Confirmatory Order in respect of inspection of Capital Stroke Investment Services Pvt. Ltd. · 15 Oct 2026

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National Stock Exchange of India

Circular

Department: Investigation Download Ref No: NSE/INVG/76934 | Date: October 15, 2026 Circular Ref. No: 101/2026

To All NSE Members,

Sub: Confirmatory Order in respect of inspection of Capital Stroke Investment Services Pvt. Ltd.

This has reference to SEBI order no. WTM/MB/WRO/WRO/13176/2021-22 dated August 27, 2021, and circular no. NSE/INVG/49440 dated August 29, 2021, wherein SEBI has directed following entity not to access the securities market and buy, sell or otherwise deal in securities or associates themselves with securities market, directly or indirectly, in any manner whatsoever

SEBI vide confirmatory order no. WTM/AB/WRO/WRO/16948/2022-23 dated June 08, 2022, and circular no. NSE/INVG/52561 dated June 08, 2022, has confirmed the directions issued against the entities in the Interim Order.

Now SEBI vide confirmatory order no. QJA/BS/WRO/WRO/32771/2026-27 dated October 15, 2026, hereby direct that the Noticee is restrained from accessing the securities market and are further prohibited from buying, selling or otherwise dealing in securities, either directly or indirectly, or being associated with the securities market in any manner whatsoever, for a period of 5 (five) years. It is clarified that while calculating the period of debarment as directed above, the period of restraint already undergone pursuant to the Interim Order read with the Confirmatory Order shall be taken into consideration and set off from period mentioned above.

Order is available on SEBI website - http://www.sebi.gov.in

Further, the consolidated list of such entities is available on the Exchange website http://www.nseindia.com home page at the below mentioned link:

Confidential

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National Stock Exchange of India

https://www.nseindia.com/regulations/member-sebi-debarred-entities

Members are advised to take note of the above and ensure compliance.

In case of any further queries, members are requested to email us at dl-invsg-all@nse.co.in

For and on behalf of
National Stock Exchange of India Limited

Jyotsna Jain
Senior Manager

ANNEXURE: Confirmatory Order in respect of inspection of Capital Stroke Investment Services Pvt. Ltd.

Confidential

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QJA/BS/WRO/WRO/32771/2026-27

SECURITIES AND EXCHANGE BOARD OF INDIA

FINAL ORDER

UNDER SECTION 12 (3) OF SECURITIES AND EXCHANGE BOARD OF INDIA ACT, 1992 READ WITH REGULATION 27 AND REGULATION 35 OF SECURITIES AND EXCHANGE BOARD OF INDIA (INTERMEDIARIES) REGULATIONS, 2008

IN RESPECT OF:

In the matter of Capital Stroke Investment Services Pvt. Ltd.

TABLE OF CONTENTS

A. BACKGROUND................................................................................................ 2
B. PROCEEDINGS BEFORE DESIGNATED AUTHORITY ................................. 3
C. SHOW CAUSE NOTICE, REPLY AND HEARING........................................... 4
D. CONSIDERATION OF ISSUES AND FINDINGS............................................. 9

• I. Promising assured returns, misrepresentation on website regarding research team, advice/services, performance and accuracy to clients and fraud.................16
• II. Failure to act in a fiduciary capacity and the Code of Conduct for Investment Advisers.................................................................................................................23
• III. Qualification and certification of employees .................................................24
• IV. Submission of forged documents to SEBI....................................................27
• V. Risk-profiling questionnaire and weightage..................................................29
• VI. Failure to obtain supporting documents and call recordings in risk profiling 30
• VII. Manipulation of client’s risk category............................................................31
• VIII. Charging of advisory fees multiple times to its clients before completion of the tenure of the previous service, charging of arbitrary / illogical fees from its clients and charging of fees more than the fees specified on its website..........................33
• IX. Failure to provide proof of communication of advisory details......................37
• X. Providing free trials to its prospective clients................................................39
• XI. Maintenance of records pertaining to risk profiling, suitability assessment, selling advisory service, etc. ..................................................................................40
• XII. Involvement in the unregistered advisory activity of Green Wealth..............41

Order in respect of inspection of Capital Stroke Investment Services Pvt. Ltd.
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• XIII. Failure to disclose risk profile to a client.......................................................44
• XIV. Failure to redress investor complaints..........................................................45 E. CONCLUSION ................................................................................................46
  F. ORDER ...........................................................................................................49

A. BACKGROUND

1. The present matter emanates from post enquiry show cause notice (“SCN”) dated January 05, 2026 issued to Capital Stroke Investment Services Pvt. Ltd. (hereinafter referred to as “Noticee”) under regulation 27 (1) of SEBI (Intermediaries) Regulations, 2008 (hereinafter referred to as “Intermediaries Regulations”). The Noticee is registered with Securities and Exchange Board of India (hereinafter referred to as “SEBI”) as an Investment Adviser (“IA”) with SEBI registration no. INA000001316.

2. SEBI conducted an inspection of the Noticee from November 03, 2020 to November 06, 2020 at the registered office of the Noticee concerning various compliance requirements with respect to the provisions of SEBI (Investment Advisers) Regulations, 2013 (hereinafter referred to as “IA Regulations”) and SEBI (Prohibition of Fraudulent and Unfair Trade Practices relating to Securities Market) Regulations, 2003 (hereinafter referred to as “PFUTP Regulations”). The inspection was conducted for the period beginning from April 01, 2019 to September 22, 2020 (hereinafter referred to as “Inspection period”). Investor complaints which were received after September 22, 2020 and pending were also taken up for examination in the said inspection.

3. Based on the findings of the inspection, SEBI issued an interim ex-parte order dated August 27, 2021 against the Noticee. Pursuant to the Noticee’s reply dated October 15, 2021, SEBI issued a confirmatory order dated June 08, 2022. The confirmatory order recorded that the interim order, inter alia, alleged two main violations by the Noticee, namely, (i) making false and misleading representations by promising assured profits and returns to clients, and (ii) charging unfair and unreasonable fees from clients.

Order in respect of inspection of Capital Stroke Investment Services Pvt. Ltd.
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4. Subsequently, vide letter dated October 27, 2022, the Noticee was advised to furnish certain information to SEBI. The Noticee vide email dated November 09, 2022 and letter dated November 14, 2022, submitted the bank statements of its directors and its books of accounts, the client master, financial statements, pricing information, KYC samples, agreement samples, bank information, client count and fees collected, and refund information for the period 2019 to 2022.

5. Based on the aforesaid documents furnished by the Noticee, SEBI conducted further examination in the matter and observed certain non-compliances of the SEBI Act, the PFUTP Regulations and the IA Regulations, pursuant to which the present enquiry proceedings came to be initiated against the Noticee. The present proceedings are broader in ambit than, and are not confined to, the two allegations that formed the subject matter of the interim and confirmatory orders.

B. PROCEEDINGS BEFORE DESIGNATED AUTHORITY

6. The Designated Authority (“DA”) issued a show cause notice dated April 16, 2024 (hereinafter referred to as “pre-Enquiry SCN”) to the Noticee under regulation 25 (1) of the Intermediaries Regulations to show cause as to why appropriate recommendation should not be made against it in terms of Regulations 26 of the Intermediaries Regulations for the alleged violations.

7. Vide email dated April 29, 2024, Noticee sought two months’ time to file reply to the pre- enquiry SCN. Vide email dated April 29, 2024, Noticee was granted time till May 17, 2024 to file reply to the SCN. Vide email dated May 17, 2024, Noticee filed its reply to the SCN. Based on the allegations levelled against the Noticee in the pre-Enquiry SCN and the material available on record, the DA concluded the Enquiry Proceedings and submitted the Enquiry Report (“Enquiry Report”) dated August 29, 2025 in terms of regulation 26 of the Intermediaries Regulations.

8. The DA in the report has observed the following against the Noticee: