28:I[426309,["/_next/static/chunks/33t46atd3n2zd.js","/_next/static/chunks/13_5xgo-88-ti.js","/_next/static/chunks/1qdiot3ypuu8p.js","/_next/static/chunks/0k1u_y85kp1nu.js","/_next/static/chunks/3jv9w5luh13-h.js","/_next/static/chunks/2m2orr4p1zthr.js","/_next/static/chunks/396j1ajnr24t2.js","/_next/static/chunks/40_ipnvspmobm.js","/_next/static/chunks/2k8ijum9vhxzb.js","/_next/static/chunks/0x3w32sab_w1g.js","/_next/static/chunks/0dsf1sm79o3h9.js","/_next/static/chunks/0hhry4zljb_l8.js","/_next/static/chunks/3qlj4t73oud8o.js","/_next/static/chunks/2gxjjg41aomlx.js","/_next/static/chunks/0d5_zjj152e85.js","/_next/static/chunks/162klsaeqauz4.js"],"CompanyPage"] 29:T23d6,## The Revenue Recognition Mechanism Between FY 2011-12 and 2017-18, [The Bombay Dyeing and Manufacturing Company Ltd.](isin#INE032A01023) entered into 11 memoranda of understanding (MoUs) with group company SCAL Services Limited. These MoUs facilitated the bulk sale of allotment rights for 325 flats in Bombay Dyeing's flagship One ICC and Two ICC projects in Dadar, Mumbai, with a total consideration of ₹3,033 crore. Bombay Dyeing recognised revenue of ₹2,492.94 crore—representing 56% of its real estate segment total—and profit before tax of ₹1,302.20 crore during this period. The company applied the percentage-of-completion method under Accounting Standard-7, recognising revenue based on project milestones and an initial 10% booking amount. SCAL subsequently resold the flats to end-buyers, recording profits or losses accordingly[web:1]. ## SEBI's Sham Transaction Allegations SEBI concluded these were sham transactions based on several causal factors. The regulator alleged the MoUs lacked genuine risk transfer or cash flows and were designed to front-load revenues without economic reality. Key red flags included execution on inadequate stamp paper, SCAL's negative net worth, and the circular nature of transactions within the group. SEBI argued that Bombay Dyeing recorded sale proceeds in its books while SCAL did not reflect corresponding purchases, instead showing only an agency commission. This asymmetric accounting treatment, according to SEBI, artificially inflated the listed entity's financial statements and misled investors[web:1][web:17]. ## The Strategic Stake Reduction The timing of Bombay Dyeing's stake reduction proved crucial. On March 29, 2012, the company reduced its direct holding in SCAL from 49% to below 19%. The very next day—March 30, 2012—the first MoU was executed. SEBI characterized this as a "planned reduction" to avoid consolidation of financial statements, as the 20% threshold defines "significant influence" under Section 129(3) of the Companies Act. By keeping direct stake at 19%, Bombay Dyeing argued SCAL ceased to qualify as an associate company requiring consolidation. However, SEBI noted the 30% stake was transferred to another Wadia Group entity rather than an independent third party, maintaining effective control through indirect holdings[web:12][web:17]. ## SAT's Split Verdict on Transaction Substance In January 2026, the Securities Appellate Tribunal delivered a split 2:1 verdict. Technical Members Meera Swarup and Dr. Dheeraj Bhatnagar (majority) determined the MoUs concerned real projects with actual construction and sale of flats. They found no evidence of intent to deceive investors or manipulate the market. The majority noted that all flats were constructed and sold to third parties, evidencing economic substance. They also observed that similar MoU arrangements had been used in past projects without adverse findings, and shared group infrastructure alone did not prove sham transactions. The tribunal flagged SEBI's nine-year delay in action, noting the regulator issued show-cause notices only in June 2021 and passed orders in October 2022[web:1][web:15]. Presiding Officer Justice P.S. Dinesh Kumar dissented vigorously. He found the transactions lacked commercial substance and appeared to exist only on paper between group entities. According to his dissent, the MoUs did not reflect genuine sale of flats and were structured to recognise revenue without corresponding transfer of risks. He emphasized SCAL's negative net worth, minimal actual payments, and extensive group support through loans and comfort letters. Justice Kumar concluded SCAL functioned as an "extended arm" of Bombay Dyeing, warranting the lifting of the corporate veil[web:3][web:18]. ## Associate Company Classification Dispute The transfer of Bombay Dyeing's 30% stake to another Wadia Group entity became central to SEBI's associate company classification argument. Under SEBI's regulatory framework, "significant influence" requires control of at least 20% of total voting power or participation in business decisions under an agreement. While the appellants contended the stake dilution to 19% removed SCAL from related-party status, SEBI argued the indirect control through cross-holdings maintained effective control. The majority held that SEBI had not demonstrated SCAL qualified as an associate company requiring consolidation for the relevant years, noting transactions and disclosures were reflected in the company's accounts[web:3][web:39]. Justice Kumar's dissent applied the single economic entity principle, finding that when companies operate under unified control and direction, they should be treated as one economic unit for regulatory purposes. The circular flow of funds, common economic purpose, and integrated business operations demonstrated that SCAL lacked independent decision-making capacity. This structural characteristic—formal compliance with ownership thresholds masking substantive control—contributed significantly to the split verdict[web:22]. ## SEBI's Penalty Framework SEBI imposed penalties totaling ₹15.75 crore based on the magnitude of financial misrepresentation and deliberate evasion of regulatory requirements. The breakdown included ₹2.25 crore on Bombay Dyeing, ₹4 crore on Nusli Wadia, ₹5 crore on Jehangir Wadia, ₹2 crore on Ness Wadia, ₹1 crore on SCAL, ₹50 lakh on Durgesh Mehta (JMD & CFO), and ₹25 lakh each on SCAL's then directors. Additionally, SEBI barred the Wadias from the securities market for two years and from holding directorships for one year. The regulator found the Wadias had played "an active as well as a deliberate passive role" in the fraudulent scheme[web:5][web:12]. SEBI also penalised five former independent directors serving on the audit committee—Ishaat Hussain, SS Kelkar, RA Shah, S Ragothaman, and SM Palia—with ₹59 lakh for failure to carry out adequate due diligence. Three former CFOs were penalised for certifying that financials presented a true and fair view despite material misstatements. These governance failures enabled the execution of 11 MoUs aggregating ₹3,333 crore over two years without adequate scrutiny[web:70][web:83]. ## Supreme Court Proceedings and Precedent Clarification The Supreme Court recently declined SEBI's request to stay the SAT verdict while hearing the regulator's appeal. The bench of Justices BV Nagarathna and R Mahadevan issued notice to the respondents but clarified that "since the impugned order is a split verdict, 2:1, we observe that the same shall not be a precedent in similar matters before SAT." The Court directed that all four connected appeals be listed together for comprehensive resolution[web:54][web:44]. The nine-year delay significantly influenced the Court's decision. The respondents highlighted that SEBI had not challenged several findings validating the transactions and emphasized the prejudice caused by delayed proceedings. Senior Advocate Arvind Datar, appearing for SEBI, argued the case raised fundamental questions concerning associate companies, corporate veil lifting, and the single economic entity principle. While finding merit in these arguments warranting detailed consideration, the Court denied interim relief based on the split verdict nature, extraordinary delay, and complete factual exoneration by the SAT majority[web:17][web:44]. ## Regulatory Implications The SAT's exoneration of Nusli Wadia and other Wadia Group executives has significant implications for regulatory approach to related-party transactions. The majority's finding that there was "no evidence of intent to deceive investors" establishes a high evidentiary threshold for proving fraudulent intent. This may require regulators to focus more on obtaining direct evidence of intent rather than relying on circumstantial evidence. The case also highlights the tension between formal compliance with ownership thresholds and substantive economic reality in corporate group structures[web:1]. The asymmetric accounting treatment—recording sale proceeds in Bombay Dyeing's books without corresponding purchases in SCAL's books—created significant transparency issues. This distorted revenue recognition, profit inflation, and risk assessment, impairing investor decision-making. The governance failures at multiple levels—board oversight, audit committee due diligence, internal controls, and external audit—enabled these transactions to escape regulatory scrutiny for seven years[web:17][web:70]. As the Supreme Court prepares to hear the consolidated appeals, its eventual decision will be crucial in clarifying the threshold for establishing fraudulent intent under PFUTP Regulations and providing much-needed certainty for companies navigating intra-group transactions and disclosure obligations. The outcome will shape SEBI's enforcement approach and establish important precedents for corporate governance in India's securities markets[web:1][web:54].1e:[["$","script",null,{"type":"application/ld+json","dangerouslySetInnerHTML":{"__html":"{\"@context\":\"https://schema.org\",\"@type\":\"Corporation\",\"name\":\"Bombay Dyeing\",\"url\":\"https://askfuzz.ai/company/bombay-dyeing-ltd\",\"industry\":\"Manmade 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Santhosh leaves to pursue a specific leadership role outside the organization.","title":"Bombay Dyeing CEO Rohit Santhosh to step down in July 2026"},"publish_date":1785557872576},{"news_object":{"overall_sentiment":"neutral","text":"Supreme Court issued notice on SEBI's civil appeal against Bombay Dyeing. The company must file replies; no stay granted on SAT order.","title":"Supreme Court issues notice in SEBI appeal"},"publish_date":1784103738637},{"news_object":{"overall_sentiment":"neutral","text":"Bombay Dyeing filed its BRSR for FY26, detailing ESG initiatives and compliance. The report covers energy efficiency, waste management, and stakeholder engagement.","title":"Bombay Dyeing reports FY26 sustainability"},"publish_date":1783614461992},{"news_object":{"overall_sentiment":"neutral","text":"Bombay Dyeing promoters confirmed no shares were encumbered in FY26. The disclosure was made to BSE and NSE.","title":"Bombay Dyeing confirms no share encumbrance in FY26"},"publish_date":1782870299382},{"news_object":{"overall_sentiment":"neutral","text":"Bombay Dyeing announced a Rs 0.40 per share dividend for FY26. Shareholders must submit tax documents by July 31, 2026, to avoid higher TDS.","title":"Bombay Dyeing sets July 31 deadline for dividend tax details"},"publish_date":1782849449578},{"news_object":{"overall_sentiment":"negative","text":"Bombay Dyeing received a GST order demanding Rs 6.14 Cr for FY 2018-19. The demand includes tax, interest, and penalty on infrastructure charges. The company plans to appeal the order.","title":"Bombay Dyeing faces Rs 6.14 Cr GST demand for FY 2018-19"},"publish_date":1781856206549},{"news_object":{"overall_sentiment":"positive","text":"Bombay Dyeing reported Q4 FY26 standalone net profit of ₹20.99 crore, up from ₹11.48 crore YoY. Revenue from operations rose to ₹395.84 crore. The Board recommended a 20% dividend.","title":"Bombay Dyeing FY26 Results: Q4 Profit Rises, 20% Dividend Declared"},"publish_date":1778361444394},{"news_object":{"overall_sentiment":"neutral","text":"Bombay Dyeing reports SEBI has challenged the SAT order dated January 16, 2026, which had set aside SEBI's October 21, 2022 order. The company is reviewing the development with legal advisors.","title":"Bombay Dyeing Discloses SEBI Challenge to SAT Order"},"publish_date":1778187598033}],"NEWS":[{"id":"6a54c1cfb6ce5670744073bc","card_variant":"primary","web_results_preview":{"total_count":13,"url_list":[{"article_title":"SAT Quashes SEBI Order Accusing Bombay Dyeing of ...","article_url":"https://www.moneylife.in/article/sat-quashes-sebi-order-accusing-bombay-dyeing-of-orchestrating-fraud-scheme-presiding-officer-dissents/79406.html","source_domain":"www.moneylife.in","source_main_domain":"moneylife","source_name":""},{"article_title":"Supreme Court Seeks Reply On SEBI's Appeal Against ...","article_url":"https://www.livelawbiz.com/amp/supreme-court/supreme-court-bombay-dyeing-verdict-sat-will-not-operate-as-precedent-seeks-response-on-sebi-appeal-540930","source_domain":"www.livelawbiz.com","source_main_domain":"livelawbiz","source_name":""},{"article_title":"Lifting Corporate Veil to Include Group Company Assets in ...","article_url":"https://www.drishtijudiciary.com/current-affairs/lifting-corporate-veil-to-include-group-company-assets-in-cirp","source_domain":"www.drishtijudiciary.com","source_main_domain":"drishtijudiciary","source_name":""},{"article_title":"SAT Sets Aside SEBI Penalties Against Bombay Dyeing ...","article_url":"https://www.24law.in/story/sat-sets-aside-sebi-penalties-against-bombay-dyeing-scal-bulk-flat-sale-mous-not-sham-in-2-1-verdict","source_domain":"www.24law.in","source_main_domain":"24law","source_name":""},{"article_title":"SAT Overturns SEBI Orders Against Bombay Dyeing, SCAL ...","article_url":"https://www.livelawbiz.com/securities-law/sat/securities-appellate-tribunal-mumbai-quashes-sebi-orders-alleging-sham-transactions-bombay-dyeing-519956","source_domain":"www.livelawbiz.com","source_main_domain":"livelawbiz","source_name":""},{"article_title":"Supreme Court Declines Stay on SAT Verdict Exonerating ...","article_url":"https://www.moneylife.in/article/supreme-court-declines-stay-on-sat-verdict-exonerating-nusli-wadia-others-in-fraud-scheme-case-issues-notices/81045.html","source_domain":"www.moneylife.in","source_main_domain":"moneylife","source_name":""},{"article_title":"SAT DELIVERS SPLIT VERDICT IN BOMBAY DYEING ...","article_url":"https://www.ilflaw.com/publications/sebi-update-sat-delivers-split-verdict-in-bombay-dyeing-case-majority-allows-the-appeals/","source_domain":"www.ilflaw.com","source_main_domain":"ilflaw","source_name":""},{"article_title":"SEBI bars Bombay Dyeing, Ness Wadia, others from ...","article_url":"https://www.thehindu.com/business/sebi-bars-bombay-dyeing-ness-wadia-others-from-securities-market-for-up-to-two-years-imposes-fines-of-1575-crore/article66043867.ece","source_domain":"www.thehindu.com","source_main_domain":"thehindu","source_name":""},{"article_title":"Bombay Dyeing case: SEBI imposes ₹59 lakh fine on 9 ...","article_url":"https://www.fortuneindia.com/enterprise/bombay-dyeing-case-sebi-imposes-59-lakh-fine-on-9-members/110259","source_domain":"www.fortuneindia.com","source_main_domain":"fortuneindia","source_name":""},{"article_title":"SEBI imposes a penalty of Rs. 2.25 crores on Bombay ...","article_url":"https://www.scconline.com/blog/post/2022/10/27/sebi-barred-bombaydyeingandmanufacturingcompanyltd-promoters-nusliwadia-nesswadia-jehangirwadia-from-accessing-securities-market-2years-violating-provisions-sebipfutpregulations2003-misrepresenting/","source_domain":"www.scconline.com","source_main_domain":"scconline","source_name":""},{"article_title":"SEBI Penalises 5 Ex-directors of Bombay Dyeing, Others ...","article_url":"https://www.moneylife.in/article/sebi-penalises-5-exdirectors-of-bombay-dyeing-others-over-alleged-due-diligence-lapses/68779.html","source_domain":"www.moneylife.in","source_main_domain":"moneylife","source_name":""},{"article_title":"Section 129. Financial statement","article_url":"https://ca2013.com/129-financial-statement/","source_domain":"ca2013.com","source_main_domain":"ca2013","source_name":""},{"article_title":"Supreme Court declines stay on SAT verdict exonerating ...","article_url":"https://www.barandbench.com/news/litigation/supreme-court-declines-stay-on-sat-verdict-exonerating-nusli-wadia-others-in-fraud-scheme-case","source_domain":"www.barandbench.com","source_main_domain":"barandbench","source_name":""}]},"title":"Bombay Dyeing-SCAL Case: Revenue Recognition, Associate Status, and Regulatory Battle","description":"SEBI's ₹15.75 crore penalty against Bombay Dyeing and the Wadia Group for alleged sham transactions with SCAL Services was overturned by SAT in a split 2:1 verdict. The Supreme Court has now clarified that this split verdict will not serve as a precedent, while hearing SEBI's appeal.","text_content":"$29","image_link":"https://images.askfuzz.ai/article_images/9fb97a1d-3ac1-4495-9209-68f885514e66.png","image_source":"","slug":"bombay-dyeing-scal-case-revenue-recognition-associate-status-and-regulatory-battle","last_updated":"2026-07-13T16:15:35.804+05:30","created_at":"2026-07-13T16:15:35.804+05:30","view_count":554,"follow_up_questions":["What enhanced disclosure requirements should SEBI introduce for complex related-party transactions to prevent asymmetric accounting treatment?","How should audit committees strengthen oversight mechanisms for large related-party transactions to prevent governance failures?","What balance should regulators strike between formal compliance with ownership thresholds and substantive economic reality?"],"read_time":"6 min","reading_time":370,"isin":["INE032A01023"],"category":["Connect the Dots"],"llm_info":{"model":""}},{"id":"01KQSXWBGHWET8X9K5XKYNRKZR","card_variant":"primary","web_results_preview":{"total_count":2,"url_list":[{"article_title":"Bombay Dyeing gets income tax assessment order with ₹574 crore income enhancement for AY24 - CNBC TV18","article_url":"https://www.cnbctv18.com/market/stocks/bombay-dyeing-share-price-gets-income-tax-assessment-order-with-rs-574-crore-income-enhancement-for-ay24-ws-l-19898553.htm","source_domain":"www.cnbctv18.com","source_main_domain":"cnbctv18","source_name":"Cnbc Tv18"},{"article_title":"DCB Bank Ltd. 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Shares rise 11.91% despite assessment.","text_content":"*Bombay Dyeing and Manufacturing Company Ltd* received an assessment order from the Income Tax Department's Assessment Unit on Monday, May 4, 2026, enhancing its taxable income by **₹574.35 crore** for Assessment Year 2023-24. According to reports from *CNBC TV18*, the enhanced income has been set off against available tax losses, resulting in a tax demand notice of **₹2,26,760**. The company stated that penalty proceedings have also been initiated separately by the Income Tax Department.","image_link":"https://images.askfuzz.ai/article_images/bombay-dyeing-gets-574-crore-tax-enhancement-order.webp","image_source":"","slug":"bombay-dyeing-gets-574-crore-tax-enhancement-order","last_updated":"2026-05-04T23:22:00.298+05:30","created_at":"2026-05-04T22:01:02+05:30","view_count":333,"follow_up_questions":["What specific transfer pricing adjustments were made that contributed to the ₹574.35 crore income enhancement?","How will the company address the penalty proceedings initiated by the Income Tax Department separately?","What legal remedies under the Income Tax Act will the company pursue to challenge the assessment order?","What other expenses were disallowed that contributed to the income enhancement?","How will the company manage the tax demand of ₹2,26,760 while maintaining its operations?"],"read_time":"less than a minute","reading_time":54,"isin":["INE032A01023"],"category":["Companies"],"category_l2":["Litigation"],"category_l3":["Tax Disputes"],"llm_info":{"model":"artham"}},{"id":"01KE1FTP56KT9VPS23FXGTWM4F","card_variant":"primary","web_results_preview":{"total_count":5,"url_list":[{"article_title":"Crisil revises Bombay Dyeing rating outlook to stable, reaffirms BBB+ rating","article_url":"https://www.cnbctv18.com/market/stocks/crisil-revises-bombay-dyeing-share-price-rating-outlook-to-stable-reaffirms-bbb-rating-19813594.htm","source_domain":"www.cnbctv18.com","source_main_domain":"cnbctv18","source_name":"Cnbc Tv18"},{"article_title":"Bombay Dyeing's Rating Outlook Shifts to Stable: What Crisil's Latest Assessment Means for Investors","article_url":"https://www.whalesbook.com/news/English/industrial-goodsservices/Bombay-Dyeings-Rating-Outlook-Shifts-to-Stable-What-Crisils-Latest-Assessment-Means-for-Investors/6958d9cb5012e0ea752671e5","source_domain":"www.whalesbook.com","source_main_domain":"whalesbook","source_name":"Whalesbook"},{"article_title":"CRISIL Revises Bombay Dyeing Rating Outlook to Stable, Reaffirms BBB+ Rating","article_url":"https://scanx.trade/stock-market-news/stocks/bombay-dyeing-credit-rating-outlook-revised-to-stable-by-crisil-ratings/28965894","source_domain":"scanx.trade","source_main_domain":"scanx","source_name":"Scanx"},{"article_title":"Crisil revises Bombay Dyeing rating outlook to stable, reaffirms BBB+ rating","article_url":"https://www.linkedin.com/posts/cnbc-tv18_crisil-revises-bombay-dyeing-rating-outlook-activity-7413135604210921472-p_hS","source_domain":"www.linkedin.com","source_main_domain":"linkedin","source_name":"Linkedin"},{"article_title":"Bombay Dyeing & Manufacturing Company Ltd. Share Price Today","article_url":"https://www.cnbctv18.com/market/stocks/bombay-dyeing-manufacturing-company-ltd-share-price/BDM/","source_domain":"www.cnbctv18.com","source_main_domain":"cnbctv18","source_name":"Cnbc Tv18"}]},"title":"Crisil revises Bombay Dyeing outlook to stable","description":"Crisil Ratings Ltd has revised its outlook on The Bombay Dyeing and Manufacturing Company Ltd to 'Stable' from 'Positive', while reaffirming the long-term rating at 'Crisil BBB+'. The revision reflects moderation in operating profitability of the polyester staple fibre segment due to reduced export business from 34% to 16% in H1 fiscal 2026, primarily caused by US tariffs.","meta_description":"Crisil revises Bombay Dyeing outlook to stable from positive, reaffirms BBB+ rating amid PSF segment challenges and reduced exports","text_content":"Crisil Ratings Ltd on Friday revised its outlook on the long-term bank facilities and fixed deposits of *The Bombay Dyeing and Manufacturing Company Ltd* to **'Stable' from 'Positive'**, while reaffirming the long-term rating at **'Crisil BBB+'**. The rating on the company's short-term bank loan facilities has been reaffirmed at **'Crisil A2+'**, with total bank loan facilities standing at **₹501 crore**. The rating on fixed deposits of **₹0.3 crore** has also been reaffirmed at 'Crisil BBB+' with the outlook revised to 'Stable' from 'Positive'. According to Crisil, the revision to a **'Stable' outlook suggests the company's creditworthiness will remain steady**, without significant immediate pressure for upgrades or downgrades.","image_link":"https://images.askfuzz.ai/article_images/crisil-revises-bombay-dyeing-outlook-to-stable.jpg","image_source":"cnbctv18","slug":"crisil-revises-bombay-dyeing-outlook-to-stable","last_updated":"2026-01-03T16:09:24.588+05:30","created_at":"2026-01-03T13:56:32+05:30","view_count":19,"follow_up_questions":["Will Bombay Dyeing's PSF segment achieve the critical 2% operating profitability threshold in FY26?","How will the Q4 FY26 real estate project launch impact the company's cash flow and liquidity position?","Can Bombay Dyeing overcome US tariff challenges to restore export volumes from 16% back to 34% levels?","What will be the market response and booking levels for the upcoming real estate project launch?","Will the company's cost efficiency measures be sufficient to offset margin pressures in the PSF segment?"],"read_time":"2 min 40 sec","reading_time":160,"isin":["INE032A01023"],"category":["Debt Markets"],"category_l2":["Rating Actions"],"category_l3":["Outlook Changes"],"llm_info":{"model":""}}],"PEERS":[{"CHAIRMAN_NAME":"Madhu Sudhan Bhageria","DISPLAY_SYMBOL":"Filatex India","HIGH":77.7,"ISIN":"INE816B01035","LISTING_DATE":"","LOW":73,"LTP":76.72,"MARKET_CAPITALISATION":3255.4,"PE_RATIO":17.06,"PREV_CLOSE":73.31,"SEO_SYMBOL":"filatex-india-ltd","SUPPORTED_EXCHANGES":"BOTH","SYMBOL":"FILATEX","SYMBOL_LINK":"https://images.askfuzz.ai/symbol/FILATEX.png","VOLUME":1567238},{"CHAIRMAN_NAME":"Nusli N Wadia","DISPLAY_SYMBOL":"Bombay Dyeing","HIGH":115.8,"ISIN":"INE032A01023","LISTING_DATE":"","LOW":112.54,"LTP":113.19,"MARKET_CAPITALISATION":2351.6,"PE_RATIO":116.17,"PREV_CLOSE":113.86,"SEO_SYMBOL":"bombay-dyeing-ltd","SUPPORTED_EXCHANGES":"BOTH","SYMBOL":"BOMDYEING","SYMBOL_LINK":"https://images.askfuzz.ai/symbol/BOMDYEING.png","VOLUME":512234},{"CHAIRMAN_NAME":"O P 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