Noticee No Clause Samples

Noticee No. 29 had purchased 5,000 shares of RSGBL out of the loans availed in normal course of business. Noticee No. 29 has used the amount of Rs.50 lakh for the purchase of shares of other listed company. Except for the transaction of 5,000 shares of RSGBL, there is no funds trail and no connection with dealing the scrip of RSGBL nor any relations with the promoters of RSGBL. The account statement and contract notes evidencing the entire trail of funds till the utilisation of the same are enclosed.

Noticee No. 14 to 29 vide common email dated February 10, 2020 and vide common letter / email dated July 15, 2020 submitted their reply / written submissions in the matter. Their submission in brief are as under: 12.1. Noticee No. 14 to 29 denied all allegations mentioned against them in the SCN. 12.

Noticee No. 4 vide letter dated February 17, 2020, Noticee No. 5 to 9 vide common letter dated February 17, 2020 and Noticee No. 4 to 9 vide common letter / email dated July 15, 2020 submitted their reply / written submissions in the matter. Their submission in brief are as under: 9.1. Noticee No. 4 to 9 denied the allegation mentioned in the SCN. 9.2. Sayaridevi does not have any connection with RSGBL. ▇▇▇▇▇▇▇▇▇▇ neither holds any shares in RSGBL nor had anything to do with the delisting process or in the book building process of delisting of shares of RSGBL. ▇▇▇▇▇▇▇▇▇▇ was part of the family arrangement / separation and not part of the promoter group. 9.3. ▇▇▇▇▇▇▇▇▇▇ transferred the fund of Rs. 31,25,000/- to her son Motit out of her love and affection for him to utilise the fund in usual course of his business. ▇▇▇▇▇ utilised the funds to acquire the shares of Vital. The said acquisition of Vital was not on the instruction of ▇▇▇▇▇▇▇▇▇. The acquisition of Vital was an independent decision of ▇▇▇▇▇ and was carried out in the ordinary course of business for the purpose of carrying on the business of advisory and consultancy in finance and management.

Noticee No. 19 had availed a loan from Metroglobal Limited and payment of Rs. 150 lakhs mentioned in the Show Cause Notice is towards repayment of the said loan. The amounts outstanding against the loans from Metroglobal Limited loan as on March 31, 2019 is Rs.425.10 Lakhs. The loan ledger from April 1, 2016 to March 31, 2019 enclosed

Noticee No. Period Gross Buy quantity Gross Sell quantity Total Gross Buy and Sell Quantity % to total gross buy and sell quantity compared to total gross buy and sell quantity during IP 1, 2 ,3 and 14 to 33 01.12.2015 - 30.11.2016 79,520 75,750 1,55,270 9.08 01.12.2016 - 30.11.2017 8,50,669 8,59,545 17,10,214 100.00 01.12.2017 - 30.11.2018 1,06,047 1,54,133 2,60,180 15.21

Noticee No. 30 vide email dated January 11, 2020 and July 07, 2020 submitted her reply / written submissions in the matter. Her submission in brief are as under: 13.1. The investments in the securities market are made after carrying out a study of the Companies listed on the Stock Exchange. The factors, which taken into consideration while investing are debt of the Company, book value of the Company, ratio analysis of the company in comparison to the price at which the said equity shares are being quoted on the stock exchange, fundamentals of the company, the future growth of the company and margins arises on account of buying and selling of the scrip. 13.2. RSGBL as a company showed excellent prospects and the returns which could get by making investments in RSGBL would be worth the amount of money that put in purchase of the shares of RSGBL. The investment in RSGBL are as part of ordinary course of investment and out of her own funds and have been investing in RSGBL prior to as well as during the course of inquiry by SEBI 13.3. All the investments in the share markets are made by her out of her own funds and have not borrowed any funds to make investment in share markets. Balance sheet for the FY 2016-17 and 2017-18 as well as the profits and loss accounts and copy of Income Tax Returns which give details of her investments in the securities market along with the value of the same are enclosed. The balance sheet for the FY 2016- 17 indicates that the value of investments in the share market is around 19 lakhs and current assets are around 27 lakhs and investment in mutual funds are approximately 19 lakhs. 13.4. The investments made in RSGBL are commensurate and proportionate to the total investments made in the securities market. 13.5. At the time of opening Noticee No. 30 trading and demat account, her father’s E- mail i.d. had been given. After marriage, merely out of convenience the transactions are being carried out in her maiden name and hence, even the e-mail i.d. of her father is being used. 13.6. She has no professional or business relations with ▇▇. ▇▇▇▇▇▇▇▇▇▇ ▇.

Noticee No. 38 vide letters dated January 20, 2020 and June 27, 2020 submitted that she was an independent director of RSGBL from March 27, 2015 to February 12, 2019. She was not involved in day to day activities of RSGBL. There is no allegation in the SCN against her. All actions and decision taken during his tenure as an independent director were based on the facts and figure presented to the board of directors of RSGBL. The promoter and RSGBL will submit detailed response in the matter.

Noticee No. Name Connection 9 Kauvery Trexim Private Limited (Kauvery) Account number 9412074333 with Kotak Mahindra Bank analysed from 01/01/16 to 30/09/18. Had multiple high value fund transaction with RSGBL and its promoters. • On 28/02/2017 received Rs. 25 lacs from Siwana and transferred same to ▇▇▇▇▇ ▇▇▇▇▇▇▇▇▇▇▇▇ ▇▇▇▇ on same day. (Siwana had received 100 lacs from RSGBL on same day and 35 lacs on previous day from blueseal agro private limited and blue seal has common address with RSGBL). • On 16/03/2017 received Rs. 25 lacs from Siwana and transferred same to ▇▇▇▇▇ ▇▇▇▇▇▇▇▇▇▇▇▇ ▇▇▇▇ on same day. (Siwana had received 24 lacs from RSGBL and 01 lac from creelotex on same day.) • On 18/03/2017 received Rs.50 lacs from Siwana and transferred same to ▇▇▇▇▇▇▇▇▇▇ ▇▇▇▇▇▇▇▇▇▇▇▇ ▇▇▇▇ on same day. (Siwana had received 50 lacs from RSGBL on same day.) • On 22/03/17 received Rs. 25 lacs from RSGBL and transferred it to ▇▇▇▇ ▇▇▇▇▇ on same day. • On 22/03/17 received Rs. 3.00 lacs from Blue Seal Agro Private Limited and received Rs. 22 lacs from Siwana on 23/03/2017. Rs. 25 lacs transferred to ▇▇▇▇ ▇▇▇▇▇ on 23/03/2017. ((Siwana had received 198 lacs from Marg Biotech Private Limited and 1475 lacs from Safari Infrastructure LLP on same day. Safari has ▇▇▇▇▇▇▇▇▇ ▇▇▇▇▇▇▇▇▇ and ▇▇▇▇▇▇▇▇▇ ▇▇▇▇▇▇▇▇▇ as its designated partners and has common address with RSGBL. Marg has common address with ▇▇▇▇▇▇ ▇▇▇▇▇▇▇▇ who is CFO of RSGBL) • On 07/04/2017 received Rs. 100 lacs from RSGBL and transferred 50 lacs to ▇▇▇▇▇▇▇▇▇▇ ▇▇▇▇▇▇▇▇▇▇▇▇▇ ▇▇▇▇ and 50 lacs to ▇▇▇▇▇▇▇ ▇▇▇▇▇▇▇▇ ▇▇▇▇. • On 17/05/2017 received Rs. 30 lacs from Siwana and transferred the same to ▇▇▇▇▇ ▇▇▇▇▇▇▇▇▇▇▇▇ ▇▇▇▇ on same day 10 Blue Seal Agro Pvt. Ltd. • Has common address with RSGBL • On 28/02/2017 Kauvery Trexim Private Limited received Rs. 25 lacs from Siwana and transferred same to ▇▇▇▇▇ ▇▇▇▇▇▇▇▇▇▇▇▇ ▇▇▇▇ on same day. (Siwana had received 100 lacs from RSGBL on same day and 35 lacs on previous day from blueseal agro private limited • On 22/03/17 Kauvery Trexim Private Limited received Rs. 3.00 lacs from Blue Seal Agro Private Limited 11 Marg Biotech Private Limited • Marg has common address with ▇▇▇▇▇▇ ▇▇▇▇▇▇▇▇ (Noticee No. 13) who is CFO of RSGBL Noticee No. Name Connection • Kauvery Trexim Private Limited received Rs. 22 lacs from Siwana on 23/03/2017. Siwana had received 198 lacs from Marg Biotech Private Limited and 1475 lacs from Safari Infrastructure LLP on same day. 12 ▇▇▇▇▇▇▇▇▇ ▇▇▇▇▇▇ ▇▇▇▇ • On 30/03/17, received an a...

Noticee No. 13 (▇▇. ▇▇▇▇▇▇▇▇▇▇▇ ▇▇▇▇ Samadria), CFO of RSGBL is connected to Noticee No. 3 (promoter of RSGBL) and Noticee No. 23 (traded entities) through fund transfer.