If any person indulges in unfair trade practices relating to securities, the monetary penalty should be imposed under 15HA of SEBI act -THE SECURITIES AND EXCHANGE BOARD OF INDIA

BEFORE THE ADJUDICATING OFFICER SECURITIES AND EXCHANGE BOARD OF INDIA ADJUDICATION ORDER NO. Order BM UR 2021 22 14819] UNDER SECTION 15 I OF SECURITIES AND EXCHANGE BOARD OF INDIA ACT 1992 READ WITH RULE 5 OF SEBIRULES 1995. In respect of Kasturi Aich PAN: ACCPA1896N) In the matter of Trading in Illiquid Stock Options on BSE BACKGROUND OF THE CASE 1. Securities and Exchange Board of India observed large scale reversal of trades in stock options segment of Bombay Stock Exchange (hereinafter referred to as the “Noticee”) was one of the various entities who indulged in execution of reversal trades in stock options segment of BSE during the IP. Such trades were observed to be non genuine in nature and created false or misleading appearance of trading in terms of artificial volumes in stock options and therefore were alleged to be manipulative deceptive in nature. In view of the same SEBI initiated adjudication proceedings against the Noticee for violation of the provisions of Regulations 3(a) (c) 4(1) and 4(2)(a) of SEBI Prohibition of Fraudulent and Unfair Trade Practices) Regulations 2003 hereinafter referred to as “PFUTP Regulations 2003”). APPOINTMENT OF ADJUDICATING OFFICER The undersigned was appointed as Adjudicating Officer in the matter conveyed vide communique dated September 27 2021 under Section 19 read with Section 15 I(1) of the Securities and Exchange Board of India Act 1992 hereinafter referred to as “SEBI Act 1992”) and Rule 3 of SEBIRules 1995to conduct adjudication proceedings in the manner specified under Rule 4 of Adjudication Rules read with Section 15 I(1) andof SEBI Act 1992 and if satisfied that penalty is liable impose such penalty as deemed fit in terms of Rule 5 of Adjudication Rules and Section 15HA of SEBI Act 1992. SHOW CAUSE NOTICE REPLY AND HEARING 4. A Show Cause Notice dated October 21 2021was issued to the Noticee under Rule 4(1) of the Adjudication Rules to show cause as to why an inquiry should not be initiated against her and why penalty should not be imposed under section 15HA of the SEBI Act 1992 for the violations alleged to have been committed by Noticee. It was inter alia alleged in the SCN that the Noticee had executed 2 non genuine trades in 1 Stock Options contract which resulted in artificial volume of total 50 000 units. Summary of dealings of the Noticee in the said Options contracts in which the Noticee allegedly executed non genuine trades during the I.P is as Contract No. of No. of of of Non of trades of in the Noticee in in the Noticee s to Total Noticee s trades in in the Volume in of by Noticee in the to Total Volume in VEDL15MAY250.00PE 35 25000 55.45 From the above table following was noted as regard to dealings of the Noticee: a) The Noticee had executed non genuine trades in 1 contract wherein 100% of all trades of Noticee in the said contract were non genuine b) No. of non genuine trades of the Noticee had significantly contributed to total no. of trades from the market in the above contract as 6.67% of the trades that happened in the said contract were due to non genuine trades executed by the Noticee. c) 100% of volume generated by Noticee in the above contract was artificial volume and further the percentage of artificial volume generated by the Noticee in the above contract to the total volume from the market in said contract was 10.31%. Therefore the Noticee allegedly generated artificial volume in the above contract. The SCN with reference no. EAD 3 BM UR ISO II 29382 2021 was served on the Noticee via Speed Post Acknowledgement Dueand via email dated October 21 2021. The proof of service is on record. Vide email dated November 30 2021 Noticee submitted reply to the SCN and vide email dated December 21 2021 Noticee through her Authorized Representative submitted additional submissions pursuant to hearing. The main contentions made in the aforesaid reply are summarized below: She executed trades which were purely speculative trades that were carried out by her broker. Noticee contended that it is purely coincidental that the counterparty was the same for both legs and emphasized that she has no dealings with the counterparty in this regard. She also submitted that she has no clue of the counterparty in the trade. Noticee contended that if any such contract were illiquid and were not supposed to be traded then the onus was on the BSE exchange and the broker to restrict the clients through adequate surveillance measures in their system. She has also filed Income tax return for all the tranactions carried out in the said Financial year. 8. Hearing Notice dated November 30 2021 was issued to the Noticee advising her to appear for the hearing on December 15 2021. The personal hearing was conducted on scheduled date and time through video conferencing. The Noticee was represented by her Authorized Representative. During the course of hearing the authorized representative reiterated submissions made by her vide email dated November 30 2021. He also made additional submissions on behalf of the Noticee vide email dated December 21 2021. The personal hearing in the matter was completed and hearing minutes are on record. CONSIDERATION OF ISSUES AND FINDINGS I have carefully perused the charges levelled against the Noticee her reply and the documents material available on record. The issues that arise for consideration in the present case are: a) Whether the Noticee has violated provisions of Regulations 3(a) (c) d) 4(1) and 4(2)(a) of PFUTP Regulations 2003 b) Does the violation if any attract monetary penalty under section 15HA of the SEBI Act 1992 If so what would be the quantum of monetary penalty that can be imposed on the Noticee after taking into consideration the factors mentioned in section 15J of the SEBI Act 1992 10. Before proceeding further I would like to refer to the relevant provisions of the PFUTP Regulations 2003 as below: PFUTP Regulations 2003 3. Prohibition of certain dealings in securities No person shall directly or indirectly— a) buy sell or otherwise deal in securities in a fraudulent manner b) use or employ in connection with issue purchase or sale of any security listed or proposed to be listed in a recognized stock exchange any manipulative or deceptive device or contrivance in contravention of the provisions of the Act or the rules or the regulations made there under c) employ any device scheme or artifice to defraud in connection with dealing in or issue of securities which are listed or proposed to be listed on a recognized stock exchange d) engage in any act practice course of business which operates or would operate as fraud or deceit upon any person in connection with any dealing in or issue of securities which are listed or proposed to be listed on a recognized stock exchange in contravention of the provisions of the Act or the rules and the regulations made there 4. Prohibition of manipulative fraudulent and unfair trade practices 1) Without prejudice to the provisions of regulation 3 no person shall indulge in a fraudulent or an unfair trade practice in securities. 2) Dealing in securities shall be deemed to be a fraudulent or an unfair trade practice if it involves fraud and may include all or any of the following namely:— a) indulging in an act which creates false or misleading appearance of trading in the securities market 2003 Issue No 1 : Whether the Noticee has violated provisions of Regulations 3(a) (c) and Regulation 4(1) & 4(2)(a) of PFUTP Regulations I note that allegation against the Noticee is that while dealing in the stock option contracts at BSE during the IP she had executed reversal trades which were allegedly non genuine and the same had resulted in generation of artificial volume in stock option contracts at BSE. Reversal trades are considered to be those trades in which an entity reverses its buy or sell positions in a contract with subsequent sell or buy positions with the same counterparty during the same day. The said reversal trades are alleged to be non genuine trades as they are not executed in the normal course of trading lack basic trading rationale lead to false or misleading appearance of trading in terms of generation of artificial volumes and hence are deceptive and manipulative. I shall now proceed to deal with the transactions executed by the Noticee in the alleged non genuine trades. 13. I note from the trade log of the Noticee that she had traded in one contract in the stock options segment of BSE during the IP. It is observed that the Noticee had executed 2 non genuine trades in 1 contract. I further note that the above mentioned trades of the Noticee had resulted in the creation of artificial volume of 50000 units in the said contract. Summary of non genuine trades of the Noticee is as follows: Contract Name No. of trades of Noticee in the contract No. of to Noticee s Total trades of Non in the of of of Non trades of by Noticee in the in the Noticee in contract to to Total Noticee s trades in to Total Volume in Volume in VEDL15MAY250.00PE 35 25000 55.45 25000 100 I further note that pursuant to a preliminary examination conducted in the Illiquid Stock Options matter interim order was passed by SEBI on August 20 2015 which was confirmed vide Orders dated July 30 2016 and August 22 2016. Meanwhile SEBI initiated a detailed investigation relating to stock options segment of BSE which was completed in the year 2018. The investigation revealed that 14 720 entities were involved in executing non genuine trades in BSE’s stock option segment during the investigation period. The proceedings initiated vide the aforementioned Interim Order were disposed of vide Final Order dated April 05 2018 also considering that appropriate action was initiated against the said 14 720 entities in a phased manner. During the course of hearing in the case of R. S. Ispat Ltd Vs SEBI the Hon’ble Securities Appellate Tribunalvide its Order dated October 14 2019 inter alia observed that: “SEBI may consider holding a Lok Adalat or adopting any other alternative dispute resolution process with regard to the Illiquid Stock Options”. A Settlement Scheme was framed under the SEBI Regulations 2018 which provided one time opportunity for settlement of proceedings in the Illiquid Stock Options matter. The said scheme was kept open from August 01 2020 till December 31 2020. Subsequently adjudication proceedings were initiated against those entities who had not availed of the opportunity of settlement. As can be seen from the narration of facts in the foregoing paragraphs pursuant to appointment of AO in the matter conveyed vide communique dated September 27 2021 SCN was issued on October 21 2021. In compliance with principles of natural justice after receipt of reply an opportunity of personal hearing was scheduled on December 15 2021 and upon conclusion of hearing additional written submissions were received from the Noticee on December 21 15. It is noted that the Noticee had executed non genuine trades in said contract wherein the percentage of non genuine trades of the Noticee in stock options contract to total trades in the contract was 6.67% in the aforesaid contract. Further the alleged artificial volume generated by Noticee in the contract amounted to 100% of total volume generated by her in the contract. It is also noted that artificial volume generated by the Noticee contributed 10.31% of the total volume from the market in the said contract. 16. The details of squaring up done by the Noticee the contract ‘VEDL15MAY250.00PE’ are as given below : Trade Date CP Client l by the Kasturi Aich Ajeit P.S 35 25000 Rajbans Huf Kasturi Aich 55.45 25000 Ajeit P.S Rajbans Huf I note from the trade log that the trades executed by the Noticee in a contract were squared up within a short span of time with her counterparties. To illustrate the Noticee on May 28 2015 entered into 1 buy trade of 25000 units of contract “VEDL15MAY250.00PE’” at 13:04:13 hrsat the rate of Rs 35 per unit with counterparty viz. Ajeit P.S Rajbans Huf. Thereafter on the same day Noticee at 13:11:48 hrs Order time of Noticee: 13:11:48 and Counterparty Order time: 13:11:48) entered into 1 sell trade with same counterparty for 25000 units at the rate of Rs. 55.45 per unit in the same contract. It is noted that while dealing in the said contract during the I.P. the Noticee executed reversal trades with same counterparty viz. Ajeit P.S Rajbans Huf on the same day. Thus the Noticee through her dealing in the contract viz. ‘VEDL15MAY250.00PE’ during the I.P. executed non genuine trades which was 6.67% of the total trades from the market in the said contract during the I.P. and thereby Noticee generated artificial volume of 50000 units which was 10.31% of the volume traded in the said contract from the market during the I.P. I note that the abovementioned trades of the Noticee had resulted in the creation of artificial volume of a total of 50 000 units in the given contract. 16. The non genuineness of these transactions executed by the Noticee is evident from the fact that there was no commercial basis as to why within a short span of time the Noticee reversed the position with her counterparty with significant price difference. The fact that the transactions in a particular contract were reversed with the same counterparty indicates a prior meeting of minds with a view to execute the reversal trades at a pre determined price. Since these trades were done in illiquid option contract there was negligible trading in the said contract and hence there was no price discovery in the strictest terms. There was no significant change in the price of the underlying scrip to justify the wide variation in prices of the said contracts. The wide variation in prices of the said contracts within such a short span of time is a clear indication that there was pre determination in the prices by the counterparties while executing the trades. Thus it is observed that Noticee had indulged in reversal trades with the counterparties in the stock options segment of BSE and the same were non genuine trades. 17. Noticee has interalia contended she executed trades which were purely speculative trades that were carried out by her broker. I note that Noticee was owner of the trading account through which impugned trades were carried out. Therefore the obligation to ensure genuineness of impugned trades lay with the Noticee and thus the aforesaid contentions of Noticee are without merits. 18. Noticee contended that it is purely coincidental that the counterparty was the same for both legs and emphasized that she has no dealings with the counterparty in this regard. She also submitted that she had no clue of the counterparty in the trade. I note that considering the precision at which the reversal transactions have taken place i.e. synchronisation of the quantity order price and order time and sale with price variations as observed in the instant matter the same couldn’t have been possible without prior meeting of mind In this regard I find it relevant to refer to the decision of Hon’ble Supreme Court in the matter of SEBI vs. Rakhi Trading Private Ltd. in Civil appeals no. 1969 of 2011 decided on February 8 2018 wherein it has been held as under “considering the reversal transactions quantity price and time and sale parties being persistent in the number of such trade transactions with huge price variations it will be too naïve to hold that the transactions are through screen based trading and hence anonymous. Such conclusion would be over looking the prior meeting of minds involving synchronization of buy and sell order and not negotiated deals as per the Board s circular. The impugned transactions are manipulative deceptive device to create a desired loss and or profit. Such synchronized trading is violative of transparent norms of trading in securities” 18(a).The Hon’ble Supreme Court has also held in the aforesaid Judgment that the price discovery system itself was affected by synchronization and rapid reverse trade which also had the impact of excluding other investors from participating in the market. The Supreme Court therefore found that the traders having engaged in a fraudulent and unfair trade practice while dealing in securities are hence liable to be proceeded against for violation of Regulations 3(a) 4(1) and 4(2)(a) of the PFUTP Regulations 2003. 18(b).The Hon’ble SAT in its judgment dated September 14 2020 in the matter of Global Earth Properties and Developers Pvt Ltd Vs SEBIalso relied upon the aforesaid judgment of the Hon’ble Supreme Court and held that “...It is not a mere coincidence that the Appellants could match the trades with the counter party with whom he had undertaken the first leg of respective trade. In our opinion the trades were non genuine trades and even though direct evidence is not available in the instant case but in the peculiar facts and circumstances of the present case there is an irresistible inference that can be drawn that there was meeting of minds between the Appellants and the counter parties and collusion with a view to trade at a predetermined 18(c).The Hon’ble SAT reaffirmed its stand taken in Global Earth Properties and Developers Pvt Ltd Vs SEBIin itsjudgment dated November 24 2021 in the matter of Radha Malani vs. SEBIhas held the following: “Having heard the learned counsel for the appellant in our view the controversy involved in the present appeal is squarely covered by a decision of this Tribunal in Global Earth Properties and Developers Pvt. Ltd. vs. SEBIwith the same counterparty with whom Noticee had undertaken first leg of the respective trades. It indicates meeting of minds. In this context I would like to rely on the judgment of the Hon’ble Supreme Court of India in SEBI Vs Kishore R Ajmerawherein it was held that “...in the absence of direct proof of meeting of minds elsewhere in synchronized transactions the test should be one of preponderance of probabilities as far as adjudication of civil liability arising out of the violation of the Act or provision of the Regulations is concerned. The conclusion has to be gathered from various circumstances like that volume of the trade effected the period of persistence in trading in the particular scrip the particulars of the buy and sell orders namely the volume thereof the proximity of time between the two and such other relevant factors. The illustrations are not exhaustive...” 18(f).The Hon’ble Supreme Court further held in the said case that “...It is a fundamental principle of law that proof of an allegation levelled against a person may be in the form of direct substantive evidence or as in many cases such proof may have to be inferred by a logical process of reasoning from the totality of the attending facts and circumstances surrounding the allegations charges made and levelled. While direct evidence is a more certain basis to come to a conclusion yet in the absence thereof the Courts cannot be helpless. It is the judicial duty to take note of the immediate and proximate facts and circumstances surrounding the events on which the charges allegations are founded and to reach what would appear to the Court to be a reasonable conclusion therefrom. The test would always be that what inferential process that a reasonable prudent man would adopt to arrive at a conclusion.” 18(g).In the instant matter I note that though direct evidence regarding meeting of minds or collusion of the Noticee with the counterparty is not forthcoming the trading behavior of the Noticee makes it clear that the aforesaid non genuine trades could not have been possible without meeting of minds at some level. In this context I deem it appropriate to refer to the order dated July 14 2006 passed by Hon’ble SAT in the case of Ketan Parekh vs. SEBIwherein Hon’ble SAT has held that: The nature of transactions executed the frequency with which such transactions are undertaken the value of the transactions the conditions then prevailing in the market are some of the factors which go to show the intention of the parties. This list of factors in the very nature of things cannot be exhaustive. Any one factor may or may not be decisive and it is from the cumulative effect of these that an inference will have to be drawn." 18(h).Further I would like to rely on the judgement of Hon’ble Supreme Court passed in the case of SEBI vs. Rakhi Trading Private Ltd. wherein the Apex Court held that “the entities were engaged in a fraudulent and unfair trade practice while dealing in Options and hence were liable for violation of SEBI Regulations”. The Hon’ble Apex Court has also held that in the absence of direct proof of meeting of minds the test should be one of preponderance of probability and also stated that the conclusion has to be gathered from various circumstances like volume of trade period of persistence of trading particulars of buy and sell orders proximity of time between the two and such other relevant factors. 18(i).In line with the aforesaid judgements of Hon’ble SAT and Hon’ble Supreme Court I note from the foregoing findings that the trading pattern of the Noticee in terms of volume of reversal trades proximity of buy sell and subsequent reversal evidences the indulgence of the Noticee beyond a reasonable doubt of the manipulative intent in creation of artificial volume. Further the dealings by Noticee only in such options contracts which was illiquid clearly demonstrates the manipulative intent to use stock exchange platform to carry out non genuine trades with the aim to execute such trades for manipulative 18(j).In this regard I would like to rely on the judgement of Hon’ble Supreme Court in the matter of SEBI vs. Rakhi Trading Private Ltd.(supra) decided on February 8 2018 where Apex Court held that “The stock market is not a platform for any fraudulent or unfair trade practice. The field is open to all the investors. By synchronization and rapid reverse trade as has been carried out by the traders in the instant case the price discovery system itself is affected. Except the parties who have pre fixed the price nobody is in the position to participate in the trade. It also has an adverse impact on the fairness integrity and transparency of the stock market.” 19. Noticee contended that if any such contract were illiquid and were not supposed to be traded then the onus was on the BSE exchange and the broker to restrict the clients through adequate surveillance measures in their system. I note that the Noticee’s contentions imply that there is no dispute that the impugned trades were definitely executed by the Noticee. I note that Noticee was obligated to ensure genuineness of the trades executed by him on the exchange platform. The aforesaid obligation was mandatory notwithstanding any surveillance measures to be undertaken by BSE or broker. The Noticee’s contention reveals that she had executed the impugned trades which generated artificial volume as demonstrated by the trade log. Thus the Noticee’s contentions do not establish any denial of the charges made in the SCN. 20. She contended that she has also filed Income tax return for all the transactions carried out in the said financial year. I note from the above that the said transactions are not in question but genuineness of trades is in question. Thus the contention of notice is not maintainable. 21. Therefore the trading behaviour of the Noticee confirms that such trades were not normal indicating that the trades executed by the Noticee were not genuine trades and being non genuine created an appearance of artificial trading volumes in respective contracts. In view of the above I find that the allegation of violation of regulations 3(a) (c) 4(1) and 4(2)(a) of PFUTP Regulations 2003 by the Noticee stands established. Issue No 2: Does the violation if any attract monetary penalty under Section 15HA of the SEBI Act 1992 22. Considering the findings that the Noticee as mentioned above has executed non genuine trades resulting in the creation of artificial volume thereby violating the provisions of Regulation 3(a) (c) && Regulation 4(1) and 4(2)(a) of the PFUTP Regulations 2003 and in terms of the judgement of Hon’ble Supreme Court of India in the matter of SEBI Vs. Shri RAM Mutual Fund[2006] 68 SCL 216(SC) decided on May 23 2006 held that “In our considered opinion penalty is attracted as soon as the contravention of the statutory obligation as contemplated by the Act and the Regulations is established and hence the intention of the parties committing such violation becomes wholly irrelevant...” I am convinced that it is a fit case for imposition of monetary penalty under the provisions of Section 15 HA of SEBI Act which reads as under: Penalty for fraudulent and unfair trade practices. 15HA. If any person indulges in fraudulent and unfair trade practices relating to securities he shall be liable to a penalty 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 3: If so what would be the quantum of monetary penalty that can be imposed on the Noticee after taking into consideration the factors mentioned in Section 15J of the SEBI Act 1992 23. While determining the quantum of penalty under Section 15HA of SEBI Act it is important to consider the factors as stipulated in Section 15J of the SEBI Act which reads as under: 15J. While adjudging quantum of penalty undershall have due regard to the following factors namely:— the amount of disproportionate gain or unfair advantage wherever quantifiable made as a result of the default the amount of loss caused to an investor or group of investors as a result of the default the repetitive nature of the default. andof section 15F 15G 15H and 15HA shall be and shall always be deemed to have been exercised under the provisions of this section.] I observe that the material available on record does not quantify any disproportionate gains or unfair advantage if any made by the Noticee and the losses if any suffered by the investors due to such violations on part of the said Noticee. However the Noticee has entered into two non genuine trades which demonstrates the violation of PFUTP Regulations 2003. 25. Therefore I note that Noticee indulged in execution of reversal trades in stock options contracts in the IP which were non genuine and created false and misleading appearance of trading in terms of artificial volumes in stock options leading to violation of Regulation 3(a)(c)and 4(1)of the PFUTP Regulations 2003. 26. Having considered all the facts and circumstances of the case the material available on record the factors mentioned in section 15J of the SEBI Act 1992 and in exercise of power conferred upon me under section 15 I of the SEBI Act 1992 read with rule 5 of the Adjudication Rules 1995 I hereby impose following penalty under section 15HA of the SEBI Act 1992 on the Noticee: Name of the Violation provisions Kasturi Aich Regulations 3(a) (c) ₹ 5 00 000 PAN: ACCPA1896N d) 4(1) and 4(2)(a) of Rupees Five Lakhs PFUTP Regulations 2003 I am of the view that the said penalty is commensurate with the lapse omission on the part of the Noticee. 27. The Noticee shall remit pay the said amount of penalty within 45 days of receipt of this order either by way of Demand Draft in favour of “SEBI Penalties Remittable to Government of India” payable at Mumbai OR through online payment facility available on the website of SEBI i.e. www.sebi.gov.in on the following path by clicking on the payment link: ENFORCEMENT  Orders  Orders of AO  PAY NOW 28. The aforesaid Noticee shall forward said Demand Draft or the details confirmation of penalty so paid to “The Division ChiefSecurities and Exchange Board of India SEBI Bhavan Plot No. C 4 A “G” Block Bandra Kurla Complex Bandra Mumbai 400 051.”. The Noticee shall also provide the following details while forwarding DD payment  Name and PAN of the Noticee  Name of the case matter  Bank Name and Account Number  Transaction Number  Purpose of Payment Payment of penalty under AO proceedings In the event of failure to pay the said amount of penalty within 45 days of the receipt of this Order SEBI may initiate consequential actions including but not limited to recovery proceedings under section 28A of the SEBI Act 1992 for realization of the said amount of penalty along with interest thereon inter alia by attachment and sale of movable and immovable properties. In terms of the provisions of rule 6 of the Adjudication Rules a copy of this order is being sent to the Noticee viz. Kasturi Aich and also to the Securities and Exchange Board of India. Date: January 28 2022 BARNALI MUKHERJEE Place: Mumbai ADJUDICATING OFFICER 

Summary: If any person indulges in unfair trade practices relating to securities, the monetary penalty should be imposed under 15HA of SEBI act -THE SECURITIES AND EXCHANGE BOARD OF INDIA SEBI observed some large-scale trade reversals in the stocks segment and pursuing further investigation it was found that total 2,91,744 trades comprising substantial 81.40% of all the trades were non genuine and these trades lead to creation of artificial volumes. During investigation Kasturi Aich (“Noticee”) was found indulged in execution of reversal trades in stock options segment of BSE. Adjudication proceedings initiated against the noticee for violation of Regulations 3(a), (b), (c), (d), 4(1) and 4(2)(a) of SEBI regulation,2003. The proceeding was conducted by appointed adjudicating officer BARNALI MUKHERJEE in [ADJUDICATION ORDER NO. Order/BM/UR/2021-22/14819] A show cause notice was issued as to show why penalty should not be imposed under section 15HA of the SEBI Act, 1992 for the alleged violations in the notice it was alleged that Noticee had executed 2 non genuine trades in 1 Stock Options contract which resulted in artificial volume of total 50,000 units. And the investigation was conducted in response of the noticee response. The proceedings were conducted, and it was found that the Noticee had executed non-genuine trades in stock options contract to total trades in the contract was 6.67% in the aforesaid contract and from the trade log it was found that the trades executed by the Noticee in a contract were squared up within a short span of time and the wide variations in the trades indicates that there was pre-determination in the prices by the counterparties while executing the trades. The authority relied on SEBI vs. Rakhi Trading Private Ltd to consider that the trades were not coincidental but were pre-planned. From the investigation and from the trading behavior of the noticee confirms that the noticee has violated   regulations 3(a), (b), (c), (d), 4(1) and 4(2)(a) of PFUTP Regulations, 2003 and the authority confirmed the imposition of monetary penalty of ₹ 5,00,000/-under the provisions of Section 15 HA of SEBI Act.