Have you ever wondered whether the investment advisory firm calling you with “sureshot tips” is actually keeping proper records of your onboarding, or whether they could even prove tomorrow that they spoke to you today?
It sounds like a basic thing. But it turns out, for many registered investment advisors in India, even something as simple as maintaining client call records becomes a point of regulatory failure.
Bestway Smart Financial Pvt Ltd is one such case. On paper, it looks straightforward, a SEBI-registered investment advisory company offering stock market tips.
But beneath that surface, there’s a formal adjudication order from SEBI dated March 28, 2025, laying out exactly where the firm fell short of its compliance obligations.
In this blog, we’ll cover who Bestway Smart Financial Pvt Ltd is, what the official SEBI order says, break down each violation clearly, and tell you what investors can learn from all of this.
Bestway Smart Financial Overview
Bestway Smart Financial Private Limited was incorporated on November 8, 2021, making it a relatively young firm in the financial advisory space.
It was registered under the Ministry of Corporate Affairs (MCA) with the Corporate Identification Number U67100MH2021PTC371007.
The company markets itself as a provider of stock market tips and intraday advisory services across NSE equity, Bank Nifty options, stock futures, and MCX commodities.
Tips and recommendations are delivered primarily via SMS, which the firm has also cited as the reason phone calls weren’t used for advisory purposes.
| Full Name | Bestway Smart Financial Private Limited |
| CIN | U67100MH2021PTC371007 |
| Incorporation Date | November 8, 2021 |
| Registered Office | H.No. 3232, Pl No. 368, Sindhi Colony, Khamla Road, Nagpur, Maharashtra – 440022 |
| Branch Office | 181, Badi Bhamori, First Floor, Indore, Madhya Pradesh |
| SEBI Registration No. | INA000017392 |
| Entity Type | Investment Adviser (IA) |
| Directors | Manoj Jethanand Varyani & Vikash Soni |
| Authorized Capital | ₹50 Lakhs |
| Paid-Up Capital | ₹30 Lakhs |
Bestway Smart Financial Pvt Ltd held the SEBI Registration Number of INA000017392.
However, as of the time of writing this blog, a search on SEBI’s official registered intermediaries list does not return this registration as an active, currently listed entity.
When a SEBI registration number is no longer visible in SEBI’s active records, it typically means the registration may have lapsed, been surrendered, not been renewed, or been cancelled.
Before engaging any investment advisor, always verify their current registration status directly on sebi.gov.in.
This is a critical point. A registration number that once existed but no longer appears in SEBI’s live records is a serious flag for any trader or investor considering using this firm’s services.
Now, with the basic profile covered, let’s get into the heart of why this firm is worth examining closely: the SEBI adjudication order.
Bestway Smart Financial Pvt Ltd SEBI Order
On March 28, 2025, SEBI’s Adjudicating Officer passed a formal order against Bestway Smart Financial Private Limited under Adjudication Order No. Order/AN/SM/2024-25/31350.
The inspection was initiated by SEBI through BASL, covering a period of nearly 17 months between April 2022 and August 2023.
BASL submitted its inspection report to SEBI, along with comments on the firm’s own replies to the findings.
- Inspection Period: April 1, 2022 – August 31, 2023
- Inspection Conducted By: BSE Administration and Supervision Limited (BASL)
- Show Cause Notice Issued: October 11, 2024
- Hearing Date: November 29, 2024 (online, via video conferencing)
- Order Date: March 28, 2025
- Adjudicating Officer: Amar Navlani, Mumbai
- Penalty Imposed: ₹1,00,000
What SEBI found wasn’t a minor paperwork gap.
The violation established against Bestway Smart Financial went to a foundational compliance obligation, one that every registered investment advisor is expected to follow without exception.
Major Violations
The following key compliance gaps were identified during SEBI’s inspection:
1. Non-Maintenance of Call Recordings: Regulation 19 of SEBI IA Regulations, 2013
SEBI observed that Bestway Smart Financial had onboarded 1,723 clients during the inspection period, of which 751 were unique clients.
When BASL asked for call recordings during the on-site inspection held on September 5, 2023, the firm could only produce 40 call records, and those 40 calls were merely payment confirmation calls, not advisory conversations.
That means out of 751 unique clients, there was essentially no call record documenting client interaction, onboarding conversations, or advice-related communication, a near-complete absence of required record keeping.
Under Regulation 19 of the SEBI (Investment Advisers) Regulations, 2013, every investment advisor is required to maintain records of all client interactions, including with prospective clients, where any conversation related to advice has taken place.
This includes telephone recordings, and all such records must be preserved for a minimum period of five years, either in physical or electronic form.
2. Bestway Smart Financial Pvt Ltd’s Defence
Bestway Smart Financial, through its directors Manoj Jethanand Varyani and Vikash Soni, submitted a reply to the Show Cause Notice on October 23, 2024.
Their position had two main arguments:
- A technical issue wiped out the recordings: The firm claimed that after the SEBI on-site inspection, their server crashed, which corrupted the call recordings and made them inaccessible. They stated this was an unforeseen technical malfunction and that they had taken steps to prevent recurrence.
- Financial advice was never given over phone calls: The firm argued that all financial advice was communicated via SMS, not phone. So the phone calls, in their view, were purely for procedural and customer service purposes, not advisory ones, and therefore weren’t subject to the call recording requirement.
On the surface, these arguments may sound reasonable. But the Adjudicating Officer didn’t accept them.
The Adjudicating Officer concluded clearly: the allegation that the Noticee had failed to maintain call recordings of clients on-boarded during the inspection period stands established.
After evaluating all factors, including whether there was any quantifiable investor loss, disproportionate gain, or repetitive pattern of violations, the Adjudicating Officer imposed a monetary penalty of ₹1,00,000 (Rs. One Lakh) under Section 15EB of the SEBI Act, 1992.
What Traders and Investors Should Learn From This?
The SEBI order against Bestway Smart Financial isn’t just a regulatory formality. It surfaces a set of questions every trader should be asking before subscribing to any paid advisory service.
- Always verify active SEBI registration before paying anything: Check the intermediary’s registration number directly on SEBI’s website. A number that existed once isn’t the same as a valid, active registration today.
- Ask the firm how they record and store your onboarding conversations: A firm that can’t produce call records for 751 clients cannot protect your interests if something goes wrong later.
- A SEBI penalty order is a red flag, not a clean chit: Some firms frame enforcement actions as minor, resolved matters. But a violation established under SEBI regulations, regardless of penalty size, reflects a culture of non-compliance.
- SMS-only advice isn’t necessarily safer: Just because tips come via SMS doesn’t mean a firm is transparent. It may simply mean there’s less of a paper trail for clients to refer back to.
- The absence of proper records hurts you the most: If you ever need to file a complaint, call records and client interaction logs are your primary evidence. When those records don’t exist, proving your case becomes significantly harder.
How to File a Complaint Against an Investment Advisor?
If you have subscribed to services from Bestway Smart Financial Pvt Ltd or any similar investment advisory firm and have faced losses, mis-selling, or unresponsive service, you have clear formal routes available to raise your complaint.
Step 1: Organise Your Evidence
Collect all payment receipts, bank transfer records, SMS tips received, any written agreements, WhatsApp messages, and email correspondence.
Arrange everything date-wise. A well-documented complaint is taken far more seriously.
Step 2: Draft a Factual Complaint
Write out what was promised, what was delivered, how much you paid, and what losses you incurred.
Keep it factual and to the point. Numbers and timelines carry more weight than emotional accounts.
Step 3: File a Complaint in SCORES
Visit the SEBI SCORES portal. Register, file your complaint, and upload all supporting documents.
You can track the status and respond to any queries through the portal. For complaints against investment advisors specifically, SCORES is the primary channel.
Step 4: Escalate Complaint with SMART ODR
If SCORES doesn’t resolve your issue, you can escalate to the SMART ODR (Online Dispute Resolution) portal for a more structured conciliation or arbitration process.
No legal representation is required, making it accessible for individual investors.
Step 5: Share Market Arbitration
For higher-value disputes where regulatory response isn’t sufficient, formal arbitration through the exchange framework remains an option, particularly if your advisory agreement contains an arbitration clause.
Facing issues with Bestway Smart Financial Pvt Ltd or another SEBI-registered advisor?
Register with us and our team helps you document your case correctly, draft structured complaints, and navigate SEBI SCORES or SMART ODR, so your complaint actually gets heard.
Conclusion
Bestway Smart Financial Pvt Ltd entered India’s financial advisory space in November 2021 with a SEBI registration and a website promising reliable stock market tips.
But the March 2025 adjudication order tells a different story, one of a firm that couldn’t produce call records for the vast majority of its 751 unique clients, couldn’t locate its backup data during an on-site inspection, and couldn’t even unlock a password-protected hard disc meant to hold that backup.
These aren’t technology accidents. They reflect the underlying seriousness with which a firm approaches its compliance obligations, obligations that exist specifically to protect the investors trusting them with their money.
The SEBI registration number is no longer visible in SEBI’s active registered intermediaries list. For any trader or investor, that alone is reason enough to pause before proceeding.
Before you subscribe to any advisory service, verify active registration, read any enforcement orders, and ask the hard questions upfront. Your capital deserves that level of diligence, every single time.
