Cash Cow Broking and 3 Partners Ordered To Refund ₹44.76 Lakh Collected from Investors for Unregistered Investment Advisory

Moneylife Digital Team 16 March 2026

Investor Interest

Market regulator Securities and Exchange Board of India (SEBI) has directed Cash Cow Broking & Advisory Solutions and its partners Shailendra Sen, Amit Jain and Chirag Sharma to refund ₹44.76 lakh collected from investors through unregistered investment advisory activities, following a recalculation exercise carried out pursuant to directions from the securities appellate tribunal (SAT).

In an order, Amarjeet Singh, SEBI’s whole-time member (WTM), held that the partnership firm had collected ₹44.76 lakh from clients while offering investment advisory services without obtaining the mandatory registration under the SEBI Act and the Investment Advisers Regulations.

SEBI had received complaints alleging that the firm was providing investment advice without the required regulatory authorisation. After examining the complaints, SEBI concluded that the firm had been operating as an unregistered investment adviser.

In January 2022, SEBI passed an order directing the firm and its partners to refund ₹65.51 lakh collected from investors. The noticees challenged the order before SAT. While the tribunal upheld SEBI’s finding that the firm had, indeed, carried out investment advisory activities without registration, it observed that the exact amount collected from such activities required recalculation. The firm had argued that some of the receipts related to other services such as brokerage or internet services.

SAT, therefore, remanded the matter to SEBI for a fresh calculation and directed the noticees to deposit ₹30 lakh with the regulator as a precondition for reconsidering the case. The firm initially failed to comply with this direction. Later, in August 2024, SAT granted additional time, subject to a deposit of ₹40 lakh, which was eventually paid.

During the recalculation process, the firm admitted that it had received ₹37.29 lakh as investment advisory fees but disputed the balance amount identified by SEBI. It argued that the remaining funds related to internet services, brokerage income or contributions made by partners rather than advisory fees.

However, SEBI found several inconsistencies in the documents submitted by the noticees. The regulator observed that invoices produced to support claims of income from internet services lacked credibility, with several invoices carrying identical numbers or incomplete details. SEBI also noted that the firm failed to provide documentary evidence supporting its claim that certain cash deposits represented partner contributions.

After examining bank records and adjusting certain entries, including a contra transfer of ₹1.25 lakh and a reversal entry of ₹9,005.75. SEBI concluded that the firm had collected ₹44.76 lakh from clients through unregistered investment advisory activities.

The regulator also noted that the firm had published its bank account details on its website and solicited funds from investors through those accounts. In such circumstances, unexplained credits in these accounts were reasonably treated as advisory fees collected from investors.

SEBI has now directed the firm and its partners to refund ₹44.76 lakh to investors in accordance with the procedures specified in the earlier 2022 order. The regulator also clarified that the funds already deposited in the interest-bearing account pursuant to SAT’s directions may be used to facilitate refunds to affected investors.

The order further states that the timelines and mechanisms for implementing the refund will follow those laid down in the January 2022 order. Copies of the order have also been circulated to stock exchanges, banks, depositories and mutual fund registrars to ensure compliance with the refund directions.

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