Market regulator Securities and Exchange Board of India (SEBI) has barred Madhav Tiwari, the proprietor of Divinecommodity.co, from accessing the securities market and directed him to refund ₹1.70 crore collected from clients and investors as fees or consideration for unregistered investment advisory activities. The directions follow SEBI’s findings that Mr Tiwari operated as an investment adviser without registration and misled investors through unauthorised advisory services.
In a final order dated 6 February 2026, SEBI reconsidered the quantification of unlawful gains after the securities appellate tribunal (SAT) remanded the matter for limited review. While SAT had upheld SEBI’s earlier findings on violations and penalties, it asked the regulator to reassess the amount collected through unregistered advisory services after giving Mr Tiwari an opportunity to explain the entries in his bank statements.
SEBI had earlier held that Mr Tiwari acted as an investment adviser without registration under the SEBI (Investment Advisers) Regulations, 2013, and falsely projected himself as a SEBI-registered entity. He was also found to have assured guaranteed returns and collected money from investors, in violation of the SEBI Act and the Prohibition of Fraudulent and Unfair Trade Practices (PFUTP) Regulations.
During the remand proceedings, Mr Tiwari claimed that only ₹9.66 lakh of the receipts related to advisory services and that the remaining amounts were linked to other activities such as SEO services, website development, astrology, numerology and property commissions. SEBI, however, found that these claims lacked reliable or verifiable evidence.
The regulator noted serious deficiencies in the invoices and ledgers submitted by Mr Tiwari. Many invoices lacked basic particulars such as the nature of services rendered, dates, client details and mode of payment. In several cases, the bank account numbers on the invoices did not match the accounts to which funds were actually credited, undermining their evidentiary value.
SEBI’s analysis of bank statements revealed multiple recurring credits that exactly matched the subscription amounts of advisory packages advertised on Divinecommodity.co, including ‘base metal divine tips’, ‘bullion divine tips’, ‘crude oil divine tips’ and other MCX-linked offerings. Based on the preponderance of probability, SEBI concluded that these receipts represented fees collected for unregistered investment advisory services.
After re-quantification, SEBI held that Mr Tiwari was liable to refund ₹1.70 crore collected from investors. SEBI has also debarred Mr Tiwari from accessing the securities market and from buying, selling or dealing in securities, directly or indirectly, until the refund process is completed and a compliance report certified by an independent chartered accountant is filed.
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