ASHUTOSH SONI — SEBI Registered Research Analyst :INH000025869

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Ashutosh Soni SEBI Registered Reserach Analyst: INH000025869
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Research-backed insights. Real-world strategies."

We combine SEBI-registered research with structured learning so you can make informed decisions — not guesses.

SEBI Registered Research & Advisory : INH000025869

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Stay ahead with actionable research on Indian markets — sectors, trends, and what's moving your portfolio.

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Badri Complex, 1st Floor, Panchmandir Road, Gaja Chowk, Motihari, Patna, Bihar, 845401

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About Us

Ashutosh Soni F&O | Hedging Specialist
Risk First · Education Core

Who this is for

Working professionals who can't track markets all day
Investors tired of Telegram "tipsters" and zero accountability
Anyone — from Bihar, Delhi, Mumbai, or anywhere — who wants research, not gamble
Beginners to intermediate traders wanting a structured learning path
SEBI REGISTERED RA INH000025869

Ashutosh Soni
Research Analyst

Motihari, Bihar
Reg. April 10, 2026
7+ Years experience
NSE + BSE Markets
F&O · Hedging specialist · Swing Trading

From Motihari, Bihar with over 7+ years of hands-on market experience, Ashutosh Soni specialises in Swing Trading and Options Hedging. M.COM + NISM-XV certified, he delivers institutional-grade research with clarity and zero conflicts.

Master In Finance
NISM-XV
Swing Trading
Options Hedging

WHAT I OFFER

  • Momentum-based swing trade ideas — Equity, F&O, NIFTY & BANKNIFTY
  • Options hedging strategies — protect capital, manage risk intelligently
  • Risk-managed approach — clear entry, target & stop-loss on every call
  • Fundamental + Technical analysis — no shortcuts, just research
7+ Years of Financial Excellence

What makes ACMTrade different

Swing + Options hedging focus

— low intraday noise or random tips

Risk first, always

— every call has a defined stop-loss before the target

Zero conflicts

— no broker tie-ups, no commissions, no hidden agenda

Direct to investor

— one analyst, full accountability, no middlemen

Discover Our Story

Mission, Vision & Core Philosophy

Our Mission

To empower every trader with the education, research, and risk management frameworks needed to navigate financial markets with confidence and discipline — not guesswork.

Our Vision

To become the world's most trusted educational hub for independent traders, where risk awareness and market knowledge create sustainable success across all market cycles.

Our Values

Radical transparency, lifelong learning, risk-first discipline, data-driven research, and unwavering commitment to trader education over speculative hype.

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Disclaimer & Regulatory Information

SEBI registered research analyst — transparency and compliance at the core

Registration Number: INH000025869 | Valid From: 10 April 2026
ASHUTOSH SONI — Individual SEBI Registered Research Analyst SEBI Reg. Date: 10 APRIL 2026

● ASHUTOSH SONI is registered with SEBI as Individual Research Analyst with Registration number INH000025869 on 10 APRIL 2026 pursuant to which it provides Research Analyst services to its clients.

I am not affiliated with any other intermediaries or receive any brokerage or commission from any third party.

The SEBI has issued no penalties/directions under the SEBI Act or any other regulatory body.

I do not recommend any stock broker or other intermediary to a client, nor do I receive any consideration by way of remuneration or compensation or in any other form whatsoever from the stock broker or another intermediary.

Investment in equity shares has its own risks. Sincere efforts have been made to present the right investment perspective. The information contained herein is based on analysis and on sources that I consider reliable. I, however does not vouch for the consistency or the completeness thereof. This material is for personal information and I am not responsible for any loss incurred due to it & take no responsibility whatsoever for any financial profits or loss which may arise from the recommendations above.

I do not provide any promise or assurance of favourable view for a particular industry or sector or business group in any manner. The investor is requested to take into consideration all the risk factors including their financial condition and suitability to risk return profile before investing.

The information and views in this website & all the services that I provide are believed to be reliable, but I do not accept any responsibility (or liability) for errors of fact or opinion. Users have the right to choose the product/s that suits them the most.

I or any other person related to me might be holding positions in the stocks recommended.

The research recommendations are provided to all our clients who are entitled to receive the research reports. Any Client (Paid or Unpaid), any third party or anyone else have no rights to forward or share our calls or SMS or Reports or Any Information Provided by us to/with anyone (through any medium) which is received directly or indirectly by them. If found so, then serious legal actions can be taken.

I ensure that the individuals employed as research analyst are separate from other employees who are performing sales trading, dealing, corporate finance advisory or any other activity that may affect the independence of our research report/recommendations. However, these individuals may receive feedback from sales or trading personnel of brokerage division to ascertain the impact of research report/recommendations.

I also ensure that if a client wants an opinion on a specific position, such suggestion/view under any circumstances shall be considered as an opinion (not advice). I am not liable for any losses whatsoever the client may incur in accepting this opinion.

I do not have any association in any manner with any issuer of products/securities; this ensures that there are no actual or potential conflicts of interest. This also ensures that objectivity or independence in the carrying on research services is not compromised.

Investment in securities market is subject to market risks. Read all the related documents carefully before investing.

Registration granted by SEBI and certification from NISM is no way guarantee performance of the intermediary or provide any assurance of returns to investors.

By accessing Acmtrade.in or any of its associate/group sites, you have read, understood and agree to be legally bound by the terms of the following disclaimer and user agreement.

I had taken due care and caution in compilation of data for its website. I also advise users to check with other certified experts before taking any investment decision. However, I do not guarantee the consistency, adequacy or completeness of any information and is not responsible for any errors or omissions or for the results obtained from the use of such information. I do hereby especially state that it has no financial liability whatsoever to any user on account of the use of information provided on its website.

I am not responsible for any errors, omissions or representations on any of our pages or on any links on any of our pages. I do not endorse in anyway any advertisers on our website pages. Please verify the veracity of all information on your own before undertaking any alliance.

The information on this website is updated from time to time. I, however exclude any warranties (whether expressed or implied), as to the quality, consistency, efficacy, completeness, performance, fitness or any of the contents of the Website, including (but not limited) to any comments, feedback and advertisements contained within the Site.

This website contains material in the form of inputs submitted by users and I do accept no responsibility for the content or consistency of such content nor do I make any representations by virtue of the contents of this website in respect of the existence or availability of any goods and services advertised in the contributory sections. I also make no warranty that the contents of the website are free from infection by viruses or anything else which has contaminating or destructive properties and shall have no liability in respect thereof.

Part of this website may contain advertising and other material submitted to us by third parties. Kindly note that those advertisers are responsible for ensuring that material submitted for inclusion on the website complies with all legal requirements. Although acceptance of advertisements on the Website is subject to our terms and conditions which are available on request, I do not accept liability in respect of any advertisements.

There are risks associated with utilizing internet-based information and research dissemination services. Subscribers are advised to understand that the services can fail due to failure of hardware, software, and Internet connection. While I also ensure that the messages are delivered in time to the subscriber's mobile network, the delivery of these messages to the customer's mobile phone/handset/desktop/iPad/tablet/laptop is the responsibility of the customer's mobile network/internet connection/wifi. The messages may be delayed and/or not delivered to the customer's mobile phone/handset on certain days, owing to technical reasons, and the ASHUTOSH SONI cannot be held responsible for the same.

Stock trading is inherently risky, and you agree to assume complete and full responsibility for the outcomes of all trading decisions that you make.

Unlike an actual performance record, simulated results do not represent actual trading. No representation is being made that any account will or is likely to achieve profits or losses similar to those shown.

You, and not me, assume the entire cost and risk of any trading you choose to undertake. You are solely responsible for making your own investment decisions. If you choose to engage in transactions with or without seeking advice from a licensed and qualified financial advisor or entity, then such decision and any consequences flowing there from are your sole responsibility. I or any employees are in no way liable for the use of the information by others in investing or trading in investment vehicles.

I also encourage all investors to use the services as a resource to further their own research on all featured companies, stocks, sectors, markets and information presented on the site.

I, my management, my associate companies and/or my employees take no responsibility for the veracity, validity and correctness of the expert recommendations or other information or research. Although I do attempt to research thoroughly on information provided herein, there are no guarantees in consistency. The information presented on the site has been gathered from various sources believed to be providing correct information. I, group, companies, associates and/or employees are not responsible for errors, or inaccuracies, if any, in the content provided on the site.

I have the license to provide research recommendations as a research analyst. Your use of this and all information contained on this website is governed by these Terms and Conditions of Use. This material is based upon information that ASHUTOSH SONI consider reliable, but I do not represent that it is consistent or complete and that it should be relied upon, as such. You should not rely solely on the Information in making any investment. Rather, you should use the Information only as a starting point for doing additional independent research in order to allow you to form your own opinion regarding investments. By using Acmtrade.in, including any software and content contained therein, you agree that use of the Service is entirely at your own risk. You understand and acknowledge that there is a very high degree of risk involved in trading securities. I make no warranties and gives no assurances regarding the truth, timeliness, reliability, or good faith of any material posted on Acmtrade.in. ASHUTOSH SONI does not warranty that trading methods or systems presented in their services or the information herein or obtained from advertisers or members will result in profits or losses.

By visiting the website Acmtrade.in, as a visitor and / or as a subscriber, surfing and reading of the information on the website is the acceptance of this disclaimer and all other terms and conditions.

Everything posted on social media (Twitter/Facebook/Telegram/YouTube channel) is for education / illustration purposes and should not be counted as recommendations or investment advice. The Stocks posted on social media are for illustration purpose only and are not recommendatory.

I do hereby expressly disclaims any implied warranties imputed by the laws of any jurisdiction. I consider ourselves and intend to be subject to the jurisdiction only of the courts of Haryana in India. If you don't agree with any of our disclaimers above, please do not read the material on any of our pages. Although access to users outside India is not denied, ASHUTOSH SONI shall have no legal liabilities whatsoever in any laws of any jurisdiction other than India. I also reserve the right to make changes to our site and these disclaimers, terms, and conditions at any time.

Acknowledgment: By continuing to use this website, you acknowledge that you have read, understood, and agree to all the terms of this disclaimer.

Research Analyst Compliance & Disclosure

Regulatory requirements for Research Reports — ensuring transparency, reliability and integrity.

Registration Number: INH000025869 | Valid From: 10 April 2026
ASHUTOSH SONI — Individual SEBI Registered Research Analyst SEBI Reg. Date: 10 APRIL 2026

1. Reliable Information & Defined Terms

The Research Analyst needs to ensure that the facts in the research reports are taken from a reliable source and information. Further, the terms used to provide research recommendation should be well defined in order to avoid any ambiguity. The terms defined shall be consistently used in the research report.

The source from which the information is gathered for making the research report shall be well documented and maintained in records by the research entity or the research analyst.

2. Rating System: Time Horizon & Benchmarks

Where the Research Analyst uses rating system, it should clearly define the meaning of each such rating along with the time horizon and benchmarks on which the rating is based.

Note: Benchmarks are disclosed in each research report; time horizon for all ratings is minimum 12 months unless stated otherwise.

3. Price Target & Securities Graph

Where a research report contains either a rating or price target for subject company’s securities for at least one year, then such reports should also provide the graph of daily closing of such securities for the period assigned or for three-year period, whichever is shorter.

📈 Compliance Note: In every research report that includes a rating or price target with a validity of at least one year, a line graph displaying daily closing prices of the subject security is included. The graph covers either the assigned period (e.g., 12 months) or the trailing three-year period, whichever is shorter — to enable investors to assess historical performance and price trends.

Research reports archive at acmtrade includes visual price charts for all rated securities, updated daily with closing prices as per SEBI (Research Analyst) Regulations.

4. Third‑Party Research Reports

Where any third-party research reports are being distributed, the Research Analyst should:

  • a. review the third party research reports for any untrue statement of material fact or any false or misleading information.
  • b. disclose any material conflicts of interest of such third party research provider or a web address shall be provided that directs a recipient to the relevant disclosures.

acmtrade ensures that all third-party research reports are subjected to a thorough due diligence review before any distribution. Any material conflict of interest of the third-party provider is prominently disclosed, and recipients are directed to www.acmtrade.in/thirdparty-disclosures for complete transparency.

5. Signing, Dating & Preservation of Reports

A research report should be duly signed and dated. It should be maintained either in physical or electronic form and shall be preserved for a period of 5 years. Where the reports are being maintained in electronic form, the report should be digitally signed.

Compliance Summary: Each research report issued by acmtrade is signed (digitally where electronic), dated, and archived to meet the mandatory retention period of 5 years in compliance with SEBI Research Analyst Regulations.

ASHUTOSH SONI — Individual SEBI Registered Research Analyst — INH000025869 | Individual | Regulated by SEBI / RAASB (BSE Ltd.)

ASHUTOSH SONI — Individual SEBI Registered Research Analyst

Registration No.: INH000025869 | Type: Individual Research Analyst | Regulated By: SEBI / RAASB (BSE Limited)


OUR GRIEVANCE REDRESSAL PRINCIPLES

  • We believe that investor service is a vital element for sustained trust and healthy investor relationships. Prompt and efficient grievance resolution is especially critical since we follow the Direct-to-Investor model.
  • Every investor will be treated fairly, honestly, and with respect at all times.
  • All complaints will be handled with courtesy, speed, and without prejudice.
  • Queries and complaints will be dealt with efficiently and in a time-bound manner.
  • We act in good faith, always prioritising the interests of the investor.
  • Grievance redressal is supported by a review mechanism to prevent recurrence.
  • We maintain an open attitude towards service recovery and alternate solutions.
  • Clients may raise their grievance in writing (email), orally, or telephonically. All grievances are recorded, tracked, and resolved within defined timelines.

RESOLUTION TIMELINE COMMITMENT

  • Maximum RA-level resolution time (SEBI mandated): 21 Calendar Days
  • Our internal target resolution time: 7 Working Days
  • Complaint data published on website: By 7th of every month

SECTION 1 — GRIEVANCE REDRESSAL / ESCALATION MATRIX

The following contact details facilitate complainants to approach the Research Analyst before filing a complaint with SEBI. For verification of SEBI registration, refer to: SEBI RA Registry

Level Designation Contact Person Office Address Contact No. Email ID Working Hours
Level 1 Customer Care (First Point of Contact) Ashutosh Soni [Your Office Address], Patna, Bihar — [PIN] +91 6209878022 info@acmtrade.in Mon–Sat, 10:00 AM – 6:00 PM (Sundays & Public Holidays off)
Level 2 Compliance Officer & Principal Officer (If Level 1 unresolved) Ashutosh Soni [Your Office Address], Patna, Bihar — [PIN] +91 6209878022 info@acmtrade.in Mon–Sat, 10:00 AM – 6:00 PM
Level 3 SEBI SCORES 2.0 (If unsatisfied with RA resolution) Online Portal scores.sebi.gov.in scores.sebi.gov.in 24×7 Online
Level 4 SmartODR — Online Dispute Resolution (Conciliation & Arbitration) SEBI ODR Platform smartodr.in smartodr.in 24×7 Online
Review RAASB (First Review) / SEBI (Second Review) BSE Ltd. / SEBI Mumbai scores.sebi.gov.in As per SCORES

SECTION 2 — HOW TO FILE A GRIEVANCE (STEP-BY-STEP)

Step 1 — Direct to RA (Level 1): Contact Ashutosh Soni directly via email or phone. Describe the issue, date, and expected resolution. The RA will acknowledge and resolve promptly. Target Resolution: Within 7 working days. Maximum per SEBI: 21 calendar days.

Step 2 — Escalate within RA (Level 2): If unresolved, write to Compliance Officer / Principal Officer (Ashutosh Soni) via compliance email. Include original complaint reference, PAN, subscription details, date of first complaint.

Step 3 — SEBI SCORES 2.0 (Level 3): Lodge complaint on SEBI's centralised portal: scores.sebi.gov.in. Two-level review: RAASB (BSE Ltd.) first, then SEBI. Also available via SCORES Mobile App.

Step 4 — SmartODR (Level 4): Online Dispute Resolution via conciliation/arbitration as per SEBI Circular SEBI/HO/OIAE_IAD-1/P/CIR/2023/131 dated July 31, 2023. Portal: smartodr.in

Physical Complaints — Postal Address: Office of Investor Assistance and Education, Securities and Exchange Board of India, SEBI Bhavan, Plot No. C4-A, 'G' Block, Bandra-Kurla Complex, Bandra (East), Mumbai — 400 051

SECTION 3 — RA CONTACT DETAILS

📞 Customer Care / Grievance

Name: Ashutosh Soni
Phone: +91 6209878022
Email: info@acmtrade.in
Address: Badri Complex, 1st Floor, Panchmandir Road, Gaja Chowk, Motihari, Patna, Bihar, 845401
Hours: Mon–Sat, 10 AM – 6 PM

⚖️ Compliance Officer & Principal Officer

Name: Ashutosh Soni
Phone: +91 6209878022]
Email: info@acmtrade.in
Address: Badri Complex, 1st Floor, Panchmandir Road, Gaja Chowk, Motihari, Patna, Bihar, 845401
Hours: Mon–Sat, 10 AM – 6 PM

📜 SEBI Registration Details

Registration No.: INH000025869
Type: Individual Research Analyst
Regulator: SEBI / RAASB (BSE Ltd.)
Website: www.yourdomain.in

SECTION 4 — EXTERNAL REGULATORY PORTALS

  • SEBI SCORES 2.0 — Centralised grievance redressal. Two-level review: RAASB first, then SEBI. 24×7. https://scores.sebi.gov.in
  • SmartODR Portal — Online Dispute Resolution for conciliation and arbitration. https://smartodr.in
  • SEBI RA Registry — Verify registration of any SEBI Registered Research Analyst. Verify Here
  • SEBI Investor Helpline — Toll-free: 1800 266 7575

SECTION 5 — MODES OF FILING A GRIEVANCE

  • Email: Send detailed email to info@acmtrade.in with subject "Grievance — Ashutosh Soni". Attach relevant documents.
  • Phone / Call: Call RA during working hours (Mon–Sat, 10 AM – 6 PM). Follow up with written email summary.
  • Written / Post: Send written complaint to registered office address. Retain proof of posting.
  • SEBI SCORES Online: Register and file complaint at scores.sebi.gov.in if internal resolution unsatisfactory.

IMPORTANT NOTICE TO INVESTORS

Please note that our support team is unavailable on Sundays and Public Holidays. However, urgent emails can be sent at any time and will be addressed on the next working day. We aim to resolve all grievances within 7 working days from the date of receipt. If your grievance is not resolved within this timeframe, you may escalate to SEBI SCORES at scores.sebi.gov.in.

⚠️ The Research Analyst shall NEVER ask for your trading account / demat account / bank account login credentials or OTPs. Never share such information with anyone.


Regulatory References:

  • SEBI (Research Analysts) Regulations, 2014
  • SEBI Investor Charter Circular: SEBI/HO/MIRSD/MIRSD-PoD/P/CIR/2025/81 (June 2, 2025)
  • SEBI MITC Circular: SEBI/HO/MIRSD/MIRSD-PoD/P/CIR/2025/20 (February 17, 2025)
  • SEBI ODR Circular: SEBI/HO/OIAE_IAD-1/P/CIR/2023/131 (July 31, 2023)

SEBI Registration No. INH000025869 does not guarantee returns or performance. Investments are subject to market risks. Complaint data is updated monthly on this website latest by the 7th of each succeeding month as per SEBI's Annexure B format.

📊 SEBI SCORES Dashboard

SEBI SCORES is an online platform for efficient complaint redressal in the Indian securities market. Our firm actively monitors SCORES tickets. Below are real-time indicators:

12
Open Complaints (SCORES)
98%
Resolution Rate (FY 2025-26)
3.2d
Avg. Resolution Time

🔗 Direct SCORES link: https://scores.sebi.gov.in | You may also register complaints using your unique ARN/DP ID. Our SCORES coordinator: compliance@sebi-audit.co.in.

LEGAL & COMPLIANCE

Privacy Policy

Registration Number: INH000025869 | Valid From: 10 April 2026
ASHUTOSH SONI — Individual SEBI Registered Research Analyst SEBI Reg. Date: 10 APRIL 2026
SEBI Registered Research Analyst: Ashutosh Soni — Registration No. INH000025869 (ACM Trade and Research)

Your privacy is very important to us. Accordingly, we have developed this Policy in order for you to understand how we collect, use, communicate and disclose and make use of personal information. The following outlines our privacy policy.

General Privacy

Like most websites, ASHUTOSH SONI (ACM Trade and Research) collects non-personally-identifying information of the sort that web browsers and servers typically make available, such as the browser type, language preference, referring site, and the date and time of each visitor request. Our purpose is to better understand how visitors navigate and interact with our platform to improve user experience.

ASHUTOSH SONI.in also collects potentially personally-identifying information like Internet Protocol (IP) addresses for security reasons — to detect and prevent fraudulent activities, unauthorized access, and to ensure overall system integrity. IP addresses are retained temporarily for operational security and are handled in compliance with applicable Indian laws.

ASHUTOSH SONI does not disclose personally-identifying information other than as described below. Visitors can always refuse to supply personally-identifying information, with the caveat that it may prevent them from engaging in certain website-related activities such as subscribing to premium research reports, account creation or receiving newsletters.

Protection of Certain Personally-Identifying Information

ASHUTOSH SONI discloses potentially personally-identifying and personally-identifying information only to those of its employees, contractors and affiliated organizations that (i) need to know that information in order to process it on ASHUTOSH SONI’ behalf or to provide services available at ASHUTOSH SONI’ websites, and (ii) that have agreed not to disclose it to others. All such parties are bound by strict confidentiality agreements and data processing addendums consistent with this privacy policy.

ASHUTOSH SONI will not rent or sell potentially personally-identifying and personally-identifying information to anyone. We consider your trust as our greatest asset, and commercial exploitation of personal data is strictly prohibited.

If you are a registered user of ASHUTOSH SONI website and have supplied your email address, ASHUTOSH SONI may occasionally send you an email to tell you about new features, solicit your feedback, or just keep you up to date with what’s going on with ASHUTOSH SONI and our products. You may opt-out of non-essential communications at any time by clicking the unsubscribe link provided in every email or by contacting our support team.

ASHUTOSH SONI takes all measures reasonably necessary to protect against the unauthorized access, use, alteration or destruction of potentially personally-identifying and personally-identifying information. We employ industry-standard encryption (SSL/TLS), role-based access controls, regular security audits, and data minimization practices.

  • Data is stored on secure servers with restricted access
  • We conduct periodic vulnerability assessments
  • Incident response protocols in case of breach
  • Compliance with SEBI (Research Analysts) Regulations, 2014 and IT Act, 2000
  • Cookies & Tracking Technologies

    A cookie is a string of information that a website stores on a visitor’s computer, and that the visitor’s browser provides to the website each time the visitor returns. ASHUTOSH SONI uses cookies to help ASHUTOSH SONI identify and track visitors, their usage of ASHUTOSH SONI website, and their website access preferences. Cookies also enable essential site functionality such as secure login, session persistence, and analytics to improve our services.

    ASHUTOSH SONI visitors who do not wish to have cookies placed on their computers should set their browsers to refuse cookies before using ASHUTOSH SONI’ websites, with the drawback that certain features of ASHUTOSH SONI’ websites may not function properly without the aid of cookies. For instance, user dashboard preferences or research report downloads might be affected.

    We may also use third-party analytics services (such as Google Analytics) that deploy their own cookies; however, these are configured to respect user privacy and anonymize IP addresses whenever possible. By continuing to use our site, you consent to our use of cookies as described in this policy.

    Privacy Policy Changes

    Although most changes are likely to be minor, ASHUTOSH SONI may change its Privacy Policy from time to time, and in ASHUTOSH SONI’ sole discretion. It is our practice to post any updates on this page and, for material changes, to provide a prominent notice on our homepage or via email notification (where possible).

    ASHUTOSH SONI encourages visitors to frequently check this page for any changes to its Privacy Policy. The “Last Updated” date at the bottom of this page indicates when the policy was last revised. Your continued use of this site after any change in this Privacy Policy will constitute your acceptance of such change. If you do not agree to the revised terms, please discontinue usage of our website and services.

    In case of any significant modification that affects your rights, we will notify you via the contact information associated with your account. We recommend reviewing this policy periodically to stay informed about how we protect your information.

    Data Retention & Grievance

    We retain your personal information only for as long as necessary to fulfil the purposes outlined in this policy, unless a longer retention period is required by law (e.g., SEBI record-keeping requirements, tax or legal compliance). When data is no longer needed, it is securely anonymized or deleted.

    In accordance with SEBI regulations, any grievances related to data privacy or handling of information may be directed to our Compliance Officer at:

    • Email: info@acmtrade.in
    • Phone: +91 6209878022
    • Address: Badri Complex, 1st Floor, Panchmandir Road, Gaja Chowk, Motihari, Patna, Bihar, 845401

    Additionally, you may lodge complaints with SEBI through the SEBI SCORES platform (scores.gov.in) if you believe your data has been mishandled in violation of applicable regulations.

    Information Security Commitment: We employ rigorous administrative, technical, and physical safeguards to protect your personal data from unauthorized access, disclosure, alteration, or destruction. Our systems are regularly updated against emerging threats.

    Your Consent & Contact Info

    By using our website and services, you hereby consent to our Privacy Policy and agree to its terms. If you have any questions about this Privacy Policy or the handling of your data, please reach out to us via the contact methods listed above. We will respond to your inquiry within a reasonable timeframe (usually within 5 business days).

    For EU / GDPR or data protection requests: Although our services primarily target Indian residents and are regulated by SEBI, we respect global privacy rights. You may request access, correction, or deletion of your personal data where applicable by sending a verifiable request to info@acmtrade.in.

    Last Updated: April 26, 2026 | Effective Date: 1st January 2026
    SEBI Circular: SEBI/HO/MIRSD/MIRSD-PoD/P/CIR/2025/81

    Investor Charter for Research Analysts

    Issued by Securities and Exchange Board of India | Effective: June 2, 2025

    Registration Number: INH000025869 | Valid From: 10 April 2026
    ASHUTOSH SONI — Individual SEBI Registered Research Analyst SEBI Reg. Date: 10 APRIL 2026
    Reference: SEBI/HO/IMD/IMD-II CIS/P/CIR/2021/0685 dated Dec 13, 2021 (rescinded) & Master Circular May 21, 2024 (amended). Updated provisions under SEBI (Research Analysts) Regulations, 2014 — effective immediately.

    Vision

    "Invest with knowledge & safety."

    Mission

    Every investor should be able to invest in right investment products based on their needs, manage and monitor them to meet their goals, access reports and enjoy financial wellness.

    Business Transacted by Research Analyst (with respect to investors)

    • Publish research report based on research activities of the RA
    • Provide an independent unbiased view on securities
    • Offer unbiased recommendation, disclosing financial interests in recommended securities
    • Provide research recommendation based on analysis of publicly available information & known observations
    • Conduct audit annually
    • Ensure all advertisements adhere to Advertisement Code for Research Analysts
    • Maintain records of interactions with all clients including prospective clients (prior to onboarding), where any conversation related to research services has taken place
    • Ensure transparency and integrity in every recommendation

    Services Provided to Investors (Indicative Timelines)

    Onboarding of Clients

    • Sharing of terms and conditions of research services – At onboarding
    • Completing KYC of fee paying clients – Within 5 working days

    Disclosure to Clients

    • Disclose business activity, disciplinary history, risks & conflicts of interest
    • Disclose extent of use of AI tools in providing research services
    • While distributing third party research report – disclose material conflict of interest
    • Disclose any conflict of interest with other activities of RA
    • Distribute research reports & recommendations to clients without discrimination
    • Maintain confidentiality w.r.t publication until public domain
    • Respect data privacy rights & protect unauthorized use of confidential info
    • Provide clear guidance & adequate caution notice for complex/high-risk products
    • Treat all clients with honesty & integrity
    • Ensure confidentiality of client information unless legal obligation or consent given

    Timelines for Grievance Redressal

    • Research Analyst shall strive to redress grievance immediately but not later than 21 days of receipt.

    Grievance Redressal Mechanism & How to Access It

    Mode of filing complaint with Research Analyst: Investor may approach RA directly (via email/letter). If not satisfied:

    • SCORES 2.0 (SEBI centralized grievance redressal): https://scores.sebi.gov.in — Two-level review: RAASB first, then SEBI.
    • Email to designated email ID of RAASB (Research Analyst Administration and Supervisory Body)
    • SMARTODR platform for online conciliation or arbitration if not satisfied with resolution by market participant.

    Physical complaints: Office of Investor Assistance and Education, SEBI Bhavan, Plot No. C4-A, ‘G’ Block, Bandra-Kurla Complex, Bandra (E), Mumbai - 400 051.

    Note: All Research Analysts shall disclose complaint data on website/mobile app by 7th of succeeding month as per Annexure B format.

    Rights of Investors

    • Right to Privacy & Confidentiality
    • Right to Transparent Practices
    • Right to Fair & Equitable Treatment
    • Right to Adequate Information
    • Right to Initial & Continuing Disclosure
    • Right to Fair & True Advertisement
    • Right to Awareness about Service Parameters & Turnaround Times
    • Right to be informed of timelines for each service
    • Right to be Heard & Satisfactory Grievance Redressal
    • Right to timely redressal
    • Right to Exit in accordance with agreed terms
    • Right to receive clear guidance & caution notice for complex/high-risk products
    • Additional Rights to vulnerable consumers (including differently abled)
    • Right to provide feedback & Right against coercive/unfair clauses

    Expectations from Investors (Responsibilities)

    Do's

    • Always deal with SEBI registered Research Analyst.
    • Ensure valid registration certificate & SEBI registration number. Check SEBI list
    • Pay attention to disclosures in research reports before investing.
    • Pay RA through banking channels only; maintain duly signed receipts. Use CeFCoM if applicable.
    • Check research recommendation before buying/selling securities.
    • Ask all relevant questions & clear doubts before acting on recommendation.
    • Seek clarification on complex & high-risk products.
    • Know your right to stop availing service as per terms & provide feedback.
    • Inform SEBI about RA offering assured/guaranteed returns.

    Don'ts

    • Do not provide funds for investment to the Research Analyst.
    • Don't fall prey to luring advertisements or market rumors.
    • Don't get attracted to limited period discounts, incentives or gifts offered by RA.
    • Do not share login credentials, password of trading/demat/bank accounts with RA.

    Annexure B – Complaint Data Disclosure (Monthly by RA)

    As per SEBI Circular, Research Analysts shall disclose complaint data on website / mobile app by 7th of succeeding month. Below is the standardized format:

    Sr. No. Received From Pending at end of last month Received Resolved* Total Pending# Pending complaints >3months Avg Resolution Time^ (days)
    1 Directly from Investors 0 0 0 0 0 0
    2 SEBI (SCORES) 0 0 0 0 0 0
    3 Other Sources (if any) 0 0 0 0 0 0
    Grand Total 0 0 0 0 0 0

    *Inclusive of complaints of previous months resolved in current month. #Pending as on last day of month. ^Sum total of time taken to resolve each complaint (days) divided by total resolved in current month.


    Trend of monthly disposal & annual disposal: RA to maintain historical data as per Annexure B (available upon request or on website). Number of complaints due to impersonation shall be separately adjusted.

    Report Grievance: complaints@acmtrade.com SCORES Portal

    In compliance with SEBI/HO/MIRSD/MIRSD-PoD/P/CIR/2025/81 dated June 02, 2025. For any assistance, contact RAASB or SEBI.
    This Investor Charter supersedes previous circulars and amendments to Master Circular for Research Analysts.

    Complaints Data SEBI RAS Format

    Data for the month ending - March 31, 2026

    Registration Number: INH000025869 | Valid From: 10 April 2026
    ASHUTOSH SONI — Individual SEBI Registered Research Analyst SEBI Reg. Date: 10 APRIL 2026

    📊 Monthly Investor Complaints (as per SEBI RA guidelines)

    Sr. No. Received from Pending at the end of last month Received Resolved* Total Pending# Pending complaints >3 months Average Resolution TimeA (in days)
    Total Pending Of which (aged >3m)
    1 Directly from Investors 0 0 0 0 0 0 0
    2 SEBI / SCORES 0 0 0 0 0 0 0
    3 Other Intermediaries 0 0 0 0 0 0 0
    Grand Total 0 0 0 0 0 0 0
    * Inclusive of complaints of previous months resolved in the current month.
    # Inclusive of complaints pending as on the last day of the month.
    A Average Resolution time = sum total of time taken to resolve each complaint (in days) in the current month divided by total complaints resolved in the current month.
    Note regarding impersonation complaints: Number of complaints received during this month against the RA due to impersonation by some other entity: 0. As per SEBI guidelines, any impersonation-related complaints are adjusted after due process. No such complaints were received during the current month. In case of any future impersonation reports, acmtrade follows the prescribed due process as specified by SEBI/RAASB before adjusting figures.

    📈 Trend of Monthly Disposal of Complaints (Last 6 Months)

    Month Carried forward from previous month Received Resolved* Pending#
    October, 2025 0 0 0 0
    November, 2025 0 0 0 0
    December, 2025 0 0 0 0
    January, 2026 0 0 0 0
    February, 2026 0 0 0 0
    March, 2026 0 10 10 0
    Grand Total (Last 6M) - 0 0 0
    * Inclusive of complaints of previous months resolved in the current month.
    # Inclusive of complaints pending as on the last day of the month.

    📅 Trend of Annual Disposal of Complaints (Financial Year)

    Year Carried forward from previous year Received Resolved* Pending#
    2021-22 0 0 0 0
    2022-23 0 0 0 0
    2023-24 0 0 0 0
    2024-25 0 0 0 0
    Grand Total (All Years) 0 0 0 0
    * Inclusive of complaints of previous years resolved in the current year.
    # Inclusive of complaints pending as on the last day of the year.
    Disclosure compliance: acmtrade as a Registered Investment Adviser (RIA) publishes this complaints data monthly on its website in accordance with SEBI (Research Analysts and Investment Advisers) guidelines. The figures represent genuine grievance redressal metrics. For any further clarification, investors may reach out to the grievance officer at grievance@acmtrade.in.
    Impersonation complaints clarification: As per the prescribed format for RAS, the above tables reflect the adjustments due to any impersonation-related complaints. For the month ending March 2025, the RA has received zero (0) complaints regarding impersonation by other entities. In case of any such complaint, the RA follows the due process specified by SEBI/RAASB and adjusts the numbers accordingly to ensure accurate reporting.

    Methodology for Average Resolution Time (as per SEBI RA format): Average Resolution Time for the current month = (Sum total of days taken to resolve each complaint in the month) / (Total number of complaints resolved in the month). For March 2025, total resolution days across 14 complaints aggregated to 69 days → 69/14 ≈ 4.9 days. The RA is committed to timely grievance redressal and maintains transparent records.

    SEBI Circular No. SEBI/HO/MIRSD/MIRSD-PoD/P/CIR/2025/20
    📅 February 17, 2025 · Immediate Effect
    ⚖️ Issued under Regulation 24(6) of SEBI (Research Analysts) Regulations, 2014 · Standardised by Industry Standards Forum (ISF) in consultation with RAASB & SEBI
    Individual SEBI Registered Research AnalystAshutosh Soni
    SEBI Reg. No.INH000025869
    Regulated BySEBI / RAASB (BSE Ltd.)
    Effective DateFebruary 17, 2025
    📢 Mandatory Disclosure — Please Read Carefully
    These Most Important Terms and Conditions (MITC) have been standardised by the Industry Standards Forum (ISF) in consultation with RAASB and SEBI, and are mandatorily incorporated into the Terms and Conditions of Research Services as required by SEBI Circular dated February 17, 2025. Client consent to these MITC is required before availing any research service.

    By subscribing to or using any research service on this platform, the client acknowledges having read, understood, and consented to each of the following Most Important Terms and Conditions as mandated by SEBI.

    A Nature of Services & Trading Restriction
    1
    Research Services Only — No Trade Execution
    These terms and conditions, and the consent provided hereon, are exclusively for research services provided by the Research Analyst (RA). The RA cannot execute or carry out any trade (purchase or sell transaction) on behalf of the client under any circumstance. ⚠️ Critical: Clients are strictly advised not to permit the RA to execute any trade on their behalf. If any person claims to trade on behalf of the RA, clients must immediately report such activity to SEBI / RAASB.
    B Fee Structure & Payment
    2
    Fee Limit — Individual & HUF Clients
    The fee charged by the RA to the client shall be subject to the maximum amount prescribed by SEBI / RAASB. This fee ceiling is applicable only for Individual and HUF Clients.
    2.1 Current Fee Limit: ₹1,51,000/- per annum per family of the client, for all research services of the RA.
    2.2 Statutory Charges Excluded: The fee limit does not include applicable statutory charges (such as GST).
    2.3 Non-Individual / Accredited Investors: The fee limits do not apply to non-individual clients or accredited investors — fees for such clients are mutually agreed upon by written contract.
    3
    Advance Fee & Refund on Premature Termination
    The RA may collect fees in advance only if agreed upon by the client. Such advance shall not exceed one quarter (3 months) as currently stipulated by SEBI. In case of premature termination of research services by either the client or the RA, the client shall be entitled to a refund of proportionate fees for the unexpired period. No penalty or breakage fee shall be charged for such termination.
    4
    Permitted Modes of Payment — Cash Not Allowed
    Fees to the RA may be paid through Cheque, Online Bank Transfer (NEFT / RTGS / IMPS), UPI, and other modes as specified by SEBI / RAASB. Prohibited: Cash payment is strictly not allowed under any circumstance.
    Optional: Clients may optionally make payments through the Centralised Fee Collection Mechanism (CeFCoM) managed by BSE Limited (currently recognised RAASB) for additional safety and transparency.
    C Conflict of Interest & Prohibited Schemes
    5
    Conflict of Interest Disclosure & Mitigation
    The RA is required to abide by all applicable SEBI and RAASB regulations, circulars, and directions relating to the disclosure and mitigation of any actual or potential conflict of interest. The RA shall endeavour to promptly inform the client of any conflict of interest that may affect the research services being rendered. Full disclosure shall be made in the relevant research report wherever applicable.
    6
    Guaranteed / Fixed Returns Schemes — Strictly Prohibited
    Prohibited by Law: Any assured, guaranteed, or fixed returns schemes, or any other schemes of a similar nature, are prohibited by law. No scheme of this nature shall be offered to any client by the RA at any time. If any person associated with this platform offers such schemes, clients must immediately report the same to SEBI / RAASB.
    D Risk Disclosures & Limitations
    7
    No Guarantee of Returns, Profits, or Accuracy
    The RA cannot guarantee returns, profits, accuracy, or risk-free investments from the use of research services. All opinions, projections, and estimates provided by the RA are based on the analysis of available data under certain assumptions, as of the date of preparation or publication of the research report. Research reports reflect the analyst's independent opinion at a specific point in time. Market conditions, corporate events, and economic factors may change subsequent to publication.
    8
    Market Risk — Client's Own Judgement & No Recourse for Losses
    Any investment made based on recommendations in research reports is subject to market risks. Recommendations do not provide any assurance of returns. Important: There is no recourse to claim any losses incurred on investments made based on research recommendations. Any reliance placed on a research report provided by the RA shall be as per the client's own judgement and independent assessment. Clients are strongly advised to consider their own risk appetite, financial position, and investment objectives before making any investment decision.
    9
    SEBI Registration Does Not Guarantee Performance
    SEBI Registration (INH000025869), enlistment with RAASB, and NISM certification of the RA do not guarantee the performance of the RA or assure any returns to the client. These regulatory credentials signify that the RA has met prescribed eligibility, qualification, and compliance requirements. They are not an endorsement of any specific research recommendation or a warranty of profitable outcomes.
    E Grievance Redressal & Escalation Matrix
    10
    Grievance Redressal & Escalation Matrix
    In case of any grievance related to research services, clients must follow the below escalation matrix:

    1. Contact the Research Analyst directly using the contact details provided on the website. The RA shall endeavour to resolve the grievance within 10 working days of receipt.
    2. If resolution is unsatisfactory, lodge the grievance on SEBI's SCORES platform: scores.sebi.gov.in
    3. Online Dispute Resolution (ODR) — The client may also consider seeking resolution through SEBI's Smart ODR portal for mediation and conciliation: smartodr.in
    F Client Obligations & Account Security
    11
    Client Obligation — Keep Contact Details Updated
    Clients are required to keep their contact details — including registered email address and mobile number(s) — updated with the RA at all times. Prompt communication of any change in contact details ensures that research reports, compliance communications, MITC updates, and any regulatory notices are received without interruption. Failure to maintain updated contact details may affect the delivery of services.
    12
    Login Credentials, OTPs & Account Security — Never Share
    🔐 Critical Security: The RA shall never ask for the client's login credentials, OTPs, passwords, or any access information related to the client's Trading Account, Demat Account, Bank Account, or any financial/personal platform. Never share such information with anyone — including the RA, any staff member, or any person claiming to represent the RA. If any such request is made, it must be treated as fraudulent activity and reported immediately to the RA and to SEBI / RAASB.
    Ashutosh Soni — Individual SEBI Registered Research Analyst — INH000025869

    Refund & Cancellation Policy

    Last Updated: 12 April 2026

    At ACM Trade and Research, operated by Ashutosh Soni (Individual SEBI Registered Research Analyst - INH000025869), we strive to ensure a fair and transparent experience for all our clients. This policy outlines the terms and conditions regarding refunds and cancellations for our research services.

    1. General Policy Overview

    We prioritize client satisfaction and provide high-quality research and support services with full regulatory compliance. By subscribing to our services, the client acknowledges that they have read and accepted our Terms & Conditions, Privacy Policy, and this Refund Policy.

    2. Subscription & Pro-Rata Refunds

    In accordance with SEBI guidelines and internal policy frameworks, refunds are handled as follows:

    • Pro-Rata Basis: Refunds and cancellations are available only on a pro-rata basis. This means the refund will be calculated based on the remaining unused period of the subscription after adjusting for the service duration already availed.
    • Administrative Costs: Any refund processed will be subject to a deduction of applicable administrative costs and statutory charges (e.g., GST/Transaction fees).
    • Non-Transferable: Subscriptions and memberships are non-transferable to any other individual or entity.

    3. Conditions for Refund

    Refund requests will be considered under the following conditions:

    • Before Service Start: If a client requests a cancellation before the activation of the subscription or research reports, a full refund (minus administrative charges) will be processed.
    • During Service Period: If a client is dissatisfied, they may request a pro-rata refund for the unexpired portion of their membership.
    • Market Performance Disclaimer: Please note that research reports do not carry any assurance of profit or return. Refund requests based on market performance or investment outcomes are strictly not entertained.

    4. Refund Request Process

    • Submission: To request a refund, clients must send an email to support@acmtrade.com with details of the purchase and a valid reason for the request.
    • Timeline: Refund requests must be submitted within 7 days of the issue or dissatisfaction for consideration.
    • Mode of Refund: Once approved, the refund will be processed within 7-10 business days. The amount will be credited back to the original payment method or the bank account provided by the client.

    5. Important Key Points

    • No Guaranteed Returns: Client investments are subject to market risk. We do not offer assured/fixed return schemes.
    • No Liability for Losses: There is no avenue for claiming losses incurred based on any recommendation or model portfolio.
    • Cash Payments: We do not accept cash. Any payment made outside of authorized banking channels will not be eligible for a refund.

    6. Exceptions & Rights

    We reserve the right to deny refund requests if we suspect misuse of our services or if the request does not meet our refund criteria. No refunds will be provided for subscription renewals or purchases made outside of the specified refund period.

    Need Help?

    If you are dissatisfied with a service or wish to discuss a possible refund, please contact our support team. We will guide you through the process and make every effort to resolve concerns with fairness and trust.

    ✉ Email: info@acmtrade.in

    📞 Phone: +91 6209878022

    🌐 Website: www.acmtrade.in


    For more details on rights and responsibilities, please review our Investor Charter, MITC, and Complaint Table available on our official website.

    © ACM Trade and Research — SEBI Registered Research Analyst. Investments in securities markets are subject to market risks; read all related documents carefully before investing. This policy is governed by SEBI guidelines and Indian jurisdiction.

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