Gold jewellery maker and exporter Rajesh Exports Ltd, which is facing scrutiny from market regulator Sebi over alleged financial irregularities, on Wednesday said only nine queries raised by the regulator remain unresolved, including one related to the alleged inflation of consolidated revenue by Rs 15.15 lakh crore.
Of the several thousand clarifications sought by Sebi over the past two-and-a-half years, the company has responded to all but nine, Rajesh Exports founder and chairman Rajesh Mehta told PTI.
"All the other eight questions are minor. Even this ninth question is absolutely minor. Sebi has found certain things suspicious and needs more documents," he said.
In an interim order, Sebi alleged that Rajesh Exports inflated its consolidated revenue by Rs 15.15 lakh crore between FY21 and FY25 by attributing outsized revenue to overseas subsidiaries, particularly Switzerland-based Valcambi SA, even though the subsidiary's audited standalone financial statements reflected only a fraction of those figures.
The regulator said the company's financial position may have been misrepresented, noting that a substantial portion of reported revenue was attributed to overseas subsidiaries whose financial statements were not publicly available.
Mehta rejected the allegation, arguing that the discrepancy stemmed from a misunderstanding of Valcambi's financial disclosures.
"Sebi has taken the EBITDA of Valcambi and considered it as revenue. That is the entire confusion - the nucleus of the confusion," he said.
While acknowledging that Valcambi accounts for 97-99 per cent of Rajesh Exports' consolidated revenue, Mehta disputed Sebi's conclusion that the subsidiary's standalone revenue represented only 0.5 per cent of that amount.
"That 0.50 per cent is its EBITDA, not its revenue," he said, adding that audited financial statements of Global Gold Refinery (GGR), Valcambi's holding company, had been submitted to Sebi. The statements were certified by KPMG, he added.
Seeking to illustrate the scale of Valcambi's business, Mehta said the Swiss refinery processes around 900 tonnes of precious metals annually. Of this, about 300 tonnes are processed through toll refining arrangements, while the remaining 600 tonnes involve outright purchase, refining, branding and sale to banks, central banks and bullion dealers.
According to Mehta, processing and selling 600 tonnes annually over five years translates into transactions worth roughly Rs 15.10 lakh crore, the figure that Sebi has questioned.
On GGR, in which Rajesh Exports holds a 5 per cent stake and REL Singapore owns the remaining 95 per cent, Mehta said the entity functions solely as a holding company and does not generate independent revenue.
"GGR only consolidates its subsidiaries' revenues. The exact revenue of Valcambi has been consolidated into GGR. It is the same thing - not higher," he said.
Responding to Sebi's observation that standalone financial statements of material overseas subsidiaries were not available on the company's website, Mehta acknowledged the issue but said the company was prioritising responses to the regulator's pending queries.
"If subsidiary-level data is required as per regulation, we have no hesitation in uploading it," he said.
Sebi's interim order also highlighted transfers of Rs 338.90 crore from Rajesh Exports to promoter-linked personal accounts between April 2020 and September 2025, of which Rs 232.4 crore was subsequently returned.
Mehta maintained that all transactions were legitimate and undertaken for business purposes.
"There is no diversion of even a single rupee," he said, adding that complete details had been submitted to the regulator.
Asked why the transactions were not disclosed as related-party dealings despite his declared annual remuneration of Rs 1.2 lakh, Mehta said the transfers were commercial in nature and therefore did not require such disclosure.
"The account was used only for channelising and bringing the required product back," he said.
Sebi also questioned reported sales and purchase transactions worth Rs 11,400 crore between Rajesh Exports and Affluence Shares and Stocks Ltd during FY22-FY24 after the latter reportedly denied having the company as a client.
Mehta said the company had furnished complete documentation to the regulator and described its explanation as satisfactory.
On Sebi's concerns regarding an alleged circular fund-routing arrangement involving ACC Energy Storage and promoter-controlled Elest Pvt Ltd, including a Rs 147 crore transfer returned on the same day and a Rs 262 crore investment made without a disclosed valuation, Mehta said the transactions were commercial in nature and objected to the regulator's characterisation.
Regarding a separate Rs 565 crore transfer to Elest Pvt Ltd, Mehta said around Rs 300 crore had since been repaid and that the funds were extended as loans based on business requirements. He added that Elest had also lent money to Rajesh Exports on occasion.
"It is not a transfer. Every justification of every rupee has been given to Sebi," he said.