Omaxe Limited & Others vs SEBI

IN THE SECURITIES APPELLATE TRIBUNAL
AT MUMBAI

ST
DATED THIS THE 1 DAY OF SEPTEMBER, 2026

CORAM: Justice P.S. Dinesh Kumar, Presiding Officer
Ms. Meera Swarup, Technical Member
Dr. Dheeraj Bhatnagar, Technical Member


Appeal No.568 of 2024
[Along with Misc. Application No.1296
of 2024]


1. Omaxe Limited
Shop No-19-B, First Floor,
Omaxe Celebration Mall,
Sohna Road, Gurgaon,
Haryana – 122001, India.

2. Rohtas Goel
Khaitan & Co., One Forbes
th
Building, A Wing, 4 Floor,
Dr. VB Gandhi Marg, Kala Ghoda,
Fort, Mumbai, Maharashtra 400001.

3. Mohit Goel
Khaitan & Co., One Forbes
th
Building, A Wing, 4 Floor,
Dr. VB Gandhi Marg, Kala Ghoda,
Fort, Mumbai, Maharashtra 400001.

4. Arun Kumar Pandey
Khaitan & Co., One Forbes
th
Building, A Wing, 4 Floor,
Dr. VB Gandhi Marg, Kala Ghoda,
Fort, Mumbai, Maharashtra 400001.

2


5. Vimal Gupta
Khaitan & Co., One Forbes
th
Building, A Wing, 4 Floor,
Dr. VB Gandhi Marg, Kala Ghoda,
Fort, Mumbai, Maharashtra 400001.





…..Appellants


(By Mr. Pradeep Sancheti, Senior Advocate with Mr. Tomu
Francis, Ms. Zarnaab Aswad, Mr. Apoorva Upadhyay and Mr.
Tarun Toprani, Advocates i/b. Khaitan & Co. for the
Appellants.)

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



…..Respondent
(By Mr. Suraj Chaudhary, Advocate with Mr. Ratan Sing, Mr.
Sagar Dhakane, Advocates i/b Agama Law Associates for

the Respondent.)


THIS APPEAL IS FILED UNDER SECTION 15T OF THE SEBI ACT,
1992 TO SET ASIDE THE ORDER DATED JULY 30, 2024 PASSED
BY THE AO, SEBI.


THIS APPEAL HAVING BEEN HEARD AND RESERVED FOR
ORDERS ON JULY 7, 2026 COMING ON FOR PRONOUNCEMENT
OF ORDER THIS DAY, THE TRIBUNAL MADE THE FOLLOWING:

3

ORDER

Per: Justice P.S. Dinesh Kumar, Presiding Officer




This appeal is directed against order dated 30.07.2024
1 2
passed by the CGM , SEBI restraining the appellants from
accessing the securities market for a period of two years,
prohibiting Noticee Nos.2 to 6 from holding any position as a
3
Director or KMP and imposing monetary penalties.

2. The impugned order is against 16 Noticees. This appeal is
filed by Noticee Nos.1, 2, 3, 5 and 6.

3. We have heard Mr. Pradeep Sancheti, learned Senior
Advocate for the appellants and Mr. Suraj Chaudhary, learned
Advocate for the SEBI.

4. Brief facts of the case are, first appellant, Omaxe Limited
(„Omaxe/Company‟ for short) is a listed company. Second
appellant, Rohtas Goel („Rohtas‟ for short) is its promoter,
Chairman and Non-Executive Director. Third appellant, Mohit
Goel („Mohit‟ for short) is its Managing Director. Fourth appellant,
Arun Kumar Pandey („Arun‟ for short) and fifth appellant Vimal
Gupta („Vimal‟ for short) who were Company‟s CFOs at different
times.


1
Chief General Manager
2
Securities and Exchange Board of India
3
Key Managerial Personnel

4

5. SEBI received a complaint against the Company with
allegations of fraudulent transactions, siphoning funds,
misrepresentation in financial statements, inflated turnover etc.
SEBI conducted a forensic audit for the period between
01.04.2018 and 31.03.2021. The investigation report revealed
that the Company was reporting false and manipulated financial
statements. An SCN was issued to 16 Noticees calling upon
them to show cause as to why suitable directions should not be
issued against them under Sections 11(1), 11(4), 11(4A),
11B(1), 11B(2), read with Sections 15A(a), 15HA, 15HB of SEBI
4
Ac t and Rule 4(1) of SEBI (Procedure for Holding Inquiry and
Imposing Penalties) Rules 1995. In the SCN, following
allegations were levelled:
i. Misstatement/Misrepresentation in consolidated financial
statements of Omaxe with respect to transactions with JBPL,
Garv, Pancham
ii. Overstatement of sale transactions with Pullback Apparels
Pvt. Ltd.,
iii. Overstatement of sale transactions between JRS Projects
Pvt. Ltd. and Bamdev Builders & Developers Pvt. Ltd.,
iv. Fictitious services i.e. Project Management Consultancy
(PMC) provided to inflate the revenue,
v. Consultancy services related to medical activities provided to
inflate the revenue,
vi. Overstatement of Sale of Flats vis-à-vis Customer Advance
Outstanding,
vii. Overstatement of sale of Property, Plant and Equipment
(PPE) land,

4
Securities and Exchange Board of India Act,1992

5

viii. Overstatement of Rent Expenses,
ix. Overstatement of Interest Expenses,
x. Overstatement of Debtors/ Trade Receivables,
xi. Overstatement of advances recoverable,
xii. Impairment of Goodwill,
xiii. Overstatement/ understatement of Loans,
xiv. Disclosure related violations,
xv. Wrong classification of loans & advances/bad-debts in Cash
Flow Statement
xvi. Non-co-operation with the investigating team xvii. Other
accounting irregularities
xviii. Price impact on Omaxe scrip due to misstatements in
financial statements.

6. The Company submitted its reply and other appellants
adopted the same. Appellant Nos.1 to 3 attended the personal
hearing and appellant Nos.4 and 5 did not. The CGM has held
that the appellants had violated the securities laws by recording
thus:
“35. I have carefully considered the facts and evidences
available on record against the Noticees, the circumstances
surrounding the violations committed by them and the
submissions advanced by the Noticees as well as following the
principles of preponderance of probabilities, I hold that the
charges relating to violation of the provisions of the SEBI Act,
PFUTP Regulations and LODR Regulations as brought out in
detail in this order are found to have been substantially
established.”

6

7. Mr. Sancheti, learned Senior Advocate for the appellants
urged two points.

8. Firstly, the appellants have suo motu refrained
themselves from accessing the securities market, though the
direction in para 41(i) of the impugned order was stayed by this
Tribunal vide order dated 01.10.2024. The debarment period of
two years expires on 30.07.2026. Since the appellants have
voluntarily refrained from accessing the securities market, this
Tribunal may hold that the appellants have suffered the
debarment and the direction in para 41(i) of the impugned order
stands complied.

9. Secondly, with regard to the monetary penalties, he
submitted that the same are grossly disproportionate and prayed
that this Tribunal may suitably modify the quantum of penalty by
applying the principle of doctrine of proportionality. He submitted
5
that Company‟s two fully owned subsidiaries, namely Garv and
6
Pancham have entered into separate valid contracts with the UP
Government to acquire large parcels of land and to develop as
7 8
housing colonies in Lucknow and Allahabad . After acquiring the
lands, the said subsidiaries have entered into valid contracts with
the Company and agreed to sell the housing plots in bulk. In
turn, the Company has entered into various memoranda of

5
Garv Buildtech Private Limited (presently, Omaxe Garv Buildtech Private
Limited)
6
Pancham Realcon Private Limited
7
Lucknow Hi-tech City
8
Allahabad Hi-tech City

7

9
understanding with another entity called „JBPL ‟ agreeing to sell
those plots in bulk. The JBPL, has sold its rights back to Garv and
Pancham. He submitted that all these transactions are valid in
law, however, SEBI has incorrectly held that the revenue earned
by JBPL and the Company have not been treated as per the
Accounting Standards and mis-construed that the appellants
10 11
have violated LODR and PFUTP Regulations.

10. He submitted that the allegations listed in (i), (ii), (iv),
(viii) and (x) are unfounded qua the appellants. The other
violations are venial in nature.

11. In reply, Mr. Chaudhary, learned Advocate for the SEBI
argued in support of the impugned order contending inter alia
that the Company, its subsidiaries and JBPL have indulged in
illegal transactions and made circular movement of funds to book
profits. Amplifying his contention, he submitted that initially
funds were provided by the Company to Grav and Pancham to
acquire the lands. Grav and Pancham agreed to sell the right,
title and interest in the housing plots to the Company in bulk.
The Company entered into MoUs with another entity „JBPL‟. JBPL
sold its rights to Grav and Pancham. All financial transactions
have taken place by round tripping the funds. To substantiate
this argument, he adverted to Table No.5 in para 29.1.1.8 in the
impugned order and submitted that on 30.03.2017, Company
paid ₹23.25 Crore to Garv and Garv paid to JBPL to purchase

9
Jeet Builders Private Limited
10
SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015
11
SEBI (Prohibition of Fraudulent and Unfair Trade Practices relating to
Securities Market) Regulations, 2003

8

JBPL‟s rights. In turn, JBPL paid to the Company as consideration
payable under the MoU between the Company and JBPL. He
submitted that similar modus operandi has been adopted to
move funds in a circular manner on 19.05.2017, 22.05.2018 and
13.06.2018 and in all a sum of ₹647.73 Crore has been shown
as the consideration received by the Company from JBPL. He
argued that the subsidiaries had acquired lands by using
Company‟s funds. The subsidiaries entered into MoUs with the
Company itself offering to sell the lands. In turn, Company has
sold its rights to JBPL and JBPL sold its rights to the original
owners, namely Grav and Pancham. These transactions are
wholly unnatural and carried out to mislead the investors of the
listed company. He vehemently contended that the violation of
securities laws is writ large on the face and prayed that the
appeal may be dismissed.

12. We have carefully considered rival contentions and
perused the records.

13. Undisputed facts of the case are, Omaxe Limited is a
listed entity. Garv and Pancham are its wholly owned
subsidiaries. They have acquired land from UP Government in
12 13
Lucknow and Allahabad , by using Omaxe‟s funds. They have
entered into MoUs with Omaxe. One of the MoUs between Grav
and Omaxe dated 24.10.2013 is produced as Exhibit – C and it
reads as follows:


12
Lucknow Hi-tech City
13
Allahabad Hi-tech City

9

“ BETWEEN


M/s Garv Buildtech Private Limited a company incorporated
under the Companies Act, 1956 having its Registered Office at
10, Local Shopping Centre Kalkaji New Delhi-10019 through its
authorized signatory Mr. Pavan Aggarwal (hereinafter referred
to as the 'First Party' ) which term shall, unless the context
requires otherwise, include his legal heirs, permitted assigns,
successors.
AND
M/s. Omaxe Limited , a company incorporated under the
Companies Act, 1956 having its Registered Office at 7, Local
Shopping Centre, Kalkaji, New Delhi - 110 019 through its
authorized signatory Mr. Manish Garg (hereinafter referred to
as the 'Second Party' ) which term shall, unless the context
requires otherwise, include its permitted assigns, nominees,
successors, administrators, legal representatives.

Hereinafter First Party & Second Party are collectively referred
to as 'Parties' and individually as 'Party' as the context
demands.”

WHEREAS:

(A) The First Party is contemplating to develop a Hi Tech City in
accordance with Hi Tech Policy of the Government of Uttar
Pradesh in Lucknow, Uttar Pradesh (hereinafter referred to as
the 'Said Colony') after purchase of raw undeveloped land in its
own name and/or in the name of its associates/subsidiaries;

(B) The First Party is in the process of acquiring land for the
Colony as the Government of Uttar Pradesh has already granted
license to it to develop Hi Tech City in Lucknow.

(C) The Second Party which is holding company of the first party
has approached the First Party and has expressed its consent to
invest funds for the purchase of such raw undeveloped land,
which is being purchased by the First Party for development of
the proposed residential colony to be executed by the First Party
or its subsidiary after obtaining all permissions and approvals
from the Concerned Authorities.

(D) The Second Party has also requested the First Party that in
lieu of the aforesaid contribution by the Second Party for the

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purchase of raw land as aforesaid, developed plot of land in the
proposed Colony shall be reserved for allotment to the Second
Party after the licenses / LOI / requisite permissions for the said
Colony are granted by the authorities.
(E) The First Party has accepted the request of the Second Party
and has agreed to accept the contribution of funds by the Second
Party for the aforesaid purpose.

(F) In the light of the above representations, the parties hereto
have agreed to enter into this arrangement subject to the terms
and conditions contained hereafter.

NOW THEREFORE, THIS AGREEMENT WITNESSETH AS
UNDER:

1. The Second Party has agreed to provide funds to the First
Party for the purchase / acquisition of undeveloped / raw land for
the purpose of development of the said Colony. The First Party
shall be entitled to purchase land for colony in its own name or in
the name of its associates / nominees, as may be necessary in
order to procure permissions and approvals.

2. The Second party has already paid an amount of
Rs.8,77,50,000/(Rupees Eight Crore Seventy Seven Lakh Fifty
Thousand Only) receipts of which the first Party hereby
acknowledges.

3. The first Party, in lieu of the aforesaid contribution of the
second party towards purchase of the said Land for the
development of Hi Tech City, has agreed to allot 130 plots of
approx. 500 sq. yards each. Total area of all the plots to be
allotted will be approximately 65,000sq.yds.

4. The First Party shall obtain either itself or through its
subsidiary or nominee all sanctions, approval, licenses for
developing a Colony on the said land at their own costs and
expenses. The First Party shall develop the land at its own costs.

5. The Second Party or his allottee/nominee shall be liable to pay
levies and charges like city development charges, external
development charges & conversion charges from leasehold to
freehold etc, that are imposed in terms of the Hi-Tech townships
policy of U.P. Govt. as at present, or in future in terms of the

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MOU and Developer Agreements executed; or to be executed
between the First Party and U.P Govt. through the controlling
authority.

6. It is agreed by and between the Parties that the amount paid by
the Second Party shall only comprise the basic cost of the plot
and all other charges such as Club Membership, IFMS, ECC and
FFC, EDC, PLC, Club Membership fees etc. shall be paid by the
Second Party as may be applicable to other buyers of the plot in
the Colony.

7. That the Second Party shall be entitled to get the plot of land
allotted in its own name or its nominees, in lieu of its contribution
towards purchase of raw land after the grant of license for the
proposed Colony in the High Tech City. The First Party
contemplates that it shall allot the plot of land to the Second Party
within a period of 60 months from the date of this Agreement

8. The terms and conditions of the allotment of the plot of land by
the First Party to the Second Party except as specifically provided
in this agreement will be Identical as applicable to other buyers
of the plot of land. The Second Party undertakes to execute the
Standard Plot Buyer's Agreement as shall be executed by other
allottees in the Colony and such terms as contained in the
agreement which shall contain detailed terms and conditions
pertaining to the allotment as well as rights and obligations of the
allottees. This shall be a condition precedent for allotment of plot
in favour of Second Party. It is specifically agreed that the
contribution made by the Second Party is equivalent to Basic Sale
Price (BSP) of the plots and other charges will be applicable as
per plot buyer agreement.

9. The Second Party shall be entitled to have the allotments in
respect of the plot agreed to be sold in its favour or its nominee
on the payment of entire consideration as per the respective Plot
Buyer Agreement. All expenses with regard to Stamp Duty,
Registration Charges etc. to cover the cost of Registration of the
Sale Deed will be borne by the Second Party. Also, all expenses
payable to the local authority or to the First Party at the time of
execution of registered deed and taking possession of plot shall be
paid by the nominee/allottee or by the Second Party.

10. In case of any dispute between the Parties arising out of or in
connection with this Agreement, the same shall be resolved

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through arbitration to be held in New Delhi in accordance with
the provisions of Arbitration & Conciliation Act, 1996 by a
mutually appointed arbitrator. In case of difference in choice of
an arbitrator, then each party shall appoint one arbitrator and
such appointed two arbitrators shall appoint third arbitrator who
will be the Presiding Arbitrator. The cost of the arbitration shall
be borne equally by the Parties. The venue of arbitration shall be
Delhi and the courts at Delhi/New Delhi shall have exclusive
jurisdiction in the matter.

11. The Parties may revise the terms of this Agreement or agree
on fresh terms and conditions, if warranted, by an instrument in
writing signed by the authorized representatives of both the
Parties.

12. For any item not covered in this Agreement, the same shall be
settled mutually after consultation of both the parties; however,
the decision of the First Party shall be final and binding.

IN WITNESS WHEREOF, THE PARTIES HAVE SET THEIR
RESPECTIVE HANDS ON THE DAY, MONTH AND YEAR
FIRST ABOVE WRITTEN.

M/s Garv Buildtech Private Limited
WITNESSES:

Authorized Signatory
FIRST PARTY


M /s. Omaxe Limited

Authorized Signatory
SECOND PARTY”

14. A careful analysis of the above MoU shows that in
consideration of ₹8.77 Crore, Garv agreed to sell 130 plots to
Omaxe. Omaxe, in turn, entered into several MoUs with JBPL
offering to sell the housing plots to JBPL.

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15. What is surprising is, JBPL in turn offered to sell its rights
to the original owners, namely the Grav and Pancham with a
premium. It was argued by Mr. Sancheti that there is no
illegality in such transactions.

16. JBPL was holding an agreement/MoU to purchase plots
from Omaxe. If JBPL had sold its rights to any third party, it is a
normal transaction. Appellants‟ argument is, Garv and Pancham
had agreed to buy-back their rights from JBPL. This is wholly
unnatural.

17. SEBI has alleged in the SCN that JBPL is a related party of
Omaxe. However, that charge has been dropped. The resultant
position is, JBPL is an independent third party. Garv and
Pancham were the owners of the plots and funding was made by
the parent company Omaxe. Accounts of Garv and Pancham have
been consolidated with Omaxe. Table No.5 in the impugned order
relied upon by Mr. Chaudhary, clearly shows that there has been
round tripping of money on the very same day between Omaxe
to Garv, Garv to JBPL and JBPL to Omaxe and similarly between
Omaxe to Pancham, Pancham to JBPL and JBPL to Omaxe. The
table 5 is as follows:
Table No. 5 (Rs. In crore)
Date Omaxe to
Omaxe to
Pancham
Garv to
Pancham
JBPL to
Garv
JBPL
to JBPL
Omaxe
30/03/2017 23.25 - 23.25 - 23.25
19/05/2017 200.00 150.00 200.00 148.50 331.40
22/05/2018 101.25 98.50 101.25 98.50 200.87
13/06/2018 74.50 25.47 74.50 25.47 92.21
Total 398.99 273.97 398.99 272.47 647.73

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18. On 30.03.2017, Omaxe has transferred ₹23.25 Crore to
Garv. Garv has transferred₹23.25 Crore to JBPL. Further, JBPL
has transferred ₹23.25 Crore to Omaxe. All transactions have
happened on the same day.

19. Similarly, on 19.05.2017, Omaxe has transferred ₹200
Crore to Garv and ₹150 Crore to Pancham. Garv has transferred
₹200 Crore to JBPL and Pancham has transferred ₹148.50 Crore
to JBPL. Further, JBPL has transferred ₹331.40 Crore to Omaxe.
All transactions have happened on the same day.

20. Similarly, on 22.05.2018, Omaxe has transferred ₹101.25
Crore to Garv and ₹98.50 to Pancham. In turn, Garv and
Pancham transferred exactly the same amounts to JBPL and
further, JBPL has transferred ₹200.87 Crore to Omaxe. All
transactions have happened on the same day.

21. Similarly, on 13.06.2018, Omaxe has transferred ₹74.50
Crore to Garv and ₹25.47 Crore to Pancham. In turn, Garv and
Pancham transferred exactly the same amounts to JBPL and
further, JBPL has transferred ₹92.21 Crore to Omaxe. All
transactions have happened on the same day.

22. A careful analysis of the above transactions shows that
Garv and Pancham have paid premium to JBPL to purchase its
rights. But interestingly, that money was funded by their parent
company Omaxe and JBPL has transferred that money to
Omaxe. The first allegation is, misstatement/ misrepresentation
in consolidated financial statements of Omaxe with respect to

15

transactions with JBPL, Garv, Pancham. The round tripping of
movement of funds is conspicuous. The ostensible revenue
sought to be projected by Omaxe based on the sale of rights to
JBPL and JBPL‟s claim of revenue receipts based on the
ostensible sale of rights to Garv and Pancham is nothing but a
result of camouflaged sham transactions and hence, the first
charge stands established.

23. The second charge is with regard to overstatement of sale
transactions with Pullback Apparels Private Limited („Pullback‟ for
short). Mr. Sancheti for appellants submitted that on 11.01.2021,
the Company entered into an agreement to sell, whereby land
was purchased by Pullback and on the same day, full
consideration amount was paid by Pullback to Omaxe. On
16.01.2021, Omaxe handed over possession of plots to Pullback
and executed the sale deed on 25.06.2021 in favour of Pullback.
It was argued that the transaction cannot be questioned on the
basis of accounting treatment given by the buyer (Pullback). He
contended that a deed of conveyance and its registration is only
a formality and not a precondition for revenue recognition. With
these submissions, Mr. Sancheti contended that CGM‟s finding on
this allegation is untenable.

24. In reply, Mr. Chaudhary submitted that in FY 2020-21,
Omaxe has recorded sale of land to Pullback based on an
agreement to sell. The payment was received on 11.01.2021
and possession letter was given on 15.01.2021. The sale deed
has been executed on 25.06.2021. Pullback‟s financial statement
for that financial year has categorised this transaction as

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„advance given for land‟. He submitted that para 6 of ICAI
guidance note makes it clear that revenue from sale of land
should be recognised when all conditions in para 4.2 are fulfilled.
Para 4.2 of the note states that completion of revenue
recognition is identified when the entity has transferred to the
buyer, the significant risk and rewards of ownership. In
substance, he contended that sale deed was executed after
31.03.2021 and therefore, the receipt of money could not have
been considered as sale consideration.

25. It is settled in law that the rights and obligations in an
immovable property are transferred only upon execution of a
deed of conveyance which is registered within the prescribed
time limit provided in the Indian Registration Act, 1908. Admitted
position is, sale deed was executed on 25.06.2021. Further,
admitted position is Pullback has recognised the money
transferred to Omaxe as „advance sale consideration‟. Thus, it is
clear that Pullback treated the money paid as advance sale
consideration and sale deed was executed only after 31.03.2021.
Hence, Omaxe could not have shown the receipt of money as
income in FY 2020-21. Hence, the second charge stands
established.

26. With regard to charges at (iv), (vii) and (x), it was urged
by Mr. Sancheti that this Tribunal may take a lenient view and
reduce the penalty by considering the doctrine of proportionality.
We may record that in the written submissions filed on behalf of
the appellants, it is stated thus:

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“Other allegations in the Impugned Order

The Impugned Order is replete with similar perfunctory
allegations, as elaborated in the Memorandum of Appeal. While
the Appellants have submissions on merits in respect of the
charges(sic) levelled in the Impugned Order, the Appellants
would request for a favourable consideration on the aspect of
proportionality while computing /adjudicating the quantum of
penalty. In this regard, it is worthwhile to note that the penalty
in the Impugned Order is computed on a lump-sum basis and
not segregated on the basis of charges.”

27. Thus, in their written submissions appellants have
restricted their prayer only with regard to quantum of penalty.

28. This is one of the classic cases in which gullible investors
are induced to invest by misrepresentation of financials. The
round tripping of money between Omaxe, its subsidiaries and
JBPL recorded hereinabove establishes that the transactions were
not genuine and designed to dress up the financial results to give
a false impression that the listed company had good financials. It
is shocking to note that Omaxe‟s subsidiary companies which
acquired lands from the State Government of Uttar Pradesh
sought to sell the lands to their parent company, which in turn
sought to sell them to a third party company, JBPL. There are no
deeds of conveyances transferring the immovable properties
from Garv, Pancham to Omaxe. Hence, Omaxe had no title, yet
dealt with the immovable properties by offering to sell the plots
to JBPL. It is further shocking to note that JBPL, without having
any title offered to sell the properties back to Garv and Pancham,
to whom the lands were allotted by the Government. This is
nothing but a series of fraudulent „make believe‟ financial

18

transactions. The PFUTP violation is largely writ on the face of
each transaction. Hence, the prayer made by Mr. Sancheti to
take a lenient view is only noted to be rejected.

29. In the result, the following:

ORDER

i. Appeal is dismissed.
ii. Pending interlocutory application(s), if any, stand
disposed of.
iii. No costs.






Justice P.S. Dinesh Kumar
Presiding Officer


Ms. Meera Swarup
Technical Member


Dr. Dheeraj Bhatnagar
Technical Member

01.09.2026
RHN
RAJALA
KSHMI
H NAIR
Digitally signed
by RAJALAKSHMI
H NAIR
Date: 2026.09.01
14:09:13 +05'30'