to Mkt. Vol. No. of Trades

1 Viking Industries Private Limited 1368852 6.24 1057 1603860 7.31 1306

2 Nilesh A Doshi Huf 534268 2.43 516 532689 2.43 438

3 Nileshkumar Amrutlal Doshi 501439 2.28 517 485314 2.21 427

4 Minu Nileshkumar Doshi 570684 2.60 559 570654 2.60 484

5 Anand Honwadker 1618887 7.37 1103 1497483 6.82 1110

6 Jigneshkumar Indravadanbhai Shah 430537 1.96 180 486180 2.21 229

7 Bhatt Bhavana Pareshkumar 997186 4.54 463 717073 3.27 340

8 Rohit Kiritkumar Hiralal 486804 2.22 283 541538 2.47 264

9 Leena Jigneshkumar Shah 354733 1.62 163 428599 1.95 243 Grand Total 6863390 31.27 4841 6863390 31.27 4841 Adjudication order in the matter of 20 Microns Ltd

25. I note in this regard, the details of transactions carried out by three Noticees viz. Nilesh HUF, Nilesh, Minu and Anand on July 01, 2014 on BSE: Date Seller Client Name Buyer Client Name Total Traded Qty. Total No. of Trades 01.07.2014 Nilesh A Doshi HUF Anand Honwadker 1500 2 01.07.2014 Minu Nileshkumar Doshi Anand Honwadker 1500 2 01.07.2014 Anand Honwadker Nileshkumar Amrutlal Doshi 1500 1 01.07.2014 Nileshkumar Amrutlal Doshi Anand Honwadker 1500 1 01.07.2014 Anand Honwadker Nilesh A Doshi HUF 1500 1 01.07.2014 Anand Honwadker Minu Nileshkumar Doshi 1500 1

26. Pictorial representation of the above transactions carried out on July 01, 2014 on BSE are as follows:

27. Similarly, the transactions carried out by the above entities on July 02, 2014 on BSE are as follows: Date Seller Client Name Buyer Client Name Total Traded Qty. Total No. of Trades 02.07.2014 Anand Honwadker Nilesh A Doshi HUF 1500 2 02.07.2014 Anand Honwadker Minu Nileshkumar Doshi 1500 2 02.07.2014 Nilesh A Doshi HUF Anand Honwadker 1500 2 02.07.2014 Anand Honwadker Nileshkumar Amrutlal Doshi 1500 2 02.07.2014 Minu Nileshkumar Doshi Anand Honwadker 1500 2 02.07.2014 Nileshkumar Amrutlal Doshi Anand Honwadker 1500 1

28. Pictorial representation of the above transactions carried out on July 02, 2014 on BSE are as follows: Adjudication order in the matter of 20 Microns Ltd

29. I note that in case of above transfers, shares of 20 Microns moved between Anand Honwadker and three other Noticees on July 01 and July 02, 2014. For instance, on July 02, 2014, Anand Honwadker transferred 1500 shares to Minu Nileshkumar Doshi through 2 trades, and thereafter, 1500 shares were transferred back by Minu Nileshkumar Doshi to Anand Honwadker on the same trading date. In this regard, I note, the impugned trades qualify more as reversal trades between Anand Honwadker as one counterparty, and Minu Nileshkumar Doshi, Nileshkumar Amrutlal Doshi and Nilesh A Doshi HUF acting as the counterparties. Therefore, the aforesaid reversal trades contributed to creation of artificial volume in the scrip of 20 Microns amounting to 41.73% of the market volume on BSE and 31.27% of the market volume on NSE.

30. Further, it has been alleged that 5 Noticees viz. Viking Industries Pvt Ltd, Minu Nileshkumar Doshi, Nilesh A Doshi, Nilesh A Doshi HUF and Anand Honwadker executed reversal trades as per the following details: BSE NSE Sum. of Reversal % of Reversal Qty to mkt. Vol. Sum of No. of Reversal Trades No. of days of reversal Trades Sum. of Reversal % of Reversal Qty to mkt. Vol. Sum of No. of Reversal Trades No. of days of reversal Trades 1527660 8.44 2721 306 1430347 6.52 2873 300 I note that aforesaid 5 Noticees entered into reversal trades on more than 1 occasion, and contributed around 1% of the market volume individually. The details of reversal trades carried out by each Noticee along with their contribution to market volume, on BSE and NSE is as follows: Adjudication order in the matter of 20 Microns Ltd Client Name (A) Counterparty Client Name (B) No. of shares bought by client B from client No. of shares bought by client A from client Reversal Qty. % of reversal Qty to volume No. of Reversal trades No. of days of Reversal trades Viking Industries Private Limited Minu Nileshkumar Doshi 325437 340182 315912 1.7 472 171 Viking Industries Private Limited Nilesh A Doshi 279266 272956 260203 1.4 414 160 Viking Industries Private Limited Nileshkumar Amrutlal Doshi 256545 262332 236845 1.3 402 155 Nilesh A Doshi Honwadker Anand 234165 221250 217630 1.2 341 119 Minu Nileshkumar Doshi Honwadker Anand 233631 206800 204752 1.1 336 119 Nileshkumar Amrutlal Doshi Honwadker Anand 203450 199654 190624 1.1 322 118 Total of 5 entities 1532494 1503174 1425966 7.9 2287 Viking Industries Private Limited Minu Nileshkumar Doshi 292787 270286 267891 1.2 538 153 Viking Industries Private Limited Nileshkumar Amrutlal Doshi 244420 240113 219880 1.0 468 147 Viking Industries Private Limited Nilesh A Doshi 218207 221195 211229 1.0 421 130 Nilesh A Doshi Anand Honwadker 218238 214340 209998 1.0 373 119 Minu Nileshkumar Doshi Anand Honwadker 212044 211544 207157 0.9 414 125 Nileshkumar Amrutlal Doshi Anand Honwadker 197893 206892 196583 0.9 394 126 Total 1383589 1364370 1312738 6.0 2608 800

31. I note that the aforesaid 5 Noticees contributed 7.9% & 6% of the total market volume at BSE and NSE respectively through such reversal trades, leading to creation of artificial volume and misleading appearance of trading.

32. Noticees have interalia contended that the alleged artificial volume created by them individually vide reversal trades was insignificant as compared to the market volume. I note that the impugned reversal trades involved transfer of shares among multiple Noticees in coordination, so that the artificial volume generated by all the Noticees through their trades is to be considered as regards the impugned Adjudication order in the matter of 20 Microns Ltd violations. Further, Noticees have also contended that as they carried out intra day trading, some of their trades matched in the form of reversal trades. I note that such reversal trades have occurred on multiple dates in the IP involving 5 of the Noticees who were connected to each other, which indicates that such trades had not taken place by coincidence and involved prior meeting of minds among the Noticees.

33. Therefore, I hold that Noticees indulged in reversal trades, with the intent of creation of artificial volume and misleading appearance of trading, leading to violation of provisions of regulations 3(a),(b), (c), (d), 4(1)(a), (g) of the PFUTP Regulations, 2003. Self-Trades

34. It was alleged that Viking Industries Pvt Ltd entered into self-trades as per following details, leading to creation of misleading appearance of trading: Particulars BSE NSE Self- Trade Qty. No. of Self Trades No. of days % to mkt Self-Trade Qty. No. of Self Trades No. of days % to mkt vol Viking Industries Pvt. Ltd 52658 54 29 0.29 110836 109 37 0.50

35. I note that self-trades are the ones which are executed between same buyer and seller, resulting in creation of artificial volume without any change in ownership of such shares. I note that Viking Industries Pvt Ltd entered into 54 self-trades spread over 29 days on BSE, which contributed 0.29% to market volume. Similarly, Viking Industries Pvt Ltd also entered into 109 self-trades spread over 37 days on NSE, which contributed 0.50% to market volume.

36. I note that the instant allegations pertain to self-trades executed by Viking Industries Pvt Ltd in IP, however, I find it imperative to consider such trades along with synchronized trades and reversal trades carried out by Viking Industries Pvt Ltd with other Noticees in toto. I note that Viking Industries Pvt Ltd, used self-trades as another form of trading pattern, to supplement creation of artificial volume in the scrip of 20 Microns on BSE and NSE. Therefore, I hold that Viking Industries Pvt Adjudication order in the matter of 20 Microns Ltd Ltd, on account of impugned self-trades, has violated provisions of Regulations 3(a),(b),(c),(d),4(1)(a) and (g) of the PFUTP Regulations, 2003.

37. Based on the discussion in the above paragraphs and considerations made therein, I hold that as regards Issue (a), Noticees created artificial volume and misleading appearance of trading vide impugned synchronized trades, circular trades and reversal trades, leading to violation of provisions of Regulations 3(a),(b),(c),(d),4(1)(a) and (g) of the PFUTP Regulations, 2003. Issue (b) Whether the trades carried out by Noticees in IP have resulted in violation of the provisions of Regulation 3(a)(b)(c)(d), 4(1), 4(2)(a) and 4(2)(e) of the PFUTP Regulations, 2003?

38. It is alleged that Noticees manipulated the scrip price of 20 Microns on both BSE and NSE, in Patch 1 and Patch 3 of the IP. The details of price volume data of the scrip on BSE in the three patches of IP is as follows: Patch Period Open High Low Close Volume Price (Rs.) Vol. Price (Rs.) Vol. Price (Rs.) Vol. Price (Rs.) Vol. Total Vol. Avg. Vol. (Price Fall) 01/07/2014 11/01/2015 36.9 78136 40 241686 26.5 13403 30.5 22478 8067139 63024 01/07/2014 09/07/2014 30/07/2014 01/12/2014 10/12/2014 09/01/2015 (Price Rise) 12/01/2015 15/01/2015 30.9 115977 47.6 337866 30.4 89311 45.8 89311 752708 188177 12/01/2015 15/01/2015 13/01/2015 12/01/2015 15/01/2015 15/01/2015 (Price Fall) 16/01/2015 31/10/2015

46 38629 46.1 670264 25 9401 29.85 388909 9261301 47251 16/01/2015 16/01/2015 14/10/2015 25/08/2015 18/05/2015 30/10/2015

39. It was observed that as regards Patch 1 of the IP, Noticees contributed Rs -44.05 to net LTP and Rs -114.1 to negative LTP, which was 19.42% of market negative LTP. Details of analysis of trades carried out by Noticees as sellers are as follows: Name All trades LTP Diff. >0 LTP Diff. < 0 LTP Diff. =0 % of negative LTP to Total Market negative of LTP diff traded No of trades Sum of LTP diff traded No of trades Sum of diff traded No of trades traded No of trades

1 Viking Industries Private Limited -30.15 1122795 1037 13.8 245079 127 -43.95 297534 233 580182 677 7.48

2 Anand Honwadker -26.75 923449 858 11.55 240399 94 -38.3 244462 218 438588 546 6.52 Adjudication order in the matter of 20 Microns Ltd

3 Bhavana Pareshkumar Bhatt -2.75 470786 325 2.5 89497 26 -5.25 112282 42 269007 257 0.89

4 Rohit Kiritkumar Hiralal -2.65 503315 322 2.75 108653 28 -5.4 97306 46 297356 248 0.92

5 Leena Jigneshkumar Shah -1.55 240205 81 0.95 44131 6 -2.5 13855 13 182219 62 0.43

6 Jigneshkumar I. Shah -0.55 200009 94 1.4 56096 12 -1.95 44264 20 99649 62 0.33

7 Minu Nileshkumar Doshi -0.55 236001 166 5.6 59828 39 -6.15 65950 43 110223 84 1.05

8 Nileshkumar Amrutlal Doshi 3.85 216800 175 7.3 44893 31 -3.45 56998 38 114909 106 0.59

9 Nilesh A Doshi HUF 17.05 245903 170 24.2 127941 82 -7.15 48842 36 69120 52 1.21 Total -44.05 4159263 3228 70.05 1016517 445 -114.1 981493 689 2161253 2094 19.42 Market Total -6.4 8067139 21190 581.25 2006777 4038 -587.6 1980235 4352 4080127 12800

40. It was observed that Viking Industries Pvt Ltd contributed Rs. -43.95 to negative LTP (i.e. 7.48% to market negative LTP) through 233 trades, and that the counterparty entities in 143 of those 233 trades were other Noticees viz. Nilesh HUF, Viking, Anand, Minu, Nilesh, Rohit, Jignesh, Leena and Bhavana which contributed Rs. -28 to negative LTP (i.e. 4.76% to market negative LTP). It was further observed that Anand Honwadker contributed Rs. -38.3 to negative LTP (i.e. 6.52% to market negative LTP) through 218 trades, and that counterparties to 96 of those 218 trades were observed to be the Noticees viz., Nilesh HUF, Viking, Anand, Minu, Nilesh, Rohit, Jignesh, Leena and Bhavana which contributed Rs. - 20.2 to negative LTP i.e. 3.44% to market negative LTP.

41. Similarly, it was observed as regards Patch 3 of the IP, 10 connected entities contributed Rs. -96.9 to net LTP and Rs. -270.4 to negative LTP which was 25.59% to market negative LTP. Details of analysis of trades carried out by entities of the group during this patch are as follows: Name All trades LTP Diff. >0 LTP Diff. < 0 LTP Diff. =0 % of negative LTP to Total Market negative of LTP diff traded No of trades of LTP diff traded No of trades Sum of LTP diff traded No of trades traded No of trades

1 Viking Industries Private Limited -68.15 1168299 2152 53.6 207320 476 -121.75 318779 502 642200 1174 11.52

2 Honwadker Anand -39.35 855684 945 23.2 223138 171 -62.55 270965 320 361581 454 5.92

3 Rohit Kiritkumar Hiralal -7.2 563587 373 12.7 173732 63 -19.9 189191 130 200664 180 1.88

4 Jigneshkumar Indravadanbhai Shah -5.3 217593 129 1.05 45772 12 -6.35 44080 36 127741 81 0.6

5 Bhavana Pareshkumar Bhatt -1.65 543304 307 9.7 170746 61 -11.35 122173 59 250385 187 1.07 Adjudication order in the matter of 20 Microns Ltd Name All trades LTP Diff. >0 LTP Diff. < 0 LTP Diff. =0 % of negative LTP to Total Market negative of LTP diff traded No of trades of LTP diff traded No of trades Sum of LTP diff traded No of trades traded No of trades

6 Shishir Jayantilal Khandwala -0.8 18800 5 0.3 12500 1 -1.1 2750 2 3550 2 0.1

7 Minu Nileshkumar Doshi -0.25 473708 387 19 112803 64 -19.25 185562 148 175343 175 1.82

8 Leena Jigneshkumar Shah 0.1 117742 70 2.05 31549 13 -1.95 34298 14 51895 43 0.18

9 Nilesh A Doshi Huf 2.9 394568 277 14.2 92951 59 -11.3 176419 102 125198 116 1.07

10 Nileshkumar Amrutlal Doshi 22.8 376952 308 37.7 182547 109 -14.9 88412 69 105993 130 1.41 Total -96.9 4730237 4953 173.50 1253058 1029 -270.4 1432629 1382 2044550 2542 25.59 Market Total -16.15 9261301 29743 1040.8 2378682 5909 -1056.75 2553564 7072 4329055 16762

42. It was observed that Viking Industries Pvt Ltd contributed Rs. -121.75 to negative LTP (i.e. 11.52% to market negative LTP) through 502 trades, and that counterparties entities to 171 trades out of those 502 trades were observed to be suspected entities of the group (viz., Nilesh HUF, Viking, Anand, Minu, Nilesh, Rohit, Jignesh, Leena & Bhavana) which contributed Rs. -55.5 to negative LTP (i.e. 5.25% to market negative LTP). Further, Anand Honwadker contributed Rs. -62.55 to negative LTP (i.e. 5.92% to market negative LTP) through 320 trades, and that counterparties entities in 138 trades out of those 320 trades were observed to be suspected entities of the group viz.,Nilesh HUF, Viking, Anand, Minu, Nilesh, Rohit, Jignesh, Leena & Bhavana which contributed Rs. -39.6 to negative LTP (i.e. 3.75% to market negative LTP).

43. Therefore, it was observed that by executing such trades in Patch 1 and 3, as discussed in above paragraphs, Noticees matched the price of prevailing buy/sell orders which were placed at a price lower than the LTP and thus contributed to the price fall, leading to alleged violation of regulations 3 (a), (b), (c), (d) and 4 (1), 4(2)(a) and (e) of PFUTP Regulations, 2003.

44. Further, the details of price volume data of the scrip on NSE in the three patches of IP are as follows: Patch Period Open High Low Close Volume Price (Rs.) Vol. Price (Rs.) Vol. Price (Rs.) Vol. Price (Rs.) Vol. Total Vol. Avg. Vol. (Price Fall) 01/07/2014 11/01/2015 (Price Fall) 36.5 115064 36.95 265657 27.8 14082 30.6 20967 8946758 69896 01/07/2014 01/07/2014 28/08/2014 17/12/2014 03/07/2014 09/01/2015 30.75 255207 47.5 792926 30.35 103198 45.9 103198 1471293 367823 Adjudication order in the matter of 20 Microns Ltd Patch Period Open High Low Close Volume Price (Rs.) Vol. Price (Rs.) Vol. Price (Rs.) Vol. Price (Rs.) Vol. Total Vol. Avg. Vol. (Price Rise) 12/01/2015 15/01/2015 (Price rise) 12/01/2015 15/01/2015 13/01/2015 12/01/2015 15/01/2015 15/01/2015 (Price Fall) 16/01/2015 31/10/2015 (Price Fall) 46.6 57398 46.6 706206 24.5 10373 30.2 706206 11534138 58847 16/01/2015 16/01/2015 30/10/2015 23/09/2015 16/03/2015 30/10/2015

45. It was observed that during Patch-1, Noticees contributed Rs. -35.2 to net LTP and Rs. -93.25 to negative LTP, which was 11.92% to market negative LTP. Details of the analysis of trades carried out by the Noticees as sellers during this patch is as follows: Name All trades LTP Diff. >0 LTP Diff. < 0 LTP Diff. =0 % of negative LTP to Total Market negative Sum of diff traded No of trade Sum of diff traded No of trade Sum of diff traded No of trades traded No of trade

1 Viking Industries Private Limited -26.1 1252206 1531 11.15 195444 135 -37.25 260912 272 795850 1124 4.76

2 Honwadker Anand Trambakrao -22.3 910332 1431 12.95 184533 130 -35.25 209819 252 515980 1049 4.5

3 Bhatt Bhavana Pareshkumar -1.45 510247 297 2.1 129464 35 -3.55 124648 32 256135 230 0.45

4 Jigneshkumar Indravadanbhai Shah -1.15 206917 161 0.95 46293 14 -2.1 37932 31 122692 116 0.27

5 Leena Jigneshkumar Shah -0.6 242400 132 1.05 51070 13 -1.65 59942 22 131388 97 0.21

6 H Rohit Kiritkumar -0.4 423460 241 2 87515 27 -2.4 109782 25 226163 189 0.31

7 Nileshkumar Amrutlal Doshi 0.3 187100 188 3.8 28395 29 -3.5 43407 34 115298 125 0.45

8 Minu Nileshkumar Doshi 0.95 221874 246 5.95 61694 50 -5 50908 41 109272 155 0.64

9 Nilesh A Doshi(HUF) 15.55 216361 199 18.1 108427 86 -2.55 43346 31 64588 82 0.33 Total -35.2 4170897 4426 58.05 892835 519 -93.25 940696 740 2337366 3167 11.92 Market Total -5.9 8946758 57072 776.85 1583787 6474 -782.75 1737759 6942 5625212 43656

46. It was observed that Viking Industries Pvt Ltd contributed Rs -37.25 to negative LTP (i.e. 4.76% to market negative LTP) through 272 trades, and that the counterparty entities in 131 trades out of those 272 trades were observed to be the Noticees viz. Nilesh HUF, Viking, Anand, Minu, Nilesh, Rohit, Jignesh, Leena & Bhavana, which contributed Rs. -17.2 to negative LTP (i.e. 2.20% to market negative LTP). It was further observed that Anand Honwadker contributed Rs. - Adjudication order in the matter of 20 Microns Ltd 35.25 to negative LTP (i.e. 4.5% to market negative LTP) through 252 trades, and that counterparties in 89 trades were observed to be the Noticees viz.,Nilesh HUF, Viking, Anand, Minu, Nilesh, Rohit, Jignesh, Leena and Bhavana which contributed Rs. -13 to negative LTP (i.e. 1.66% to market negative LTP).

47. It was observed that during Patch-3, 10 suspected entities of the group contributed Rs. -79.75 to net LTP and Rs. -199.25 to negative LTP, which was 11.33% to market negative LTP. Details of the analysis of trades carried out by the said entities of the group as sellers during this patch are as follows: Name All trades LTP Diff. >0 LTP Diff. < 0 LTP Diff. =0 % of negative LTP to Total Market negative diff traded No of trades Sum of LTP diff traded No of trades Sum of LTP diff traded No of trades traded No of trades

1 Anand Honwadker -47.2 1054918 1950 20.2 182873 235 -67.4 231678 549 640367 1166 3.83

2 Viking Industries Private Limited -38.5 941320 1996 35.05 197868 356 -73.55 246976 413 496476 1227 4.18

3 Kiritkumar Hiralal Rohit -6 257831 283 4.45 37408 36 -10.45 56177 82 164246 165 0.6

4 Jigneshkumar Indravadanbhai Shah -2.7 316540 205 3 80829 27 -5.7 131870 65 103841 113 0.32

5 Bhavana P Bhatt -0.45 366635 251 6.5 88012 49 -6.95 91205 54 187418 148 0.4

6 Nilesh A Doshi(Huf) -0.1 342641 416 10.1 90332 75 -10.2 114054 106 138255 235 0.58

7 Khandwala Shishir Jayantilal 0.15 13700 5 0.2 1250 1 -0.05 1165 1 11285 3 0

8 Leena Jigneshkumar Shah 0.55 199100 117 2.8 59852 22 -2.25 58212 21 81036 74 0.13

9 Minu Nileshkumar Doshi 4.1 412522 579 15.3 86009 90 -11.2 141899 130 184614 359 0.64

10 Nileshkumar Amrutlal Doshi 10.4 367609 462 21.9 132960 112 -11.5 102630 93 132019 257 0.65 Total -79.75 4272816 6264 119.5 957393 1003 -199.25 1175866 1514 2139557 3747 11.33 Market Total -16.4 11534138 62003 1743.2 2278085 11626 -1759.6 2691944 13699 6564109 36679

48. It was observed that Anand Honwadker contributed Rs. -67.4 to negative LTP (i.e. 3.83% to market negative LTP) through 549 trades, and that out of those 549 trades, the counterparties to 158 trades were observed to be other Noticees viz. Nilesh HUF, Viking, Minu, Nilesh, Rohit, Jignesh, Leena and Bhavana. It was observed that these 158 trades contributed Rs. -16.6 to negative LTP (i.e. 0.94% to market negative LTP). Further, it was observed that Viking Indistries Pvt Ltd Adjudication order in the matter of 20 Microns Ltd contributed Rs. -73.55 to negative LTP (i.e. 4.18% to market negative LTP) through

413 trades, and that out of those 413 trades, the counterparties to 152 trades were observed to be the Noticees viz. Nilesh HUF, Viking, Anand, Minu, Nilesh, Rohit, Jignesh, Leena and Bhavana which contributed Rs. -23.4 to negative LTP (i.e. 1.33% to market negative LTP).

49. Therefore, it was observed that by executing such trades in Patch 1 and 3, as discussed in above paragraphs, Noticees matched the price of prevailing buy/sell orders which were placed at a price lower than the LTP and thus contributed to the price fall, leading to alleged violation of regulations 3 (a), (b), (c), (d) and 4 (1), 4(2)(a) and (e) of PFUTP Regulations, 2003.

50. I note that Viking Industries Pvt Ltd and Anand Honwadker are alleged to have contributed to fall in price of the scrip during Patch 1 and 3 of the IP, through their trades with connected counterparties on BSE and NSE. I note that such contribution can be summarized as follows: Name of the entity BSE (in%) NSE (in%) Patch 1 Patch 3 Patch 1 Patch 3 Viking Industries Ltd. 4.76 5.25 2.20 1.33 Anand Honwadker 3.44 3.75 1.66 0.94 Total contribution 8.2 9.0 3.86 2.27 I proceed to consider connected counterparty trades of Noticees on BSE and NSE sequentially.

51. I note from the trade log on record that details of trades of Noticees among connected counterparties during Patch 1 and 3 of the IP on BSE to be as follows: Patch no Name of seller Name of buyers No of trades rate(Rs) LTP (as % of market negative LTP) Patch 1 Viking Industries Pvt Nilesh HUF, Minu, Nilesh, Rohit, Jignesh, Leena and Bhavana, Anand, Viking

143 -28 4.76 Adjudication order in the matter of 20 Microns Ltd Anand Honwadker Nilesh HUF, Minu, Nilesh, Rohit, Jignesh, Leena, Bhavana, Viking, Anand

96 -20.20 3.44 Total Contribution by connected counterparties

239 -48.20 8.2 Patch 3 Viking Industries Pvt Nilesh HUF, Minu, Nilesh, Rohit, Jignesh, Leena, Bhavana, Anand, Viking

171 -55.5 5.25 Anand Honwadker Nilesh HUF, Minu, Nilesh, Rohit, Jignesh, Leena, Bhavana, Viking, Anand

138 -39.60 3.75 Total Contribution by connected counterparties

309 -95.1 9

52. I note that in Patch 1, Viking Industries Pvt Ltd and Anand Honwadker acting as sellers contributed Rs -28 (143 trades) and Rs -20.2 (96 trades) to negative LTP respectively through connected counterparty trades. Further, in Patch 3, Viking Industries Pvt Ltd and Anand Honwadker contributed Rs -55.5 (171 trades) and Rs -39.6 (138 trades) to market negative LTP through such trades. Considering the contributions made by trades of both the aforesaid entities as seller together, Noticees contributed Rs -48.20 (8.2% of market negative LTP) to negative LTP through 239 trades in Patch 1 of the IP. Further, Noticees contributed Rs -95.1 (9% of market negative LTP) to negative LTP through 309 trades in Patch 3 of the IP.

53. I note the details of trades of Noticees among connected counterparties during Patch 1 and 3 of the IP on NSE as follows: Adjudication order in the matter of 20 Microns Ltd Patch no Name of seller Name of buyers No of trades rate(Rs) LTP (as % of market negative LTP) Patch 1 Viking Industries Pvt Nilesh HUF, Minu, Nilesh, Rohit, Jignesh, Leena and Bhavana, Anand, Viking

131 -17.2 2.20 Anand Honwadker Nilesh HUF, Minu, Nilesh, Rohit, Jignesh, Leena, Bhavana, Viking, Anand

89 -13 1.66 Total Contribution by connected counterparties

220 -30.20 3.86 Patch 3 Viking Industries Pvt Nilesh HUF, Minu, Nilesh, Rohit, Jignesh, Leena, Bhavana, Anand, Viking

158 -16.6 0.94 Anand Honwadker Nilesh HUF, Minu, Nilesh, Rohit, Jignesh, Leena, Bhavana, Viking, Anand

152 -23.4 1.33 Total Contribution by connected counterparties

310 -40 2.27

54. I note that in Patch 1, Viking Industries Pvt Ltd and Anand Honwadker acting as sellers contributed Rs -17.2 (131 trades) and Rs -13 (89 trades) to negative LTP respectively through connected counterparty trades. Further, in Patch 3, Viking Adjudication order in the matter of 20 Microns Ltd Industries Pvt Ltd and Anand Honwadker contributed Rs -16.6 (158 trades) and Rs -23.4 (152 trades) to market negative LTP through such trades. Considering the contributions made by trades of both the aforesaid entities as seller together, Noticees contributed Rs -30.20 (3.86% of market negative LTP) to negative LTP through 220 trades in Patch 1 of the IP. Further, Noticees contributed Rs -40 (2.27% of market negative LTP) to negative LTP through 310 trades in Patch 3 of the IP.

55. I note that in most of the trades executed among Noticees, buyer entity placed the order first, which was subsequently matched in a short span of time by seller viz. Viking Industries Pvt Ltd or Anand Honwadker. I note that in such trades, buyers placed the order at a price below LTP, which was subsequently matched by sellers contributing to price fall in the scrip. I note for instance the details of trades by Anand Honwadker in Patch 1 of BSE, wherein Anand executed 96 trades as seller which contributed Rs 20.20 to negative LTP. Out of these 96 trades, in 75 trades the buy order was placed first. I note details of following trades for example: Date Seller name Buyer Name Buy order time order rate Sell order time Sell order rate Trade rate Rs. 01/07/2014 Anand Honwadker Nilesh A Doshi HUF 09:20:31 36.60 09:20:34 36.60 36.60 14/08/2014 Minu Nileshkumar Doshi 09:20:53 31.15 09:20:55 31.15 31.15 01/09/2014 Nileshkumar A Doshi 09:44:08 32.15 09:44:09 32.15 32.15 I note that the sellers matched the buy orders, which were placed first at a price below LTP, so that buyers drove the fall in scrip price in majority of trades.

56. Therefore, I note that Noticees contributed substantially negative LTP in Patch 1 and 3 of the IP on BSE and NSE, with Viking Industries Pvt Ltd and Anand Honwadker acting as sellers, while rest of the Noticees acting as buyers. Noticees entered into such connected counterparty trades, contributing to misleading appearance of trading and to substantial price manipulation in the scrip of 20 Microns on both the aforesaid exchanges.

57. Noticees have interalia contended that complete data with regard to LTP contribution by each entity is not given in the SCN. I note that relevant tables along with explanation in the SCN clearly bring out the contribution made by each entity Adjudication order in the matter of 20 Microns Ltd towards negative LTP. Further, the trade log of the Noticee on BSE and NSE during the IP have been provided as Annexure 17 to the SCN. Therefore, contentions of Noticee in this regard are without merits. Noticees have also contended that they did not contribute to new high or new low price in the scrip, and that their LTP contributions individually were very small. I note that the contribution of Noticees collectively as a group in negative LTP was relied upon in framing of charges and that creation of new high or new low price as a trading pattern is not relied upon as regards the instant matter.

58. Noticees have also contended that the price movement in the scrip of 20 Microns was consistent before, during and after the IP. I note the price movement of the scrip on BSE during the IP: Patch Period Open High Low Close Price (Rs.) Vol. Price (Rs.) Vol. Price (Rs.) Vol. Price (Rs.) Vol. (Price Fall) 01/07/2014 11/01/2015 36.9 78136 40 241686 26.5 13403 30.5 22478 01/07/2014 09/07/2014 30/07/2014 01/12/2014 10/12/2014 09/01/2015 12/01/2015 15/01/2015 13/01/2015 12/01/2015 15/01/2015 15/01/2015 (Price Fall) 16/01/2015 31/10/2015

46 38629 46.1 670264 25 9401 29.85 388909 16/01/2015 16/01/2015 14/10/2015 25/08/2015 18/05/2015 30/10/2015 I note that price of the scrip during Patch 1 decreased from Rs 36.9 to Rs 26.5, and during Patch 3 from Rs 46 to Rs 25, so that the Noticees contributed 7.91% during Patch 1 and 8.81% during Patch 3 to the market negative LTP through its connected counterparty trades. The aforesaid substantial contribution to the negative LTP via impugned trades points to prior meeting of minds to manipulate price of the scrip, and to significant contribution in decreasing the scrip price vi the impugned trades. Nilesh A. Doshi HUF, Nilesh A. Doshi and Minu Nileshkumar Doshi have interalia contended that the sum of LTP contributed by them in Patch 1 and 2 of the IP was positive. I note in this regard that the scrip price fell during Patch 1, while it rose during Patch 2 of the IP. In the instant matter, the contribution of Noticees interalia in price fall during Patch 1 of the IP has been relied upon for framing the charges, so that the price contribution during the successive patches cannot be added up arbitrarily. Therefore, I note that contentions of Noticees are without merits in this regard. Adjudication order in the matter of 20 Microns Ltd

59. Therefore, I hold that considering the trades executed by the Noticees as connected counterparties on BSE during Patch 1 and 3 of the IP contributed substantially to price fall in each of the patches, establishing the violation of provisions of Regulations 3 (a), (b), (c), (d) and 4 (1), 4(2)(a) & (e) of PFUTP Regulations, 2003 against them. Issue (c) Does the violation, if any, attract penalty under Section 15HA of the SEBI Act, 1992?

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

61. Therefore, I am of the view that monetary penalty needs to be imposed upon the Noticees under Section 15HAof the SEBI Act, 1992 for the violation of the provisions of Regulations 3(a), (b), (c) & (d), 4(1) and 4(2)(a), (e) and (g) of PFUTP Regulations, 2003. The text of Section 15HA of SEBI Act, 1992 is reproduced hereunder: SEBI Act, 1992 Penalty for fraudulent and unfair trade practices. 15HA.If any person indulges in fraudulent and unfair trade practices relating to securities, he shall be liable to a penalty 1[which shall not be less than five lakh rupees but which may extend to twenty-five crore rupees or three times the amount of profits made out of such practices, whichever is higher]. Issue (c) If so, what would be the monetary penalty that can be imposed taking into consideration the factors mentioned in Section 15J of SEBI Act, 1992?

62. While determining the quantum of penalty under Section 15HB of the SEBI Act, 1992, it is important to consider the factors stipulated in Section 15J of the SEBI Act, 1992 read with Rule 5(2) of the Adjudication Rules, 1995 which read as under:

1 Substituted for the words twenty-five crore rupees or three times the amount of profits made out of such failure, whichever is higher by the Securities Laws (Amendment) Act, 2014, w.e.f. 08-09-2014 Adjudication order in the matter of 20 Microns Ltd SEBI Act, 1992 15J While adjudging quantum of penalty under section 15-I, the adjudicating officer shall have due regard to the following factors, namely (a)the amount of disproportionate gain or unfair advantage, wherever quantifiable, made as a result of the default; (b) the amount of loss caused to an investor or group of investors as a result of the default; (c) the repetitive nature of the default.

63. I observe, that the material available on record does not quantify any disproportionate gains or unfair advantage, if any, made by the Noticees and the losses, if any, suffered by the investors due to such violations on the part of the said Noticee. Further, material available on record does not show that the said failure is repetitive. However, in the present matter I note that by executing manipulative trades in small quantities to increase the price of scrip of AVIL, Noticees have violated the provisions of Regulation 3(a), (b), (c), (d) and 4 (1), 4 (2) (a),(e) and (g) of PFUTP Regulations, 2003. ORDER

64. Accordingly, taking into account the aforesaid observations and in exercise of power conferred upon me under Section 15-I of the SEBI Act read with Rule 5 of the Adjudication Rules, 1995, I hereby impose following penalty under Section 15HA of the SEBI Act, 1992 on Noticees under Regulation 3(a), (b), (c), (d) and 4 (1), 4 (2) (a),(e) and (g) of PFUTP Regulations, 2003: Name of Noticee Violation provisions Penalty Viking Industries Pvt Ltd Regulation 3(a),(b),(c),(d) 4(1),(2)(a),(e) and (g) of the PFUTP Rs 10,00,000/- Rupees Ten lakh only (to be paid jointly and severally) Anand Honwadker Rohit Kiritkumar H. Bhavana P. Bhatt Minu Nileshkumar Doshi Nilesh A. Doshi HUF Nileshkumar A. Doshi Adjudication order in the matter of 20 Microns Ltd Jignesh I. Shah Regulations, 2003 Leena J. Shah

65. The Noticees shall remit / pay the said amount of penalty within 45 days of receipt of this order either by way of Demand Draft in favor of SEBI - Penalties Remittable to Government of India, payable at Mumbai, OR through online payment facility available on the website of SEBI, i.e. www.sebi.gov.in on the following path, by clicking on the payment link: ENFORCEMENT Orders Orders of AO PAY NOW.

66. The aforesaid Noticee shall forward said Demand Draft or the details / confirmation of penalty so paid to The Division Chief (Enforcement Department - DRA-1), Securities and Exchange Board of India, SEBI Bhavan, Plot No. C 4 A, G Block, Bandra Kurla Complex, Bandra (E), Mumbai 400 051.. The Noticee shall also provide the following details while forwarding DD / payment information:

a) Name and PAN of the Noticee

b) Name of the case / matter

c) Purpose of Payment Payment of penalty under AO proceedings

d) Bank Name and Account Number

e) Transaction Number

67. In the event of failure to pay the said amount of penalty within 45 days of the receipt of this Order, SEBI may initiate consequential actions including but not limited to recovery proceedings under Section 28A of the SEBI Act, 1992 for realization of the said amount of penalty along with interest thereon, inter alia, by attachment and sale of movable and immovable properties.

68. In terms of Rule 6 of the Adjudication Rules, 1995, copy of this order is sent to the Noticees and also to the Securities and Exchange Board of India. Date: August 30, 2021 K SARAVANAN Place: Mumbai ADJUDICATING OFFICER