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 scrip
of Kelvin during the Examination Period is given below:

0
20000
40000
60000
80000
100000
120000
140000
160000
180000
200000
0
100
200
300
400
500
600
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 cannot prima-facie be 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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were instrumental in the rise in price /buy volume of Kelvin. A set of 22 (twenty two) such
entities (hereinafter referred to as the "Shortlisted Group") of Kelvin Fincap Group was
shortlisted on the basis of following parameters, viz.

A. Top 10 entities based on gross buy quantity;
B. Top 10 entities based on positive contribution in last traded price (hereinafter referred
to as "LTP");
C. Promoters/Directors of Kelvin who transacted with other members of Kelvin Fincap
Group by way of funds / securities or, had any other relationship with them.

6. The particulars of the members of the Shortlisted Group and the basis of their inter-se
relationship/connection are given in the following table :

Table 1: Basis of inter-se relationship/ connection amongst the Shortlisted Group.
Sl No PAN Name Basis of Relationship
1 AAACD1880G Dahyhabhai Shares
and Stock Brokers
Ltd.
1. The entity is the promoter of Kelvin as on June 30, 2014
as per BSE website.
2. The entity has received ` 25,000 from Cromakem
Limited on 12/05/2012.
2. AAHPS4084K Keyur M Shah 1. The entity is the director of Dahyhabhai Shares and Stock
Brokers Ltd as per MCA website and was a promoter of
Kelvin as per shareholding pattern disclosed on BSE
website for quarter ending December 2012.
2. The entity transferred shares to Mr. Narendra R Shah,
Mr. Mahesh R Shah, Mr. Abhishek N Shah and Ms.
Geeta N Shah in physical form.
3. AAAHK5034L Keyur M Shah
(HUF)
1. The entity is HUF with Keyur M Shah as karta and was a
promoter of Kelvin as per shareholding pattern disclosed
on BSE website as on March 31, 2012.
2. The entity transferred shares to Narendra R Shah (HUF)
in physical form on 07/04/2012.
4. AAYPS3458E Kavita K Shah 1. The entity is the director of Dahyhabhai Shares and Stock
Brokers Ltd as per MCA website and a promoter of
Kelvin as per shareholding pattern disclosed on BSE
website for quarter ending December 2012. She also
shares common address with Keyur M Shah viz, 22 / 23,
Purab Apartment, 42, B. G. Kher Marg, Malbar Hill
Mumbai 400006.
2. The entity transferred shares to Mr. Narendra R Shah,
Mr. Abhishek N Shah and Ms. Geeta N Shah in physical
form on 07/04/2012.
5. ALRPB9295L Bhavik Satish Badani 1. The entity is director of Kelvin as per BSE and MCA
websites.
2. The entity is one of the directors of Cromakem Limited.
6. AIDPP3653M Bipin Bhikhabhai
Patel
1. The entity is director of Kelvin as per BSE and MCA
websites.
2. The entity shares common address, viz. 401 B-28, Shanti
Nagar Co. Op. Hsg. Ltd. Shanti, Nagar, Sec - 7, Above Indra
Hospital, Mira Road,, Mumbai - 401107 with Mr. Jitendra
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Patel, director of RFL International Limited and Fast
Track Entertainment Limited.
7. BBPPE7839K Sushma Vimalkumar
Raval
1. The entity is one of the directors of Kelvin as per MCA
website.
2. The entity is also director of Millennum Cybertech
Limited.
3. The entity shares common address, viz. 23 Shri Ram
Vihar Rokadia Lane, Borivali West, Mumbai, 400092, with
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 Acil Cotton
Limited) and Mr. Mitesh Jagdish Jani (Director of
Novagold Petro-Resources Limited).
8. AJMPS0962J Mahendrabhai
Sakalchand Shah
Website.
2. The entity is also a director of Heema Infocom Limited
and 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 of
Kelvin and Cromakem Limited.

2. Narendra Ramanlal Shah and Cromakem Limited share
common address, viz. 24, jalaram Nagar, opp.chamunda
Circle, 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, Sonal
International Limited, Stardom Trading Co. Pvt. Ltd. and
IFSL Limited.

4. Mr. Jayshree Shankar Bhosle, Heema Infocom Limited,
Do Max Steel Limited, Suryamangal Media And
Entertainment Limited, Cornhill Trading Company Pvt
Ltd, Sapan Chemicals Limited, Ms. Padmaben Jagdish
Jani, Ms. Jalpa Mitesh Jani, Cromakem Limited, Acil
Cotton Industries Limited, Mr. Rupesh Balkrishna Bhoir,
Mr. Chirag Dineshkumar Shah, Mr. Namdeo Shantaram
Gole, Ms. Varsha Praful Trivedi, Mr. Mahesh Ramanlal
Shah, Ms. Geeta Narendra Shah, Zimig Trading
Company Private Limited and Mr. Parag Chandrkant
Shah share common e-mail ID
'NOVAGOLD2007@YAHOO.CO.IN'.

5. The entity received/transfered funds from/to SDFC
Finance Limited and Kosha Cubidor Containers Limited.

11. AACCD7020L Do Max Steel
Limited
1. The entity shares common director, Mr. Vishal Kumar
Shah, with Kelvin, Cornhill Trading Co. Pvt. Ltd. and
Earth Exim Limited.

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12. AAHCS1332H Stardom Trading
Company Pvt. Ltd
1. Cornhill Trading Company Pvt Ltd, Stardom Trading
Company Pvt Ltd and Acil Cotton Industries Limited
share common address, viz. 38, Ganga Vihar, 3rd Floor,
Rokadia Lane, Borivali (w), Mumbai - 400092.
2.
Ms. Pallavi Chetan Pandit is one of the directors of
IFSL Limited.
3.
Cornhill Trading Company Pvt Ltd, Earth Exim Ltd,
Stardom Trading Company Pvt Ltd, Mr. Rupesh
Balkrishna Bhoir, Fast Track Entertainment Limited and
Mr. Chirag Dineshkumar Shah, share common e-mail ID
'NOVAGOLD2011@GMAIL.COM'.
13. AAFCS2725Q Sapan Chemicals
Limited
1. Earth Exim Ltd, Ms. Geeta N Shah, Sapan Chemicals
Limited and Mr. Narendra Ramanlal Shah share common
address, viz. 23 Jalaram Nagar Nr. Chamunda Circle
Gajawala Lane Borivli West, , Mumbai, 400092.
2.
Ms. Sushma Vimalkumar Raval (Director of Kelvin as per
MCA 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 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,
4.
Jaishree Shankar Bhosle is the promoter of Sapan
Chemical Limited, as per BSE website.
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14. AAACF7961Q Fast Track
Entertainment
Limited
1. Director of Fast Track Entertainment Limited and RFL
International 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, 401107
2. Acil Cotton Industries Limited and Fast Track
Entertainment Limited share common address, viz. B-
7/404 A, Natraj Township Part-ii,near Parshuram Nagar
Society, Sayaji Ganj,, Vadodara, Gujarat, India, 390005.
3. Cornhill Trading Company Pvt Ltd, Earth Exim Ltd,
15. AACCC0591P Cornhill Trading
Company Pvt. Ltd
1. Mr. Vishal Kumar Shah is one of the directors of Kelvin,
Cornhill Trading Co. Pvt. Ltd., Earth Exim Limited and
Do Max Steel Limited.
2. Universal Credit and Securities Limited, Suryamangal
Media And 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.
Rokadia Lane, Borivali (w), Mumbai, Maharashtra, India,
400092.
4. Ms. Pallavi Chetan Pandit is one of the director of
IFSL Limited.
16. AACCS1185R Sonal International
Ltd
1. Ms. Pallavi Chetan Pandit is one of the directors of
IFSL Limited.

2. Sonal International Ltd and RFL International Limited
share common address, viz. 304, Akruti
Complex,nr.stadium Six Cross Road, Navrangpura,,
Ahmedabad, Gujarat, India, 380009.
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17. AAACO2454R Nova Gold Petro
Resources Limited
1. Ms. Sushma Vimalkumar Raval (Director of Kelvin as per
Cotton Limited as per MCA website) 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.

2. The entity received `25,00,000 from Cromakem Ltd on
20/11/2013.

18.

AABCA7788F Acil Cotton
Industries Limited
Rokadia Lane, Borivali (w), Mumbai, 400092.

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

address, viz. 23 Shri Ram Vihar Rokadia Lane, Borivali West,
Mumbai, 400092.


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

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19. AAACZ6848C Zimig Trading
Company Private
Limited

1.1.1 Vimalkumar Raval is one of the directors of Zimig
Trading Pvt. Ltd. and Acil Cotton Industries Limited.
20. AMVPJ5720H Jalpa Jani 1. Ms. Sushma Vimalkumar Raval (Director of Kelvin as per
address, viz. 23 SHRI RAM VIHAR ROKADIA LANE,
BORIVALI WEST, MUMBAI, 400092.

'NOVAGOLD2007@YAHOO.CO.IN'
21. AKSPM3939N Kirti Mehta As per the bank Account No. 911010005936771 of Kirti
Mehta with Axis Bank Limited, the entity
received/transferred funds from/to Kelvin, Cromakem
Limited, Stardom Trading Co. Pvt. Ltd., Fast Track
Entertainment Limited, Earth Exim Limited, Cornhill
Trading Co. Pvt. Ltd., IFSL Limited, GFL Financial India
Limited, Inventure Finance Pvt. Ltd., Sonal International
Limited, Kosha Cubidor Containers Limited and Acil
Cotton Industries Limited.
22. AFMPB0449P Jayshree Shankar
Bhosle
2. Jaishree Shankar Bhosle is the promoter of Sapan
Chemical Limited as per BSE website.
Page 9 of 55

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 the Kelvin Fincap Group during January
01, 2012 to March 31, 2014, were observed. Instances of such inter se fund 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. 10000000
21-03-2012 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 205000
11/2/2012 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 Private
Limited
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 Entertainment
Pvt 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 Brokers
Ltd.
28/03/2013 Cromakem Limited Padmaben Jagdish Jani 510000
20/05/2013 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 Group entities were observed to have transferred
shares in physical form as well as in dematerialised form within the group and started
trading 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 Group in 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 out of the 24 instances of positive
contribution to the LTP, Kelvin Fincap Group contributed 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 Group to price rise in Patch 1
PAN Name Contribution
in positive
LTP (in `)
No. of
Instances
of positive
LTP
Contribution to
New High
Price (in `)
No. of
Instances of
New High
Price
AAACF7961Q Fast Track Entertainment
Limited
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
Page 12 of 55

14. It was observed that the Shortlisted Group contributed to the positive LTP to the extent of
`47/-, which was 90.04% of the contribution made by the Kelvin Fincap Group to the extent of
`52.20/-. It was further observed that the Shortlisted Group has contributed in establishing
new high price to the extent of `18.80/-, which is 98.95% of the Kelvin Fincap Group's overall
contribution of `19/-.

Patch 2: July 24, 2013 to May 29, 2014 (post share split)

15. During Patch 2, price of Kelvin rose from ` 118/- to ` 535/- and was accompanied by a
substantial rise in the traded volumes. The average volume in the scrip during Patch 2
increased to 40,974 shares from 22,237 shares in Patch 1. It was observed that during Patch
2, Kelvin Fincap Group collectively bought 81,99,511 shares (97.62% of traded volume) and
sold 81,12,737 shares (96.58% of traded volume) out of a total of 83,99,726 shares traded at
BSE . As high as 80,53,453 shares which constitute 95.88% of traded volume, were traded
amongst the Kelvin Fincap Group entities. As high as 98.22% of their total buy volume
matched with the sell orders of one or the other Kelvin Fincap Group entity. Similarly, 99.27%
of their sell volume matched with the buy orders within the Kelvin Fincap Group.

16. It was observed that during Patch 2, out of a total of 81 instances of trades establishing new
high price in the scrip, the Kelvin Fincap Group established new high price on as many as 64
instances. The contribution of the Kelvin Fincap Group in establishing new high price was `
328.10/-, which constitutes 77.75% of total new high price of ` 422/- in this Patch.

17. On LTP analysis during Patch 2, it was observed that out of the 472 instances of positive
contribution to the LTP, Kelvin Fincap Group contributed to positive LTP in as many as 414
instances. By executing such trades above the LTP, Kelvin Fincap Group contributed to the
positive LTP to the extent of `1,712.65/-, which was 86.25% of overall positive LTP
contribution of `1,985.65/-. in the scrip. The details of contribution to price rise by the
Kelvin Fincap Group during Patch 2 are as under:

Table 4: Contribution of Kelvin Fincap Group to price rise in Patch 2
PAN Name Contributio
n to Positive
LTP (in `)
No. of
Instance
s to
Positive
LTP
Contributio
n to New
High Price
(in `)
No. of
Instance
s to New
High
Price
AAFCS2725Q Sapan Chemicals Limited 233.1 51 40.5 8
AACCD7020L Do Max Steel Limited 216.15 45 52.6 7
Page 13 of 55

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 & Entertainment
Ltd
63.45 18 19 4
AAACZ6848C Zimig Trading Company Private
Limited
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 2
ALZPB9604R 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 Private
Limited
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's overall 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
Page 14 of 55

orders placed in those trades persistently matched. An illustration of the trading patterns of
order placements followed by Kelvin Fincap Group entities 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 sell
orders 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 Buy
Order
Time
Buy
Order
Quantity
Buy
Order
Price
Jayshree Shankar Bhosle 14:44:24 3750 340
Nova Gold Petro Resources
Limited
14:48:36 1700 340
Stardom Trading Company Pvt
Ltd
14:54:23 550 340
Fast Track Entertainment Limited 14:55:15 400 340
Cornhill Trading Company Pvt
Ltd
14:57:22 300 340
Cromakem Limited 14:58:05 100 340
IFSL Limited 14:58:31 100 340
Stardom Trading Company Pvt
Ltd
14:58:59 100 340

Page 15 of 55

Day wise Trading Analysis
21. The shares of Kelvin were traded on 231 days during the Examination Period. It was
observed that on the days when the Kelvin Fincap Group did not trade, the average
volume in the scrip was significantly low. The details of groups concentration vis-a-vis
average volume in the scrip during the Examination Period are as under:

Table 6: Concentration of Kelvin Fincap Group
Group's Concentration No. of Days Average
Market
Volume
No Trading 1 25
Between 0% and 50% 10 5,743
Between 50% and 80% 13 13,705
Between 80% and 100% 152 44,370
100% 55 36,328
Total 231 38,865

22. Thus, the Kelvin Fincap Groups concentration in the scrip was significant on the
majority of the days it traded and the average volume in the scrip increased with an
increase in groups concentration. Also, on 55 out of 231 days, Kelvin Fincap Group was
present in all the trades, both on buy and sell sides and average volume of 36,328
shares was created on account of trades amongst the entities of Kelvin Fincap Group.

23. It was observed that out of the trades of Kelvin Fincap Group during the Examination
Period, the Shortlisted Group bought 72,83,765 shares, which constitutes 83.27% of
Kelvin Fincap Group's total purchase volume of 87,47,329 shares. Further, the Shortlisted
Group contributed to the positive LTP to the extent of `1,450.25/- which was 82.17%
of the contribution made by the Kelvin Fincap Group to the extent of `1,764.85/-. The
Shortlisted Group also contributed in establishing new high price to the extent of
`288.40/-, which is 83.09% of the Kelvin Fincap Group's overall contribution of
`347.10/-.

24. In view of the above analysis, it was observed that, in this case, the connected/related
entities of Kelvin Fincap Group continuously and persistently traded in substantial
volumes in the scrip of Kelvin which was an illiquid one. They traded among
themselves substantially and executed matched trades in very large number. In these
Page 16 of 55

matched trades amongst connected/ related entities of Kelvin Fincap Group there 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-alia stating 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/Entities
Number 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
Page 17 of 55

26 Manisha Pramesh Rambhia 200000
27 Nirmala Shantilal Maru 400000
28 Sejul Pratish Maru 100000
29 Mitesh Rajnikant Shah 150000
30 Bhavini B.Furia 250000
31 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 150000
40 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 Certificate
Number
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
Page 18 of 55

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 4151000
17 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 7251000
32 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 8051000
36 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 11351000
50 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
Page 19 of 55

27. From the above, it is observed that Kelvin had prima 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 is prima-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 Group on 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 AAHCS4914K
Suryamangal Media & Entertainment
Ltd 6215-6306 13099001 13996000
Page 20 of 55

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 Group on 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 Of
Transaction
Transferor
Name
Transferee Name Quantity
Transferred
07/04/2012 Keyur M Shah
HUF
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 200000
07/04/2012 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 40000
14/04/2012 Keyur M Shah Geeta Narendra Shah 50000
14/04/2012 Keyur M Shah Narendra R Shah 80000

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 quarter
ended 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
Page 21 of 55

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: MCA
website as on April 25, 2014)
List of Directors (Source: BSE Website
as on April 25, 2014)
Bhavik Satish Badani Mansukh Sanghvi
Bipin Bhikhabhai Patel Bhavik Satish Badani
Sushma Vimalkumar Raval Bipin Bhikhabhai Patel
Mahendrabhai 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 Group are as follows:
Table 11: Connection with other Kelvin Fincap Group Entities
Name of Director Connection with other Kelvin Fincap Group Entities
Bhavik Satish Badani He is one of the directors of Cromakem Limited.
Bipin Bhikhabhai Patel He shares common address with Mr. Jitendra Patel, director of RFL
International Limited and Fast Track Entertainment Limited.
Sushma Vimalkumar
Raval
She is one of the directors of Millennum Cybertech Limited.
She also shares common address with 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 Acil Cotton Limited) and Mr. Mitesh
Jagdish Jani (Director of Novagold Petro-Resources Limited).
Mahendrabhai
Sakalchand Shah
He is one of the directors of Heema Infocom Limited and GFL
Financial India Limited.
Vishal Kumar Shah He is one of the directors of Cornhill Trading Co. Pvt. Ltd., Earth
Exim Limited and Do -Max Steel Limited.

Page 22 of 55

34. I note from the above examination and the factors mentioned at Annexure A, that the
entities belonging to the Kelvin Fincap Group are prima-facie related/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 Group started
trading in the said shares. The Kelvin Fincap Group entities 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
Group entities 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 would
always wish to purchase shares at the lowest available price. The modus operandi used by
Kelvin Fincap Group to 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
facie indicate that Kelvin issued new shares to certain entities, which were subsequently
Page 23 of 55

transferred by these allottees to other Kelvin Fincap Group entities. 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 Group entities 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:-
fraud includes any act, expression, omission or concealment committed whether in a deceitful manner or not
by a person or by any other person with his connivance or by his agent while dealing in securities in order to
induce another person or his agent to deal in securities, whether or not there is any wrongful gain or avoidance of
any loss, and shall also include

(1) a knowing misrepresentation of the truth or concealment of material fact in order that another person may
act 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 anything
derived 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 that Kelvin Fincap Group entities
adopted 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 substantial
acquisition of securities or control.

12A. No person shall directly or indirectly
Page 24 of 55

(a) use or employ, in connection with the issue, purchase or sale of any securities listed or proposed to be
listed on a recognized stock exchange, any manipulative or deceptive device or contrivance in contravention
of 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 which
are 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 upon
any person, in connection with the issue, dealing in securities which are listed or proposed to be listed on a
recognised stock exchange, in contravention of the provisions of this Act or the rules or the regulations made
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 listed
in a recognized stock exchange, any manipulative or deceptive device or contrivance in contravention of the
provisions of the Act or the rules or the regulations made there under;
(c) employ any device, scheme or artifice to defraud in connection with dealing in or issue of securities which
are listed or proposed to be listed on a recognized stock exchange;
(d) engage in any act, practice, course of business which operates or would operate as fraud or deceit upon
any person in connection with any dealing in or issue of securities which are listed or proposed to be listed on
a recognized stock exchange in contravention of the provisions of the Act or the rules and the regulations
made there under.

"4. Prohibition of manipulative, fraudulent and unfair trade practices
(1) Without prejudice to the provisions of regulation 3, no person shall indulge in a fraudulent or an unfair
trade practice in securities.
(2) Dealing in securities shall be deemed to be a fraudulent or an unfair trade practice if it involves fraud
and may include all or any of the following, namely:-

(a) indulging in an act which creates false or misleading appearance of trading in the securities market;
(b) dealing in a security not intended to effect transfer of beneficial ownership but intended to operate only as
a device to inflate, depress or cause fluctuations in the price of such security for wrongful gain or avoidance of
loss;
(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 that Kelvin concealed the actual number of allottees and prima 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
Page 25 of 55

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 directors prima
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 is prima facie in violation of clause 35 of the Listing Agreement
read with section 21 of the Securities Contracts (Regulation) Act, 1956 (hereinafter
referred 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 facie violated 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 Group as
described above is prima facie inimical to the interests of participants in the securities
market. It is noted that the entities of Kelvin Fincap Group have 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 Group is still actively trading
in 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
Page 26 of 55

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 Group to
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 Group which 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 Group Entities holding substantial shares in Kelvin
S.No. PAN Name Shareholding
No. %
1 AAACM0623J Inventure Finance Private Limited 1106112 3.95
2 ARYPS5993F Naresh Nagindas Shah 1009163 3.61
3 AAFCS2725Q Sapan Chemicals Limited 863281 3.08
4 AACCD7020L Do Max Steel Limited 757224 2.71
5 AATPD0728R Mukesh Nanubhai Desai 734527 2.62
6 AAACR9384B RFL International Limited 700602 2.50
7 ALZPB9604R Rupesh Balkrishna Bhoir 699902 2.50
8 AAJPB7775N Kavita Sunish Behl 675500 2.41
9 AMVPJ5720H Jalpa M Jani 630472 2.25
10 AKSPM3939N Kirti Kantilal Mehta 522345 1.87
11 AAOPS2033H Geeta Narendra Shah 400000 1.43
12 AADPS8752L Hasmukhlal Ramanlal Shah 391300 1.40
13 AIKPM4674N Shobhanaben N. Moradia 390750 1.40
14 AMTPM0749H Bharat N. Moradiya 390600 1.40
15 AEGPD4889J Vasantben Dhanjibhai Donda 385590 1.38
16 AIVPM3622K Mukesh N. Moradia 384160 1.37
17 AIVPM3623J Shehul V. Moradia 378377 1.35
18 ACXPP9049B Bhimjibhai D. Chanchapara 374950 1.34
19 AEIPD5332A Dhanjibhai S. Donda 366460 1.31
20 ACXPP9026C Vallabhbhai D. Sachapra 360900 1.29
21 AMTPM8714C Hiren Tulsibhai Moradia 339500 1.21
22 ACRPM4534E Rajesh Moradia 334900 1.20
Page 27 of 55

23 AFMPB0449P Jayshree Shankar Bhosle 325847 1.16
24 AACCC0591P Cornhill Trading Company Pvt Ltd 316521 1.13
25 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
by Kelvin 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-parte order 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-parte order:

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, till further directions:
Sl.
No.
Name of the entity PAN
1 Kelvin Fincap Limited AAACD1881H
2 Keyur M Shah AAHPS4084K
3 Keyur M Shah (HUF) AAAHK5034L
4 Kavita K Shah AAYPS3458E
5 Dahyabhai Shares And Stock Brokers Ltd AAACD1880G
6 Bhavik Satish Badani ALRPB9295L
7 Bipin Bhikhabhai Patel AIDPP3653M
8 Sushma Vimalkumar Raval BBPPE7839K
9 Mahendrabhai Sakalchand Shah AJMPS0962J
10 Mansukh Sanghvi ABJPS8618E
11 Vishal Kumar Shah AYBPS0534J
12 Surekhaben K Shah BORPS0804Q
13 Cromakem Limited AAECC0841Q
Page 28 of 55

14 Do Max Steel Limited AACCD7020L
15 Stardom Trading Company Pvt Ltd AAHCS1332H
16 Sapan Chemicals Limited AAFCS2725Q
17 Fast Track Entertainment Limited AAACF7961Q
18 Cornhill Trading Company Pvt Ltd AACCC0591P
19 Sonal International Ltd AACCS1185R
20 Jalpa Jani AMVPJ5720H
21 Kirti Mehta AKSPM3939N
22 Jayshree Shankar Bhosle AFMPB0449P
23 Nova Gold Petro Resources Limited AAACO2454R
24 Acil Cotton Industries Limited AABCA7788F
25 Zimig Trading Company Private Limited AAACZ6848C
26 Inventure Finance Private Limited AAACM0623J
27 Naresh Nagindas Shah ARYPS5993F
28 Mukesh Nanubhai Desai AATPD0728R
29 RFL International Limited AAACR9384B
30 Rupesh Balkrishna Bhoir ALZPB9604R
31 Kavita Sunish Behl AAJPB7775N
32 Geeta Narendra Shah AAOPS2033H
33 Hasmukhlal Ramanlal Shah AADPS8752L
34 Shobhanaben N. Moradia AIKPM4674N
35 Bharat N. Moradiya AMTPM0749H
36 Vasantben Dhanjibhai Donda AEGPD4889J
37 Mukesh N. Moradia AIVPM3622K
38 Shehul V. Moradia AIVPM3623J
39 Bhimjibhai D. Chanchapara ACXPP9049B
40 Dhanjibhai S. Donda AEIPD5332A
41 Vallabhbhai D. Sachapra ACXPP9026C
42 Hiren Tulsibhai Moradia AMTPM8714C
43 Rajesh Moradia ACRPM4534E
44 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.

Page 29 of 55

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 14
th
, 2014 RAJEEV KUMAR AGARWAL
PLACE: MUMBAI WHOLE TIME MEMBER

Page 30 of 55

ANNEXURE - A
S.
No.
PAN Name Basis of Relationship
1 AAACD1880G Dhayhabhai Shares
and Stock Brokers
Pvt. Ltd.
1. The entity is the promoter of Kelvin Fincap Limited
("Kelvin") as on June 30, 2014 as per BSE website.

2. The entity has received `25,000 from Cromakem Limited on
12/05/2012.
2 AAHPS4084K Keyur M Shah 1. The entity is director of Dhayhabhai Shares and Stock
Brokers Pvt. Ltd and was promoter of Kelvin as per
shareholding pattern on BSE website quarter ending
December 31, 2012.

2. The entity transferred shares to Mr. Narendra R Shah, Mr.
Mahesh R Shah, Mr. Abhishek N Shah and Ms. Geeta N
Shah in physical form.
3 AAAHK5034L Keyur M Shah
(HUF)
1. The entity is an HUF with Keyur M Shah as the karta and
was the promoter of Kelvin as on March 31, 2012 as per BSE
website.

2. The entity transferred 50,000 shares to Narendra R Shah
(HUF) in physical form on 07/04/2012.
4 AAYPS3458E Kavita K Shah 1. The entity is director of Dhayhabhai Shares and Stock
Brokers Pvt. Ltd and was promoter of Kelvin as per
shareholding pattern on BSE website for quarter ending
December 31, 2012. She also shares common address with
Keyur M Shah viz, 22 / 23, Purab Apartment, 42, B. G. Kher
Marg, Malbar Hill Mumbai 400006.

2. The entity transferred shares to Mr. Narendra R Shah, Mr.
Abhishek N Shah and Ms. Geeta N Shah in physical form, on
07/04/2012.
5 ALRPB9295L Bhavik Satish
Badani
1. The entity is director of Kelvin as per MCA and BSE
websites

2. The entity is one of the directors of Cromakem Limited.
6 AIDPP3653M Bipin Bhikhabhai
Patel
1. The entity is one of the directors of Kelvin as per MCA and
BSE website.

2. The entity shares common address, viz. 401 B-28, Shanti
Nagar Co. Op. Hsg. Ltd. Shanti, Nagar, Sec - 7, Above Indra
Hospital, Mira Road, Mumbai, 401107, with Mr. Jitendra
Patel (director of RFL International Limited and Fast Track
Entertainment Limited).
7 BBPPE7839K Sushma
Vimalkumar Raval
website.

2. The entity is also the director of Millennum Cybertech
Limited.

3. The entity shares common address, viz. 23 Shri Ram Vihar
Rokadia Lane, Borivali West, Mumbai, 400092, with 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 Acil Cotton Limited) and Mr.
Mitesh Jagdish Jani (Director of Novagold Petro-Resources
Limited).
Page 31 of 55

8 AJMPS0962J Mahendrabhai
Sakalchand Shah
1. The entity one of the directors of Kelvin as per MCA
Website.

2. The entity is also a director of Heema Infocom Limited and
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 of Kelvin
and Cromakem Limited.

common address, viz. 24, jalaram Nagar, opp.chamunda
Circle, 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, Sonal International
Limited, Stardom Trading Co. Pvt. Ltd. and IFSL Limited

4. Mr. Jayshree Shankar Bhosle, Heema Infocom Limited, Do
Max Steel Limited, Suryamangal Media And Entertainment
Limited, Cornhill Trading Company Pvt Ltd, Sapan
Chemicals Limited, Ms. Padmaben Jagdish Jani, Ms. Jalpa
Mitesh Jani, Cromakem Limited, Acil Cotton Industries
Limited, Mr. Rupesh Balkrishna Bhoir, Mr. Chirag
Dineshkumar Shah, Mr. Namdeo Shantaram Gole, Ms.
Varsha Praful Trivedi, Mr. Mahesh Ramanlal Shah, Ms. Geeta
Narendra Shah, Zimig Trading Company Private Limited and
Mr. Parag Chandrkant Shah share common e-mail ID

5. The entity received/transfered funds from/to SDFC Finance
Limited and Kosha Cubidor Containers Limited.
11 AACCD7020L Do Max Steel
Limited
1. The entity shares common director viz, Mr. Vishal Kumar
Shah, with Kelvin, Cornhill Trading Co. Pvt. Ltd. and Earth
Exim Limited.

12 AAHCS1332H Stardom Trading
Company Pvt Ltd
Company Pvt Ltd and Acil Cotton Industries Limited share
common address, viz. 38, Ganga Vihar, 3rd Floor, Rokadia
Lane, Borivali (w), Mumbai, Maharashtra - 400092.

Limited, Stardom Trading Co. Pvt. Ltd. and IFSL Limited.

Page 32 of 55

Stardom Trading Company Pvt Ltd, Mr. Rupesh Balkrishna
Bhoir, Fast Track Entertainment Limited and Mr. Chirag
Dineshkumar Shah, share common e-mail ID
13 AAFCS2725Q Sapan Chemicals
Limited
address, viz. 23 Jalaram Nagar Nr. Chamunda Circle Gajawala
Lane Borivli West, Mumbai, Maharashtra - 400092.

2. Ms.Sushma Vimalkumar Raval (Director of Kelvin as per
MCA 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 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.


4. Jaishree Shankar Bhosle is the promoter of Sapan Chemical
Limited, as per BSE website.
14 AAACF7961Q Fast Track
Entertainment
Limited
International 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, 401107.

2. Acil Cotton Industries Limited and Fast Track Entertainment
Limited share common address, viz. B-7/404 A, Natraj
Township Part-ii, near Parshuram Nagar Society, Sayaji Ganj,,
Vadodara, Gujarat - 390005.


Page 33 of 55

15 AACCC0591P Cornhill Trading
Company Pvt Ltd
1. Mr. Vishal Kumar Shah is one of the director of Kelvin,
Cornhill Trading Co. Pvt. Ltd., Earth Exim Limited and Do
Max steel limited.

2. Universal Credit and Securities Limited, Suryamangal Media
And 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.

Lane, Borivali (w), Mumbai, Maharashtra, India, 400092.



16 AACCS1185R Sonal International
Ltd

2. Sonal International Ltd and RFL International Limited share
common address, viz. 304, Akruti Complex,nr.stadium Six
Cross Road, Navrangpura,, Ahmedabad, Gujarat, India,
380009.
17 AAACO2454R Nova Gold Petro
Resources Limited
Vihar Rokadia Lane, Borivali West, Mumbai, 400092,
Maharashtra, India.

2. The entity received ` 25,00,000 from Cromakem Ltd on
20/11/2013
18 AAACI4383H IFSL Limited
Ms. Pallavi Chetan Pandit is one of the directors of Cornhill
Limited, Stardom Trading Co. Pvt. Ltd. and IFSL Limited
Page 34 of 55

19 AABCA7788F Acil Cotton
Industries Limited
Lane, Borivali (w), Mumbai, Maharashtra, India, 400092.

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



5. Vimalkumar Raval is one of the directors of Zimig Trading
Pvt. Ltd. and Acil Cotton Industries Limited.
20 AAACZ6848C Zimig Trading
Company Private
Limited

2. Vimalkumar Raval is one of the directors of Zimig Trading
Pvt. Ltd. and Acil Cotton Industries Limited.
21 AAHCS4914K Suryamangal Media
& Entertainment
Ltd
1. The entity is one of the preferential allottees.


Page 35 of 55

22 AABCE3676Q Earth Exim Ltd 1. Mr. Vishal Kumar Shah is one of the directors of Kelvin,
Cornhill Trading Co. Pvt. Ltd., Earth Exim Limited and Do
Max Steel Limited.

Lane Borivli West, , Mumbai, Maharashtra, India, 400092.

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

23 AADCH2621N Heema Infocom
Limited
1. Mr. Mahendrabhai Sakalchand Shah is one of the directors of
Kelvin, Heema Infocom Limited and GFL Financials India
Limited.

24 AABCG0597Q GFL Financial
India Ltd
1. The entity is one of preferential allottees of Kelvin.

2. Mr. Mahendrabhai Sakalchand Shah is one of the directors of
Kelvin, Heema Infocom Limited and GFL Financials India
Limited.

Ltd and GFL Financials India Limited share common
address, viz. 15 Shriram Vihar, Rokadia Lane, Borivali (w),
Mumbai, Maharashtra, India, 400092.
25 AAACR9384B RFL International
Limited .
International 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, 401107, Maharashtra, India.

2. Sonal International Ltd and RFL International Limited share
common address, viz. 304, Akruti Complex,nr.stadium Six
Cross Road, Navrangpura,, Ahmedabad, Gujarat, India,
380009.
26 AABCM8712D Millennum
Cybertech Ltd
Ms. Sushma Vimalkumar Raval is one of the directors of Kelvin
and Millennium Cybertech Limited.

Page 36 of 55

27 AAACU2627G Universal Credit
And Securities Ltd

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 Ramanlal
Shah
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 Shah
share common address, viz. D-28-205 Yogi Nagar Borivali
West Mumbai.
31 ANIPR5608Q Vimalkumar
Sureshchandra
Raval

2. Vimalkumar Sureshchandra Raval is one of the directors of
Zimig Trading Pvt. Ltd. and Acil Cotton Industries Limited.
32 ARYPS5993F Naresh Nagindas
Shah
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 physical
form.

West Mumbai.


Page 37 of 55

common address, viz. 24,jalaram Nagar,opp.chamunda
Circle,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, on
07/04/2012.
35 AAOPS2033H Geeta Narendra
Shah
1. The entity received shares from Keyur M Shah and Kavita K
Shah, promoter of Kelvin till December 31, 2012, in physical
form.

West Mumbai.


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

West Mumbai.
37 ADQPJ5053P Padmaben Jagdish
Jani
Maharashtra, India.

Page 38 of 55

38 AMVPJ5720H Jalpa Jani 1. Ms. Sushma Vimalkumar Raval (Director of Kelvin as per
Maharashtra, India.

39 AKSPM3939N Kirti Mehta As per the bank Account No. 911010005936771 of Kirti Mehta
with Axis Bank Limited, the entity received/transferred funds
from/to Kelvin, Cromakem Limited, Stardom Trading Co. Pvt.
Ltd., Fast Track Entertainment Limited, Earth Exim Limited,
Cornhill Trading Co. Pvt. Ltd., IFSL Limited, GFL Financial
India Limited, Inventure Finance Pvt. Ltd., Sonal International
Limited, Kosha Cubidor Containers Limited and Acil Cotton
Industries Limited
40 AFMPB0449P Jayshree Shankar
Bhosle

2. Jaishree Shankar Bhosle is the promoter of Sapan Chemical
Limited, as per BSE website.
41 ALZPB9604R Rupesh Balkrishna
Bhoir
Mr. Jayshree Shankar Bhosle, Heema Infocom Limited, Do Max
Steel Limited, Suryamangal Media And Entertainment Limited,
Cornhill Trading Company Pvt Ltd, Sapan Chemicals Limited,
Ms. Padmaben Jagdish Jani, Ms. Jalpa Mitesh Jani, Cromakem
Limited, Acil Cotton Industries Limited, Mr. Rupesh Balkrishna
Bhoir, Mr. Chirag Dineshkumar Shah, Mr. Namdeo Shantaram
Gole, Ms. Varsha Praful Trivedi, Mr. Mahesh Ramanlal Shah, Ms.
Geeta Narendra Shah, Zimig Trading Company Private Limited
and Mr. Parag Chandrkant Shah share common e-mail ID
Page 39 of 55

42 ARIPG5267E Gole Namdeo
Shantaram
43 CFPPS4835H Chirag
Dineshkumar Shah
44 ARRPS2518R Parag Chandrkant
Shah
45 ABBPT1431A Varsha Trivedi Mr. Jayshree Shankar Bhosle, Heema Infocom Limited, Do Max
46 AMIPS6846A Zubin Kamlesh
Shah
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 Jain
HUF
49 AAIPS9404N Mithalal Manoharlal
Sahlot
50 ACKPM8513A Champaben
Devjibhai Makwana
51 AZTPM3476A Deepaben
Trabakbhai
Makwana
52 AAAPT3253A Jagdish Hari
Thakur
Page 40 of 55

53 AATPD0728R Mukesh N Desai The entity is one of the preferential allottees.
54 AAAPV4085A Rajesh Gopaldas
Villaitramani
55 AAAPT6038P Kamlesh Hari
Thakur
56 ACJPN8415H Prameela
Mohandas
57 AABPK2469A Ashok Gopaldas
Kripalani
58 AAEPT2433N Mrs. Lajwanti Hari
Thakur
59 AAJPS0851L Mitesh Rajnikant
Shah
60 AARPJ2757L Ramniranjan C
Jhunjhunwala
61 AETPA7958N Prem Aggarwal The entity is one of the preferential allottees.
62 AAFPS1767F Ketan
Bhupendrakumar
Shah
63 AACHM2754B Mukesh N Desai
(HUF)
64 AHCPP2686C Poonam
Pramesagar
Pasricha
65 AAIHR3732E Ravi Sancheti
(HUF)

2. The entity transferred a total of 2,00,000 shares to Jitendra
Tejmal Dugar and Dhiraj Parasmal Dugar in physical form.
66 AQQPS2059B Tasneem Iqbal
Syed
67 ABEPN6198B N.Satyanarayana The entity is one of the preferential allottees.
68 ADXPD6143K Mrs.Bhavani
Bharatbhai Danga
69 AGKPM6963C Jignasa Subhash
Mithawalla
70 ACXPP9026C Vallabhbhai D
Sachapara
71 AADPM3931D Subhash Tikamdas
Mithawalla
72 ACXPP9049B B.D.Sachpara The entity is one of the preferential allottees.
73 AAACM0623J Inventure Finance
Private Ltd
2. The entity received `25,22,400 from Cromakem Limited on
13/03/2013.
74 AIVPM3623J Shehul Vallabhbhai
Moradiya
Page 41 of 55

75 AEIPD5332A Dhanjibhai
Shamjibhai Donda
76 ACRPM4534E Rajesh Haribhai
Moradia
77 AIVPM3622K Mukeshbhai
Moradiya
78 AEGPD4889J Vasantben
Dhanjibhai Donda
79 AMTPM8714C Hiren Tulsibhai
Moradia
80 ADPPD5068B KRISHNA
M.DAWDA
81 AIKPM4674N Shobhanaben
Nareshbhai
Mpradiya
82 AMTPM0749H Bharatbhai
Nanjibhai Morada
83 AAJPB7775N Kavita Sunish Behl The entity is one of the preferential allottees.
84 AADPS8752L Hasmukhlal R.Shah The entity is one of the preferential allottees.
85 ABVPJ5592Q Sunita Dinesh
Jaiswal
1. The entity is one of the preferential allottees of Kelvin.

2. The entity transferred 2,20,000 shares to Naresh Nagindas
Shah on 12/8/2013 through off market transactions.
86 ABVPJ5571B Dinesh
Gangaprasad
Jaiswal
1. The entity is one of the preferential allottees of Kelvin.

2. The entity transferred 2,50,000 shares to Naresh Nagindas
Shah on 12/8/2013 through off market transactions.
87 ALEPM6311R Dharmesh
Tulsibhai Moradia
88 AFZPS4055B Falguni Ketan Shah 1. The entity shares common address with Ketan Shah,
preferential allottee.

2. The entity received 1700 shares from Ketan Bhupendrakumar
Shah on 6/11/2013 and transferred the same number of
shares on 27/11/2013 through off market transactions
89 ABOPM3631N Banubibi Sarwar
Mohid
The entity received 3000 shares from Cornhill Trading Company
Pvt Ltd on 26/6/2013 through off market transactions
90 ABOPM3630P Sarwar Abdulkadir
Mohid
91 AABHM5423J Maheshwari
Omprakash
Basantilal (HUF)
The entity received 3000 shares and 5000 shares from Cornhill
Trading Company Pvt Ltd on 8/7/2013 and 16/7/2013
respectively and 2000 shares from Dadima Capital (P) Ltd on
19/11/2013 through off market transactions
92 AKXPR4288E S Rajesh The entity received 5000 shares from Cornhill Trading Company
93 ABOPC2448M Anilbhai Devjibhai
Chauhan
Pvt Ltd on 2/8/2013 and 5500 shares from Dadima Capital (P)
Ltd on 4/9/2013 through off market transactions
Page 42 of 55

94 AAVPU3814B Bharati Bharat
Upadhyay
The entity received 72600 shares from Cromakem Limited on
1/2/2014 through off market transactions and 67400 shares from
Mukesh N Desai (HUF) on 16/11/2013 in physical form
95 AGSPD5628B Niranjanaben
Ashwinkumar
Desai
The entity received 4800 shares from Naresh Nagindas Shah on
96 AAVPS2772G Haresh Rajmal
Shah
97 AABHS8946N Sanjay Madanlal
Sanghvi (HUF)
98 AAAPI4645P Dinesh Dhanjibhai
Italia
99 AAGCR4662J Reachsmart
Construction
Private Limited .
100 AEQPS7882A Priti Vipul Shah The entity received 17400 shares from Naresh Nagindas Shah
from 3/12/2013 to 16/1/2014 through off market transactions
101 AADPT0508R Rekha Manoj
Thakkar
102 AAVPS6090F Mamta Mahesh
Sanghavi
103 ABWPT3678G Chhaya Deepak
Thakker
104 AABPS8536Q Chandrika
Dharmendra
Sanghavi
105 AMVPS6299J Geeta Bharat
Sanghvi
106 BMMPS8777F Rushabh Vipul
Shah
The entity received 13200 shares from Naresh Nagindas Shah
from 3/12/2013 to 21/1/2014 through off market transactions
107 ACQPS5671M Sanjay Madanlal
Sanghvi
108 AXFPS1272E Seema Haresh Shah The entity received 9200 shares from Naresh Nagindas Shah on
109 ACNPS2202F Priti Sanjay Sanghvi The entity received 20000 shares from Naresh Nagindas Shah on
110 AFIPP4761L Dharmeshkumar
Vinodchandra Patel
The entity received 3200 shares each from Sonal International Ltd
and Dadima Capital (P) Ltd. on 30/8/2013 through off market
transactions
111 AABCD2140E Dadima Capital (P)
Ltd
Narendra R Shah is one of the directors of the entity. The entity
received 1,50,000 shares from Stardom Trading Pvt. Ltd. On
August 21, 2013 and 1,00,500 shares from Padmaben Jain on
September 04, 2013 through off market transactions.
Page 43 of 55

112 AHAPP5916H Jaswant Kantilal
Parmar
The entity transfered 11430 shares to Cornhill Trading Company
Pvt Ltd from 7/4/2014 to 28/4/2014 and 5000 shares to Vijay
Govindarajan on 11/4/2014 through off market transactions
113 AIOPG4980F Hiren Kirit Gandhi The entity transfered 2825 shares to Do Max Steel Limited on
114 AQQPG4855K Maruti Shankar
Gaude
The entity transfered 2130 shares to Dadima Capital (P) Ltd on
9/1/2014 and 85025 shares to Earth Exim Ltd. From 9/1/2014
to 6/5/2014 through off market transactions
115 AHNPD1452H Vidyadhar
Ramnaresh Dubey
The entity transfered 4100 shares to Narendra Shah on
2/11/2013, 5530 shares to Dadima Capital (P) Ltd on 9/1/2014
and 61460 shares to Sonal International Limited from 8/2/2014
to 5/3/2014 through off market transactions
116 BPLPR1372B Maheshbhai
Chhanalal Raval
The entity transfered 39350 shares to Naresh Nagindas Shah on
117 BPPPR0616L Amitkumar
Maheshbhai Raval
The entity transfered 29950 shares to Naresh Nagindas Shah on
118 AIYPD1020H Vinod Gajanan
Dhadave
The entity transfered a total of 29925 shares to Naresh Nagindas
Shah on 13/3/2014, 27/3/2014 and 30/4/2014 through off
market transactions
119 BINPP6932L Bharatkumar
Prahladbhai
Prajapati
The entity transferred a total of 10,150 shares to Naresh Shah,
Sonalben Dhirenkumar Patel, Minaben Ambalal Patel, Ambalal
Ranchhodbhai Patel, Bhavika Jaykumar Patel And Keyur Babulal
Patel during the period from 21/11/2013 to 6/3/2014.
120 AOYPM7851H Madhuben H Modi The entity transfered 2900 shares to Naresh Nagindas Shah on
121 AADPA1333M Hansaben
Mahendra Amin
The entity received 200000 shares from GFL Financial India Ltd
on 29/9/2012 in physical form
122 AABPA4050H Mahendra
Dhanjibhai Amin
The entity received 200000 shares from GFL Financial India Ltd
123 AABPD2576M Jitendra Tejmal
Dugar
The entity received 100000 shares from Ravi Sancheti (HUF) on
29/9/2012 in physical form
124 ADXPD9319B Dhiraj Parasmal
Dugar
The entity received 100000 shares from Ravi Sancheti (HUF) on
125 AAACU8715B Umang Projects
Limited
The entity received 1,00,000 shares from Geeta Narendra Shah on
126 AADCS7899F Solex Commercial
& Credit Pvt.Ltd.
The entity received 100000 shares from Narendra R Shah on
127 AAICS0162N Dukes Products
(India) Limited
The entity received 10000 shares from Geeta Narendra Shah on
128 AADCV0856B Viren Shelters
Limited
The entity received 30000 shares from Abhishek N Shah and
70,000 shares from Mahesh R Shah on 30/4/2012 in physical
form
129 AABCA7142D Ankit Biscuits Pvt.
Ltd.
130 AABCD4645E Dukes Consumer
Care Limited
The entity received 50000 shares from Narendra R Shah (HUF)
and 50,000 shares from Narendra R Shah on 30/4/2012 in
physical form
Page 44 of 55

131 AAAHO2774F Omprakash
Agarwal (HUF)
The entity received 40000 shares from Abhishek N Shah on
132 ACLPA3472F Omprakash
Agarwal
133 AFCPJ6983L Ruchit Hiralal Jain The entity received 15000 shares from Mukesh N Desai (HUF) on
134 ADSPA1892P Ajay Shridhar
Acharya
The entity received 15000 shares from Mukesh N Desai (HUF) on
135 AAAPJ9174C Champalal
Mohanlalji Jain
136 ABOPG4132E Vikas Sarwankumar
Gupta
The entity received 30000 shares from Suryamangal Media &
Entertainment Ltd on 6/7/2013 in physical form
137 AAGHM2012J Gopi Krishna
Manepally (HUF)
138 AAGHM2011M Muralikrishna
Manepally
139 ABLPJ0975H Premchand
Gainchand Jain
140 AGJPA1748G Ankit Agarwal The entity received 120000 shares from Suryamangal Media &
141 CAJPS1111F Madhu K
Shyamsukha
142 AJGPK7846K Nitin K Kagzi The entity received 5000 shares from Cromakem Limited on
31/10/2012 and 5,000 shares from Millennum Cybertech Limited
143 AGKPB1054B Suraj Prakash
Bhalla
144 AFCPB9484J Naveen Bhalla The entity received 10000 shares from Poonam Premsagar
Pasricha on 25/7/2013 in physical form
145 AMDPB7288C Garima Bhalla The entity received 10000 shares from Poonam Premsagar
146 ABHPM9092L Sonalben Vijaybhai
Makwana
147 ABHPM9090J Rakshaben
Arunbhai Makwana
148 AAPPM6446H Mohanbhai
Ranchodlal
Makwana
149 AAGPP4875J Jyoti D Parekh The entity received 12500 shares from Poonam Premsagar
150 AHMPP5481H Prakash
Narayanbhai
Prajapati
151 AAAPD5694H Vinod K Doshi The entity received 40000 shares from Mukesh N Desai (HUF) on
Page 45 of 55

152 ALZPP3198A Bhagwatilal Pagaria The entity received 17000 shares from Mukesh N Desai (HUF) on
153 ADGPD0192D Rakesh Dhariwal The entity received 8500 shares from Suryamangal Media &
154 AEEPG7912H Devibai Bhawarlal
Gandhi
155 ABSPT8049H Sadhana Tolasariya The entity received 16000 shares from Mukesh N Desai (HUF) on
156 ABTPT0016D Laxmi Kanta
Tolasariya
157 ADFPJ1887Q Krunal Ramesh
Janani
The entity received 12000 shares from SDFC Finance Ltd on
158 AJSPP5881H Prachi Nitin Kagzi The entity received 7800 shares from Kosha Cubidor Containers
Ltd on 31/10/2012 in physical form
159 AAEPP2449Q Shivali D Parekh The entity received 12500 shares from Poonam Premsagar
160 AHMPP6874C Rakesh
Narayanbhai
Prajapati
161 AQSPS3383G Karnesh
Shyamsukha
162 ABCPN0097M Anand Kumar
Nahar
163 ACTPR0863K Jaya Lalit Shah The entity received 6000 shares from Suryamangal Media &
164 AATPC3367M Bhavna Bharatbhai
Chopra
165 AFYPB2359C Sweetydevi Hitesh
Chopra
166 AAAHC6262J Nemichand B
Chopra Huf
167 AAMPC2665F Bharatkumar
Nemichand Chopra
168 AAQPC7475F Nemichand
Baxiram Chopra
169 ADRPM4459K Mahendra K Mehta The entity received 8500 shares from GFL Financial India Ltd on
170 AEGPS6711Q Suman Rajesh Shah The entity received 6000 shares from Suryamangal Media &
171 AFZPG5363E Mamta Pravin
Gandhi
Page 46 of 55

172 AAPPM6445E Vijaybhai
Mohanbhai
Makwana
173 AAJPJ4929L Babita Mahendra
Jain
The entity received 5500 shares from GFL Financial India Ltd on
174 ACWPJ4028K Anjana Satish Jain The entity received 5500 shares from GFL Financial India Ltd on
175 AAJPJ8038L Rajashree
Nitinkumar Jain
176 ALLPJ0145R Alka Ankit Jain The entity received 5500 shares from GFL Financial India Ltd on
177 AAJPJ4928M Sukhiben Sagarmal
Jain
178 AADHJ2188K Satish Sagarmal Jain
(HUF)
179 AAAHM8205M Mahendra Sagarmal
Jain (HUF)
180 AAAHN4499J Nitin Sagarmal Jain
(HUF)
181 AAKHA9197C Ankit Mahendra
Jain Huf
182 AAUPS6522K Sailesh Pragji Shah The entity received 10000 shares from Suryamangal Media &
183 AAAHN3298K Nainesh G Jain Huf The entity received 8200 shares and 50 shares from Kosha
Cubidor Containers Ltd on 14/7/2012 and 14/8/2012
respectively and 1000 shares from SDFC Finance Limited on
184 AAEPJ2561P Vaishali Nainesh
Jain
The entity received 8300 shares from Kosha Cubidor Containers
Ltd and 1200 shares from SDFC Finance Limited on 14/7/2012
in physical form
185 AACPP8181B Kalpesh D Parekh The entity received 12500 shares from Poonam Premsagar
186 ADVPD5950A Priti Dharewa The entity received 5000 shares from Suryamangal Media &
187 AEDPA7637Q Manish Agrawal The entity received 5000 shares from GFL Financial India Ltd on
188 ACKPS1326D Nitin K Shah The entity received 15000 shares from Suryamangal Media &
189 AFLPD0265J Kapilaben
Umiyashankar Joshi
190 ACXPM5128N Sheetal S Mehta The entity received 8500 shares from GFL Financial India Ltd on
191 ABIPM7371D Chandrika M Mehta The entity received 8500 shares from GFL Financial India Ltd on
192 AACPP8180A Dhirajlal J Parekh The entity received 12500 shares from Poonam Premsagar
Page 47 of 55

193 AAPPM6035J Shardaben
Mohanbhai
Makwana
194 AFDPJ1441A Ankit N Janani The entity received 8000 shares from RFL International Limited
and 4000 shares from SDFC Finance Limited on 14/7/2012 in
physical form
195 ABOPP8114D Manish Porwal The entity received 10000 shares from Suryamangal Media &
196 AABHD3494G Pramod Kumar
Dalmia (HUF)
197 AAAHR0144Q Ramesh C Janani
Huf
The entity received 8000 shares from RFL International Limited
physical form
198 AOQPJ6594N Manav J Janani The entity received 10500 shares from SDFC Finance Ltd on
199 AJCPD4157A Kunal Prabhakar
Deshmukh
200 AAZPD5085B Hema Prabhakar
Deshmukh
201 BMTPS0594M Shreya U Sanghavi The entity received 3500 shares from GFL Financial India Ltd on
202 CAQPK7555L Nimishaben A
Kadia
203 AKSPK4046N Harshadkumar B
Kadia
204 AFNPK8525J Alkeshkumar
Babubhai Kadia
205 AGFPK2166G Shakuntala Karwa The entity received 6500 shares from Mukesh N Desai (HUF) on
206 AAFHP5115A Praveen Chand
Amichand (HUF)
207 AGFPK2169K Kamal Kishore
Karwa
208 AGFPK2167H Venu Gopal Karwa The entity received 6500 shares from Mukesh N Desai (HUF) on
209 AGFPK2155H Shrikant Karwa The entity received 6500 shares from Mukesh N Desai (HUF) on
210 AACHM6405R Makwana Arunbhai
Mohanbhai (HUF)
211 AJCPD8627M Mayuri Prabhakar
Deshmukh
212 AFJPR1610P Ramesh Chhallani The entity received 3000 shares from Suryamangal Media &
213 AAFHS8024K Sheetal S Mehta
Huf
Page 48 of 55

214 AALHR9880C Ramesh Chhallani
Huf
215 AAEHN0043C Narendra C Janani
Huf
The entity received 8200 shares from RFL International Limited
physical form
216 AAAHJ0488F Jitendra C Janani
Huf
The entity received 8900 shares from Universal Credit And
Securities Ltd and 1600 shares from SDFC Finance Limited on
217 AJEPB3408Q Shailesh Z
Bhandari
The entity received 4000 shares from Poonam Premsagar Pasricha
218 ANZPD8205A Anup Prabhakar
Deshmukh
219 ALWPS7304N Rekha Manoj Shah The entity received 40000 shares from Mukesh N Desai (HUF) on
220 ADGPJ0194B Geetaben
Rajeshkumar Jain
221 AEGPN6094P Urmila P Nemani The entity received 3000 shares from Suryamangal Media &
222 AIVPN2183N Prerak P Nemani The entity received 3000 shares from Suryamangal Media &
223 AEMPN1814R Nishant P Nemani The entity received 3000 shares from Suryamangal Media &
224 AKLPJ5402A Minal Krunal
Janani
The entity received 8000 shares from Universal Credit And
Securities Ltd on 14/7/2012 in physical form
225 AJZPP1664P Avinash Porwal The entity received 10000 shares from Suryamangal Media &
226 AABHU0096B U R Sanghvi Huf The entity received 3500 shares from GFL Financial India Ltd on
227 AAFHS1862M Srikant Karwa Huf The entity received 5000 shares from Mukesh N Desai (HUF) on
228 AMTPJ9069K Pooja Jain The entity received 2500 shares from Suryamangal Media &
229 AAEHP3764Q Pawan Kumar
Nemani Huf
230 AAEHK3969C Manoj Z Khivsara
Huf
231 ACAPS2670J Chaya Sailesh Shah The entity received 10000 shares from Suryamangal Media &
232 AACHK9840E Kamal Kishor
Karwa Huf
233 AJHPK7359L Murari Ramnarayan
Karwa
234 ALFPK4226Q Sulochana R Karwa The entity received 5000 shares from Mukesh N Desai (HUF) on
235 AABHV8959A Venu Gopal Karwa
Huf
Page 49 of 55

236 AGFPK2158L Ramanarayan H
Karawa
237 AUFPK2191R Archana G Karwa The entity received 5000 shares from Mukesh N Desai (HUF) on
238 AGCPK5348P Neelu Manoj
Khivsara
239 AACHS8497K Suresh
Rameshwarlal
Kothari Huf
240 AFHPV9545F Vishal Jain The entity received 2500 shares from Suryamangal Media &
241 AAQPB9783P Zumberlal H
Bhandari
242 AAFHB8657P Bhavin Chandulal
Shah Huf
243 AMGPB6442B Anil Hiralal
Bhandari
244 AAVPA0108L Rameshwarlal G
Kothari
245 ACXPM5129P Meera Sheetal
Mehta
246 DFHPS4978L Divyang Ramesh
Sadhwani
247 AAMHR5898D Ramesh
Morandmal
Sadhwani (HUF)
248 AADPA6233E Sunita Rakesh
Agarwal
249 AALHR9586F Rakesh R Agarwal
Huf
250 AAPPB2953C Nilesh Vijay
Bhatevara
251 ACVPA5077A Rakesh Agarwal The entity received 2000 shares from Suryamangal Media &
252 ATIPP5949C Saurabh N Patel The entity received 5000 shares from GFL Financial India Ltd on
253 BMDPP9341R Mittal P Patel The entity received 5000 shares from GFL Financial India Ltd on
254 AASPV1975F Ravi Vajawat The entity received 3000 shares from Suryamangal Media &
255 AABPS7373R Amita Parag Shah The entity received 15100 shares from Cromakem Limited and
1100 shares from Millennium Cybertech Limited on 14/7/2012 in
physical form
256 AIGPP8081J Neha D Patel The entity received 5000 shares from GFL Financial India Ltd on
257 ADPPK8753Q Suresh
Rameshwarlal
Kothari
Page 50 of 55

258 BBZPB0749L Archana Rohit
Bhandari
259 AADHR6147N Rameshwarlal
Gulabchand Huf
260 AIGPP8011N Dinesh M Patel The entity received 5000 shares from GFL Financial India Ltd on
261 AVJPS3232Q Pallavi M Shirude The entity received 4000 shares from Poonam Premsagar Pasricha
262 AAQHS5761J Shirude Milind R
Huf
263 AGFPK2157F Ghanshyamdas
Karwa
264 EFMPS7289C Yash Parag Shah The entity received 2000 shares from Millennium Cybertech Ltd
and 8000 shares from Cromakem Limited on 31/7/2012 in
physical form
265 AGLPK7190G Surinder
Charansingh Kaur
266 ABMPK0516A Deepak
Rameshwarlal
Kothari
267 ACNPS1799P Milind R Shirude The entity received 3500 shares from GFL Financial India Ltd on
268 AEJPB4820Q Vandana Anil
Bhandari
269 AAAPJ7220P Jayanthi Kumari The entity received 2500 shares from Mukesh N Desai (HUF) on
270 ABWPM8495Q Mangi Devi The entity received 2500 shares from Mukesh N Desai (HUF) on
271 AAIHM3818E Mahaveerkumar
Praveenchand
(HUF)
272 AAEHV8290D Vimalkumar
Praveenchand
(HUF)
273 AAFHV9245P Vikramkumar
Praveenchand
(HUF)
274 AABPS7371P Parag Anandlal
Shah
The entity received 18400 shares from Millennum Cybertech Ltd
275 AFAPD5513L Dinesh Kumar Jain The entity received 5000 shares from Mukesh N Desai (HUF) on
276 ABAPJ3319G Prakash Kumar Jain The entity received 2500 shares from Suryamangal Media &
277 AIMPB3417A Rohitkumar S
Bhandari
Page 51 of 55

278 AJXPB9684M Rakesh S Bhandari The entity received 4000 shares from Poonam Premsagar Pasricha
279 AIDPD8304R Pritesh G Deo The entity received 2000 shares from GFL Financial India Ltd on
280 AARPV3324P P Vimal Kumar The entity received 2500 shares from Mukesh N Desai (HUF) on
281 AONPB7989N Bhandari Kanchan
Sumtilal
282 AAQPD5950Q Govind D Deo The entity received 2000 shares from GFL Financial India Ltd on
283 AACHV0256P Vijay F Sabadra
Huf
The entity received 2000 shares from GFL Financial India LTD
284 ANMPS8650B Vijay F Sabadra The entity received 2000 shares from GFL Financial India Ltd on
285 ACMPS2295K Sunanda Vijay
Sabadra
286 BGWPS0440K Rashmi Vijay
Sabadra
287 AACHM6406N Makwana Vijaybhai
Mohanbhai Huf
288 BHXPS4067C Shilpa Bagreecha The entity received 2500 shares from Mukesh N Desai (HUF) on
289 AJLPJ2277L Vikas Kumar Jain The entity received 2500 shares from Mukesh N Desai (HUF) on
290 ABTPB2111P Sumtilal Pannalal
Bhandari
291 ABWPM8494R P Mahaveer Kumar The entity received 2500 shares from Mukesh N Desai (HUF) on
292 AAFHN2519A Narendra M
Agrawal Huf
293 AAPPV3421M Bindu Vajawat The entity received 3000 shares from Suryamangal Media &
294 AOFPV5904B Rohin Vajawat The entity received 3000 shares from Suryamangal Media &
295 AAQPD5949R Usha G Deo The entity received 2000 shares from GFL Financial India Ltd on
296 AABPY4151B Shashikant N Yeola The entity received 2000 shares from GFL Financial India Ltd on
297 ALJPS5991A Ramesh
Morandmal
Sadhwani
298 ANYPS3580Q Sunita
Rameshchandra
Sadhwani
299 AXDPK5755C Mohit Rajkumar
Kothari
Page 52 of 55

300 ABNPK6901A Durga Rajkumar
Kothari
301 AAEHR3848D Rajkumar
Rameshwarlal Huf
302 AFAPB6534M Shweta Vivek
Kothari
303 ABBPD8991K Padma Devi The entity received 2500 shares from Suryamangal Media &
304 AIDPD8303J Hitesh G Deo The entity received 2000 shares from GFL Financial India Ltd on
305 AAJHA8394Q Arvind M Agrawal
Huf
306 AAAHB8392L Abhay P Bora Huf The entity received 2000 shares from GFL Financial India Ltd on
307 AASPA8019P Kiran Dineshkumar
Agrawal
308 AARPV3323L P Vikram Kumar The entity received 2500 shares from Mukesh N Desai (HUF) on
309 AESPJ3783R Rupali Atul Jain The entity received 1500 shares from GFL Financial India Ltd on
310 AALPJ3459K Atul Satishchandra
Jain
311 AAKPT6824H Nandkishor
Kantilal Tated
312 AFSPB0852N Anita Abhay Bora The entity received 2000 shares from GFL Financial India Ltd on
313 AFRPB3527R Neena Tejpal Bora The entity received 2000 shares from GFL Financial India Ltd on
314 AABHT0453R Tejpal P Bora Huf The entity received 2000 shares from GFL Financial India Ltd on
315 ADHPB4828M Tejpal P Bora The entity received 2000 shares from GFL Financial India Ltd on
316 ADHPB4825G Abhaykumar P
Bora
317 AFRPB3530L Suganbai P Bora The entity received 2000 shares from GFL Financial India Ltd on
318 AWNPB0219R Sailee A Bora The entity received 2000 shares from GFL Financial India Ltd on
319 AFQPA2808F Alka Jain The entity received 2500 shares from Mukesh N Desai (HUF) on
320 AANPA7734J Mithailal K
Agarawal
321 AFQPA9253C Ranibai M
Agarawal
Page 53 of 55

322 ADPPA4146F Arvind Mithailal
Agrawal
323 AALHP4640Q Narayan P Panicker
Huf
324 AMLPB2241H Piyush Sunil Bafna The entity received 1200 shares from Suryamangal Media &
325 ABGPA9107R Narendra M
Agrawal
326 AFQPA9251A Swati Narendra
Agrawal
327 AHGPB6587L Leena Sunil Bafna The entity received 1000 shares from Suryamangal Media &
328 AZXPB5572E Priyanka Sunil
Bafna
329 AFQPA9252D Neelam Arvind
Agrawal
330 AYUPK7834Q Sarthak
Sureshkumar
Kothari
331 ADVPG5413H Aniruddha R
Gawade
332 AALPY6141M Vijaya Shashikant
Yeola
333 AAEPC5128R Sampatraj Chhallani The entity received 3000 shares from Suryamangal Media &
334 AADHB8997E Balkishan Innani
Huf
335 ATHPG7447B Akash A Gawade The entity received 2500 shares from GFL Financial India Ltd on
336 AAFHD8458Q Dineshkumar Jain
Huf
337 AEXPK9060M Lalita Suresh
Kothari
338 AABHG8591H Ghanshyamdas
Harikishan Karwa
Huf
The entity received 1950 shares from Ghanshyamdas Karwa on
339 AACHM6051K Mohanbhai R
Makwana Huf
340 AAQPT4000M Namdeo Kisan
Tajane
The entity received 80000 shares from Dadima Capital (P) Ltd on
341 AGSPT2723R Minal Namdeo
Tajane
Page 54 of 55

342 ADKPP2023P Bharatbhai
Zaverbhai Prajapati
The entity received 6000 shares and 4500 shares from Dadima
Capital (P) Ltd on 11/9/2013 and 9/10/2013 respectively
through off market transactions
343 ARGPA6417L Aishwarya
Abhishek Agrawal
344 BHZPA3199P Esha Ankit
Agrawal
345 AABHP8743A Gordhanbhai
Narandas Patel
346 AOMPC0772K Komilkumar
Anilbhai Chauhan
347 ACTPP7683H Dhanjibhai
Ravjibhai Dholaria
348 AAEHD9550L Dhanjibhai
Ravjibhai Dholaria
(Huf)
349 ANPPP5555K Saritaben D Patel The entity received 6000 shares from Dadima Capital (P) Ltd on
350 AACCS6506N Siddhachal
Tradelink Pvt Ltd
351 AFNPS9308B Vimlaben Kantilal
Sanghvi
352 ATRPK4534D Ramesh Krishna
Kulaye
The entity transfered a total of 32370 shares to Dadima Capital
(P) Ltd from 7/4/2014 to 7/5/2014 through off market
transactions
353 AEKPK6751Q Santosh Kumar The entity transfered 13000 shares to Dadima Capital (P) Ltd on
354 ABNPV8151B Vijay Govindarajan The entity received 5000 shares from Jaswant Kantilal Parmar on
355 ARCPP2280L Keyur Babulal Patel The entity received a total of 2100 shares from Bharatkumar
Prahladbhai Prajapati on 21/11/2013 and 27/11/2013 through
off market transactions and 5000 shares from Mukesh N Desai
HUF on 26/10/2013 in physical form.
356 ACQPP0211N Minaben Ambalal
Patel
The entity received a total of 1800 shares from Bharatkumar
off market transactions
357 APLPP4465J Sonalben
Dhirenkumar Patel
The entity received a total of 1800 shares from Bharatkumar
off market transactions
358 AACHP4026P Ambalal
Ranchhodbhai
Patel -
The entity received 1800 shares from Bharatkumar Prahladbhai
Prajapati on 11/12/2013 through off market transactions
Page 55 of 55

359 AXMPP3283D Bhavika Jaykumar
Patel
The entity received 700 shares from Bharatkumar Prahladbhai
Prajapati on 10/12/2013 through off market transactions
360 AEKPJ9968A Pawan Jain The entity received 6500 shares from Mukesh N Desai (HUF) on
361 AAHHV3712M Vikas Kumar Jain
(HUF)

DATE: AUGUST 14
th
, 2014 RAJEEV KUMAR AGARWAL
PLACE: MUMBAI WHOLE TIME MEMBER


Order in The Matter of Kelvin Fincap Limited

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WTM/RKA/ 103 /ISD/2014

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