SEBI v. Excel Realty N Infra Limited and others (misstated accounts, 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.
In July 2023 a SEBI whole-time member found that Excel Realty N Infra and four of its promoters and officers presented misleading accounts that carried about Rs 22.9 crore advanced to a UAE subsidiary as trade receivables for ten years without provision. The company and the individuals were barred from the market for between six months and two years and fined Rs 1.75 crore in total.
The record
| Agency | SEBI (India) |
|---|---|
| Date filed | 2023-07-28 |
| Date resolved | 2023-07-28 |
| Court | SEBI whole-time member |
| Status | judgment |
| Asset class | equities |
| Instruments | Excel Realty N Infra Ltd shares |
| Venue | NSE, BSE |
| Criminal parallel | No |
| Bars imposed | Lakhmendra Khurana restrained from the securities market for 2 years and from director or KMP roles for 1 year, Ranjana Khurana, Arpit Khurana and Pramod Kokate restrained for 1 year, Excel Realty restrained from accessing the market for 6 months and directed to recover advances from its UAE subsidiary within a year |
| Defendants | Excel Realty N Infra Limited ; Lakhmendra Chamanlal Khurana ; Ranjana Khurana Lakhmendra ; Arpit Lakhmendra Khurana ; Pramod Yeshwant Kokate |
| Techniques | Misleading issuer disclosure |
What was ordered
- Civil penalty
- —
- Disgorgement
- —
- Prejudgment interest
- —
- Total relief
- —
- Alleged gain
- —
- Penalty as published
- 17.5m INR
What is alleged to have happened
This final order was issued on 28 July 2023 by Ananta Barua, a whole-time member of SEBI. It concerns Excel Realty N Infra Limited, a listed real estate company, and four individuals: Lakhmendra Chamanlal Khurana, his wife Ranjana Khurana Lakhmendra, his son Arpit Lakhmendra Khurana, and Pramod Yeshwant Kokate. SEBI examined the company's affairs from April 2016 to March 2021 after a complaint of March 2021.
The show cause notice of September 2022 alleged that Excel advanced money to Excel Info FZE, a wholly owned subsidiary in the Ras Al Khaimah free trade zone, and that the balance was carried as trade receivables in the consolidated accounts from 2011-12 to 2020-21 while the subsidiary booked it as trade payables, with no corresponding business. SEBI said this misrepresented the financials and diverted funds, breaching section 12A of the SEBI Act, the PFUTP Regulations and the listing regulations.
The company said it had advanced Rs 22,91,61,591 for genuine business, that the subsidiary existed and its trade licence was renewed each year, and that part had been repaid: Rs 8.09 crore at one point and Rs 898.90 lakh by July 2023. The order accepts that the subsidiary existed but finds the noticees gave no documentary proof of the subsidiary's receivables, that the amounts should have been provided for under the accounting standard, and that repayment began only after the auditors' adverse remarks and the show cause notice. It treats the accounts as misleading.
Excel must bring back the outstanding funds within one year, under review by its audit committee, and was restrained from the market for six months. Mr Khurana was restrained for two years and from director or key managerial roles for a year; the other three individuals for a year. Penalties under sections 15HA and 15HB were Rs 10 lakh for the company, Rs 1 crore for Mr Khurana, Rs 25 lakh each for Ms Khurana and Arpit Khurana, and Rs 15 lakh for Mr Kokate, Rs 1.75 crore in all. The noticees had applied to settle in 2022, and SEBI rejected the applications in July 2023.
The order is an administrative sanction, not a criminal judgment, and describes no criminal case. The record does not show whether the noticees appealed, whether the balance was recovered or whether the penalties were paid.
This library tags the matter as misleading issuer disclosure. 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 one technique 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.
- Misleading issuer disclosure — see how it works, what statute it engages, and every other action tagged the same way.
Timeline
- 2023-07-28 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.
Related actions
Other actions in the library sharing at least one technique tag with this one.