SEBI v. Eden Infrasmith Pvt Ltd and others (Funny Software Ltd, matched trades, 2023)

Judgment entered

✓ Checked against the primary document on October 8, 2026. The library's summary, tags and figures for this record were compared with the regulator's own document by an AI model (Claude) following written instructions, in a single reading of the order; an independent second reading of 60 SEBI records agreed on every field for 56, the four misses being penalty amounts; a later sample of 50 of the SEBI records added on 9 October agreed on every field for 46. No lawyer has reviewed them. A checked record can still contain errors, and checked does not mean endorsed. See how we check records or report a correction.

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In April 2023 a SEBI adjudicating officer found that a group of connected entities traded among themselves in Funny Software Ltd shares to create artificial volume, lift the price and help two of them exit. Eight entities were fined Rs 46 lakh in total; the case against a ninth, a struck-off company, was abated.

The record

What was ordered

Civil penalty

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Disgorgement

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Prejudgment interest

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Total relief

—

Alleged gain

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Penalty as published

4.6m INR

A dash means the release did not state a figure we could extract, not that the figure is zero. Penalty and disgorgement are stored separately so aggregates across the library do not double-count the same dollars. This regulator states penalties in INR. The figure is recorded as published and is not converted, so it does not appear in the USD totals or medians used elsewhere on this site.

What is alleged to have happened

This adjudication order was issued on 28 April 2023 by Vijayant Kumar Verma, a SEBI adjudicating officer. It covers nine corporate noticees, led by Eden Infrasmith Pvt Ltd, and concerns trading in the shares of Funny Software Ltd, a company listed on BSE that moved from the SME segment to the main board in July 2017.

SEBI's examination followed complaints about SMS messages urging purchases of the stock with a target price and a claim that a large technology company would acquire it. The investigation period ran from April 2017 to February 2018 and was split into five patches by price and volume. SEBI alleged that connected entities used synchronised and matched trades with each other to push up the last traded price and volumes, and that in later patches several connected entities bought from two other noticees who were selling heavily, giving them an exit.

The adjudicating officer concluded that three noticees created a false and misleading appearance of trading and contributed to price rises in the early patches, and that the scheme of providing an exit through coordinated buy orders on the days the two sellers entered large sell orders involved all nine noticees. The order says the timing could not be coincidence and indicated a meeting of minds. It found breaches of section 12A(a), (b) and (c) of the SEBI Act and the PFUTP Regulations.

One noticee, Meticulous IT Solutions, had been struck off the register of companies, and the proceedings against it were abated with no penalty. The other eight were fined under section 15HA: Rs 5 lakh each for Eden Infrasmith, Wave Mercantile, Ninja Healthcare, Gracious Software and Madhuban Constructions, and Rs 7 lakh each for Sungar Textiles, Saras Developers and Skynet Solutions, which had prior penalties for similar conduct. The total is Rs 46 lakh.

The show cause notice did not quantify any gain or investor loss, and the order records that no assessment was possible. No market bar or disgorgement was ordered. The record does not show whether the noticees appealed or paid, who sent the SMS messages, or any criminal case.

This library tags the matter as matched orders, with price manipulation. The tagging is ours, not the regulator's.

For the regulator's own account of the facts, read the primary document linked above. This page deliberately summarises the structured record rather than reproducing the order.

What technique is this, and how does it work?

This action is tagged with 2 techniques in our taxonomy. The tagging is ours: regulators charge statutory provisions, not technique names, so the mapping is an editorial judgement described in our editorial policy.

• Matched orders — see how it works, what statute it engages, and every other action tagged the same way.
• Price manipulation — see how it works, what statute it engages, and every other action tagged the same way.

Timeline

1. 2023-04-28 SEBI order

Primary documents

Everything on this page derives from the documents below. Where our summary and the primary document disagree, the primary document is right.

• SEBI order
• Order (PDF)

The linked release is published by the issuing regulator under its own terms. Our summary and narrative above are our own writing.

Related actions

Other actions in the library sharing at least one technique tag with this one.

Record added October 8, 2026. submit a correction.