Adjudication Order in respect of Snehbar Stockholdings Private Limited in the matter of Oasis Tradelink Limited

BEFORE THE ADJUDICATING OFFICER
SECURITIES AND EXCHANGE BOARD OF INDIA
[ADJUDICATION ORDER Ref No.: Order/AP/VS/2020-21/9534]

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:
Snehbar Stockholding Private Limited
(PAN: AACCS7431G)
Maruti House, Opp. Air India,
Nr. Popular House, Ashram Road,
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 Snehbar Stockholding Private Limited (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) during the period January 1, 2018 to March 31, 2018 (hereinafter referred to as ‘investigation period’).

2. During the investigation it was noted that the Noticee has purchased 1,48,496 shares off market during the week February 9, 2018 to February 16, 2018 and sold 4,220 shares off market during the week February 16, 2018 to February 23, 2018. Later it also sold 1,44,276 shares during the March 16, 2018 to March 23, 2018. Due to the aforementioned transactions, the shareholding of the Noticee remained unchanged for the Quarter ended March 2018 vis-à-vis for the quarter ending December 2017. The details of its transactions are as follows:

3. From the above table it is noted that for the transaction at Sr. No. 1 and 3 the transaction value of the shares exceeded ₹10 lakhs. As per regulation 7(2)(a) of the PIT Regulations, the Noticee was under obligation to make the requisite disclosures within two days to OTL. It is alleged that the Noticee failed to make the requisite disclosure to OTL on all the above mentioned occasions.

4. In order to conduct an 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 August 09, 2019 and reminder summons dated August 21, 2019 and September 05,2019 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 it. However, the Noticee failed to give any response.

5. SEBI sought information from BSE regarding the details of disclosures filed by OTL to BSE, under relevant provisions of PIT Regulations in respect of transactions undertaken by the Noticee and other promoters of the OTL. BSE vide email dated July 26, 2019 submitted that it had not received any disclosures under PIT Regulations from the Noticee in the scrip of OTL for the investigation period.

6. In view of the above, it was alleged that the Noticee have violated the provisions of regulation 7(2)(a) of the PIT Regulations with regard to its transfer during the investigation period as per mentioned in para 2 hereinabove. The relevant provisions of the PIT Regulations are reproduce as follows:

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