The Shri Money SEBI order documents how a SEBI-registered research analyst misled clients through employee communications and skipped mandatory disclosures across thousands of recommendations.
Moreover, the firm continued these violations even after receiving a prior administrative warning from SEBI.
At the same time, Shri Money maintained a website that prominently disclaimed guaranteed returns. Here is the complete picture.
Shri Money Review
Shri Money is a Navi Mumbai-based stock market research and advisory platform run by Punit Kumar research analyst as a proprietary firm.
Operating from Office No. 615, Rupa Solitaire, MBP, Mahape, Navi Mumbai – 400710, the firm offers subscription-based research services including equity and F&O recommendations.
Punit Kumar also holds directorship in Shri Money Financial Analytics Private Limited and Market Khiladi Traders Private Limited, and is associated with the Association of Registered Research Analysts of India.
Is Shri Money SEBI Registered?
Shri Money held SEBI Research Analyst registration number INH000008844 under the name Punit Kumar.
However, a search on SEBI’s official RA registry as of May 10, 2026 returns “No record(s) available” for this registration number, meaning the registration no longer appears as an active intermediary on SEBI’s official records.
This can raise the question-is shri money safe in the mind of investors.
Moreover, this is a significant development for any current or prospective subscriber.
Investors must verify intermediary status directly on SEBI’s official registry before engaging with or continuing to pay for any advisory service.
SEBI Order Against Shri Money
SEBI conducted a physical inspection of Shri Money’s operations on February 13, 2024, covering the period April 1, 2022 to February 13, 2024.
The inspection revealed violations across three areas, misleading client communications, missing disclosures in research reports, and absence of rationale behind recommendations.
These findings resulted in two separate SEBI orders, an Adjudication Order dated January 27, 2025 imposing a monetary penalty, and a Final Order dated October 6, 2025 restricting new client acquisition for one month.
1. Background of the Case
Shri Money used around 98 employees for sales and client communication through calls, WhatsApp, and Telegram.
However, SEBI found that the firm failed to maintain mandatory call recordings and chat records while incorrectly claiming the requirement did not apply to research analysts.
Moreover, SEBI inspectors searched the firm’s compliance emails using terms like “assured,” “returns,” and “profit” and identified client communications that crossed regulatory limits.
At the same time, Shri Money continued publishing recommendations without mandatory disclosures even after a prior SEBI warning and also gave false confirmations to its auditor regarding record maintenance.
2. Violations by Shri Money
SEBI established violations across three distinct categories. Each finding comes directly from SEBI’s published adjudication order.
- Misleading Client Communication, WhatsApp Profit Inducement
A Shri Moneyemployee sent WhatsApp messages to client Sanjay Dubey stating, “4L ka profit kara sakta hu” and “if you don’t want to earn, what should I say now.”
The messages offered a specific profit figure without any accompanying risk disclosure.
Based on these assurances, the client paid ₹5,45,000 for the services and later incurred losses. SEBI rejected the firm’s defence that the word “can” merely indicated possibility rather than certainty.
Instead, SEBI held that the messages amounted to fraudulent inducement under PFUTP Regulations when read in their full context.
Moreover, SEBI rejected Punit Kumar’s argument that SEBI registration proved there was no intent to defraud, clarifying that registration does not provide immunity from fraud.
- Failure to Supervise Employee Communications
Shri Money used 98 employees for sales and advisory communications but maintained no client interaction records.
SEBI found that WhatsApp recommendations were sent directly to client Manoj Panda outside the app.
Punit Kumar blamed a technical issue, but SEBI found no supporting communication, logs, or technical records.
As a result, SEBI held that Shri Money failed to supervise employee communications and violated the RA Code of Conduct.
- Missing Mandatory Disclosures in Every Research Report
Regulation 19 requires every research report to disclose financial interests, conflicts, compensation, and disciplinary history.
Shri Money argued that its recommendations were not “research reports” and claimed website disclosures were sufficient.
However, SEBI rejected both defences and clarified that every buy, sell, or hold recommendation qualifies as a research report.
SEBI also noted that Shri Money continued the non-disclosure practice despite receiving a warning in November 2022.
- No Rationale in App Recommendations and Three Physical Reports
Regulation 25(1)(iii) requires research analysts to maintain the rationale behind every recommendation.
However, SEBI found that all app-based recommendations lacked rationale, while several physical reports, including a Bank Nifty 43800 PE call dated November 22, 2023, contained only charts and indicators without any explanatory basis.
Additionally, Shri Money falsely informed its auditor that no research reports existed between April 2022 and March 2023 despite issuing app-based and physical recommendations during that period.
2. Penalty
SEBI Adjudicating Officer Asha Shetty imposed a monetary penalty of ₹10,00,000 under Section 15EB of the SEBI Act.
The order cited misleading client communication, failure to supervise employees, missing disclosures in research reports, and repeated disclosure violations despite a prior administrative warning.
SEBI Final Order Against Shri Money
SEBI’s Whole Time Member Ananth Narayan G. passed a separate Final Order under Section 12(3) of the SEBI Act following an enquiry proceeding.
The WTM confirmed that the WhatsApp inducement to Sanjay Dubey constituted fraudulent conduct under PFUTP Regulations, specifically the 24 Carat Financial Services SAT order which held that promising guaranteed returns is manipulative.
The WTM also confirmed the continuing disclosure violations and absence of rationale in app recommendations.
Taking into account the mitigating factor that a ₹10 lakh penalty had already been paid, the WTM issued a direction, effective immediately from October 6, 2025, prohibiting Shri Money from onboarding new clients for one month.
A copy of the order went to BSE Limited as the RA Administration and Supervisory Body.
Key Takeaways
The Shri Money SEBI order teaches every investor one central lesson, a firm can display correct disclaimers on its website while its employees contradict those disclaimers in every direct client interaction.
- A disclaimer on a website does not protect you from what a sales employee says on WhatsApp.
- Every research recommendation must carry mandatory disclosures, not just on the website, but in the report itself.
- An administrative warning from SEBI that goes unheeded leads to a monetary penalty in the next inspection.
- Registration number “No record available” on SEBI’s registry means the intermediary no longer holds active registered status, verify before paying.
The two orders against Shri Money ₹10 lakh penalty and a new client ban, both stem from conduct that the firm’s own website disclaimers explicitly prohibited.
That gap between published policy and actual employee conduct is what SEBI’s inspection mechanism is specifically designed to find.
How To File A Complaint Against Research Analyst?
If you subscribed to Shri Money, paid fees based on profit promises from a sales executive, or received recommendations without mandatory disclosures, these steps apply.
Step 1: Document All Communications Immediately
Save every WhatsApp message, email, call recording, payment receipt, and subscription record.
Specifically preserve any message where a specific profit figure or loss recovery assurance was given, these are the most relevant evidence for a SEBI complaint.
Step 2: Send a Formal Written Complaint
Write a structured complaint by email and registered post to Shri Money grievance officer.
State the specific communication that induced your subscription, the amount paid, the losses incurred, and the absence of risk disclosures at the time of the communication.
Give the firm 21 days to respond before escalating.
Step 3: File a Complaint in SCORES
File a detailed complaint on SEBI SCORES citing the specific violations, misleading profit inducement, missing disclosures in recommendations, and unsupervised employee communications.
SEBI’s inspection of Shri Moneybegan after complaints were received and keywords like “assured” and “profit” were found in client emails.
Your complaint follows the same evidence-driven path.
Step 4: Register Complaint in SMART ODR
If SEBI SCORES does not resolve the matter, escalate to Smart ODR, SEBI’s Online Dispute Resolution platform.
Register your case, upload your documentation, and request a conciliation session for a structured, regulator-supervised resolution process.
Step 5: Stock Market Arbitration
If trading losses resulted from following Shri Money recommendations, particularly recommendations delivered without mandatory disclosures or rationale, pursue arbitration.
The SAT-established principle from 24 Carat Financial Services that promising returns is manipulative and fraudulent directly supports a compensation claim for losses caused by such conduct. Arbitration produces a binding decision.
Need Help?
If a Shri Money employee promised profits on WhatsApp, sold undisclosed recommendations, or caused losses after subscription payments, we can help you build a stronger investor complaint case.
Our services include:
- Case assessment: we review your WhatsApp records, payment history, and recommendation screenshots to determine which specific SEBI violations apply
- Complaint drafting: we prepare a precise complaint citing PFUTP Regulations, RA Regulation 19 (disclosures), and Regulation 25 (rationale) as established in the Shri Money SEBI order itself
- SCORES and Smart ODR guidance: we walk you through every step of the filing process and ensure the right evidence reaches the right platform
- Arbitration support: we help you build and present your case for trading loss recovery through the dispute resolution framework
Every case remains confidential, evidence-focused, and structured to maximise the strength and clarity of your regulatory and recovery proceedings.
Conclusion
The Shri Money SEBI order, a ₹10 lakh penalty, and a new client ban exposed a firm whose employee communications contradicted its public disclaimers.
SEBI found profit assurances, missing disclosures, absent rationale, and false reporting to the auditor despite prior regulatory warnings.
For investors, the lesson remains simple: a SEBI registration number is only the starting point of verification, not proof of trust.
