Securities and Exchange Board of India SEBI Bhavan, Plot No. C4A, GBlock, Bandra Kurla Complex, Mumbai 400 051. ...Respondent Mr. Somasekhar Sundaresan, Advocate with Mr. Abishek Venkataraman and Ms. Arti Raghavan, Advocates for the Appellant. Mr. Kumar Desai, Advocate with Mr. Pulkit Sukhramani, Advocate for the Respondent. CORAM : Justice J. P. Devadhar, Presiding Officer A. S. Lamba, Member Per : A.S. Lamba 1. The present appeal has been preferred by Angel Broking Private Limited (ABPL), formerly Angel Broking Limited, (referred to hereinafter as "Appellant") against Order number BM/AO169170/2013 dated December 30, 2013 of Ld. Adjudicating Officer (AO), Securities and Exchange Board of India (SEBI for short), for imposition of penalty of Rs. 10 lac on ABPL under Section 15HA of Securities and Exchange Board of India Act, 1992 (SEBI Act for short) for violation of Regulation 3(a), 4(1) and 4(2)(a), (b), (e) and (g) of Securities and Exchange Board of India 2 (Prohibition of Fraudulent and Unfair Trade Practices Relating to Securities Market) Regulations, 2003 (PFUTP Regulations for short), Rs. 10 lac on ABPL under Section 15HB of SEBI Act for violation of Regulation 7 read with Clause A(1), A(3), A(4) and A(5) of Code of Conduct for Stock Brokers under Securities and Exchange Board of India (StockBrokers and SubBrokers) Regulations, 1992 (StockBrokers Regulations for short) and imposition of penalty of Rs. 10 lac on AIPL under Section 15HA of SEBI Act for violation of Regulation 3(a), 4(1) and 4(2)(a), (b), (e) and (g) of PFUTP Regulations. 2. SEBI investigated trading in scrip of Sterling Green Wood Limited (SGWL or company, for short) from November 6, 2009 to December 2, 2009 (IP for short), during which price of scrip of SGWL increased from Rs. 19.80 as on November 6, 2009 to Rs. 42.50 as on December 31, 2009, with average daily volume of 69,776 shares. 3. From shareholding pattern of SGWL, it is seen that ABPL was holding more than 1% shares of SGWL as on September 30, 2009. AIPL was the holding company of ABPL; although AIPL was also acting as broker for proprietary trading account of Angel Group,which comprised ABPL, AIPL, Angel Capital and Debt Market Limited and Angel Commodities Broking Private Limited. AIPL a client of ABPL was found to be executing self trades in scrip of SGWL during IP and executed 1 (one) self trade on November 30, 2009 and 3 (three) self trades on December 1, 2009 and traded 9,866 shares in these 4 self trades, where broker and counter party brokers for selftrades was ABPL. It is alleged that ABPL consciously executed selftrades for its client AIPL and hence ABPL connived with AIPL for these self trades. 3 4. A Show Cause Notice (SCN) was issued by Ld. AO to Appellant vide letter dated July 15, 2013 and Appellant made following relevant submissions before Ld. AO:  Basic nature of AIPL's activity was jobbing / arbitrage, which is undertaken through a network of around 70 dealers and all these 70 dealers place orders through single client code viz. M888, while using 156 terminals.  Regarding alleged self trades by AIPL, it has been submitted by AIPL that multiple dealers traded based on their individual outlook of market / stock and that traders buy / sell stocks based on their bullish / bearish view and it is possible that while one dealer may place buy order for a scrip, while another dealer place sell order for same scrip and hence alleged selftrades are purely coincidental and not outcome of any design and hence such trades may appear selftrades on consolidated basis, but are separate and independent trades at individual level.  Regarding alleged self trade of November 30, 2009 in which 193 shares were matched , it is submitted that buy trade was from terminal number 553 and sell trade from terminal no. 556; which implies jobbing activity, wherein, more than one dealer carried out this trade. It is further submitted that the two dealers had placed buy quantity at 500, while sell quantity was 400, but only 193 shares got t