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Accuracap Consultancy Services Pvt. Ltd. Corp. Office: 19, 9th Floor, Wave 1st Silver Tower, Sector-18, Noida- 201301 (U.P.)

Phone: 0120-4272370 Website: www.accuracap.com

Regd. Office: 2nd Floor, 61, Panchkuian Road, Delhi-110001

CIN: U74140DL2009PTC187215

ACCURACAP CONSULTANCY SERVICES PRIVATE LTD.

DISCLOSURE DOCUMENT

FOR

PORTFOLIO MANAGEMENT SERVICES

i) This document has been filed with the Securities and Exchange Board of India (SEBI) along with

the certificate in the prescribed format in terms of Regulation 22 of SEBI (Portfolio Managers) Regulations, 2020.

ii) The purpose of this document is to provide essential information about the portfolio services in

a manner to assist and enable the investors in making informed decision for engaging Accuracap Consultancy Services Pvt. Ltd. as a Portfolio Manager.

iii) The necessary information about the Portfolio Manager required by an investor before investing

is provided in the Document and investors are also advised to retain the Document for future reference.

iv) The name, phone number, email address of the principal officer so designated by the portfolio manager is as below

Mrs. Shreya Gupta, Fund Manager - Portfolio Management Services Accuracap Consultancy Services Private Limited Office No. 919, 9thFloor, Wave 1st Silver Tower, Sector- 18, Noida- 201301 Telephone: 9654757090 E-mail: [email protected]

http://www.accuracap.com/

mailto:[email protected]




CIN: U74140DL2009PTC187215

FORM C

SECURITIES AND EXCHANGE BOARD OF INDIA (PORTFOLIO MANAGERS) REGULATIONS,2020

(Regulation 22)

ACCURACAP CONSULTANCY SERVICES PVT. LTD

Office No. 919, 9thFloor, Wave 1st Silver Tower, Sector- 18, Noida- 201301 Telephone: 0120-4272370 Email: [email protected]

We confirm that:

1. The Disclosure Document forwarded to the Board is in accordance with the SEBI (Portfolio Managers) Regulations, 2020 and the guidelines and directives issued by the Board from time to time;

2. The disclosures made in the document are true, fair and adequate to enable the investors to make a well informed decision regarding entrusting the management of the portfolio to us / investment in the Portfolio Management.

3. The Disclosure Document has been duly certified by an independent chartered accountant- M/s Sanjiv Syal & Associates, New Delhi, Phone: 011-23586204, Membership No.: 083440 on 12.07.2020.

Date :21/07/2020 Signature of the Principal Officer Place: Noida ( Shreya Gupta)

Accuracap Consultancy Services Private Limited Office No. 919, 9thFloor, Wave 1st Silver Tower, Sector- 18, Noida- 201301Telephone: 0120-4272370 E-mail: [email protected]






CIN: U74140DL2009PTC187215

INDEX

Item No. Contents Page No.

1 Disclaimer Clause 1

2 Definitions 1

3 Description i. History and Background of Portfolio Manager ii. Present Activities of Portfolio Manager iii. Details of Promoters & Directors of Portfolio Managers and

their background. iv. Details of Group Companies of Portfolio Manager v. Details of services being offered

3 4 4 5 5

4 Penalties, pending litigations or proceedings, findings of Inspection or Investigations

6

5 Services offered 7

6 Risk factors 11

7 Client representation 13

8 Financial performance of Portfolio Manager 14

9 Portfolio management performance of the Portfolio Manager 14

10 Audit Observation 16

11 Nature of expenses 16

12 Taxation 18

13 Accounting policies 26

14 Investor services 27


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1) Disclaimer Clause This document has been prepared in accordance with the Securities and Exchange Board of India (Portfolio Managers) Regulations 2020 and it has been filed with the SEBI. The document has neither been approved nor disapproved by SEBI nor has SEBI certified the accuracy or adequacy of the contents of this Document. 2) Definitions

Application’ means the application made by the Client to the Portfolio Manager to place its funds and/or securities with the Portfolio Manager for Portfolio Management Services. Upon execution of the Agreement by the Portfolio Manager, the Application shall be deemed to form an integral part of the Agreement, Provided that in case of any conflict between the contents of the application and provisions of the agreement, the provisions of the agreement shall prevail. Assets’ means (i) the Portfolio and/or (ii) the Funds. AUM’ means Assets under Management. Benchmark Indices’ means BSE 100, BSE 500, BSE Midcap or BSE Small cap etc. Board’ means the Securities and Exchange Board of India established under sub-section (1) of Section 3 of the Securities and Exchange Board of India Act. Chartered Accountant’ means a chartered accountant as defined in clause (b) of sub-section (1) of section 2 of the Chartered Accountants Act, 1949 (38 of 1949) and who has obtained a certificate of practice under sub-section (1) of section 6 of that Act; Client or Investor’ means any person/entity that enters into the Client Agreement with the Portfolio Manager for availing the Portfolio Management Services. Client Agreement’ means the agreement executed between the Client and the Portfolio Manager for providing Portfolio Management Services to that Client and stating therein the terms and conditions on which the Portfolio Manager shall provide such Portfolio Management Services to that Client. Custodian’ means the entity appointed as custodian by Portfolio Manager from time to time and on case to case basis to provide custodial services and to act as a custodian on the terms and conditions as are agreed between the Custodian and the Portfolio Manager. Presently, Accuracap has appointed ORBIS Financial Corporation Ltd. as custodians for its Portfolio Management Services. Depository’ means depository as defined in the Depositories Act, 1996. Depository Account’ means any account of the Client or for the Client with an entity registered as a depository participant as per the relevant regulations in which the Securities comprising part of the Portfolio of the Client are kept by the Portfolio Manager.

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Disclosure Document’ means this Disclosure Document dated 21st July, 2020 for offering Portfolio Management Services. Discretionary Portfolio Management Services’ means Portfolio Management Services where the Portfolio Manager exercises or may, under a contract relating to portfolio management exercise any degree of discretion as to the investments or management of the portfolio of Securities or the Funds of the Client, as the case may be. Financial year’ means the year starting from April 1st of a year and ending on 31st March the following year. Funds’ means the money placed by the Client with the Portfolio Manager and any accretions thereto. Investment Advisory Services’ means the services, where the Portfolio Manager advises Clients on investments in general or gives specific advice required by the Clients and as agreed upon in the Agreement. Non-Discretionary Portfolio Management Services’ means Portfolio Management Services where a Portfolio Manager acts on the instructions received from the client with regard to investment of the funds of the client under a contract relating to Portfolio Management and will exercise no discretion as to the investment or management of the portfolio of securities or the funds of the client, as the case may be. Portfolio’ means the securities managed by the Portfolio Manager on behalf of the Client pursuant to the Portfolio Investment Management Agreement and includes any Securities mentioned in the Application, any further securities placed by the Client with the Portfolio Manager for being managed pursuant to the Portfolio Investment Management Agreement, securities acquired by the Portfolio Manager through investment of funds and bonus and rights shares or otherwise in respect of securities forming part of the Portfolio, so long as the same is managed by the Portfolio Manager. Portfolio Manager’ means Accuracap Consultancy Services Pvt. Ltd., who pursuant to a contract or arrangement with a client, advises or directs or undertakes on behalf of the client (whether as a discretionary Portfolio Manager or otherwise) the management or administration of a portfolio of securities or the funds of the client, as the case may be; Portfolio Management Services’ means the Discretionary Portfolio Management Services or Non-Discretionary Portfolio Management Services or Investment Advisory Services, as the context may require. Principal Officer’ means an employee of the Portfolio Manager, who has been designated as such by the Portfolio Manager. Regulations’ means the Securities and Exchange Board of India (Portfolio Managers) regulations, 2020 including the Rules, Guidelines or Circulars issued in relation thereto from time to time.

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SEBI’ means Securities and Exchange Board of India established under the Securities and Exchange Board of India Act, 1992. Securities means “Securities” as defined under the Securities Contracts (Regulations) Act, 1956 as amended from time to time and includes: i) Shares, scrips, stocks, bonds, debentures, debenture stock or other marketable securities of a

like nature in or of any incorporated company or other body corporate;

a) Derivative; b) Units or any other instrument issued by any collective investment scheme to the investors

in such schemes; c) Security receipt as defined in clause(zg) of section 2 of the Securitization and Reconstruction

of Financial Assets and Enforcement of Security Interest Act, 2002; d) Units or any other such instrument issued to the investors under any mutual fund scheme; e) Government securities;

ii) Such other instruments as may be declared by the Central Government to be securities; iii) Rights or interest in securities iv) Exchange Traded Funds v) Liquid Funds The terms that are used herein and not defined herein, except where the context otherwise so requires, shall have the same meanings as are assigned to them under the Regulations, as may be in force and as amended from time to time. 3. DESCRIPTION

(i) History, Present Business & Background of Portfolio Manager History and Background of the Portfolio Manager

Accuracap Consultancy is primarily focused on financial services and specializes in Portfolio Management, research and advisory services. Accuracap is acting as a financial intermediary for Indian stock markets being a registered Portfolio Manager and a sub-broker with India’s leading broking house Motilal Oswal Securities Ltd. for both National Stock Exchange and Bombay Stock Exchange. The present structure of the company is based on the following developments: -

➢ Accuracap Consultancy Services Pvt. Ltd. was incorporated as a private limited company on February 03, 2009.

➢ It started its business in equity trading as registered Sub Broker of Motilal Oswal Ltd. in July 2009.

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➢ In December 2009, AccuraCap Consultancy Services Pvt. Ltd. has been recognized and feted by Motilal Oswal for being one of its fastest growing associates.

➢ In January 2010, Company started offering equity research services in Indian equity markets to select clients.

➢ In April 2010 Company obtained an ARN from AMFI and started the activities in Mutual Fund distribution business.

➢ In March 2011, Accuracap Consultancy Services has obtained a certificate from SEBI to act as a Portfolio Manager under Securities & Exchange Board of India (Portfolio Manager) Regulations 1993.

(ii) Present activities of the Portfolio Manager Accuracap Consultancy Services Pvt. Ltd. is a registered Portfolio Manager with a Certificate of

Registration from SEBI vide Registration No. INP000004037. Accuracap Consultancy Services is a private limited company registered under the provisions of the Companies Act, 1956 having its corporate office at ‘Office No. 919, 9thFloor,Wave 1st Silver Tower, Sector- 18, Noida- 201301, Tele: 0120-6612345’ and Registered office at 61, 2nd Floor, Panchkuian Road, New Delhi, India -110001.

Accuracap Consultancy Services Pvt. Ltd. is also dealing in NSE and BSE as a registered sub broker with Motilal Oswal Securities Ltd. Currently AccuraCap offerings includes Portfolio Management Service and Brokerage. (iii) Details of Promoters & Directors of Portfolio Managers and their background. Mrs. Dipika Nagpal and Mrs. Nidhi Gupta are the two promoter directors of the company. The details about their qualifications and experience is as follows:

S.No.

Name of Director & Date of Appointment

Qualification Brief Experience

1. Mrs. Dipika Nagpal (3rd February 2009)

M.Phil (Delhi School of Economics), M.Com (Delhi University), AMFI Certified

Has around Nine years’ experience of handling Research, Operations and Marketing at Accuracap Consultancy Services Pvt. Ltd. She also has around Four years’ experience of being a lecturer at Delhi University. She was an AMFI certified Mutual Fund advisor and advising to large HNI’s on their Mutual Fund investments for a long.

2. Mrs. Nidhi Gupta (3rd February 2009)

BFA (Jaipur University)

Has around Nine years’ experience of managing Administration and HR at Accuracap Consultancy Services Pvt Ltd. She also has Four years of experience in administration management in Al Jubail Hospital and Al Muwasat Hospital, Saudi Arabia.

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(iv) Details of Group Companies There is no associate or subsidiary entity of the Accuracap Consultancy Services Pvt. Ltd. (v) Details of services being offered Portfolio Manager offers Discretionary, Non – discretionary and Advisory Services as per individual client agreement. The main features of services being offered are as follows: a) Discretionary Services

Under these services, the choice as well as the timings of ability to make the investment decisions on an on-going basis rest solely with the Portfolio Manager. The Portfolio Manager may at times and at its own discretion, adhere to the views of the Client pertaining to the investment / disinvestments decisions of the Client’s Portfolio. The Portfolio Manager shall have the sole and absolute discretion to invest in respect of the Client’s account in any type of security as per the Client agreement and make such changes in the investments and invest some or all of the Client’s account in such manner and in such markets as it deems fit. The Client may give informal guidance to customize the portfolio; however, the final decision rests with the Portfolio Manager. The securities invested / disinvested by the Portfolio Manager for Clients in the same Product/Option may differ from one Client to another Client. The Portfolio Managers’ decision taken in good faith towards deployment of the Clients’ account is absolute and final and can never be called in question or be open to review at any time during the currency of the Client agreement or any time thereafter except on the ground of malafide, intent, fraud, conflict of interest or gross negligence. This right of the Portfolio Manager shall be exercised strictly in accordance with the Regulations. Under these services, the Clients may authorize the Portfolio Manager to invest their Funds in specific financial instruments or a mix of specific financial instruments or restrict the Portfolio Manager from investing in specific financial instruments or securities. Periodical statements in respect of Client’s Portfolio shall be made available to the respective Clients.

(b) Non-Discretionary Services

Under these services, the Client decides their own investments, with the Portfolio Manager only facilitating the research and execution of transactions. The Portfolio Manager’s role would include but not limited to providing research, structuring of clients’ portfolios, investment advice, and guidance and trade execution at the Client’s request. The Portfolio Manager shall execute orders as per the mandate received from Clients. The deployment of the Client’s Funds by the Portfolio Manager on the instructions of the Client is absolute and final and can never be called in question or shall not be open to review at any time during the currency of the Client agreement or at any time thereafter except on the ground of malafide, fraud, conflict of interest or gross negligence. The rights and obligations of the Portfolio Manager shall be exercised strictly in accordance with the Act, Rules and/or Regulations, guidelines and notifications in force from time to time. Periodical statements in respect of Client’s Portfolio shall be sent to the respective Clients.

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(c) Investment Advisory Services

Under these services, the Portfolio Manager advises both Individual & Institutional Clients on investments in general and any specific advice required by the Clients and agreed upon in the Client agreement. The Portfolio Manager will render the best possible advice to the client having regard to the client’s needs and the environment, and his own professional skills. The same can be binding or non - binding in nature or in such terms as mentioned in the Client agreement. For such services, the Portfolio Manager charges the Client a fee for services rendered mentioned in the Client agreement. The advice may be either general or specific in nature and may pertain to a particular portfolio. The Portfolio Manager shall be solely acting as an advisor in respect of Portfolio of the Client and shall not be responsible for the investment / divestment of securities and / or administrative activities of the Client’s Portfolio.

Minimum size of Investment The client would need to invest/ start with a minimum portfolio of Rs. 50 lacs Investment Horizon A minimum investment horizon of one year is preferred.

4. PENALTIES, PENDING LITIGATION OR PROCEEDINGS, FINDINGS OF INSPECTIONS OR INVESTIGATIONS FOR WHICH ACTION MAY HAVE BEENTAKEN OR IN THE PROCESS OF BEING TAKEN BY ANY REGULATORY AUTHORITY.

1 All cases of penalties imposed by the Board or the directions issued by the Board under the Act or Rules or Regulations made there under;

NIL

2. The nature of the penalty/direction.

Not Applicable.

3. Penalties imposed for any economic offence and/ or for violation of any securities laws.

NIL

4. Any pending material litigation/legal proceedings against the portfolio manager/key personnel with separate disclosure regarding pending criminal cases, if any.

NIL.

5. Any deficiency in the systems and operations of the portfolio manager observed by the Board or any regulatory agency.

NIL

6. Any enquiry/ adjudication proceedings initiated by the Board against the portfolio manager or its directors, principal officer or employee or any person directly or indirectly connected with the portfolio manager or its directors, principal officer or employee, under the Act or Rules or Regulations made thereunder.

NIL

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5. SERVICES OFFERED Investment Objectives The objective of the investment/s is to generate capital appreciation by investing mainly in equities and equity oriented mutual funds units, according to the risk-return profile of investors. The products will have a quantitative driven asset allocation which issued to construct portfolio to suit to a specific profile. Investment Policy

a) To build the portfolio for its PMS products, Accuracap would focus on analyzing stocks based on sound fundamentals using a unique blending algorithm of Growth and Value parameters with the help of software programs.

b) Using this algorithm, a number of stocks at reasonable valuation will be arrived at, after which

a diversified portfolio will be formed keeping in mind not to allocate disproportionately large amount of funds to any particular stock or sector.

c) The product will follow a “long-only” strategy and so will not indulge in any attempts to make

profits through short selling.

d) The portfolio will be reviewed regularly and will typically be rebalanced once a quarter. However the frequency of review might vary based on several factors like market and economic conditions, portfolio valuations etc.

Products offered

a) To cater to the different needs and risk profile of different investors, the Portfolio Manager is offering Five different products. The portfolios under these products will be customized as per the risk profiles of the investors and will have stocks as per the investment philosophy of

these products. The brief Details about portfolio strategy of these products are as

follows:-

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1) AccuraCapAlphaGen

Product Profile The objective of the strategy is to achieve capital appreciation by investing through a diversified Combination of Large, Mid and Small Cap Stocks across multiple sectors.

Universe of Investment Stocks typically comprising the top 700 largest companies by market capitalization on BSE.

No. of companies in the portfolio Generally, 30 to 40 but can vary

Risk Relative to Market Medium Volatility due to combination of large, mid and smallcap companies

Liquidity High to Medium

Return will be benchmarked against BSE 500*.

*Applicable from 01.01.2016. Earlier the portfolio was benchmarked against BSE 100 & BSE Small Cap indices

2) AccuraCap Alpha10

Product Profile The Investments under the strategy will predominately comprise of stocks having Larger Market Caps. The objective is to outperform the BSE 100 Index through constructing a relatively stable portfolio with high level of liquidity and lower impact cost.

Universe of Investment Stocks typically comprising the top 200 largest companies by market capitalization on BSE.

No. of companies in the portfolio Generally, 10 to 20

Risk Relative to Market Being predominantly large cap portfolio, is typically less volatile than smaller companies

Liquidity High

Return will be benchmarked against BSE 100 Index

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3) AccuraCap Pico Power

Product Profile The strategy seeks to provide capital appreciation by investing primarily in stocks having Small Market Caps with high growth potential. The objective of the strategy is to outperform the returns generated by BSE Small Cap Index

Universe of Investment Small Cap: Stocks typically falling within the top 700 largest companies by market capitalization on BSE.

No. of companies in the portfolio Generally, 30 to 40

Risk Relative to Market Being predominantly smaller companies, the volatility expected is high

Liquidity Medium to low

Return will be benchmarked against BSE Small cap Index.

4) AccuraCap DYNAMO

Product Profile The strategy seeks to provide capital appreciation by investing in relatively attractively valued stocks across Market Caps with high growth potential. The objective of the strategy is to outperform the returns generated by BSE 500.

Universe of Investment Stocks typically falling within the top 1000 largest companies by market capitalization on BSE.

No. of companies in the portfolio Can vary based on market conditions. Typically from 20-50 stocks.

Equity Exposure Between 0-100% (depending upon the market conditions)

Risk Relative to Market Medium to High

Liquidity Being a multicap strategy liquidity is between medium to high

Return will be benchmarked against BSE Small Cap index

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Duration / Maturity period Earlier of Three years from the date of investment OR the month end in which Market value of Investment becomes double.

5) AccuraCapAlphaGenR

Product Profile The objective of the strategy is to achieve capital appreciation by investing through a diversified Combination of Large, Mid and Small Cap Stocks across multiple sectors. Key differences between

AccuraCap AlphaGenR and AccuraCap

AlphaGen are that:

1. AccuraCap AlphaGenR scheme

will not have sectoral exposure caps

and can make concentrated bets on a

few sectors with the goal to increase

returns.

2. Based on various macro events, company specific events as well as other market relevant

developments, AccuraCap

AlphaGenR will try to churn and

rebalance the portfolio in a timely

manner.

3. AccuraCap AlphaGenR will try to capitalize on both long term as well as short term opportunities.

On the other hand, AccuraCap

AlphaGen primarily focuses on

generating long term gains. Universe of Investment Stocks typically comprising the top 800

largest companies by market capitalization on BSE.

No. of companies in the portfolio Generally, 30 to 40 but can vary

Risk Relative to Market Medium Volatility due to combination of large, mid and smallcap companies

Liquidity High to Medium

Return will be benchmarked against BSE 500*.

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6. RISK FACTORS

The investment made in securities are subject to market risks and there is no assurance or guarantee that the value of or return on the investments made will always appreciate, it could depreciate to an unpredictable extent and largely dependent on capital market conditions. Following are the risk factors as perceived by the Portfolio Manager.

▪ Investment in equities, derivatives and mutual funds etc. are subject to market risks and there is no assurance or guarantee that the objective of investments will be achieved.

▪ As with any investment in securities, the value of the portfolio can go up or down depending upon the factors and forces affecting the capital markets. Accordingly, the investment decisions made by the Portfolio Manager may not always be profitable.

▪ The performance of the portfolio may be affected by changes in Government policies, general levels of interest rates, currency rates, taxation laws and risks associated with trading volumes, liquidity and settlement systems in equity and debt markets.

▪ The Portfolio Management Service is subject to risk arising from the investment objective, investment strategy and asset allocation.

▪ The Portfolio Management activities have been launched by the company from April’ 2011only, and prior to that the Portfolio Manager has no experience related to portfolio management. However, the Principal Officer so designated by the Portfolio Manager has the relevant experience to manage the Portfolio Management Services.

▪ The past performance of the Portfolio Manager does not indicate its future performance of the same product or any other present or future product/s of the Portfolio Manager.

▪ The performance of the Asset of the Client may be adversely affect by the performance of the individual securities, changes in the market place and industry specific and macroeconomic factors.

▪ Investment in debt instruments and other fixed income securities are subject to default risk, liquidity risk and interest rate risk. Interest rate risk results from changes in demand and supply for money and other macroeconomic factors and creates price changes in the value of the debt instruments. Consequently, the value of the portfolio may be subject to fluctuation.

▪ Investments in debt instruments are subject to reinvestment risks as interest rates prevailing on interest amount or maturity due dates may differ from the original coupon of the bond, which might result in the proceeds being invested at the lower rate.

▪ The Portfolio Manager may invest in non-publicly offered debt securities and unlisted equities. This may expose the client’s portfolio to liquidity risks.

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▪ Engaging in securities lending is subject to risk related to fluctuations in collateral value/settlement/liquidity/counter party.

▪ The Portfolio Manager may use derivatives instruments like index futures, stock futures and options contracts, warrants, convertible securities, swap agreements or any other derivative instruments for the purpose of hedging and portfolio balancing, as permitted under the Regulations and guidelines. Usage of derivatives will expose the Portfolio to certain risks inherent to such derivatives. As and when the Portfolio Manager deals in the derivatives market on behalf of the client, there are risk factors and issues concerning the use of derivatives that investors should understand.

▪ Derivative products are specialized instruments that require investment techniques and risk analyses different from those associated with stocks and bonds. The use of a derivative requires an understanding not only of the underlying instrument but of the derivative itself. Derivatives require the maintenance of adequate controls to monitor the transactions entered into, the ability to assess the risk that a derivative adds to the portfolio and the ability to forecast price or interest rate movements correctly. There is the possibility that a loss may be sustained by the portfolio as a result of the failure of another party (usually referred to as the “counter party”) to comply with the terms of the derivatives contract. Other risk in using derivatives include the risk of mispricing or improper valuation of derivatives and the inability of derivatives to correlate perfectly with underlying assets, rates and indices. Thus, derivatives are highly leveraged instruments. Even a small price movement in the underlying security could have a large impact on their value.

▪ The value of the securities may be affected by changes in settlement periods and transfer procedures. The liquidity of the investments made by the Portfolio may be restricted by the trading volumes, settlement periods and transfer procedures. Different segments of the Indian financial markets have different settlement periods and such periods may be extended significantly by unforeseen circumstances leading to delays in receipt of proceeds from sale of securities.

▪ Investors are not being offered any guaranteed or indicative returns through any of the Product / Options. The investments may not be suited to all categories of investors.

▪ The names of the Product do not in any manner indicate their prospects or returns.

▪ The investments made are subject to external risks such as war, natural calamities, and policy changes of Local/International markets which affect stock/capital markets.

▪ Risk arising out of non-diversification: The investment objectives of one or more of the portfolio management Product / Options could result into concentration on a specific asset/ asset class/sector/ issuer etc., which could lead to non-diversified portfolio which tends to be more volatile than diversified portfolio.

▪ In the interest of investors, the Portfolio Manager may, at its sole discretion, invest/advise to invest up to 100% of the portfolio in liquid and / or debt mutual fund schemes. Moreover, the

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Portfolio Manager may at its sole discretion decide not to apply to the securities and return the funds to investors, in case there is any change in the risk/return profile of the portfolio in the backdrop of changed market conditions or for any other reason that the Portfolio Manager may deem appropriate.

▪ The Portfolio Manager is neither responsible nor liable for any losses resulting from the operations of the portfolio management services.

▪ Performance of the portfolio/s may be impacted as a result of specific investment restrictions, if any provided by the client.

▪ The tax implications provided in this document is for general purposes only and is based on advice that the Portfolio Manager has received regarding the law and the practice that is currently in force in India and the client should be aware that the relevant fiscal rules and their interpretation may change. As is the case with any investment, there can be no guarantee that the tax position or the proposed tax position prevailing at the time of investment in the Portfolio will endure indefinitely. In view of the individual nature of tax consequences, each client is advised to consult his/her own professional tax advisor.

▪ To implement a decision of the client regarding investments, the Portfolio Manager would have to take the services of persons and bodies that are not the Portfolio Manager’s employees and rely on them. While the Portfolio Manager, would exercise all care and take all precautions while employing such persons, it should be understood that the Portfolio Manager would not be liable for any act or omission on the part of such persons engaged by the Portfolio Manager for the purpose of making an investment or disposing off an investment and that the Portfolio Manager would not be liable for any loss caused by any act or omission on the part of such person.

▪ The Portfolio Manager will also not be liable for any bona fide act of omission or commission or delay in carrying out the instructions of the client.

▪ Clients are advice to review/study this disclosure document carefully and consult their own professional advisors on legal, taxation, financial matters before investing.

7. CLIENT REPRESENTATION

i)

Category of Clients No. of Clients* Funds Managed* (Rs Cr.)

Discretionary/ Non-Discretionary/ Investment Advisory

Associates/ Group Companies

2 506.23 Investment Advisory Only.

Others 341 421.73 Discretionary

Others 6 29.83 Investment Advisory Only.

*As on 30th June 2020

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ii) Related Party Transactions i) During the 18-19 and 19-20 Company has paid a sum of Rs. 23.04 Lakhs and Rs. 8.61

Lakhs respectively to the directors as Salary & Bonus respectively. Also, Company has paid Rs. 17.45 Lakhs and 11.85 Lakhs to the CEO and CIO respectively of the company as Salary during the FY 19-20

ii) The Investment Advisory Corpus of Rs.506.23 Crs (shown above) belongs to the relatives of the Promoters/ Directors of the Company.

8. FINANCIAL PERFORMANCE OF THE PORTFOLIO MANAGER

Financial performance (audited) of the Portfolio Manager for the last 3 financial years is as under:- (Rs. in Lacs)

Particulars 2018-19 2017-2018 2016-2017

Gross Income 856.07 1155.5 967.18

Gross Expenses 590.86 746.3 504.33

Profit Before Tax 265.20 409.26 462.85

Provisions for Tax 53.29 99.47 143.65

Provisions for Deferred Tax/Credit/Short, Excess of prev. Year

-0.26 0.85 2.15

Profit After Tax 212.17 308.94 317.04

9. PORTFOLIO MANAGEMENT PERFORMANCE OF THE PORTFOLIO MANAGER Each investor’s individual returns would depend on the time of their investments as also the specific portfolios made for them. Hence each investor’s experienced returns may be different than the performance of the overall fund reported on a weighted average basis. However, in the spirit of full disclosure & transparency, we are presenting the portfolio performance numbers as on 30 June, 2020 on the basis of three different methodologies as explained below: i) Accuracap Alpha10 Portfolio:

Particulars Methodol-ogies

Current Year Performance ((1st April, 2020- 30th Jun , 2020)

Year 1 Performance (1st April, 2019- 31st Mar , 2020)



Portfolio Performance (%), Net of all fees and charges levied by the portfolio manager

TWRR

15.20%

-10.50%

10.40%

14.60%

Benchmark Performance % (BSE 100)

20.10%

-26.60%

12.40%

10.60%

*Product offered from September 19, 2011

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(ii) Accuracap Pico Power Portfolio:

Particulars Methodologies Current Year Performance ((1st April, 2020- 30th Jun , 2020)





TWRR 26.40%

-26.10% -20.10% 27.30%

Benchmark Performance % (BSE Small Cap) 28.80% -36.10% -11.60% 17.70%

*Product offered from October 10, 2011 (iii) Accuracap Alpha Gen Portfolio:






TWRR 17.20% -19.00% -7.50% 24.80%

Benchmark Performance %

BSE100 20.10%BSE SmallCap:

28.80% BSE500: 21.10%

BSE100: -26.60%BSE

SmallCap: -36.10% BSE500: -27.50

BSE100: 12.5% BSE

SmallCap: -11.6%

BSE500: 8.4%

BSE100: 10.60%

BSE SmallCap: 17.70%% BSE500: 11.80%

*Product offered from July 6, 2011 # The portfolio has been re-launched as a multi-cap portfolio w.e.f 01.01.2016 and hence the past performance is not at all indicative and comparable with future performance. Also, henceforth portfolio will be benchmarked against BSE500.

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(iv) Accuracap Dynamo Portfolio:






TWRR 34.40% -32.20% -28.20% 43.00%

Benchmark Performance %

BSE

SmallCap

28.80% BSE500: 21.10%

SmallCap: --

36.10%BSE500: -27.50%

SmallCap: -11.6%

BSE500: +8.4%

BSE SmallCap:

+17.7%

BSE500:+11.8%

*Product offered from January 1, 2017 10. AUDIT OBSERVATIONS

As on the date of filing of this disclosure document, for the year ending Mar 31, 2020 audit of financial statement is under process. For the preceding three financial years i,e years ending as on Mar 31, 2018, 2017 and 2016 audit has been concluded with no observations (Unqualified Opinion). 11. NATURE OF EXPENSES

The following are indicative types of costs and expenses to be borne by clients in respect of availing the Portfolio Management services. The exact basis of charge relating to each of the following services shall be annexed to the Client and the agreements of each of the services availed at the time of execution of such agreements.

i) Investment Management & Advisory Fees

Fee Schedule (Distribution)

Investment Amount Option 1: Pure

Management Fee Option 2: Management Fee with Incentive Fee

Less than Rs 5 Crores 2.50% 1.5% + 20%

Rs 5 Crores to less than Rs 10 Crores 2% 1.25% + 20%

Rs 10 Crores to less than Rs 25 Crores 1.50% 1% + 20%

Rs 25 Crores or more 1.25% 0.75% + 20%

Fee Schedule (Direct)

Investment Amount Option 1: Pure

Management Fee Option 2: Management Fee with Incentive Fee

Less than Rs 5 Crores 2.00% 1.00% + 20%

Rs 5 Crores to less than Rs 10 Crores 1.50% 0.75% + 20%

Rs 10 Crores to less than Rs 25 Crores 1.00% 0.50% + 20%

Rs 25 Crores or more 0.75% 0.25% + 20%

*Incentive fees to be charged on High watermark bases

*Hurdle Rate Alpha10 – 10%, PicoPower-12%, AlphaGen-12%, Dynamo-14%

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The above mentioned fee structure is for indicative purpose only. The actual fees charged and the frequency of charging such fee by the Portfolio Manager for each Client shall be determined separately and may vary from Client to Client.

It is further provided that the SEBI circular no. IMD/DF/13/2010 dated October 5, 2010 shall be followed while calculating the Investment Management Fee.

ii) Custodian/Depository Fees: The charges relating to opening and operation of dematerialized

accounts, custody and transfer charges for shares, bonds and units, dematerialization and other charges in connection with the operation and management of the depository accounts. These charges will be charged to the client on actual basis(refer schedule of charges given below)

iii) Brokerage & Transaction Cost: The investments under Portfolio Management would be done through registered members of the Stock Exchange(s), any brokerage paid to them will be charged on actual basis. In addition to the brokerage, other transaction cost/s like turnover charges, stamp duty, services tax, Securities transaction tax or any other tax/charge levied by statutory authority(ies) will be charged. Any load payable on purchase/sale of units of Mutual Funds will also be charged. (Current Charges: 0.12% of the turnover amount +Service Tax +STT and other statutory charges) Specifically, the client is aware that Accuracap Consultancy Services Pvt. Ltd. also operates a sub- brokerage business. The Portfolio Manager may from time to time, purchase, sell or otherwise deal in securities through its sub- broking business, in which event, the Portfolio Manager shall be entitled to charge brokerage charged by sub broking business of Accuracap Consultancy Services Pvt. Ltd. in respect of such transactions.

iv) Goods and Services Tax: As applicable from time to time.

v) Exit fee: As may be mutually agreed to between the Client and the Portfolio Manager.

vi) Certification and Professional Charges: Charges payable for out sourced professional services

like accounting, auditing, taxation and legal services, etc. for documentation, notarizations, certifications, attestations required by bankers or regulatory authorities including legal fees etc. related to the client’s portfolio management will be charged on actual basis.

vii) Incidental Expenses: Charges in connection with day-to-day operations like courier expenses

stamp duty, service tax, postal, opening and operation of bank account, distribution charges or any other out of pocket expenses as may be incurred by the Portfolio Manager in respect of client’s portfolio management will be charged on actual basis.

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SCHEDULE OF OTHER CHARGES

Entity Category Amount Frequency

Orbis Custodian Demat Charges - A/C opening Rs. 500/- One Time

Annual Maintenance charges for DP Rs. 500/- Annual

Demat Transaction charges Rs. 7.00/- per debit transaction As per transaction

Annual Custody Charges 0.1% of daily closing AUM Calculated on daily basis, accrued on monthly basis & charged on monthly basis

Clearing & settlement charges Maximum of (0.01% of transaction amount) or (Rs. 100/-) As per transaction

Broker Brokerage 0.12% As per transaction

STT 0.1% of the transaction amount As per transaction

Indusind Bank PIS approval issuance fee Rs. 500/- One time

Applicable to NRIs Purchase Rs. 50/- per Scrip As per transaction

Sale Rs. 50/- per Scrip As per transaction

Minimum Balance in PIS account NIL

Annual maintenance charges for PIS Account Rs. 500/- Annual

Scrip transfer in / transfer out charges Rs. 50/- per Scrip As per transfer

#There can be charges of notary, franking etc of around Rs. 1000-1500 at the time of opening. #All the above charges are exclusive of GST.

12. TAXATION

The information set out below outlines the tax implications based on relevant provisions of the Indian Income-tax Act, 1961 (“the Act”) as on date. A. General

In view of the individual nature of tax consequences on the income, capital gains or otherwise, arising from investments, each Client is advised to consult / his / her / its tax advisor with respect to the specific tax consequences to him/ her / it of participation in the portfolio management services. The Portfolio Manager shall not be responsible for assisting in or completing the fulfillment of the client’s tax obligations.

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B. Tax Deducted at Source If any tax is required to be withheld on account of any present or future legislation, the Portfolio Manager will be obliged to act in accordance with the regulatory requirements in this regard. C. Advance tax obligations It shall be the Client’s responsibility to meet the obligation on account of advance tax installments payable on the due dates under the Income Tax Act. D. Interest on Securities Income by way of interest on securities is taxable at the slab rates applicable to the assessee under the head “Income from other sources”. E. Securities Transaction Tax Securities Transaction Tax (‘STT”) is applicable on transactions of purchase or sale of equity shares in a company or ETF or a derivative or units of Equity Oriented Funds entered into on a recognized stock exchange and sale of units of Equity Oriented Fund to the Mutual Fund. The STT rates as applicable in the Finance Act 2020, on or after April 1, 2020are given in the following table:

Taxable Securities Transaction Rate Payable by

Purchase of an equity share in a company, where:-

a) The transaction of such purchase is entered into a recognized stock exchange; and

b) The contract of the purchase of such share is settled by the actual delivery or transfer of such share.

0.1%

Buyer

Purchase of a unit of Equity oriented fund, where:-

c) The transaction of such purchase is entered into a recognized stock exchange; and

d) The contract of the purchase of such share is settled by the actual delivery or transfer of such share.

NIL

-

Sale of an equity share in a company, where:

a) The transaction of such sale is entered into in a recognized stock exchange; and

b) The contract for the sale of such share or unit is settled by the actual delivery or transfer of such share or unit.

0.1%

Seller

Sale of a unit of an Equity oriented fund, where:

c) The transaction of such sale is entered into in a recognized stock exchange; and

d) The contract for the sale of such share or unit is settled by the actual delivery or transfer of such share or unit.

0.001%

Seller

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Sale of an equity share in a company, or a unit of an equity oriented fund, where:- a) The transaction of such sale is entered into in a recognized stock exchange; and b) The contract for the sale of such share or unit is settled otherwise than by the actual delivery or transfer of such share or unit.

0.025% Seller

Derivatives: Futures 0.01% Seller

Derivatives: Options a) Where Option is not exercised –

b) Where Option is exercised-

0.05% of option premium. 0.125% on settlement price

Seller Buyer

F. Tax Implications to Different Categories of Investors Income arising from purchase and sale of securities can give rise to business income or capital gains in the hands of the Client. The issue of income characterization as above is essentially a question of fact and dependent on whether the shares are held as Business / Trading assets or on Capital Account. Based on judicial decisions, all of the following factors and principles need to be considered while determining the nature of assets as above:

✓ Motive for the purchase of shares.

✓ Frequency of transactions and the length of period of holding of the shares

✓ Treatment of the shares and profit or loss on their sale in the accounts of the assessees.

✓ Source of funds out of which the shares were acquired – borrowed or own.

✓ Existence of an object clause permitting trading in shares – relevant only in the case of corporate.

✓ Acquisition of the shares – from primary market or secondary market.

✓ Circumstances responsible for the sale of securities.

✓ Infrastructure employed for the share transactions by the client including the appointment of managers, etc.

Any single factor discussed above in isolation cannot be conclusive to determine the exact nature of the shares. All factors and principles need to be construed harmoniously. Further, the background of the investor (Investor v/s. a trader in shares) would also be a relevant factor in determining the nature of the shares. In view of the above, the profits or gains arising from transaction in securities could be taxed either as “Profits or Gains of Business or Profession” under section 28 of the Act or as “Capital Gains” under section 45 of the Act.

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Tax Implications where Transaction in Securities are in the nature of Investments Where investment under the Portfolio Management Services is treated as investment, then the profit or loss from transfer of securities shall be taxed as Capital Gains under section 45 of the Act. Dividend received from an Indian company was exempt until 31 March 2020 (FY 2019-20). That was because the company declaring such dividend already paid dividend distribution tax (DDT) before making payment.

However, the Finance Act, 2020 changed the method of dividend taxation. Henceforth, all dividend received on or after 1 April 2020 is taxable in the hands of the investor/shareholder. if shares are held for trading purposes then the dividend income shall be taxable under the head business or profession. Whereas, if shares are held as an investment then income arising in nature of dividend shall be taxable under the head other sources The DDT liability on companies and mutual funds stand withdrawn. Similarly, the tax of 10% on dividend receipts of resident individuals, HUF and firms in excess of Rs 10 lakh (Section 115BBDA) also stands withdrawn.

The Finance Act, 2020 also imposes a TDS on dividend distribution by companies and mutual funds on or after 1 April 2020. The normal rate of TDS is 10% on dividend income paid in excess of Rs 5,000 from a company or mutual fund. However, as a COVID-19 relief measure, the government reduced the TDS rate to 7.5% for distribution from 14 May 2020 until 31 March 2021.

Long Term Capital Gains

A. Under Section 10(38), Long Term Capital Gains on sale of Equity Shares in a company or units of Equity Oriented Fund are taxable at the rate of 10% over and above 1 lakh(Subject to grandfathering of the highest prices as on 31.01.18) for all categories of investors provided such transactions are entered into a recognized stock exchange or such units are sold to the Mutual Fund and such transactions are chargeable to STT.

B. In respect of Long-term capital gains (other than long-term capital gains on securities

exempted by Sec. 10(38) of the Act,) the provisions for taxation of long-term capital gains for different categories of assesses are explained hereunder:

i. For individuals and HUF’s Long-term Capital Gains in respect of listed security and units of Equity Mutual Fund held for a period of more than 12 months will be chargeable under section 112 of the Act at the rate of 20% plus surcharge, as applicable and cess, Capital gains would be computed after taking into Account cost of acquisition as adjusted by Cost Inflation Index notified by the Central Government and expenditure incurred wholly and exclusively in connection with such transfer. However, where the tax payable on such long-term capital gains, computed before indexation, exceeds 10% of the amount of capital gains, such excess tax shall not be payable by the assessee.

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In case of resident individuals and HUFs, where the total income as reduced by long-term capital gains, is below the basic exemption limit, the long-term capital gains will be reduced to the extent of the shortfall and only the balance long-term capital gains will be subjected to the 20% tax or the 10% as the case may be. The said tax rate would be increased by an applicable Surcharge, Education Cess and Secondary & Higher Education Cess. ii. For Indian Companies Long-term Capital Gains in respect of listed securities and units of Equity Mutual Fund held for a period for more than 12 months will be chargeable under section 112 of the Act at the rate of 20% plus surcharge, as applicable and cess. Capital Gains would be computed after taking into account cost of acquisition as adjusted by Cost Inflation Index notified by the Central Government and expenditure incurred wholly and exclusively in connection with such transfer. It is further provided that an assessee will have an option to apply concessional rate of 10% plus applicable surcharge and cess, provided the long term capital gains are computed without substituting indexed cost in place of cost of acquisition. Tax implications for Non-resident Indians Long-term capital gains arising on transfer of equity shares on recognized stock exchange or units of an equity oriented fund on which STT is paid, are exempt from tax under section 10(38) of the Act. Under section 111A of the Act, income from Short-term Capital Gains arising from transfer of equity shares in a company on recognized stock exchange or a unit of equity oriented fund, on which STT is paid, are taxable @ 15% (plus applicable surcharge and cess). In the case of an assessee of a country with which a DTAA is in force, the tax should be withheld as per provisions in the Act or as per the provisions in the DTAA whichever is more beneficial to the non-resident investor. Under the provisions of section 112 of the Act, long-term capital gains (other than those exempt as above) are subject to tax @ 20% (plus applicable surcharge and cess). Non-resident Indians are permitted to be governed by the general provisions of the Act (same as above except for indexation) or the special provisions contained in section 115E of the Act. Under section 115E of the Act for non-resident Indians, income by way of long-term capital gains in respect of specified assets purchased in foreign currency as defined under section 115C (which includes shares, debentures, deposits in an Indian Company and security issued by central govt.) is chargeable at the rate of 10% (plus applicable surcharge and cess as mentioned in Para 1.3.8). The benefit of indexation is not available to non-resident Indians from transfer of shares or debentures of an Indian company. SHORT-TERM CAPITAL GAINS Under section 111A of the Act, income from Short-term Capital Gains arising from transfer of equity shares in a company on recognized stock exchange or a unit of equity oriented fund, on which STT is paid, are taxable @ 15% (plus applicable surcharge and cess).

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In case of resident individuals and HUFs, where the total income as reduced by short-term capital gains u/s 111A, is below the basic exemption limit, the long-term capital gains will be reduced to the extent of the shortfall and only the balance Short-term capital gains will be subjected to the 15% tax. The said tax rate would be increased by an applicable Surcharge, Education Cess and Secondary & Higher Education Cess. The tax rates applicable to different categories of assesses on Short-term Capital Gains (other than on securities referred above) would be the normal applicable rates. CAPITAL LOSS Losses under the head ‘Capital Gains’ cannot be set-off against income under any other head. Further, within the head ‘Capital Gains’, long-term capital losses cannot be adjusted against short-term capital gains. However, short-term capital losses can be adjusted against both short-term and long-term capital gains. Unabsorbed long-term capital loss can be carried forward and set off against the long-term capital gains arising in subsequent eight assessment years. Unabsorbed short-term capital loss can be carried forward and set off against the income under the head Capital Gains in subsequent eight assessment years subject to the relevant provisions of Income Tax Act 1961. Tax Implications where securities are treated as Business Assets Profits and Gains of Business or Profession The following are the various income streams that can arise from securities held under the PMS:

1. Gains on sale of securities; 2. Dividend income on shares / Income-distributed on units; and 3. Interest income on debt securities.

If the securities under the PMS is regarded as a business/ trading asset, then any gain/ loss arising from sale of such securities would be taxed under the head “Profits and Gains of Business or Profession” under section 28 of the Act. The gain/ loss is to be computed under the head “Profits and Gains of Business or Profession” after allowing normal business expenses (inclusive of the expenses incurred on transfer) as per the provisions of the Act. Dividend received from an Indian company was exempt until 31 March 2020 (FY 2019-20). That was because the company declaring such dividend already paid dividend distribution tax (DDT) before making payment. However, the Finance Act, 2020 changed the method of dividend taxation. Henceforth, all dividend received on or after 1 April 2020 is taxable in the hands of the investor/shareholder. if shares are held for trading purposes then the dividend income shall be taxable under the head business or profession. Whereas, if shares are held as an investment then income arising in nature of dividend shall be taxable under the head other sources. The DDT liability on companies and mutual funds stand withdrawn. Similarly, the tax of 10% on dividend receipts of resident individuals, HUF and firms in excess of Rs 10 lakh (Section 115BBDA) also stands withdrawn. The Finance Act, 2020 also imposes a TDS on dividend distribution by companies and mutual funds on or after 1 April 2020. The normal rate of TDS is 10% on dividend income paid in excess of Rs

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5,000 from a company or mutual fund. However, as a COVID-19 relief measure, the government reduced the TDS rate to 7.5% for distribution from 14 May 2020 until 31 March 2021. Interest income arising on securities may be categorized as ‘Business Income’ or ‘Income from Other Sources’. Any expenses incurred to earn such interest (such as interest expense) would be available as deduction as per the provisions of the Act. STT paid on securities held as a business asset would be allowable as a deduction under section 36(1)(xv) of the Act, subject to the condition that such income from taxable securities transactions is included under the head ‘profits and gains of business or profession’. Business Income is chargeable to tax at the following rates:

Assessee % of Income Tax

Individuals, Hindu undivided family (‘HUF’), Association of Persons

Applicable Slab Rates

Partnership Firms [including Limited Liability Partnerships (’LLPs’)]

30%+ applicable surcharge (if any)and cess

Indian Corporate 15% under section 115BAB, 22% under section 115BAA. Otherwise 30%+ applicable surcharge (if any)and cess In case Gross receipts or Total Turnover of Previous year 16-17 <Rs. 250 crores rate - 25%+applicable surcharge.

Foreign Company 40%+ applicable surcharge (if any) and cess

Losses under the head Profits and Gains of Business or Profession In the case of loss under the head ‘Profits and Gains of Business or Profession’ (other than speculative loss), it can be set off against the income from any other source under the same head or income under any other head (except certain exceptions) in the same assessment year. If such loss cannot be set off against any other head in the same assessment year, then it will be carried forward and shall be set off against the profits and gains of the business (other than speculative loss), within the period of 8 subsequent assessment years. In case the loss is in the nature of speculation loss, set-off would be available in the same assessment year only against speculation gain. In terms of Explanation to section 73, in case of a company, other than a company whose gross total income consists mainly of income which is chargeable under the heads “Income from house property”, “Capital gains and “Income from other sources”, or a company - the principal business of which is the business of banking or the granting of loans and advances, loss on sale of shares forming part of the business of the company (even if delivery based) is considered as speculation loss. Such loss can be carried forward for set-off against speculative gains for a period of four subsequent assessment years. The Act has been amended to exclude derivatives transactions traded on a recognised stock exchange from being treated as a speculative transaction.

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SLAB RATES The slab rates for individuals as per the Finance Act, 2020 are as under:

Slabs % of Income Tax

UptoRs. 2,50,000* Nil

From Rs. 2,50,001 to Rs. 5,00,000 5%

From Rs. 5,00,001 to Rs. 10,00,000 20%

Above Rs. 10,00,000 30%

*Basic exemption limit for senior citizens (Completed 60 years but below 80 years) is Rs. 3.0 lacs The slab rates for Resident individuals (80years and above)as per the Finance Act, 2020 are as under:


UptoRs. 5,00,000 Nil

From Rs. 5,00,001 to Rs. 10,00,000 20%

Above Rs. 10,00,000 30%

* A resident individual (whose net income does not exceed Rs.5,00,000) can avail a rebate of Rs. 12500 or 100% of income tax, whichever is less. *Additionally, Health and education cess @ 4% is leviable on the income tax and surcharge as computed above. New tax regime: Budget 2020 has announced a new tax regime giving taxpayers an option to pay taxes as per the new tax slabs from FY 2020-21 onwards. Any individual opting to be taxed under the new tax regime from FY 2020-21 onwards will have to give up certain exemptions and deductions.


UptoRs. 2,50,000 Nil

From Rs. 2,50,001 to Rs. 5,00,000 5%

From Rs. 5,00,001 to Rs. 7,50,000 10%

From Rs. 7,50,001 to Rs. 10,00,000 15%

From Rs. 10,00,001 to Rs. 12,50,000 20%

From Rs. 12,50,001 to Rs. 15,00,000 25%

Above Rs. 15,00,000 30%

* A resident individual (whose net income does not exceed Rs.5,00,000) can avail a rebate of Rs. 12500 or 100% of income tax, whichever is less. *Additionally, Health and education cess @ 4% is leviable on the income tax and surcharge as computed above.

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13. ACCOUNTING POLICIES The Portfolio Manager shall maintain a separate Portfolio records in the name of the Client in its book for accounting the assets of the Client. The Portfolio Manager shall keep and maintain proper books of accounts, records and documents, for the Client, so as to explain its transactions and to disclose at any point of time the financial position of the Client’s Portfolio. Following Accounting Policies are to be followed for the purpose of maintaining books of accounts & records of the Client. a) Basis of Accounting Financial statement of the Client under Portfolio Management Services shall be prepared and maintained as per the accrual basis of accounting. b) Income Recognition: Dividend income shall be recognized on the ex-dividend date. Interest income on investments shall be accounted on accrual basis. Gains or loss on sale of investments shall be recognized on the trade dates on the basis of first-in-first-out basis. c) Recognition of fees and other expenses Investment Management fees/advisory fee and other charges shall be accrued and charged as agreed in the agreement between the Portfolio Manager and the Client. d) Investments: Investments are stated at cost of acquisition by the Portfolio Manager. Securities shall be marked to market on a daily basis. Securities brought in by the Client shall be valued at the closing price of the Security at NSE. If closing price on NSE is not available, BSE price would be considered. Mutual fund units brought in shall be valued at the NAV for the date on which the corpus is fully credited to the account of the Portfolio Manager. Secondary market transactions shall be recognized as investments on the trade dates at cost including brokerage, service tax and stamp fees and other applicable transaction charges. Subscriptions to primary market issues shall be recognized as investments on allotment. Bonus and/or right entitlements shall be recognized on ex-bonus/ex-right dates. e) Valuation of Investments: (i) Traded Securities: Shall be valued on the basis of closing market prices on the National Stock Exchange ("NSE") as on the relevant valuation date. If the Security is not listed on the NSE, If closing price on NSE is not available or security is not listed on NSE, then BSE price would be considered.

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In the event of this date being a holiday at the exchange, the rates as on the immediately preceding trading day shall be adopted. Unlisted, non- traded and all other securities where value cannot be ascertained shall be valued in good faith. (ii) Mutual Fund units: Investments in units of Mutual Funds shall be valued at the Net Asset Value of the previous day declared for the relevant Scheme on the date of the report. Where no NAV is published for a particular day, the previous working day’s published NAV will be taken for the valuation purpose. Investments in units of close-ended schemes of mutual funds, which are listed on NSE, will be valued at the closing market price on NSE. (iii) Government securities shall be valued at the prices released by an agency recommended by AMFI. Government securities, where prices are not available, shall be valued at yield to maturity based on the prevailing interest rates. (iv)Rights entitlements for shares shall be valued at the market price of the share, reduced by the exercise price payable, and further discounted for dividend element, wherever applicable. (v) Derivatives shall be valued at settlement price declared by NSE on the valuation date. (vi) Gains / loss on derivatives shall be marked to market on daily basis. The accounting policies and standards as outlined above are subject to changes made from time to time by Portfolio Manager. However, such changes would be in conformity with the Regulations. 14. INVESTOR SERVICES (i) Name and Address and telephone number of Investor relation officer who shall attend to

the investor queries and complaints is as follows: Name: Prateek Gupta Designation: Senior Executive- Compliance and Operations Address: Office No. 919, 9thFloor, Wave 1st Silver Tower, Sector- 18, Noida- 201301 Telephone: 0120-4272370 Email: [email protected] (ii) Grievance Redressal and Dispute Settlement Mechanism Accuracap Consultancy Services Pvt. Ltd. endeavor to address all complaints regarding service deficiencies or causes for grievance, for whatever reason, in a reasonable time and manner. Accuracap realizes that quick and effective handling and resolution of customer’s complaints is essential to provide excellent customer service. To achieve this company has a clearly documented policy for redressal of customer grievances. Through this policy, the company shall ensure that a suitable mechanism exists for receiving and addressing complaints from its customers with specific emphasis on resolving such complaints fairly and expeditiously.


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For the timely and proper redressal of client’s complaints and grievances, the Portfolio Manager shall have the following Grievance Redressal and Dispute Handling Mechanism at place: The Portfolio Manager has appointed Mr. Prateek Gupta, Sr Executive- Compliance and Operations as a first point for the redressal of the Client’s complaints. The Client can approach him at below mentioned contacts: Accuracap Consultancy Services Pvt. Ltd. Office No. 919, 9thFloor, Wave 1st Silver Tower, Sector- 18, Noida- 201301 Telephone: 0120-4272370 Mobile No. 09654757090 Email: [email protected] Clients can also email their complaints to a dedicated email ID i.e. [email protected] If the client remains dissatisfied with the remedies offered or the stand taken by above designated person, he/she can contact Ms. Shreya Gupta, Principal officer/Director at: Accuracap Consultancy Services Pvt. Ltd. Office No. 919, 9thFloor, Wave 1st Silver Tower, Sector- 18, Noida- 201301 Telephone: 0120-4272370 Email: [email protected] For disputes or differences arising between the Client and Portfolio Manager which could not be resolved amicably, shall be settled in accordance with and subject to the provisions of the Arbitration and Conciliation Act, 1996 or any statutory requirement, modification or re-enactment thereof for the time being in force. Such Arbitration proceedings shall be held at New Delhi. All the legal actions and proceedings are subject to the jurisdiction of court in Delhi only and are governed by Indian Law.` SEBI COMPLAINTS REDRESS SYSTEM (SCORES) Investor may also register/ lodge their complaints to SEBI through its online portal SCORES (SEBI COMPLAINTS REDRESS SYSTEM). The link to access SCORES is http://scores.gov.in/and investors can file complaints by clicking “Complaint Registration” under “Investor Corner”. SCORES facilitates investors to lodge their complaint online with SEBI and subsequently view its status.



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Names & Signatures of two directors of the Portfolio Manager

S.No. Name of the Director Signature

1

Mrs. Dipika Nagpal

2

Mrs. Nidhi Gupta

Date: 21.07.2020

Place: Noida

TO WHOMEVER IT MAY CONCERN

We hereby certify that the disclosures made in the enclosed disclosure document dated 21/07/2020

prepared and forwarded by Accuracap Consultancy Services private limited in terms of fifth schedule of

regulation 22 of Securities and exchange board of India (Portfolio Manager) regulations,2020 are true,

fair and adequate to enable investors to make a well informed decision.

The certificate is issued on the basis of information and documents produced before us and on the basis

of representations made by Accuracap Consultancy Services private limited.

For Sanjiv syal& Associates

Chartered Accountants

Firm Regn. No.: 02377N

SANJIV SYAL

Membership No.: 083440

Place: New Delhi

Date: 21/07/20

UDIN: 20083440AAAABR8732

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