Adjudication Order in respect of Mr. Snehal Bharatbhai Patel in the matter of Oasis Tradelink Limited

BEFORE THE ADJUDICATING OFFICER
SECURITIES AND EXCHANGE BOARD OF INDIA
[ADJUDICATION ORDER Ref No.: Order/AP/VS/2020-21/9533]
 

UNDER SECTION 15-I OF SECURITIES AND EXCHANGE BOARD OF INDIA ACT, 1992 READ WITH RULE 5 OF SEBI (PROCEDURE FOR HOLDING INQUIRY AND IMPOSING PENALTIES) RULES, 1995.

In respect of:
Mr. Snehal Bharatbhai Patel
(PAN: BJBPP1597A)
14/A, Hindu Colony,
Nr Swastik Vidhya Mandir, Navrangpura,
Ahmedabad, Gujarat-380009
In the matter of
Oasis Tradelink Limited

1. Oasis Tradelink Limited (hereinafter referred to as ‘OTL’), is a company listed on Bombay Stock Exchange Limited (BSE). Securities and Exchange Board of India (‘SEBI’) had conducted an investigation in the matter of trading in the scrip of the OTL by its promoter and Compliance Officer, Mr. Snehal Bharatbhai Patel (hereinafter referred to as ‘the Noticee’), to ascertain whether there was any violation of the provisions of SEBI (Prohibition of Insider Trading) Regulation, 2015 (hereinafter referred to as ‘the PIT Regulations) and SEBI (Substantial Acquisition of Shares & Takeovers) Regulations, 2011 (hereinafter referred to as ‘the SAST Regulations) during the period January 1, 2018 to March 31, 2018 (hereinafter referred to as ‘investigation period’).

2. During the investigation it was observed that the Noticee had sold 3,28,362 shares off market during the week January 12, 2018 to January 26, 2018. The details of his transactions are as follows:

3. From the above table it is noted that by selling 3,00,000 shares off market during the January 12, 2018 to January 19, 2018, the shareholding of Noticee reduced from 5.27% to 2.51%. As per regulation 29(2) read with 29(3) of the SAST Regulations the Noticee was under obligation to disclose the change in his shareholding to OTL and BSE.

4. It is also noted that the transaction value of 3,00,000 shares based on closing price on BSE on the date of transaction is calculated as ₹2,49,15,000/-, in this regard the Noticee was under obligation to make requisite disclosure under regulation 7(2)(a) of PIT Regulations. Further, the selling of 28,362 shares of transaction value ₹23,55,464/- (based on closing price on BSE on the date of transaction) by the Noticee puts him under obligation of regulation 7(2)(a) of the PIT Regulations. It is alleged that the Noticee fails to make the requisite disclosure to OTL and BSE on all the above mentioned occasions.

5. In order to conduct a thorough investigation in to the disclosures made by the Noticee to BSE/OTL the Investigating Authority (IA) appointed by SEBI in the matter, vide summon dated April 10, 2019 summoned the Noticee to furnish documents/records/information etc. as per enclosed annexure therein. It was also advised to the Noticee that in case he fails to disobey the information requisition vide the aforesaid summons, SEBI may initiate prosecution/adjudication proceedings against him. The Noticee vide his letter dated May 04, 2019 acknowledged the summons and requested additional time for his submission.

6. The Noticee vide letter dated May 27, 2019, informed that he had filed the disclosures with the OTL and BSE. The Noticee had also submitted the courier delivery receipt dated January 22, 2018, addressed to BSE. However, he did not provide any copies of disclosures acknowledged by BSE/OTL.

7. Subsequently, SEBI vide its email dated June 19, 2019, asked the Noticee to provide the copies of disclosures filed by him, duly acknowledged by the OTL. However, no information was received from the Noticee. Further, reminder summons were issued to the Noticee on August 9, 2019 and Aug 21, 2019, seeking information pertaining to disclosures made by him to the OTL under PIT Regulations and SAST Regulations in respect of his transfer in the scrip of OTL during the investigation period. However no response has been received till date.

To know more in details find the attachment file.