Market regulator SEBI has alleged that Dhenu Buildcon Infra Ltd used a network of connected entities to repeatedly circulate a base amount of ₹25 crore, creating the appearance that the company had received ₹1,000 crore in unsecured loans.

According to an interim order passed by SEBI Whole Time Member Kamlesh Chandra Varshney, the alleged arrangement was orchestrated by Surendra Kumar Jain and Virendra Jain and involved Dhenu Buildcon and several connected entities.

During financial year 2024-25, Dhenu Buildcon purportedly received ₹1,000 crore in unsecured loans from seven entities. The company subsequently converted ₹840 crore of the purported debt into equity through a preferential allotment to six of those entities in December 2025.

However, an examination of the bank-account transactions allegedly showed that the ₹1,000 crore was not the result of fresh funds entering the company. Instead, SEBI alleged that a single base amount of ₹25 crore was repeatedly transferred and circulated through the bank accounts of connected entities.

The regulator further alleged that the initial ₹25 crore itself originated from suspicious fund rotations involving other connected entities. Based on its examination of the fund trail, SEBI said it had prima facie inferred that the purported loans did not represent genuine financial transactions.

SEBI therefore alleged that the subsequent allotment of ₹840 crore worth of preferential shares was made without genuine financial consideration.

The regulator also identified multiple links between Dhenu Buildcon, the purported lenders, the preferential allottees and entities that received funds from the company. These included common addresses, directors, authorised signatories and bank branches, along with extensive cross-shareholdings.

According to the order, the entities involved were directly or indirectly owned, controlled or managed by Surendra Jain and Virendra Jain.

SEBI also relied on chat messages and call records recovered during search-and-seizure operations in a separate matter. The regulator said these records provided evidence of the alleged control exercised over the network.

Physical inspections of the registered offices of the entities also raised concerns, with SEBI stating that the inspections indicated a lack of genuine physical presence and commercial substance.

The alleged transactions coincided with a sharp increase in Dhenu Buildcon’s market value. According to SEBI, the company’s market capitalisation rose from around ₹3 crore to ₹4,925 crore during the examination period, despite negligible changes in its revenues and profitability.

SEBI said the increase in market value was driven by the purported conversion of loans into equity. Since the preferential shares were allegedly allotted without genuine consideration, the regulator said their subsequent sale in the market could potentially result in unearned gains for the recipients.

As part of its interim measures, SEBI has restrained six individuals and entities from buying, selling or otherwise dealing in Dhenu Buildcon shares. The company has also been prohibited from undertaking corporate actions.

SEBI has separately restrained Surendra Kumar Jain and Virendra Jain from buying, selling or dealing in securities and from associating themselves with the securities market, directly or indirectly.

The regulator has also directed the the stock exchanges to examine compliance by the noticees with the Securities Contracts (Regulation) Rules, 1957, and other applicable laws.

What Is Round-Tripping And How Does It Allegedly Work Here?

Round-tripping, in simple terms, is when money moves through a chain of entities and eventually returns to the original company or a connected entity, creating the appearance of fresh funds even though the underlying money may be the same.

In the Dhenu Buildcon case, SEBI’s allegation can be understood through the ₹25 crore at the centre of the fund trail.

The regulator alleged that the ₹25 crore was repeatedly moved through the bank accounts of connected entities. Each movement created another transaction in the banking trail, but SEBI said the underlying pool of money remained essentially the same.

The result, according to the regulator, was that Dhenu Buildcon appeared to have received ₹1,000 crore through unsecured loans from seven entities.

The distinction is important. A genuine ₹1,000 crore loan arrangement would ordinarily involve ₹1,000 crore of actual funds being advanced to the borrower. In the alleged structure described by SEBI, however, the same ₹25 crore was repeatedly circulated, allowing the transactions to collectively appear much larger than the original amount.

SEBI also alleged that the first ₹25 crore itself came from suspicious fund rotations involving other connected entities.

The regulator therefore questioned whether the transactions represented genuine loans at all.

The alleged round-tripping did not end with the purported loans. Dhenu Buildcon subsequently converted ₹840 crore of the alleged debt into equity through a preferential allotment to six of the entities.

That is where the fund trail becomes significant.

If the loans were not backed by genuine financial consideration, as SEBI has prima facie alleged, then the equity issued against those loans would also not represent a conventional conversion of genuine debt into shares.

In other words, the regulator’s case is not simply about money moving in circles. It is about whether those movements were used to create the appearance of financial transactions that then supported a much larger equity transaction.

And that brings the ₹840 crore preferential allotment into focus.

But What Exactly Is Dhenu Buildcon?

Dhenu Buildcon Infra Ltd is not a new company that suddenly appeared on the stock market. Its corporate history stretches back more than a century.

The company was originally incorporated in 1909 as Hingir-Rampur Coal Company Ltd and was associated with coal mining. Its coal mines were subsequently taken over by the Government of India in 1973.

The company later changed its name to Dhenu Buildcon Infra Ltd in 2012.

Its present-day profile, however, looks very different from its original identity as a coal company. Dhenu Buildcon’s recent filings describe its principal activity as trading in securities.

That makes the company’s financial profile particularly relevant to the SEBI allegations.

In financial year 2024-25, Dhenu Buildcon reported no revenue from operations, according to its financial disclosures. Its loss before tax and extraordinary items was also relatively small compared with the scale of the transactions now under scrutiny.

Yet during the same broad period examined by SEBI, the company became the recipient of purported unsecured loans totalling ₹1,000 crore.

That figure dwarfs the company’s underlying operating activity.

The contrast becomes even more striking when the company’s market value is considered.

According to SEBI’s interim order, Dhenu Buildcon’s market capitalisation increased from approximately ₹3 crore to ₹4,925 crore during the examination period.

SEBI has linked this sharp increase to the purported loan-to-equity conversion.

The company therefore sits at the centre of a striking mismatch: a listed entity with negligible operating revenue, purported unsecured loans running into ₹1,000 crore, an ₹840 crore preferential allotment and a market capitalisation that rose into the thousands of crores.

But the company’s corporate history and financial profile raise another question – who actually owned and controlled Dhenu Buildcon as this transformation took place?

Who Owns Dhenu Buildcon?

The ownership picture around Dhenu Buildcon changed sharply during the period under examination.

As of March 2025, promoters held around 11.53% of the company. By March 2026, promoter holding had fallen to almost zero, at approximately 0.04%. The shift came as the company’s share capital expanded dramatically following the preferential allotment.

Among the shareholders holding a significant stake before the change was Sunsitara Multitrade Pvt Ltd, which held around 11.53% of Dhenu Buildcon.

The post-allotment ownership structure looked very different.

By March 2026, several corporate entities had emerged as major shareholders. These included Twinkle Mercantiles and Credits Pvt Ltd, Golkonda Aluminium, Shanta Agencies Pvt Ltd, Tiaan Consumer Ltd, Shri Niwas Leasing and Finance Ltd and Utsav Securities Ltd.

Together, these entities accounted for a substantial portion of the company’s outstanding shares.

That change in ownership is important because six entities that received the preferential allotment were also part of the wider network examined by SEBI.

The regulator has alleged that the entities involved in the purported loan transactions and preferential allotment were connected through common directors, authorised signatories, addresses, bank branches and cross-shareholdings.

SEBI has further alleged that these entities were directly or indirectly owned, controlled or managed by Surendra Kumar Jain and Virendra Jain.

The ownership data, however, needs to be distinguished from SEBI’s allegations about ultimate control. A company’s shareholding pattern can establish who formally holds shares, but it does not by itself establish who ultimately controls those shareholders.

That distinction becomes particularly important in Dhenu Buildcon’s case because the company’s capital structure changed on an extraordinary scale in a matter of months.

The company that had a paid-up equity capital of around ₹1.83 crore in FY2024-25 subsequently issued billions of new shares. And that takes us to one of the biggest numbers in the entire case – the ₹840 crore preferential allotment.

The ₹840 Crore Preferential Allotment

The purported loans did not simply remain on Dhenu Buildcon’s books.

In December 2025, the company converted ₹840 crore of the purported ₹1,000 crore unsecured loans into equity through a preferential allotment to six of the entities that had allegedly advanced the loans.

The scale of that allotment was extraordinary when compared with Dhenu Buildcon’s existing share capital.

Before the transaction, the company had around 1.83 crore equity shares. The preferential issue involved the allotment of 5,91,54,92,940 shares.

That meant the company was effectively creating an enormous new pool of equity in a relatively short period.

The six entities receiving the shares were among the entities that had purportedly provided the unsecured loans to Dhenu Buildcon.

SEBI’s concern was not simply the size of the allotment. It was the consideration behind it.

According to the regulator, its examination of the bank-account trail indicated that the purported ₹1,000 crore loans had been created through repeated circulation of a ₹25 crore base amount. SEBI therefore said it had prima facie concluded that the purported loans were not genuine financial transactions.

If that conclusion holds, the ₹840 crore debt-to-equity conversion becomes central to the case. SEBI alleged that the preferential shares were allotted without genuine financial consideration.

The regulator further said that because the shares had allegedly been issued without genuine consideration, their subsequent sale in the market could generate unearned gains for the recipients.

The transaction also fundamentally altered Dhenu Buildcon’s capital structure. The company went from having a relatively small number of outstanding shares to having billions of shares after the preferential allotment.

That enormous increase in share capital coincided with the extraordinary rise in the company’s market capitalisation that SEBI has highlighted in its order. 

The question, therefore, is not merely why Dhenu Buildcon raised ₹840 crore through a preferential issue. It is whether the ₹840 crore was ever genuinely paid in the first place.

From 1.83 Crore Shares To Billions

The scale of Dhenu Buildcon’s preferential allotment becomes clearer when its share count is placed side by side. 

At the end of financial year 2024-25, the company had around 1.83 crore equity shares outstanding. In December 2025, it allotted 5,91,54,92,940 shares on a preferential basis.

• That is more than 320 times the number of shares the company had before the allotment. The transaction transformed the company’s capital structure almost overnight.
• It also changed the ownership profile of the listed company. The entities receiving the preferential shares became some of its largest shareholders, while the earlier promoter holding was diluted to almost nothing.
• By March 2026, promoter holding stood at approximately 0.04%, compared with around 11.53% a year earlier.

The post-allotment shareholding showed several corporate entities holding sizeable stakes in Dhenu Buildcon.

Twinkle Mercantiles and Credits Pvt Ltd held around 21.96%, while Golkonda Aluminium, Shanta Agencies Pvt Ltd and Tiaan Consumer Ltd each held around 18.99%. Shri Niwas Leasing and Finance Ltd held approximately 13.65%, while Utsav Securities Ltd held around 7.12%.

These entities need to be viewed alongside SEBI’s findings about the network of companies connected to Dhenu Buildcon.

The regulator has alleged that common directors, authorised signatories, addresses, bank branches and cross-shareholdings linked the purported lenders, preferential allottees and other entities receiving funds from Dhenu Buildcon.

The result was a dramatic transformation in the company’s equity structure. But the share-count explosion was only one part of the change. As the number of shares multiplied, so did Dhenu Buildcon’s market value.

According to SEBI, the company’s market capitalisation rose from around ₹3 crore to ₹4,925 crore during the examination period.

For a company that reported virtually no operating revenue, that jump would become one of the most striking features of the entire episode.
From ₹3 Crore To ₹4,925 Crore

The transformation in Dhenu Buildcon’s share capital was accompanied by an equally dramatic rise in its market value. 

According to SEBI’s interim order, the company’s market capitalisation increased from around ₹3 crore to ₹4,925 crore during the period examined by the regulator.

That is an increase of more than 1,600 times.

SEBI has linked the rise to the purported conversion of the unsecured loans into equity.

The timing is significant. The company had purportedly received ₹1,000 crore in unsecured loans during FY2024-25, subsequently converted ₹840 crore of that purported debt into equity, and then saw its market capitalisation climb into the thousands of crores.

At the same time, SEBI said there was negligible change in the company’s revenues and profitability. The regulator’s concern was what could happen next.

If the preferential shares had been issued without genuine consideration, as SEBI has alleged, their subsequent sale in the market could allow the recipients to realise gains that were not backed by genuine investment in the company.

That is why the market-cap jump matters to the regulator’s case.

The issue is not simply that Dhenu Buildcon’s valuation increased sharply.

It is whether a purported financial transaction created the equity that helped drive that increase in market value.

The Jain Connection

At the centre of SEBI’s allegations are Surendra Kumar Jain and Virendra Jain.

According to the regulator’s interim order, the two were the people behind the network of entities involved in the alleged transactions.

SEBI has alleged that the entities connected to Dhenu Buildcon, the purported lenders, the preferential allottees and other recipients of funds were directly or indirectly owned, controlled or managed by the two men.

The regulator’s case is based on more than common ownership records.

SEBI identified overlapping directors and authorised signatories across several entities. It also found common addresses, common bank branches and extensive cross-shareholdings.

The regulator further relied on chat messages and call records recovered during search-and-seizure operations in a separate matter.

According to SEBI, the material provided evidence of the alleged control exercised over the network. The physical inspections of the companies’ registered offices added another layer to the regulator’s concerns.

SEBI said the inspections indicated that several entities lacked genuine physical presence and commercial substance. That finding matters because the purported loans at the heart of the case were formally shown as transactions between different corporate entities.

If those entities were, in reality, under common control, then the apparent separation between borrower and lender becomes much less straightforward. SEBI has therefore treated the network of relationships as part of the alleged scheme rather than as a collection of unrelated corporate connections.

Dhenu Buildcon Was Not New To Regulatory Attention

The current SEBI action is not the first time Dhenu Buildcon has appeared in regulatory or tax proceedings.

The company has also featured in earlier cases involving its shares, including proceedings before the Income Tax Appellate Tribunal.

In one such matter, an assessee had purchased 50,000 shares of Dhenu Buildcon and subsequently sold them for around ₹7.84 crore. The case examined the tax treatment of the gains from those transactions.

Dhenu Buildcon was also identified in tax-related material involving penny-stock transactions.

These earlier proceedings are separate from the current SEBI case. They do not, by themselves, establish that the transactions examined by SEBI were fraudulent or that the people involved in the earlier matters were connected to the current allegations.

But they add another chapter to the company’s history as a listed stock that has attracted regulatory and tax scrutiny.

The Auditor And The Questions Around The Books

Dhenu Buildcon’s FY2024-25 annual report names Subramaniam Bengali & Associates, Chartered Accountants, as its statutory auditor. The firm was reappointed for a second five-year term beginning FY2024-25.

The company’s financial statements for FY2024-25 showed zero revenue from operations and a loss before tax and extraordinary items of ₹39.55 lakh.

The auditor’s report on the FY2024-25 results stated that the financial results gave a true and fair view in accordance with the applicable accounting standards and principles, based on the information and explanations provided to the auditor.

That is significant in the context of the transactions now being examined by SEBI.

The regulator’s interim order alleges that Dhenu Buildcon had received purported unsecured loans of ₹1,000 crore during FY2024-25, while the company’s reported operating revenue for the year was zero.

The SEBI order, however, deals with allegations arising from its own examination of bank-account transactions and connected entities. An auditor’s opinion on financial statements and SEBI’s subsequent regulatory findings are not the same thing.

There is also a notable development around the company’s auditors after the period covered by the annual report.

In September 2025, Dhenu Buildcon informed the stock exchanges that its board had approved the appointment of Rajesh Gupta and Co. as statutory auditor for five consecutive years.

That change came just months before the December 2025 preferential allotment of billions of shares.

It raises a straightforward reporting question: what changed in the company’s audit arrangements just as its balance sheet and capital structure were undergoing their most dramatic transformation?

What Happens Now?

SEBI’s order is an interim order, meaning the regulator’s findings at this stage are prima facie and the proceedings are not the same as a final determination of liability.

But the action it has taken is already significant.

The regulator has restrained six entities that received Dhenu Buildcon’s preferential shares from disposing of those shares. The six entities are Golkonda Aluminium Extrusions Ltd, Shanta Agencies Pvt Ltd, Shri Niwas Leasing and Finance Ltd, Tiaan Consumer Ltd, Twinkle Mercantiles & Credits Pvt Ltd and Utsav Securities Ltd.

SEBI has also barred Surendra Kumar Jain and Virendra Jain from buying, selling or dealing in securities, directly or indirectly, and from associating themselves with the securities market. Dhenu Buildcon has been directed not to undertake corporate actions until further directions.

The regulator has further directed the stock exchanges to examine compliance by the noticees with the Securities Contracts (Regulation) Rules, 1957 and other applicable laws.

The case followed a reference from the Serious Fraud Investigation Office (SFIO) received by SEBI on April 20, 2026. SEBI’s examination covered transactions involving Dhenu Buildcon between August 1, 2024 and July 31, 2026.

The regulator’s examination found that Dhenu Buildcon purportedly received ₹1,000 crore through 46 transactions over eight days. SEBI said the company’s bank balance, however, never exceeded roughly ₹26 crore during the period, while approximately ₹996 crore was subsequently transferred to five entities within the wider network.

That fund trail is now at the centre of the regulatory case.

The question SEBI is examining is whether those transactions represented genuine financing between independent parties or whether the same money was repeatedly circulated to create the appearance of a much larger financial transaction.

And There Are More Red Flags In Dhenu Buildcon’s Latest Filings

The SEBI order is not the only reason Dhenu Buildcon’s recent corporate record deserves scrutiny.

The company’s latest disclosures throw up several additional issues around its finances and governance.

According to market-data records based on the company’s filings, Dhenu Buildcon’s latest limited review identified unprovided interest on a ₹160 crore loan, along with ₹756.2 crore of advances and questions around the fair valuation of ₹175.17 crore of equity investments.

Those numbers are significant in the context of a company that reported virtually no operating revenue.

There has also been movement among the company’s key financial personnel.

Dhenu Buildcon changed its statutory auditor in September 2025, after the departure of its CFO and executive director, according to the company’s corporate disclosures.

More recently, its internal auditor Asutosh Arun Sahu resigned with effect from August 14, 2026, citing professional reasons. Sahu had also been appointed as a non-executive independent director with effect from the same date, subject to shareholder approval.

The Auditor Change Came Before The Big Transformation

There was also a change in Dhenu Buildcon’s statutory auditor just months before the company completed the preferential allotment that transformed its capital structure.

On July 21, 2025, Subramanium Bengali & Associates resigned as the company’s statutory auditor. In its disclosure to the stock exchanges, Dhenu Buildcon said the resignation was due to a “change in stakeholders during last financial year.”

The company subsequently appointed Rajesh H Gupta & Co. as its new statutory auditor for five consecutive years beginning FY2025-26.

The timing is notable.

The auditor change came after the period in which Dhenu Buildcon had purportedly received the ₹1,000 crore in unsecured loans that are now at the centre of SEBI’s investigation, but before the December 2025 preferential allotment through which ₹840 crore of the purported debt was converted into equity.

The company’s FY2024-25 financial statements had reported zero revenue from operations, with a loss before tax and extraordinary items of ₹39.55 lakh.

The current SEBI proceedings, however, concern purported unsecured loans of ₹1,000 crore and a subsequent ₹840 crore conversion into equity.

The auditor’s resignation and the sequence is worth noting.

The Six Allottees Ended Up With 99.70% Of Dhenu Buildcon

The preferential allotment did more than dramatically increase Dhenu Buildcon’s share count. It effectively transferred control of the diluted company to the six entities that received the shares.

On December 27, 2025, Dhenu Buildcon allotted 5,91,54,92,940 shares at ₹1.42 per share to six non-promoter entities against purported outstanding unsecured loans of around ₹840 crore.

Following the allotment, the six entities collectively held approximately 99.70% of Dhenu Buildcon’s diluted equity share capital, according to SEBI’s order.

The six entities were Golkonda Aluminium Extrusions Ltd, Shanta Agencies Pvt Ltd, Shri Niwas Leasing and Finance Ltd, Tiaan Consumer Ltd, Twinkle Mercantiles & Credits Pvt Ltd and Utsav Securities Ltd.

That concentration of ownership created another issue for the regulator.

The preferential shares were subject to a lock-in period. Once that period expired on August 15, 2026, some of the allottees began selling their shares. SEBI said the six entities collectively sold 17,444 Dhenu Buildcon shares worth around ₹1.34 lakh over two days after the lock-in expired.

The quantities sold were tiny compared with the billions of shares allotted to them.

But SEBI was concerned about what could happen if the entities were allowed to dispose of their much larger holdings at prevailing market prices.

Based on the three-month volume-weighted average price before July 31, 2026, the regulator estimated that the preferential shares had a market value of around ₹5,667.04 crore.

SEBI said allowing the allottees to sell the shares could potentially result in gains of around ₹5,667 crore. 

That was one of the reasons behind the regulator’s decision to restrain the six entities from disposing of their Dhenu Buildcon shares.

The sequence therefore becomes important.

The Paper Trail Appeared To Start Before The Money Moved

SEBI’s order also points to communications that appear to predate the actual loan transactions.

The regulator examined WhatsApp messages and other material recovered during search-and-seizure operations in a separate matter. According to SEBI, the communications contained discussions relating to Dhenu Buildcon, bank accounts and the proposed preferential allotment.

One communication examined by the regulator referred to arrangements for the preferential issue. Other messages allegedly discussed accounting entries and the need to “rotate funds”.

The sequence continued into November 2024, when communications allegedly referred to loan agreements, stamp papers, KYC documentation and bank verification.

SEBI also found discussions concerning physical verification at Dhenu Buildcon’s premises, including arrangements for a person to be present at the company’s office and for a company name board to be installed, according to the regulator’s findings.

The timing is significant because Dhenu Buildcon purportedly received the ₹1,000 crore in loans through 46 transactions over eight days in December 2024.

SEBI’s bank-account analysis found that despite the purported ₹1,000 crore of inflows, Dhenu Buildcon’s bank balance never exceeded around ₹26 crore during the relevant period. Around ₹996 crore was subsequently transferred to five entities within the wider network, according to the order.

The communications therefore form part of SEBI’s broader case that the transactions were not simply a series of independent loans that happened to move between related companies. 

Instead, the regulator has alleged that the fund movements, accounting entries, documentation and preferential allotment were part of a coordinated arrangement.

The Network Had More Than Financial Links

The connections between the companies involved in the Dhenu Buildcon transactions were not limited to the movement of money.

SEBI said its examination found a series of common links between Dhenu Buildcon, the purported lenders, the preferential allottees and other entities that received funds from the company.

These included common directors, shareholders, authorised signatories, registered addresses and banking arrangements.

The regulator also identified extensive cross-shareholdings between entities in the network.

That mattered because the purported ₹1,000 crore in loans were formally shown as coming from seven different entities. If those entities were genuinely independent, each transaction would represent a separate source of funding for Dhenu Buildcon.

SEBI’s findings raised questions about that independence.

The regulator has alleged that the unsecured loans being converted into equity were themselves not genuine financial transactions, and that the apparent ₹1,000 crore of loans had been created through repeated circulation of an initial ₹25 crore.

That creates the central contradiction at the heart of the case.

The Investigation Started With An SFIO Reference

SEBI’s examination into Dhenu Buildcon did not begin in isolation.

According to the regulator’s order, SEBI received a reference from the Serious Fraud Investigation Office (SFIO) on April 20, 2026, following which it examined transactions involving Dhenu Buildcon between August 1, 2024 and July 31, 2026.

The examination focused on the purported unsecured loans of ₹1,000 crore received by Dhenu Buildcon from seven entities and the subsequent conversion of around ₹840 crore of those loans into equity.

SEBI’s investigation then moved beyond the company’s financial statements and into the underlying bank transactions.

The regulator examined the movement of funds between Dhenu Buildcon and the network of connected entities, along with corporate records, shareholding patterns and other material.

It also considered communications and call records obtained during search-and-seizure operations in a separate matter, as well as the results of physical inspections of the registered offices of entities connected to the transactions.

SEBI ultimately said it had prima facie found that the purported loans were not genuine financial transactions and that the subsequent preferential allotment was made without genuine consideration.

That wording matters.

The August 19 order is an interim order, not a final adjudication establishing fraud as a concluded fact. SEBI’s directions are intended to prevent further dealing in the shares and preserve the position while the matter proceeds.

The next stage will therefore be about establishing the underlying facts: whether the money actually represented genuine loans, whether the entities were genuinely independent, and whether the ₹840 crore equity allotment was supported by real financial consideration.

For now, SEBI’s case rests on a striking proposition – that a relatively small pool of money was allegedly made to look like ₹1,000 crore of funding, and that paper trail was then used to create billions of shares in a listed company.

The bank-account trail is perhaps the clearest part of SEBI’s case against the purported ₹1,000 crore loans.

According to the regulator, Dhenu Buildcon received the money through 46 transactions spread across eight days in December 2024.

But despite the purported ₹1,000 crore in inflows, the company’s bank balance never exceeded roughly ₹26 crore during the relevant period.

SEBI said around ₹996 crore was subsequently transferred to five entities within the wider network. That is central to the regulator’s allegation.

The distinction between money passing through the company and money remaining with the company is therefore critical.