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Markets Securities & Exchange Board

SEBI finds Shrimoney proprietor violated regulations by guaranteeing returns

This is a final order by SEBI regarding Punit Kumar, the proprietor of Shrimoney (a registered Research Analyst), concerning alleged violations of regulations related to guaranteeing returns and failing to maintain required disclosures and…

This is a final order by SEBI regarding Punit Kumar, the proprietor of Shrimoney (a registered Research Analyst), concerning alleged violations of regulations related to guaranteeing returns and failing to maintain required disclosures and records.

Who it concerns: Punit Kumar (Proprietor of Shrimoney – Research Analyst), SEBI Registration No. INH000008844

What SEBI found or ordered

  • SEBI found that the Noticee guaranteed returns and misled clients in violation of PFUTP Regulations and RA Regulations.
  • SEBI found that the Noticee failed to make required disclosures under Regulation 19 of RA Regulations.
  • SEBI found that the Noticee did not maintain records of the rationale for research recommendations as required under Regulation 25 of RA Regulations.
  • The Designated Authority recommended prohibiting the Noticee from taking new clients for one month.
  • The order is issued under Section 12(3) of the SEBI Act, 1992, and Regulation 27 of the SEBI (Intermediaries) Regulations, 2008.

Also in the document

  • The inspection period covered from April 01, 2022, to February 13, 2024.
  • The Noticee argued that statements like 'try to recover loss' or 'can make profit' were not guarantees but expressions of possibility or service fee waivers.
  • The Noticee contended that providing buy/sell/hold recommendations via WhatsApp or apps did not constitute publishing 'research reports' requiring specific disclosures under the regulations applicable at the time.

How this was written

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The original document

Securities & Exchange Board of India (SEBI) — enforcement orders

Regulatory order · Ref. WTM/AN/MIRSD/MIRSD-SEC-6/31706/2025-26 · 6 Oct 2025

Order 6 Oct 2025 · 0.7 MB Open the document On sebi.gov.in ↗
Read it here

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