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CARAVELA BEACH RESORT June 26, 2026 VARCA, GOA The Chairman, Securities and Exchange Board of India, Plot No.C4-A,'G' Block, Bandra Kurla Complex, Bandra (East), Mumbai 400051 Subject: Complaint against Simply Wall Street Pty Ltd for serious and blatant violations of SEBI regulations and request for passing of a cease and desist order and other consequential enforcement action against it. Dear Sir/Madam, We, Advani Hotels & Resorts (India) Ltd. (‘Company”), a company listed on the BSE (523269) and NSE (ADVANIHOTR), bring to your urgent attention, serious and blatant contravention of certain regulations administered by the Securities and Exchange Board of India (“SEBI") by Simply Wall Street Pty Ltd (ACN 600 056 611) ("SWS”). SWS, through its website www.simplywall.st (“Simply Wall St), systematically publishes articles, reports, analyses and dashboard content concerning the Company, which are, in several respects, factually inaccurate, incomplete and misleading, and that in our respectful submission, constitute research reports under the Securities and Exchange Board of India (Research Analysts) Regulations, 2014 (‘RA Regulations”) In terms of Regulation 3 of the RA Regulations, no person can act as a research analyst or research entity without registering as such with SEBI. Regulation 4 of the RA Regulations further mandates a foreign entity that is issuing research reports to enter into an agreement with a research analyst or research entity registered with SEBI as a Research Analyst. Regulation 21 of the RA Regulations requires any person making recommendations on public media is required to disclose, inter alia, its registration status. However, SWS does not disclose any such registration status, including any agreement with a SEBI-registered research analyst or research entity on Simply Wall St, where it publishes research reports as required under Regulation 21 of the RA Regulations. The RA Regulations also require compliance with the legal requirements, including requirements of Regulation 15(1)(iij) of the RA Regulations, which are expected to be undertaken by an Indian SEBI-registered research analyst or research entity. SWS flouts these mandates with utter disdain. It disseminates financial data and investment recommendations in respect of Indian listed securities from outside India without there being any clarity of them having any registration, agreement, or compliance whatsoever under the RA Regulations. By flooding the Indian market with such inaccurate content, SWS exposes millions of retail investors, predominantly small, individual shareholders, to manipulative, misleading advice and information that may distort valuations, affect market integrity, and invite systemic risks. SWS’s reach amplifies this peril, potentially fueling volatility and undermining investor confidence in Indian capital markets. Owned and operated by : ADVANI HOTELS & RESORTS (INDIA) LIMITED Registered Office : 18A & 188, Jolly Maker Chamber - I, Nariman Poine, Mumbai - 400021,Te i.: (91-22) 22850101 CIN-1999991 M98H7P I (042891 Website: www.car avelabeachresortgoa.com We highlight the following specific instances of violation and misleading publication by SWS, as these instances demonstrate a recurring pattern of inaccurate and misleading content relating to the Company. (a) Dashboard content: The dashboard relating to the Company on Simply Wall St contains the following inaccurate and misleading statements, which present a materially inaccurate and incomplete picture of the Company's affairs by omitting relevant facts, relying on erroneous assumptions and advancing conclusions that are not supported by publicly available information: (i) Dividend: The dashboard of SWS states that the Company’s dividend has been volatile in the last 10 years. However, contrary to the above averment, except in the financial year 2020-21 (when the Company was affected due to the COVID-19 pandemic), the Company has paid regular and healthy dividends, as published in the Company’s Financial Summary in the Annual Reports. Over the last ten years, the Company has paid dividends aggregating INR 102,00,00,000 (including dividend tax) to all its shareholders in nine out of the last ten financial years. The only year during which the Company did not declare a dividend was the financial year 2020-2021, during which the resort was closed for six months due to the COVID-19 lock-down (i) Number of Directors: The dashboard of SWS flags in a red colour and states that: (A) the Company has ‘insufficient new directors’; and (B) the Company has ‘high number of new directors’. These two statements of SWS are mutually contradictory. It is thus observed that SWS via its dashboard is trying to create a negative perception about the Company and its management. (ii) Negative Remarks: The dashboard sets out several negative remarks, including ‘Below Future Cash Flow Value’, ‘Significantly Below Future Cash Flow Value’, ‘Price-To-Earnings vs Fair Ratio’ and ‘Analyst Forecast’ without any explanation of the basis for such negative remarks. Details pertaining to the remarks are given below: A. Two of the remarks are in substance identical, distinguished only by the addition of ‘significantly’, thereby conveying the impression of two distinct adverse findings while referring to the same observation. B. SWS has not disclosed the methodology or the assumptions underlying its Discounted Cash Flow model, which states that the Company’s ‘Cash Flow Value’ & ‘Future Cash Flow Valuge’ is only INR 20.39 per equity share. On that basis, and given the prevailing price of INR 53.86 per share, SWS asserts that the Company’s stock price is 164.2% overvalued, an assertion emphasized in red. By contrast, two Registered Valuers approved by SEBI have undertaken detailed Discounted Cash Flow analyses and set out their methodology and assumptions in their respective Executive Summary Report for the valuation of the operating business undertaking of the Caravela Beach Resort Goa as a going-concern of the Company, which have been released in the public domain on June 12, 2026, and these are attached as Annexure A and Annexure B. In addition, the above-mentioned Registered Valuers have undertaken a detailed valuation of the Company's freehold land and the market value of the same. These reports have been released in the public domain on May 26, 2026, and these are attached as Annexure C and Annexure D. C. On the valuation figures published by SWS that are visible on their website as on June 25, 2026, the value of INR 20.39 per equity share, which applied to 9,24,38,500 fully paid up shares, implied a market capitalization of INR 188,48,00,000, which is 56% lower than the value of the Company’s freehold land itself, without even considering the value of the business undertaking. SWS further lists two additional negative factors under the valuation section on the dashboard, namely ‘Price-To-Earnings vs Fair Ratio’ and ‘Analyst Forecast’, without any explanation of the ‘Analyst Forecast' or the basis for the negative ‘Price- To-Earnings vs Fair Ratio’. (iv) Future Growth: In the future growth section on the dashboard, SWS usually presents revenue and earnings growth projections based on the consensus estimates of professional analysts to help investors understand the company’s ability to generate profit. In the dashboard, there is a statement analyst forecast. its future earnings cannot be reliably calculated. and it describes this as a rare situation, given that 97% of companies covered by Simply Wall St have past financial data. This is incorrect because the Company is a listed company whose financial data is publicly available. Additionally, it is notable that while SWS states that it lacks sufficient data for forecasting, it nonetheless assigns the Company adverse factors with respect to the ‘Valuation Score’ and ‘Future Cash Flow Value'. This position is inconsistent and indicates that the conclusions drawn by SWS are arbit [Showing first 8,000 characters — download PDF for full document]