Debock Industries SEBI Final Order: 2-Year Market Ban

Order Reference: WTM/AS/CFID/CFID-SEC4/32684/2026-27 dated September 30, 2026
Issuing Authority: Securities and Exchange Board of India (SEBI)
Legal Basis: Sections 11(1), 11(4), 11(4A), 11B(1) and 11B(2) of the SEBI Act, 1992

Debarred from accessing securities market for 2 years from order date
Prohibited from buying, selling or dealing in securities directly or indirectly
Monetary penalty of ₹50,00,000 (Rupees Fifty Lakh) under Section 15HA of SEBI Act, 1992
Penalty payable within 45 days from order receipt date

Show Cause Notice dated September 15, 2025 issued after detailed investigation
Interim order dated August 23, 2024 against Noticee Nos. 1, 2, 3 and 4
Confirmatory order dated December 11, 2024
Investigation focused on violations of SEBI Act, PFUTP Regulations, and LODR Regulations

Sales Inflation: 69.95% in FY22, 62.17% in FY23, 40.38% in FY24 of total sales were fictitious
Purchases Inflation: 95.09% in FY22, 94.51% in FY23, 58.82% in FY24 of total purchases were fictitious
Circuitous Transactions: ₹22.90 crore sales and ₹22.64 crore purchases in FY24 through circular fund movements
Non-Existent Bank Accounts: Transactions recorded in Equitas Small Finance Bank account that was closed in November 2020

1st Preferential Issue (September 2021): 3,00,00,000 convertible warrants at ₹12.5 per warrant, totaling ₹37.57 crore consideration not actually received
2nd Preferential Issue (November 2023): 5,35,71,428 convertible warrants at ₹14 per warrant, totaling ₹74.99 crore consideration not actually received
Fictitious Allottees: Shares issued to connected parties including employees and promoters without genuine consideration

Amount Raised: ₹49.50 crore through rights issue in June 2023
Stated Objects: Meeting incremental working capital requirements and general corporate purposes
Actual Diversion: ₹49 crore transferred to Impex Agrotech Limited (related party) within 3 days of receipt
Fund Trail: Funds ultimately routed to promoters and overseas entities through multiple layers

Issue Size: 3.82 crore shares at 1:1 ratio on November 01, 2022
Fictitious Reserves: ₹25.01 crore out of ₹38.22 crore free reserves used were fictitiously generated

Fabricated bank statements submitted to SEBI to conceal fictitious transactions
Forged bank statements of allottees submitted to substantiate preferential issue receipts
False certifications of financial statements

Total Unlawful Gains: ₹59,30,52,248 to be disgorged with 12% simple interest
Sunil Kalot: ₹37,66,55,212 individually
Mukesh Manveer Singh: ₹4,24,17,670 individually
Mukesh Manveer Singh & Gaurav Jain: ₹17,39,79,366 jointly and severally
Payment due within 45 days to Investor Protection and Education Fund (IPEF)

Debock Industries Limited: ₹1,10,00,000 (₹1 crore under 15HA + ₹10 lakh under 15HB)
Mukesh Manveer Singh: ₹20,10,00,000 (₹20 crore under 15HA + ₹10 lakh under 15HB)
Sunil Kalot: ₹5,00,00,000
Priyanka Sharma: ₹1,00,00,000
Naturo IndiaBull Limited: ₹50,00,000
Impex Agrotech Limited: ₹1,00,00,000
Gaurav Jain: ₹50,00,000
Avance Ventures: ₹20,00,000
Nishu Goyal: ₹6,00,000 (₹5 lakh under 15HA + ₹1 lakh under 15HB)
Vandana Patidar: ₹6,00,000 (₹5 lakh under 15HA + ₹1 lakh under 15HB)
Jyoti Choudhary: ₹5,00,000

7-year debarment from accessing securities market
7-year prohibition from buying/selling/dealing in securities
Mukesh Manveer Singh restrained from association with listed companies/SEBI intermediaries as director/KMP
Period reckoned from Interim Order date (August 23, 2024)

Sunil Kalot: 5-year market ban and director/KMP restraint
Priyanka Sharma & Gaurav Jain: 3-year market ban and director/KMP restraint
Nishu Goyal, Vandana Patidar, Jyoti Choudhary, Avance Ventures, Impex Agrotech, Naturo IndiaBull: 2-year market ban
Nishu Goyal, Vandana Patidar, Jyoti Choudhary: 2-year director/KMP restraint

Debock Industries must recover ₹49 crore diverted rights issue funds from Impex Agrotech Limited within 3 months
Interest payable at 12% per annum from diversion date (July 24, 2023)

Regulations 3(a), (b), (c), (d), 4(1), 4(2)(c), (f), (h), (k) of PFUTP Regulations
Sections 12A(a), (b), (c) of SEBI Act, 1992
Regulations 4(1), 4(2)(e), 17(1)(b), 23(1), (2), (4), 32(1), (2), (4), 33(1)(a), (c), 48 of LODR Regulations
Sections 11(2)(ia), 11C(2), 11C(3) of SEBI Act
Non-compliance with Ind AS 1 and Ind AS 7 accounting standards

Company is examining the Final Order and its implications
Will take further steps as required under applicable law
Blamed former employees (Abhishek Khandelwal and Ankit Sharma) for fraudulent activities
Claimed submission of forged documents was inadvertent by new compliance officer