Final Order 5

Order Details: COPY OF ORDER
Pdf Text: Bail Application No. 1919/2022
VAIBHAV DIPAK SHAH Vs. DIRECTORATE OF ENFORCEMENT
15.11.2022
Present: Sh. Siddharth Singh, proxy counsel on behalf of Sh. Arun
Khatri, Ld. Special PP for the Department.
Ms. Arveen Sekhon, Ld. Counsel for accused.
Order
1. Vide this order, I propose to dispose off the application
for anticipatory bail filed on behalf of the applicant.
2. Before proceeding to deal with the factual background, it
may be pertinent to note that the bail application of co-accused Rahil
Hiteshbhai Chovatia was disposed off by Ld. Bail Roster Judge, Sh.
Shailender Malik, ASJ-03, Patiala House Courts, New Delhi vide his
order dated 19.10.2022. The facts and circumstances of the present
case have been extensively discussed by the said Ld. ASJ in his order
dated 19.10.2022 and therefore I have relied upon the contents of the
said order and the discussion carried out therein. The said order dated
19.10.2022 is also relevant inasmuch as the role of the present
applicant/accused is at the most akin to, if not less than, the role of the
said co-accused Rahil H. Chovatia. I say this because of the
allegations made in the reply filed by the department and the
observations of the Ld. ASJ in order dated 19.10.2022 to which I will
hereinafter refer.
Vaibhav Dipak Shah Vs. ED Page 1 of 18
-- 1 of 18 --
3. The factual background of the case has been reproduced
in the order dated 19.10.2022 in following words:
“2. Before discussing the grounds taken in bail
application, it is appropriate to precisely discuss the facts
leading to registration of ECIR by the Directorate as well as
arrest of the accused. It appears from the record/reply filed by
the ED that (i)FIR No.14/2021 dated 18.05.2021; (ii) FIR
No.18/2021 dated18.05.2021; (iii) FIR No.19/2021 dated
20.05.2021 were registered by Uttarakhand police for offence
under section 420IPC, 66C and 66D of I.T. Act. In Delhi FIR
No.141/2021 dated29.05.2021 was registered by Special Cell
against unknown persons for offence under section 419, 420,
468, 471 34, 120BIPC as well as section 66D of I.T. Act. Beside
these cases FIR No.08/2021 dated 01.06.2021 for similar
offences was also registered by CID Cyber rime, Karnataka. It
is stated that in all the above mentioned FIRs allegations
against the accused are of cheating public through Apps i.e.
‘Power Bank App’, ‘Tesla Power Bank App’ Ezplan App etc. by
alluring people in guise of diverting the money deposited
through such Apps in short time. It is alleged that many people
were cheated, who deposited money through above mentioned
Apps. Initially money was credited or returned to investors by
10-15% of the amount deposited as interest. However later
money was misappropriated and there was no response from the
executives of the said App. It is alleged that money cheated from
the public in such manner was onward forwarded to bank
accounts of various shell entities through payment gateways like
Vaibhav Dipak Shah Vs. ED Page 2 of 18
-- 2 of 18 --
PayU, Razor Pay as well as by normal banking channels.
3.Among the above mentioned five FIRs, Special Cell of
Delhi Police has also filed the charge sheet in FIR No.141/2021
wherein it is inter alia alleged that amount of Rs.250 crores was
collected through above mentioned payment gateways and more
than five lakh victims were cheated. 15accused have been
charge sheeted. It is inter alia alleged in the charge sheet that
some of the Chinese persons were mastermind of Power Bank
App by fraud and they joined Indian people including CA/CS etc
for forming companies, appointing Directors, opening of bank
accounts, payments gateways and accounts etc. It is stated that
since the offence u/s 419, 420, 468,471 and 120B IPC are
scheduled offences under Part A Paragraph1 of Scheduled
under the PML Act, by the receipt of letter dated10.06.2021
informing about the commission of cheating involving huge
amount of money as alleged in those FIRs, facts regarding
generation of proceeds of crime from scheduled offence and
laundering of such money were investigated and after initial
investigation present ECIR was registered.
4. From investigation conducted by the Directorate uptil
now it is mentioned that during period August 2020 to
June2021, various shell companies M/s Diyabati Technology
Private Limited, M/s Maojaja Technology Pvt. Ltd., M/s Sumyth
Technologies Pvt. Ltd (first layer entities) were either formed or
purchased by Chinese nationals with the help of some Indian
professions being CA/CS etc. It is stated that bank account of
above mentioned first layered shell companies were used for
Vaibhav Dipak Shah Vs. ED Page 3 of 18
-- 3 of 18 --
collecting money from public and cheated money was further
layered/laundered through several bank accounts and dummy
companies like M/s Akash Corporation, M/s Haresh
Corporation,M/s Balaji Traders, M/s Dynamic Fab World, M/s
Jitender Enterprises (being second layer entities) during the
period August2020 to June 2021.
5.It is mentioned in the reply filed by the ED that
analysis of ICICI Bank account no.244605500632 of M/s
Diyabati Technology Pvt. Ltd., ICICI Bank account
no.244605500407 of M/s Maojaza Technologies Pvt. Ltd. and
ICICI bank account no. 244605500408 of M/s Sumyth
Technologies Pvt. Ltd. revealed that huge funds were received in
the above mentioned bank accounts of shell companies and was
transferred to various bank accounts including bank account
no.259023954406 of M/s Akash Corporation being maintained
in IndusInd Bank, bank account no.201004377970 of M/s
Haresh Corporation (second layer entities). It is further in the
allegations that the funds so received in the account of second
layered entities was further layered/laundered by onward
transfer to account no.123805005479 of M/s Sagar Diamonds
Ltd. maintained with ICICI Bank and account
no.201007176105 of M/s Patel Rushabh & Co. (being third
layer entities) maintained in IndusInd Bank.
6. It is stated that the funds so received in the account of
M/s Sagar Diamonds Ltd. was further transferred either to its
another account no.039392347980 with SBI for making
Vaibhav Dipak Shah Vs. ED Page 4 of 18
-- 4 of 18 --
payment remittance in the guise of import or IDFC bank
account no.100055588628 and SBI account no.39583280574 of
M/s RHC Global Exports Private Limited (4th layer entities). It
is stated that on the basis of analysis of bank account of M/s
RHC Global Exports Pvt. Ltd., it came in the light that above
remitted huge funds brought during the scam period of
November 2020 to June2021 in the guise of payment towards
imports. It is stated that from the KYC of SBI and IDFC Bank
accounts of above said RHC Global Exports Pvt. Ltd as well as
KYC bank statement of M/s Sagar Diamonds Ltd. it is noticed
that accused/applicant was common Director in both the said
companies.
7.It is stated that accused was summoned on06.07.2022
for recording of his statement on 11.07.2022,however instead of
joining the investigation accused chose to flee to Dubai for
avoiding appearance before the ED. However Bureau of
Immigration detained him on 07.07.2022 and thereafter brought
him to Mumbai Office of ED where statement of the
accused/applicant was recorded on 08.07.2022,13.07.2022,
05.08.2022 as well as on 19.09.2022 at Delhi Office in terms of
section 50 of PML Act. It is further mentioned in the reply filed
by ED to the bail application that accused/applicant has shifted
onus of revealing details on Vaibhav Dipak Shah by stating that
he looks after the affairs relating to trade, export/import of M/s
Sagar Diamonds Ltd. and M/s RHC Global Exports Pvt. Ltd.”
4. Ld. Counsel for the accused has argued that the twin
Vaibhav Dipak Shah Vs. ED Page 5 of 18
-- 5 of 18 --
requirements as required u/s 45 of PML Act are completely fulfilled in
the present case. It is stated that accused has been falsely implicated in
the present case without any effective involvement in laundering of
proceeds of crime. It is stated that transaction between M/s Akash
Corporation and M/s Sagar Diamonds Ltd. is a regular business
transaction. It is stated that M/s Sagar Diamonds Ltd. is into
manufacturing of diamond studded gold jewellery, trading in
diamonds and bullion and that company is into such business since
long i.e. at least the year 2015 and among many of its customers, one
of its customers is M/s Akash Corporation.
5. Ld. Counsel has stated that it is the very case of the
prosecution that there are four layers of companies as on date in the
present case:
1. Diyabati Technology Pvt. Ltd.,
Maojaza Technologies Pvt. Ltd.,
Sumith Technologies Pvt. Ltd.
2. Haresh Corporation,
Akash Corporation.
3. Sagar Diamonds Ltd.
4. RHC Global Exports Pvt. Ltd.
6. The present applicant is related to the third layer entity
i.e. Sagar Diamonds Ltd. alone. Ld. Counsel submits that the co-
accused Rahil who has already been granted bail was in fact related to
both the third and fourth layer of companies and the counsel has relied
Vaibhav Dipak Shah Vs. ED Page 6 of 18
-- 6 of 18 --
upon the reply filed by the department in support of the said
submission.
7. Therefore, at this juncture, the relevant portion of reply
filed by the department is being reproduced:
“10… …... From the KYC of the SBI & IDFC bank
account of M/s RHC Global Exports Pvt. Ltd. And ICICI bank
account statement of M/s Sagar Diamonds Ltd, it is noticed that
Mr. Rahil Chovatia (present applicant/accused) was the common
Director in both the said companies.”
8. It is in fact the case of the department that during
interrogation, accused Rahil H. Chovatia
“12……..instead of revealing the details asked for, he
shifted the onus of revealing the details on Mr. Vaibhav Dipak
Shah stating that Mr. Vaibhav Dipak Shah, his brother-in-law,
only looks after the matter related to the trading, exports/imports
and finance in respect of M/s Sagar Diamond Ltd. and M/s RHC
Global Exports Pvt Ltd.”
9. Ld. Counsel further submits that the department has
itself stated Para 14 of the reply that:
“14….... Further, analysis of the part books of accounts
of M/s RHC Global Exports Pvt. Ltd. & M/s Sagar Diamonds
Ltd and Bank account statements of M/s Akash Corporation, M/s
Patel Rushabh & Co., M/s Haresh Corporation, M/s RHC
Global Exports Pvt Ltd and M/s Sagar Diamonds Ltd, it is
Vaibhav Dipak Shah Vs. ED Page 7 of 18
-- 7 of 18 --
noticed that M/s Sagar Diagmonds Ltd has received funds to the
tune of approx. Rs.160 crores from M/s Akash Corporation, M/s
Haresh Corporation and M/s Patel Rushabh & Co. during the
period from November, 2020 to June, 2021 which is the scam
period.”
10. That even though the department claims that Sagar
Diamonds received funds to the tune of Rs. 160 Crores from the
second layer entities, yet it was department’s own case that only 7.10
crores was being treated as proceeds of crime by the department. He
has relied on Para 19 of the reply which is quoted for ease of
reference:
“19…... Money trail of the POC and the analysis of the
bank accounts involved has revealed that during the scam period
from August, 2020 to June, 2021, POC to the tune of Rs.7.10
crores has been layered through the bank accounts of M/s Akash
Corporation, M/s Pate Rushabh & Co., M/s Haresh
Corporation, M/s Sagar Diamonds Ltd & M/s RHC Global
Exports Pvt Ltd and finally remitted aborad in the guise of
payments towards imports.”
11. Ld. Counsel submits that the recent decision of the
Supreme Court in Vijay Madanlal Chaudhary and Ors. Vs. Union
of India (Supreme Court, 2022) has settled the controversy viz-a-viz
the expression proceeds of crime and the scope of investigation under
PMLA. He has specifically relied on Para 250 to 253 and Para 282 of
Vaibhav Dipak Shah Vs. ED Page 8 of 18
-- 8 of 18 --
the said judgment. He submits that in the present case only five FIRs
are the genesis of investigation and can be treated as predicate
offence. The claim of the Delhi Police that there are more than 5 lakh
victims in the present case, is based on the analysis of bank statements
showing inflow of money in the accounts of first layer companies. He
submits that in the absence of complaints on behalf of large number of
investors or verification by police, the claim is only an assumption.
Even otherwise, the charge-sheet only refers to 25 complainants and
the proceed of crime would have to be construed accordingly. Even
otherwise, he submits that since the money has been received in
regular business transaction by the third layer company associated
with the accused, even if the claim of Delhi Police was believed, there
is no presumption that accused has committed any offence related to
proceeds of crime.
12. Ld. Counsel has next relied upon Section 19 of the PML
Act to contend that the power to arrest can only be exercised if the
department was already in possession of material, and had recorded
the reasons in writing for arrest as also concluded that the accused was
prima facie of guilty of offence of money laundering. He submits that
in the present case, the department has so far not been able to collect
such a material and the claim that the co-accused Rahil H. Chovatia
has given a statement that it is the applicant who is having knowledge
of affairs of the third and fourth layer entities, cannot be considered
legally admissible material. Further, it is not the applicant but the
accused Rahil H. Chovatia who is common to both the third and
Vaibhav Dipak Shah Vs. ED Page 9 of 18
-- 9 of 18 --
fourth layer companies. Therefore, in fact applicant’s case is better
than that of co-accused Rahil H. Chovatia who has already been
admitted to bail.
13. Ld. Counsel for the department has on the other hand
contended that the present applicant is a majority share holder in
Sagar Diamonds and secondly, the statement of accused Rahil H.
Chovatia only indicates that it was the applicant who was running the
affairs of both Sagar Diamonds as well as RHC Global Exports Pvt.
Ltd. and only he could answer or provide the necessary material.
14. Ld. Counsel for the department submits that the Apps
used to collect money from public were introduced in February-March
2021 and the first and second layer companies were formed in the year
2020/2021 and had no previous business and therefore the purpose of
forming such companies was only to commit the fraud.
15. Ld. Counsel submits that even though the department has
only been able to identity Rs. 7.10 Crore as proceeds of crime, it is
likely that if the investigation proceeds, the department may be able to
identify more amount. Ld. Counsel submits that the transactions of
foreign purchase, import in India of diamonds and its subsequent sale
thereof to the second layer companies and then reutilization of the
purchase money for further purchase and import of diamonds is a
sham transaction, cyclic in nature only for laundering money.
16. Ld. Counsel submits that no diamonds were ever
imported or purchased from India and thereafter sold to the second
layer companies but only money was routed through third and fourth
Vaibhav Dipak Shah Vs. ED Page 10 of 18
-- 10 of 18 --
layer companies by the applicant and co-accused Rahil H. Chovatia
and Saurin Shah. Ld. Counsel has stated that the affairs of the
company i.e. Sagar Diamonds need investigation and the same may
reveal large scale money laundering by the said company.
17. Ld. Counsel has relied upon several decisions to contend
that accused persons involved in economic offence ought not to be
admitted to bail and are required to be dealt with sternly.
18. Ld. Counsel has stated the NBWs have already been
issued against the accused and he has relied upon the decision Shafi
S.M. Vs. State of Kerala and Ors. decided on 13.07.2020 by Kerala
High Court to contend that anticipatory bail cannot be granted to a
person qua whom NBWs have been issued and who is not in India.
19. In rejoinder, Ld. Counsel for the applicant stated that
firstly this Court is bound by the observations made by a Court of
equal jurisdiction in the same matter and has claimed parity viz-a-viz
accused Rahil as also relied upon the observations made by the Court
viz-a-viz applicability of Section 45 of PMLA to the present case.
20. He has next relied upon the recent decision of the
Supreme Court in Satender Kumar Antil Vs. CBI and Ors. to
contend that the Supreme Court has stated that merely because
accused is involved in an economic offence that is not itself sufficient
to treat him as a class apart and ultimately the punishment provided
for a particular offence is also required to be considered. He has
further stated that in order to show his bona fides, his client has
already booked his tickets to travel to Delhi from 28.11.2022 to
Vaibhav Dipak Shah Vs. ED Page 11 of 18
-- 11 of 18 --
03.12.2022 and that his client will not only join the investigation but
also cooperate in the same.
21. He has further stated that even though his client has
received the money from second layer companies in a business
transaction, to show his bona fides, his client undertakes to deposit the
entire alleged proceeds of crime to the tune of Rs. 7.10 Crores with
the trial Court and the refund of the same can be made subject to the
outcome of the case or further orders of the Court.
22. I have gone through the material placed before me by
both sides. As on date, the best case of the department against the
accused is that they have identified the flow of Rs. 7.10 Crore as
proceeds of crime to third layer company i.e. Sagar Diamonds from
the second layer companies, which money was thereafter given to the
fourth layer company i.e. RHC Global Exports Pvt. Ltd. The accused
Rahil H. Chovatia is the common factor in both the third and fourth
layer companies whereas the applicant/accused is related to only the
third layer company. In that view of the matter, his case is on a better
pedestal than the case of the accused Rahil.
23. Ld. Counsel has placed on record a chart showing the
documents furnished by the accused to the department through his
other director, which prima facie shows an intent to cooperate in the
present case. However, before saying anything further, I would rely on
the stand taken by the department. Relevant portions of the stand as
contained in Para 10, Para 12, Para 14 and Para 19 have already been
quoted herein above. Besides the aforesaid paragraphs, the stand of
Vaibhav Dipak Shah Vs. ED Page 12 of 18
-- 12 of 18 --
the department as contained in para 20 to 22 is also relevant and is
quoted herein below:
“20. From the analysis of the KYC documents with respect to
IDFC bank account no. 10055588628 & SBI Bank account no.
39583280574 of M/s RHC Global Exports Pvt Ltd and SBI bank
account no. 039392347980 & ICICI bank account no.
123805005479 of M/s Sagar Diamonds Ltd, it is noticed that
Mr. Rahil Chovatia has been authorized signatory on-behalf of
both the companies. Thus, all the payments in the guise of sale
and purchase in both the companies were in his knowledge.
21. Mr. Rahil Chovatia, through his company M/s RHC Global
Exports Pvt Ltd, has entered into bogus transactions with M/s
Sagar Diamonds Ltd, which has received funds of approx.
Rs.160 crores from shell entities M/s Akash Corporation, M/s
Patel Rushabh & Co. and M/s Haresh Corporation during the
scalm period August, 2020 to June, 2021. Further he, through
his company M/s RHC Global Exports Pvt Ltd has also executed
sham transaction with M/s Akash Corporation during November,
2020 to March, 2021.
22. Further it is pertinent to mention here that this Directorate
has identified M/s Sagar Diamonds Ltd and M/s RHC Global
Exports Pvt Ltd for their involvement in the offence of money
laundering by trailing POC to the tune of Rs.7.10 cr.”
24. The above stand of the department also shows that
the role of accused Rahil H. Chovatia was key, even as per the
department. Although, I need not go into the merits of probable
defence at this stage, but a claim that money was sent abroad and
the claim of import of diamonds being raised by the applicant
and third layer company was bogus would have to be seen in the
light of import documentation and clearances obtained from
Vaibhav Dipak Shah Vs. ED Page 13 of 18
-- 13 of 18 --
various departments including customs. Such a claim that entire
transaction is bogus cannot be readily inferred.
25. In any event, at this stage, I may refer to the order
passed by a Ld. Bail Roster Judge, ASJ, Patiala House Courts,
New Delhi dated 19.10.2022 wherein following observations
were made:
“39……. So hon’ble Supreme Court observed in
explicit terms that only such property which is diverted or
obtained directly or indirectly as a result of criminal activity
relating to scheduled offence can be regarded as ‘proceeds of
crime’. The possession of unaccounted property acquired by
legal means may be actionable for tax violations, yet will not be
regarded as ‘proceeds of crime’ unless it constitutes an offence
which is included in the Schedule of PML Act. In order to be
“proceeds of crime”, the property must be derived or obtained
directed or indirectly as a result of criminal activity relating to
schedules offence. In the facts of present case also mere fact
that the investigating agency could locate certain transactions
in the account of M/s Sagar Diamonds Ltd. and M/s RHC
Global Exports Pvt. Ltd., is not itself sufficient to draw an
assumption that the said property/funds forms part of the
‘proceeds of crime’.
40. This Court would refrain from making much observation
on the merits of the matter at this stage as the investigation is
still going on but for deciding the question of bail purpose.
Taking the facts and evidence on the face of it, I am of the view
that I the peculiar facts of the case when accused/applicant as
per allegations is related to fourth layer entity and there being
no evidence of its connection with first or second layer entities,
that fact by itself to my mind makes out the case of satisfying the
requirement of Section 45 of PML Act for the purpose of bail.
26. These observations pertain to an accused who was the
authorized signatory as well as common director in, both, the third and
Vaibhav Dipak Shah Vs. ED Page 14 of 18
-- 14 of 18 --
fourth layer companies and the key accused even as per the
department. The aforesaid observations equally pertain to M/s Sagar
Diamonds Ltd. and judicial discipline requires that these observations
are respected by this Court while holding coordinate jurisdiction. In
the reply filed by the department and during oral arguments, the
department could not convince as to how these observations did not
apply to the case of the applicant.
27. I had put it to the department whether the said order dated
19.10.2022 had been challenged and stayed. The department fairly
stated that a challenged was made to the order dated 19.10.2022,
immediately, before the Hon’ble High Court of Delhi. It was fairly
conceded that the Delhi High Court refused to pass any ex-parte order
of stay in the said matter and only two additional conditions were
imposed by the High Court while issuing notice and the conditions
pertained to a restriction on the movement of the accused Rahil H.
Chovatia out of NCR region and about his whereabouts.
28. I may note here that the judgment of the Kerala High
Court in Shafi S.M (supra) has also been considered by me and the
same does not lay any proposition of law that where a person is out of
India, he cannot be admitted to anticipatory bail at all. In fact the
judgment records that such relief was not available to a person who
does not intend to visit India soon or who had not made out any
definite case that he will come on a particular day. The Court had
noted that a blanket order could not be passed to enable a person to
weild the order whenever he finds pleasure to visit India and thereafter
Vaibhav Dipak Shah Vs. ED Page 15 of 18
-- 15 of 18 --
leave at his pleasure.
29. The entire crux of the matter is that the prima facie
finding of the Court having coordinate jurisdiction as recorded in
order dated 19.10.2022, in the facts and circumstances of the present
case, binds this Court to the extent the observations are applicable to
the third layer company i.e. M/s Sagar Diamonds (whose business
activities I am concerned with while passing this order) and
consequently to the applicant herein.
30. Further, the fact that accused has undertaken to deposit
Rs. 7.10 Crore on being asked by the Court, adequately secures the
alleged proceeds of crime and may also act as a security for ensuring
the presence of the accused during investigation. Merely because
NBWs have been issued, jurisdiction to grant bail is not taken away,
more so when the correspondence reveals that the accused had his
pregnant wife in Dubai and she required medical support. It is not the
case of the department that the accused has no business
transactions/interest in Dubai and his presence in Dubai can only be
attributable to his running away from the country.
31. It may be pertinent to also note here that over the years,
we have noticed that accused persons involved in large scale financial
bunglings, flee from the country, and do not join investigation at all
and years are spent only trying to secure their presence in India by
way of extradition. On the other hand, their presence for the purpose
of investigation and trial can be ensured if the provision for bail is
liberally applied while imposing adequate restrictions securing the
Vaibhav Dipak Shah Vs. ED Page 16 of 18
-- 16 of 18 --
interest of both sides. Often, accused also claim persecution instead of
prosecution to justify their absence.
32. In the present case, considering the grounds of parity
arising out of observations made in order dated 19.10.2022 as also the
fact that accused has shown willingness to deposit the alleged
proceeds of crime amounting to Rs. 7.10 Crore as also that he is
willing to travel to India on 28.11.2022 to join investigation and
cooperate in the same as also the fact that he has no established link
with the establishment of first and second layer companies as also the
fact that Sagar Diamonds has admittedly been in business at least
since the year 2015 (as was submitted during arguments), whereas the
first and second layer companies were formulated in the year
2020/2021, accused is admitted to anticipatory bail and it is directed
that in the event of his arrest he be released on bail on furnishing bail
bond and surety bond in the sum of Rs.25,00,000/- each. The bail shall
also be subject to the following conditions:
(i) The accused shall deposit the sum of Rs. 7.10
Crores within 07 days of passing of this order, as undertaken by his
counsel.
(ii) He will return to India on 28.11.2022 or in no case
beyond end of November 2022 and join investigation and cooperate in
the same.
(iii) The applicant/accused shall not tamper with any
evidence or try to influence any of the witnesses.
(iv) He shall not leave the country without the
Vaibhav Dipak Shah Vs. ED Page 17 of 18
-- 17 of 18 --
permission of this Court.
(v) While in India, he shall make his location available
to the Investigating Officer and shall not leave New Delhi without
prior intimation to the investigating officer as also to the prejudice of
the investigation or the requirement of his presence by the IO on any
given day.
33. Needless to say that in case the accused commits breach
of any of the condition or fails to cooperate in investigation, the
department shall be at liberty to approach the Court seeking
cancellation of bail.
34. Bail application is disposed off in terms thereof.
35. Order dasti.
(Harjyot Singh Bhalla)
Bail Roster Judge/ASJ-04/NDD/PHC/ND
15.11.2022
Vaibhav Dipak Shah Vs. ED Page 18 of 18
-- 18 of 18 --