SEBI finds ₹8.81 lakh discrepancy in Cash Cow Broking fees

This order addresses a dispute over the exact amount of fees collected by Cash Cow Broking & Advisory Solutions and its partners for unregistered investment advisory services, following a previous SEBI order and a Securities Appellate Tribunal (SAT) directive to recalculate the refund amount.

Who it concerns: M/s. Cash Cow Broking & Advisory Solutions, Mr. Shailendra Sen, Mr. Amit Jain, and Mr. Chirag Sharma

What SEBI found or ordered

• SEBI found that the Noticees engaged in unregistered investment advisory activities.
• SEBI calculated the fees collected from unregistered activities to be ₹46,10,906.06, which contradicts the Noticees' claim of ₹37,29,444.
• The Noticees had previously deposited ₹40,00,000 with SEBI as directed by the SAT to enable the recalculation process.
• SEBI stated that the verification of refunds already made to 121 clients (claimed as ₹32,83,930) is outside the scope of the current recalculation proceedings and will be handled at the implementation stage.
• The order notes that the Noticees were restrained from accessing the securities market since the 2022 order.

Also in the document

• There is a discrepancy of approximately ₹8.81 lakh between the amount claimed by the Noticees and the amount calculated by SEBI based on bank data.
• The Noticees argued that some amounts were for internet services or partner contributions, while SEBI classified them as advisory fees.
• The proceedings are limited to crystallizing the total amount collected, as per the SAT's direction, rather than adjudicating the merits of the unregistered activity itself.