The inter se connections of various entities are established from common addresses, KYC documents, common directorship and off market transfers.
SEBI, through its Whole time Member, in the matter of Vertex Spinning Limited and DMC International Limited, considered the issue of whether the Noticees are connected entities?
It was observed by the Whole time Member that that during the investigation, certain entities including Chetan Dogra were identified as connected entities and the said connection was based on inter se connections established because of common addresses, KYC documents, common directorship and off market transfers. From the materials on record, it is noted that the Noticee no. 1 (Chetan Dogra) is the Karta of the Noticee no. 2 (Chetan Dogra HUF) and as per the KYC documents of these two Noticees, they both share common address and located at 801, Tower-1, NRI Complex, Sea Wood estate, Palm Beach Road, Nerul, Navi Mumbai, Maharashtra. Further, the Noticee no. 1 is one of the director in the Noticee no. 3 to 8. Besides, there are off market transfers of shares of VSL between the Noticees (except the Noticee no. 4 & the Noticee no. 5) and the promoter of VSL. Considering, the aforesaid and particularly, considering that the Noticee no. 1 is the Karta of the Noticee no. 2, and that the Noticee no. 1 is the common director in the Noticee nos. 3 to 8 and also the fact that there were off-market transactions of shares amongst them, I find that it can be reasonably concluded that the Noticees are connected entities. Moreover, the allegations of their connections based on the above have not been disputed by any of the Noticees which further establishes that the Noticees have nothing to dispute so far as their inter-connectedness is concerned.
(Link : https://www.sebi.gov.in/enforcement/orders/oct-2019/order-in-the-matter-of-trading-by-chetan-dogra-group-entities-in-the-scrips-of-vertex-spinning-limited-and-dmc-international-limited-_44790.html)