Adjudication Order Against Against Splash Media & Infra Ltd. in The Matter of Proposed Rights Issue of Splash Media & Infra Ltd.

BEFORE THE ADJUDICATING OFFICER
SECURITIES AND EXCHANGE BOARD OF INDIA

[ADJUDICATION ORDER NO. ASK/AO/115/2014-15]
UNDER SECTION 15-I OF SECURITIES AND EXCHANGE BOARD OF INDIA
ACT, 1992 READ WITH RULE 5 OF SEBI (PROCEDURE FOR HOLDING
INQUIRY AND IMPOSING PENALTIES BY ADJUDICATING OFFICER)
RULES, 1995
In respect of
Splash Media and Infra Limited
(PAN: AAACH2735G)
In the matter of
Proposed Rights Issue of Splash Media and Infra Limited
BACKGROUND IN BRIEF
1. Securities and Exchange Board of India (SEBI) conducted investigation in the
Proposed Rights Issue of Splash Media and Infra Limited (SMIL/Noticee) on observing
certain irregularities and inconsistencies in the Draft Letter of Offer (DLO) dated
December 17, 2010 filed by Noticee with SEBI through Khandwala Securities Limited
(KSL). The period of investigation was from April 01, 2010 to December 17, 2010.
2. It was observed that Noticee was originally incorporated on July 7, 1981 in the name
of Indus Commercial Limited as a public limited company under the Companies Act,
1956. The name of the Company was changed to Hindustan Stockland Limited and
further changed to Splash Mediaworks Limited. Again its name was changed to
Splash Media & Infra Limited vide a fresh certificate of incorporation consequent to
name change dated November 9, 2009. Investigation revealed that Noticee had failed to
ensure that atleast 50% of its total income in the preceding year of name change were
from new activity i.e. from infrastructure. Therefore, it was alleged that Noticee had
Adjudication order against SMIL in the matter of proposed Rights Issue of Splash Media and Infra Ltd. Page 1 of 14
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failed to comply with Clause 32 of Listing Agreement read with Section 21 of the
Securities Contract (Regulations) Act, 1956 {(hereinafter referred to as SC(R) Act)},
which required that at least 50% of the total revenue in the preceding one year period
should have been accounted for by the new activity suggested by the new name.
3. It was further observed that Noticee did not disclose in the DLO the material
information regarding the fact that its project Krishna Marvel for which Noticee had
proposed to use the proceeds of Rights Issue was under dispute despite the said fact
being known to it. Therefore, it was alleged that the Noticee violated Regulation 57(1)
of Securities and Exchange Board of India (Issue of Capital and Disclosure
Requirements) Regulations, 2009 (hereinafter referred to as ICDR Regulations,)
regarding material disclosures in offer document and Clause IV(B) of Part A of
Schedule VIII read with Regulation 57(2)(a)(ii) of ICDR Regulations, 2009.
4. Investigation further revealed that as per the disclosures made by the Noticee in DLO,
Sukusama Trades and Investments Private Ltd (STIP) was a related party of Noticee as
on September 30, 2010 and that no related party transaction had taken place between
STIP and Noticee. However, from the ledger statements of STIP for the period of April
1, 2010 to March 31, 2011, it was observed that during the period April-September
2010, Noticee had paid a total of ` 3.01 crore to STIP in three different transactions
from July 14, 2010 to August 07, 2010 and it received only ` 20 lakh on September 28,
2010. Thus, as at the end of September 2010, Noticee was to receive ` 2.81 crore back
from STIP. However, no disclosure regarding the said fact was made in DLO by the
Noticee. Therefore, it was alleged that Noticee violated Clause IX(B)(12)(a) of Part A of
Schedule VIII read with Regulation 57(2)(a)(ii) of ICDR Regulations, 2009.
5. It was further observed that as per the DLO the Noticee had a turnover of ` 26.68
crore for the six month period of April-September 2010. However, as per form No. 231
of MVAT returns dated April 29, 2011 filed by Noticee for the period of April 1, 2010
to September 30, 2010, the gross turnover was more than ` 30 crore for trades in tiles.
Thus it was observed that Noticee had not disclosed the actual turnover in its books of
account for the six month period of April-September 2010. Further, while Noticee had
booked profits of ` 7.66 lakh by such trades in tiles and showed the same in the
Statement of Profit and Loss Account, it did not show the turnover of the tiles traded by
it in its Statement of Profit and Loss Account as stipulated by IX(B)(10) of Part A of
Schedule VIII of ICDR Regulations, 2009. Therefore, it was alleged that Noticee has
violated Clause IX(B)(10) of Part A of Schedule VIII read with Regulation 57(2)(a)(ii)
of ICDR Regulations, 2009.
APPOINTMENT OF ADJUDICATING OFFICER
6. Shri Piyoosh Gupta was appointed as Adjudicating Officer vide order dated April 3,
2013 to inquire and adjudge under section 15HB of the Securities and Exchange Board
of India Act, 1992 (hereinafter referred to as SEBI Act) and under section 23E of
SC(R) Act, the alleged violations of provisions of Clause IV(B), Clause IX(B)(10) and
Clause IX(B)(12)(a) of Part A of Schedule VIII read with Regulation 57(2)(a)(ii) of
ICDR Regulations, 2009; Regulation 57(1) of ICDR Regulations, 2009 and and Clause
32 of the Listing Agreement read with Section 21 of SC(R) Act by the Noticee.
Subsequently, upon the transfer of Shri Piyoosh Gupta, I have been appointed as
Adjudicating Officer, in the present matter, vide order dated November 08, 2013.
SHOW CAUSE NOTICE, REPLY AND HEARING
7. Show Cause Notice dated July 31, 2014 (herein after referred to as SCN) was
issued to the Noticee under rule 4 of SEBI (Procedure for Holding Inquiry and imposing
penalties by Adjudicating Officer) Rules, 1995 (hereinafter referred to as Rules) to
show cause as to why an inquiry should not be held against it in terms of rule 4 of the
Rules read with section 15I of SEBI Act, 1992 and in terms of Rule 4 of Securities
Contracts (Regulation) (Procedure for Holding Inquiry and Imposing Penalties by

Adjudicating Officer) Rules, 2005 read with section 23I of SC(R) Act, 1956 for the
violations specified in the SCN. The copies of the documents relied upon in the SCN
were provided to the Noticee along with the SCN.
8. Noticee vide letters dated October 07, 2014 and December 04, 2014 replied to the SCN
and made the following submissions:
The company changed its name from 'Splash Mediaworks Limited' to 'Splash
Media & Infra Limited' around November 2009 and we were carrying out both the
activities. Both are new activities as far as Clause 32 is concerned. As we were
carrying out diversified activities, one activity will contribute more as compared
to other and it is not possible that each activity contributes more than 50% of the
total revenue. The revenue of the same was booked as per provisions contained in
Accounting Standard 7(AS7) on Constructions Contract issued by Institute of
Chartered Accountants of India. As per para 34 of AS7, "When the uncertainties
that prevented the outcome of the contract being estimated reliably no longer
exist, revenue and expenses associated with the construction contract should be
recognized in accordance with paragraph 21 rather than in accordance with
paragraph 31". Para 21 of AS7 states that when the outcome of a construction
contract can be estimated reliably, contract revenue and contract costs associated
with construction contracts should be recognized as revenue and expenses
respectively by reference to the stage of completion of the contract activity at the
reporting date. The contract that we received from Delta Telecom (India) Ltd. was
a fixed price contract and para 22 specifies the conditions which a fixed price
contract need to satisfy to reliably estimate the outcome of construction contract.
In our opinion and in the opinion of the Company Secretary, who certified the
same, the contract was a fixed price contract and accordingly the full revenue
accrued from the contract was recognized at the reporting date. However, due to
unforeseen circumstances, the said contract was cancelled and accordingly the
revenue recognized in the books of accounts was reversed.
As regards the circumstances for cancellation of contract, we would like to bring
to your kind notice that in December 2009, we were informed by Delta that said
contract has been cancelled. We would like to clarify that Delta received the
contract from Suzlon Infrastructure Services Ltd. and sub contracted a portion of
the same to us. We received the contract in October 2009 which was cancelled in
December 2009. When we received the contract, we accounted for the entire
income and when the contract was cancelled in December 2009, we reversed the
entire income. Hence, there was no effect of the same in the financial statements of
Splash. In view of the above submissions, we reiterate and deny that we have
violated Clause 32 of Listing Agreement read with Section 21 of SC(R) Act, 1956.
Suit No. 6671 of 1999 has not been filed against us or our directors or in respect
of the property owned by the Company. The suit has been filed by one Shree
Bhanbhai Nenshi Mahila Vidayalay against Krishna developers. Furthermore, as
per the certificate given by Advocate Sanjeev R Singh, the suit is in respect of Plot
A/2 admeasuring 3,939.80 sq mts of CTS 484 whereas the company has acquired
development rights in respect of 8,287 sq mts in Plot Nos CTS no. 455, 464 (Part)
and 484(Part) except property bearing CTS No. 484 Plot A/2. Therefore, the said
Suit No. 6671 of 1999 before the Bombay High Court did not affect the
development rights acquired by SMIL and hence the same was not required to be
disclosed in the DLO.
The details of related party transactions are clearly disclosed in a table at page 98
of DLO under the heading Statement of Related Party Transactions. STIP had
plans to carry out some investment and in view of the same SMIL subscribed to
equity shares of STIP and paid them share application money. However, when
STIP dropped the plans to carry out the proposed investment, they refunded ` 20
lakh to SMIL. It has been disclosed on page 99 of the DLO that share application
money of ` 281 lakh has been advanced to an Associate (as mentioned in the DLO,
STIP was the only associate of the company.) Hence, the allegation that SMIL
has not disclosed the same in the DLO is erroneous.
Trading in Tiles is not the main business activity of the company and not part of its
operations and was a one time activity to avoid loss. As per the accounting
practices followed at the relevant time and to show a true and correct view of the
financial statements to our shareholders, only profit from sale of tiles were
included in the Profit and Loss account. If SMIL had shown the full sale of tiles in
the DLO, it would have given a misleading figure of turnover of the company since
the sale of tiles is not part of the main operations of the company and was only a
one time activity and not part of the operations of the company.
DLO was dated December 17, 2010 whereas the MVAT return was the revised
return as filed by SMIL in April 2011. Further, sales figure as disclosed in the
DLO was sales net of tax whereas the sales figures in its MVAT return is
gross sales inclusive of tax.
9. In the interest of natural justice and in order to conduct an inquiry in terms of rule
4(3) of the Rules, the Noticee was granted an opportunity of personal hearing on
November 21, 2014 at SEBI, Head Office, Mumbai, vide notice dated November 03,
2014. On the scheduled date of hearing Shri Joby Mathew, Advocate, appeared as
Authorised Representative (AR) on behalf of the Noticee and reiterated the submissions
made by the noticee in the reply to SCN. AR submitted that the DLO dated December
17, 2010 filed with SEBI through KSL in the matter of the Proposed Rights Issue of
SMIL was withdrawn and the Noticee did not go ahead with the Rights Issue. He further
submitted that the Whole Time Member, SEBI, vide order dated November 10, 2014 has
disposed of the similar violations alleged against the noticee arising out of the same
investigation as in the present matter.
CONSIDERATION OF ISSUES AND FINDINGS
10.
The issues that arise for consideration in the present case are :
a) Whether the Noticee had violated the provisions of Clause 32 of Listing

Agreement read with Section 21 of the SC(R) Act, 1956?
b) Whether the Noticee had violated the provisions of Clause IV(B), Clause
IX(B)(10) and Clause IX(B)(12)(a) of Part A of Schedule VIII read with
Regulation 57(2)(a)(ii) of ICDR Regulations, 2009; and Regulation 57(1) of
ICDR Regulations, 2009?
c) Does the violation, if any, on the part of the Noticee attract monetary penalty
under section 23E of SC(R) Act, 1956 and Section 15HB of SEBI Act?
d) If so, what would be the monetary penalty that can be imposed taking into
consideration the factors mentioned in Section 15J of SEBI Act or Section
23J of SC(R) Act, 1956?
11. Before moving forward, it is pertinent to refer to aforesaid provisions which at the
relevant period read as under:
Clause 32 of Listing Agreement
''If the company has changed its name suggesting any new line of business, it shall
disclose the net sales or income, expenditure and net profit or loss after tax figures
pertaining to the said new line of business separately in the financial results and shall
continue to make such disclosures for the three years from the date of change in name.
In addition to the above provisions, listed companies which decide to change their
names would be required to comply with the following conditions:
1...........................................
2.at least 50% of the total revenue in the preceding 1 year period should have been
accounted for by the new activity suggested by the new name.
3.................................................."
SC(R) Act, 1956
"Conditions for listing.
21. Where securities are listed on the application of any person in any recognised stock
exchange, such person shall comply with the conditions of the listing agreement with
that stock exchange."
Regulation 57 of SEBI (ICDR) Regulations) 2009
"Manner of disclosures in the offer document.
57. (1) The offer document shall contain all material disclosures which are true and
adequate so as to enable the applicants to take an informed investment decision.
(2) Without prejudice to the generality of sub-regulation (1):
(a) the red-herring prospectus, shelf prospectus and prospectus shall contain:
(i) ....................; and
(ii) the disclosures specified in Part A of Schedule VIII, subject to the provisions of Parts
B and C thereof.
Clause (IV) (B) of Part A of Schedule VIII of SEBI (ICDR) Regulations, 2009
Risk Factors:
"(A) ...................................
(B) The risk factors shall be classified as those which are specific to the project and
internal to the issuer and those which are external and beyond the control of the issuer."
Clause (IX)(B)(12)(a) of Part A of Schedule VIII :
"(12) Related Party Transactions: The issuer shall disclose the following details of
related party transactions and make disclosures in accordance with the requirements of
Accounting Standard (AS 18) Related Party Disclosures issued by the Institute of
Chartered Accountants of India:
(a) Information with respect to transactions or loans between the issuer and
(i) enterprises that directly or indirectly through one or more intermediaries, control or
are controlled by, or are under common control with, the issuer;
(ii) associates;
(iii) individuals owning, directly or indirectly, an interest in the voting power of the
company that gives them significant influence over the issuer, and close members of any
such individuals family;
(iv) key managerial personnel, that is, those persons having authority and responsibility
for planning, directing and controlling the activities of the issuer, including directors
and senior management of companies and close members of such individuals families;
(v) enterprises in which a substantial interest in the voting power is owned, directly or
indirectly, by any person described in (c) or (d) or over which such a person is able to
exercise significant influence and includes enterprises owned by directors or major
shareholders of the issuer."
Clause (IX)(B)(10) of Part A of Schedule VIII :
"(IX) Financial Statements: ............................
(B) Financial Information of the issuer:
.............................................
(10) The turnover disclosed in the Profit and Loss Statement shall be bifurcated into:
(a) turnover of products manufactured by the issuer;
(b) turnover of products traded in by the issuer; and
(c) turnover in respect of products not normally dealt in by the issuer but included in (b)
above, shall be mentioned separately.
FINDINGS
12. I have carefully considered the SCN issued to the noticee, their replies/submissions
and the relevant material available on record. Having considered the same, I record my
findings hereunder.
Issue I - Whether the Noticee had violated the provisions of Clause 32 of Listing
Agreement read with Section 21 of the SC(R) Act, 1956?
13. I note that Clause 32(2) of Listing Agreement requires that a listed company which
decide to change its name should ensure that at least 50% of its total revenue in the
preceding 1 year should have been accounted by the new activity suggested by the new
name. It is a matter of record that noticee changed its name from Splash Mediaworks
Limited to Splash Media & Infra Limited on November 9, 2009. Thus, as per Clause
32(2) of Listing Agreement, noticee should have ensured that 50% of its total revenue
during the one year period preceding November 9, 2009 should have been accounted by
the infrastructure activity, being the new activity as suggested by the new name. I note
that during the course of investigation, Noticee submitted that it had entered into a
construction contract in October 2009 with one of its clients for infrastructure work and
the revenue from the said contract was more than 50% of the total revenue of the
company and the said contract was cancelled in December 2009. Further, in the current
proceeding, noticee submitted that when it received the contract, it accounted for the
entire income and when the contract was cancelled they reversed the entire income and
accordingly there was no effect of the same in the financial statement of the noticee.
Noticee further submitted that the accounting treatment given to the contract was in
accordance with para 21-22 of AS7 that is given to such fixed price construction
contract.
14. In my view the limited question for determination here is that whether noticee was
right in accounting the construction contract the way it did or it was merely an attempt
on its part to bypass the requirement of Clause 32(2) of Listing Agreement. I note that
AS7 issued by ICAI, as cited by the Noticee, deals with accounting treatment for
allocation of cost and revenue in the case of construction contracts if initiation and
completion of contract fall in different accounting period. Noticee has submitted that the
contract was a fixed price contract. As per para 2.2 of AS7 " A fixed price contract is a
construction contract in which the contractor agrees to a fixed contract price, or a fixed
rate per unit of output, which in some cases is subject to cost escalation clauses." The
accounting treatment of revenue and expense recognition of construction contract is
described under Para 21- 22 of AS7 which reads as under:
"21. When the outcome of a construction contract can be estimated reliably, contract
revenue and contract costs associated with the construction contract should be
recognized as revenue and expenses respectively by reference to the stage of completion
of the contract activity at the reporting date. An expected loss on the construction
contract should be recognized as an expense immediately in accordance with paragraph
35.
22. In the case of a fixed price contract, the outcome of a construction contract can be
estimated reliably when all the following conditions are satisfied:

(a) total contract revenue can be measured reliably;
(b) it is probable that the economic benefits associated with the contract will flow to the
enterprise;
(c) both the contract costs to complete the contract and the stage of contract completion
at the reporting date can be measured reliably; and
(d) the contract costs attributable to the contract can be clearly identified and measured
reliably so that actual contract costs incurred can be compared with prior estimates."
15. Noticee has submitted that the revenue from the contract has been booked as per
para 21-22 of AS7. However, I note that para 21 of AS7 requires the recognition of
revenue and expenses by reference to stage of completion of the contract activity at the
reporting date. In the instant case, I note that the noticee has accounted the whole
contract value as revenue of the contract at one go itself without any reference to the
stage of completion. Moreover, there is no evidence on record to show that as on the
reporting date the cost attributable to the contract was identified or measured reliably by
the noticee. As per the noticee's own submission the contract was cancelled in December
2009 and the entire income was reversed implying that no work was done as regards that
contract. This leads to the conclusion that the stage of completion of the contract as on
the reporting date was zero and accordingly noticee could not have accounted for the
revenue of the contract in its accounts. I have, therefore, no hesitation to conclude that
Noticee had intentionally booked the amount of ` 1.08 crore as revenue from
infrastructure activity in a wrong manner mainly to circumvent the conditions prescribed
under Clause 32 of listing agreement. In view of the above, I hold that the noticee has
violated Clause 32 of Listing Agreement read with Section 21 of the SC(R) Act, 1956
Issue II - Whether the Noticee had violated the provisions of of Clause IV(B),
Clause IX(B)(10) and Clause IX(B)(12)(a) of Part A of Schedule VIII read with
Regulation 57(2)(a)(ii) of ICDR Regulations, 2009; and Regulation 57(1) of ICDR
Regulations, 2009?
16. Noticee has submitted that the DLO was withdrawn and it did not make its proposed
rights issue and the letter of offer was not issued to its shareholders. The Noticee has
brought to my attention the fact that Whole Time Member (WTM) of SEBI vide Order
dated November 10, 2014 (Said order) in a separate proceedings against the noticee and
its directors under sections 11(1), 11(4)(b) and 11B of SEBI Act, 1992 read with ICDR
Regulations, on the same set of facts and allegations, had exonerated them of the charges
leveled against them.
17. I note that in the said order, there was a specific finding that DLO was withdrawn by
KSL vide its letter dated May 23, 2013 and accordingly, SEBI did not issue any
observation on the said DLO and SMIL did not make the proposed rights issue. I further
note that in the said order the WTM has also recorded the finding that "The issues of
non-disclosures have remained academic particularly in view of the fact that no case of
any fraudulent device is made out in this case and that the rights issues was withdrawn
and letter of offer was not issued to the shareholders of SMIL." As regards the violation
of the provisions of Clause IV(B), Clause IX(B)(10) and Clause IX(B)(12)(a) of Part A
of Schedule VIII read with Regulation 57(2)(a)(ii) of ICDR Regulations, 2009; and
Regulation 57(1) of ICDR Regulations, 2009, the WTM SEBI has held that these
provisions are applicable in case of public issues and has disposed of the SCN without
issuing any directions under sections 11(1), 11(4)(b) and 11B of SEBI Act, 1992 read
with ICDR Regulations.
18. I have also gone through the charges leveled against the noticee in the SCN which
have arisen out of the certain non-disclosures / wrong disclosures contained in DLO
which was filed in respect of the proposed rights issue of SMIL. I find that these charges
leveled against the noticee are applicable to public issues whereas in the instant
proceedings, it is a case of proposed rights issue. Moreover, the DLO in respect of the
proposed Rights issue was withdrawn and Noticee did not make its proposed rights
issue. I am, therefore, of the view that the charges leveled against the noticee are not
tenable. The similar view was also taken by WTM SEBI in the said order and I do not
find any reason to disagree with the same.
19. In view of the foregoing, the alleged violations of the provisions of Clause IV(B),
Clause IX(B)(10) and Clause IX(B)(12)(a) of Part A of Schedule VIII read with
Regulation 57(2)(a)(ii) of ICDR Regulations, 2009; and Regulation 57(1) of ICDR
Regulations, 2009 by the Noticee do not stand established.
Issue III - Does the violation, if any, on the part of the Noticee attract monetary
penalty under section 23E of SC(R) Act, 1956 and Section 15HB of SEBI Act?
20. Since the allegation of violation of Clause IV(B), Clause IX(B)(10) and Clause
IX(B)(12)(a) of Part A of Schedule VIII read with Regulation 57(2)(a)(ii) of ICDR
Regulations, 2009; and Regulation 57(1) of ICDR Regulations, 2009 by the Noticee
could not be established, noticee is not liable for monetary penalty under section 15HB
of SEBI Act.
21. Since the violation of Clause 32 of Listing Agreement read with Section 21 of the
SC(R) Act, 1956 by the Noticee has been established, I hold that the Noticee is liable for
monetary penalty 23E of SC(R) Act, 1956, which reads as under:
"Penalty for failure to comply with provision of listing conditions or delisting
conditions or grounds.
23E. If a company or any person managing collective investment scheme or mutual
fund, fails to comply with the listing conditions or delisting conditions or grounds or
commits a breach thereof, it or he shall be liable to a penalty not exceeding twenty-five
crore rupees."
Issue - (IV) - If so, what would be the monetary penalty that can be imposed taking
into consideration the factors mentioned in section 15J of SEBI Act or Section 23 J
of SC(R) Act, 1956?
22. While determining the quantum of penalty under section 23E, it is important to
consider the factors stipulated in section 23J of SC(R) Act, 1956, which reads as
under:23J - Factors to be taken into account by the adjudicating officer
While adjudging quantum of penalty under section 23-I, the adjudicating officer shall
have due regard to the following factors, namely:Adjudication order against SMIL in the matter of proposed Rights Issue of Splash Media and Infra Ltd. Page 12 of 14
(a) the amount of disproportionate gain or unfair advantage, wherever quantifiable,

made as a result of the default;
(b) the amount of loss caused to an investor or group of investors as a result of the
default;
(c) the repetitive nature of the default.
23. From the material available on record, the amount of disproportionate gain or unfair
advantage to the Noticee or loss caused to the investors as a result of the default is
not quantifiable. Though it may not be possible to ascertain the monetary loss to the
investors on account of default by the Noticee, I cannot lose sight of the fact that the
Noticee has indulged in a dubious act to reflect a picture about its revenues, only to
give a false impression that it is in compliance with the conditions pre-requisite for
giving effect to the name change. In fact, this is nothing but a deliberate and willful
act on the part of the noticee to circumvent law and mislead the shareholders and the
investing public into believing that the company, with the changed name, is into a
new line of business as suggested by the new name. Therefore, it is necessary that a
justifiable penalty is imposed on the Noticee to meet the ends of justice.
ORDER
24.Therefore, in exercise of the powers conferred upon me under Section 23I (2) of the
SC(R) Act, 1956, I hereby impose a penalty of ` 5,00,000/- (Rupees Five Lakh only)
under Section 23E of SC(R) Act, 1956 for the violation of Clause 32 of Listing
Agreement read with Section 21 of the SC(R) Act, 1956 on the Noticee i.e. Splash
Media and Infra Limited. I am of the view that the said penalty is commensurate
with the violation committed by the Noticee.
25. The penalty shall be paid by the Noticee by way of demand draft in favour of SEBI
- Penalties Remittable to Government of India, payable at Mumbai, within 45 days
of receipt of this order. The said demand draft should be forwarded to The Division
Chief (Enforcement Department- DRA II), Securities and Exchange Board of India,
SEBI Bhavan, Plot No. C4 A, G Block, Bandra Kurla Complex, Bandra (E),
Mumbai 400 051.
26. In terms of rule 6 of the Rules, copies of this order are sent to the Noticee and also to
the Securities and Exchange Board of India.
Date: December 30, 2014

Place: Mumbai
A. Sunil Kumar
Adjudicating Officer

Adjudication Order Against Against Splash Media & Infra Ltd. in The Matter of Proposed Rights Issue of Splash Media & Infra Ltd.

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Adjudication Order Against Against Splash Media & Infra Ltd. in The Matter of Proposed Rights Issue of Splash Media & Infra Ltd.

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BEFORE THE ADJUDICATING OFFICER

SECURITIES AND EXCHANGE BOARD OF INDIA

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Contracts (Regulation) (Procedure for Holding Inquiry and Imposing Penalties by

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a) Whether the Noticee had violated the provisions of Clause 32 of Listing

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estimated reliably when all the following conditions are satisfied:

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(a) the amount of disproportionate gain or unfair advantage, wherever quantifiable,

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Date: December 30, 2014

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