Authority: Amarjeet Singh, Whole Time Member, Securities and Exchange Board of India

Order Date: Not explicitly stated in the provided text

Case Overview

The proceedings were initiated by SEBI based on complaints received against Sai Proficient Research Investment Advisory (SPRIA), a SEBI-registered investment advisor. During the examination of these complaints, it was observed that a complainant, Mr. Shyamsundar Virmani, had paid ₹5 lakhs to SPRIA but never received the assured returns promised. Investigation revealed that payments were received into an Easebuzz account belonging to Shree Sai Proficient Financial Services, Proprietor – Ms. Madhuri Garg (Noticee/SSPFS). A Show Cause Notice (SCN) dated June 5, 2025, was issued to the Noticee alleging two violations: (1) providing investment advisory services without requisite registration in violation of Section 12(1) of the SEBI Act and regulation 3(1) of the IA Regulations, and (2) promising assured returns in violation of Regulations 3(a), (b), (c), (d) and 4(2)(k) of the PFUTP Regulations read with Section 12A(c) of the SEBI Act.

The Noticee defended herself by stating she had only entered into a non-core activities outsourcing agreement with SPRIA, limited to administrative and back-office support. She claimed the bank and Easebuzz accounts, though in her name, were operated solely by the proprietor of SPRIA, who also controlled the email communications and assured refunds to investors. The Noticee denied providing any investment advice, conducting risk profiling, or having any client interaction.

Final Outcome

After examining the material on record, including account details from Easebuzz and Axis Bank, and emails from the proprietor of SPRIA assuring refunds, the Whole Time Member found that the evidence was insufficient to establish that the Noticee was providing investment advice for consideration. The address linked to the accounts belonged to SPRIA, and it was SPRIA's proprietor, not the Noticee, who contacted investors. Consequently, the allegations of unregistered investment advisory activities and promising assured returns were dismissed. The proceedings initiated vide SCN dated June 5, 2025, were disposed of without issuing any directions or imposing any monetary penalty on the Noticee.

Topics: SEBI Enforcement, Unregistered Investment Advisory, Dismissal of Proceedings