TMI Blog2016 (3) TMI 1321X X X X Extracts X X X X X X X X Extracts X X X X ..... how each one of the connected entities at various sequences in the chain has catalysed the routing of funds and shares, in a web of make believe transfers/transactions meant to mislead and obfuscate, to the final confluence in the market amidst artificial volume and price rise entrapping the unsuspecting and gullible investors. The manipulation in the traded volume and price of the scrip by a group of connected entities as observed in this case has potential to further induce unsuspecting and gullible investors to trade in the scrip and harm them. These connected parties have grossly misused the stock exchange system to generate bogus LTCG to aid and help beneficiaries to convert their unaccounted income into accounted one with no payment of taxes as LTCG is tax exempt. SEBI strives to safeguard and protect the interests of a genuine investor in the Indian securities market. The fraudulent, manipulative and deceptive acts, device, plan and artifice employed by the connected parties acting in league in this case have wider impact on the securities market and should be dealt with sternly and post- decisional hearing will be sufficient compliance of procedure, in the facts and circ ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... iod was merely 280 shares per day with average number of trade as low as 3 per day. For the purposes of preliminary examination of facts and circumstances prevailing during these periods these periods were taken in three patches i.e., (a) January 17, 2013 to June 04, 2013 (Patch -1) , (b) July 22, 2013 to November 05, 2014 (Patch-2) and (c) November 07, 2014 to December 31, 2015 (Patch -3). The price movement vis-a-vis traded volume in the scrip during this period is illustrated below: 2. During preliminary examination several acts and omissions, in connection with dealing in shares of Kailash Auto having a bearing on the securities market, including layering of funds, circulation of funds and securities, amongst inter -connected parties for acquisition and divestment of securities of connected unlisted private companies and corporate actions including capital reduction, issuance of bonus shares, private placement and merger of such companies with Kailash Auto were also observed. These activities needed examination of several aspects of interconnected transactions amongst the large number of entities. As a part of preliminary examination, the bank statement of the conc ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Impex Ltd., the erstwhile promoter of Kailash Auto through a share purchase agreement dated May 02, 2012. Consequently, the board of directors of Kailash Auto had approved CPAL and PML as promoters of Kailash Auto. (b). On November 22, 2012, the board of directors of Kailash Auto had agreed for reduction of share capital of Kailash Auto and merger of CPAL and PML with Kailash Auto. The scheme of reduction of share capital of Kailash Auto and amalgamation of CPAL and PML with it were approved by the Hon'ble High Court of Allahabad and the Hon'ble High Court Bombay vide separate orders dated May 9, 2013 and May 10, 2013, respectively. The swap ratio for the amalgamation was approved as follows: (i) The paid up value per share of the transferee company (Kailash Auto) would be of ₹ 1/- each, fully paid up post reduction of capital. (ii) The paid up value per share in the transferor companies (CPAL and PML) would be of ₹ 1/- each, fully paid up. (iii) Accordingly, for every equity share of ₹ 1/- held by the shareholders of CPAL and PML, one equity share of ₹ 1/- of Kailash Auto (post reduction of capital) was to be allotted to them as fully p ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 4,05,000 31/03/2011 Panchshul Marketing Pvt. Ltd. 7,65,250 31/03/2011 Pushapmala Vinimay Pvt. Ltd. 3,45,000 31/03/2011 Shivratri Merchants Pvt. Ltd. 83,300 31/03/2011 Solty Dealtrade Pvt. Ltd. 1,58,300 31/03/2011 Speedwell Enclave Consultancy Pvt. Ltd. 1,73,300 31/03/2011 Timeless Suppliers Pvt. Ltd. 1,48,300 Total 33,01,550 (f). During the Financial Year 2011-12, CPAL had a paid up share capital of ₹ 285,686,800/- consisting of 285,686,800 shares of ₹ 1/- each. CPAL had increased its authorised share capital from ₹ 3,450,000/- to ₹ 290,000,000/- and then its shares were split from ₹ 10/- each to ₹ 1/- each, thereby converting 340,155 equity shares of ₹ 10/- each into 3,401,550 equity shares of ₹ 1/- each. (g). Thereafter, during t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... sting shareholders prior to bonus issue as well the private placement. The primary allottees of CPAL were the only shareholders as there was no other issuance of shares after the first private placement and before the bonus issue and second private placement. This implies that the aforesaid recipients of CPAL shares had become shareholders of CPAL on purchase of shares from the primary allottees of CPAL before the bonus issue and second private placement. (i). Similarly, PML had made private placement of 3,36,900 equity shares of face value ₹ 10/- each at a premium of ₹ 690/- each during the Financial Year 2010-11 to 15 entities (hereinafter referred to as primary allottees of PML ) and purportedly raised a share premium of ₹ 23,24,61,000/- within short time of its incorporation. The list of primary allottees of PML is mentioned in following Table: Table 3- List of primary allottees of PML Date Name of Allottees Shares Allotted (Face value- ₹ 10) 31/03/2011 Confident Vanijya Pvt. Ltd. 20,200 31/03/2011 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... f recipients of PML shares Date Name of Allottees Corporate Action Shares Allotted 15/09/2011 Binod Kumar Toshniwal Bonus Issue 3250000 15/09/2011 Hanish Toshniwal Bonus Issue 3250000 15/09/2011 Santosh Sharma Bonus Issue 3250000 15/09/2011 Anand Thakur Sagar Bonus Issue 59475000 15/09/2011 Needful Vincom Pvt. Ltd. Bonus Issue 53040000 15/09/2011 Brijdhara Merchantile Pvt. Ltd. Bonus Issue 53560000 15/09/2011 Overflow Mercandise Pvt. Ltd. Bonus Issue 49660000 16/03/2012 Sanskriti Vincom Pvt. Ltd. Private Placement 25000000 16/03/2012 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Kolkata-700006 11. Pushpdant Tradelink Pvt. Ltd. 9. Gannayak Sales Pvt. Ltd. 9/12, Lal Bazar Street, 3rd Floor, Kolkata -700001 12. Pushpdhara Dealer Pvt. Ltd. 13. Speedwell Enclave Consultancy Pvt. Ltd. 14. Timeless Suppliers Pvt. Ltd. 10. Speedwell Enclave Consultancy Pvt. Ltd. 11. Timeless Suppliers Pvt. Ltd. 26, W.C. Banerjee Street, Near Girish Park, Kolkata-700006 Table - 6 Common directors of primary allottees of CPAL and PML Common Directors primary allottees of PML primary allottees of CPAL Hanish Toshniwal Confident Vanijya Pvt. Ltd. Heaven Sales Pvt. Ltd. Mrityunjoy Sarkar Pushpdhara Dealer Pvt. Ltd. Needful Projects Advisory Pvt. Ltd. Shivratri Merchants Pvt. Ltd. Pradeep Shaw Dhandevi Merchandise Pvt. Ltd. Dhankuber Dealcomm Pvt. Ltd. Safeline Develoeprs Advisory Pvt.Ltd. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... A (q). The key financial figures of the Kailash Auto for the Financial Years 2010-11, 2011-12, 2012-13 and 2013-14 are tabulated as below: Table 8 - Key financial figures of Kailash Year FY13-14 ( Rs. in crore) FY12-13 ( Rs. in crore) FY11-12 ( Rs. in crore) FY10-11 ( Rs. in crore) Operating Income 20.41* 0.34 0.13 0.35 Operating Administration Expenses 18.88* 0.3 0.1 0.12 Employee Expense 0.05 0.02 0.05 0.1 Adjusted Net Profit 0.84 0.01 -0.21 -0.17 Price Earning (P/E) 4,065.00 0 0 0 EPS 0.01 0 -0.51 0 Price to Book Val ue ( P/BV) 41.06 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... rease in the paid up share capital of CPAL and PML. (v). As a result of the schemes of reduction in share capital of Kailash Auto and amalgamation of CPAL and PML the market capital of Kailash Auto on May 10, 2013 was ₹ 10,48,52,545/- consisting of 38,05,900 equity shares of ₹ 27.55/- each, which was increased to ₹ 21,72,12,23,071/- on July 22, 2013 consisting of 58,70,60,083 equity shares of ₹ 37/- each. Thus, the schemes of reduction of share capital and thereafter the amalgamation, the market capital of Kailash Auto had increased by 20615.97%, i.e., (approximately 206 times). BSE had permitted listing and trading in the shares of Kailash Auto that were issued as consideration in the scheme of amalgamation with effect from July 22, 2013. Just after change in the promoter group of Kailash Auto from Padma Impex Pvt. Ltd. to PML and CPAL, within a short span of time, the price of the scrip increased significantly which continued till July 22, 2013 when new category share (after amalgamation) of Kailash Auto was listed and permitted for trading on BSE. (w). The above findings indicate that CPAL and PML were incorporated with a dubious plan and premeditat ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... s and recipients of PML shares (that acted as conduit to distribute the equity shares of CPAL/PML to beneficiaries) and were also part of Kailash Auto Group I (that had acted as buyer to such beneficiaries to provide exit from market at high value). 9. During Patch-1, on January 17, 2013, the scrip opened at ₹ 11/- and closed at ₹ 36.25/- on June 04, 2013, i.e., recorded a substantial price rise of 230%. During said period, the scrip was traded only on 36 trading days with an average trading volume of 280 shares per day and an average of 3 trades per day (on 4 out of 36 trading days, extreme trading volumes were observed and same was not included as part of computing average trading volume during Patch-1). It was observed that price of the scrip was influenced by certain entities primarily through first trades during this period. It was also noticed that these entities by putting 1 or 2 trades per day with negligible/very less quantity of buy order contributed significantly to the price rise. From last traded price ( LTP ) analysis, it was observed that price of the scrip increased from ₹ 11 to ₹ 36.25 mainly through first trades on 27 instances. Out of t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ut of this 40.82 crore shares were bought by top 300 buyers/entities and the beneficiaries accounted for selling of 46.56 crore shares. It was also noticed that during Patch -2, the beneficiaries were net sellers and entities forming part of Kailash Auto Group I and Kailash Auto Group II were net buyers, a summary of which is given below:- Table 10 - Exit provided by Kailash Auto Group I and Kailash Auto Group II to beneficiaries Gross sell Gross sell as % of Market Gross Buy Gross Buy as % of Market Gross Beneficiaries 46,56,90,392 94.32 - - Kailash Auto Group - - 17,50,81,045 35.47 11. Movement of shares from CPAL and PML to Kailash Auto Group I and Kailash Auto Group II is shown in the following diagram: 12. The beneficiaries had received shares of CPAL and PML at an average price of ₹ 1/- per share. Pursuant to the scheme of amalgamation, for every one equity share held by the shareholders of ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... up II is given in the following Table: Table 12 - Fund flow from promoter/promoter related entities of Kailash Auto to top 5 entities of Kailash Auto Group I and Kailash Auto Group II 15. The above Table depicts the transfer of funds amounting to ₹ 9,58,77,000/- from some of the promoter/promoter related entities of Kailash Auto to the entities of Kailash Auto Group I and Kailash Auto Group II. Further, top entities (in terms of buy trading volume) of Kailash Auto Group I and Kailash Auto Group II were majorly funded by Sri Karani Exports Pvt. Ltd., Stepan Commotrade Pvt. Ltd., Build Con Finance Limited and Nirdesh Trading Pvt. Ltd. It was noted that Sri Karani Exports Pvt. Ltd. and Radhashyam Dealtrade Private Limited are the only promoters of Kailash Auto. Sri Karani Exports Pvt. Ltd. is a closely held private limited company wherein Stepan Commotrade Pvt. Ltd. and Nirdesh Trading Pvt. Ltd. were two of its very few shareholders. Similarly, Radhashyam Dealtrade Private Limited is a closely held private limited company wherein Buildcon Finance Ltd. was one of its few shareholders. Thus, Sri Karani Exports Pvt. Ltd., Radhashyam Dealtrade Pvt. Ltd., Stepan Commot ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ayering; fund was finally transferred to the entities belonging to Kailash Auto Group I and II. A typical flow chart of movement of funds for one of the top beneficiaries is given below: 18. In the above example, it can be seen that funds have been transferred by Mr. Om Prakash Agarwal and Om Prakash Agarwal HUF (a beneficiary) to Shivling Mercantile Pvt. Ltd. (recipients of PML shares) as a consideration for the purchase of equity shares of PML. After receiving funds from Mr. Om Prakash Agarwal and Om Prakash Agarwal HUF, Shivling Mercantile Pvt. Ltd. transferred funds on the same day fund to CPAL, Kakrania Trading Pvt. Ltd. and some other entities. Kakrania Trading Pvt. Ltd. transferred the amount that it received from Shivling Mercantile Pvt. Ltd. to Management Consultancy Pvt. Ltd. and Eversafe Promoters on the same day. Eversafe Promoters transferred fund to one Mr. S. K. Khemka on the same day. Mr. S. K. Khemka is part of Kailash Auto Group II, who are facilitating exit to the beneficiary in the market at high price. From the above flow of fund it is observed that the purported consideration paid by a beneficiary is transferred to the entities of Kailash Auto Group II ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Auto. 20. From the preliminary examination it is observed that the scheme of reduction of share capital and amalgamation were the mechanism adopted by the Kailash Auto to dubiously increase its value of market capital significantly. From the prima facie findings of preliminary examination it is inter alia noted that:- (a). During the financial year 2010-11, CPAL and PML were incorporated with a dubious plan and premeditated arrangement and artifice to increase number of equity shares therein through sham and non-genuine transactions with regard to issuance of their shares which resulted in fetching exorbitant and unrealistic consideration in the scheme of amalgamation. Pursuant to amalgamation 2058 shareholders of PML and 1,972 shareholders of CPAL (beneficiaries) received 58,59,10,800 shares of Kailash Auto in the form of consideration. (b). Subsequent to acquisition of management and control of Kailash Auto by CPAL and PML the price of the Kailah Auto was rigged by 230% from Jan 2013 to June 04, 2013 (Patch- 1). During Patch- 1, the scrip was an illiquid one and there was negligible trading therein at that time. During this period the price was manipulated by the connect ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... uring relevant periods are found to be inflated and unrealistic. 21. From the above facts and circumstances it is noted that shortly after their incorporation CPAL and PML made private placement to the primary allottees. In their private placements CPAL and PML issued equity shares for value of ₹ 19.80 crores and ₹ 23.58 crores, respectively by circulating back and forth smaller amounts of funds amongst the primary alllottees and themselves. Thus, on account of the repeated circulation of funds between different primary allottees and the companies, the receipt of allotment money for total equity shares issued in the private placement had been merely as book entry. I, therefore, prima facie find that these companies and their primary allottees engineered a web of transfers and retransfers of funds and shares amongst themselves in a bid to create a facade of infusion of funds by way of private placement of shares when actually there was actually no infusion of funds for the large part of the private placement. In the private placement by CPAL and PML, the purported share premium amount of ₹ 19,47,91,450/-and ₹ 23,24,61,000/-, respectively were also through ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... bitant and unrealistic consideration for their shares in the scheme of amalgamation. 23. From the observations of preliminary inquiry it is noted that Kailash Auto did not have any business operations during the relevant period. It had very poor fundamentals during the relevant period i.e., the financial years 2010-11, 2011-12, 2012-13 and 2013-14. The adjusted net profits and earnings per share (EPS) of Kailash Auto for these periods were always nil or negligible as reported by it. Prior to Patch -1, there was no trading at all in the scrip of Kailash Auto and there was no market discovered price for the scrip during this period. Thus, the astronomical increase in the price of the scrip during Patch -1 and continuance of the increased price throughout till Patch-2 was not supported by any genuine factor such as fundamentals/operating results of the company and market forces of supply and demand in its shares. Such price rise and maintenance thereof during the relevant period were predominantly on account of transactions amongst the connected/related entities during these periods as found during preliminary inquiry. 24. In this regard, it is noted that during Patch-1, price o ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... a share or shares in an Indian company, which becomes the property of the assessee in consideration of a transfer, there shall be included the period for which the share or shares in the amalgamating company were held by the assessee . Thus, though the beneficiaries had received the shares of Kailash Auto on June 08, 2013, the holding period of 12 months for the purpose of exemption from tax on LTCG, the gains made by beneficiaries on account of sale of shares of Kailash Auto would be eligible for LTCG exemption under Income Tax Act, 1961 since they were holding shares of CPAL and PML prior to swap under the scheme of amalgamation. In the entire process, the beneficiaries made huge profit of approximately 3400% on their investment and claimed exemption of long term capital gains (LTCG) on such profit. I, prima facie, find that such profit was generated on account of rigged price of the scrip and creation of artificially inflated volumes. Thus, the details of transactions put through in such a ruse contain tell-tale story of how the entire process of private placement, fabrication of share premium, issuance of bonus shares, subsequent transfer of shares and funds to connected/relate ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... alings in securities No person shall directly or indirectly- (a) buy, sell or otherwise deal in securities in a fraudulent manner; (b) use or employ, in connection with issue, purchase or sale of any security listed or proposed to be listed in a recognized stock exchange, any manipulative or deceptive device or contrivance in contravention of the provisions of the Act or the rules or the regulations made there under; (c) employ any device, scheme or artifice to defraud in connection with dealing in or issue of securities which are listed or proposed to be listed on a recognized stock exchange; (d) engage in any act, practice, course of business which operates or would operate as fraud or deceit upon any person in connection with any dealing in or issue of securities which are listed or proposed to be listed on a recognized stock exchange in contravention of the provisions of the Act or the rules and the regulations made there 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 securit ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... allotment of shares by CPAL and PML to a select coterie, running through the maze of funds/shares transfers and retransfers amongst chosen interconnected parties, unrealistic increase of liquidity in shares of Kailsah Auto held by shareholders of CPAL and PML pursuant to scheme of amalgamation is a classic example of touch-me-not distancing through intermediations and culminating in the final denouement wherein connected parties with all their manipulative assemblage came to the fore setting a seal on their machinations of fraudulent, manipulative and deceptive dealings to the detriment of unsuspecting investors. 29. The whole picture on the canvass suggests tell- tale strands of how each one of the connected entities at various sequences in the chain has catalysed the routing of funds and shares, in a web of make believe transfers/transactions meant to mislead and obfuscate, to the final confluence in the market amidst artificial volume and price rise entrapping the unsuspecting and gullible investors. The connected entities, acting in concert under a premeditated plan, had acquired dominant market power for the shares of Kailash Auto. Their acts, conduct, behaviour and dealin ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ubstance, it will give wrong signals in the system. I am of also of the view, the fraudulent, manipulative and deceptive acts, device, plan and artifice employed by the connected parties acting in league in this case have wider impact on the securities market and should be dealt with sternly and post- decisional hearing will be sufficient compliance of procedure, in the facts and circumstances of this case. Considering the facts and circumstances of this case and the indulgence of a listed company in such fraudulent, manipulative and deceptive plan, device and artifice as prima facie found in this case, I am convinced that this is a fit case where, pending investigation, effective preventive and remedial action is required to be taken by way of ad interim ex -parte order to protect the interests of investors and preserve the safety and integrity of the securities market. 31. In view of the foregoing, in order to protect the interest of the investors and safeguard the integrity of the securities market, I, in exercise of the powers conferred upon me in terms of section 19 read with section 11(1), section 11 (4) and section 11B of the SEBI Act, 1992, pending investigation in the m ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 19 Veena Rajesh Sarda AHAPS4880R 20 Ramasamy Santhamani ALJPS3141G 21 Satish Jain AAFPJ6142B 22 Dhirajkumar Khetan AAWPK2634C 23 Vikrant Kumar Khetan AAWPK2621F 24 GauravBhalotia ADAPB9680Q 25 Bhagwati Devi Patwari AEYPP3706L 26 N.Kanniah AAHPK8800D 27 Nikita Agarwal AOTPA7379H 28 Sanjib Kumar Patwari HUF AAPHS3236R 29 Priyanka Patwari ALSPK8179K 30 Sarika Patwari ABAPL2442E ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Kumar Kejriwal ADHPK4175C 55 Sweety Manglani AGAPM6677R 56 Praveen Goud Adhikam ACOPA7454Q 57 Sapna Goud Adhikam ADAPA1398J 58 Ashish Singhania BFWPS0721Q 59 Poonam Makin AEVPM9256K 60 Ramesh Kumar Kedia HUF AAEHR9181H 61 Saurabh Mittal ADDPM5232A 62 Kapil Mittal ADDPM5233B 63 Rekha Ajaykumar Agrawal AASPA2993A 64 Jyoti Vardhan Sonthalia AADHJ8034N 65 Sandhya Jain AAGPJ0189B ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 3C 90 Sher Singh Agarwal AAAHS9623K 91 Dinesh Shersingh Agarwal AAAPA5629D 92 Shiv Kumar HUF AABHS3053G 93 Pushpa Rani Nagpal AABPN0865H 94 Rajendra Neminath Shete AACHR9687J 95 Sitaram Ashok Kumar HUF AACHS4243P 96 Ramachandran Ananthan Pothi AACPP8620K 97 ShersinghAgarwal AADPA3198C 98 Sarda AAEHS0587A 99 Sanjay Kumar Agarwal AAOPA1798H 100 Anand Swaroop Rathi ABLPR8103M 101 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 124 Keshavah Dealtrade Pvt. Ltd. AAECK7236R 125 Keshavah Mercantile Pvt. Ltd. AAECK7235N 126 Realstep Tradecom Pvt. Ltd. AAGCR4447R 127 Jai Dada Steel Pvt. Ltd. AACCJ3125C 128 Depandable Consultancy Business Kanti Ltd. AADCD1443J 129 Fortright Consultants Pvt. Ltd. AACCF2203K 130 Deekay Engineers Dealers Ltd. AAACD8823B 131 Pragyan Realty Pvt. Ltd. AAHCP1157B 132 Huk Wealth Consultants Pvt. Ltd. AADCH1933R 133 Panchmadhu Projects Pvt. Ltd. AAHCP0443J 134 Mdbp Market ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 155 Saktimata Marketing Pvt. Ltd. AARCS1549Q 156 Gainsay Property Pvt. Ltd. AAFCG2185A 157 Shivsathi Mercantile Pvt. Ltd. AASCS6284R 158 Sanmati Goods Pvt. Ltd. AAICS9154Q 159 Albino Overseas Pvt. Ltd. AAHCA6112B 160 Levia Trading Pvt. Ltd. AACCL5027D 161 Camellia Vinimay Pvt. Ltd. AADCC5732H 162 Reachsmart Construction Pvt. Ltd. AAGCR4662J 163 Swarnprakash Traders Pvt. Ltd. AATCS6718D 164 Shallot Vincom Pvt. Ltd. AARCS5124P 165 Reachsmart Dealtrade Pvt. Ltd. AAFCR9881C 166 Expression Dealers Pvt. Ltd. AACCE5935D 167 Signature Dealtr ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Ltd. AARCS5133J 193 Rajgharana Agencies Pvt. Ltd. AAFCR2462P 194 Mobixa Distributors Pvt. Ltd. AAICM4750C 195 AriseDealcom Pvt. Ltd. AAJCA5108R 196 Rangan Vincom Pvt. Ltd. AAGCR1715E 197 Signet Vinimay Pvt. Ltd. AAMCS1712Q 198 Kapeeshwar Vintrade Pvt. Ltd. AAECK7329P 199 Touchwin Commercial Pvt. Ltd. AAECT1846Q 200 Ladios Trading Pvt. Ltd. AACCL3868N 201 Katyani Commodities Pvt. Ltd. AAECK6244R 202 Runicha Merchants Pvt. Ltd. AAECR0580M 203 Spice Merchants Pvt. Ltd. AAPCS7492G 204 Core Commodities Pvt. Ltd. AAECC2931M P ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 228 Sudhir Jain ALKPJ3343G 229 Rohit Agarwal AONPA7646B 230 Anand Sagar Thakur AEYPT0142A 231 Rudra Prasad Banerjee AVTPB4409J 232 Stepan Commotrade Pvt. Ltd. AADCS9460Q 233 Binod Kumar Toshniwal AFDPT0326E 234 Hanish Toshniwal AHJPT9222F 235 Santosh Sharma BFAPS7597Q 236 Needful Vincom Pvt. Ltd. AADCN3984C 237 Brijdhara Merchantile Pvt. Ltd. AAECB2629R 238 Overall Vincom Pvt. Ltd. AABCO1200E RECIPIENTS OF CP ..... X X X X Extracts X X X X X X X X Extracts X X X X
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