19thAugust 2023

Shri. Amit Kapoor

General Manager & Adjudicating Officer
Securities and Exchange Board of India (SEBI)
SEBI Bhawan, Plot No. C4-A,
“G” Block, Bandra Kurla Complex,
Bandra (E), Mumbai-400051.

Sub: Submission of Settlement Application under SEBI (Settlement Proceedings) Regulations,

2018

Dear Sir/Madam

Securities and Exchange Board of India (SEBI) had vide Letter No. EAD-6/ADJ/AK/AJ/OW/
25378/1-6/2023 dated 21stJune, 2023 had issued a Show Cause Notice to IIFCL Asset Management
Company Limited (IAMCL) and four past key employees viz. Sh. Emandi Sankara Rao (ex-CEO), Sh.
Prasanna Prakash Panda (ex-CIO), Sh. Anil Kumar Taneja (ex-CEO) and Sh. Sumiran Bansal (ex-CFO)
under Rule 4(1) of the Securities And Exchange Board Of India (Procedure for Holding Inquiry and
Imposing Penalties) Rules, 1995 read with Section 19 and Section 15-1 of the Securities and Exchange
Board of India Act, 1992.

A detailed pointwise submission against the SEBI Show Cause Notice was submitted by the undersigned
to SEBI already. In the said response, I also stated that we intend to submit a separate “Settlement
Application” under SEBI (Settlement Proceedings) Regulations, 2018.

Accordingly, enclosed herewith the Settlement Application in prescribed format along with the requisite
enclosures.

The application along with annexures has been duly uploaded on SEBI’s Settlement Portal with payment
of requisite fees.

Thanking You,

Yours faithfully

Applicant

Encls. Settlement Applicationwith Annexures and proof of payment

 Part-A
FORM

Application for settlement

(To be filed only after conclusion of investigation, inspection, inquiry or audit, as the case may be)

(For Office use only)

Date of receipt of the application:
Application Registration Number:

(Instructions: All particulars, including submission regarding details of loss caused to investors, profit made and
proposed settlement amount must be filled, else application shall be returned. Put ‘NA’ only where NOT
APPLICABLE)

Before the Securities and Exchange Board of India

In the matter of SCN Ref: EAD-6/ADJ/AK/AJ/OW/25500/1/2023 dated June 21, 2023

1. Name/Trade name of the applicant/co-applicants : Sumiran Bansal

(a) Registration no., if applicable : NA
(b) Date of Registration, if applicable : NA
(c) PAN/DIN/CIN number, as available : ADKPB6803F
(d) Paid-up capital of applicant : NA
2. If stock broker, name of the stock exchange : NA
3. If sub-broker/authorised person, name of stock broker with whom affiliated and name of the stock exchange
: NA
4. Name of the segment (Cash/derivative etc.) : NA
5. Form of organization: corporate body/ sole proprietorship / partnership / LLP/ financial institution (if listed co.,
details of listing) : NA
6. Names of promoters/directors/proprietors/partners : NA
7. Key management personnel(s) : NA
8. Address/correspondence address, contact no./fax no. and email (any changes in aforesaid details shall be
communicated to the Board promptly) : O 1902, Amrapali Sapphire Phase 2, Sector
45, Noida UP – 201301 Email- sumiran.bansal@gmail.com, Mobile:9821165682
9. Name and contact details (including e-mail) of the contact person (s) : Same as above
10. Other registration(s) with the Board, if applicable : NA
(a) Trade name ’
(b) Registration type :
(c) Registration no. .
11. Case(s) pending with the Board/SAT/Court (Pl. specify) : No
12. Case(s) pending under 11B/Adjudication/Enquiry/others (pl. specify) : No
13. Stage at which pending [including details of hearing opportunity given by the Board or AO, if any] : No
14. Interim order(s) in the pending proceedings (gist of the orders passed), if any : No
15. Other actions pending with/concluded by the Board, if any (with their details) : No
(a) Against the applicant
(b) Against its associates
(c) Against its key management personnel(s) ’
(d) Against its other promoters/directors:
(e) Other details, if any:
16. Date of show cause notice/summons/communication indicating probable cause of action, if any, against which
the settlement is sought (PLEASE ENCLOSE COPIES )* : Show Cause Notice dated 21.06.2023 ref
EAD- 6/ADJ/AK/AJ/OW/25500/1/2023
Applicant submitted its response vide email dated 26.07.2023
17. Full and true disclosure of facts (including the loss caused, profit made, loss avoided, gross fees, brokerage,
commissions, etc., in respect of the cause of action, with manner of calculation thereof):
Factual Background:
a. The Notice has been issued against the Applicant and IAMCL and its Ex- employees namely Mr. Emandi
Samara Rao, Mr. Anil Kumar Taneja and Ms. Sumiran Bansal (collectively referred to as the “Noticees”).
b. The Notice was issued pursuant to the inspection carried out by the Board for the period 2014-2022.
c. As per the Notice, the Noticees have allegedly violated Regulations 25(2), 25(3), 25(6), 25(6A), 25(6B)
and 49R(2) of the MF Regulations. The details of the alleged non-compliances are mentioned at
paragraphs 5 (including 5.7. to 5.4) and 6 (fncltlding 6.1 to 6.4) of the Notice.
d. The Applicant, vide its email dated 26" July 2023, has submitted a detailed pointwise response to all the
observations/allegations made by SEBI in the Notice.
e. Further, details of the “Submissions” made by IAMCL , in its Settlement application (Form A) may be
considered
f. settlement of the Contravention:
g. It is most respectfully submitted that the Applicant has always acted in a bona fide manner. The alleged
deficiencies mentioned in the Notice did not impact the interests of the investors, and did not contribute
to any adverse effect on the securities market.
h. In view of the above, and in order to resolve the matter expeditiously, I request SEBI to settle the issues.
Request for Confidentiality
i. Please note that the details set out in this application and submissions made to SEBI in relation to this
matter contain proprietary information about the Applicant. Disclosure or release of these details to the
public would cause grave prejudice to the Applicant.
j. I therefore, request SEBI to kindly accord full confidentiality to the contents of this application, including
in the settlement order that the SEBI is pleased to pass in the matter.
18. Specific charges alleged:
The Notice alleges that Applicant has violated Regulations 25(2), 25(3), 25(6), 25(6A), 25(6B) and 49R(2) of
SEBI (Mutual Fund) Regulations, 1996 (“MF Regulations”).

19. Submissions in respect of sub-regulations (2), (3) & (4) of Regulation 5:

(i) The deficiencies alleged in the Notice: (a) did not have any market wide impact; (b) have not affected the
interests of the investors; and (c) have not affected the integrity of the market.
(ii) The Applicant is neither a willful defaulter nor a fugitive economic offender and has not defaulted in
payment of any fees due or penalty imposed under securities laws.

20. Terms of settlement proposed by the Applicant:-

(a) Monetary terms, with manner of calculation:-
(b) Non-monetary terms, including manner of calculation of terms of disgorgement due:-

In the instant case, there are a number of factors which merit consideration which are inter alia as under:
a. The alleged deficiencies mentioned in the Notice did not have any impact on the interest of investors.
b. This has been the first and only instance where SEBI has i5sued a show cause notice against the
Applicant.
c. In view of the above facts and circumstances read in conjunction with SEBI’s powers under Paragraph 9,
Chapter I, Schedule II of the Settlement Regulations, without admission or liability of guilt, the Applicant
proposes to settle the matter as per the Settlement Regulations pursuant to the deliberations at the Internal
Committee Meeting.

21. Original documents to be enclosed:

(a) Undertakings and waivers (as per Format specified in Part C). Enclosed
(b) Authority letter/Board resolution.
22. List of other enclosures:
(a) A copy of the notice to show cause/ summons/ communication/ other notices indicating the probable
cause of action, if any, against which the settlement is sought; Enclosed
(b) Complete Annual Reports / other relevant financial details for the last three Financial years and the
quarterly audited financial results of the current year;
(c) A statement showing net worth of the applicant (only for those applicants who are required to comply
with the networth requirements as specified by the Board or by the stock exchanges), gross annual
income before tax, the amount of gross profit made/loss avoided, including the gross brokerage, fees,
management/ performance /transaction fee, carried interest, compensation, etc., in respect of the said
default;
(d) Copy of PAN card/ DIN/CIN details; Enclosed
 (e) Complete Income-tax Returns of the applicant for the last three financial years; Enclosed
(f) In case of a foreign body corporate applicant, include details relating to incorporation, place of
business, registration details with any non-Indian financial sector regulatory authority.
(g) In case of a non-resident applicant, include details relating to passport and national identity document, if
any.
(h) Any other relevant document (s)/submissions.

(Sumiran Bansal)

Verification

I, SUMIRAN BANSAL, son of Shri RAMAVATAR BANSAL, being the applicant do hereby verify and affirm
on oath that this application and the contents thereof are true to my knowledge and belief and as per the records
and that I have not suppressed any material facts and shall keep the Board informed without delay, of any other
relevant information that may come to my notice.

(Sumiran Bansal)
Date : 19.08.23
Place : Delhi