Case Details

  • Entity Involved: Mr. Amit Guruh Sachdeva, a SEBI registered Research Analyst (SEBI Registration No. INH100005190, PAN: BIJPS0406C).
  • Order Number: QJA/BS/MIRSD/MIRSD-SEC-5/32425/2026-27.
  • Order Date: May 27, 2026.
  • Period of Investigation: The surprise onsite inspection was conducted on March 14-15, 2024, covering the period from April 01, 2022, to February 29, 2024 (the "Inspection Period").
  • Financial Impact: A separate Adjudication Order dated August 28, 2025, had already imposed a monetary penalty of ₹2 Lakh on the Noticee for violations from the same inspection period, which has been paid. The present order imposes no additional monetary penalty, only a regulatory censure.

Persons Involved

  • Mr. Amit Guruh Sachdeva (Noticee): The individual Research Analyst who is the subject of the order.
  • Designated Authority (DA): The SEBI authority who conducted the initial enquiry and submitted a report recommending action.
  • Authorized Representative (AR): Represented the Noticee during personal hearings.
  • Relationship Managers (RMs): Employees of the Noticee who were directly involved in making calls assuring returns to clients. The Noticee stated three RMs were involved and their services were terminated.
  • Biju S.: The Quasi Judicial Authority for SEBI who issued the final order.

Violations and Allegations

The inspection found violations of the SEBI (Research Analyst) Regulations, 2014 (RA Regulations) and the SEBI (Prohibition of Fraudulent and Unfair Trade Practices relating to Securities Market) Regulations, 2003 (PFUTP Regulations).

1. Assurance of Returns (Mis-selling):

  • The Noticee's Relationship Managers (RMs), who were considered "associated persons" under the RA Regulations, routinely made calls to prospective clients who provided contact details on the website www.stockbenifits.com.
  • In these calls, the RMs assured returns of "18-20%" profit, using phrases like "Aapki capital par 18 se 20% ka munafa nikal sake" and "try karte hai 18-20% profit nikal ke de sake". In one instance, a claim of 20-25% profit was made.
  • The Noticee argued these were unauthorized actions by RMs for the derivatives segment and were forbidden in internal manuals, but no evidence of such manuals or disciplinary action was produced.
  • This was deemed a violation of:
  • Clauses 1 (Honesty and Good Faith), 2 (Diligence), 7 (Compliance), and 8 (Responsibility of senior management) of the Code of Conduct under the Third Schedule of the RA Regulations, read with Regulation 24(2).
  • Regulations 3(c), 3(d), 4(1), 4(2)(k), 4(2)(o), and 4(2)(s) of the PFUTP Regulations.
  • Section 12A(c) of the SEBI Act, 1992.

2. Non-Cooperation with SEBI Inspection:

  • Delay in Meeting: The Noticee caused a two-hour delay on the final inspection day, claiming he was under a "digital arrest" from individuals impersonating TRAI and Mumbai Police. The authority found no supporting evidence like an FIR or dated documents to substantiate this claim.
  • Deletion of Data: Data was deleted from the email account stockbenefits80@gmail.com. The Noticee claimed this was due to a "technical glitch" but provided no evidence to support this assertion.
  • These actions were deemed a failure to cooperate, violating Regulations 29(1) and 29(2) of the RA Regulations and Clauses 1, 2, 5, 7, and 8 of the Code of Conduct.
  • An allegation regarding the installation of CCTV cameras to monitor SEBI officers was not upheld, as the Noticee provided purchase receipts showing they were installed months prior for internal monitoring.

Penalties, Settlement Terms & Rulings

  • The Designated Authority (DA) had recommended two actions: (a) a regulatory censure, and (b) prohibiting the Noticee from taking any new clients for a period of two months.
  • The final ruling considered the mitigating factors presented: the non-repetitive nature of the violations, action taken against errant employees (though unproven), no investor complaints related to the allegations, and the fact a monetary penalty of ₹2 Lakh had already been paid for violations from the same inspection period.
  • The Adjudication Order (monetary penalty) and this proceeding under the Intermediaries Regulations were deemed separate; one does not preclude the other.
  • The final order concluded that a prohibition on new clients was not commensurate given the mitigating factors and the already-paid monetary penalty.

Final Ruling and Enforcement

  • Final Decision: A regulatory censure is issued against Mr. Amit Guruh Sachdeva under Section 12(3) and Section 19 of the SEBI Act, 1992, read with Regulation 27(5) of the SEBI (Intermediaries) Regulations, 2008.
  • Effective Date: The order came into force immediately on May 27, 2026.
  • Enforcement: A copy of the order was to be served upon the Noticee and BSE Limited (the Research Analyst Administration and Supervisory Body) for information and record.