SEBI recalculates PMS fees at Rs. 13.42 crore after forensic audit

This order addresses the violation of SEBI regulations by Mr. Nishaan Singh for providing unregistered Portfolio Management Services (PMS). It details the reassessment of the amount collected for these services following a remand by the Securities Appellate Tribunal (SAT) and a forensic audit.

Mr. Nishaan Singh (Proprietor of Sanbun Investments and Sanbun Capital Hedge Fund)

• SEBI found that the Noticee violated Section 12(1) of the SEBI Act and Regulation 3 of the SEBI (Portfolio Manager) Regulations, 2020 by providing unregistered PMS.
• The Securities Appellate Tribunal (SAT) upheld SEBI's initial findings but remitted the matter for reassessment of the quantum of money received and the period of debarment.
• A Forensic Audit Report (FAR) dated July 16, 2025, was conducted by an empaneled auditor to assess PMS-related receipts in two HDFC bank accounts.
• SEBI deemed the FAR findings inconclusive due to lack of sufficient documents and incomplete methodology, leading to a recalculation of the PMS amount.
• SEBI recalculated the amount collected towards PMS activity at Rs. 13,42,38,054.90, excluding unrelated credits of Rs. 2,77,45,259.71 from the total credits of Rs. 16,19,83,314.61.
• The Noticee's authorized representatives agreed to refund the amount as arrived in the FAR (Rs. 82,65,548.46) to expedite closure, but later contested SEBI's recalculation.
• Multiple personal hearings were held between February and May 2026, with the Noticee and his mother appearing on May 11, 2026, agreeing to refund monies as per the FAR findings.

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