Authority: Adjudicating Officer, Securities and Exchange Board of India

Order Date: September 11, 2026

Case Overview

The Adjudicating Officer of SEBI passed an order against Investowryght Research Analytics Private Limited (Registration No. INH000012157), a SEBI-registered research analyst, following an inspection conducted on September 23, 2025, covering the period from April 1, 2024, to August 31, 2025. The inspection revealed multiple violations across several regulatory frameworks.

The principal allegations included:

1. Assurance of Returns and Inducement to Trade: Based on SCORES portal complaints from two investors (XYZ and PQR), the Noticee's executives were found to have assured returns, guaranteed profit recovery, and induced trading through WhatsApp communications. Evidence included messages such as "recover ho jyega sir" (losses will be recovered), "profit deke jyega" (will give profit), "10 lot buy krke ss do" (buy 10 lots and share screenshot), and demands to arrange additional funds after losses were incurred.

2. KYC Record Maintenance Deficiencies: The Noticee failed to maintain Know Your Customer records in the uniform format prescribed by SEBI circulars and CERSAI's CKYCR Template, capturing only basic information (name, PAN, address, email, mobile number) instead of the mandated details.

3. Excessive Fee Charging: The Noticee charged fees beyond the maximum permissible limit of ₹1,51,000 per annum per family from nine clients after the regulatory ceiling became effective (January 8, 2025, for new clients; June 30, 2025, for existing clients). The excess payments totaled approximately ₹6 lakh. Additionally, the Noticee's website continued to display plans priced above the limit during the inspection period.

4. Delayed Complaint Redressal Publishing: As of April 1, 2026, the Noticee had published complaint redressal data only up to July 2025 on its website, failing to meet the requirement to publish such data by the 7th of the succeeding month.

5. Delayed Periodic Reporting: The Noticee failed to submit half-yearly periodic reports to the Research Analyst Administration and Supervisory Body (RAASB) for the periods ending March 31, 2025, and September 30, 2025, within the stipulated 30-day timeframe.

The Noticee submitted written replies denying the allegations regarding assured returns and profit-sharing, claiming payments were for research services only. It admitted to KYC format deficiencies but claimed corrective measures were undertaken. For excessive fees, it cited transitional challenges and delayed awareness of the new limit. The Noticee did not rebut the allegations regarding delayed publishing of complaint data or delayed reporting to RAASB.

The Adjudicating Officer found the WhatsApp evidence conclusive in establishing fraudulent inducement, noting that the communications went beyond permissible research advice and contained specific trading instructions, recovery assurances, and demands for additional funds. The Officer applied the Supreme Court's test from Reliance Industries Ltd. v. SEBI, finding both injury to investors and deceitful intention established.

Final Outcome

The Adjudicating Officer imposed a total penalty of ₹10,00,000 (Ten Lakh Rupees) under sections 15HA and 15EB of the SEBI Act:

  • ₹5,00,000 under Section 15HA for violations of PFUTP Regulations (assurance of returns/inducement)
  • ₹5,00,000 under Section 15EB for all other violations (KYC, excessive fees, delayed publishing, delayed reporting)

The penalty must be paid within 45 days of receipt of the order. Failure to pay may lead to recovery proceedings under Section 28A of the SEBI Act.

Topics: SEBI Enforcement, Research Analyst Compliance, Fraudulent Trade Practices