SEBI orders ₹1.70 crore refund in unregistered investment advisory case

This final order determines the specific amount of illegal gains made by Mr. Madhav Tiwari from unregistered investment advisory activities, following a directive from the Securities Appellate Tribunal (SAT) to re-quantify the refund amount after reviewing his bank statements and evidence.

Who it concerns: Mr. Madhav Tiwari (Proprietor of Divinecommodity.co)

What SEBI found or ordered

• SEBI found that the Noticee acted as an unregistered investment advisor and fraudulently assured guaranteed returns.
• The Noticee admitted to collecting INR 9,66,207 specifically for advisory services between FY 2020-21 and FY 2022-23.
• The Noticee claimed other income (SEO, real estate, astrology) totaling INR 1,52,84,893 was separate from advisory fees.
• SEBI directed the Noticee to refund the amount received from investors for unregistered advisory activities.
• The Noticee was debarred from accessing the securities market for 2 years or until the repayment report is filed, whichever is later.
• A penalty of INR 5,00,000 under Section 15HA and INR 1,00,000 under Section 15EB of the SEBI Act was imposed.
• The SAT upheld the penalties but directed SEBI to reconsider the quantification of the refund amount based on the Noticee's explanation of bank entries.

Also in the document

• The initial SEBI order (Sept 2024) had directed a refund of INR 1,70,12,615, which the Noticee disputed, claiming only INR 9,66,207 was for advisory services.
• The SAT order (Sept 2025) upheld the penalties but remanded the quantification of the refund amount back to SEBI for re-evaluation.
• The Noticee operated multiple businesses including SEO, real estate, and astrology, which he argued were distinct from the illegal advisory activities.