| S.No. |
ENTITY |
PERSONS |
REGULATORY CHARGES |
REGULATORY ACTION(S) / DATE OF ORDER |
FURTHER DEVELOPMENTS |
| 81 |
|
IREO INVESTMENT ADVISORS PVT.LTD.
|
|
|
DID NOT FILE QUARTERLY REPORTS TO SEBI
|
IMPOSED PENALTY RS.1,00,000
30-SEP-2022
|
|
| 82 |
|
|
IROHA EMERGING INDIA FUND
(PAN:AACTI2000G)
(Along with : IROHA INVESTMENT MANAGEMENT PVT.LTD.)
|
|
|
|
CHANDRASHEKAR SHEKAR
PAN:BMTPS0481H
|
|
|
JAIRAM JANARDHANAN
PAN:AMRPJ9564D
|
|
|
KIRTI CHOPRA
PAN:ADRPC8713G
|
|
|
NAVEEN LOHIYA
PAN:AHWPL2078C
|
|
ALLEGED VIOLATION OF CONCENTRATION LIMIT OF 10% OF INVESTABLE FUNDS IN A SINGLE INVESTEE COMPANY
|
REACHED SETTLEMENT ( SETTLEMENT CHARGES RS.29,25,000 ALONG WITH OTHER ENTITIES/PERSONS VIDE CONSENT ORDER)
01-JUL-2025
|
|
| 83 |
|
|
IROHA INVESTMENT MANAGEMENT PVT.LTD.
(PAN:AAFCI2658Q)
(Along with : IROHA EMERGING INDIA FUND)
|
|
|
|
CHANDRASHEKAR SHEKAR
PAN:BMTPS0481H
|
|
|
JAIRAM JANARDHANAN
PAN:AMRPJ9564D
|
|
|
KIRTI CHOPRA
PAN:ADRPC8713G
|
|
|
NAVEEN LOHIYA
PAN:AHWPL2078C
|
|
ALLEGED FAILURE TO ENSURE PROPER CARE AND DUE DILIGENCE IN COMPLYING WITH CONCENTRATION NORMS AND SUBMITTED INACCURATE INFORMATION TO THE TRUSTEE IN COMPLIANCE TEST REPORT VIOLATING REGULATIONS 20(1), 20(5) AND CLAUSES 2(A) AND 2(C) OF CODE OF CONDUCT READ WITH REGULATION 15(1)(D)OF SEBI (ALTERNATIVE INVESTMENT FUNDS) REGULATIONS, 2012 IN MATTER OF IROHA EMERGING INDIA FUND
|
REACHED SETTLEMENT ( SETTLEMENT CHARGES RS.29,25,000 ALONG WITH OTHER ENTITIES/PERSONS VIDE CONSENT ORDER)
01-JUL-2025
|
|
| 84 |
|
|
ISF SPECIAL OPPORTUNITY FUND
|
|
|
DID NOT FILE QUARTERLY ACTIVITY REPORTS (QARS) ON SEBI INTERMEDIARY PORTAL
|
CANCELLED REGISTRATION AS ALTERNATE INVESTMENT FUND
03-JUN-2026
|
|
| 85 |
|
|
KAE CAPITAL FUND II
(PAN:AACTK5644C)
(Along with : KAE CAPITAL MANAGEMENT PVT.LTD.)
|
|
|
|
SASHA GULU MIRCHANDANI
PAN:AACPM1608G
|
|
ALLEGED FAILURE IN MAINTAINING MINIMUM CONTINUING INTEREST IN FUND VIOLATING REGULATIONS 10(D) READ WITH 20(1)AND CLAUSE 1(E) OF CODE OF CONDUCT AS MENTIONED IN FOURTH SCHEDULE OF SEBI (ALTERNATIVE INVESTMENT FUNDS) REGULATIONS, 2012
|
REACHED SETTLEMENT (SETTLEMENT CHARGES RS.12,75,000 ALONG WITH OTHER ENTITIES/PERSONS VIDE CONSENT ORDER)
04-JUN-2026
|
|
| 86 |
|
|
KAE CAPITAL MANAGEMENT PVT.LTD.
(PAN:AAGCM3183K)
(Along with : KAE CAPITAL FUND II)
|
|
|
|
SASHA GULU MIRCHANDANI
PAN:AACPM1608G
|
|
ALLEGED FAILURE TO ENSURE COMPLIANCE WITH MINIMUM CONTINUING INTEREST REQUIREMENT IN FUND VIOLATING REGULATIONS 20(1) READ WITH CLAUSES 2(A) AND 2(C) OF CODE OF CONDUCT IN FOURTH SCHEDULE OF SEBI (ALTERNATIVE INVESTMENT FUNDS) REGULATIONS, 2012
|
REACHED SETTLEMENT (SETTLEMENT CHARGES RS.12,75,000 ALONG WITH OTHER ENTITIES/PERSONS VIDE CONSENT ORDER)
04-JUN-2026
|
|
| 87 |
|
|
KARVY CAPITAL ALTERNATIVE INVESTMENT TRUST
(PAN:AACTK1328H)
|
|
|
DID NOT SATISFY ‘FIT AND PROPER PERSON’ CRITERIA FOR GRANT OF REGISTRATION AS ALTERNATIVE INVESTMENT FUNDS VIOLATING REGULATIONS 4(F),7(1)(A) AND 35 OF SEBI (ALTERNATE INVESTMENT FUNDS) REGULATIONS, 2012 READ WITH REGULATION 9, CLAUSES 2, 3, 6 AND 7 OF SCHEDULE II OF SEBI (INTERMEDIARIES) REGULATIONS, 2008
|
CANCELLED REGISTRATION AS ALTERNATE INVESTMENT FUND FROM 25-MAR-2025
25-MAR-2025
|
|
| 88 |
|
|
KCAP ALTERNATIVE INVESTMENT FUND
(PAN:AADTK7212M)
|
|
|
DID NOT SATISFY ‘FIT AND PROPER PERSON’ CRITERIA FOR GRANT OF REGISTRATION AS ALTERNATIVE INVESTMENT FUNDS VIOLATING REGULATIONS 4(F),7(1)(A) AND 35 OF SEBI (ALTERNATE INVESTMENT FUNDS) REGULATIONS, 2012 READ WITH REGULATION 9, CLAUSES 2, 3, 6 AND 7 OF SCHEDULE II OF SEBI (INTERMEDIARIES) REGULATIONS, 2008
|
CANCELLED REGISTRATION AS ALTERNATE INVESTMENT FUND FROM 25-MAR-2025
25-MAR-2025
|
|
| 89 |
|
|
KELLYGAMMA ADVISORS LLP
(PAN:AAOFK7796F)
|
|
|
|
SHARVIL PARIKH
PAN:AMNPP9971C
|
|
INVESTED UN-INVESTED PORTION OF INVESTIBLE FUNDS IN LOW DURATION FUNDS INSTEAD OF LIQUID FUNDS
INVESTED MORE THAN 10% OF TOTAL INVESTIBLE FUNDS COLLECTED FROM INVESTORS IN A SINGLE INVESTEE COMPANY
DID NOT COMPUTE AND COMMUNICATE NAV TO INVESTORS
DID NOT FILE QUARTERLY REPORTS TO SEBI
SUBMITTED INCORRECT INFORMATION IN COMPLIANCE TEST REPORT (CTR)
|
IMPOSED PENALTY RS.1,00,000
28-FEB-2025
|
|
| 90 |
|
|
KELLYGAMMA FUND
(PAN:AACTK7280Q)
|
|
|
|
SHARVIL PARIKH
PAN:AMNPP9971C
|
|
INVESTED UN-INVESTED PORTION OF INVESTIBLE FUNDS IN LOW DURATION FUNDS INSTEAD OF LIQUID FUNDS
INVESTED MORE THAN 10% OF TOTAL INVESTIBLE FUNDS COLLECTED FROM INVESTORS IN A SINGLE INVESTEE COMPANY
DID NOT COMPUTE AND COMMUNICATE NAV TO INVESTORS
DID NOT FILE QUARTERLY REPORTS TO SEBI
SUBMITTED INCORRECT INFORMATION IN COMPLIANCE TEST REPORT (CTR)
|
IMPOSED PENALTY RS.5,00,000
28-FEB-2025
|
|
| 91 |
|
|
KOTAK ALTERNATE ASSET MANAGERS LTD.
(PAN:AAACK5933H)
|
|
|
|
GAURAV AGGARWAL
PAN:BHUPA5595E
|
|
|
PARAG SUKHIJA
PAN:DDDPS8579F
|
|
|
SHOBHIT MATHUR
PAN:ANRPM0696C
|
|
ALLEGED VIOLATION OF CONCENTRATION LIMIT OF 10% OF INVESTABLE FUNDS IN A SINGLE INVESTEE COMPANY
|
REACHED SETTLEMENT ( SETTLEMENT CHARGES RS.7,87,500 ALONG WITH OTHER ENTITIES/PERSONS VIDE CONSENT ORDER)
30-JAN-2024
|
|
| 92 |
|
|
KOTAK ALTERNATE ASSET MANAGERS LTD.
(PAN:AAACK5933H)
|
|
|
DID NOT WINDUP SCHEME UPON COMPLETION OF TENURE AS DISCLOSED IN ORIGINAL PRIVATE PLACEMENT MEMORANDUM VIOLATING REGULATION 23(1)(A) OF SEBI (VENTURE CAPITAL FUNDS) REGULATIONS, 1996 READ WITH REGULATION 39 OF SEBI (ALTERNATIVE INVESTMENT FUNDS) REGULATIONS, 2012
|
IMPOSED PENALTY RS.3,00,000 ALONG WITH OTHER ENTITIES/PERSONS
21-FEB-2024
|
SAT: SAT VIDE ITS ORDER DATED 25/04/2024ALLOWED SEBI THREE WEEKS TO FILE REPLY AND APPELLANTS TO FILE REJOINDER THREE WEEKS THEREAFTER
SAT: SAT VIDE ITS ORDER DATED 27/04/2026 DISMISSED THE APPEAL AS WITHDRAWN. NO COSTS
|
| 93 |
|
|
KOTAK ALTERNATE ASSETS FUND III
(PAN:AADTK5968J)
|
|
|
|
GAURAV AGGARWAL
PAN:BHUPA5595E
|
|
|
PARAG SUKHIJA
PAN:DDDPS8579F
|
|
|
SHOBHIT MATHUR
PAN:ANRPM0696C
|
|
ALLEGED VIOLATION OF CONCENTRATION LIMIT OF 10% OF INVESTABLE FUNDS IN A SINGLE INVESTEE COMPANY
|
REACHED SETTLEMENT ( SETTLEMENT CHARGES RS.7,87,500 ALONG WITH OTHER ENTITIES/PERSONS VIDE CONSENT ORDER)
30-JAN-2024
|
|
| 94 |
|
|
KOTAK MAHINDRA TRUSTEESHIP SERVICES LTD.
(PAN:AABCK4227B)
|
|
|
DID NOT WINDUP SCHEME UPON COMPLETION OF TENURE AS DISCLOSED IN ORIGINAL PRIVATE PLACEMENT MEMORANDUM VIOLATING REGULATION 23(1)(A) OF SEBI (VENTURE CAPITAL FUNDS) REGULATIONS, 1996 READ WITH REGULATION 39 OF SEBI (ALTERNATIVE INVESTMENT FUNDS) REGULATIONS, 2012
|
IMPOSED PENALTY RS.3,00,000 ALONG WITH OTHER ENTITIES/PERSONS
21-FEB-2024
|
SAT: SAT VIDE ITS ORDER DATED 25/04/2024ALLOWED SEBI THREE WEEKS TO FILE REPLY AND APPELLANTS TO FILE REJOINDER THREE WEEKS THEREAFTER
SAT: SAT VIDE ITS ORDER DATED 27/04/2026 DISMISSED THE APPEAL AS WITHDRAWN. NO COSTS
|
| 95 |
|
|
KOTAK SEAF INDIA FUND
(PAN:AAATK8360K)
|
|
|
DID NOT WINDUP SCHEME UPON COMPLETION OF TENURE AS DISCLOSED IN ORIGINAL PRIVATE PLACEMENT MEMORANDUM VIOLATING REGULATION 23(1)(A) OF SEBI (VENTURE CAPITAL FUNDS) REGULATIONS, 1996 READ WITH REGULATION 39 OF SEBI (ALTERNATIVE INVESTMENT FUNDS) REGULATIONS, 2012
|
IMPOSED PENALTY RS.3,00,000 ALONG WITH OTHER ENTITIES/PERSONS
21-FEB-2024
|
SAT: SAT VIDE ITS ORDER DATED 25/04/2024ALLOWED SEBI THREE WEEKS TO FILE REPLY AND APPELLANTS TO FILE REJOINDER THREE WEEKS THEREAFTER
SAT: SAT VIDE ITS ORDER DATED 27/04/2026 DISMISSED THE APPEAL AS WITHDRAWN. NO COSTS
|
| 96 |
|
|
LANDMARK CAPITAL ADVISORS PVT.LTD.
(PAN:AACCL4482A)
|
|
|
|
ASHISH KUMAR JOSHI
PAN:AAFPJ2088L
|
|
DID NOT DISCHARGE DUTY AS FUND MANAGER VIOLATING REGULATIONS 15(1)(C), 20(1), 20(2) AND 20(5) READ WITH CLAUSES 2(A), 2(C) AND 2(D) OF CODE OF CONDUCT SPECIFIED IN FOURTH SCHEDULE OF SEBI (ALTERNATIVE INVESTMENT FUNDS) REGULATIONS, 2012
|
IMPOSED PENALTY RS.3,00,000
26-AUG-2025
|
|
| 97 |
|
|
LANDMARK OPPORTUNITY FUND
(PAN:AABTL1214A)
|
|
|
INVESTED MORE THAN 25% OF INVESTIBLE FUNDS IN A SINGLE INVESTEE COMPANY
|
IMPOSED PENALTY RS.5,00,000
26-AUG-2025
|
|
| 98 |
|
|
LARES ALPHA SCHEME
|
|
|
DID NOT FILE QUARTERLY ACTIVITY REPORTS (QARS) ON SEBI INTERMEDIARY PORTAL
|
CANCELLED REGISTRATION AS ALTERNATE INVESTMENT FUND
08-JUN-2026
|
|
| 99 |
|
|
LEVERAGE INVESTMENT ADVISOR PVT.LTD.
|
|
|
DID NOT FILE QUARTERLY REPORTS TO SEBI
|
IMPOSED PENALTY RS.1,00,000
30-SEP-2022
|
|
| 100 |
|
|
MODULUS ALTERNATIVES INVESTMENT MANAGERS LTD.
(PAN:AAHCC9755G)
|
|
|
ALLEGED FAILURE IN MAINTAINING CONTINUING INTEREST CRITERIA VIOLATING REGULATIONS 10(D) OF SEBI (ALTERNATIVE INVESTMENT FUNDS) REGULATIONS, 2012 READ WITH CLAUSE 11.1.2 OF MASTER CIRCULAR DATED 07/05/2024
|
REACHED SETTLEMENT (SETTLEMENT CHARGES RS.10,87,500 VIDE CONSENT ORDER)
30-JUL-2026
|
|
| The regulatory charges/regulatory actions may be fully or partly applicable to the entities/persons mentioned in the second column. |
| |
|
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| Page 5 of 8
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