Order in the matter of Kelvin Fincap Limited

8/11/2019 Order in the matter of Kelvin Fincap Limited

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WTM/RKA/ 103 /ISD/2014

SECURITIES AND EXCHANGE BOARD OF INDIA

ORDER

UNDER SECTION 11(1), 11(4) AND 11B OF THE SEBI ACT, 1992 AND SECTION

12A OF THE SECURITIES CONTRACTS (REGULATION) ACT, 1956 - IN THE

MATTER OF KELVIN FINCAP LIMITED.

1. Pursuant to the detection of a huge rise in the traded volumes and price of the shares of

Kelvin Fincap Limited {formerly known as Dahyabhai Sons Limited and hereinafter referred

to as "Kelvin "} on the Bombay Stock Exchange Limited (BSE) during the period from June

18, 2013 to May 29, 2014 (hereinafter referred to as "Examination Period"), Securities and

Exchange Board of India (SEBI) undertook preliminary inquiry in the dealings in the scrip

during the said period.

2. It was noticed that during the period from June 18, 2013 to July 23, 2013 (Patch 1), the price

of the scrip rose from `151.55/- to`225/, i.e. an increase of 48% in 26 trading days. On

July 24, 2013, the shares of Kelvin were split in the ratio of 1:1 and from July 24, 2013 to

May 29, 2014 (Patch 2), the price of the scrip increased from `118/- to `535/-, i.e. an

increase of 353% in 205 trading days. An illustration of price/volume movement in the scripof Kelvin during the Examination Period is given below:

0

20000

40000

60000

80000

100000

120000

140000

160000

180000

200000

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100

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Total Volume Close Price

Brought to you by http://StockViz.biz


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3. Kelvin had a share capital of 9,96,000 shares of`10/- each as on December 31, 2011.From

the Annual Reports of Kelvin for FY 2011-12 and FY 2012-2013, it was observed that it is in

the business of financing and investing and it had earned a negligible profit of`25,869/-

during 2011-12 which marginally increased to `43,957.13/-, at the end of the FY 2012-13,

with negative reserves. Kelvin's financial statements for the quarters ending June 2013,

September 2013, December 2013 and March 2014 also indicated negligible profits earned by

it during the relevant period. It was further noted that during the Examination Period there

was no corporate announcement made by Kelvin which could support such price rise in its

scrip. Thus, the sharp rise in the price of the scrip of Kelvin during the Examination Period

was not supported by its fundamentals or any other genuine factor. It is interesting to note

that the shares of Kelvin were suspended on BSE till November 2011 and till March 29,

2012, there were no trades on BSE except a single trade of 50 shares at a price of `8.55/-.

Strangely, inspite of such poor fundamentals, Kelvin was able to raise `13,00,00,000/- by

issuing 1,30,00,000 shares in physical form to certain entities ( individuals and a few

corporate entities) at`10/- per share on March 20, 2012. To invest in a company having

such poor and meagre fundamentals at a price which is at a premium to the prevailing

market price cannotprima-faciebe termed as rational buying behaviour. Such investments, as

in this case, normally could be made only if the allottees had nexus with directors/promoters

of Kelvin and the issue of these shares was under a pre- arrangement between them.

4. On analysis of the trading activity in the above scrip, it was observed that, during the

Examination Period, certain related/connected entities had substantially traded amongst

themselves in shares of Kelvin and created artificial volume and contributed to the artificial

price rise in the scrip. The list of those related/connected entities is given at Annexure - A

and they are hereinafter referred to as the "Kelvin Fincap Group". It was observed that prior to

the Examination Period, shares of Kelvin had low liquidity, which increased substantially

only after those related/connected entities commenced trading heavily in the scrip. Their

inter-relationship/connection were noted from the Know Your Client (KYC) details , their

bank statements, off-market transactions amongst themselves including the abovementioned

allotment of shares, and information available on the Ministry of Corporate Affairs

(hereinafter referred to as "MCA") website.

5. Considering the large number of related/connected entities of Kelvin Fincap Group, it was

deemed necessary to shortlist those entities who were closely connected to Kelvin and/or



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Patel, director of RFL International Limited and FastTrack Entertainment Limited.

7. BBPPE7839K Sushma VimalkumarRaval

1. The entity is one of the directors of Kelvin as per MCAwebsite.

2. The entity is also director of Millennum CybertechLimited.

3. The entity shares common address, viz. 23 Shri RamVihar Rokadia Lane, Borivali West, Mumbai, 400092, withMr. Vimalkumar Sureshchandra Raval, Ms. Padmaben

Jagdish Jani, Ms. Jalpa Mitesh Jani, Mr. Jagdish Jani(Director of Sapan Chemical Limited, Surya MangalMedia and Entertainment Pvt. Ltd. and Acil CottonLimited) and Mr. Mitesh Jagdish Jani (Director ofNovagold Petro-Resources Limited).

8. AJMPS0962J MahendrabhaiSakalchand Shah

1. The entity is one of the directors of Kelvin as per MCAWebsite.

2. The entity is also a director of Heema Infocom Limitedand GFL Financial India Limited.

9. AYBPS0534J Vishal Kumar Shah 1. The entity is one of the directors of Kelvin as per BSE

website.2. The entity is one of the directors of Cornhill Trading Co.

Pvt. Ltd., Earth Exim Limited and Do Max Steel Limited.10. AAECC0841Q Cromakem Limited

1. Mr. Bhavik Satish Badani is one of the directors ofKelvin and Cromakem Limited.

2. Narendra Ramanlal Shah and Cromakem Limited sharecommon address, viz. 24, jalaram Nagar, opp.chamundaCircle, ganjawala Lane,Borivali(w), , Mumbai,Maharashtra - 400092.

3. Ms. Pallavi Chetan Pandit is one of the directors of

Cornhill Trading Co. Pvt. Ltd, Cromakem Limited, SonalInternational Limited, Stardom Trading Co. Pvt. Ltd. andIFSL Limited.

4. Mr. Jayshree Shankar Bhosle, Heema Infocom Limited,Do Max Steel Limited, Suryamangal Media AndEntertainment Limited, Cornhill Trading Company PvtLtd, Sapan Chemicals Limited, Ms. Padmaben Jagdish

Jani, Ms. Jalpa Mitesh Jani, Cromakem Limited, AcilCotton Industries Limited, Mr. Rupesh Balkrishna Bhoir,Mr. Chirag Dineshkumar Shah, Mr. Namdeo ShantaramGole, Ms. Varsha Praful Trivedi, Mr. Mahesh RamanlalShah, Ms. Geeta Narendra Shah, Zimig Trading

Company Private Limited and Mr. Parag ChandrkantShah share common e-mail ID'[email protected]'.

5. The entity received/transfered funds from/to SDFC

Finance Limited and Kosha Cubidor Containers Limited.

11. AACCD7020L Do Max SteelLimited

1. The entity shares common director, Mr. Vishal KumarShah, with Kelvin, Cornhill Trading Co. Pvt. Ltd. andEarth Exim Limited.

2. Mr. Jayshree Shankar Bhosle, Heema Infocom Limited,Do Max Steel Limited, Suryamangal Media And

Entertainment Limited, Cornhill Trading Company Pvt



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Ltd, Sapan Chemicals Limited, Ms. Padmaben JagdishJani, Ms. Jalpa Mitesh Jani, Cromakem Limited, AcilCotton Industries Limited, Mr. Rupesh Balkrishna Bhoir,Mr. Chirag Dineshkumar Shah, Mr. Namdeo ShantaramGole, Ms. Varsha Praful Trivedi, Mr. Mahesh RamanlalShah, Ms. Geeta Narendra Shah, Zimig Trading

Company Private Limited and Mr. Parag ChandrkantShah share common e-mail ID'[email protected]'.

12. AAHCS1332H Stardom TradingCompany Pvt. Ltd

1. Cornhill Trading Company Pvt Ltd, Stardom TradingCompany Pvt Ltd and Acil Cotton Industries Limitedshare common address, viz. 38, Ganga Vihar, 3rd Floor,Rokadia Lane, Borivali (w), Mumbai - 400092.

2.Ms. Pallavi Chetan Pandit is one of the directors ofCornhill Trading Co. Pvt. Ltd, Cromakem Limited, SonalInternational Limited, Stardom Trading Co. Pvt. Ltd. andIFSL Limited.

3.

Cornhill Trading Company Pvt Ltd, Earth Exim Ltd,Stardom Trading Company Pvt Ltd, Mr. RupeshBalkrishna Bhoir, Fast Track Entertainment Limited andMr. Chirag Dineshkumar Shah, share common e-mail ID'[email protected]'.

13. AAFCS2725Q Sapan ChemicalsLimited

1. Earth Exim Ltd, Ms. Geeta N Shah, Sapan ChemicalsLimited and Mr. Narendra Ramanlal Shah share commonaddress, viz. 23 Jalaram Nagar Nr. Chamunda CircleGajawala Lane Borivli West, , Mumbai, 400092.

2.Ms. Sushma Vimalkumar Raval (Director of Kelvin as perMCA website), Mr. Vimalkumar Sureshchandra Raval,Ms. Padmaben Jagdish Jani, Ms. Jalpa Mitesh Jani, Mr.

Jagdish Jani (Director of Sapan Chemical Limited, SuryaMangal Media and Entertainment Pvt. Ltd. and AcilCotton Limited) and Mr. Mitesh Jagdish Jani (Director ofNovagold Petro-Resources Limited) share commonaddress, viz. 23 Shri Ram Vihar Rokadia Lane, Borivali West,

Mumbai, 400092.3.

Mr. Jayshree Shankar Bhosle, Heema Infocom Limited,Do Max Steel Limited, Suryamangal Media AndEntertainment Limited, Cornhill Trading Company PvtLtd, Sapan Chemicals Limited, Ms. Padmaben Jagdish

Jani, Ms. Jalpa Mitesh Jani, Cromakem Limited, AcilCotton Industries Limited, Mr. Rupesh Balkrishna Bhoir,Mr. Chirag Dineshkumar Shah, Mr. Namdeo Shantaram

Gole, Ms. Varsha Praful Trivedi, Mr. Mahesh RamanlalShah, Ms. Geeta Narendra Shah, Zimig TradingCompany Private Limited and Mr. Parag ChandrkantShah share common e-mail ID'[email protected]'.

4.Jaishree Shankar Bhosle is the promoter of SapanChemical Limited, as per BSE website.



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14. AAACF7961Q Fast TrackEntertainmentLimited

1. Director of Fast Track Entertainment Limited and RFLInternational Limited (Jitendra Patel) share same address

with the Director of Kelvin, Mr. Bipin Patel, viz. 401 B-28, Shanti Nagar Co. Op. Hsg. Ltd. Shanti, Nagar, Sec - 7,

Above Indra Hospital, Mira Road,, Mumbai, 4011072. Acil Cotton Industries Limited and Fast Track

Entertainment Limited share common address, viz. B-7/404 A, Natraj Township Part-ii,near Parshuram NagarSociety, Sayaji Ganj,, Vadodara, Gujarat, India, 390005.

3. Cornhill Trading Company Pvt Ltd, Earth Exim Ltd,Stardom Trading Company Pvt Ltd, Mr. RupeshBalkrishna Bhoir, Fast Track Entertainment Limited andMr. Chirag Dineshkumar Shah, share common e-mail ID'[email protected]'.

15. AACCC0591P Cornhill TradingCompany Pvt. Ltd

1. Mr. Vishal Kumar Shah is one of the directors of Kelvin,Cornhill Trading Co. Pvt. Ltd., Earth Exim Limited andDo Max Steel Limited.

2. Universal Credit and Securities Limited, SuryamangalMedia And Entertainment Limited, Cornhill Trading

Company Pvt Ltd and Gfl Financials India Limited sharecommon address, viz. 15 Shriram Vihar, Rokadia Lane,Borivali (w), Mumbai, Maharashtra, India, 400092.

3. Cornhill Trading Company Pvt Ltd, Stardom TradingCompany Pvt Ltd and Acil Cotton Industries Limitedshare common address, viz. 38, Ganga Vihar, 3rd Floor,Rokadia Lane, Borivali (w), Mumbai, Maharashtra, India,400092.

4. Ms. Pallavi Chetan Pandit is one of the director ofCornhill Trading Co. Pvt. Ltd, Cromakem Limited, SonalInternational Limited, Stardom Trading Co. Pvt. Ltd. andIFSL Limited.


Jani, Ms. Jalpa Mitesh Jani, Cromakem Limited, AcilCotton Industries Limited, Mr. Rupesh Balkrishna Bhoir,Mr. Chirag Dineshkumar Shah, Mr. Namdeo ShantaramGole, Ms. Varsha Praful Trivedi, Mr. Mahesh RamanlalShah, Ms. Geeta Narendra Shah, Zimig TradingCompany Private Limited and Mr. Parag ChandrkantShah share common e-mail ID'[email protected]'.

6. Cornhill Trading Company Pvt Ltd, Earth Exim Ltd,Stardom Trading Company Pvt Ltd, Mr. RupeshBalkrishna Bhoir, Fast Track Entertainment Limited and

Mr. Chirag Dineshkumar Shah, share common e-mail ID'[email protected]'.

16. AACCS1185R Sonal InternationalLtd

1. Ms. Pallavi Chetan Pandit is one of the directors ofCornhill Trading Co. Pvt. Ltd, Cromakem Limited, SonalInternational Limited, Stardom Trading Co. Pvt. Ltd. andIFSL Limited.

2. Sonal International Ltd and RFL International Limitedshare common address, viz. 304, AkrutiComplex,nr.stadium Six Cross Road, Navrangpura,,

Ahmedabad, Gujarat, India, 380009.



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17. AAACO2454R Nova Gold PetroResources Limited

1. Ms. Sushma Vimalkumar Raval (Director of Kelvin as perMCA website), Mr. Vimalkumar Sureshchandra Raval,Ms. Padmaben Jagdish Jani, Ms. Jalpa Mitesh Jani, Mr.

Jagdish Jani (Director of Sapan Chemical Limited, SuryaMangal Media and Entertainment Pvt. Ltd. and AcilCotton Limited as per MCA website) and Mr. Mitesh

Jagdish Jani (Director of Novagold Petro-ResourcesLimited) share common address, viz. 23 SHRI RAMVIHAR ROKADIA LANE, BORIVALI WEST,

MUMBAI, 400092.

2. The entity received`25,00,000 from Cromakem Ltd on20/11/2013.

18. AABCA7788F Acil CottonIndustries Limited

1. Cornhill Trading Company Pvt Ltd, Stardom TradingCompany Pvt Ltd and Acil Cotton Industries Limitedshare common address, viz. 38, Ganga Vihar, 3rd Floor,Rokadia Lane, Borivali (w), Mumbai, 400092.

2.

Acil Cotton Industries Limited and Fast TrackEntertainment Limited share common address, viz. B-7/404 A, Natraj Township Part-ii,near Parshuram NagarSociety, Sayaji Ganj,, Vadodara, Gujarat, India, 390005.

3. Ms. Sushma Vimalkumar Raval (Director of Kelvin as perMCA website), Mr. Vimalkumar Sureshchandra Raval,Ms. Padmaben Jagdish Jani, Ms. Jalpa Mitesh Jani, Mr.

Jagdish Jani (Director of Sapan Chemical Limited, SuryaMangal Media and Entertainment Pvt. Ltd. and AcilCotton Limited) and Mr. Mitesh Jagdish Jani (Director ofNovagold Petro-Resources Limited) share commonaddress, viz. 23 Shri Ram Vihar Rokadia Lane, Borivali West,

Mumbai, 400092.


Jani, Ms. Jalpa Mitesh Jani, Cromakem Limited, AcilCotton Industries Limited, Mr. Rupesh Balkrishna Bhoir,Mr. Chirag Dineshkumar Shah, Mr. Namdeo ShantaramGole, Ms. Varsha Praful Trivedi, Mr. Mahesh RamanlalShah, Ms. Geeta Narendra Shah, Zimig TradingCompany Private Limited and Mr. Parag ChandrkantShah share common e-mail ID

'[email protected]'.

5. Vimalkumar Raval is one of the directors of ZimigTrading Pvt. Ltd. and Acil Cotton Industries Limited.



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19. AAACZ6848C Zimig TradingCompany PrivateLimited


Jani, Ms. Jalpa Mitesh Jani, Cromakem Limited, AcilCotton Industries Limited, Mr. Rupesh Balkrishna Bhoir,

Mr. Chirag Dineshkumar Shah, Mr. Namdeo ShantaramGole, Ms. Varsha Praful Trivedi, Mr. Mahesh RamanlalShah, Ms. Geeta Narendra Shah, Zimig TradingCompany Private Limited and Mr. Parag ChandrkantShah share common e-mail ID'[email protected]'.

1 Vimalkumar Raval is one of the directors of ZimigTrading Pvt. Ltd. and Acil Cotton Industries Limited.

20. AMVPJ5720H Jalpa Jani 1. Ms. Sushma Vimalkumar Raval (Director of Kelvin as perMCA website), Mr. Vimalkumar Sureshchandra Raval,Ms. Padmaben Jagdish Jani, Ms. Jalpa Mitesh Jani, Mr.

Jagdish Jani (Director of Sapan Chemical Limited, Surya

Mangal Media and Entertainment Pvt. Ltd. and AcilCotton Limited) and Mr. Mitesh Jagdish Jani (Director ofNovagold Petro-Resources Limited) share commonaddress, viz. 23 SHRI RAM VIHAR ROKADIA LANE,BORIVALI WEST, MUMBAI, 400092.


Jani, Ms. Jalpa Mitesh Jani, Cromakem Limited, AcilCotton Industries Limited, Mr. Rupesh Balkrishna Bhoir,Mr. Chirag Dineshkumar Shah, Mr. Namdeo Shantaram

Gole, Ms. Varsha Praful Trivedi, Mr. Mahesh RamanlalShah, Ms. Geeta Narendra Shah, Zimig TradingCompany Private Limited and Mr. Parag ChandrkantShah share common e-mail ID'[email protected]'

21. AKSPM3939N Kirti Mehta As per the bank Account No. 911010005936771 of KirtiMehta with Axis Bank Limited, the entityreceived/transferred funds from/to Kelvin, CromakemLimited, Stardom Trading Co. Pvt. Ltd., Fast TrackEntertainment Limited, Earth Exim Limited, Cornhill

Trading Co. Pvt. Ltd., IFSL Limited, GFL Financial IndiaLimited, Inventure Finance Pvt. Ltd., Sonal InternationalLimited, Kosha Cubidor Containers Limited and AcilCotton Industries Limited.

22. AFMPB0449P Jayshree ShankarBhosle


Jani, Ms. Jalpa Mitesh Jani, Cromakem Limited, AcilCotton Industries Limited, Mr. Rupesh Balkrishna Bhoir,Mr. Chirag Dineshkumar Shah, Mr. Namdeo ShantaramGole, Ms. Varsha Praful Trivedi, Mr. Mahesh RamanlalShah, Ms. Geeta Narendra Shah, Zimig TradingCompany Private Limited and Mr. Parag ChandrkantShah share common e-mail ID'[email protected]'.

2. Jaishree Shankar Bhosle is the promoter of Sapan

Chemical Limited as per BSE website.



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7. In addition, from the bank accounts of Kelvin (account No. 912020012135343) and

Cromakem Limited (account No. 910020027467767) with Axis Bank, inter se fund

transfers between Kelvin and certain entities of theKelvin Fincap Group during January

01, 2012 to March 31, 2014, were observed. Instances of such inter sefund transfers

amongst the related/connected entities of Kelvin Fincap Group and Kelvin are as under:

Table 2: Funds Flow among the Kelvin Fincap Group

Date Transferer Name Transferee Name Amount ()

9/3/2012 Kelvin Fincap Limited SDFC Finance Limited 5000000

10/3/2012 Kelvin Fincap Limited Universal Credit And Securities Ltd 1600000

13-03-2012 Kelvin Fincap Limited Keyur M Shah 3000000

19-03-2012 Kelvin Fincap Limited Millennium Cybertech Limited 10000000

19-03-2012 Kelvin Fincap Limited Stardom Trading Co.Pvt.Ltd. 1000000021-03-2012 Kelvin Fincap Limited Novagold Petro-Resources Ltd 9000000

22-03-2012 Kelvin Fincap Limited Acil Cotton Indutries Limited 8000000

24-03-2012 Kelvin Fincap Limited Kirti Mehta 1200000

25-04-2012 Geeta Shah Kelvin Fincap Limited 500000

27/04/2012 Abhishek Narendra Shah Kelvin Fincap Limited 500000

13/09/2012 Cromakem Limited Kelvin Fincap Limited 500000

8/2/2013 Do Max Steel Limited Kelvin Fincap Limited 30000

20/02/2013 Earth Exim Ltd Kelvin Fincap Limited 300000

6/5/2013 Sapan Chemicals Ltd Kelvin Fincap Limited 20000

29/01/2014 Kelvin Fincap Limited Fast Track Entertainment Ltd 300000

3/1/2012 Cromakem Limited Sonal International Limited 400000

11/2/2012 Cromakem Limited Fast Track Entertainment Ltd 20500011/2/2012 Cromakem Limited SDFC Finance Limited 210000

15/02/2012 Cromakem Limited RFL International Limited 15000

29/02/2012 Gfl Financials India Ltd Cromakem Limited 1000000

11/4/2012 Cromakem Limited Kirti Kantilal Mehta 2000000

16/04/2012 Cromakem Limited Chirag Dinesh Kumar Shah 1775000

20/04/2012 Cromakem Limited Namdeo Shantaram Gole 190000

2/5/2012 Kosha Cubidor Containers Ltd Cromakem Limited 2000000

5/5/2012 Cromakem Limited Millennium Cybertech Limited 200000

5/5/2012 Cromakem Limited IFSL Limited 200000

8/5/2012 Cromakem Limited Yogesh Bhogilal Chauhan 685000

9/5/2012 Stardom Trading Company PrivateLimited

Cromakem Limited 1000000

10/5/2012 Cromakem Limited Parag Chandrkant Shah 1000000

12/5/2012 Cromakem Limited Dahyabhai Sons Limited 25000

16/05/2012 Suryamangal Media And EntertainmentPvt Ltd.


2/7/2012 Cromakem Limited Universal Credit And Securities Ltd 25000

28/01/2013 Cromakem Limited Earth Exim Ltd 25000



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13/03/2013 Cromakem Limited Inventure Finance Pvt Ltd 2522400

14/03/2013 Cromakem Limited Do Max Steel Limited 2523000

15/03/2013 Cromakem Limited Cornhill Trading Company Private Limited 2522400

19/03/2013 Dahyhabhai Shares and Stock BrokersLtd.


28/03/2013 Cromakem Limited Padmaben Jagdish Jani 51000020/05/2013 Cromakem Limited Jalpa Jani 200000

18/07/2013 Cromakem Limited Rupesh Bhoir 500000

25/07/2013 Cromakem Limited Mahesh Ramanlal Shah 400000

6/8/2013 Cromakem Limited Varsha Trivedi 1000000

8/8/2013 Cromakem Limited Jayshree Shankar Bhosle 1000000

12/8/2013 Cromakem Limited Geeta Narendra Shah 65000

11/9/2013 Acil Cotton Industries Limited Cromakem Limited 500000

27/09/2013 Cromakem Limited Sapan Chemicals Limited 1500000

20/11/2013 Cromakem Limited Novagold Petro Resources Ltd 2500000

7/2/2014 Cromakem Limited Zimig Trading Co Pvt Ltd 365000

8/3/2014 Heema Infocom Limited Cromakem Limited 3890000

19/03/2014 Cromakem Limited Abhishek N Shah 115000

8. It is observed from the disclosures made on BSE website that prior to the allotment of

shares made in March 2012, Kelvin had a share capital of 9,96,000 shares with promoters'

holding 7,43,800 shares constituting 74.67% in the company. Pursuant to the issuance of

1,30,00,000 shares to certain entities, the promoter shareholding decreased to 5.31% and the

total number of shareholders in Kelvin increased from 176 to 225.

9. It was further observed that during the quarter ending June, 2012, the Kelvin Fincap Group

entities consolidated their holding in Kelvin which resulted in number of shareholders

decreasing to 64. During the same period, the promoters of Kelvin also transferred 7,11,050

shares in physical form to certain Kelvin Fincap Group entities through off- market

transactions. Thereafter, the Kelvin Fincap Groupentities were observed to have transferred

shares in physical form as well as in dematerialised form within the group and startedtrading heavily in the scrip pursuant to June 18, 2013.

Analysis of trading in the scrip of Kelvin

10.The analysis of the trading of entities of Kelvin Fincap Group during the aforesaid two (2)

patches was carried out with a focus on the following:-

The trading frequency;

The volume generated;

Contribution to price rise;



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Buying behaviour as observed from Last Traded Price (LTP) data;

Patch 1: June 18, 2013 to July 23, 2013 (prior to share split)

11.During the Patch 1, price of Kelvin rose from `151.55 to`225/-( i.e. 48% increase) and

was accompanied by rise in the traded volumes. The daily average volume in the scrip which

was merely 6 shares during January 1, 2013 to June 17, 2013( i.e. six months prior to Patch

1) increased to 22,237 shares during Patch 1. It was observed that during Patch 1, Kelvin

Fincap Group entities collectively bought 5,47,818 shares (94.75% of trade volume) and sold

5,64,913 shares (97.71% of trade volume), out of a total of 5,78,174 shares traded at BSE. As

high as 5,36,292 shares which constitute 92.76% of trade volume, were traded amongst the

group entities. As high as 97.90% of the total buy volume of the group matched with the sell

orders of one or the other group entity. Similarly, 94.93% of their sell volume matched with

the buy orders within the group.

12.It was observed that in Patch 1, out of a total of 17 instances of trades establishing new high

price in the scrip, the Kelvin Fincap Group established new high price on 4 instances. The

contribution of the Kelvin Fincap Groupin establishing new high price was`19/- out of total

price rise of`82.40/-, which constitutes 23.06% of the total new high prices.

13.On LTP analysis during Patch 1, it was observed that outof the 24 instances of positive

contribution to the LTP, Kelvin Fincap Groupcontributed positively to the LTP in as many as

9 instances. By executing such trades above the LTP, Kelvin Fincap Group contributed to

positive LTP to the extent of `52.20/-, which was 41.04% of overall positive LTP

contribution of `127.20/- in the scrip. The details of contribution to price rise by Kelvin

Fincap Group during Patch 1 are as under:

Table 3: Contribution of Kelvin Fincap Groupto price rise in Patch 1

PAN Name Contributionin positive

LTP (in )

No. ofInstancesof positiveLTP

Contribution toNew High

Price (in )

No. ofInstances ofNew HighPrice

AAACF7961Q Fast Track EntertainmentLimited

19.7 2 9 1

AMVPJ5720H Jalpa Jani 13.75 3 1.25 1

AAECC0841Q Cromakem Limited 8.55 1 8.55 1

AABCE3676Q Earth Exim Ltd 5 1 0 0

AKSPM3939N Kirti Mehta 5 1 0 0

ADQPJ5053P Padmaben Jagdish Jani 0.2 1 0.2 1



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AAECC0841Q Cromakem Limited 203.65 53 48.9 9

AACCC0591P Cornhill Trading Company Pvt Ltd 118.9 24 6.5 2

AACCS1185R Sonal International Ltd 94.4 21 34.1 6

AAHCS1332H Stardom Trading Company Pvt Ltd 91.75 26 19.5 4

AMVPJ5720H Jalpa Jani 90.3 26 5 1

AABCA7788F Acil Cotton Industries Limited 82.65 15 0 0

AAACO2454R Nova Gold Petro Resources Limited 78.8 17 34.5 6

AAHCS4914K Suryamangal Media & EntertainmentLtd

63.45 18 19 4

AAACZ6848C Zimig Trading Company PrivateLimited

54.2 12 2 1

AKSPM3939N Kirti Mehta 52.15 15 7 3

AAACI4383H IFSL Limited 51.05 9 0 0

AAACF7961Q Fast Track Entertainment Limited 49 11 11 3

AQQPG4855K Maruti Shankar Gaude 45 8 0 0

AFMPB0449P Jayshree Shankar Bhosle 38.2 16 8 2ALZPB9604R Rupesh Balkrishna Bhoir 29.35 8 6 2

AHNPD1452H Vidyadhar Ramnaresh Dubey 26.85 9 5 1

ATRPK4534D Ramesh Krishna Kulaye 21.5 3 1 1

AOYPM7851H Madhuben H Modi 18.5 1 17.5 1

AIYPD1020H Vinod Gajanan Dhadave 14.95 4 0 0

AADCH2621N Heema Infocom Limited 11.05 6 0 0

ADQPJ5053P Padmaben Jagdish Jani 10.5 2 5 1

AEKPK6751Q Santosh Kumar 5 1 4 1

AAGCR4662J Reachsmart Construction PrivateLimited

3 1 0 0

AIOPG4980F Hiren Kirit Gandhi 2.6 4 0 0

ANIPR5608Q Vimalkumar Sureshchandra Raval 2.1 4 0 0

AAOPS2034A Mahesh Ramanlal Shah 2 1 0 0

AHAPP5916H Jaswant Kantilal Parmar 1.5 2 0 0

ABBPT1431A Varsha Trivedi 1 1 1 1

Total 1712.65 414 328.1 64

18.It was observed that the Shortlisted Group contributed to positive LTP to the extent of `

1,403.25/-, which is 81.93% of contribution (`1,712.65/-) made by Kelvin Fincap Group.

Further, the Shortlisted Group contributed`269.60/- in establishing new high price, which

is 82.17% of the Kelvin Fincap Group'soverall contribution of`328.10/-.

19.From the above analysis, it was observed that the trades of Kelvin Fincap Group contributed

significantly to both traded volume and to price rise in the scrip during the Examination

Period.

20.It was observed that during the Examination Period the connected/related entities belonging

to Kelvin Fincap Group had traded amongst themselves in the scrip and their buy and sell



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orders placed in those trades persistently matched. An illustration of the trading patterns of

order placements followed by Kelvin Fincap Groupentities are as under:-

One of the patterns of order placement by the Kelvin Fincap Group entities was

where a buy order placed by one group entity exactly matched with the sell order

placed by another group entity. For instance, on January 16, 2014, Jeetandra Janani

(HUF) placed a sell order at 11:22:56 AM for a quantity of 2,500 at a price of `

350/-. After 7 seconds, i.e. 11:23:03, Fast Track Entertainment Limited placed a

buy order of same quantity of 2500 shares at a price of `350/-, which immediately

matched. Similarly, Prameela Mohandas placed a sell order of 3,000 shares at a

price of`340/- at 13:50:53 on the same day, which matched with a buy order of

3,000 shares at a price of`340/- placed by Sapan Chemicals Limited at 13:51:11. In

the same manner, the buy and sell orders for 4,000 shares placed by Sapan

Chemicals Limited and Zubin K Shah, respectively within a gap of 3 seconds

matched at 13:52:13.

In another pattern, the order placed by one group entity matched with the orders

placed by more than one entity belonging to the Kelvin Fincap Group. For instance,

on January 16, 2014, Ashok Jasraj Jain (HUF) placed 2 sell orders of 5,000 and

2,000 shares at a price of`

340/- at 14:44:10 and 14:44:42, respectively. The said sellorders matched with the buy orders placed by the following 8 entities belonging to

Kelvin Fincap Group:

Table 5: Counterparties to Ashok Jasraj Jain(HUF)

Buyer Name BuyOrderTime

BuyOrderQuantity

BuyOrderPrice

Jayshree Shankar Bhosle 14:44:24 3750 340

Nova Gold Petro ResourcesLimited

14:48:36 1700 340

Stardom Trading Company PvtLtd

14:54:23 550 340

Fast Track Entertainment Limited 14:55:15 400 340

Cornhill Trading Company PvtLtd

14:57:22 300 340

Cromakem Limited 14:58:05 100 340

IFSL Limited 14:58:31 100 340

Stardom Trading Company PvtLtd

14:58:59 100 340



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matched trades amongst connected/ related entities of Kelvin Fincap Groupthere was no

change in beneficial ownership of the traded shares. Their trades created artificial

volumes and manipulated the price of the scrip during the Examination Period. Such

manipulation in the traded volume and price of any scrip by a group of connected

entities has the potential to induce gullible and genuine investors to trade in the scrip

and harm them.

25.Apart from the above, it was observed that Kelvin had disclosed to BSE on March 20,

2012 inter-aliastating that it had made a preferential allotment of 1,30,00,000 shares to

certain entities as described in the following table :

Table 7: List of Preferential Allottees disclosed by Kelvin on BSE website

Sr. No. Name of Allottees/EntitiesNumber of Equity Shares

Allotted

1 Mukesh N Desai 500000

2 Mukesh N Desai Huf 500000

3 Sunish B.Bhel/Kavita Sunish Behl 530000

4 Dinesh Jaiswal/Sunita D.Jaiswal/Santlal Jaiswal 345000

5 Subhash Tikamdas Mithawalla/Jignasa S.Mithawalla 150000

6 Tasneem Iqbal Syed/Krishna M.Dawda/Prem Agarwal 330000

7 Mukeshbhai Nanjibhai Moradiya 200000

8 Shehul Vallabhbhai Moradiya 200000

9 Dhanjibhai Shamjibhai Donda 200000

10 Hiren Tulsibhai Moradia 200000

11 Dharmesh Tulsibhai Moradia 200000

12 Bharatbhai Nanjibhai Moradia 200000

13 Vallabhbhai D Sachapara 200000

14 B D Sachpara 200000

15 Rajesh Haribhai Moradia 200000

16 Vasantben Dhanjibhai Donda 200000

17 Chhotubha Shivubha Saravaiya 200000

18 Shobhanaben Nareshbhai Mpradiya 200000

19 Ramniranjan C Jhunjhunwala 200000

20 Hasmukhlal R.Shah 200000

21 Ashok Jashraj Jain HUF 200000

22 Ketan Bhupendrkumar Shah 100000

23 Shantilal Dungarshi Maru HUF 200000

24 Kalpesh Shantilal Maru/Rachana Kalpesh Maru 600000

25 Saloni Ramniklal Maru 100000



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26 Manisha Pramesh Rambhia 200000

27 Nirmala Shantilal Maru 400000

28 Sejul Pratish Maru 100000

29 Mitesh Rajnikant Shah 150000

30 Bhavini B.Furia 25000031 Rajesh Gopaldas Villaitramani 200000

32 Kamlesh Hari Thakur 200000

33 Jagdish Hari Thakur 200000

34 Ashok Gopaldas Kripalani 200000

35 Mrs Lajwanti Hari Thakur 200000

36 Zubin Kamlesh Shah/Zeenal Zubin Shah 400000

37 Prameela Mohandas 200000

38 Inventure Finance Private Limited 600000

39 Deepaben Trabakbhai Makwana 15000040 Champaben Devjibhai Makwana 150000

41 MrsBhavani Bharatbhai Dangar 100000

42 Mithalal Manoharlal Sahlot 300000

43 Poonam Premsagar Pasricha/Premsagar L Pasricha 100000

44 M.V.R.S Prasad 300000

45 N.Satyanarayana 150000

46 Ravi Sancheti HUF 200000

47 Rakesh Agrawal/Trapti Agrawal 100000

48 GFL Financial India Ltd 898000

49 Suryamangal Media & Entertainment Ltd 897000

26.It is curious to note that the list of entities mentioned in the table above actually have

more than one entity clubbed together at serial nos. 3, 4, 5, 6, 24, 36, 43 and 47. On

inquiry from the Share Transfer Agent of Kelvin, i.e. Purva Sharegistry (India) Pvt.

Ltd. (hereinafter referred to as "Purva Sharegistry) it was observed that the shares were

issued to 56 entities and not 49 entities, as disclosed by Kelvin to BSE. It was observed

that different share certificates were issued to the following 56 entities and not to 49 as

disclosed by Kelvin:-

Table 8: List of Preferential Allottees provided by Purva Sharegistry

S.No.

PAN Name Share CertificateNumber

Distinctive Number

1 AATPD0728R Mukesh N Desai 5001-5050 996001 1496000

2 AACHM2754B Mukesh N Desai HUF 5051-5100 1496001 1996000

3 AAAPB8093N Sunish B. Bhel 5101-5119 1996001 2186000

4 AAJPB7775N Kavita Sunish Behl

5120-5153 2186001 2526000



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5 AAQPJ0509B Shantilal Jaiswal 5154-5164 2526001 2636000

6 ABVPJ5592Q Sunita Dinesh Jaiswal 5165-5175 2636001 2746000

7 ABVPJ5571B Dinesh Jaiswal 5176-5188 2746001 2871000

8 AADPM3931D Subhash Tikamdas Mithawalla 5189-5195 2871001 2941000

9 AGKPM6963C Jignasa Subhash Mithawalla 5196-5203 2941001 3021000

10 AQQPS2059B Tasneem Iqbal Syed 5204-5213 3021001 3121000

11 ADPPD5068B Krishna M.Dawda 5214-5224 3121001 3231000

12 AETPA7958N Prem Agarwal 5225-5236 3231001 3351000

13 AIVPM3622K Mukeshbhai Moradiya 5237-5256 3351001 3551000

14 AIVPM3623J Shehul Vallabhbhai Moradiya 5257-5276 3551001 3751000

15 AEIPD5332A Dhanjibhai Shamjibhai Donda 5277-5296 3751001 3951000

16 AMTPM8714C Hiren Tulsibhai Moradia 5297-5316 3951001 415100017 ALEPM6311R Dharmesh Tulsibhai Moradia 5317-5336 4151001 4351000

18 AMTPM0749H Bharatbhai Nanjibhai Morada 5337-5356 4351001 4551000

19 ACXPP9026C Vallabhbhai D Sachapara 5357-5376 4551001 4751000

20 ACXPP9049B B.D.Sachpara 5377-5396 4751001 4951000

21 ACRPM4534E Rajesh Haribhai Moradia 5397-5416 4951001 5151000

22 AEGPD4889J Vasantben Dhanjibhai Donda 5417-5436 5151001 5351000

23 AGBPS6488F Chhotubha Shivubha Saravaiya 5437-5456 5351001 5551000

24 AIKPM4674N Shobhanaben Nareshbhai Mpradiya 5457-5476 5551001 5751000

25 AARPJ2757L Ramniranjan C Jhunjhunwala 5477-5496 5751001 5951000

26 AADPS8752L Hasmukhlal R.Shah 5497-5516 5951001 6151000

27 AAAHJ0191D Ashok Jashraj Jain HUF 5517-5536 6151001 6351000

28 AAFPS1767F Ketan Bhupendrakumar Shah 5537-5546 6351001 6451000

29 AAFHS8932L Shantilal Dungarshi Maru Huf 5547-5566 6451001 6651000

30 AAAPM8353N Kalpesh Shantilal Maru 5567-5568 6651001 6851000

31 AAOPS6468G Rachana Kalpesh Maru 5569-5572 6851001 725100032 AAAPM8349Q Saloni Ramniklal Maru 5627-5636 7251001 7351000

33 AAFPM7257G Manisha Pramesh Rambhia 5637-5656 7351001 7551000

34 AAFPM7256H Nirmala Shantilal Maru 5657-5696 7551001 7951000

35 AQWPM5566H Sejul Pratish Maru 5697-5706 7951001 805100036 AAJPS0851L Mitesh Rajnikant Shah 5707-5721 8051001 8201000

37 AAAPM8354M Bhavin B. Furia 5722-5746 8201001 8451000

38 AAAPV4085A Rajesh Gopaldas Villaitramani 5747-5766 8451001 8651000

39 AAAPT6038P Kamlesh Hari Thakur 5767-5786 8651001 8851000

40 AAAPT3253A Jagdish Hari Thakur 5787-5806 8851001 9051000

41 AABPK2469A Ashok Gopaldas Kripalani 5807-5826 9051001 9251000

42 AAEPT2433N Mrs Lajwanti Hari Thakur 5827-5846 9251001 9451000

43 AMIPS6846A Zubin Kamlesh Shah 5847-5886 9451001 9851000

44 ACJPN8415H Prameela Mohandas 5887-5906 9851001 10051000

45 AAACM0623J Inventure Finance Private Ltd 5907-5966 10051001 10651000

46 AZTPM3476A Deepaben Trabakbhai Makwana 5967-5981 10651001 10801000

47 ACKPM8513A Champaben Devjibhai Makwana 5982-5996 10801001 10951000

48 ADXPD6143K Mrs Bhavani Bharatbhai Danga 5997-6006 10951001 11051000

49 AAIPS9404N Mithalal Manoharlal Sahlot 6007-6036 11051001 1135100050 AHCPP2686C Poonam Pramesagar Pasricha 6037-6046 11351001 11451000

51 AAZPM0394A M.V.R.S Prasad 6047-6084 11451001 11826000

52 ABEPN6198B N.Satyanarayana A6084-6091 11826001 11901000



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27.From the above, it is observed that Kelvin hadprima facie given false information to the

BSE with regard to the number of allottees and had concealed the actual number of

allottees. The method of disclosure i.e. clubbing of one or more allottees under one

suggests that the Kelvin showed the false number so as to show such allotment as

private placement, which it actually was not. In this regard, it is relevant to mention

that Hon'ble Supreme Court in its judgement and order dated August 31, 2012 in

matter of Sahara India Real Estate Corporations Limited & Ors Vs SEBI & Anr. - Civil Appeal No.

9813 and 9833 of 2011 [(2013) 1 SCC 1 has held that an offer to fifty or more persons

becomes public issue by virtue of first proviso to section 67(3) of the Companies Act,

1956. Hence, it isprima-facie observed that the above allotment was not a preferential

allotment (private placement) but was a public issue. Thus, prima-facie, the said

allotment of shares by Kelvin was in violation of sections 56, 60 and 73 read with

section 67(3) of the Companies Act, 1956 and regulations 4(2), 5(1), 5(7), 6, 7, 25, 36,

37, 46 and 57 of SEBI (Issue of Capital and Disclosure Requirement) Regulation 2009

(hereinafter referred to as "ICDR Regulations").

28.As discussed above, Kelvin had disclosed that the above allotment was a preferential

allotment. Assuming it was so, in terms of regulation 78(2) of the ICDR Regulations,

the shares so allotted had to be locked- in for a period of one year from the date of

allotment on March 20, 2012. However, in this case, two of the allottees viz, Mr. Ravi

Sancheti (HUF) and GFL Financial India Limited sold a total of 6,00,000 shares of

Kelvin held by them to 4 other entities of Kelvin Fincap Groupon September 29, 2012.

It was observed from the Annual Report of Kelvin for the FY 2012-13 that the

transfer of physical shares was looked after by Shareholders' Grievance and Share

Transfer Committee of Kelvin, which comprised three of its directors viz. Mansukh

Sanghvi, Bipin Patel and Bhavik Badani. Thus, Kelvin and its directors were under

obligation to ensure that the shares allotted under the purported preferential allotment

are not transferred within one year from the date of the allotment. Therefore, it was

observed that such transfer of shares in violation of regulation 78(2) of ICDR

Regulations was in connivance with Kelvin and its these three directors.

53 AAIHR3732E Ravi Sancheti HUF 6092-6111 11901001 12101000

54 ABYPA6388G Rakesh Agrawal 6112-6121 12101001 12201000

55 AABCG0597Q GFL Financial India Ltd 6122-6214 12201001 13099000

56 AAHCS4914KSuryamangal Media & EntertainmentLtd 6215-6306 13099001 13996000



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29.It was further observed from the shareholding pattern filed by Kelvin with BSE for

quarters ending June 30, 2012 and September 30, 2012, that the promoters of Kelvin

were holding 7,43,800 shares, i.e. 5.31% of its share capital, as on June 30, 2012, which

decreased to 0.01% of the share capital of Kelvin during the quarter ended September

30, 2012. However, from the data regarding transactions in Kelvin as shared by Purva

Sharegistry it was noted that three promoters of Kelvin viz. Keyur M. Shah , Kavita

Shah and Keyur M. Shah HUF transferred a total of 7,11,050 shares (5% of the share

capital of Kelvin) to five other entities of the Kelvin Fincap Groupon April 07, 2012 and

April 14, 2012. Keyur M. Shah had further transferred 25,750 shares to Abhishek N

Shah on January 15, 2013. All such transfers were off- market transfers involving

shares in physical form. The details of such transfers are as under:

Table 9: Off-Market Transactions by the Promoters

Date OfTransaction

TransferorName

Transferee Name QuantityTransferred

07/04/2012 Keyur M ShahHUF

Narendra R Shah HUF 50000

07/04/2012 Kavita K Shah Narendra R Shah 50000

07/04/2012 Kavita K Shah Geeta Narendra Shah 50000

07/04/2012 Kavita K Shah Abhishek N Shah 30000

07/04/2012 Keyur M Shah Narendra R Shah 20000007/04/2012 Keyur M Shah Geeta Narendra Shah 50000

07/04/2012 Keyur M Shah Mahesh R Shah 70000

07/04/2012 Keyur M Shah Abhishek N Shah 4000014/04/2012 Keyur M Shah Abhishek N Shah 41050

14/04/2012 Keyur M Shah Geeta Narendra Shah 50000

14/04/2012 Keyur M Shah Narendra R Shah 80000

15/01/2013 Keyur M Shah Abhishek N Shah 25750

30.However, the abovementioned transactions (for April 07, 2012 and April 14, 2012)

were not disclosed in the shareholding pattern filed by Kelvin with BSE for the quarterended June 30, 2012 as required under Clause 35 of the Listing Agreement. Further,

the aforesaid promoters failed to disclose the above changes in their shareholding

under the provisions of regulation 13(4A) of the SEBI (Prohibition of Insider Trading)

Regulations, 1992, (hereinafter referred to as "PIT Regulations").

31.Apart from the above irregularities by Kelvin, it was observed that details of the Board

of Directors of Kelvin as available on BSE and MCA websites are different. Mr.

Mansukh Sanghvi, who is shown as a Managing Director of Kelvin on BSE website, is



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not shown in the list of directors disclosed on MCA website by Kelvin. Mr Mansukh

Sanghvi is also the Authorized Signatory for Kelvins bank accounts with Axis Bank.

Similarly, Surekhaben K Shah is not shown as a director on MCA website. However,

as per annual report for FY 2011-12 , she was non-executive independent director of

Kelvin at the time of preferential allotment. The difference in details of directors as

observed from disclosures available at BSE and MCA websites are given below:

Table 10: Details of Directors on MCA and BSE websites

List of Directors (Source: MCAwebsite as on April 25, 2014)

List of Directors (Source: BSE Websiteas on April 25, 2014)

Bhavik Satish Badani Mansukh Sanghvi

Bipin Bhikhabhai Patel Bhavik Satish Badani

Sushma Vimalkumar Raval Bipin Bhikhabhai PatelMahendrabhai Sakalchand Shah Vishal Kumar Shah

Surekhaben K Shah

32.Further, Kelvin has avoided SEBI's advices seeking information from it regarding its

board of directors and above mentioned allotment, vide email dated May 22, 2014 and

letter dated May 27, 2014. Therefore, all the above persons at Table 10 are considered

to be in charge of affairs of Kelvin.

33.Although none of the directors have traded on their own account during the

Examination Period, it is observed that most of them were not merely directors of

Kelvin but were deeply connected with entities belonging to the Kelvin Fincap Group,

who had traded in the scrip as described in preceding paragraphs. Details of their

connection with the entities belonging to the Kelvin Fincap Groupare as follows:

Table 11: Connection with other Kelvin Fincap GroupEntities

Name of Director Connection with other Kelvin Fincap GroupEntitiesBhavik Satish Badani He is one of the directors of Cromakem Limited.

Bipin Bhikhabhai Patel He shares common address with Mr. Jitendra Patel, director of RFLInternational Limited and Fast Track Entertainment Limited.

Sushma VimalkumarRaval

She is one of the directors of Millennum Cybertech Limited.She also shares common address with Mr. Vimalkumar SureshchandraRaval, Ms. Padmaben Jagdish Jani, Ms. Jalpa Mitesh Jani, Mr. Jagdish

Jani (Director of Sapan Chemical Limited, Surya Mangal Media andEntertainment Pvt. Ltd. and Acil Cotton Limited) and Mr. Mitesh

Jagdish Jani (Director of Novagold Petro-Resources Limited).MahendrabhaiSakalchand Shah

He is one of the directors of Heema Infocom Limited and GFLFinancial India Limited.

Vishal Kumar Shah He is one of the directors of Cornhill Trading Co. Pvt. Ltd., EarthExim Limited and Do -Max Steel Limited.



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34.I note from the above examination and the factors mentioned atAnnexure A, that the

entities belonging to the Kelvin Fincap Groupareprima-facierelated/connected with each

other and with Kelvin.

35.I also note that during the Examination Period, the traded volume and the liquidity in

the shares of Kelvin increased substantially only after the Kelvin Fincap Groupstarted

trading in the said shares. The Kelvin Fincap Groupentities brought up the share price

from`151.55 to almost`1070/- (adjusted)/`535/- (unadjusted) through persistently

matched trades within the group during the Examination Period. Also, the Kelvin Fincap

Groupentities continuously executed orders at a price above LTP leading to an artificial

price rise. In my view, such a pattern of trading by placing buy orders at a price higher

than the LTP is apparently against the accepted economic rationale that a buyer wouldalways wish to purchase shares at the lowest available price. The modus operandiused by

Kelvin Fincap Groupto raise the price of the scrip and to create artificial volume is as

under:

A. Kelvin issued 1,30,00,000 shares in physical form to 56 related entities on March 20,

2012. It made false disclosure about number of allottees to camouflage the issuance

to more than 49 persons so as to avoid compliance of issuance of prospectus and

detailed disclosures therein. It concealed the actual number of allottees.

B. Thereafter, the shares of Kelvin were transferred among Kelvin Fincap Group entities

in physical as well as dematerialized form after April 01, 2012.

C. Suddenly after June 18, 2013, Kelvin Fincap Group entities started to trade heavily in

Kelvin with huge trading volume concentration on BSE.

D. Kelvin Fincap Group entities dealt amongst themselves in the market i.e. they were

observed to be buying and selling shares amongst each other thereby creating

artificial trading volume. Such artificial volume constituted almost 95.68% of the

total market volume during the Examination Period. Sans these entities, the volume

of trading in Kelvin was very low.

E. Kelvin Fincap Group also significantly exerted an upward pressure on the price, an act

inconsistent with normal buyer behaviour.

36.I further note that the sequence of events and pattern of transactions in this case prima

facieindicate that Kelvin issued new shares to certain entities, which were subsequently



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transferred by these allottees to other Kelvin Fincap Groupentities. The promoters of

Kelvin viz. Keyur Shah, Kavita Shah and Keyur Shah HUF also transferred their

shares off-market in physical form to other entities belonging to the Kelvin Fincap

Group. Thereafter, the Kelvin Fincap Groupentities by indulging in non- genuine trading

amongst themselves through repeated and continuous substantial matched transactions

in the illiquid scrip of Kelvin created artificial volumes in the scrip and manipulated its

price. Such transactions were prima facie carried out for the sole or dominant purpose

of creating artificial volumes in the scrip and manipulating its price by taking the scrip

to entice trading therein at artificial price. The acts, omissions and conduct of the

Kelvin Fincap Group as observed during preliminary examination prima facie fall in the

definition of "fraud' under regulation 2(1) (c) of the SEBI(Prohibition of Fraudulent

and Unfair Trade Practices Relating to Securities Market) Regulation 2003 (hereinafter

referred to as "PFUTP Regulations") which reads as under:-

fraudincludes any act, expression, omission or concealment committed whether in a deceitful manner or notby a person or by any other person with his connivance or by his agent while dealing in securities in order toinduce another person or his agent to deal in securities, whether or not there is any wrongful gain or avoidance ofany loss, and shall also include

(1) a knowing misrepresentation of the truth or concealment of material fact in order that another person mayact to his detriment;(2) a suggestion as to a fact which is not true by one who does not believe it to be true;

(3) an active concealment of a fact by a person having knowledge or belief of the fact;(4) a promise made without any intention of performing it;(5) a representation made in a reckless and careless manner whether it be true or false;(6) any such act or omission as any other law specifically declares to be fraudulent,(7) deceptive behaviour by a person depriving another of informed consent or full participation,(8) a false statement made without reasonable ground for believing it to be true.(9) the act of an issuer of securities giving out misinformation that affects the market price of the security,resulting in investors being effectively misled even though they did not rely on the statement itself or anythingderived from it other than the market price."

And fraudulent shall be construed accordingly;

37.In view of the above , I am of the prima facie view thatKelvin Fincap Groupentitiesadopted fraudulent device and artifice to defraud the genuine shareholders of Kelvin

and have thus violated sections 12A (a) (b) and (c) of the SEBI Act, 1992 and

regulations 3(a), (b), (c), (d), 4(1) and 4(2)(a), (b), (e) and (g) of the PFUTP Regulations

which read as under:

SEBI Act, 1992"Prohibition of manipulative and deceptive devices, insider trading and substantialacquisition of securities or control.

12A.No person shall directly or indirectly



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(a) use or employ, in connection with the issue, purchase or sale of any securities listed or proposed to belisted on a recognized stock exchange, any manipulative or deceptive device or contrivance in contraventionof the provisions of this Act or the rules or the regulations made thereunder;(b) employ any device, scheme or artifice to defraud in connection with issue or dealing in securities whichare listed or proposed to be listed on a recognised stock exchange;

(c) engage in any act, practice, course of business which operates or would operate as fraud or deceit uponany person, in connection with the issue, dealing in securities which are listed or proposed to be listed on arecognised stock exchange, in contravention of the provisions of this Act or the rules or the regulations made

there under;"

PFUTP Regulations"Prohibition of certain dealings in securities.3.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 securities listed or proposed to be listedin 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 whichare 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 uponany person in connection with any dealing in or issue of securities which are listed or proposed to be listed ona recognized stock exchange in contravention of the provisions of the Act or the rules and the regulationsmade there under.

"4. Prohibition of manipulative, fraudulent and unfair trade practices(1) Without prejudice to the provisions of regulation 3, no person shall indulge in a fraudulent or an unfairtrade 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;(b) dealing in a security not intended to effect transfer of beneficial ownership but intended to operate only asa device to inflate, depress or cause fluctuations in the price of such security for wrongful gain or avoidance ofloss;(c)..(d)(e) any act or omission amounting to manipulation of the price of a security;(f).(g) entering into a transaction in securities without intention of performing it or without intention of change

of ownership of such security;

38.I further note that the shares of Kelvin were allotted to 56 entities. However, it

appears thatKelvin concealed the actual number of allottees andprima facie made false

disclosure in that regard to camouflage the issuance to more than 49 persons so as to

avoid compliance of issuance of prospectus and detailed disclosures therein. Such act

omission and conduct, prima facie, apart from being fraudulent and in violation of the

provisions of sections 12A (a) (b) and (c) of the SEBI Act, 1992, regulations 3(b), (c),

(d) and 4(1) of the PFUTP Regulations were also in contravention of the provisions of



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sections 56, 60 and 73 read with section 67(3) of the Companies Act, 1956 and

regulations 4(2), 5(1), 5(7), 6, 7, 25, 36, 37, 46, and 57 of ICDR Regulations. Even if

the allotment in this case was a preferential allotment the Kelvin and its directorsprima

facie contravened the provisions of regulation 78(2)of the ICDR Regulations as they

connived and allowed transfer of shares during the lock- in period of one year.

Kelvins non-cooperative attitude during the Preliminary Examination further leads to

these preliminary findings against it.

39.In this case, as observed hereinabove, the shareholding pattern filed by Kelvin with

BSE for the quarter ended June 30, 2012 was incorrect. I am of the view that this act

and omission of Kelvin isprima faciein violation of clause 35 of the Listing Agreement

read with section 21 of the Securities Contracts (Regulation) Act, 1956 (hereinafterreferred to as SCRA). Further, Keyur M. Shah, Keyur M Shah (HUF) and Kavita K

Shah have failed to disclose changes in their shareholding to BSE and have thereby

prima facieviolated provisions of regulation 13(4A) of the PIT Regulations.

40.It is trite to say that SEBI is mandated to regulate activities in the securities market

thereby encouraging transparent and fair practices by the market participants. The

entities of Kelvin Fincap Group as stated in this order are prima facie found to be

instrumental in manipulating trading in scrip of Kelvin by the intricate modus operandi.

The acts, omissions and conduct of Kelvin and entities of the Kelvin Fincap Groupas

described above is prima facie inimical to the interests of participants in the securities

market. It is noted that the entities of Kelvin Fincap Grouphave continued with their

trading in the scrip in the same manner as discussed hereinabove even after the

Examination Period. The price of the scrip Kelvin has further increased from `535/-

to`599.50/- after the Examination Period (i.e. from May 30, 2014 to August 01, 2014)

with an average volume of 14,223 shares. The Kelvin Fincap Groupis still actively tradingin the scrip by contributing 66% to gross market volume and 79.14% to total positive

LTP contribution in the price of the scrip. Such trading and price rise is neither

supported by fundamentals of Kelvin nor by any other factor including any corporate

announcement by it during the post Examination Period, which may justify the kind of

rise which the price of the scrip has gone through. If such concerted and prima facie

fraudulent dealings in securities of an illiquid scrip as in this case are allowed to

continue in the market, the same is fraught with danger of immense mischief and



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incalculable damage to the securities market besides undermining the confidence of the

investors in the fairness and integrity of the market.

41.In this case, it has been observed that out of total contribution of Kelvin Fincap Groupto

the total purchase volume, positive LTP and new high price, Shortlisted Group of

Kelvin Fincap Group has been observed to have contributed 83.27%, 82.17% and

83.09% of the total purchase volume, positive LTP and new high price respectively.

Further, all directors including Mansukh Sanghvi and Surekhaben K Shah are prima

facie liable for the acts, omissions and conduct of Kelvin as prima facie found in this

case. I further note that promoters and some of the directors of Kelvin are part of the

Shortlisted Group.

42.Apart from the above, I note that, as on August 11, 2014, the following entities of

Kelvin Fincap Groupwhich is prima facie found to have adopted fraudulent device and

artifice, are holding substantial quantity of shares in Kelvin ( more than 1% of its share

capital):-

Table 12: Kelvin Fincap GroupEntities holding substantial shares in Kelvin

S.No. PAN Name Shareholding

No. %

1 AAACM0623J Inventure Finance Private Limited 1106112 3.952 ARYPS5993F Naresh Nagindas Shah 1009163 3.613 AAFCS2725Q Sapan Chemicals Limited 863281 3.084 AACCD7020L Do Max Steel Limited 757224 2.715 AATPD0728R Mukesh Nanubhai Desai 734527 2.626 AAACR9384B RFL International Limited 700602 2.507 ALZPB9604R Rupesh Balkrishna Bhoir 699902 2.508 AAJPB7775N Kavita Sunish Behl 675500 2.419 AMVPJ5720H Jalpa M Jani 630472 2.2510 AKSPM3939N Kirti Kantilal Mehta 522345 1.87

11 AAOPS2033H Geeta Narendra Shah 400000 1.4312 AADPS8752L Hasmukhlal Ramanlal Shah 391300 1.4013 AIKPM4674N Shobhanaben N. Moradia 390750 1.4014 AMTPM0749H Bharat N. Moradiya 390600 1.4015 AEGPD4889J Vasantben Dhanjibhai Donda 385590 1.3816 AIVPM3622K Mukesh N. Moradia 384160 1.3717 AIVPM3623J Shehul V. Moradia 378377 1.3518 ACXPP9049B Bhimjibhai D. Chanchapara 374950 1.3419 AEIPD5332A Dhanjibhai S. Donda 366460 1.3120 ACXPP9026C Vallabhbhai D. Sachapra 360900 1.2921 AMTPM8714C Hiren Tulsibhai Moradia 339500 1.2122 ACRPM4534E Rajesh Moradia 334900 1.20



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23 AFMPB0449P Jayshree Shankar Bhosle 325847 1.1624 AACCC0591P Cornhill Trading Company Pvt Ltd 316521 1.1325 ALEPM6311R Dharmesh Tulsibhai Moradia 300000 1.07

43.The entities mentioned in the above table have either been alloted shares by way of

further issue or have transacted in the scrip through off-market transfers amongst the

entities of the Group as discussed hereinabove. These entities, by virtue of having

sizeable holding (i.e. more than 1%) and being, prima facie, part of the scheme executed

byKelvin Fincap Group,have the potential of not only disturbing the market equillibrium

but also inducing the gullible investors to buy their holding at the artificially raised

price.

44.Considering the above facts and circumstances, I am of the view that an urgent

preventive and remedial action needs to be taken by way of ad interim ex-parteorder in

this case, during pendency of investigation in the matter.

45.I, therefore, in order to protect the interest of the investors and the integrity of the

securities market, in exercise of the powers conferred upon me in terms of section 19

read with section 11(1), section 11 (4) (b) and section 11B of the SEBI Act, 1992 and

section 12A of the SCRA, pending investigation and passing of final order, hereby

issue following directions, by way of this ad-interim ex-parteorder:

a) The following entities are restrained from accessing the securities market and further

prohibited from buying, selling or dealing in the securities markets, either directly or

indirectly, in any manner whatsoever, tillfurther directions:

Sl.No.

Name of the entity PAN

1 Kelvin Fincap Limited AAACD1881H

2 Keyur M Shah AAHPS4084K3 Keyur M Shah (HUF) AAAHK5034L4 Kavita K Shah AAYPS3458E5 Dahyabhai Shares And Stock Brokers Ltd AAACD1880G6 Bhavik Satish Badani ALRPB9295L7 Bipin Bhikhabhai Patel AIDPP3653M8 Sushma Vimalkumar Raval BBPPE7839K9 Mahendrabhai Sakalchand Shah AJMPS0962J10 Mansukh Sanghvi ABJPS8618E11 Vishal Kumar Shah AYBPS0534J12 Surekhaben K Shah BORPS0804Q

13 Cromakem Limited AAECC0841Q



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14 Do Max Steel Limited AACCD7020L15 Stardom Trading Company Pvt Ltd AAHCS1332H16 Sapan Chemicals Limited AAFCS2725Q17 Fast Track Entertainment Limited AAACF7961Q18 Cornhill Trading Company Pvt Ltd AACCC0591P

19 Sonal International Ltd AACCS1185R20 Jalpa Jani AMVPJ5720H21 Kirti Mehta AKSPM3939N

22 Jayshree Shankar Bhosle AFMPB0449P23 Nova Gold Petro Resources Limited AAACO2454R24 Acil Cotton Industries Limited AABCA7788F25 Zimig Trading Company Private Limited AAACZ6848C26 Inventure Finance Private Limited AAACM0623J27 Naresh Nagindas Shah ARYPS5993F28 Mukesh Nanubhai Desai AATPD0728R

29 RFL International Limited AAACR9384B30 Rupesh Balkrishna Bhoir ALZPB9604R31 Kavita Sunish Behl AAJPB7775N32 Geeta Narendra Shah AAOPS2033H33 Hasmukhlal Ramanlal Shah AADPS8752L34 Shobhanaben N. Moradia AIKPM4674N35 Bharat N. Moradiya AMTPM0749H36 Vasantben Dhanjibhai Donda AEGPD4889J37 Mukesh N. Moradia AIVPM3622K38 Shehul V. Moradia AIVPM3623J39 Bhimjibhai D. Chanchapara ACXPP9049B

40 Dhanjibhai S. Donda AEIPD5332A41 Vallabhbhai D. Sachapra ACXPP9026C42 Hiren Tulsibhai Moradia AMTPM8714C43 Rajesh Moradia ACRPM4534E44 Dharmesh Tulsibhai Moradia ALEPM6311R

b) Kelvin Fincap Limited (PAN: AAACD1881H) is restrained from raising further

capital, either directly or indirectly, in any manner whatsoever, till further directions.

46.SEBI reserves right to proceed against other entities of Kelvin Fincap Group at any stage

of the investigation or thereafter. The persons/entities against whom this order is

passed may file their replies, if any, to SEBI within 21 days from the date of receipt of

this order, if they so desire, avail an opportunity of personal hearing on a date, place

and time fixed in that regard by Securities and Exchange Board of India.



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47.This order is without prejudice to the right of SEBI to take any other action that may

be initiated against the aforementioned entities, mentioned in para 40 above, in

accordance with law.

48.This order shall come into force with immediate effect.

DATE: AUGUST 14th, 2014 RAJEEV KUMAR AGARWAL

PLACE: MUMBAI WHOLE TIME MEMBER

SECURITIES AND EXCHANGE BOARD OF INDIA



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3. Cornhill Trading Company Pvt Ltd, Earth Exim Ltd,Stardom Trading Company Pvt Ltd, Mr. Rupesh BalkrishnaBhoir, Fast Track Entertainment Limited and Mr. ChiragDineshkumar Shah, share common e-mail ID'[email protected]'.

13 AAFCS2725Q Sapan ChemicalsLimited

1. Earth Exim Ltd, Ms. Geeta N Shah, Sapan ChemicalsLimited and Mr. Narendra Ramanlal Shah share commonaddress, viz. 23 Jalaram Nagar Nr. Chamunda Circle GajawalaLane Borivli West, Mumbai, Maharashtra - 400092.

2. Ms.Sushma Vimalkumar Raval (Director of Kelvin as perMCA website), Mr. Vimalkumar Sureshchandra Raval, Ms.Padmaben Jagdish Jani, Ms. Jalpa Mitesh Jani, Mr. Jagdish

Jani (Director of Sapan Chemical Limited, Surya MangalMedia and Entertainment Pvt. Ltd. and Acil Cotton Limited)and Mr. Mitesh Jagdish Jani (Director of Novagold Petro-Resources Limited) share common address, viz. 23 Shri Ram

Vihar Rokadia Lane, Borivali West, Mumbai, 400092.

3. Mr. Jayshree Shankar Bhosle, Heema Infocom Limited, DoMax Steel Limited, Suryamangal Media And EntertainmentLimited, Cornhill Trading Company Pvt Ltd, SapanChemicals Limited, Ms. Padmaben Jagdish Jani, Ms. JalpaMitesh Jani, Cromakem Limited, Acil Cotton IndustriesLimited, Mr. Rupesh Balkrishna Bhoir, Mr. ChiragDineshkumar Shah, Mr. Namdeo Shantaram Gole, Ms.

Varsha Praful Trivedi, Mr. Mahesh Ramanlal Shah, Ms. GeetaNarendra Shah, Zimig Trading Company Private Limited andMr. Parag Chandrkant Shah share common e-mail ID'[email protected]'.

4. Jaishree Shankar Bhosle is the promoter of Sapan Chemical

Limited, as per BSE website.14 AAACF7961Q Fast Track

EntertainmentLimited

1. Director of Fast Track Entertainment Limited and RFLInternational Limited (Jitendra Patel) share same address withthe Director of Kelvin, Mr. Bipin Patel, viz. 401 B-28, ShantiNagar Co. Op. Hsg. Ltd. Shanti, Nagar, Sec - 7,Above IndraHospital, Mira Road,, Mumbai, 401107.

2. Acil Cotton Industries Limited and Fast Track EntertainmentLimited share common address, viz. B-7/404 A, Natraj

Township Part-ii, near Parshuram Nagar Society, Sayaji Ganj,,Vadodara, Gujarat - 390005.

3. Cornhill Trading Company Pvt Ltd, Earth Exim Ltd,

Stardom Trading Company Pvt Ltd, Mr. Rupesh BalkrishnaBhoir, Fast Track Entertainment Limited and Mr. ChiragDineshkumar Shah, share common e-mail ID'[email protected]'.



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15 AACCC0591P Cornhill TradingCompany Pvt Ltd

1. Mr. Vishal Kumar Shah is one of the director of Kelvin,Cornhill Trading Co. Pvt. Ltd., Earth Exim Limited and DoMax steel limited.

2. Universal Credit and Securities Limited, Suryamangal MediaAnd Entertainment Limited, Cornhill Trading Company Pvt

Ltd and Gfl Financials India Limited share common address,viz. 15 Shriram Vihar, Rokadia Lane, Borivali (w), Mumbai,Maharashtra, India, 400092.

3. Cornhill Trading Company Pvt Ltd, Stardom TradingCompany Pvt Ltd and Acil Cotton Industries Limited sharecommon address, viz. 38, Ganga Vihar, 3rd Floor, RokadiaLane, Borivali (w), Mumbai, Maharashtra, India, 400092.

4. Ms. Pallavi Chetan Pandit is one of the directors of CornhillTrading Co. Pvt. Ltd, Cromakem Limited, Sonal InternationalLimited, Stardom Trading Co. Pvt. Ltd. and IFSL Limited.

5.

Mr. Jayshree Shankar Bhosle, Heema Infocom Limited, DoMax Steel Limited, Suryamangal Media And EntertainmentLimited, Cornhill Trading Company Pvt Ltd, SapanChemicals Limited, Ms. Padmaben Jagdish Jani, Ms. JalpaMitesh Jani, Cromakem Limited, Acil Cotton IndustriesLimited, Mr. Rupesh Balkrishna Bhoir, Mr. ChiragDineshkumar Shah, Mr. Namdeo Shantaram Gole, Ms.


6. Cornhill Trading Company Pvt Ltd, Earth Exim Ltd,Stardom Trading Company Pvt Ltd, Mr. Rupesh BalkrishnaBhoir, Fast Track Entertainment Limited and Mr. ChiragDineshkumar Shah, share common e-mail ID'[email protected]'.

16 AACCS1185R Sonal InternationalLtd

1. Ms. Pallavi Chetan Pandit is one of the directors of CornhillTrading Co. Pvt. Ltd, Cromakem Limited, Sonal InternationalLimited, Stardom Trading Co. Pvt. Ltd. and IFSL Limited.

2. Sonal International Ltd and RFL International Limited sharecommon address, viz. 304, Akruti Complex,nr.stadium SixCross Road, Navrangpura,, Ahmedabad, Gujarat, India,380009.

17 AAACO2454R Nova Gold PetroResources Limited

1. Ms. Sushma Vimalkumar Raval (Director of Kelvin as perMCA website), Mr. Vimalkumar Sureshchandra Raval, Ms.

Padmaben Jagdish Jani, Ms. Jalpa Mitesh Jani, Mr. JagdishJani (Director of Sapan Chemical Limited, Surya MangalMedia and Entertainment Pvt. Ltd. and Acil Cotton Limited)and Mr. Mitesh Jagdish Jani (Director of Novagold Petro-Resources Limited) share common address, viz. 23 Shri Ram

Vihar Rokadia Lane, Borivali West, Mumbai, 400092,Maharashtra, India.

2. The entity received ` 25,00,000 from Cromakem Ltd on20/11/2013

18 AAACI4383H IFSL Limited Ms. Pallavi Chetan Pandit is one of the directors of CornhillTrading Co. Pvt. Ltd, Cromakem Limited, Sonal InternationalLimited, Stardom Trading Co. Pvt. Ltd. and IFSL Limited



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19 AABCA7788F Acil CottonIndustries Limited

1. Cornhill Trading Company Pvt Ltd, Stardom TradingCompany Pvt Ltd and Acil Cotton Industries Limited sharecommon address, viz. 38, Ganga Vihar, 3rd Floor, RokadiaLane, Borivali (w), Mumbai, Maharashtra, India, 400092.

2. Acil Cotton Industries Limited and Fast Track Entertainment

Limited share common address, viz. B-7/404 A, NatrajTownship Part-ii,near Parshuram Nagar Society, Sayaji Ganj,,Vadodara, Gujarat, India, 390005.

3. Ms. Sushma Vimalkumar Raval (Director of Kelvin as perMCA website), Mr. Vimalkumar Sureshchandra Raval, Ms.Padmaben Jagdish Jani, Ms. Jalpa Mitesh Jani, Mr. Jagdish



4.

Mr. Jayshree Shankar Bhosle, Heema Infocom Limited, DoMax Steel Limited, Suryamangal Media And EntertainmentLimited, Cornhill Trading Company Pvt Ltd, SapanChemicals Limited, Ms. Padmaben Jagdish Jani, Ms. JalpaMitesh Jani, Cromakem Limited, Acil Cotton IndustriesLimited, Mr. Rupesh Balkrishna Bhoir, Mr. ChiragDineshkumar Shah, Mr. Namdeo Shantaram Gole, Ms.


5. Vimalkumar Raval is one of the directors of Zimig TradingPvt. Ltd. and Acil Cotton Industries Limited.

20 AAACZ6848C Zimig TradingCompany PrivateLimited



2. Vimalkumar Raval is one of the directors of Zimig Trading

Pvt. Ltd. and Acil Cotton Industries Limited.21 AAHCS4914K Suryamangal Media

& EntertainmentLtd

1. The entity is one of the preferential allottees.

2. Universal Credit and Securities Limited, Suryamangal MediaAnd Entertainment Limited, Cornhill Trading Company PvtLtd and Gfl Financials India Limited share common address,

viz. 15 Shriram Vihar, Rokadia Lane, Borivali (w), Mumbai,Maharashtra, India, 400092.



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27 AAACU2627G Universal CreditAnd Securities Ltd

1. Mr. Narendra R Shah is one of the directors of Earth EximLimited and Universal Credit and Securities Limited.

2. Universal Credit and Securities Limited, Suryamangal MediaAnd Entertainment Limited, Cornhill Trading Company PvtLtd and Gfl Financials India Limited share common address,

viz. 15 Shriram Vihar, Rokadia Lane, Borivali (w), Mumbai,Maharashtra, India, 400092.28 AADCS2886E SDFC Finance Ltd The entity received/transferred funds from/to Kelvin and

Cromakem.29 AAACK6201G Kosha Cubidor

Containers Ltd The entity received/transferred funds from/to Cromakem.

30 AAOPS2034A Mahesh RamanlalShah

1. The entity is one of the directors of Sapan Chemical Limited.2. The entity received shares from Keyur M Shah, promoter of

Kelvin till December 31, 2012, in physical form.3. Ms. Geeta Narendra Shah, Mr. Narendra Ramanlal Shah, Mr.

Mahesh Ramanlal Shah and Mr. Abhishek Narendra Shahshare common address, viz. D-28-205 Yogi Nagar Borivali

West Mumbai.4. Mr. Jayshree Shankar Bhosle, Heema Infocom Limited, Do

Max Steel Limited, Suryamangal Media And EntertainmentLimited, Cornhill Trading Company Pvt Ltd, SapanChemicals Limited, Ms. Padmaben Jagdish Jani, Ms. JalpaMitesh Jani, Cromakem Limited, Acil Cotton IndustriesLimited, Mr. Rupesh Balkrishna Bhoir, Mr. ChiragDineshkumar Shah, Mr. Namdeo Shantaram Gole, Ms.


31 ANIPR5608Q VimalkumarSureshchandra

Raval

1. Ms. Sushma Vimalkumar Raval (Director of Kelvin as perMCA website), Mr. Vimalkumar Sureshchandra Raval, Ms.



2. Vimalkumar Sureshchandra Raval is one of the directors ofZimig Trading Pvt. Ltd. and Acil Cotton Industries Limited.

32 ARYPS5993F Naresh NagindasShah

The entity is director of GFL Financial India Limited.

33 AAPPS6559P Narendra Shah 1. The entity received shares from Keyur M Shah and Kavita K

Shah, promoters of Kelvin till December 31, 2012, in physicalform.

2. Ms. Geeta Narendra Shah, Mr. Narendra Ramanlal Shah, Mr.Mahesh Ramanlal Shah and Mr. Abhishek Narendra Shahshare common address, viz. D-28-205 Yogi Nagar Borivali

West Mumbai.

3. Earth Exim Ltd, Ms. Geeta N Shah, Sapan ChemicalsLimited and Mr. Narendra Ramanlal Shah share commonaddress, viz. 23 Jalaram Nagar Nr. Chamunda Circle GajawalaLane Borivli West, , Mumbai, Maharashtra, India, 400092.

4.

Mr. Narendra R Shah is one of the directors of Earth EximLimited and Universal Credit and Securities Limited.



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5. Narendra Ramanlal Shah and Cromakem Limited sharecommon address, viz. 24,jalaram Nagar,opp.chamundaCircle,gemjawala Lane, Borivali(w), Mumbai Maharashtra,India, 400092.

34 AAAHN2023C Narendra R Shah(HUF)

1. The entity is HUF of Narendra R Shah.

2. The entity received 50,000 shares from Keyur M Shah(HUF), promoter of Kelvin, in physical form, on07/04/2012.

35 AAOPS2033H Geeta NarendraShah

1. The entity received shares from Keyur M Shah and Kavita KShah, promoter of Kelvin till December 31, 2012, in physicalform.


West Mumbai.

3. Earth Exim Ltd, Ms. Geeta N Shah, Sapan ChemicalsLimited and Mr. Narendra Ramanlal Shah share commonaddress, viz. 23 Jalaram Nagar Nr. Chamunda Circle GajawalaLane Borivli West, , Mumbai, Maharashtra, India, 400092.


Varsha Praful Trivedi, Mr. Mahesh Ramanlal Shah, Ms. Geeta

Narendra Shah, Zimig Trading Company Private Limited andMr. Parag Chandrkant Shah share common e-mail ID'[email protected]'.

36 BFVPS2543P Abhishek N Shah 1. The entity received shares from Keyur M Shah and Kavita KShah, promoter of Kelvin till January 15, 2013, in physicalform.


West Mumbai.37 ADQPJ5053P Padmaben Jagdish

Jani1. Ms. Sushma Vimalkumar Raval (Director of Kelvin as per

MCA website), Mr. Vimalkumar Sureshchandra Raval, Ms.



2. Mr. Jayshree Shankar Bhosle, Heema Infocom Limited, DoMax Steel Limited, Suryamangal Media And EntertainmentLimited, Cornhill Trading Company Pvt Ltd, SapanChemicals Limited, Ms. Padmaben Jagdish Jani, Ms. JalpaMitesh Jani, Cromakem Limited, Acil Cotton Industries

Limited, Mr. Rupesh Balkrishna Bhoir, Mr. Chirag



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Dineshkumar Shah, Mr. Namdeo Shantaram Gole, Ms.Varsha Praful Trivedi, Mr. Mahesh Ramanlal Shah, Ms. GeetaNarendra Shah, Zimig Trading Company Private Limited andMr. Parag Chandrkant Shah share common e-mail ID'[email protected]'.

38 AMVPJ5720H Jalpa Jani 1. Ms. Sushma Vimalkumar Raval (Director of Kelvin as perMCA website), Mr. Vimalkumar Sureshchandra Raval, Ms.Padmaben Jagdish Jani, Ms. Jalpa Mitesh Jani, Mr. Jagdish



2. Mr. Jayshree Shankar Bhosle, Heema Infocom Limited, DoMax Steel Limited, Suryamangal Media And EntertainmentLimited, Cornhill Trading Company Pvt Ltd, SapanChemicals Limited, Ms. Padmaben Jagdish Jani, Ms. Jalpa

Mitesh Jani, Cromakem Limited, Acil Cotton IndustriesLimited, Mr. Rupesh Balkrishna Bhoir, Mr. ChiragDineshkumar Shah, Mr. Namdeo Shantaram Gole, Ms.


39 AKSPM3939N Kirti Mehta As per the bank Account No. 911010005936771 of Kirti Mehtawith Axis Bank Limited, the entity received/transferred fundsfrom/to Kelvin, Cromakem Limited, Stardom Trading Co. Pvt.Ltd., Fast Track Entertainment Limited, Earth Exim Limited,Cornhill Trading Co. Pvt. Ltd., IFSL Limited, GFL FinancialIndia Limited, Inventure Finance Pvt. Ltd., Sonal International

Limited, Kosha Cubidor Containers Limited and Acil CottonIndustries Limited

40 AFMPB0449P Jayshree ShankarBhosle



2. Jaishree Shankar Bhosle is the promoter of Sapan ChemicalLimited, as per BSE website.

41 ALZPB9604R Rupesh BalkrishnaBhoir

Mr. Jayshree Shankar Bhosle, Heema Infocom Limited, Do MaxSteel Limited, Suryamangal Media And Entertainment Limited,Cornhill Trading Company Pvt Ltd, Sapan Chemicals Limited,Ms. Padmaben Jagdish Jani, Ms. Jalpa Mitesh Jani, CromakemLimited, Acil Cotton Industries Limited, Mr. Rupesh BalkrishnaBhoir, Mr. Chirag Dineshkumar Shah, Mr. Namdeo ShantaramGole, Ms. Varsha Praful Trivedi, Mr. Mahesh Ramanlal Shah, Ms.Geeta Narendra Shah, Zimig Trading Company Private Limitedand Mr. Parag Chandrkant Shah share common e-mail ID'[email protected]'.



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42 ARIPG5267E Gole NamdeoShantaram

Mr. Jayshree Shankar Bhosle, Heema Infocom Limited, Do MaxSteel Limited, Suryamangal Media And Entertainment Limited,Cornhill Trading Company Pvt Ltd, Sapan Chemicals Limited,Ms. Padmaben Jagdish Jani, Ms. Jalpa Mitesh Jani, CromakemLimited, Acil Cotton Industries Limited, Mr. Rupesh BalkrishnaBhoir, Mr. Chirag Dineshkumar Shah, Mr. Namdeo Shantaram

Gole, Ms. Varsha Praful Trivedi, Mr. Mahesh Ramanlal Shah, Ms.Geeta Narendra Shah, Zimig Trading Company Private Limitedand Mr. Parag Chandrkant Shah share common e-mail ID'[email protected]'.

43 CFPPS4835H ChiragDineshkumar Shah

Mr. Jayshree Shankar Bhosle, Heema Infocom Limited, Do MaxSteel Limited, Suryamangal Media And Entertainment Limited,Cornhill Trading Company Pvt Ltd, Sapan Chemicals Limited,Ms. Padmaben Jagdish Jani, Ms. Jalpa Mitesh Jani, CromakemLimited, Acil Cotton Industries Limited, Mr. Rupesh BalkrishnaBhoir, Mr. Chirag Dineshkumar Shah, Mr. Namdeo ShantaramGole, Ms. Varsha Praful Trivedi, Mr. Mahesh Ramanlal Shah, Ms.Geeta Narendra Shah, Zimig Trading Company Private Limitedand Mr. Parag Chandrkant Shah share common e-mail ID

'[email protected]'.44 ARRPS2518R Parag ChandrkantShah

Mr. Jayshree Shankar Bhosle, Heema Infocom Limited, Do MaxSteel Limited, Suryamangal Media And Entertainment Limited,Cornhill Trading Company Pvt Ltd, Sapan Chemicals Limited,Ms. Padmaben Jagdish Jani, Ms. Jalpa Mitesh Jani, CromakemLimited, Acil Cotton Industries Limited, Mr. Rupesh BalkrishnaBhoir, Mr. Chirag Dineshkumar Shah, Mr. Namdeo ShantaramGole, Ms. Varsha Praful Trivedi, Mr. Mahesh Ramanlal Shah, Ms.Geeta Narendra Shah, Zimig Trading Company Private Limitedand Mr. Parag Chandrkant Shah share common e-mail ID'[email protected]'.

45 ABBPT1431A Varsha Trivedi Mr. Jayshree Shankar Bhosle, Heema Infocom Limited, Do MaxSteel Limited, Suryamangal Media And Entertainment Limited,Cornhill Trading Company Pvt Ltd, Sapan Chemicals Limited,Ms. Padmaben Jagdish Jani, Ms. Jalpa Mitesh Jani, CromakemLimited, Acil Cotton Industries Limited, Mr. Rupesh BalkrishnaBhoir, Mr. Chirag Dineshkumar Shah, Mr. Namdeo ShantaramGole, Ms. Varsha Praful Trivedi, Mr. Mahesh Ramanlal Shah, Ms.Geeta Narendra Shah, Zimig Trading Company Private Limitedand Mr. Parag Chandrkant Shah share common e-mail ID'[email protected]'.

46 AMIPS6846A Zubin KamleshShah

The entity is one of the preferential allottees.

47 AAZPM0394A M.V.R.S Prasad The entity is one of the preferential allottees.

48 AAAHJ0191D Ashok Jashraj JainHUF


49 AAIPS9404N Mithalal ManoharlalSahlot


50 ACKPM8513A ChampabenDevjibhai Makwana


51 AZTPM3476A DeepabenTrabakbhaiMakwana


52 AAAPT3253A Jagdish Hari

Thakur




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53 AATPD0728R Mukesh N Desai The entity is one of the preferential allottees.

54 AAAPV4085A Rajesh GopaldasVillaitramani


55 AAAPT6038P Kamlesh HariTha

Documents

Order in the matter of Kelvin Fincap Limited