BEFORE THE ADJUDICATING OFFICER SECURITIES AND EXCHANGE BOARD OF INDIA [ADJUDICATION ORDER NO. Order/AK/DS/2025-26/31761-31780]

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;

Noticee No.		Noticee Name		PAN
1		M/s Chandrima Mercantiles Limited		AABCC1666J
2		Mr. Pranav Kamleshkumar Trivedi		AWQPT8856R
3		Mr. Nayan Mahendrabhai Thakkar		BYHPT2277A
4		Mr. Kuntal Jitendra Trivedi		AKNPT2945A
5		Mr. Jigneshkumar P. Patel		AQEPP8019J
6		Mr. Rohit Bairwa		ELYPB0179Q
7		Mr. Ankit Ajitbhai Panchal		ECSPP4637J
8		Mr. Hardik Himmatbhai Munjpara		AULPM8809N
9		Mr. Jagdish Chhanabhai Vaghela		AFPPV2562Q
10		Ms. Usha Devi		AEXPU5745D
11		Mr. Parth Rajanikant Pandya		FGMPP6491K
12		Mr. Manish Jethabhai Bhaskar		DHEPB7576N
13		Mr. Nitinkumar Lalji Bhai Bharvad		DWAPB3135C
14		Mr. Babubhai Bhikhaji Godha		BALPG5393L
15		Ms. Narmadaben Pravinbhai Parmar		DQEPP6650L
16		Mr. Pravinbhai Lakhabhai Parmar		DQEPP6651M
17		Ms. Shvetalben Sagarbhai Dataniya		CQGPD5278K
18		Mr. Sagarkumar P. Dataniya		BJIPD7414F
19		Mr. Mrugesh Natwarlal Ruparel		AITPR2718M
20		Mr. Arpit Piyushbhai Shah		BECPS1043E
				In the matter of
Price  and	volume  manipulation  in  the  scrip		of  Quasar  India  Limited

_________________________________________________________________

Adjudication Order in the matter of price and volume manipulation in the scrip of Quasar India Limited           Page 1 of 56

1. Securities and Exchange Board of India (hereinafter referred to as “SEBI”) conducted investigation in the matter of price and volume manipulation in the scrip of Quasar India Limited (hereinafter referred to as “Quasar” / “the Company”) during the period beginning May 01, 2022 till December 31, 2023 (hereinafter referred to as “investigation period” / “IP”) to find violations of provisions of SEBI Act, 1992 and SEBI (Prohibition of Fraudulent and Unfair Trade Practices relating to Securities Market) Regulations, 2003 (hereinafter referred to as “PFUTP Regulations”), if any.

APPOINTMENT OF ADJUDICATING OFFICER

• Upon being satisfied that the Noticees have violated various applicable provisions, SEBI initiated adjudication proceedings against the Noticees u/s 15-I(1) of SEBI Act and Rule 3 of SEBI (Procedure for Holding Inquiry and Imposing Penalties) Rules, 1995 (hereinafter referred to as “SEBI Adjudication Rules”) r/w Section 19 of SEBI Act and appointed the undersigned as the Adjudicating Officer (AO), vide Order dated December 10, 2024 u/s 15-I(1) of the SEBI Act, and Rule 3 of SEBI Adjudication Rules r/w Section 19 of the SEBI Act, to inquire into and adjudge u/s 15HA and 15A(a) of SEBI Act, the violations of provisions of SEBI Act and PFUTP

Regulations, alleged to have been committed by the Noticees, as under;

	Noticee No.	Noticee Name	Under Section
	1	M/s Chandrima Mercantiles Limited	Section 15HA of SEBI Act, 1992
	2	Mr. Pranav Kamleshkumar Trivedi
	3	Mr. Nayan Mahendrabhai Thakkar
	4	Mr. Kuntal Jitendra Trivedi
	5	Mr. Jigneshkumar P. Patel
	6	Mr. Rohit Bairwa
	7	Mr. Ankit Ajitbhai Panchal
	8	Mr. Hardik Himmatbhai Munjpara
	9	Mr. Jagdish Chhanabhai Vaghela
	10	Ms. Usha Devi
	11	Mr. Parth Rajanikant Pandya
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Noticee No.	Noticee Name	Under Section
12	Mr. Manish Jethabhai Bhaskar
13	Mr. Nitinkumar Lalji Bhai Bharvad
14	Mr. Babubhai Bhikhaji Godha
15	Ms. Narmadaben Pravinbhai Parmar
16	Mr. Pravinbhai Lakhabhai Parmar
17	Ms. Shvetalben Sagarbhai Dataniya
18	Mr. Sagarkumar P. Dataniya
19	Mr. Mrugesh Natwarlal Ruparel	Section 15HA and 15A(a) of
		SEBI Act, 1992
20	Mr. Arpit Piyushbhai Shah

(These persons are hereinafter referred to by their respective names / respective Noticee numbers given in the table above, and collectively referred to as “the Noticees/ Entities”.)

SHOW CAUSE NOTICE, REPLY OF THE NOTICEE AND HEARING

• Show Cause Notice (hereinafter referred to as “SCN”) dated January 29, 2025 was issued to the Noticees in terms of rule 4 of SEBI Adjudication Rules, to show cause as to why inquiry should not be held against them and why penalty, if any, be not imposed on them u/s 15HA and 15A(a) of SEBI Act, as applicable.

• Summary of the allegations made in the SCN is as under:

4.1. Total 18 suspected entities, connected to each other, were found to be manipulating the scrip of Quasar by contributing to the artificial volume and subsequent rise in price in the scrip. Out of the 18 suspected entities, 8 of the suspected entities acquired more than 1% shares of Quasar in public category and rest of them aided and abetted the said entities (1% shareholders in public category) to dump their shares of Quasar and subsequently manipulate the scrip of Quasar. During investigation period, few suspected entities also indulged in circular trading and after manipulating the scrip of Quasar, almost all the 18 suspected entities squared off their entire shareholding and exited the scrip of Quasar.

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4.2. Investigation concluded that one of the suspected entity, Noticee 2 viz. Mr. Pranav Kamleshkumar Trivedi along with Noticee 19 (Mr. Mrugesh Natwarlal Ruparel) and Noticee 20 (Mr. Arpit Piyushbhai Shah) was operating the trading and banking accounts of the 18 suspected entities for trading in the scrip of Quasar. Further, the suspected entities in collusion with Noticees 2, 19 and 20 manipulated the scrip of Quasar by lending their trading and bank accounts. Thus, all of them together manipulated the scrip of Quasar by generating high volumes and subsequent rise in price in the scrip of Quasar. The artificial increase in high volume and price misled the retail investors and influenced them to invest in the shares of Quasar and such act could prove detrimental for the securities market.

4.3. Thus, 18 suspected entities, i.e. Noticees 1 to 18 were alleged to be in violation of provisions of Section 12A (a), (b) and (c) of SEBI Act, 1992 read with Regulations, 3(a), (b), (c), (d), 4(1), 4(2)(a), 4(2)(b) and 4(2)(e) of PFUTP Regulations and Noticees 19 and 20 were alleged to be in violation of Section 12A (a), (b) and (c) of SEBI Act read with Regulations 3(a), (b), (c), (d), 4(1), 4(2)(a) of PFUTP Regulations, by aiding and abetting Noticee 2 in manipulating the scrip of Quasar.

4.4. Further, based on the findings of investigation, it was alleged that Noticees 2,

3, 5, 7, 11, 12, 13, 15 and 16 have violated the provisions of section 12A (a),

• and (c) of SEBI Act, 1992 r/w Regulations 3 (a), (b), (c) and (d), 4(1), 4(2)(g) and 4(2)(n) of PFUTP Regulations, as it was observed that these Noticees had indulged in circular trades in the scrip of Quasar on three days during Patch 2 and had contributed around 21%, 68% and 11% respectively, of volume to total market volume on three days by trading among themselves without intending to change the ownership of shares and provide a false appearance of trading in scrip in order to inflate or cause fluctuations in the price of share of Quasar and thereby have created artificial volume in the scrip of Quasar.

4.5. Further, Noticees 19 and 20 did not appear for statement recording even after issuing summons multiple times which hampered the process of investigation

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in ascertaining more facts and information and thus, both have violated provision of Sec 11C(3) of SEBI Act.

• The SCN was duly delivered to Noticees 1, 2, 4, 6, 7, 8, 9, 11, 12, 13, 16, 17, 18 and 19 through SPAD, and to all the Noticees through digitally signed email dated January 30, 2025. As the SPAD had returned undelivered from the addresses of Noticees 3, 5, 10, 14, 15 and 20, affixture of SCN was attempted at their respective communication address on April 7 and 8, 2025. The SCN was affixed/ hand delivered to Noticees 3, 10, 15 and 20. As the SCN was not delivered to Noticees 5 and 14 through hand delivery/ affixture, delivery was made to them by way of public notice. The SCN was serviced in terms of Rule 7(3) of SEBI Adjudication Rules by publishing on September 02, 2025 in The Times of India (English Newspaper), Gujarat Vaibhav (Hindi Newspaper), Sandesh Ahmedabad Express (Gujarati Newspapers).

• Noticees 1 and 2 submitted their reply vide email dated March 04, 2025. No response has been received from Noticees 3 to 20 as on date. I note that no prejudice has been caused to Noticees 3 to 20 and that the principal of natural justice has been duly followed in the matter. I am, therefore, inclined to take a view that Noticees 3 to 20 have nothing to submit in the matter.

• The submissions made by Noticees 1 and 2 are summarized below:

7.1.     Noticee 2 is the CFO and MD of Noticee 1.

7.2.    The percentage of total shares traded in the scrip by Noticee 1 was merely 1.27%, and my personal trading in the scrip accounted for less than 1% of the total market volume. These figures, when viewed in the broader context of the total trading activity of the scrip, are inconsequential. It is simply implausible that such minimal activity from Noticees 1 and 2 could have any material impact on the price or volume of the scrip.

7.3.     Noticees 1 and 2 are active participants in securities markets. The scrip of M/s Quasar India Limited appeared to offer such an opportunity. Based on Noticee 2’s understanding of the stock market and after detailed discussions with the board

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members of Noticee 1, it was decided that both the company and Noticee 2 would seize this opportunity to diversify their trades and invest in the said scrip.

7.4.     The investment and trading decisions were made based on market dynamics, technical analysis, and potential intraday price movements that were observed at that time. It is crucial to emphasize that these were not speculative trades or part of any manipulation scheme. Rather, they were regular intraday trades executed with the intention of capitalizing on fluctuations in the scrip’s price, a practice that is standard in the stock market.

7.5.     Noticees 1 and 2 did not had any direct or indirect contact with the promoters, management, or major shareholders of M/s Quasar India Limited. Thier trading activity in the scrip was entirely independent of any internal corporate affairs of Quasar India Limited. There was no collusion or any kind of cooperation with the management or shareholders of the company in question.

7.6.     One of the primary reasons for engaging in the trades of M/s Quasar India Limited was the higher trading volumes observed on certain days. As any seasoned trader would know, market liquidity is a critical factor when executing intraday trades. Their trading activity was conducted on days when the volumes were sufficiently high, which is a common strategy employed by traders to ensure the execution of their trades without disrupting the market.

7.7.     It is well known that traders seek opportunities in stocks with higher volumes to execute their trades efficiently. This is a routine strategy to maximize returns and minimize risks in any market. For SEBI to question the nature of these trades, merely on the basis of higher volumes on certain days, is not only perplexing but also raises concerns about the fairness of regulatory scrutiny. Higher trading volume does not equate to market manipulation; rather, it reflects market participants responding to favourable conditions. I would like to highlight that I, along with M/S Chandrima Mercantiles Limited, engaged in trading purely on the basis of market liquidity and the opportunity presented by price movements within the scope of normal market dynamics. These actions are entirely consistent with the behaviour of any prudent investor or trader in the stock market.

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• In the interest of natural justice, Noticees 1, 2, 4, 6, 7, 8, 9, 11, 12, 13, 16, 17, 18 and 19 were granted an opportunity of hearing. Vide notice dated March 06, 2025, they were granted hearing on March 13, 2025, which was duly delivered to these Noticees. Since no response was received from Noticees 3, 5, 10, 14, 15 and 20, to whom the SCN was delivered through hand delivery / affixture / public notice, despite due opportunity, the necessity of granting a personal hearing did not arise.

• Noticees 1 and 2 appeared for the scheduled hearing through their AR. The AR reiterated the submissions already made, vide email dated March 04, 2025, and also made additional submissions, which they submitted in writing on April 15, 2025.

1. The additional submissions are summarized below.

10.1.   In order to allege the creation of artificial price and volume in the market, it is imperative to show that parties carrying out the trades were connected to each other, or at least shared a common objective of creating artificial volume. However, in the present case, no connection is shown with any counterparties. Transferring of funds to other counterparties does not mean that Noticees 1 and 2 are connected to them. The transferring of funds was in relation to genuine business transaction, therefore, no illegality can be assumed or alleged on the same. Further, it is also impossible to know the identities of the counterparties in a screen based trading system. A serious charge of fraud and manipulation cannot be levelled on the possibility of suspicion.

10.2.   The counterparties were not known to Noticees 1 and 2 and trades were executed in the normal course of business, devoid of any malafide intentions.

10.3.   In this regard, Noticees 1 and 2 referred and relied upon the judgements of Hon’ble SAT in the matter of M/S. Jagruti Securities Limited, Vintel Securities Pvt. Ltd dated November 23, 2009 (Appeal No. 219/2009), Nishith M Shah HUF dated January 16, 2020 (Appeal No. 97 of 2019).

10.4.   Nothing has been shown in the SCN to allege collusion between the Noticees, and no evidence has been placed on record to show that the action of Noticees 1 and 2 were fraudulent in any manner.

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10.5.   It is alleged that Noticee 2 had executed circular trades during patch 2 of the IP, on March 14, 2023. It is submitted that Noticee 2 had bought 545 shares from Ankit Ajitbhai at 13:00 PM. When Noticee 2 was seller side, he traded around 42 times for 981 quantity i.e. before 11 am, and his trade with Nayan was at around 10:44 am. It appears that SEBI has merged two independent trades, which has nothing to do with circular trades.

10.6.   The SCN is not substantiated by any evidence or material on record. In so far as the Noticees is concerned, the charges are based on surmises and conjectures and on the wild allegation of having carried out collusive trading, the impact of which on securities market have not been shown in the Notice. It is submitted that on such a charge alone no action can be taken against the Noticees. To make any one liable for any commission or omission to visit adverse consequence, there should be adequate justification and, in the absence, thereof any punishment meted to him will be unsustainable

10.7.   In and around April 2022 to December, 2023, there were hearsay news in the Agricultural Produce Market Committee (APMC market), Quasar was going to be acquired by Shah group (commodity merchant based in Ahmedabad, Gujarati), and it appears that based on the said news, most of people who are working and has day to day business in the APMC market like us, commission agent, trader, farmer and other, has traded in the said scrip.

10.8.   Noticees 1 and 2 had bought and sold the shares from their own fund, when there was news they had brought the shares, and when they came to know that the company is not in acquisition then they sold the shares. The said trading was in the normal course of business only.

10.9.   With respect to the fund transactions with the proprietorship firms, namely M/s Vinit Enterprises, M/s Sara Enterprises, M/s Rajni Enterprises, M/s Sahjanand Trading Co., and M/s Vishwakarma Trading Co., as well as other partnership/ proprietorship firms and companies, Noticees 1 and 2 maintain business relations with these entities for the trading of agricultural products. The said fund transactions were therefore business-related transaction, and have submitted certain bills in support of their submissions.

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10.10. Noticees do not own or control any MAC address through which could have traded in the scrip. Therefore, Noticees have no comments to offer on the matter. A MAC address does not disclose who actually has possession of the device, therefore, directly alleging that the said trades executed by the Noticees is illegal and not tenable under law.

10.11. At present, Ahmedabad covers an area of 505 kms and the range of a network tower can vary wide in the big city where by the tower location can covers the range of a network tower, also known as its coverage area or size, can vary based on several factors such as the type of tower, its location, and the frequency band it uses. Within this range, the location of the IPS can be tracked. Given the extensive coverage area of the network, which spans from 1 to 12 miles, Noticees 1 and 2 fail to understand that how the location of the Noticeels office and address is relevant or determinable for the IPS in question, as the networks coverage area extends over a broad range in which any location within that can potentially be traced.

10.12. Para nos. 46.3 and 46.4 of the SCN deal with the details of internet banking login IPS received from IDBI Bank and Axis bank wherein the IPs have a common mobile no. ‘6358042132’ in the name of a person viz. ‘Mr. Shaikh Mohammed Asif’ and the tower location of this mobile no. was the same tower location address as the office address of Noticees. In this regard, it is submitted that, firstly, it has been erroneously concluded, based solely on the tower location of the common mobile number, that the bank accounts of the 11 suspected entities were operated from the Noticee’s office address. Further, it is submitted that, the location of network towers spans a broad geographical area, and it is entirely plausible that the individual was located at or present at the same location or nearby location. Further, the allegation based on the same tower location was purely contradictory and conceptual as SEBI’s Investigation team can call the individual for the investigation, however, instead of calling Amit, Shaikh and another person, SEBI has made up their mind that allege numbers are belonging to same person i.e. Noticees.

10.13. Noticee 2 had Calls/SMS interactions with Mr. Sagar Kumar Dataniya (“Noticee 18”) concerning commodity trades, as Noticee 18 is merely a mercantile agent.

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Furthermore, there were no financial transactions or trade activities between Noticees 1 and 2 and Noticee 18.

10.14. Para nos. 56 and 56.4 of the SCN deal with the observations from the overall Geo-analysis of three locations. In this regard, it is denied that the said mobile number are at same geo location, since geo location is not exact and does not show specific location data, and based on the said assumption and coming to the conclusion that it is the Noticee no. 1 office location is incorrect.

10.15. Para nos. 57 to 59 of the SCN deal with the statements of Noticees and Mr. Gaurav Bachani. With regard to this, it is submitted that Noticee no. 2, out of his fear and nervousness, has given the said statement that “he doesn’t know about the company and its financial transactions”. He has given all the financial and trade details in this reply.

1. Noticees 3 to 20 neither did not submit their replies to the SCN. Noticees 4, 6, 7, 8, 9, 11, 12, 13, 16, 17, 18 and 19, to whom hearing was granted, did not avail the opportunity of personal hearing provided to them.

1. In this regard, I note that the Hon’ble SAT in the matter of Classic Credit Ltd. vs.

SEBI (Appeal No. 68 of 2003 decided on December 08, 2006) has, inter alia, observed that, “……the appellants did not file any reply to the second show-cause notice. This being so, it has to be presumed that the charges alleged against them in the show cause notice were admitted by them”.

1. Further, the Hon’ble SAT in the matter of Sanjay Kumar Tayal & Others vs SEBI

(Appeal No. 68 of 2013 decided on February 11, 2014), has also, inter alia, observed that: “……….. appellants have neither filed reply to show cause notices issued to them nor availed opportunity of personal hearing offered to them in the adjudication proceedings and, therefore, appellants are presumed to have admitted charges leveled against them in the show cause notices…”

1. In view of the observations made by Hon’ble SAT, I find no reason to take a

different view and accordingly, in terms of Rule 4(7) of SEBI Adjudication Rules,

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the matter is being proceeded ex-parte so far as Noticees 3 to 20 are concerned, on the basis of material available on record.

CONSIDERATION OF ISSUES AND FINDINGS

1. Considering the allegations made out in the SCN and the submissions made by the Noticee, I find that following issues require consideration in the present case: ISSUE I – Whether the Noticees have violated the provisions of SEBI Act andPFUTP Regulations, as alleged in the SCN?

ISSUE II – Do the violations, if any, attract penaltyu/s15HA and Section 15A(a) ofthe SEBI Act, as applicable?

ISSUE III – If so, what should be the monetary penalty that can be imposed takinginto consideration the factors mentioned in Section 15J of SEBI Act?

1. The said provisions under which violations are alleged against the Noticees are reproduced below –

SEBI Act, 1992 Investigation.

11C (3) The Investigating Authority may require any intermediary or any person associated with securities market in any manner to furnish such information to, or produce such books, or registers, or other documents, or record before him or any person authorised by it in this behalf as it may consider necessary if the furnishing of such information or the production of such books, or registers, or other documents, or record is relevant or necessary for the purposes of its investigation.

Prohibition of manipulative and deceptive devices, insider trading and substantial acquisition of securities or control.

12A. No person shall directly or indirectly—

(a) use or employ, in connection with the issue, purchase or sale of any securities listed or proposed to be listed on a recognized stock exchange, any manipulative or deceptive device

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or contrivance in contravention of the provisions of this Act or the rules or the regulations made thereunder;

• employ any device, scheme or artifice to defraud in connection with issue or dealing in securities which are listed or proposed to be listed on a recognised stock exchange;

• engage in any act, practice, course of business which operates or would operate as fraud or deceit upon any person, in connection with the issue, dealing in securities which are listed or proposed to be listed on a recognised stock exchange, in contravention of the provisions of this Act or the rules or the regulations made thereunder;

SEBI (Prohibition of Fraudulent and Unfair Trade Practices relating to Securities Market) Regulations, 2003

• Prohibition of certain dealings in securities No person shall directly or indirectly—

(a)buy, sell or otherwise deal in securities in a fraudulent manner;

• 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;

• 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;

• 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

• Without prejudice to the provisions of regulation 3, no person shall indulge in a manipulative, fraudulent or an unfair trade practice in securities markets.

Explanation.– For the removal of doubts, it is clarified that any act of diversion, misutilisation or siphoning off of assets or earnings of a company whose securities are listed or any concealment of such act or any device, scheme or artifice to manipulate the

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books of accounts or financial statement of such a company that would directly or indirectly manipulate the price of securities of that company shall be and shall always be deemed to have been considered as manipulative, fraudulent and an unfair trade practice in the securities market.

• Dealing in securities shall be deemed to be a fraudulent or an unfair trade practice if it involves any of the following:—

• knowingly indulging in an act which creates false or misleading appearance of trading in the securities market;

• dealing in a security not intended to effect transfer of beneficial ownership but intended to operate only as a device to inflate, depress or cause fluctuations in the price of such security for wrongful gain or avoidance of loss;

• any act or omission amounting to manipulation of the price of a security including, influencing or manipulating the reference price or bench mark price of any securities;

• entering into a transaction in securities without intention of performing it or without intention of change of ownership of such security;

• circular transactions in respect of a security entered into between persons including intermediaries to artificially provide a false appearance of trading in such security or to inflate, depress or cause fluctuations in the price of such security;

1. I now proceed to deal with the issues on merits as under:

ISSUE I – Whether Noticees 1 and 2 have violated the provisions of Regulation Section 12A(a), (b) & (c) of SEBI Act r/w Regulation 3(a), 3(b), 3(c), 3(d) and 4 (1) of PFUTP Regulations?

1. From the SCN, I note that the Noticees are alleged to have violated aforesaid provisions of SEBI Act and PFUTP Regulations as Noticees 1, 3 to 18 aided and abetted Noticees 2, 19 and 20 for manipulating the scrip of Quasar by lending their trading and bank accounts and thus, were involved in fraud of manipulating the scrip of Quasar. Further, Noticees 2, 3, 5, 7, 11, 12, 13, 15 and 16 had indulged in circular trades in the scrip of Quasar on three days during Patch 2 and had

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contributed around 21%, 68% and 11% of volume to total market volume on three days by trading among themselves without intending to change the ownership of shares and provide a false appearance of trading in scrip in order to inflate or cause fluctuations in the price of share of Quasar and thereby created artificial volume in the scrip of Quasar. In addition, it has been alleged that Noticees 19 and 20 have violated the provisions of Section 11C(3) of SEBI Act as they did not appear for statement recording even after summons were issued to them on July 31, 2024, September 26, 2024 and October 03, 2024, which hampered the process of investigation in ascertaining more facts and information.

1. Noticees 1 to 18 were considered as suspected entities during the investigation.

• Based on the trading pattern of the said 18 entities, the entire IP was divided into three Patches. The summary of price volume movement in the scrip of Quasar during the IP is provided below:

	Particulars	Period			Opening  Price	High price in	Low		Closing	Avg.  no.  of
					in Rs. (volume)	Rs.  (volume)	price(volume)		Price	(shares)
					on first day of	on last day of	during	the	(volume)	traded	daily
					the period	the period	period		during  the	during	the
									period	period
	Prior	Feb	01,	2022	12.31 (448)	10.26 (1000)	10.26 (1000)		10.26		1,128
	investigation	to	April	30,	2022-02-07	2022-04-18	2022-04-18
	period	2022
		Patch 1			9.8(5000)	8.65(1010)	5.75(1) & 5.75		8.65		14,335
		May	01,	2022	2022-05-02	2023-03-06	(100090)
		to	Mar	09,			2022-07-05 &
		2023					2022-07-06
	During	Patch 2			8.65(5)	42.36	8.65 (5) &		38.45		69,932
		Mar	10,	2023	2023-03-10	(231602)	8.65 (500)
	investigation
		to	May	11,		2023-05-11	2023-03-10 &
	Period
		2023					2023-03-13
		Patch 3			36.53 (3704)	19.2 (36479)	16.89 (92455)		19.14		36,738
		May	12,	2023	2023-05-12	2023-12-29	2023-12-13
		to	Dec	31,
		2023
	Post	Jan 01, 2024 to			19.5 (287635)	14 (45520)	12.12 (24448)		13.75	1,04,165
	investigation	Mar 31, 2024			2024-01-01	2024-03-28	2024-03-20
	period
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• Following commonalities were observed from the analysis of the information pertaining to Know Your Customer (KYC)/Account Opening Form (AOF) sought from the respective brokers and banks of the 18 entities:

Noticee	Entity Name	Common Mobile Number
No.		/Email id/Home Address
1	M/s Chandrima Mercantiles Limited	Common Mobile Number
		Noticee 2 is MD & CEO of M/s Chandrima
2	Mr. Pranav Kamleshkumar Trivedi
		Mercantiles Limited (Noticee 1)
18	Mr. Sagarkumar Pravinchandra Dataniya	Common Home Address. Noticee 18 is
		husband of Noticee 17
17	Ms. Shvetalben Sagarbhai Dataniya
16	Mr. Pravinbhai Lakhabhai Parmar	Common Home Address. Noticee 16 is
		husband of Noticee 15
15	Ms. Narmadaben Pravinbhai Parmar

• I note that 9 entities, i.e. Noticees 2, 3, 4, 5, 7, 8, 9, 10 and 14 opened their bank accounts in same branch of IDBI Bank and 4 entities, i.e. Noticees 11, 12, 15 and 16 opened their bank account in the same branch of Karur Vysya Bank.

• The summary of trading by the entities in scrip of Quasar during IP is provided in the table below:

	Noticee	Entities	Buy Traded	%Buy	Sell	%Sell	Total Buy	Total Sell
	No.		Qty	Trade Qty	Traded Qty	Trade Qty	Value	Value
	1	M/s Chandrima Mercantiles Limited	2,15,184	2.43%	2,15,184	2.43%	39,48,264	63,17,444
	7	Mr. Ankit Ajitbhai Panchal	1,09,355	1.24%	1,09,355	1.24%	8,84,302	28,00,575
	3	Mr. Nayan Mahendrabhai Thakkar	92,898	1.05%	92,898	1.05%	8,49,421	16,80,571
	5	Mr. Jigneshkumar Patel	83,967	0.95%	83,967	0.95%	10,05,010	23,99,458
	11	Mr. Parth Rajanikant Pandya	81,328	0.92%	81,328	0.92%	13,48,258	17,53,523
	16	Mr. Pravinbhai Lakhabhai Parmar	76,328	0.86%	76,328	0.86%	12,79,093	16,49,675
	18	Mr. Sagarkumar Dataniya	74,511	0.84%	74,511	0.84%	21,90,461	21,21,027
	6	Mr. Rohit Bairwa	66,461	0.75%	64,792	0.73%	6,72,979	19,08,832
	14	Mr. Babubhai Bhikhaji Godha	30,461	0.34%	30,431	0.34%	5,39,595	5,67,374
	17	Ms. Shvetalben Dataniya	28,146	0.32%	28,146	0.32%	7,72,395	7,26,504
	10	Ms. Usha Devi	23,804	0.27%	23,786	0.27%	8,25,549	7,23,511
	2	Mr. Pranav Kamleshkumar Trivedi	15,545	0.18%	15,545	0.18%	1,37,549	2,01,000
Adjudication Order in the matter of price and volume manipulation in the scrip of Quasar India Limited								Page 15 of 56

Noticee		Entities		Buy Traded	%Buy	Sell	%Sell	Total Buy	Total Sell
No.				Qty	Trade Qty	Traded Qty	Trade Qty	Value	Value
4	Mr. Kuntal Jitendra Trivedi			2,30,200	2.60%	2,75,200	3.11%	18,98,591	47,14,997
8	Mr. Hardik Himmatbhai Munjpara			70,423	0.80%	2,20,423	2.49%	4,88,376	44,94,763
9	Mr. Jagdish Chhanabhai Vaghela			85,415	0.97%	2,49,237	2.82%	6,14,429	61,60,416
15	Ms.	Narmadaben	Pravinbhai	81,328	0.92%	36,328	0.41%	13,48,173	8,27,982
	Parmar
12	Mr. Manish Jethabhai Bhaskar			77,201	0.87%	37,201	0.42%	12,97,226	8,46,228
13	Mr. Nitinkumar Lalji Bhai Bharvad			47,828	0.54%	30,328	0.34%	8,42,718	6,48,283
		Total		14,90,383	16.86%	17,44,988	19.74%	2,09,42,388	4,05,42,163
		Market total		88,40,144	100.00%	88,40,144	100.00%

23.1. As seen from the table above, the entities contributed 16.86% to buy volume and 19.74% to sell volume in the scrip of Quasar during IP. Noticees 1 to 7, 10, 11, 14, 16, 17 and 18 squared off all the shares that were bought during IP. Noticees 8 and 9 were holding few shares of Quasar before IP and sold all their shares during IP. Noticees 12, 13 and 15 bought shares from entities holding more than 1% shares of Quasar during Patch 2 and didn’t sell entirely the shares of Quasar within IP. During the IP, the entities made a profit of approx. Rs. 1.96 Crores

• Findings with regard to Price and Volume manipulation – Patch 1 – May 01, 2022

to March 09, 2023:

24.1. I note that 9 out of 18 entities traded in the scrip of Quasar and contributed significantly to the volume in the scrip of Quasar. The trading details of 9 entities during Patch 1 are provided below:

	Noticee	Entity name	Buy	%of Buy	Sell Traded		%of Sell
	No.		Traded	qty with		Qty	qty with
			Qty	mkt total			mkt total
	4	Mr. Kuntal Jitendra Trivedi	230,200	22.00%		0	0.00%
	7	Mr. Ankit Ajitbhai Panchal	107,362	10.26%		0	0.00%
	3	Mr. Nayan Mahendrabhai Thakkar	86,350	8.25%		0	0.00%
	9	Mr. Jagdish Chhanabhai Vaghela	85,001	8.12%		360	0.03%
	5	Mr. Jigneshkumar Purshottamdas	70,000	6.69%		0	0.00%
		Patel
Adjudication Order in the matter of price and volume manipulation in the scrip of Quasar India Limited							Page 16 of 56

Noticee	Entity name	Buy	%of Buy	Sell Traded	%of Sell
No.		Traded	qty with	Qty	qty with
		Qty	mkt total		mkt total
8	Mr. Hardik Himmatbhai Munjpara	69,423	6.63%	0	0.00%
1	M/s Chandrima Mercantiles Limited	68,074	6.50%	0	0.00%
6	Mr. Rohit Bairwa	55,346	5.29%	25	0.00%
2	Mr. Pranav Kamleshkumar Trivedi	15,000	1.43%	0	0.00%
	Total	786,756	75.18%	385	0.04%
	Market total	10,46,503	100.00%	10,46,503	100.00%

24.2. As seen from the table above, Noticees 1 to 9 bought around 75% of shares of Quasar in Patch 1 with negligible selling of shares. Thus, Noticees 1 to 9 were only buying the shares of Quasar in Patch 1.

24.3. Out of aforementioned 9 entities, Noticees 1 to 7 acquired shares of Quasar for first time in Patch 1 and Noticees 8 and 9 were holding few shares of Quasar before IP. Further, Noticee 1 and Noticees 3 to 8, by acquiring shares of Quasar, became 1% shareholders of Quasar in public category during Patch 1.

24.4. Details of LTP contribution by 9 entities as Buyers during patch 1 are provided below:

Noticee			All trades			Positive LTP trades			Negative LTP trades			Zero LTP trade
No.
	Client Name		Ltp RateTraded		No. Of	Ltp R	Traded	No. Of	TLtp RateTraded		No. Of	Traded	No. Of	%Ltp
					Trades		Qty				TradesQty		Trades
8	Mr.	Hardik	0.25	69423	55	0.25	2000	1	0.00	0	0	67423	54	1.24%
	Himmatbhai
	Munjpara
6	Mr. Rohit Bairwa		0.15	55346	41	0.15	1346	2	0.00	0	0	54000	39	0.75%
4	Mr.	Kuntal	0.07	230200	65	0.90	5846	3	-0.83	40050	2	184304	60	4.47%
	Jitendra Trivedi
2	Mr.	Pranav	0.00	15000	1	0.00	0	0	0.00	0	0	15000	1	0.00%
	Kamleshkumar
	Trivedi
5	Mr. Jigneshkumar		0.00	70000	16	0.00	0	0	0.00	0	0	70000	16	0.00%
	Purshottamdas
	Patel
1	M/s	Chandrima	-0.06	68074	23	0.00	0	0	-0.06	1000	1	67074	22	0.00%
	Mercantiles
	Limited
9	Mr.	Jagdish	-0.10	85001	25	0.00	0	0	-0.10	1	1	85000	24	0.00%
	Chhanabhai
	Vaghela
Adjudication Order in the matter of price and volume manipulation in the scrip of Quasar India Limited													Page 17 of 56

Noticee			All trades			Positive LTP trades			Negative LTP trades			Zero LTP trade
No.
	Client Name		Ltp RateTraded		No. Of	Ltp R	Traded	No. Of	TLtp RateTraded		No. Of	Traded	No. Of	%Ltp
					Trades		Qty				TradesQty		Trades
3	Mr.	Nayan	-0.30	86350	80	0.96	2100	2	-1.26	13420	3	70830	75	4.77%
	Mahendrabhai
	Thakkar
7	Mr.  Ankit Ajitbhai		-1.55	107362	50	0.11	4330	2	-1.66	5842	5	97190	43	0.55%
	Panchal
	Total		-1.54	786756	356	2.37	15622	10	-3.91	60313	12	710821	334	11.77%
	Market total		-0.59	1046503862		20.13	36197	69	-20.72	68589	74	941717	719	100.00%

24.5. As seen from the table above, 9 entities, i.e. Noticees 1 to 9 made positive LTP contribution of ₹2.37 (11.77%) by acquiring the shares of Quasar.

24.6. Volume Analysis – The scrip of Quasar had traded for only 73 days in Patch 1 as shown in below table along with the close price and volume in the scrip of Quasar for these 73 days.

	Date	Close Price	No. of Shares		Date	Close Price	No. of Shares
		(Rs.)	traded			(Rs.)	traded
	02-May-22	9.8	5000		01-Aug-22	8.62	300
	16-May-22	9.8	5190		03-Aug-22	8.19	10
	19-May-22	9.4	50,000		12-Aug-22	7.79	30
	26-May-22	9	50,000		16-Aug-22	7.41	1,210
	30-May-22	8.8	40,000		19-Aug-22	7.05	1
	31-May-22	8.45	500		25-Aug-22	6.7	39
	01-Jun-22	8.15	100		30-Aug-22	6.7	400
	02-Jun-22	7.85	35,020		01-Sep-22	6.45	35,377
	09-Jun-22	7.55	25,001		02-Sep-22	6.42	314
	15-Jun-22	7.55	221		05-Sep-22	6.44	95,790
	20-Jun-22	7.2	69,424		06-Sep-22	6.76	25,007
	21-Jun-22	7.35	1		08-Sep-22	7.09	40
	22-Jun-22	7	30,001		09-Sep-22	7.44	60
	23-Jun-22	7	110		13-Sep-22	7.81	196
	27-Jun-22	6.9	1,50,002		14-Sep-22	8.2	256
	28-Jun-22	7	50,113		15-Sep-22	8.61	10
	29-Jun-22	6.66	4943		16-Sep-22	9.04	33
	30-Jun-22	6.34	208		19-Sep-22	9.49	711
	01-Jul-22	6.03	180		20-Sep-22	9.96	9,911
	05-Jul-22	5.75	1		21-Sep-22	10.45	120
	06-Jul-22	6	1,00,090		22-Sep-22	10.86	1,983
	07-Jul-22	6.3	75		23-Sep-22	11.4	2
	08-Jul-22	6.61	250		26-Sep-22	11.95	100
	11-Jul-22	6.94	37		21-Nov-22	12.54	7,000
Adjudication Order in the matter of price and volume manipulation in the scrip of Quasar India Limited							Page 18 of 56

Date	Close Price	No. of Shares		Date	Close Price	No. of Shares
	(Rs.)	traded			(Rs.)	traded
13-Jul-22	7.28	1		05-Dec-22	11.92	2,000
14-Jul-22	7.64	81		16-Jan-23	11.33	906
15-Jul-22	8.02	916		30-Jan-23	11.33	1,050
18-Jul-22	8.42	150		06-Feb-23	10.77	1,800
19-Jul-22	8.84	62,040		13-Feb-23	10.24	20,065
20-Jul-22	8.4	50,609		14-Feb-23	9.73	100
21-Jul-22	8.82	307		15-Feb-23	9.73	176
22-Jul-22	9.26	4,698		17-Feb-23	9.25	5
25-Jul-22	9.61	97		23-Feb-23	9.25	5
26-Jul-22	9.13	1,02,158		24-Feb-23	9.25	300
29-Jul-22	8.68	2,572		27-Feb-23	9.25	20
				01-Mar-23	8.79	10
				02-Mar-23	8.79	60
				06-Mar-23	8.65	1,010

24.7. From the table above, I note that the scrip of Quasar was very thinly traded with trading conducted only on 73 days within a span of around 10 months of Patch 1. Out of these 73 trading days in Patch 1, the scrip of Quasar was having high volumes only on 16 days.

24.8. I note that 9 entities, i.e. Noticees 1 to 9 were the major contributors to these 16 high volume days in scrip of Quasar. Following table shows the trades of entities vis-à-vis volume in the scrip of Quasar for these 16 high volume days.

	S. No	Date	Total Quantity traded	Buy/Sell	Total market		% entities
			by entity		volume		volume/Total volume
				Patch 1
	1	19-May-2022	50,000	Buy	50,000		100%
	2	26-May-2022	20,000	Buy	50,000		40%
	3	30-May-2022	34,000	Buy	40,000		85%
	4	02-Jun-2022	10,000	Buy	35,020		29%
	5	09-Jun-2022	10,000	Buy	25,001		40%
	6	20-Jun-2022	69,423	Buy	69,424		100%
	7	22-Jun-2022	5,000	Buy	30,001		17%
	8	27-Jun-2022	1,35,001	Buy	1,50,002		90%
	9	28-Jun-2022	50,000	Buy	50,113		100%
	10	06-Jul-2022	60,000	Buy	1,00,090		60%
	11	19-Jul-2022	45,000	Buy	62,040		73%
Adjudication Order in the matter of price and volume manipulation in the scrip of Quasar India Limited							Page 19 of 56

S. No	Date	Total Quantity traded	Buy/Sell	Total market	% entities
		by entity		volume	volume/Total volume
12	20-Jul-2022	40,000	Buy	50,609	79%
13	26-Jul-2022	1,00,000	Buy	1,02,158	98%
14	01-Sep-2022	35,346	Buy	35,377	100%
15	05-Sep-2022	95,680	Buy	95,790	100%
16	06-Sep-2022	22,724	Buy	25,007	91%

24.9. Thus, from the table above, I note that the 16 high volume days in the scrip of Quasar in Patch 1 were due to the buying trades of Noticees 1 to 9. In Patch 1, Noticees 1 to 9 altogether generated around 75% volume in scrip of the Quasar as compared to the total market volume in the scrip of Quasar.

• Findings with regard to Price and Volume manipulation – Patch 2 – March 10, 2023

to May 11, 2023

25.1. During Patch 2, all the 18 entities, i.e. Noticees 1 to 18 had traded in the scrip of Quasar. The share price of Quasar rose significantly in Patch 2. Price of the scrip opened at Rs.8.65 on 10/03/2023, reached a high of Rs.42.36 on 11/05/2023, reached a low of Rs.8.65 on 10/03/2023 and closed at Rs.38.45 on 11/05/2023. Following table shows the trading of the 18 entities during Patch 2.

	NoticeeEntities		Buy Traded	%Buy		Sell Traded	%Sell
	No.		Qty			Qty
	1	M/s Chandrima Mercantiles Limited	96,774	3.46%		52,847	1.89%
	11	Mr. Parth Rajanikant Pandya	81,328	2.91%		36,328	1.30%
	15	Ms. Narmadaben Pravinbhai Parmar	81,328	2.91%		36,328	1.30%
	12	Mr. Manish Jethabhai Bhaskar	77,201	2.76%		37,201	1.33%
	16	Mr. Pravinbhai Lakhabhai Parmar	76,328	2.73%		36,328	1.30%
	18	Mr. Sagarkumar Pravinchandra Dataniya	48,748	1.74%		24,658	0.88%
	13	Mr. Nitinkumar Lalji Bhai Bharvad	47,828	1.71%		30,328	1.08%
	14	Mr. Babubhai Bhikhaji Godha	30,431	1.09%		28,130	1.01%
	17	Ms. Shvetalben Sagarbhai Dataniya	28,146	1.01%		23,279	0.83%
	10	Ms. Usha  Devi	22,557	0.81%		6,198	0.22%
	5	Mr. Jigneshkumar Purshottamdas Patel	13,967	0.50%		7,029	0.25%
	6	Mr. Rohit Bairwa	9,350	0.33%		3,243	0.12%
	3	Mr. Nayan Mahendrabhai Thakkar	6,548	0.23%		53,381	1.91%
	7	Mr. Ankit Ajitbhai Panchal	1,993	0.07%		27,400	0.98%
	8	Mr. Hardik Himmatbhai Munjpara	1,000	0.04%		52,400	1.87%
Adjudication Order in the matter of price and volume manipulation in the scrip of Quasar India Limited						Page 20 of 56

NoticeeEntities		Buy Traded	%Buy	Sell Traded	%Sell
No.		Qty		Qty
2	Mr. Pranav Kamleshkumar Trivedi	545	0.02%	14,545	0.52%
9	Mr. Jagdish Chhanabhai Vaghela	414	0.01%	1,83,280	6.55%
4	Mr. Kuntal Jitendra Trivedi	–	0.00%	2,75,200	9.84%
	Total	6,24,486	22.32%	9,28,103	33.18%
	Market total	27,97,263	100.00%	27,97,263	100.00%

25.2. From the above table, I note that out of 18 entities, 17 entities (Noticees 1 to 3 and Noticees 5 to 18) bought and sold shares of Quasar while 1 entity (Noticee

• only sold the shares of Quasar. The 17 entities contributed 22.32% to buy volume and 18 entities contributed 33.18% to sell volume and together all of them contributed 11.94% to market volume by trading among themselves.

25.3. Details of LTP contribution by the entities during Patch 2 in the scrip of Quasar are provided below:

	Notic	Entity		All trades		Positive LTP trades			Negative LTP trades			Zero LTP trades
	ee
			LTP	Traded	No. Of	LTP	Traded	No. Of	LTP	Traded	No. Of	Traded	No. Of	%LTP
	No.		Rate	Qty	Trades	Rate	Qty	Trades	Rate	Qty	Trades	Qty	Trades
	5	Mr. Jigneshkumar	2.00	13,967	72	2.22	2375	10	-0.22	3704	8	7888	54	1.50%
		Purshottamdas Patel
	6	Mr. Rohit Bairwa	1.05	9350	15	1.09	4063	10	-0.04	537	2	4750	3	0.73%
	12	Mr. Manish Jethabhai	0.51	77,201	117	0.51	24,483	15	0.00	0	0	52,718	102	0.34%
		Bhaskar
	13	Mr. Nitinkumar Lalji Bhai	0.49	47,828	179	0.53	17,910	14	-0.04	1950	2	27,968	163	0.36%
		Bharvad
	9	Mr. Jagdish Chhanabhai	0.48	414	12	0.55	85	3	-0.07	200	3	129	6	0.37%
		Vaghela
	7	Mr. Ankit Ajitbhai	0.41	1993	66	0.42	58	3	-0.01	14	1	1921	62	0.28%
		Panchal
	15	Ms. Narmadaben	0.34	81,328	108	0.55	17,002	7	-0.21	7200	7	57126	94	0.37%
		Pravinbhai Parmar
	1	M/s Chandrima	0.19	96,774	1336	6.31	12,790	37	-6.12	30,845	103	53,139	1196	4.25%
		Mercantiles Limited
	14	Mr. Babubhai Bhikhaji	0.11	30,431	43	0.90	1	1	-0.79	2279	15	28,151	27	0.61%
		Godha
	2	Mr. Pranav	0.00	545	1	0.00	0	0	0.00	0	0	545	1	0.00%
		Kamleshkumar Trivedi
	8	Mr. Hardik Himmatbhai	0.00	1000	2	0.00	0	0	0.00	0	0	1000	2	0.00%
		Munjpara
Adjudication Order in the matter of price and volume manipulation in the scrip of Quasar India Limited												Page 21 of 56

Notic	Entity		All trades		Positive LTP trades			Negative LTP trades			Zero LTP trades
ee
		LTP	Traded	No. Of	LTP	Traded	No. Of	LTP	Traded	No. Of	Traded	No. Of	%LTP
No.		Rate	Qty	Trades	Rate	Qty	Trades	Rate	Qty	Trades	Qty	Trades
16	Mr. Pravinbhai	-0.13	76,328	172	0.98	17,302	7	-1.11	5850	8	53,176	157	0.66%
	Lakhabhai Parmar
10	Ms. Usha  Devi	-0.37	22,557	50	0.45	25	1	-0.82	7290	26	15,242	23	0.30%
18	Mr. Sagarkumar	-0.77	48,748	49	0.06	1000	5	-0.83	10,568	18	37,180	26	0.04%
	Pravinchandra Dataniya
11	Mr. Parth Rajanikant	-0.80	81,328	144	0.41	16,902	12	-1.21	7950	8	56,476	124	0.28%
	Pandya
3	Mr. Nayan	-0.98	6548	55	0.02	20	2	-1.00	3136	7	3392	46	0.01%
	Mahendrabhai Thakkar
17	Ms. Shvetalben	-2.02	28,146	497	0.21	502	3	-2.23	9965	31	17,679	463	0.14%
	Sagarbhai Dataniya
	Total	0.51	6,24,486	2918	15.21	1,14,518	130	-14.70	91488	239	418480	2549	10.25%
	Market total	30.41	27,97,263	6640	148.32	2,78,805	765	–	4,78,952	850	20,39,506	5025	100.00%
								117.91

25.4. I note from analyzing these details that the entities contributed Rs.0.51 to net LTP and Rs.15.21 to positive LTP in 130 positive LTP trades. Counterparties to the positive LTP trades were analyzed and I note that in 78 positive LTP trades, the entities traded among themselves and contributed 2.51% to market positive LTP. In remaining 52 positive LTP trades, the entities traded with normal investors and contributed Rs.11.48 to positive LTP.

25.5. Volume Analysis – In Patch 2, 9 entities (Noticees 1 to 9) of Patch 1 initially started trading among themselves and subsequently the other 9 entities (namely, Ms. Narmadaben Pravinbhai Parmar, Mr. Pravinbhai Lakhabhai Parmar, Mr. Nitinkumar Lalji Bhai Bharvad, Ms. Usha Devi, Ms. Shvetalben Sagarbhai Dataniya, Mr. Parth Rajanikant Pandya, Mr. Manish Jethabhai Bhaskar, Mr. Sagarkumar Pravinchandra Dataniya and Mr. Babubhai Bhikhaji Godha) (Noticees 10 to 18) who were not holding any shares of Quasar in Patch 1, started trading in Patch 2.

25.6. During Patch 2, the scrip of Quasar traded for 40 days. The price and volume in scrip of Quasar for these 40 trading days of Patch 2 are provided in the table below:

Adjudication Order in the matter of price and volume manipulation in the scrip of Quasar India Limited           Page 22 of 56

Date	Close Price	No. of Shares	Date	Close Price	No. of Shares
	(Rs.)	traded		(Rs.)	traded
10-Mar-23	8.65	5	12-Apr-23	20.49	375
13-Mar-23	8.65	500	13-Apr-23	21.51	638
14-Mar-23	9.08	4,781	17-Apr-23	22.4	2,22,503
15-Mar-23	9.53	12,575	18-Apr-23	23.51	97,780
16-Mar-23	10	5,750	19-Apr-23	24.68	14,250
17-Mar-23	10.5	443	20-Apr-23	25.91	3,223
20-Mar-23	11.02	1,61,719	21-Apr-23	27.17	79,029
21-Mar-23	11.57	5,196	24-Apr-23	28.52	18,874
22-Mar-23	12.14	5,101	25-Apr-23	29.8	1,15,164
23-Mar-23	12.74	11,743	26-Apr-23	29.93	1,05,328
24-Mar-23	13.37	76,619	27-Apr-23	29.43	1,08,483
27-Mar-23	14.03	30,554	28-Apr-23	30.23	59,296
28-Mar-23	14.73	3,395	02-May-23	30.91	38,729
29-Mar-23	15.46	58,339	03-May-23	32.02	13,335
31-Mar-23	16.23	210	04-May-23	33.2	37,616
03-Apr-23	17.04	1,532	05-May-23	34.86	6,607
05-Apr-23	17.52	5,44,704	08-May-23	36.6	2,050
06-Apr-23	18.07	2,09,495	09-May-23	38.43	3,096
10-Apr-23	18.72	53,849	10-May-23	40.35	1,07,401
11-Apr-23	19.52	3,45,374	11-May-23	38.45	2,31,602

25.7. From the above table, I note that out of the 40 trading days in Patch 2, there were 31 trading days where high trading of shares/volume was observed. Investigation revealed that out of the 40 trading days in Patch 2, the 18 entities (Noticees 1 to 18) had significantly traded amongst themselves (including the circular trading) on 12 trading days as well as trading on buy or sell side on 11 unique trading days.

25.8. The table, along with few illustrations, showing the trades of entities among themselves on 12 trading days vis-à-vis volume in the scrip of Quasar for these

12 trading days:

	S. NO.	Trade date	Sum of traded quantity among	Total market	% to Total market
			entities	volume	volume
	1	14-Mar-2023	2781	4781	58.17%
	2	16-Mar-2023	3750	5750	65.22%
	3	20-Mar-2023	1,57,500	1,61,719	97.39%
	4	10-Apr-2023	40,000	53,849	74.28%
	5	11-Apr-2023	48,303	3,45,374	13.99%
Adjudication Order in the matter of price and volume manipulation in the scrip of Quasar India Limited					Page 23 of 56

S. NO.	Trade date	Sum of traded quantity among	Total market	% to Total market
		entities	volume	volume
6	18-Apr-2023	23,340	97,780	23.87%
7	21-Apr-2023	26,668	79,029	33.74%
8	26-Apr-2023	4000	105,328	3.80%
9	27-Apr-2023	19,986	10,8483	18.42%
10	02-May-2023	300	38,729	0.77%
11	04-May-2023	5287	37,616	14.06%
12	11-May-2023	1951	231,602	0.84%

Adjudication Order in the matter of price and volume manipulation in the scrip of Quasar India Limited           Page 24 of 56

25.9. Further, following table shows the trading of the entities in scrip of Quasar on buy side or on sell side on 11 trading day’s vis-à-vis total volume in the scrip of Quasar on these 11 days:

	S. No.	Date	Total Quantity	Buy/Sell	Total market	% quantity by suspects/
			by entites		volume	market volume
	1	24-Mar-2023	30,000	Buy	76,619	39%
	2	05-Apr-2023	42,159	Buy		12%
					5,44,704
		05-Apr-2023	25,676	Sell
	3	06-Apr-2023	20,158	Buy		19%
					2,09,495
		06-Apr-2023	20,158	Sell
	4	11-Apr-2023	62,503	Buy		100%
					3,45,374
		11-Apr-2023	3,11,803	Sell
	5	17-Apr-2023	3,267	Buy		91%
					2,22,503
		17-Apr-2023	2,00,070	Sell
	6	18-Apr-2023	39,175	Sell	97,780	40%
	7	21-Apr-2023	36,638	Buy		92%
					79,029
		21-Apr-2023	35,835	Sell
	8	26-Apr-2023	22,859	Buy	1,05,328	26%
		26-Apr-2023	4,000	Sell
	9	27-Apr-2023	55,069	Buy	1,08,483	77%
		27-Apr-2023	28,670	Sell
	10	04-May-2023	9,973	Buy	37,616	54%
		04-May-2023	10,259	Sell
	11	11-May-2023	49,829	buy	2,31,602	22%
Adjudication Order in the matter of price and volume manipulation in the scrip of Quasar India Limited							Page 25 of 56

S. No.	Date	Total Quantity	Buy/Sell	Total market	% quantity by suspects/
		by entites		volume	market volume
	11-May-2023	2,003	Sell

25.10. Thus, all the 18 entities together by trading amongst themselves and either on buy or sell side, were generating and contributing volume of around 55% in the scrip of Quasar to the total market volume and subsequently were influencing the rise in price of shares of Quasar in Patch 2.

25.11. Circular Trades by Entities – Following table & illustrations show circular trading done by the 9 entities in Patch 2:

March 14, 2023

Buyer Name	Seller Name	% Day	Circular
		Volume	Trade Volume
Mr. Pranav Kamleshkumar Trivedi	Mr. Ankit Ajitbhai Panchal	5.333612	255
Mr. Ankit Ajitbhai Panchal	Mr. Jigneshkumar Purshottamdas Patel	5.333612	255
Mr. Jigneshkumar Purshottamdas Patel	Mr. Nayan Mahendrabhai Thakkar	5.333612	255
Mr. Nayan Mahendrabhai Thakkar	Mr. Pranav Kamleshkumar Trivedi	5.333612	255
	Total Circular Trade Volume		1,020
	Total Market Volume		4,781
	% of circular trade volume to total market volume		21.33

		April 10, 2024
	Buyer Name	Seller Name	% Day	Circular Trade
			Volume	Volume
	Ms. Narmadaben Pravinbhai Parmar	Mr. Parth Rajanikant Pandya	13.64928	7,350
	Mr. Parth Rajanikant Pandya	Mr. Manish Jethabhai Bhaskar	13.64928	7,350
	Mr. Manish Jethabhai Bhaskar	Mr. Pravinbhai Lakhabhai Parmar	13.64928	7,350
Adjudication Order in the matter of price and volume manipulation in the scrip of Quasar India Limited				Page 26 of 56

Mr. Pravinbhai Lakhabhai Parmar		Mr. Nitinkumar Lalji Bhai Bharvad	13.64928	7,350
		Ms. Narmadaben Pravinbhai
Mr. Nitinkumar Lalji Bhai Bharvad		Parmar	13.64928	7,350
		Total Circular Trade Volume		36,750
		Total Market Volume		53,849
	% of circular trade volume to total market volume			68.24

April 11, 2024

Buyer Name	Seller Name		% Day Volume	Circular Trade
				Volume
Ms. Narmadaben Pravinbhai Parmar	Mr. Parth Rajanikant Pandya		2.323858	8,026
Mr. Parth Rajanikant Pandya	Mr. Manish Jethabhai Bhaskar		2.323858	8,026
Mr. Manish Jethabhai Bhaskar	Mr. Pravinbhai Lakhabhai Parmar		2.323858	8,026
Mr. Pravinbhai Lakhabhai Parmar	Mr. Nitinkumar Lalji Bhai Bharvad		2.323858	8,026
Mr. Nitinkumar Lalji Bhai Bharvad	Ms. Narmadaben Pravinbhai Parmar		2.323858	8,026
	Total Circular Trade Volume			40,130
		Total Market Volume		3,45,374
	% of circular trade volume to total market volume			11.61

Adjudication Order in the matter of price and volume manipulation in the scrip of Quasar India Limited           Page 27 of 56

25.12. I note from the tables above, that 9 out of 18 entities indulged in circular trading on March 14, 2023, April 10, 2023, & April 11, 2023 and contributed 21%, 68%, 11% volume respectively to total market volume in the scrip of Quasar on these three days. This volume generated by entities through circular trading is significant for these 3 days and these pattern of circular trades by aforesaid 9 entities indicates their meeting of minds and their intention to trade exclusively by entering into trades without intending to change the ownership of the shares and provide a false appearance of trading in scrip in order to cause variation in the price of share. Thus, I note that entities fraudulently created artificial volume in the scrip of Quasar.

• Findings with regard to Price and Volume manipulation – Patch 3 – May 12, 2023 to December 31, 2023

26.1.    The price of the scrip of Quasar opened at high price of Rs.36.53 on 12/05/2023, reached a low of Rs.16.89 on 13/12/2023 and closed at Rs.19.2 on 29/12/2023. Following table shows the trading of the entities during Patch 3:

	Noticee	Entities	Buy Traded	%Buy	Sell Traded	%Sell
	No.		Qty		Qty
	1	M/s Chandrima Mercantiles Limited	50,336	1.01%	1,62,337	3.25%
	18	Mr. Sagarkumar Pravinchandra Dataniya	25,763	0.52%	49,853	1.00%
	6	Mr. Rohit  Bairwa	1,765	0.04%	61,524	1.23%
	10	Ms. Usha  Devi	1,247	0.02%	17,588	0.35%
	14	Mr. Babubhai Bhikhaji Godha	30	0.00%	2,301	0.05%
Adjudication Order in the matter of price and volume manipulation in the scrip of Quasar India Limited					Page 28 of 56

2	Mr. Pranav Kamleshkumar Trivedi	–	0.00%	1,000	0.02%
5	Mr. Jigneshkumar Purshottamdas Patel	–	0.00%	76,938	1.54%
17	Ms. Shvetalben Sagarbhai Dataniya	–	0.00%	4,867	0.10%
9	Mr. Jagdish Chhanabhai Vaghela	–	0.00%	65,597	1.31%
8	Mr. Hardik Himmatbhai Munjpara	–	0.00%	1,68,023	3.36%
3	Mr. Nayan Mahendrabhai Thakkar	–	0.00%	39,517	0.79%
11	Mr. Parth Rajanikant Pandya	–	0.00%	45,000	0.90%
16	Mr. Pravinbhai Lakhabhai Parmar	–	0.00%	40,000	0.80%
7	Mr. Ankit Ajitbhai Panchal	–	0.00%	81,955	1.64%
	Total	79,141	1.58%	8,16,500	16.34%
	Market total	49,96,378	100.00%	49,96,378	100.00%

26.2.    From the table above, I note that 14 entities contributed 1.58% to buy volume and 16.34% to sell volume in Patch 3. Out of the 14 entities, 5 entities traded as buyer and seller and 9 entities traded as seller.

26.3.    In Patch 3, the scrip of Quasar was being regularly traded with shares being traded for 136 trading days unlike in Patch 1 where the scrip was thinly traded with only 73 trading days.

26.4.    Further, I note that 14 entities sold their shares of Quasar to normal investors and also contributed significant volume on 11 days in Patch 3. Following table shows the trades of 14 entities vis-à-vis volume in scrip of Quasar for 11 days in Patch 3:

S. No.	Date	Total Quantity traded by	Buy/ Sell	Total market	% volume/Total
		entity		volume	volume
1	12-06-2023	43,385	Sell	76,189	57%
2	13-06-2023	3,932	Sell	11,082	35%
3	26-06-2023	1,63,022	Sell	3,35,018	49%
4	03-07-2023	29,418	Sell	29,420	100%
5	26-07-2023	35,897	Sell	38,940	92%
6	28-07-2023	4,000	Sell	11,234	36%
7	20-11-2023	2,54,413	Sell	4,19,062	61%
8	21-11-2023	1,01,171 Sell, 1266 Buy	Buy & Sell	5,08,399	20%
9	22-11-2023	76,910 Sell, 22,076 Buy	Buy & Sell	5,77,116	17%
10	23-11-2023	41,756	Sell	5,68,507	7%
11	15-12-2023	85,325	Sell	2,50,859	34%

Adjudication Order in the matter of price and volume manipulation in the scrip of Quasar India Limited           Page 29 of 56

26.5.    From the table above, I note that the 14 entities majorly sold their shares of Quasar which were acquired in Patch 1 and Patch 2. During Patch 3, these entities traded for only 11 days out of 136 trading days.

• Observations on overall price & volume analysis of Patch 1, 2 & 3

27.1.    In Patch 1, the scrip of Quasar was traded for only 73 trading days within the span of 10 months with only 16 trading days observing high volumes. During this Patch, 9 entities majorly bought the shares of Quasar and 8 of them became 1% shareholders of Quasar in public category. These 9 entities altogether generated around 75% volume to the total market volume in the scrip of Quasar for all the 16 high volume trading days of Quasar in Patch 1. Thus, these 9 entities were the main entities generating the volume in the scrip of Quasar in Patch 1.

27.2.    In Patch 2, the scrip of Quasar traded for 40 trading days wherein 31 trading days observed high volumes and there was a substantial price rise observed. During this Patch, 9 entities of Patch 1, initially began trading among themselves and then subsequently were joined by remaining 9 entities for trading in the scrip of Quasar. Together, the 18 entities traded amongst themselves and either on buy/sell side and artificially contributed to the high volume in the scrip of Quasar for 23 trading days out of total 31 high volume trading days. The high volume generation also resulted in rise in the price of the scrip of Quasar which was misleading and attracted the normal investors to trade in scrip of Quasar. The same can be ascertained from the complaints received from investors pertaining to buying recommendations for scrip of Quasar, being circulated in social media platforms. Further, 9 out of 18 entities also indulged in the circular trades and contributed to the volume in the scrip of Quasar. Therefore, the sole intention of the 18 entities was to create artificial volume and influence the price of the scrip of Quasar and mislead the normal gullible investors to trade in the scrip of Quasar.

Adjudication Order in the matter of price and volume manipulation in the scrip of Quasar India Limited           Page 30 of 56

27.3.    Due to the increased volume and price in Patch 2, the retail investors started trading in the scrip of Quasar which is evident from the 265% increase (from 2,367 to 6,214) in number of public shareholders in Quasar by the end of Dec, 2023. Once these retail investors started trading of Quasar, 15 out of 18 entities sold all their shares of Quasar and remaining 3 entities were left with few shares of Quasar. Thus, overall, 18 entities were successful in executing their modus operandi of manipulating the scrip of Quasar and made profit by exiting the scrip.

• Analysis of Bank Account Statements of entities – The bank account statements of the Noticees were analysed for fund flow. Pursuant to analysis, following was

observed:

28.1. Direct bank funds transfer between entities – The entities had transferred funds amongst themselves directly, as can be seen from the table below, and thus, they were connected to each other.

Name of Transferor	Noticee	Amount	Date	Name of Receiver	Noticee
	No.	(Rs.)			No.
Mr. Kuntal Jitendra	4	73,000	16/12/2022	Ms. Shvetalben	17
Trivedi				Sagarbhai Dataniya
Mr. Jigneshkumar	5	15,000	10/08/2022	Ms. Usha Devi	10
Purshottamdas Patel
Mr. Nayan	3	60,000	26/04/2022	Mr. Pranav	2
Mahendrabhai Thakkar				Kamleshkumar Trivedi
Mr. Kuntal Jitendra	4	12,02,000	23/03/2022	Mr. Ankit Ajitbhai Panchal	7
Trivedi
Mr. Kuntal Jitendra	4	12,30,000	23/03/2022	Mr. Hardik Himmatbhai	8
Trivedi				Munjpara
Mr. Nayan	3	10,00,000	05/01/2022	Mr. Hardik Himmatbhai	8
Mahendrabhai Thakkar				Munjpara
Mr. Kuntal Jitendra	4	8,30,000	15/12/2022	Ms. Usha Devi	10
Trivedi

28.2. Bank funds transfer between entities through a proprietorship firm for trading in scrip of Quasar:

28.2.1. The entities had also indirectly transferred funds among themselves in multiple layers with the help of proprietorship firms. These fund transfers

Adjudication Order in the matter of price and volume manipulation in the scrip of Quasar India Limited           Page 31 of 56

were mainly intended for trading in scrip of Quasar. The pictorial illustration to explain such funds transfer is provided below:

28.2.2. As illustrated above, fund transactions took place in two ways i.e. firstly, either the entities received pay-in from its broker in their bank account and transferred the funds to the proprietorship firms; or secondly, these entities received funds in their bank accounts from proprietorship firms and made pay-out to their broker for the purpose of trading in the scrip of Quasar

28.2.3. The following illustration shows transfer of funds among 8 entities through a proprietorship firm (M/s Prime Trading Co.) for trading in the scrip of Quasar:

Adjudication Order in the matter of price and volume manipulation in the scrip of Quasar India Limited           Page 32 of 56

Date

of

Entity name

Pay

in

Pay  in

Amount

Date

of

Name of entities

Amount

Date

of

trading

in

received

transferred

by

transfer

of

who

received

transferred

trading

in

Quasar

by

from

entities

to

M/s

funds

from

funds

from  M/s

(Rs.)

Quasar by

entity

broker

Prime

Trading

M/s

Prime

Prime

Trading

entities

(Rs.)

Co. (Rs.)

Trading

Co.

Co.

to entities

March

20,

Mr.

Kuntal

7,78,060

7,75,000

March

21,

Mr. Parth

6,25,500

March

2023

Trivedi

2023

Rajanikant Pandya

24, 2023

(Noticee 4)

(Noticee 11)

Mr. Pravinbhai

6,00,000

Mr.

Hardik

Lakhabhai Parmar

Munjpura

15,00,000

15,00,100

March 22,

(Noticee 16)

(Noticee 8)

2023

Mr. Manish

6,00,000

Jethabhai Bhaskar

(Noticee 12)

Mr. Ankit

3,00,000

2,99,900

March

22,

Ms. Narmadaben

6,00,000

Panchal

2023

Pravinbhai Parmar

(Noticee 7)

(Noticee 15)

Mr. Nitinkumar

4,00,100

Lalji Bhai Bharvad

(Noticee 13)

28.2.4. From the above illustration and table, I note that three entities traded in scrip of Quasar and received pay-in from their respective brokers to their bank account. Thereafter, they transferred these funds to a proprietorship firm viz. M/s Prime Trading Co. which in turn transferred these funds to other 5 entities who made a pay out to their respective brokers which was subsequently used to trade in the scrip of Quasar.

28.2.5. Bank funds transfer between the entities and the proprietorship firms for trading in the scrip of Quasar: I note that fund pertaining to pay-in and pay-out were transferred / received by entities for their trades placed in scrip of Quasar. The details of fund transfers are provided in the table below:

Adjudication Order in the matter of price and volume manipulation in the scrip of Quasar India Limited           Page 33 of 56

S.

Name

of

the

Amount received

Name

of

Date

of

Amount

Date

of

Date

of

Amount  of

No.

entity

from /transferred

proprietors

receipt/transf

received

receipt/

trading

in

trading (Rs.)

to proprietorship

hip firm

er

from

transfer

Quasar

firm (Rs.)

(proprietorsh

/transferred

(broker)

ip firm)

to

broker

(Rs.)

1

Mr.

Ankit

25,00,000

M/s

Parash

25/05/2022

25,00,001

25/05/2022

30/05/2022

2,98,603

Ajitbhai Panchal

(Received)

Enterprise

(transferred)

(Noticee 7)

2,99,900

M/s

Prime

22/03/2023

3,00,000

20/03/2023

20/03/2023

2,86,520

(transferred)

Trading

(received)

24,80,818

M/s

Vinit

22/11/2023

24,83,669

21/11/2023

20/11/2023

24,98,214

Enterprise

(received)

2

Mr.

Hardik

15,00,100

M/s

Prime

22/03/2023

15,00,000

21/03/2023

20/03/2023

2,86,520

Himmatbhai

(transferred)

Trading Co.

(received)

Munjpara

36,97,525

M/s

Rajni

27/06/2023

37,00,000

27/06/2023

26/06/2023

35,13,124

(Noticee 8)

(transferred)

enterprise

(received)

3

Mr.

Kuntal

7,75,000

M/s

Prime

22/03/2023

7,78,0,60

21/03/2023

20/03/2023

7,82,420

Trivedi

(Noticee

(transferred)

Trading Co.

(received)

4)

39,22,640

M/s

Vinit

13/04/2023

39,20,719

12/04/2023

11/04/2023

39,32,577

(transferred)

Enterprise

(received)

M/s

Sara

Enterprise

M/s

Rajni

Enterprise

4

Mr.

Nayan

28,00,000

M/s

Amba

19/05/2022

28,00,100

19/05/2022

19/05/2022

2,35,000

Mahendrabhai

(received)

Enterprise

(transferred)

Thakkar

10,00,000

M/s

Parash

26/05/2022

10,00,000

26/05/2022

26/05/2022

1,80,000

(Noticee 3)

(received)

Enterprise

(transferred)

9,99,900

M/s

Rajni

08/07/2023

10,00,082

07/07/2023

03/07/2023

6,21,308

(transferred)

Enterprise

(received)

5

Mr.

30,00,000

M/s

Parash

21/06/2022

29,99,001

21/06/2022

27/06/2022

3,79,500

Jigneshkumar

(received)

Enterprise

(transferred)

Purshottamdas

34,01,250

M/s

Vinit

15/06/2023

34,00,000

14/06/2023

12/06/2023

6,05,663

Patel

(Noticee

(transferred)

Enterprise

(received)

5)

15,89,550

M/s

Kiran

24/11/2023

15,75,983

22/11/2023

20/11/2023

15,82,095

(transferred)

Enterprise

(received)

6

Ms.  Usha

Devi

5,10,000

M/s

21/11/2023

5,08,434

21/11/2023

20/11/2023

5,10,845

(Noticee 10)

(transferred)

Vasupujya

(received)

Trading

7

Mr.

Babubhai

14,10,000

M/s

13/02/2023

14,04,500

13/02/2023

05/04/2023

5,38,990

Bhikhaji  Godha

(transferred)

Vishwakarm

14/03/2023

(received)

14/03/2023

06/04/2023

(Noticee 14)

a Trading

11/04/2023

21/07/2023

27/04/2023

Adjudication Order in the matter of price and volume manipulation in the scrip of Quasar India Limited

Page 34 of 56

S.

Name  of  the

Amount received

Name

of

Date

of

Amount

Date

of

Date

of

Amount  of

No.

entity

from /transferred

proprietors

receipt/transf

received

receipt/

trading

in

trading (Rs.)

to proprietorship

hip firm

er

from

transfer

Quasar

firm (Rs.)

(proprietorsh

/transferred

(broker)

ip firm)

to

broker

(Rs.)

M/s

Sidddehswa

ri Corp

11,50,000

M/s

Vinit

17/07/2023

13,80,463

07/04/2023

12/06/2023

5,67,373

(received)

Enterprises

29/08/2023

(transferred)

17/07/2023

28/08/2023

M/s

Kiran

Enterprise

8

Mr. Rohit Bairwa

7,00,000

M/s

14/03/2023

7,01,000

14/03/2023

14/03/2023

2,67,173

(Noticee 6)

(received)

Sahjanand

(transferred)

15/03/2023

Trading

16/03/2023

27/04/2023

11/05/2023

9

Mr.

Sagar

4,75,000

M/s

22/2/2023

4,77,000

22/02/2023

15/03/2023

1,82,374

Dataniya

(received)

Vishwakarm

(transferred)

05/04/2023

(Noticee 18)

a Trading

10

Mr.

Shvetalben

4,75,000

M/s

22/2/2023

4,76,000

22/02/2023

15/03/2023

1,94,640

Dataniya

(received)

Vishwakarm

(transferred)

05/04/2023

(Noticee 17)

a Trading

11

Mr.

Parth

6,00,000

M/s

Prime

17/03/2023

6,00,000

17/03/2024

20/03/2024

5,19,400

Rajanikant

(received)

Trading

20/03/2024

(transferred)

20/03/2024

24/03/2024

Pandya

24/03/2024

24/03/2024

(Noticee 11)

8,65,000

M/s

Aman

25/12/2024

9,17,938

19/12/2023

15/12/2023

9,24,750

(transferred)

Enterprise

(received)

12

Mr.

Manish

6,00,000

M/s

Prime

17/03/2023

6,00,000

17/03/2024

20/03/2024

4,52,550

Jethabhai

(received)

Trading

20/03/2024

(transferred)

20/03/2024

24/03/2024

Bhaskar

24/03/2024

24/03/2024

(Noticee 12)

4,72,000

M/s

Prime

28/04/2023

4,71,900

27/04/2023

18/04/2023

4,90,238

(transferred)

Trading

(received)

21/04/2023

27/042023

13

Ms.

6,00,000

M/s

Prime

17/03/2023

6,00,000

17/03/2024

20/03/2024

5,19,400

Narmadaben

(received)

Trading

20/03/2024

(transferred)

20/03/2024

24/03/2024

Pravinbhai

24/03/2024

24/03/2024

Parmar (Noticee

15)

14

Mr.

Pravinbhai

6,00,000

M/s

Prime

17/03/2023

6,00,000

17/03/2024

20/03/2024

4,52,550

Lakhabhai

(received)

Trading

20/03/2024

(transferred)

20/03/2024

24/03/2024

24/03/2024

24/03/2024

Adjudication Order in the matter of price and volume manipulation in the scrip of Quasar India Limited

Page 35 of 56

S.

Name  of

the

Amount received

Name

of

Date

of

Amount

Date

of

Date

of

Amount  of

No.

entity

from /transferred

proprietors

receipt/transf

received

receipt/

trading

in

trading (Rs.)

to proprietorship

hip firm

er

from

transfer

Quasar

firm (Rs.)

(proprietorsh

/transferred

(broker)

ip firm)

to

broker

(Rs.)

Parmar (Noticee

4,26,000

M/s

Prime

28/04/2023

4,26,569

27/04/2023

18/04/2023

4,88,742

16)

(transferred)

Trading

(received)

21/04/2023

27/042023

15

Mr.   Nitinkumar

2,00,000

M/s

Prime

20/03/2024

2,00,000

20/03/2024

20/03/2024

1,92,850

Lalji

Bhai

(received)

Trading

(transferred)

Bharvad

(Noticee 13)

28.2.6. From the above table, I note that proprietorship firms namely M/s Prime Trading Co., M/s Vinit Enterprises, M/s Sara Enterprises, M/s Kiran Enterprises, M/s Rajni Enterprises, M/s Vishwakarma Trading Co, M/s Sahjanand Trading Co., M/s Parash Enterprises, M/s Siddheswari Corporation etc. had either transferred funds to entities for trading in the scrip of Quasar or had received funds from entities after trading in the scrip of Quasar. Thus, these proprietorship firms were involved in funds transfer with entities for the purpose of trading in the scrip of Quasar.

• Connection between Mr. Pranav Kamleshkumar Trivedi (Noticee 2) and M/s Chandrima Mercantiles Limited (Noticee 1): One of the entity viz. Mr. Pranav Kamleshkumar Trivedi (Noticee 2), is the director of M/s Chandrima Mercantiles Limited (Noticee 1). Both Noticees 1 and 2 had traded in the scrip of Quasar. The analysis of their bank account statements revealed that Noticee 1 had numerous banking transactions with proprietorship firms viz. M/s Vinit Enterprises, M/s Sara Enterprises, M/s Sahjanand Trading Co., M/s Vishwakarma Trading Co., M/s Rajni Enterprises etc. for trading in the scrip of Quasar along with the funds transfer with several other partnership/ proprietorship firms and companies. Further, Noticee 2 also had banking transactions in individual capacity with the proprietorship firms viz. M/s Vinit Enterprises, M/s Sara Enterprises, M/s Sahjanand Trading Co., M/s

Adjudication Order in the matter of price and volume manipulation in the scrip of Quasar India Limited          Page 36 of 56

Vishwakarma Trading Co., M/s Prime Trading Co. In fact, Noticee 2 had received funds from these proprietorship firms and the same were transferred by him to a company viz. M/s Veggie Fest Foods Pvt. Ltd. where he is the director and authorized signatory. Thus, it was inferred that Noticee 2, as a director of Noticee 1, was aware about the proprietorship firms and their funds transfer to entities for trading in the scrip of Quasar. It was also inferred that Noticee 2 was managing the operations and account of his company Noticee 1, as its director (MD&CEO).

• Analysis of Trading of entities across the market: From the trading history of the entities across market obtained from NSE and BSE during investigation period, I note that the entities placed orders in a particular scrip on same day together and these pattern was observed on multiple days. For example, on March 14, 2023, the entities together in a cluster had traded in scrip of M/s Generic Engg. Construction & Projects Ltd. at BSE and in scrip of M/s Vertoz at NSE. Similarly, on March 15, 2023, these entities had traded in group in scrip of M/s Capri Global Capital Ltd at BSE and in scrip of M/s Medico Remedies at NSE. Thus, I note that the entities were trading in a synchronized pattern together, not only in the scrip of Quasar but in multiple scrips, which points to their modus operandi of manipulative trading.

• Analysis of IP/MAC ID of trades of entities:

31.1.    Upon analysing the IP address and MAC address with respect to trades/orders placed by 18 entities, I note that certain entities had common IP or MAC id on the dates when they had done trading in scrip of Quasar. The details are provided in the table below:

	S. No.	Date	Common IP or MAC	Entities	Notice No.
	1.	14/03/2023	BFEBFBFF000306C3	Mr. Ankit Ajitbhai Panchal	7
			(MAC address)	Mr. Nayan Mahendrabhai Thakkar	3
	2.	05/04/2023	27.61.138.121	M/s Chandrima Mercantile Ltd.	1
		06/04/2023		Mr. Jagdish Chhanabhai Vaghela	9
		10/04/2023
		11/04/2023
	3.	31/03/2023	117.99.48.100	Mr. Rohit Bairwa	6
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S. No.	Date	Common IP or MAC		Entities		Notice No.
4.	08/03/2023	27.61.242.142	Mr. Jignesh Purshottamdas Patel			5
5.	25/04/2023	110.226.183.135	Mr. Manish Jethabhai Bhaskar			12
			Mr. Nitinkumar Laljibhai Bharvad			13
6.	15/03/2023	27.61.146.99	Mr. Ankit Ajitbhai Panchal			7
	16/03/2023		Ms. Usha Devi			10
7.	10/04/2023	172.18.2.101	Mr. Pravinbhai Lakhabhai Parmar			16
			Ms. Shvetalben Sagarbhai Dataniya			17
8.	05/04/2023	E0-D5-5E-02-AB-C1	Mr.	Sagarkumar	Pravinchandra	18
		(MAC Address)	Dataniya
			Ms. Shvetalben Sagarbhai Dataniya			17
9.	14/03/2023	27.61.239.206	Mr. Nayan Mahendrabhai Thakkar			3
10.	02/02/2023	27.61.247.42	Mr. Pranav Kamleshkumar Trivedi			2
11.	16/03/2023	27.61.228.144	M/s Chandrima Mercantile Ltd.			1
			Mr. Jagdish Chhanabhai Vaghela			9
12.	05/04/2023	27.61.169.242	Mr. Babubhai Bhikhaji Godha			14

31.2.    From the above table, I note that few of the entities in pair, had same MAC address or same IP which can be attributed to the fact that their trades were placed from same PC/laptop or same location and thus these entities were connected to each other.

31.3.    Further, upon analysis of the tower location of the IPs at S. no. 2,4,6,9,10,11,12 i.e. (27.61.138.121; 27.61.242.142; 27.61.146.99; 27.61.239.206; 27.61.247.42; 27.61.228.144; 27.61.169.242), I note that all these IPs had the same tower location of “At Titanium City- Near Sachin Tower- 100 Ft Road-Prahladnagar- Ahmedabad NA AHMEDABAD”. This particular tower location matches with the office location and address of M/s Chandrima Mercantiles Limited which is ‘B-712 Seven Floor Titanium City Centre, Near Sachin Tower, 100 Feet, Anandnagar Road, Ahmedabad, Gujarat – 380 015’. Thus, I find that the trades of the 9 entities, i.e. Noticees 1, 2, 3, 5, 6, 7, 9, 10 and 14, were placed from the office of Noticee 1.

• Analysis of IPs of Internet banking login by entities:

32.1.    In order to examine the internet banking login activity of the Bank Accounts of entities, login IP details were sought from their respective banks namely, IDBI Bank, Axis Bank and Karur Vysya Bank. Upon analysing the login IP details

Adjudication Order in the matter of price and volume manipulation in the scrip of Quasar India Limited           Page 38 of 56

received from the banks, I note that bank accounts of many entities were being operated from the same IP. The common IP on some dates (which includes date of trading in Quasar) are provided below.

32.2.    Common internet login IP as received from IDBI Bank

S.	Date	Internet	Entities	Noticee
No.		banking login		No.
		IP
1.	07/04/2023	2401:4900:54c3	Mr. Nayan Mahendrabhai Thakkar	3
		:86c8:80a6:3df1	Mr. Jigneshkumar Purshottamdas Patel	5
		:dd13:e2e1	Mr. Ankit Ajitbhai Panchal	7
			Mr. Hardik Himmatbhai Munjpara	8
			Mr. Jagdish Chhanabhai Vaghela	9
			Ms. Usha Devi	10
			Mr. Babubhai Bhikhaji Godha	14
2.	14/03/2023	2401:4900:3613	Mr. Kuntal Trivedi	4
		:3112:99bc:5bf8	Mr. Babubhai Bhikhaji Godha	14
		:1d50:2a0
3.	07/01/2023	2401:4900:361d	Mr. Kuntal Trivedi	4
		:348:e5bd:ab02:	Mr. Nayan Mahendrabhai Thakkar	3
		cb2a:4f67	Mr. Jagdish Chhanabhai Vaghela	9

32.3.    Common Bank Login IP as received from Axis Bank:

S.	Date	Internet banking	Entities	Noticee
No.		login IP		No.
1.	07/04/2023	27.61.138.121	Mr. Rohit Bairwa	6
			Mr. Sagarkumar Pravinchandra Dataniya	18
			Ms. Shvetalben Sagarbhai Dataniya	17
2.	10/04/2023	27.61.138.121	Mr. Rohit Bairwa	6
			Mr. Sagarkumar Pravinchandra Dataniya	18

32.4.    The details of aforesaid internet banking login IPs received from IDBI Bank and Axis Bank were sought from TSPs. The TSPs provided the requisite details wherein I note that these IPs have a common mobile number ‘6358042132’. CAF (‘Customer Application Form’) of this mobile no. sought from TSP showed that the mobile number was in the name of a person viz. ‘Mr. Shaikh Mohammed Asif’ and the tower location of this mobile no. was “At Titanium City- Near Sachin Tower- 100 Ft Road- Prahladnagar- Ahmedabad NA AHMEDABAD”. This tower location address is same as the office address of

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Noticee 1. Further, the CDR of the said mobile no ‘6358042132’ contains only SMS and not a single call has been made from this number, which shows that this mobile no. has been used only for internet purpose. As per CAF of this mobile number, I note that the said mobile number had been verified by the customer using another mobile number ’8320326808’.

32.5.    Subsequently, CAF was sought from TSP for his another mobile number 8320326808 mentioned in his KYC. From the CAF I note that this mobile number belonged to a person viz. Mr. Amit Laljibhai Makwana. Upon further examination, I note that the mobile number of one of the entity viz. Mr. Nayan Mahendrabhai Thakkar (as per UCC details) is also in the name of Mr. Amit Laljibhai Makwana. Therefore, from the above, I note that the bank accounts of the 11 entities were operated from the office address of M/s Chandrima Mercantiles limited.

32.6.    Common Bank Login IP as received from Karur Vysya Bank – The IP details received from Karur Vysya Bank were examined and out of the several common IPs for 5 entities, few IPs corresponding with trading of these entities in scrip of Quasar are mentioned as under:

S.	Date	Internet banking login	Entities	Noticee
No.		IP		No.
1.	20/03/2023	219.91.190.195	Mr. Parth Rajanikant Pandya	11
			Mr. Manish Jethabhai Bhaskar	12
2.	24/03/2024	123.201.67.135
			Mr. Pravinbhai Lakhabhai Parmar	16
3.	07/04/2023	123.201.65.79	Ms. Narmadaben Pravinbhai Parmar	15
			Mr. Nitinkumar Lalji Bhai Bharvad	13

32.7.    From the table above, I note that the bank account of the aforesaid 5 entities were operated from the same IP on same dates and these IPs belong to a broadband service provider viz. ’You Broadband’ in Gujarat. The IPDR and mobile number associated with these IPs were sought from ‘You Broadband’. The information received from ‘You Broadband’ showed that all the three IPs belong to the same customer viz. ‘ Mr. Mrugesh Ruparel’ and had a common mobile number 9327771812, common MAC address ‘B0A7B9092AC9’,

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common address ‘TF 14, Ajanta Commercial Centre,, Near Income Tax, Ashram Road’ and common registered email id as: ‘nikunjsoni06@gmail.com’.

32.8.    From the analysis of the IP for trades and internet banking login IP provided by IDBI Bank and Axis Bank, I note that the bank accounts of Noticees 1 to 10, 14, 17 and 18 namely were operated from the office of Noticee 1 and it was concluded that Noticee 2, who was the director of Noticee 1 was handling and operating the trading and banking accounts of these 13 entities, i.e. Noticees 1 to 10, 14, 17 and 18.

32.9.    Further, internet banking login IP provided by Karur Vysya Bank revealed that the banking accounts of Noticees 11, 12, 13, 15 and 16 were operated by Mr. Mrugesh Ruparel, i.e. Noticee 19.

32.10. Role of Mr. Mrugesh Ruparel (Noticee 19) and Mr. Arpit Piyushbhai Shah (Noticee 20): The analysis of the bank account statement of a proprietorship firm viz. M/s Prime Trading Co. revealed several bank transactions with Noticee 19, Mr. Mrugesh Ruparel (also known as ‘Mrugesh Natwarlal Ruparel’). Bank statement, KYC and AOF of Noticee 19 were sought from IDBI bank and pursuant to analysis of his bank statement, I note that there were few banking transactions of small amounts with a UPI id ‘nikunjsoni06@okicici’ which coincided with the email ID name of ‘You Broadband’ connection. To verify the same, KYC, AOF and bank statement were obtained from ICICI Bank for the bank account associated to said UPI id. Analysis of the details received revealed that the UPI transactions were done from the bank account of a person viz. Mr. Nikunj Dinesh Bhai Soni with registered mobile number as 9327771812. This is the same mobile number registered with ‘You Broadband’ connection as mentioned above. Thus, I note that Noticee 19, who was having bank transactions with M/s Prime Trading Co., is the same person on whose name the ‘You Broadband’ internet connection was registered and through the same internet connection, bank accounts of Noticees 11, 12, 13, 15 and 16 were being operated. Furthermore, following bank transactions were observed from the bank statement of Mr. Mrugesh Ruparel:

Adjudication Order in the matter of price and volume manipulation in the scrip of Quasar India Limited           Page 41 of 56

Date	Entity Name	Credit amount (Rs.)	Debit amount (Rs.)
04/02/2023	Mr. Kuntal Trivedi (Noticee 4)	15,000	–
23/12/2023	Mr. Parth Pandya (Noticee 11)	50,000	–
07/08/2023	M/s Rajni Enterprise	49,000	–
26/09/2023		33,500
03/10/2023		30,500
30/11/2023		30,000
21/08/2023	M/s Vinit Enterprise	37,500	–
04/09/2023		36,500
30/10/2023		25,500
06/11/2023		20,000
29/08/2023	M/s Kiran Enterprise	52,000	–
12/09/2023	M/s Hiren Enterprise	43,500
06/12/2023		70,000
Many Dates	M/s Prime Trading Co.	75,25,800	70,99,000

32.11. From the above table, I note that Noticee 19 was having bank transactions with 2 entities and 5 common partnership/ proprietorship firms (which had funds transfer with entities). Thus, it was concluded that Noticee 19 was connected to these entities. Further, I note from the analysis of the bank account statements of M/s Prime Trading Co. and Noticee 19, that there were several bank transactions observed with Mr. Arpit Piyushbhai Shah, Noticee 20. The KYC, AOF and Bank statement of Noticee 20 were obtained and the following bank transactions were observed from the analysis of the bank statement of Noticee 20 as received from Gujarat State Cooperative Bank.

Date	Entity Name	Noticee No.	Credit	amount	Debit	amount
			(Rs.)		(Rs.)
21/06/2023	Mr. Parth Pandya	11		10,500		–
26/05/2023	Mr. Manish Bhaskar	12		1,24,000		–
21/06/2023	Mr. Narmada Parmar	15		1,10,000		–
26/05/2023	Mr. Nitin Bharvad	13		–		74,000
21/06/2023	Mr. Nitin Bharvad	13		37,349		–
12/09/2023	M/s Hiren Enterprise			43,500
06/12/2023				70,000
Many dates*	M/s Prime Trading Co.			2,24,450		5,00,000
Many dates	Mr. Mrugesh Ruparel	19		2,40,532		11,370

32.12. From the above table, I note that Noticee 20 was having banking transactions with Noticees 11, 12, 13 and 15 and Noticee 19 (who was operating bank

Adjudication Order in the matter of price and volume manipulation in the scrip of Quasar India Limited           Page 42 of 56

accounts of Noticees 11, 12, 13 and 15). Also, Noticee 20 had banking transaction with a common partnership/proprietorship firm viz. M/s Hiren Enterprise (which had funds transfers with entities) and numerous banking transactions with a common partnership/proprietorship firm viz. M/s Prime Trading Co. I note that he has received a credit of Rs. 5,000 from M/s Prime Trading Co. on 19/04/2023 which was used for bill payment of Rs. 4,956 to You Broadband on same date. In this regard, details of broadband account for which this payment was made were sought from You Broadband. As per the response provided by You Broadband, the broadband account belonged to Noticee 19.

32.13. Thus, I note that Noticee 19 and Noticee 20 were connected to each other and both of them were also acquainted with entities and proprietorship firms which had funded entities for the trading in the scrip of Quasar. I further note that both of them were using You Broadband Internet connection for managing the accounts of Noticees 11, 12, 13, 15 and 16.

• Analysis of CDRs of entities: The Call Data Records (CDRs) and CAF (Customer Application Forms) of the mobile numbers of entities were sought from TSPs. Based on the analysis of CDRs of entities, following common calls between few entities are observed:

Name of person 1	Name of person 2	No.  of common
		Calls/SMS
Mr.   Mrugesh   Natwarlal   Ruparel   (Suspect  &	Mr. Arpit Piyushbhai Shah (Suspect & Operator)	28
Operator) (Noticee 19)	(Noticee 20)
Mr. Sagar Kumar Dataniya (Noticee 18)	Mr. Shvetalben Sagarbhai Dataniya (Noticee 17)	3783
Mr. Sagar Kumar Dataniya (Noticee 18)	M/s Chandrima Mercantiles Ltd (Noticee 1)	4
Mr. Pranav Kamleshkumar Trivedi (Noticee 2)	M/s Chandrima Mercantiles Ltd (Noticee 1)	27
Mr.  Arpit  Piyushbhai  Shah  Shah  (Suspect  &	Mr. Manish Jethabhai Bhaskar (Noticee 12)	1
Operator) (Noticee 20)
Mr. Pranav Kamleshkumar Trivedi (Noticee 2)	Jigneshkumar Purshottamdas Patel (Noticee 5)	27
Mr. Jigneshkumar Purshottamdas Patel (Noticee 5)	Mr. Rohit Bairwa (Noticee 6)	35

33.1.    From the table above, I note that Noticees 1, 2, 5, 6 and 18 had calls among them. Further, there was also an SMS being sent from the mobile number of Noticee 12 to Noticee 20, who was alleged to be handling the accounts of

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entities along with Noticee 19. Furthermore, there were calls/sms found between Noticee 19 and Noticee 20 which shows the connection between them.

• Geo-Location/Tower Location Analysis of mobile number of entities: As per the geo-location analysis done using CDRs for a sample period (Mar 10, 2023 – April 14, 2023) in Patch 2, I note that there were three common locations between the entities along with Noticee 19 and Noticee 20. The three common locations comprised of 2 common locations in Ahmedabad and 1 common location in Mumbai. The analysis of geo-location was carried out within the proximity range of 500 meters to 600 meters and the following screenshots were generated

accordingly for each Geo location.

34.1.    Geo-location 1 (Ahmedabad)

34.1.1. As per the above geo location map, the entities viz. Noticees 1, 2, 3, 4, 5, 6, 8, 9, 10, 14, 17 and 18 were found to be present at same location in Ahmedabad, Gujarat on multiple days including the days when they traded in scrip of Quasar. The above location coincided with the area of the office location of Noticee 1. Noticee 2 was present at this geo location for multiple days with other entities in tandem.

34.2.    Geo-location 2 (Ahmedabad)

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34.2.1. The above geo location map highlights that Noticees 2, 19 and 20 were found to be present at same location on many days almost at same time along with Noticees 11 and 12.

34.3.    Geo-Location 3 (Mumbai –Mira Road)

34.3.1. From above geo location map, I note that Noticee 19 was found to be present in Mumbai at same location along with Noticees 11, 12, 15 and 20.

34.4.    Observations from the overall Geo-analysis of three locations:

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34.4.1. For first common location in Ahmedabad, I note that mobile numbers (used for trading in scrip of Quasar) of Noticees 1, 2, 3, 4, 5, 6, 8, 9, 10, 14, 17, 18 were found to be present at the same geo-location in Ahmedabad on multiple days including the days when these entities traded in scrip of Quasar. The above geo-location coincides with the office location of M/s Chandrima Mercantiles Ltd which is “B-712 Seven Floor Titanium City Centre, Near Sachin Tower, 100 Feet, Anandnagar Road, Ahmedabad, Gujarat – 380 015”.

34.4.2. For second common location in Ahmedabad, the mobile numbers of Noticees 2, 19 and 20 were found to be together.

34.4.3. While for third common location in Mumbai, mobile numbers of Noticees

19 and 20 were found together along with Noticees 11, 12 and 15.

34.4.4. Thus, from the geo-location analysis and observations made during the analysis of IPs of Internet banking login by entities above, it was concluded that Noticees 2, 19 and 20 were together operating the accounts of Noticees 1 to 18 and were manipulating the scrip of Quasar.

• Statement recording of Mr. Pranav Trivedi & M/s Chandrima Mercantiles Ltd – Vide summon dated May 13, 2024, Noticee 2 was advised to appear before the IA for statement recording on June 04, 2024. Since he was MD & CFO of Noticee 1, he also appeared on behalf of Noticee 1 for statement recording on June 04, 2024. In

his recorded statement, he, inter-alia, submitted the following:

35.1. He doesn’t know anything about the business activity of Noticee 1, including its financial transactions. He rarely visits the office of Noticee 1 and only signs the documents on behalf of the company.

35.2. The CA of the company (Mr. Gaurav Bachani) manages operations of the company and employees of Mr. Bachani sit in the office of the company. The CA of the company manages the trading and banking account of Noticee 1.

35.3. He is not aware of his trades in the scrip of Quasar India Limited.

35.4. He doesn’t know any of the other persons (viz. the entities) or any of the firms which were found to be common among entities.

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• Statement recording of Mr. Gaurav Bachani: I note that Noticee 1 was having banking transactions with several entities and in order to ascertain the functioning and management of the financial activities of the company, Mr. Gaurav Bachani, who is secretarial auditor of Noticee 1, was summoned for statement recording. Vide summon dated June 06, 2024, 2024, Mr. Gaurav Bachani was advised to appear before the IA for statement recording on June 13, 2024, however, Mr. Gaurav Bachani, requested for statement recording to be conducted on June 11, 2024. The request was acceded to by IA and he was advised to appear on June 11, 2024 for statement recording. The submissions of Mr. Gaurav Bachani in his recorded, inter-alia, are as under:

36.1. He is a CS and owns a CS firm viz. M/s Gaurav Bachani & Associates.

36.2. He works as Secretarial Auditor of Noticee 1 since 2019-20. His work for the company is limited to filing compliance related reports.

36.3. He knows Noticee 2 as a director of Noticee 1. He meets Noticee 2 1-2 times a month at his firm’s office for company related work. Apart from Noticee 2, he knows the two independent directors of company viz. Mr. Pranav Vajani and Mr. Ziral Soni, both of whom are also company secretary and he has professional relation with them.

36.4. He submitted that Noticee 1 has no business operations and he or his employees do not visit the office of the company.

36.5. He is not aware of the trading done by Noticee 1 and any of the bank transactions done by the company.

36.6. He is not getting any remuneration for his CS services from Noticee 1 and has no business association with the company.

36.7. He doesn’t know any of the entities or any of the firms found to be common among entities in their bank statements.

• Further, for query as to why he was rendering his services to Noticee 1 without any fees or remuneration, he did not give any reply. Also, he submitted that mobile

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number 9016614449 belongs to his firm and he is not aware of any call from this mob number to Noticee 6.

• Observations/inferences from recorded statements:

38.1. Noticee 2 and Mr. Gaurav Bachani, both gave contradictory submissions in their statements with respect to the handling of the business operations of Noticee 1 and denied any trading done by them on behalf of company or any bank transactions executed by the company.

38.2. Both, Noticee 2 and Mr. Gaurav Bachani denied their connection with any of the entities or common entities. However, bank transactions have been observed between Noticee 2 with entities and common entities as well as call data records with entities. Further, there is also a call observed between Mr. Gaurav Bachani and one of the entity.

38.3. Mr. Gaurav Bachani, is lending his CS services to Noticee 1 without any remuneration or fees. This is very unusual as no CS or CA firm will offer its services to a company without any consideration.

38.4. Both, Noticee 2 and Mr. Gaurav Bachani deliberately did not provide correct information and misled the investigation and thus aided in concealing the true facts and information which could have helped in investigation.

• In view of the foregoing observations, I note that Noticee 2 along with Noticees 19 and 20 were operating the trading and banking accounts of the entities for trading in the scrip of Quasar and manipulating the scrip by generating high volumes and rise in price of the scrip of Quasar and thus, making a profit of Rs 1.96 Crores. Further, Noticees 1 and Noticees 3 to 18 aided and abetted Noticees 2, 19 and 20 for manipulating the scrip of Quasar by lending their trading and bank accounts and thus, were involved in fraud of manipulating the scrip of Quasar. The high volume and price rise in the scrip of Quasar misled the gullible investors and attracted them for trading in the shares of Quasar and such manipulation in the scrip of Quasar was detrimental for the overall securities market.

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• Noticees 1 and 2 contended that their trading was miniscule in comparison to the total market volume, and such trading cannot have any impact on the market. I note that Noticees 1 and 2, along with other Noticees contributed 16.86% to buy volume and 19.74% to sell volume in the scrip of Quasar during IP. The entities were found to be connected to each other and were indulged in generating the volume in the scrip of Quasar resulting in price rise of the scrip. Thus, trading by Noticee 1 or 2 has been considered collectively for all the Noticees and not individually. Therefore, Noticee 1 and 2’s contention cannot be accepted.

• Noticees 1 and 2 submitted that the trading and investment decisions were taken by them based on the market dynamics, technical analysis and potential intra-day movements. I note that the SCN clearly states the amount of substantial gains made by the Noticees within a short period in equity trades, without any substantial news or development in the operations of Quasar India Limited. Noticees 1 and 2 did not provide any reasons for their choice to trade in the scrip, and only stated that their decisions were based on technical analysis. In the absence of such reasons, and on the basis of their connections with other Noticees, IP based connections, geo-location analysis of mobile numbers of entities, I find that the Noticees artificially traded in a scarcely traded scrip, thereby contributing to volume in the scrip of Quasar during the IP and misleading the gullible investors to trade in the scrip. Therefore, I find that the submissions are vague, and not acceptable.

• Noticees 1 and 2 submitted that they do not have any direct or indirect contact with the promoters of Quasar India Limited. I note that there is no such allegation made out against them in the SCN.

• Noticees 1 and 2 also submitted that one of the primary reasons for engaging in the shares of Quasar was the higher trading volumes observed on certain days. In this regard, I note from the SCN that during Patch 1, 9 entities, including Noticees 1 and 2, collectively generated around 75% volume (7,82,174 shares) to the total market volume in the scrip of Quasar for all the 16 high volume trading days of

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Quasar. Further, in Patch 2, the scrip of Quasar traded for 40 trading days wherein 31 trading days observed high volumes and there was a substantial price rise observed. During this Patch, 9 entities of Patch 1, initially began trading among themselves and then subsequently were joined by remaining 9 entities for trading in the scrip of Quasar. Together, the 18 entities traded amongst themselves and either on buy/sell side and artificially contributed to the high volume in the scrip of Quasar for 23 trading days out of total 31 high volume trading days. The high volume generation also resulted in rise in the price of the scrip of Quasar which was misleading and attracted the normal investors to trade in scrip of Quasar. Thus, I note that the 18 entities, including Noticees 1 and 2, are responsible for generating volume in the scrip of Quasar. Therefore, the submissions that they traded in the scrip after observing high trading volumes cannot be accepted.

• Noticees 1 and 2 submitted that in order to allege creation of artificial price and volume, the entities should be shown connected to each other. They also submitted that mere fund transfers between them and their counterparties cannot be considered as connection between them, as the transactions were in normal course of business. I note that the fund transfers at the least show the acquaintance of Noticees 1 and 2 with their counterparties. I also note that Noticees 1 and 2 had common phone calls, fund transfers, common geolocation, and also common IP with other entities. Thus, the contention of Noticee 1 and 2 that no connection has been shown or no evidence is placed on record to show connections among entities, cannot be accepted.

• Noticees 1 and 2 further submitted that there was hearsay news in the APMC market, Ahmedabad, that Quasar will be acquired by Shah Group (Ahmedabad based commodity merchant), and for this reason, Noticees 1 and 2 and perhaps the other Noticees too, who appear to be working in and around APMC had also traded in the scrip. However, when Noticees 1 and 2 found that Quasar will not be acquired by Shah group, they sold the shares. In this regard, I note that Noticees

1 and 2 did not provide the specifics in support of their submission as to when the

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two news had surfaced. I also note that Noticees 1 and 2 were holding the shares of Quasar for some months, and also did various intra-day transactions and thereafter sold the shares at high profits after substantial increase in the volumes and price of the shares of Quasar. I further note that Noticees 1 and 2 have not convincingly demonstrated the rationale, technical or otherwise, behind their trading in the scrip of Quasar. Also, they are connected with other entities who were also responsible for artificial volume creation and circular trades. Therefore, the submissions of the hearsay news appear to be after-thought, and therefore, cannot be accepted.

• Noticees 1 and 2 submitted that Ahmedabad covers an area of 505km, and the range of a network tower cannot be the basis to allege connections among the Noticees. I note that geo-location is not the sole basis to alleged connections. The Noticees are connected through common calls, IPs, geo-location, mobile numbers, timing. All the connections have already been brought out in the previous paragraphs and were also stated in the SCN. In view of the same, Noticees 1 and

2’s submissions cannot be accepted.

• The findings in the foregoing paragraphs are summarised below:

47.1. The 18 entities (Noticees 1 to 18) and Noticees 19 and 20 were found to be connected to each other and were indulged in generating the volume in the scrip of Quasar resulting in price rise of the scrip. Further, the entities viz. the 1% shareholders of Quasar in connivance with other entities were key perpetrators in manipulating the scrip of Quasar and thus misled the investors into investing in scrip of Quasar which otherwise was very thinly traded.

47.2. Therefore, the allegation that Noticees 1 to 18 have violated the provisions of Section 12A (a), (b) and (c) of SEBI Act read with Regulations, 3(a), (b), (c), (d), 4(1), 4(2)(a) and 4(2)(b) and 4(2)(e) of PFUTP Regulations, stands established.

47.3. Also, as Noticees 19 and 20 aided and abetted Noticee 2 in manipulating the scrip of Quasar, the allegation that they have violated the provisions of Section

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12A (a), (b) and (c) of SEBI Act read with Regulations 3(a), (b), (c), (d), 4(1), and 4(2)(a) of PFUTP Regulations, stands established.

47.4. Noticees 2, 3, 5, 7, 11, 12, 13, 15 and 16, by entering into circular trades have created a misleading appearance of trading in the scrip by trading among themselves in the share of Quasar without any intention of change of ownership of the security and provide a false appearance of trading in such security to inflate or cause fluctuations in the price of Quasar. Therefore, the allegation against Noticees 2, 3, 5, 7, 11, 12, 13, 15 and 16, that they have violated the provisions of Section 12A (a), (b) and (c) of SEBI Act read with Regulations 3(a), (b), (c), (d), 4(1), 4(2)(a), 4 (2)(b), 4(2)(e), 4(2)(g) and 4(2)(n) of PFUTP Regulations, stands established.

• Hampering the process of investigation –

48.1. I note that Noticee 20 was having banking transactions with Noticees 11, 12,

13 and 15 and Noticee 19 (who was operating bank accounts of Noticees 11,

12, 13 and 15).

48.2. Therefore, summons were issued to them on July 31, 2024, September 26, 2024 and October 03, 2024. However, Noticees 19 and 20 did not appear for statement recording even after multiple summons were issued to them. This has hampered the process of investigation in ascertaining more facts and information.

48.3. I note that Noticees have been alleged to have violated the provisions of Section 11C(3) of SEBI Act for not appearing upon issuance of multiple summons. However, Section 11C(3) of SEBI Act pertains to not furnishing of information sought by the Investigating Authority. I note that not appearing before the investigating authority upon issuance of the summons attracts violation of provisions of Section 11C(5) of the SEBI Act, and accordingly the same is being considered.

48.4. Therefore, I find that Noticees 19 and 20 have violated the provisions of Section 11C(5) of SEBI Act.

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ISSUE II – Do the violations, if any, attract penalty u/s 15HA and 15A(a) of the SEBI Act?

• I note that since the above violations are established, the Noticees are liable for monetary penalty u/s 15HA and 15A(a) of the SEBI Act, as applicable, the text of which is reproduced hereunder:

SEBI Act

Penalty for failure to furnish information, return, etc.

15A. If any person, who is required under this Act or any rules or regulations madethereunder,—

• to furnish any document, return or report to the Board, fails to furnish the same or who furnishes or files false, incorrect or incomplete information, return, report, books or other documents, he shall be liable to a penalty which shall not be less than one lakh rupees but which may extend to one lakh rupees for each day during which such failure continues subject to a maximum of one crore rupees;

Penalty for fraudulent and unfair trade practices.

15HA. If any person indulges in fraudulent and unfair trade practices relating tosecurities, he shall be liable to a penalty 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 III – If so, what would be the monetary penalty that can be imposed taking into consideration the factors mentioned in Section 15J of SEBI Act?

• While determining the quantum of penalty u/s 15HA and 15A(a) of the SEBI Act, it is important to consider the factors stipulated in Section 15J of the SEBI Act, which read as under:

SEBI Act

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;

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• the amount of loss caused to an investor or group of investors as a result of the default;

• the repetitive nature of the default.

• In the present matter, I note that Noticees 1 to 18 collectively made profit of Rs. 1.96 crores by trading in the scrip of Quasar during the IP. No quantifiable figures are available to assess the disproportionate gain or unfair advantage made as a result of the defaults by Noticees 19 and 20. Further, from the material available on record, it is not possible to ascertain the exact monetary loss to the investors /clients on account of default by the Noticees. As per the available records, I note that Noticee 19 has been penalised earlier under Section 15HA and 15A(a) of SEBI Act. Therefore, suitable penalty must be imposed for non-compliances in order to ensure that the violations can be prevented in future.

ORDER

• Having considered all the facts and circumstances of the case including delay in issuing of SCN, the material available on record, time value of the unlawful gain, submissions made by Noticees 1 and 2, and the factors mentioned in Section 15J of the SEBI Act, in light of judgment of the Hon’ble Supreme Court in SEBI vs. Bhavesh Pabari (2019) 5 SCC 90, in exercise of power conferred u/s 15-I of the SEBI Act r/w Rule 5 of the SEBI Adjudication Rules, I impose the following penalty

upon the Noticees for the violations as mentioned hereunder.

	Noticee	Name of Noticee	Provisions violated	Penalty	Penalty Amount
	No.			under
	2	Pranav Kamlesh kumar	Section  12A  (a),  (b)	Section	Rs.	2,50,00,000/-
		Trivedi	and (c) of SEBI Act r/w	15HA of	(Rs.	Two	Crore
			Regulations  3(a),  (b),	SEBI	Fifty Lakhs Only) to
	3	Nayan Mahendrabhai
		Thakkar	(c), (d), 4(1), 4(2)(a), 4	Act	be paid jointly and
			(2)(b), 4(2)(e), 4(2)(g)		severally			by
	5	Jigneshkumar P. Patel
			and 4(2)(n) of PFUTP		Noticees 1 to 18
	7	Ankit Ajitbhai Panchal
			Regulations.
	11	Parth Rajanikant
		Pandya

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Noticee	Name of Noticee	Provisions violated    PenaltyPenalty Amount
No.		under

1. Manish Jethabhai Bhaskar

1. Nitinkumar Lalji Bhai Bharvad

1. Narmadaben Pravinbhai Parmar

1. Pravinbhai Lakhabhai Parmar

1	Chandrima Mercantiles	Section  12A	(a),  (b)
	Limited	and (c) of SEBI Act r/w
		Regulations, 3(a), (b),
4	Kuntal Jitendra Trivedi
		(c),  (d),  4(1),	4(2)(a)
6	Rohit Bairwa
		and 4(2)(b) and 4(2)(e)
8	Hardik Himmatbhai
	Munjpara	of	PFUTP
		Regulations.
9	Jagdish Chhanabhai
	Vaghela
10	Usha Devi

1. Babubhai Bhikhaji Godha

1. Shvetalben Sagarbhai Dataniya

1. Sagarkumar P. Dataniya

19		Mrugesh	Natwarlal	Section  12A  (a),  (b)		Section		Rs. 7,00,000/- (Rs.
		Ruparel		and (c) of SEBI Act r/w		15HA		Seven Lakhs Only)
				Regulations, 3(a), (b),		and 15A
20		Arpit Piyushbhai Shah						Rs. 7,00,000/- (Rs.
				(c), (d), 4(1), 4(2)(a);		(a)	of	Seven Lakhs Only)
				Section 11C(5) of SEBI		SEBI
				Act.		Act
Adjudication Order in the matter of price and volume manipulation in the scrip of Quasar India Limited								Page 55 of 56

I find the said penalty to be commensurate with the violation on the part of the Noticees.

• Noticees shall remit / pay the said amount of penalty within 45 days of receipt of this order 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 ^à Orders ^à Orders of AO ^à PAY NOW.

• 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 u/s 28A of the SEBI Act for realization of the said amount of penalty along with interest thereon, inter alia, by attachment and sale of movable and immovable properties.

• In terms of Rule 6 of the SEBI Adjudication Rules, copy of this order is sent to the the Noticees and also to SEBI.

	AMIT	Digitally signed
		by AMIT
		KAPOOR
	KAPOORDate: 2025.10.31
		18:21:11 +05’30’
DATE: OCTOBER 31, 2025		AMIT KAPOOR
PLACE: MUMBAI	ADJUDICATING OFFICER

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