SEBI imposes penalty on unregistered investment advisor Mohit Gupta

The order specifically addresses the penalty imposed under Section 15HA of the SEBI Act following a remand by the Securities Appellate Tribunal (SAT).

Who it concerns: Mr. Mohit Gupta (Proprietor of Safe Trading)

What SEBI found or ordered

• SEBI found that the Noticee acted as an unregistered investment advisor and collected funds by fraudulently assuring guaranteed returns.
• SEBI directed the Noticee to refund INR 23,94,574.50 to investors.
• SEBI debarred the Noticee from accessing the securities market for 1 year or until the repayment report is filed, whichever is later.
• SEBI imposed a penalty of INR 1,00,000 under Section 15EB of the SEBI Act.
• SEBI upheld the liability for a penalty under Section 15HA of the SEBI Act, which has a statutory minimum of INR 5,00,000.
• SEBI noted that the Noticee had not complied with the direction to refund investors as of the date of this order.

Also in the document

• The Securities Appellate Tribunal (SAT) had previously remitted the case to SEBI specifically to reconsider the penalty under Section 15HA, while sustaining the refund and the Section 15EB penalty.
• SEBI cited Supreme Court precedents to reject the Noticee's argument that the penalty was disproportionate or discriminatory compared to other cases.
• SEBI noted that the Noticee claimed to have issued a public notice for refunds in November 2025, but failed to open the required escrow account or comply with the refund direction.