Description

SEBI issues revised demand notice for Rs. 2,99,46,456.71 (including interest) against Dolphin Universal Rural Development Limited and seven individuals for refund of amounts with recovery proceedings under Section 28A of SEBI Act.

Summary

SEBI has issued a revised Notice of Demand dated October 14, 2025 under RC No. 6364 of 2023 against Dolphin Universal Rural Development Limited and seven individuals (Anindyo Paul, Debraj Mitra, Koushik Dutta, Rana Sikdar, Saugata Basu, and Subham Bose) for recovery of Rs. 2,99,46,456.71. This revised notice corrects an earlier demand dated March 28, 2023 which contained incorrect interest calculations. The demand arises from a refund order issued by WTM in October 2016 related to the Dolphin Universal matter.

Key Points

  • Total demand amount: Rs. 2,99,46,456.71 (Rs. 2.99 crore approximately)
  • Principal refund amount ordered: Rs. 99,79,500 (Rs. 79,11,500 + Rs. 20,68,000)
  • Interest component: Rs. 1,99,65,955.74 calculated at 15% p.a.
  • Interest period: April 1, 2012 to October 14, 2025 (on Rs. 79.11 lakh) and April 1, 2013 to October 14, 2025 (on Rs. 20.68 lakh)
  • Recovery cost: Rs. 1,000
  • Payment deadline: 15 days from receipt of notice
  • Seven entities named: One company and six individuals
  • Original WTM order dated: October 27, 2016 (Order No. WTM/RKA/EFD/164/2016)

Regulatory Changes

No new regulatory changes. This is an enforcement action under existing provisions of Section 28A of SEBI Act, 1992 read with Section 222 of Income-tax Act, 1961.

Compliance Requirements

  • Payment Method: Respondents must pay via direct credit through EFT/NEFT/RTGS to Bank of India Account No. SEBIRNCIS6364 (IFSC: BKID00VAN04), OR through online payment on SEBI’s Recovery Payment module at https://siportal.sebi.gov.in, OR via payment link on SEBI Website → Enforcement → Recovery Proceedings → Pay Now
  • Payment Deadline: Within 15 days of receipt of this notice
  • Consequence of Non-Payment: Recovery Officer will initiate recovery proceedings under Section 28A of SEBI Act read with sections 220-227, 228A, 229 and 232 of Income-tax Act, 1961

Important Dates

  • Original WTM Order: October 27, 2016
  • First Notice of Demand: March 28, 2023 (contained incorrect interest calculation)
  • Revised Notice Date: October 14, 2025
  • Interest Calculation Period: April 1, 2012 to October 14, 2025 (for Rs. 79.11 lakh component) and April 1, 2013 to October 14, 2025 (for Rs. 20.68 lakh component)
  • Payment Deadline: 15 days from receipt of notice

Impact Assessment

Market Impact: Negligible direct market impact as this relates to a specific enforcement case from 2016 involving a collective investment scheme matter.

Entity Impact: High impact on the seven named respondents who face recovery proceedings with potential attachment and sale of movable/immovable property, arrest and detention, or appointment of receiver if payment is not made within the stipulated timeframe.

Precedent Value: Demonstrates SEBI’s continued pursuit of recovery in older enforcement matters, including correction of calculation errors in demand notices. The 15% per annum interest rate and extended calculation period (13+ years) significantly increases the total liability from the original refund amount of Rs. 99.79 lakh to Rs. 2.99 crore.

Recovery Modes: In case of non-payment, SEBI can proceed with: (a) attachment and sale of movable property, (b) attachment and sale of immovable property, (c) arrest and detention, or (d) appointment of receiver for property management.

Impact Justification

High severity enforcement action against specific entities with Rs. 2.99 crore recovery demand, but limited broader market impact as it relates to past CIS violations from 2012-2013 period