w w w . L a w y e r S e r v i c e s . i n



M/s. Triveni Management Consultancy Services Ltd. Bandra Liberty Co-op. Society Ltd. v/s Securities and Exchange Board of India SEBI Bhavan


Company & Directors' Information:- R G K B SECURITIES SERVICES PRIVATE LIMITED [Active] CIN = U74999DL2004PTC130914

Company & Directors' Information:- J K CONSULTANCY AND SERVICES PRIVATE LIMITED [Active] CIN = U74899DL1995PTC066762

Company & Directors' Information:- TRIVENI MANAGEMENT CONSULTANCY SERVICES LIMITED [Active] CIN = U67120MH1995PLC085717

Company & Directors' Information:- G M MANAGEMENT CONSULTANCY P LTD [Strike Off] CIN = U74140MH1994PTC076181

Company & Directors' Information:- H S CONSULTANCY PVT LTD [Active] CIN = U74140WB1988PTC044368

Company & Directors' Information:- G K MANAGEMENT SERVICES (INDIA) LIMITED [Active] CIN = U74140TZ1999PLC009001

Company & Directors' Information:- S M CONSULTANCY PVT LTD [Active] CIN = U74140WB1992PTC057293

Company & Directors' Information:- INDIA MANAGEMENT CONSULTANCY SERVICES PRIVATE LIMITED [Strike Off] CIN = U74120DL2000PTC225726

Company & Directors' Information:- K S CONSULTANCY SERVICES PVT LTD [Active] CIN = U74140WB1988PTC045137

Company & Directors' Information:- A G S MANAGEMENT SERVICES PRIVATE LIMITED [Active] CIN = U45208TG2011PTC077420

Company & Directors' Information:- A. K. MANAGEMENT CONSULTANCY PRIVATE LIMITED [Active] CIN = U80300MH1999PTC120053

Company & Directors' Information:- A H MANAGEMENT SERVICES PRIVATE LIMITED [Active] CIN = U74140DL2010PTC206683

Company & Directors' Information:- E TO E CONSULTANCY PRIVATE LIMITED [Active] CIN = U63030KA2008PTC048557

Company & Directors' Information:- B J MANAGEMENT SERVICES LIMITED [Amalgamated] CIN = U74140WB2004PLC100864

Company & Directors' Information:- Y A CONSULTANCY SERVICES PVT LTD [Active] CIN = U74140WB1987PTC043225

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Company & Directors' Information:- R. A. CONSULTANCY PVT. LTD. [Under Process of Striking Off] CIN = U67120WB1994PTC066521

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Company & Directors' Information:- K .P. A. CONSULTANCY PRIVATE LIMITED [Active] CIN = U74140WB2010PTC142889

Company & Directors' Information:- TRIVENI SERVICES LIMITED [Strike Off] CIN = U74999DL1983PLC016303

Company & Directors' Information:- M K MANAGEMENT SERVICES PRIVATE LTD [Converted to LLP] CIN = U74899DL1987PTC029774

Company & Directors' Information:- P O CONSULTANCY SERVICES PRIVATE LIMITED [Active] CIN = U93000WB2009PTC134219

Company & Directors' Information:- L R P SECURITIES SERVICES PRIVATE LIMITED [Active] CIN = U67120MH2003PTC141738

Company & Directors' Information:- P. C. I. MANAGEMENT SERVICES LIMITED [Active] CIN = U67100MH2002PLC137588

Company & Directors' Information:- T K M CONSULTANCY INDIA PRIVATE LIMITED [Strike Off] CIN = U74140KL1998PTC012694

Company & Directors' Information:- A & A CONSULTANCY PVT. LTD. [Active] CIN = U74140WB1986PTC040777

Company & Directors' Information:- A C SECURITIES AND SERVICES PRIVATE LIMITED [Active] CIN = U67120TZ1995PTC005962

Company & Directors' Information:- Y K CONSULTANCY (INDIA) PRIVATE LIMITED [Active] CIN = U74140DL2003PTC121113

Company & Directors' Information:- C S MANAGEMENT SERVICES PRIVATE LIMITED [Active] CIN = U74140KA2004PTC035231

Company & Directors' Information:- TRIVENI CONSULTANCY PVT LTD [Active] CIN = U74140GJ1983PTC006176

Company & Directors' Information:- E C H C MANAGEMENT SERVICES PRIVATE LIMITED [Strike Off] CIN = U74910TN2005PTC056137

Company & Directors' Information:- V D S MANAGEMENT SERVICES PRIVATE LIMITED [Strike Off] CIN = U74140DL2008PTC174841

Company & Directors' Information:- M S P R MANAGEMENT SERVICES PRIVATE LIMITED [Active] CIN = U74140TG2005PTC047415

Company & Directors' Information:- L M J CONSULTANCY PRIVATE LIMITED [Active] CIN = U74140DL2010PTC208950

Company & Directors' Information:- R. K . CONSULTANCY SERVICES PRIVATE LIMITED [Active] CIN = U74140AS2006PTC008131

Company & Directors' Information:- K AND P MANAGEMENT SERVICES PRIVATE LIMITED [Active] CIN = U74120MH1988PTC099793

Company & Directors' Information:- H S D MANAGEMENT SERVICES PRIVATE LIMITED [Strike Off] CIN = U65921PB1997PTC015193

Company & Directors' Information:- N P MANAGEMENT SERVICES PRIVATE LIMITED [Strike Off] CIN = U70100MH2003PTC143620

Company & Directors' Information:- INDIA CORPORATION PRIVATE LIMITED [Active] CIN = U65990MH1941PTC003461

Company & Directors' Information:- M U S INDIA CONSULTANCY LIMITED [Strike Off] CIN = U74900WB2013PLC191253

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Company & Directors' Information:- J R CONSULTANCY SERVICES PRIVATE LIMITED [Active] CIN = U74900TN2015PTC102294

Company & Directors' Information:- I 2 I MANAGEMENT CONSULTANCY SERVICES PRIVATE LIMITED [Active] CIN = U72400TG2011PTC074119

Company & Directors' Information:- U S MANAGEMENT SERVICES PRIVATE LIMITED [Active] CIN = U74999WB2011PTC170355

Company & Directors' Information:- R A D CONSULTANCY PRIVATE LIMITED [Active] CIN = U74140DL2011PTC224038

Company & Directors' Information:- S I M CONSULTANCY SERVICES PRIVATE LIMITED [Active] CIN = U74999DL2007PTC162468

Company & Directors' Information:- Y. K. M. CONSULTANCY PRIVATE LIMITED [Active] CIN = U74900DL2013PTC254940

Company & Directors' Information:- G. D. M MANAGEMENT SERVICES PRIVATE LIMITED [Active] CIN = U74999HR2019PTC078073

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Company & Directors' Information:- J. P. CONSULTANCY PRIVATE LIMITED [Active] CIN = U51909GJ2002PTC040433

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Company & Directors' Information:- LIBERTY MANAGEMENT PRIVATE LIMITED [Strike Off] CIN = U74140MP1981PTC001871

Company & Directors' Information:- E E S MANAGEMENT SERVICES PVT LTD [Active] CIN = U74140TG1984PTC005010

Company & Directors' Information:- P C CONSULTANCY PVT LTD [Active] CIN = U74210WB1991PTC053835

Company & Directors' Information:- J A CONSULTANCY PRIVATE LIMITED [Under Process of Striking Off] CIN = U93090MH2008PTC188284

Company & Directors' Information:- I C G MANAGEMENT SERVICES PRIVATE LIMITED [Strike Off] CIN = U74140TN2010PTC075877

Company & Directors' Information:- M M MANAGEMENT SERVICES PRIVATE LIMITED [Strike Off] CIN = U74900DL2009PTC195088

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Company & Directors' Information:- N & M MANAGEMENT & CONSULTANCY SERVICES PRIVATE LIMITED [Active] CIN = U80211WB2010PTC142857

Company & Directors' Information:- S K A MANAGEMENT SERVICES PRIVATE LIMITED [Active] CIN = U74899DL1985PTC021722

Company & Directors' Information:- M Y M CONSULTANCY SERVICES INDIA PRIVATE LIMITED [Strike Off] CIN = U74900KA2011PTC058364

Company & Directors' Information:- S K A CONSULTANCY PRIVATE LIMITED [Active] CIN = U74999UP2020PTC136502

Company & Directors' Information:- T C S CONSULTANCY SERVICES PRIVATE LIMITED [Strike Off] CIN = U74140RJ1995PTC011052

Company & Directors' Information:- K B M CONSULTANCY SERVICES PRIVATE LIMITED [Strike Off] CIN = U72900TG2002PTC038403

Company & Directors' Information:- D M M CONSULTANCY PRIVATE LIMITED [Active] CIN = U74140WB2010PTC151887

Company & Directors' Information:- C I S (INDIA) CONSULTANCY PRIVATE LIMITED [Strike Off] CIN = U74120BR2013PTC021019

Company & Directors' Information:- R I W CONSULTANCY SERVICES PRIVATE LIMITED [Strike Off] CIN = U72200KL2013PTC034174

Company & Directors' Information:- D C MANAGEMENT SERVICES PRIVATE LIMITED [Active] CIN = U70101DL1998PTC094035

Company & Directors' Information:- I. Q. MANAGEMENT SERVICES PRIVATE LIMITED [Active] CIN = U74120WB2007PTC116624

Company & Directors' Information:- R P MANAGEMENT SERVICES PRIVATE LIMITED [Strike Off] CIN = U74999WB2008PTC122192

Company & Directors' Information:- A S G SECURITIES SERVICES PRIVATE LIMITED [Active] CIN = U74899DL1993PTC055394

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Company & Directors' Information:- N. K. CONSULTANCY PRIVATE LIMITED [Active] CIN = U74140HR2006PTC036471

Company & Directors' Information:- L Y D MANAGEMENT SERVICES PRIVATE LIMITED [Strike Off] CIN = U74900HR2012PTC045158

Company & Directors' Information:- K AND P MANAGEMENT SERVICES PRIVATE LIMITED [Not available for efiling] CIN = U00893KA1988PTC009632

Company & Directors' Information:- M E CONSULTANCY PRIVATE LIMITED [Strike Off] CIN = U74140KL2012PTC031172

Company & Directors' Information:- M & M CONSULTANCY SERVICES PVT. LTD. [Strike Off] CIN = U74140WB1992PTC056149

Company & Directors' Information:- V S B D CONSULTANCY SERVICES PRIVATE LIMITED [Strike Off] CIN = U74140TN2000PTC045338

Company & Directors' Information:- Z K CONSULTANCY SERVICES PRIVATE LIMITED [Strike Off] CIN = U74210DL1993PTC052338

Company & Directors' Information:- K AND P MANAGEMENT SERVICES PRIVATE LIMITED [Not available for efiling] CIN = U99999MH1996PTC099793

Company & Directors' Information:- B AND D CONSULTANCY SERVICES PVT LTD [Strike Off] CIN = U74210MH1982PTC027430

Company & Directors' Information:- D. G. CONSULTANCY SERVICES PRIVATE LIMITED [Strike Off] CIN = U74140WB2008PTC129948

Company & Directors' Information:- S. U. MANAGEMENT SERVICES PRIVATE LIMITED [Strike Off] CIN = U74140RJ2012PTC041109

Company & Directors' Information:- V F C CONSULTANCY PRIVATE LIMITED [Active] CIN = U74140RJ2015PTC048025

Company & Directors' Information:- E & C CONSULTANCY PRIVATE LIMITED [Strike Off] CIN = U74140TN2007PTC062260

Company & Directors' Information:- L & R CONSULTANCY PRIVATE LIMITED [Active] CIN = U74140TN2009PTC072839

Company & Directors' Information:- P P CONSULTANCY SERVICES PRIVATE LIMITED [Strike Off] CIN = U74210TN1982PTC009556

Company & Directors' Information:- N R 'S CONSULTANCY SERVICES PRIVATE LIMITED [Strike Off] CIN = U74210TN1986PTC013630

Company & Directors' Information:- R D MANAGEMENT CONSULTANCY SERVICES PRIVATE LIMITED [Strike Off] CIN = U74140MH2007PTC168446

Company & Directors' Information:- M F S CONSULTANCY PRIVATE LIMITED [Active] CIN = U74140MH2008PTC177948

Company & Directors' Information:- D P CONSULTANCY SERVICES PRIVATE LIMITED [Active] CIN = U74140PN2008PTC132654

Company & Directors' Information:- D C SECURITIES SERVICES PRIVATE LIMITED [Strike Off] CIN = U67200MH2004PTC146328

Company & Directors' Information:- E-EXCHANGE SERVICES PRIVATE LIMITED [Active] CIN = U70100MH2012PTC226074

Company & Directors' Information:- P K MANAGEMENT CONSULTANCY SERVICES PRIVATE LIMITED [Active] CIN = U51102MH2007PTC168738

Company & Directors' Information:- D P M C K MANAGEMENT SERVICES PRIVATE LIMITED [Active] CIN = U74999MH2002PTC135462

Company & Directors' Information:- C AND H CONSULTANCY SERVICES PRIVATE LIMITED [Strike Off] CIN = U74100MH2004PTC148618

Company & Directors' Information:- R V K CONSULTANCY SERVICES PRIVATE LIMITED [Active] CIN = U74120MH2011PTC221273

Company & Directors' Information:- H A S D CONSULTANCY SERVICES PRIVATE LIMITED [Strike Off] CIN = U74120MH2011PTC222997

Company & Directors' Information:- T & T MANAGEMENT SERVICES PRIVATE LIMITED [Active] CIN = U74120MH2013PTC244507

Company & Directors' Information:- H H S CONSULTANCY PRIVATE LIMITED [Active] CIN = U74120MH2013PTC250345

Company & Directors' Information:- A F MANAGEMENT SERVICES PRIVATE LIMITED [Strike Off] CIN = U74120MH2014PTC256072

Company & Directors' Information:- M & W CONSULTANCY PRIVATE LIMITED [Strike Off] CIN = U74910TN2004PTC053384

Company & Directors' Information:- J K M CONSULTANCY SERVICES PRIVATE LIMITED [Strike Off] CIN = U74120UP2010PTC042726

Company & Directors' Information:- D. N. P. SECURITIES SERVICES PRIVATE LIMITED [Strike Off] CIN = U74120UP2011PTC047237

Company & Directors' Information:- G & R MANAGEMENT CONSULTANCY PRIVATE LIMITED [Active] CIN = U74120UP2013PTC055438

Company & Directors' Information:- U R MANAGEMENT CONSULTANCY PRIVATE LIMITED [Active] CIN = U65900TN2011PTC081602

Company & Directors' Information:- V & U MANAGEMENT SERVICES PRIVATE LIMITED [Active] CIN = U74140TG2011PTC074925

Company & Directors' Information:- Y & D MANAGEMENT SERVICES PRIVATE LIMITED [Strike Off] CIN = U74140TG2014PTC094741

Company & Directors' Information:- Y V R CONSULTANCY SERVICES PRIVATE LIMITED [Active] CIN = U74900TG2015PTC098309

Company & Directors' Information:- J L I CONSULTANCY SERVICES PRIVATE LIMITED [Strike Off] CIN = U72300UP2012PTC052649

Company & Directors' Information:- C. D. MANAGEMENT CONSULTANCY PRIVATE LIMITED [Strike Off] CIN = U74900WB2012PTC189226

Company & Directors' Information:- D R M B CONSULTANCY SERVICES PRIVATE LIMITED [Active] CIN = U74900WB2014PTC201139

Company & Directors' Information:- M P CONSULTANCY PVT LTD [Strike Off] CIN = U74120WB1996PTC081085

Company & Directors' Information:- J. L. CONSULTANCY PVT LTD [Active] CIN = U74140WB1985PTC039818

Company & Directors' Information:- S E S CONSULTANCY PRIVATE LIMITED [Strike Off] CIN = U74999WB2011PTC170939

Company & Directors' Information:- G P R CONSULTANCY SERVICES PRIVATE LIMITED [Strike Off] CIN = U74140CH2012PTC033622

Company & Directors' Information:- S K CONSULTANCY SERVICES PRIVATE LIMITED [Strike Off] CIN = U93000JH2012PTC000348

Company & Directors' Information:- R & A CONSULTANCY SERVICES PRIVATE LIMITED [Strike Off] CIN = U67100DL2011PTC215340

Company & Directors' Information:- M J M CONSULTANCY PRIVATE LIMITED [Strike Off] CIN = U74140DL2005PTC133200

Company & Directors' Information:- A C G CONSULTANCY PRIVATE LIMITED [Strike Off] CIN = U74140DL2005PTC140720

Company & Directors' Information:- C & A MANAGEMENT SERVICES PRIVATE LIMITED [Strike Off] CIN = U74140DL2007PTC159565

Company & Directors' Information:- A & Y MANAGEMENT SERVICES PRIVATE LIMITED [Converted to LLP] CIN = U74140DL2007PTC171421

Company & Directors' Information:- H M S CONSULTANCY PRIVATE LIMITED [Active] CIN = U74140DL2010PTC201488

Company & Directors' Information:- K R A MANAGEMENT SERVICES PRIVATE LIMITED [Active] CIN = U74140DL2012PTC233124

Company & Directors' Information:- B G MANAGEMENT SERVICES PRIVATE LIMITED [Active] CIN = U74140DL2013PTC247942

Company & Directors' Information:- R S V MANAGEMENT & SERVICES PRIVATE LIMITED [Active] CIN = U72200DL2010PTC203427

Company & Directors' Information:- D & G CONSULTANCY PRIVATE LIMITED [Strike Off] CIN = U65990DL2011PTC214142

Company & Directors' Information:- L & K MANAGEMENT SERVICES PRIVATE LIMITED [Strike Off] CIN = U93000DL2010PTC205793

Company & Directors' Information:- M A MANAGEMENT SERVICES PRIVATE LIMITED [Strike Off] CIN = U74899DL2005PTC138121

Company & Directors' Information:- Z. S. MANAGEMENT SERVICES PRIVATE LIMITED [Active] CIN = U74910DL2016PTC290957

Company & Directors' Information:- R H H H CONSULTANCY PRIVATE LIMITED [Strike Off] CIN = U74900AP2014PTC095348

Company & Directors' Information:- E S D MANAGEMENT AND CONSULTANCY PRIVATE LIMITED [Active] CIN = U74140KA2005PTC037926

Company & Directors' Information:- A & C CONSULTANCY PRIVATE LIMITED [Active] CIN = U74140KA2008PTC046754

Company & Directors' Information:- J S M CONSULTANCY SERVICES PRIVATE LIMITED [Active] CIN = U93000HR2011PTC043455

Company & Directors' Information:- V MANAGEMENT SERVICES PRIVATE LIMITED [Strike Off] CIN = U82320KA2004PTC035168

Company & Directors' Information:- A P R CONSULTANCY PRIVATE LIMITED [Strike Off] CIN = U93000KA2014PTC073639

Company & Directors' Information:- D P B MANAGEMENT SERVICES PRIVATE LIMITED [Active] CIN = U74140GJ2009PTC057658

Company & Directors' Information:- V D G MANAGEMENT SERVICES PRIVATE LIMITED [Strike Off] CIN = U74140GJ2013PTC077221

Company & Directors' Information:- L AND L CONSULTANCY SERVICES PRIVATE LIMITED [Active] CIN = U74140KL1997PTC011084

Company & Directors' Information:- J AND S CONSULTANCY SERVICES PRIVATE LIMITED [Active] CIN = U74140KL2005PTC018496

Company & Directors' Information:- P E B CONSULTANCY SERVICES PRIVATE LIMITED [Active] CIN = U74140KL2011PTC027680

Company & Directors' Information:- Z & H CONSULTANCY SERVICES PRIVATE LIMITED [Active] CIN = U85190KL2008PTC023534

Company & Directors' Information:- D C D CONSULTANCY PRIVATE LIMITED [Active] CIN = U74999RJ2020PTC071399

Company & Directors' Information:- D AND N CONSULTANCY SERVICES PRIVATE LIMITED [Active] CIN = U74999PN2020PTC195417

Company & Directors' Information:- M S MANAGEMENT CONSULTANCY PRIVATE LIMITED [Active] CIN = U74140GJ2021PTC122546

Company & Directors' Information:- S S G CONSULTANCY SERVICES PRIVATE LIMITED [Strike Off] CIN = U74140TN1997PTC037763

Company & Directors' Information:- G AND G MANAGEMENT SERVICES PRIVATE LIMITED [Strike Off] CIN = U74140CH1996PTC018896

Company & Directors' Information:- S A CONSULTANCY & MANAGEMENT SERVICES PVT LTD [Strike Off] CIN = U74140WB1980PTC032840

Company & Directors' Information:- M R MANAGEMENT & CONSULTANCY PRIVATE LIMITED [Strike Off] CIN = U74140WB1997PTC084833

Company & Directors' Information:- V Z CONSULTANCY PRIVATE LIMITED [Strike Off] CIN = U74140MH2007PTC170875

Company & Directors' Information:- D AND A MANAGEMENT SERVICES PRIVATE LIMITED [Strike Off] CIN = U74110MH1995PTC090182

Company & Directors' Information:- P. A. MANAGEMENT SERVICES PRIVATE LIMITED [Strike Off] CIN = U74140CH2007PTC030834

Company & Directors' Information:- F T CONSULTANCY PRIVATE LIMITED [Strike Off] CIN = U74900CH2007PTC030854

Company & Directors' Information:- A. A. R. M. CONSULTANCY SERVICES PRIVATE LIMITED [Under Process of Striking Off] CIN = U74140DL2006PTC150076

Company & Directors' Information:- M AND M CONSULTANCY PVT LTD [Strike Off] CIN = U74140PB1985PTC006557

Company & Directors' Information:- P M MANAGEMENT SERVICES PRIVATE LIMITED [Strike Off] CIN = U99999MH1972PTC015534

Company & Directors' Information:- SERVICES AND CONSULTANCY P. LTD. [Strike Off] CIN = U99999DL2000PTC902217

Company & Directors' Information:- MANAGEMENT SERVICES PVT LTD [Strike Off] CIN = U99999DL2000PTC904070

    Appeal No. 148 of 2013

    Decided On, 10 October 2013

    At, SEBI Securities Exchange Board of India Securities Appellate Tribunal

    By, THE HONOURABLE MR. JUSTICE J.P. DEVADHAR
    By, PRESIDING OFFICER & THE HONOURABLE MR. JOG SINGH
    By, MEMBER

    For the Appellant: L.S. Shetty, Advocate with U.R. Naik, Ms. Manjiri Joshi, Advocates. For the Respondent: Dr. Mrs. Poornima Advani, Advocate with Ajay Khaire, Ms. Virakthi Hegde, Advocates.



Judgment Text

J.P. Devadhar, Presiding Officer

1. This appeal by consent of counsel for parties is heard finally at the stage of admission.

2. Appellant is aggrieved by adjudication order dated June 6, 2013 whereby total penalty of Rs.1,50,000/- (Rs.50,000/- under Section 15A(c), Rs.50,000/- under section 15B and Rs.50,000/- under Section 15 HB of Securities and Exchange Board of India Act, 1992) has been imposed upon the appellant.

3. Mr. Shetty, learned counsel appearing on behalf of appellant fairly conceded that there were deficiencies in the functioning of the appellant. However, he pleaded that since the lapses were procedural lapses, appellant ought to have been let off with warning to be more careful in future instead of imposing penalty. Alternatively, he submitted that the penalty imposed is excessive.

4. Deficiencies in the functioning of the appellant noticed in the impugned order as follows:

'(a) KYC Forms and Agreements, (b) Prevention of Money Laundering Compliances, (c) Compliance with certain SEBI Circulars, (d) Margin Collection and Reporting (F&O Segment), (e) Analysis of Client Master, (f) Analysis of Client Codes allotted to the client, (g) Irregularities in handling of funds/securities, (h) Client’s outstanding balances and (i) Third party receipts.'

5. It is contended by counsel for appellant that the above deficiencies were on account of negligence on the part of Shri Manish Mathur, CEO of the appellant and penalty of Rs.10,00,000/- has already been imposed upon Shri Manish Mathur. It is a matter of record that as soon as deficiencies were brought to the notice of the appellant, remedial steps have been taken by the appellant by terminating the services of Shri Manish Mathur and curing the deficiencies. In these circumstances, counsel for appellant submitted that penalty imposed upon the appellant be set aside on such terms and conditions as this Tribunal deems fit and proper.

6. Counsel for respondent submits that in view of various deficiencies noticed during the investigation period, penalty imposed upon appellant is reasonable and does not warrant interference.

7. We have carefully considered rival submissions.

8. Deficiencies noticed in the impugned order are procedural deficiencies and do not involve any fraudulent action on the part of the appellant. Since penalty upon Shri Manish Mathur, CEO of appellant has already been imposed and penalty is imposed upon appellant as vicarious liability, in our opinion, it would be just and proper to restrict penalty at Rs.50,000/- instead of Rs.1,50,000/-.

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/> 9. Accordingly, while upholding the decision of SEBI in imposing penalty on account of deficiencies noticed during the investigation period, we restrict the penalty at Rs.50,000/- instead of Rs.1,50,000/-. 10. Appeal is disposed of in the above terms with no order as to costs.
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