SEBI has issued Adjudication Order No. Order/SM/SM/2026-27/32385 against Pawan Kumar Malsaria (PAN: AAECD6486C) in the matter of Golden Tobacco Limited (GTL). The order follows a SEBI investigation into alleged manipulation of GTL’s books of accounts across financial years FY 2009-10 to FY 2020-21, and alleged violations of SEBI (LODR) Regulations, 2015 and SEBI (Prohibition of Fraudulent and Unfair Trade Practices) Regulations, 2003.

Key Points

• Adjudication Order No. Order/SM/SM/2026-27/32385 issued under Section 15-I of the SEBI Act, 1992 read with Rule 5 of SEBI (Procedure for Holding Inquiry and Imposing Penalties) Rules, 1995
• Noticee: Pawan Kumar Malsaria (PAN: AAECD6486C)
• Investigation covered the period April 01, 2009 to March 31, 2021 (FY 2009-10 to FY 2020-21)
• Alleged violations: Regulation 17(8) and Regulation 33(2)(a) of SEBI (LODR) Regulations, 2015
• SEBI also examined potential violations of PFUTP Regulations, 2003 and SEBI Act, 1992
• Adjudicating Officer was initially Shri Vijayant Kumar Verma (appointed September 30, 2022), then Shri Amar Navlani (appointed August 30, 2023), and finally the undersigned (appointed September 12, 2025)
• Show Cause Notice No. SEBI/EAD-9/VKS/PSS/60732/2022 dated December 05, 2022 was issued to the Noticee
• Investments and advances to subsidiaries of GTL were scrutinized as part of the investigation

Regulatory Changes

No new regulatory changes are introduced. This order enforces existing provisions:

• Section 15HB of the SEBI Act, 1992 (penalties for other violations)
• Regulation 17(8) of SEBI (LODR) Regulations, 2015 (compliance certificate by CEO/CFO)
• Regulation 33(2)(a) of SEBI (LODR) Regulations, 2015 (financial results submission with auditor certification)
• SEBI (PFUTP) Regulations, 2003

Compliance Requirements

• Listed companies must ensure CEO/CFO compliance certificates as mandated under Regulation 17(8) of LODR Regulations are accurate and not misleading
• Financial results submitted under Regulation 33(2)(a) must be certified by auditors and free of material misstatements
• Companies and their officers must not manipulate books of accounts or misrepresent financials to exchanges, investors, or regulators
• Investments and advances to subsidiaries must be accurately disclosed in financial statements

Important Dates

• Investigation Period: April 01, 2009 to March 31, 2021 (FY 2009-10 to FY 2020-21)
• First Adjudicating Officer appointed: September 30, 2022
• Show Cause Notice issued: December 05, 2022
• Second Adjudicating Officer appointed: August 30, 2023
• Current Adjudicating Officer appointed: September 12, 2025
• Order issued: April 2026

Impact Assessment

This order has limited direct market impact as it targets an individual officer at Golden Tobacco Limited, a small-cap company. However, it signals SEBI’s continued pursuit of historical financial misconduct cases, including those involving prolonged books-of-accounts manipulation over more than a decade. The enforcement action reinforces obligations on senior management (CEO/CFO) to ensure accuracy of financial certifications and disclosures under LODR Regulations. Investors in GTL should be aware of the ongoing regulatory scrutiny of the company’s historical financials.