WAPL PMS Disclosure Document

Capitalmind Financial Services Private Limited
(Formerly known as Wizemarkets Analytics Private Limited)
Portfolio Management Disclosure Document

 Disclosure on filing with SEBI:

The Document has been filed with the Board along with the certificate in the specified format in terms of
Regulation 22(3) of the SEBI (Portfolio Managers) Regulations, 2020.
 Scope and objective of this Document:
The purpose of this document is to provide essential information about the portfolio services in a manner to
assist and enable the investors in making informed decision for engaging a portfolio manager.
To provide the necessary information about the portfolio manager required by an investor before investing.
The investors are advised to retain a copy of the document for future reference. The investors can download the
latest version of the disclosure document from the capitalmind website https://get.capitalmind.in/wealth >
disclosures > PMS Disclosure Document.
 Portfolio Manager Information:
Name of the Portfolio Manager Capitalmind Financial Services Private Limited

Tradename Capitalmind
Date of Incorporation and CIN No. U74900KA2014PTC076018, 26th August 2014
Registered address #2323, “Prakash Arcade”, 17th cross, 27th Main,

Sector 1, H S R Layout, Bangalore, 560102
SEBI PMS Registration No. and INP000005847, 27th September 2021

date of registration
 Principal Officer Information:
Name of the Principal Officer Deepak Shenoy

Phone Number 080 4121 1210
e-mail Address connect@capitalmindwealth.com
July 2023 Page 2 of 31

Table of contents
Particulars Page No.

1. Disclaimer 4
2. Definitions 4
3. Description of portfolio Manager 6
4. Penalties, Pending litigations and findings on inspection and investigations etc 10
5. Services offered 11
6. Risk factors 13
7. Client representation 15
8. Financial Performance 17
9. Performance of portfolio Managers 17
10. Audit observations 19
11. Nature of expenses 19
12. Taxation 19
13. Accounting policies 29
14. Investors services 31

1) Disclaimer
i. The particulars of this document have been prepared in accordance with the Regulation 22(3) of SEBI
(Portfolio Managers) Regulations, 2020.
ii. This disclosure document has been filed with SEBI as per Regulation 22(7) of SEBI (Portfolio
Managers) Regulations, 2020.
iii. This Document has not been approved or disapproved by SEBI and SEBI do not certify the accuracy or
adequacy of the contents of this Document.
2) Definitions
All terms used in the document takes the meaning as defined in the SEBI Act, regulations, rules, circulars
and amendments. The definitions as per Securities and Exchange Board of India (Portfolio Managers)
Regulations, 2020 which are relevant to the disclosure document are replicated here and any term which
is not defined in the regulations are explained in the respective clause of the document as required.
i. “Capitalmind” is the trade name of the registered portfolio manager.
ii. “Chartered accountant" means a chartered accountant as defined in clause (b) of sub-section (1) of
section 2 of the Chartered Accountants Act, 1949 (38 of 1949) and who has obtained a certificate of
practice under sub-section (1) of section 6 of that Act.
iii. “Discretionary portfolio manager” means a portfolio manager who under a contract relating to
portfolio management, exercises or may exercise, any degree of discretion as to the investment of
funds or management of the portfolio of securities of the client, as the case may be.
iv. “portfolio” means the total holdings of securities and goods belonging to any person.
v. “Portfolio manager” means a body corporate, which pursuant to a contract with a client, advises or
directs or undertakes on behalf of the client (whether as a discretionary portfolio manager or
otherwise) the management or administration of a portfolio of securities or goods or funds of the
client, as the case may be.
vi. “principal officer” means an employee of the portfolio manager who has been designated as such by
the portfolio manager and is responsible for: -(i) the decisions made by the portfolio manager for the
management or administration of portfolio of securities or the funds of the client, as the case may be;
and (ii) all other operations of the portfolio manager.
vii. “related party” in relation to a portfolio manager, means
(i) a director, partner or his relative;

(ii) a key managerial personnel or his relative;
(iii) a firm, in which a director, partner, manager or his relative is a partner;
(iv) a private company in which a director, partner or manager or his relative is a member or director;
(v) a public company in which a director, partner or manager is a director or holds along with his
relatives, more than two per cent. of its paid-up share capital;

(vi) any body corporate whose board of directors, managing director or manager is accustomed to
act in accordance with the advice, directions or instructions of a director, partner or manager;
(vii) any person on whose advice, directions or instructions a director, partner or manager is
accustomed to act:
Provided that nothing in sub-clauses (vi) and (vii) shall apply to the advice, directions or
instructions given in a professional capacity;
(viii) anybody corporate which is—
(A) a holding, subsidiary or an associate company of the portfolio manager; or
(B) a subsidiary of a holding company to which the portfolio manager is also a subsidiary;
(C) an investing company or the venturer of the portfolio manager;
Explanation.—For the purpose of this clause, “investing company or the venturer of a portfolio
manager” means a body corporate whose investment in the portfolio manager would result in
the portfolio manager becoming an associate of the body corporate.
(ix) related party as defined under the applicable accounting standards;
(x) such other person as may be specified by the Board:
Provided that,
(a) any person or entity forming a part of the promoter or promoter group of the listed entity; or
(b) any person or any entity, holding equity shares:
(i) of twenty per cent or more; or
(ii) of ten per cent or more, with effect from April 1, 2023.
in the listed entity either directly or on a beneficial interest basis as provided under section
89 of the Companies Act, 2013, at any time, during the immediate preceding financial year;
shall be deemed to be a related party;]

3) Description of portfolio Manager
i. History, Present Business and Background of the portfolio manager.

The portfolio Manager offers Portfolio Management and subscriptions under the brand Capitalmind. The
company was incorporated on 26th August 2014 as Wizemarkets Analytics Pvt. Ltd and changed its name to
Capitalmind Financial Services Private Limited with ROC approval on 21st July 2023.
a. Capitalmind subscriptions (Aug 2014 onwards, 8+ years)

Capitalmind Financial Services Private Limited (Formerly known as Wizemarkets Analytics Private Limited) Offers
Research and Portfolio Management under the brand Capitalmind. Capitalmind premium and smallcase includes
Research and Analysis on the stock market, derivatives, macro-economics, personal finance etc. Subscribers can
access Capitalmind Premium for portfolio research that they can replicate by themselves, access to content on
financial markets and membership to an online community where they can discuss finance and investing with
other customers and community member.
b. Capitalmind Wealth (Sep 2017 onwards, 6+ years)
Capitalmind received SEBI approval for providing Portfolio Management Services in September 2017 and started
providing services from December 2017.
The details on the service are also available on the website www.capitalmindwealth.com. Capitalmind offers a
combination of debt and equity investments initially with a minimum of Rs 25 lakhs which was increased to 50
lakhs in Jan 2020 by SEBI. Investments can be tailored to meet each customer’s investing preferences around risk,
asset allocation, investment philosophy etc. Key milestones and features include:
 Passive Portfolio at 0.25% per year – among the lowest cost PMS product in India.
 Personalized Asset Allocation (equity and debt) to give each customer the risk exposure that is most suited to
their profile.
 Goal Based Financial Planning to give a context to customer’s investments and bring the SIP concept into
PMS.
c. Capitalmind Mutual Fund
Capitalmind as a sponsor has applied to SEBI for mutual Fund license and the current status of the application as
per SEBI is “Under process”.

ii. Promoters of the portfolio manager, directors, and their background.
a. Details of Mr. Deepak Shenoy - Promoter, Managing Director, CEO and Principal officer
Education
NMIMS – Mumbai
2019 onwards
Post Graduate Diploma in Banking and Finance (Online)
NATIONAL INSTITUTE OF TECHNOLOGY (NIT) – SURATHKAL

1992-1996 Bachelor of Engineering (BE) in Computer Science
NATIONAL COLLEGE – Bangalore

1990-1992
CBSE in SCIENCE stream 1992
Experience
Capitalmind Financial Services Pvt Ltd (Formerly Wizemarkets Analytics Pvt Ltd)
– Bangalore
Founder and CEO (8+ years)
 SEBI Registered Portfolio Manager
 Manages Rs 1000+ crores of 790+ investors as investment in discretionary
2014-Present Portfolio Management
 Advised on Rs 1000+ crores of 10+ investors in PMS advisory.
 Author - “MONEY WISE: Timeless Lessons on Building Wealth”
 Area(s) of responsibility: Investment Management, Marketing, Fundraising,
Overall Management
CAPITALMIND.IN- Bangalore
Author (4 years)
2010-2014  Launched website and wrote analysis on finance, economics and investing
 Area(s) of responsibility: Analysis, Technology, Writing
ICREATE SOFTWARE – Bangalore

Consultant (1 year)
 Helped implement and build iCreate's Regulatory Reporting product
 Provided functional understanding of banking to both product and
2012-2013
implementation teams
 Worked closely with management on strategy new growth opportunities
 Area(s) of responsibility: Product design, business development
ESTEE ADVISORS- Gurugram

Consulting Director on Portfolio Strategies (1 year)
 Helped build, refine and deploy algorithmic strategies, with NSE and SEBI
2009 approvals
 Built solid risk management tools and frameworks, and data analytics
 Built risk visualization metrics, and automated internal reporting framework
 Area(s) of responsibility: Trading Strategy design, programming and analytics

MONEYOGA.COM – Bangalore
Chief Executive Officer (2 years)
 Using analytics and pattern recognition to provide insights for trading and
investing
 Co-founded Moneyoga as a stock market analytics and system-based trading
company
2007-2009  Provided market analytics for stocks, futures & options for the Indian stock
market
 Researched, tested and deployed two algorithm-based trading systems
focusing on cash and derivatives
Designed and coded www.moneyoga.com (Now defunct)
 Area(s) of responsibility: Algorithm Design and Programming
Flovate technologies- Bangalore

Chief Executive Officer India (2+ years)
 Built India division of UK workflow software firm, transferring large contracts
from UK to India
2005-2007  Established cost efficiencies that ensured higher profitability to the group
 Managed low attrition and aligned employee incentives with revenue
 Ensured a smooth acquisition of the company by WNS in June 2007
 Area(s) of responsibility: Financial Modeling, Economic Analysis
Agni software – Bangalore

Chief Executive Officer India (7 years)
 Solutions range from Accounting and ERP solutions to Healthcare and
Insurance processing software applications
 Served Customers in U.S., Canada, U.K., Western Europe, India and in the
1998-2005
Pacific
 Also provides high quality consultancy and contract development services to
customers in the area of business automation software
 Area(s) of responsibility: Programming (Technology), Sales, Operations
icode india – Bangalore

1996-1998
Senior Programmer (2 years)
b) Details of Promoter and Director- Shray Chandra – Promoter and Director
Education
2012-2014 HARVARD BUSINESS SCHOOL - BOSTON, USA

Masters in business administration (General Management) | First Year Honors
2005-2009 YALE UNIVERSITY - New Haven, USA

Bachelor of Science in Computer Science and Mathematics | Bachelor of Arts in Economics.
1993-2004 LOYOLA SCHOOL – Jamshedpur, India

ISC 2005 (Computer Science) | ICSE 2003 (Science stream)

Experience
2017-Present Capitalmind Financial Services Private Limited (Formerly known as Wizemarkets Analytics
Pvt Ltd) – Bangalore
Director (6+ years)
 Worked on SEBI PMS Application, PMS Compliance Officer (2019 – Mar-2021), designed
marketing collateral, team appraisals and goal setting, finance and dashboards.
 Area(s) of responsibility: Compliance, Finance, Legal, HR, Marketing
2014-2016 COVRD – San Francisco, USA

Co-Founder and Sr. Business Analyst (1.5 years)
 Conceptualized and launched product for faster income for freelancers like Uber Drivers
 Area(s) of responsibility: Legal, Hiring, Fundraising
Summer 2013 Amazon Web Services - Seattle, USA

Sr. Technical Product Manager (Intern) (3 months)
 Analysed user behaviour to suggest new getting started features for AWS Elastic
Beanstalk
2011-2012 SILICONINDIA.COM (1 year) – Bangalore

Vice President
 Negotiated revenue-sharing partnership with Ziff Davis (PCMagazine.com) to monetize
their Indian traffic.
 Area(s) of responsibility: Marketing, Business Development, Product Design
2009-2011 JP MORGAN CHASE & CO. – New York, USA

Analyst in Market Risk Management (Sales & Trading class of 2009) (2 years)
Applied analytical techniques to identify, monitor and control firm wide portfolio risks.
Estimated and presented impact of economic events and market movements. Ranked at top
of Analyst class.
 Calculated Stress (Extreme scenario) losses for Rates Exotics, Foreign Exchange and Equity
Derivative desks
 Developed an Excel based tool to quickly approximate scenario profits/losses for the
Rates Exotics desks.
 Presented macro-economic analysis through reports on Sovereign Debt Realities, Impact
of Tax Credits on Retail Sales and the Economic Activity Surprise Index as a Leading
Indicator
 Area(s) of responsibility: Financial Modelling, Economic Analysis
iii. Top 10 Group companies/firms of the portfolio manager on turnover basis as per the latest audited
financial statements
Nil

iv. Details of the services being offered: Discretionary/ Non-discretionary / Advisory.
 Discretionary Services:
Capitalmind offers discretionary portfolio management services. Under this the portfolio manager
individually and independently under the contract with the client exercise or may exercise any degree
of discretion as to the investment of funds or management of the portfolio of securities in good faith
without waiting for directions or approval from its clients. However, the Client can specify securities
they are prevented from investing in because of insider trading or other restrictions.
 Non-Discretionary Services: Not offered currently.

Currently Capitalmind do not offer non-discretionary services to its clients. Under this the portfolio
manager manages the funds of the clients in accordance with the directions of the client where the
client decides the investment approach, portfolio allocation etc and portfolio manager executes and
manages the same as per the directions received.
 Advisory Services:
Under advisory portfolio management services, the portfolio manager only advises or suggests the
investment ideas/ strategies to the clients and the clients have the choice of investment as well as the
execution of the investment advice at his option. Capitalmind currently offers advisory services to
HNIs (High Net Worth Individuals) in accordance with regulations prescribed by SEBI.
4) Penalties, pending litigation or proceedings, findings of inspection or investigation for which action may have
been taken or initiated by any regulatory authority.
(i) All cases of penalties imposed by the Board, or the directions issued by the Board under the Act or
rules or regulations made thereunder: None
(ii) The nature of the penalty/direction: None
(iii) Penalties/fines imposed for any economic offence and/ or for violation of any securities laws: None
(iv) Any pending material litigation/legal proceedings against the portfolio manager/key personnel with
separate disclosure regarding pending criminal cases, if any: None
(v) Any deficiency in the systems and operations of the portfolio manager observed by the Board or any
regulatory agency: None
(vi) Any enquiry/ adjudication proceedings initiated by the Board against the portfolio manager or its
directors, principal officer or employee or any person directly or indirectly connected with the portfolio
manager or its directors, principal officer or employee, under the Act or rules or regulations made
thereunder: None

5) Services Offered under portfolio management services.
Capitalmind discretionary portfolio management take a disciplined, data-driven approach for investing
that is tailored to clients’ risk preferences and life/investment goals. Our goals framework helps clients to
define why they are saving, how much they need and when they need it. Our adaptive platform uses a
combination of debt and equity to figure out the best way to optimize performance and achieve those
goals.
Investments are currently restricted to listed equity and debt securities. Capitalmind dynamically adjust
debt and equity allocations to meet clients’ goals. Periodic rebalances are made to adjust the allocation
ratio between debt and equity and between the securities to make sure the portfolio is optimum for the
changes in market and to meet clients’ goals.
Our advisory services are specific to clients’ needs and we offer advice on all securities and the clients are
at complete discretion to execute our investment advice.
Our investment approaches are:
A. Surge India (formerly called as Long Term Multicap) - Capitalmind Research driven investment into high
quality, long term, growth-oriented stocks.
 Focus on Mahatrends where India benefits and select stocks that will strongly benefit from the
changes.
 Stocks with a strong growth outlook for the long term (10+ year time horizon)
 Run by competent management with a good history of capital allocation.
 Companies with a large addressable market and growing faster than the broad economy.
 Pass our governance checks in terms of accounts, shareholding, debt, and operational metrics.
 Flexibility to invest in special situations with up to 20% of portfolio for short-term returns.
 Strong risk management in place with pre-defined entry/exit strategies
 Stocks with reasonable liquidity in the market (avoid very illiquid stocks)
The goal is to benefit from India’s relatively strong domestic consumption, import substitution and infrastructure
growth in the coming decade.
B. Momentum - Active, Algorithm Based on the momentum factor.

 Rank the universe of stocks by volatility-adjusted returns: prefer smooth positive momentum
over volatile price moves.
 Filter out stocks failing price and absolute and relative volume criteria.
 Screen out stocks with recent fundamental performance issues.
 Move to cash when opportunities don’t exist.
 Use gold or bond ETFs to hedge the risk during sharp market downturns and unexpected triggers
(like Covid)
Compared to pure momentum implementations, a model combining price and volume signals improves our
chances of reducing the impact of sharp drawdowns.
C. Index / Market - Simple, Efficient and High Performing

 Strategy involves investing in a combination of Indian and/or US indices via ETFs to give exposure
to best stocks in India and abroad.

 No Fund Manager or Stock Picker Risk, this bypasses the time consuming and difficult hunt to
identify a great manager from hundreds of talented managers in the market. Don’t have to re-
evaluate every year to check if they have called the future correctly.
 100% passive allocation
D. All Weather Equity - Capitalmind MF portfolio
We’ll help you invest your money into the stock market through a well-researched, broad market mutual
fund portfolio. This suits investors with a hands-off approach to markets - keep the money invested long
enough to make meaningful inflation-beating returns, in a tax-efficient and low churn manner. It will also
be useful for those people that cannot invest directly in stocks because of restrictions at their job or
workplace.
We follow a process that looks at:
 Longevity and Track Record

 AUM Health
 Outperformance vs the category
 Underperformance vs the category
 Volatility
The selection process yields a list of mutual funds that encompasses large, mid and small caps with a
focus on performance, volatility and track record. We rebalance once a year.
E. Sticker shock- High priced stocks only

 A portfolio that selects only high-priced stocks, in terms of absolute value per share will do well as
a portfolio held for the long term.
 Stocks that have a very high absolute price are usually unaffordable for the small retail
population.
 Less selling pressure: With high promoter ownership and mostly institutional ownership, such
stocks have low float and usually, lower volatility.
 Ensure they are strong businesses: Such stocks should have remained in business and growing for
a long time.
 This is a long-term strategy that provides stability, lower volatility and higher governance
standards than most other portfolios.
 The strategy has the same downside risk as any risky equity strategy, so the chance of losing
money is high, and therefore it only makes sense if there is appetite for risk.
 Given the price, this strategy itself requires a minimum of Rs. 25 lakh by itself.
We rebalance the portfolio annually.
F. Strategic debt – Long term and strategic allocation

Some people need a longer-term debt allocation. This can come from their goal definitions, or from their
requirements of longer-term debt allocations.
Rules: Allocate in the following buckets
 PSU and Banking Debt
 Gilt allocations (calls depend on interest rates)
 Strong Corp Bond Exposure (AA, AAA)
 Fund manager to take exposure based on interest rate cycles.
 Only growth funds, no dividends

The idea is to benefit from interest rate cycles and position portfolios appropriately.
G. Short term debt – Tactical allocation with systematic transfers
At Capitalmind Wealth, allocation into equity may sometimes happen in phases. This can take a few
months to deploy. During the time that money is not in equity, it is parked in tactical short term debt
mutual funds.
Rules:
Choose funds that are:
 Available without exit loads.
 Overnight or short-term debt allocation (max: 1-2 years to maturity)
 Do not take credit risk beyond 10%
Changes once a year. Risk management is by checking portfolio regularly.
H. Preserve
Used for Capital preservation + growth. Preserve invests money into a low risk and high-quality debt
mutual fund and re-invest only the interest from the debt mutual fund every month into the CM Index
strategy. The original corpus stays invested in debt always and therefore is preserved. The equity
increases overtime to build growth in the portfolio.
I. CM Low Vol - Quantitative, factor-based

 A quantitative factor-based strategy that invests in approximately 20 stocks showing relatively
lower volatility and alpha over the NIFTY with the objective of generating returns in excess of
the benchmark NIFTY with comparable or lower volatility than the benchmark.
 Rank all stocks based on volatility over a 1 year period.
 Filter for stocks that meet volume criteria for the portfolio, using turnover averages.
 Select the top 20 with an exit filter that allows already present stocks to be ranked a little lower,
to reduce unnecessary transactions.
 Based on the hypothesis that stocks with lower historical volatility and alpha over the
benchmark can deliver excess returns in the future with comparable downside volatility. Read:
Which is the best factor index
 Consists of NSE-listed stocks, mostly of large and mid-cap stocks with some small cap stocks,
meeting conditions of sufficient volumes and liquidity
 Portfolio is reviewed quarterly.
 When stocks meeting entry criteria are not found, the strategy moves partially or fully to cash.
J. Other custom portfolios: Tailor made based on specific client requirements.
The policies for investments in associates/group companies of the portfolio manager and the maximum
percentage of such investments therein subject to the applicable laws/regulations/ guidelines:
Not applicable as we do not have investments in associates/group companies.
6) Risk factors
a. General:
i. Investments in securities are subject to several market risks and there is no assurance or
guarantee that the objective of the investments will be achieved as desired or planned.

ii. The past performance of the portfolio manager does not indicate its future performance and the
returns cannot be guaranteed as per the past performance. Clients are advised to refer past
performance for reference, they should not assume that portfolio manager can continue to yield
same performance and expect assured returns.
iii. There is always a risk arising from the investment approach, investment objective, investment
strategy and asset allocation.
iv. Diversification of the investment is vital as changes in market condition pose different level of
risks to different securities and non-diversification can increase the risk to overall portfolio.
v. There are no transactions of purchase or sale of securities by our entity and our employees who
are directly involved in investment operations having conflict of interest with the portfolio
management transactions.
vi. There are no disclosures of conflict of interest related to services offered by group companies as
we do not have group companies and hence the same is not applicable.
vii. There is no conflict of interest related to services offered by our group companies or associates.
viii. There are no investments of client’s funds in the securities of our related parties or associates and
hence diversification policy as required to be maintained by the regulations shall not be
applicable.
b. Risks specific to our strategies: Our strategies, Surge India, Momentum, Sticker stock, Index/Market, All
weather Equity, CM low-vol and Quantitative are high risk, high equity portfolios which directly or
indirectly in stocks and below are the specific risks involved:
i. Market risk: Market prices may vary significantly from expected numbers because of fear or
uncertainty and cause downside risk at times of volatility.
ii. Liquidity risk: Certain stocks may not provide sufficient liquidity to exit or enter in an easy
manner, coupled with circuit filter limits on the stock’s movements in a day.
iii. Model risk: Any stock or fund selected may not perform as expected in a fundamental,
macroeconomic or technical model, which may be based on limited data.
iv. Macro-economic risks: Factors such as RBI interest rate policies, inflation, rupee depreciation or
fiscal deficit expansion may impact markets adversely.
v. Geopolitical or external risk: Factors unrelated to the market, stock, or sector may impact stock
market liquidity, such as but not limited to war, natural disasters or political decisions.
Debt portfolios tend to have lower volatility but that alone does not translate into lower risk.
Apart from the factors mentioned above in the equity portfolios, there are secondary risks in debt
portfolios. All our other strategies including for Strategic debt, short term debt, preserve has
below specific risks associated as
i. Credit risk: the inability or unwillingness of a company to repay its debt may result in losses due
to defaults.
ii. Interest rate risk: A change in the interest rate stance or widening of credit spreads could
introduce risks in portfolio prices when marked to market.
iii. Reinvestment risk: a model that expects a certain reinvestment rate when coupon payments
are made, introduces the risk that the reinvestment may happen at a lower rate.
iv. Convexity risk: Certain types of fixed income instruments perform adversely due to certain
covenants or structures in the terms of the instrument.
C. Risk Mitigation:
i. For Debt instruments- Due to the nature of the portfolio which invests only in mutual funds that
eventually decide to buy or hold debt instruments, the risk mitigation is to keep a constant

watch on the portfolios of the funds involved once a month and see if the risks are much higher
than required.
ii. For equity instruments- The stock selection is carefully made keeping liquidity and
macroeconomic conditions in mind. There are no “hedge” positions to reduce such risk, but we
retain the ability to go to cash when the model or the fund manager so decides.
7) Client Representation
i. Details of clients and their funds managed
Total No. of Funds managed Discretionary/

Category of clients
Clients (Rs. Crores) Non-Discretionary
a. Associates and group
companies for last 3 years Nil Nil Nil
b. Others
31st March 2021

337 346.05 Discretionary
31st March 2022
629 740.39 Discretionary
31st March 2023 804 1052.16 Discretionary
ii. Complete disclosure in respect of transactions with related parties as per the standards
specified by the Institute of Chartered Accountants of India.
The company had transactions with its related party which requires disclosure as per the standards
specified by the Institute of Chartered Accountants of India, and all the transactions with such related
parties are at arm’s length price. The details of the same are as follows:
iii. Details of transactions with related parties
a) List of Related parties and their relationship

i) List of key managerial personnel
a. MD and CEO
- Mr. Deepak Shenoy
b. Whole Time Director
- Mr. Shray Chandra
c. Company Secretary
- Ms. Neha Sureka
ii) Entities over which Key Managerial personnel of the company exercise significant influence
- Capitalmind Technology Solutions Pvt Ltd

b) Transactions with related parties and the balances
For the year ended For the year ended

Particulars 31 March 2023 31 March 2022
Amount (₹) Amount (₹)
A. Transactions during the year
1. Capitalmind Technology Solutions Pvt Ltd
Incomes:
Interest on Borrowings - 21,18,831
Accounting and book keeping services- Income 2,88,000 2,40,000
Expenses:
Software related services received 4,68,35,200 6,50,00,000
Other Transactions:
Reimbursements received during the year 40,96,886 3,68,517
Transfer of Gratuity Obligation - 7,88,630
Unsecured Loan settled during the year - 2,25,00,000
2. Mr. Shray Chandra

Incomes:
Portfolio Management Service fee income 3,10,45,284 11,40,969
Expenses:
Key Managerial remuneration 12,00,000 12,00,000
3. Mr. Deepak Shenoy
Incomes:
Portfolio Management Service fee income from Account
held jointly with Spouse 1,26,746 93,660
Expenses:
Key Managerial personnel remuneration 1,04,15,187 61,50,000
4. Ms. Neha Sureka

Expenses:
Key Managerial personnel remuneration 3,00,000 1,59,166
There were no contracts or arrangements or transactions entered into during the year ended 31 March 2023,
which were not at arm's length basis.
Related Party Balances as on Balance Sheet dates

As at 31 March 2023 As at 31 March 2022
Particulars Amount (₹) Amount (₹)
1. Capitalmind Technology Solutions Pvt Ltd
Trade receivable from consideration on business transfer 1,12,23,313 1,12,23,313
Amount Receivable towards TDS & Credit Note 1,95,667 35,21,897

Amount Receivable towards transfer of CWIP_Progress Mobile App 11,01,671 -
2. Shray Chandra
Trade receivable 2,48,653 3,38,776
3. Mr. Deepak Shenoy

Trade receivable 36,231 26,309
8) Financial Performance of Capitalmind
The financial performance of the portfolio manager based on the audited financial statements and in
terms of procedures specified by the board for assessing the performance.
Particulars For the year ended For the year ended

31st March 2023 (₹) 31st March 2022 (₹)
Total Revenue 21,41,07,242 16,63,18,071
Total Expenses (20,64,81,402) (16,10,61,159)
Profit / (Loss) before tax 76,25,840 52,56,912
Tax expense:
(a) Current tax expense for current year 62,98,234 25,00,000
(b) Tax on earlier years (5,07,514) 15,498
(c) Deferred tax (50,04,587) (10,35,471)
Profit / (Loss) for the year after tax 68,39,707 37,76,885
Balance carried to reserves and surplus 68,39,707 37,76,885
9) Performance of Portfolio Manager *
Investment Benchmark May 2023 May 2022 May 2021

approach Capitalmind Benchmark Capitalmind Benchmark Capitalmind Benchmark
Momentum Nifty TRI 6.78% 12.94% 4.02% 7.90% 99.69% 64.43%
Surge India Nifty TRI 5.77% 12.94% 19.88% 7.90% 48.83% 64.43%
Index (Market) Nifty TRI 11.30% 12.94% 5.04% 7.90% 47.92% 64.43%
All Weather Nifty TRI 16.10% 12.94% - - - -

Equity
Strategic Debt Refer note 7.21% 0.09% 3.38% 3.53% 2.58% 3.25%
below
Low Volatility Nifty TRI 21.24% 12.94% - - - -
Sticker Shock Nifty TRI 8.33% 12.94% -5.40% 7.90% 27.38% 64.43%

Investment Benchmark May 2023 May 2022 May 2021
approach Capitalmind Benchmark Capitalmind Benchmark Capitalmind Benchmark
Aggressive Nifty TRI -0.39% 12.94% - - - -
Debt
Quantitative Nifty TRI 9.81% 12.94% - - - -
Value
Custom Refer note 6.45% 0.09% 2.87% 3.53% 7.10% 3.25%
Portfolio 1 below
Custom Nifty TRI 11.57% 12.94% 1.43% 7.90% 37.01% 64.43%
Portfolio 2
Portfolio 3 below
Custom Nifty TRI - - -0.82% 7.90% - 64.43%
Portfolio 4
Custom Refer note 9.13% 0.09% -37.66% 3.53% 3.79% 3.25%
Portfolio 5 below
Portfolio 6 below
Custom Nifty TRI - 12.94% - 7.9% - 64.43%
Portfolio 7
Custom Refer note - 0.09% - 3.53% - 3.25%
Portfolio 8 below
Custom Refer note - - 3.07% 3.53% 3.07% 3.25%
Portfolio 9 below
Custom Refer note - - - - 3.48% 3.25%
Portfolio 10 below
Portfolio 11 below
Custom Nifty TRI - - -10.34% 7.90% -1.05% 64.43%
Portfolio 13
Custom Nifty TRI - - -11.94% 7.90% - -
Portfolio 15
Custom Nifty TRI - - -0.03% 7.90% - -
Portfolio 16
Custom Nifty TRI 13.64% 12.94% -2.09% 7.90% - -
Portfolio 17
Custom Nifty TRI - - -1.88% 7.90% - -
Portfolio 18
Custom Nifty TRI 20.40% 12.94% - - - -
Portfolio 19
Note: Benchmark for this portfolio was HDFC Liquid Fund till 31st March 2023 and Crisil Composite Bond Fund
Index with effect from 1st April 2023.
*The performance of the portfolio manager for the last three years, the indicators are calculated using Time
weighted rate of return method in terms of regulations 22 of the SEBI (portfolio managers) regulations, 2020.

10) Audit Observations
No significant audit observations to disclose.
11) Nature of expenses

Capitalmind charges expenses under three heads as detailed below:
i. Management fees: Management fees is charged as agreed with the clients, where discretionary services
are charged at a fixed rate on the daily value of assets under the management. Advisory services are
charged either at a fixed rate on the assets under advisory or on the performance or a fixed sum
periodically as agreed. Management fees range from 0.25% to 1% p.a. of the assets under management
on discretionary services.
ii. Custodian charges: These are the charges at actuals for custodian services, which are charged to
discretionary portfolio management. Custodian charges includes custody charges, transaction charges
and other charges. These charges are related to safe custody of securities, dematerialisation and
rematerialisation and other charges in relation to custodian and depositories.
iii. Brokerage, STT, Stamp duty and Exchange transaction charges: These are mostly variable on the volume
and value of the transactions charged by broker, stock exchange (NSE and BSE) and registrar and transfer
agent. These are charged at actuals.
12) Taxation:
i. General Note and disclaimer:
The information furnished below briefly outlines the key tax implications applicable to the Clients
investing in the Securities based on advice received from the Portfolio Manager. The tax implications are
based on the relevant provisions of the Income-tax Act, 1961, (‘the IT Act’), as amended time to time
(collectively referred to as ‘the relevant provisions’).
Since the information below is based on the relevant provisions as on the date of this document, any
subsequent changes in the said provisions could impact the overall tax considerations for the Client. The
following information is provided for general information purposes only. The following summary of the
anticipated tax treatment does not constitute legal or tax advice and is based on the taxation law and
practice in force at the date of this document. While this summary is considered to be a correct
interpretation of existing laws and practice in force on the date of this document, no assurance can be
given that Courts or other authorities responsible for the administration of such laws will agree with this
interpretation, or that changes in such laws or practice will not occur. This summary does not purport to
be a complete analysis of all relevant tax considerations, nor does it purport to be a complete description
of all potential risks inherent in investing in the Securities based on advice received from the Portfolio
Manager. Clients should make their own investigation of the tax consequences of such investment and
each Client is advised to consult its own tax advisor with respect to the specific tax consequences. The
Portfolio Manager is not making any representation or warranty to any Client regarding any legal
interpretations and tax consequences to the Client.
ii. Tax Implications to Investors

Income arising from purchase and sale of equity shares or preference shares or debentures (hereinafter
referred to as ‘securities’) under PMS can give rise to business income or capital gains in the hands of the
client. The issue of characterization of income is relevant as the tax computation and rates differ in either
of the two situations. The characterization of income arising from transfer of securities as business
income or as capital gains is dependent on whether the securities are held as business / trading assets or
on capital account. Based on various judicial precedents and CBDT Circulars / Instructions, certain tests
are laid down to distinguish between shares held as stock in trade and shares held as investment.
However, many of the tests laid down in CBDT Circular / Instruction and by Courts are subjective and
prone to individual interpretation. In light thereof, each investor will have to independently determine
whether income from transfer of securities will be characterised as ‘business income’ or ‘capital gains’.
iii. Tax slabs
Tax Rates applicable to the assessment year 2024-25 (financial year 2023-24) is detailed below:
 Tax rates applicable to individuals, HUF and NRIs
Old Regime income tax Slab Rates
Resident Individuals Resident Resident

Taxable Income Slabs
& HUF < 60 years of Individuals & HUF Individuals &
age & NRIs > 60 to < 80 years HUF > 80 years
₹ 0.00 – ₹ 2.50 Lakhs NIL

NIL
₹ 2.50 – ₹ 3.00 Lakhs NIL
5%
₹ 3.00 - ₹ 5.00 Lakhs 5%
₹ 5.00 – ₹ 10.00 Lakhs 20% 20% 20%
> ₹ 10.00 Lakhs 30% 30% 30%
A resident individual (whose net income does not exceed ₹ 5,00,000) can avail rebate under section 87A of the IT
Act. It is deductible from income-tax before calculating health and education cess. The amount of rebate is 100
per cent of income-tax or ₹ 12,500, whichever is less.
Income Tax Rates

Income tax slabs
under new regime ^
Up to ₹ 3,00,000 Nil
₹ 3.00,000 to ₹ 6,00,000 5%
₹ 6,00,000 to ₹ 9,00,000 10%
₹ 9,00,000 to ₹ 12,00,000 15%
₹ 12,00,000 to ₹ 15,00,000 20%
Above ₹ 15,00,000 30%
^ Several exemptions and deductions will not be allowed if a person chooses to pay his tax under new regime.

Under the new tax regime, a resident individual (whose net income does not exceed ₹ 7,00,000) can avail rebate
under section 87A of the IT Act. It is deductible from income-tax before calculating health and education cess. The
amount of rebate is 100 per cent of income-tax or ₹ 25,000, whichever is less.
Marginal relief under new tax regime in connection with tax rebate:
The assessee being an individual resident shall be entitled to a deduction from the amount of income-tax on his
total income, of an amount equal to the amount by which the income-tax payable on such total income is in
excess of the amount by which the total income exceeds ₹ 7,00,000.
 Surcharge rates for old tax regime:
Surcharge Rates under old tax regime

Taxable Income slabs ₹ 50 Lakhs ₹ 1 Crore to ₹ 2 Crores to More than
to ₹ 1 Crore ₹ 2 Crores ₹ 5 Crores ₹ 5 crores
Surcharge Rate 10% 15% 25% 37%
Marginal relief under old tax regime

Income Range Marginal Relief
Exceeds Do not Exceed
₹ 50 Lakh ₹ 1 Crore Amount payable as income tax and surcharge shall not
exceed the total amount payable as income tax on total
income of ₹ 50 Lakh by more than the amount of
income that exceeds Rs 50 Lakhs
₹ 1 Crore ₹ 2 Crore Amount payable as income tax and surcharge shall not
exceed the total amount payable as income-tax on total
income of ₹ 1 crore by more than the amount of
income that exceeds ₹ 1 crore
₹ 5 Crore – Amount payable as income tax and surcharge shall not
 Surcharge rates for new tax regime:
Surcharge Rates under new tax regime

Taxable Income slabs ₹ 50 Lakhs ₹ 1 Crore to More than
to ₹ 1 Crore ₹ 2 Crores ₹ 2 Crores
Surcharge Rate 10% 15% 25%

Marginal relief under new tax regime
Income Range Marginal Relief
Exceeds Do not Exceed
₹ 50 Lakh ₹ 1 Crore Amount payable as income tax and surcharge shall not
exceed the total amount payable as income tax on total
income of ₹ 50 Lakh by more than the amount of
income that exceeds Rs 50 Lakhs
₹ 2 Crore - Amount payable as income tax and surcharge shall not
 Exception to incomes taxed under section 111A, 112 and 112A:
Surcharge on incomes taxable under section 111A, 112 and 112A of the IT Act shall be restricted to 15% under
both the tax regimes.
 Health and Education Cess
Health and Education Cess is levied at the rate of 4% on the amount of income-tax plus surcharge under both tax
regimes.
 Tax rates applicable to AOP, BOI and Artificial Juridical person
Net Income Range Rate of Income Tax

Up to ₹ 2,50,000 –
₹ 2,50,000 to ₹ 5,00,000 5%
₹ 5,00,000 to ₹ 10,00,000 20%
Above ₹ 10,00,000 30%
Surcharge and education cess are same as applicable to individuals:
 Tax rates applicable to domestic companies
Turnover Criteria Income tax rate

Where its total turnover or gross receipt during the previous 25%
year 2021-22 does not exceed ₹ 400 crore
Any other domestic company 30%

 Special tax rates applicable to a domestic company
Domestic Company Tax Rate Tax rate

Where it opted for section 115BA 25%
Where it opted for Section 115BAA 22%
Where it opted for Section 115BAB 15%
Surcharge: The rate of surcharge in case of a company opting for taxability under Section 115BAA or Section
115BAB shall be flat 10% irrespective of amount of total income.
 Tax rates applicable to foreign companies
Nature of Income Tax rate

Royalty received from Government or an Indian concern in pursuance of an 50%
agreement made with the Indian concern after March 31, 1961, but before
April 1, 1976, or fees for rendering technical services in pursuance of an
agreement made after February 29, 1964 but before April 1, 1976 and where
such agreement has, in either case, been approved by the Central
Government
Any other Income 40%
 The amount of tax shall be increased by a surcharge at the specified rate percentage of such tax:
Range of Income Surcharge Rate for Surcharge Rate for

domestic companies foreign companies
₹ 1 Crore to ₹10 Crore 7% 2%
Above ₹ 10 Crore 12% 5%
Marginal relief shall be available to companies who are liable to pay surcharges.
Health and Education Cess is levied at the rate of 4% on the amount of income-tax plus surcharge.
 Tax rates applicable to Partnership Firms, LLP, and Local authorities
Particulars Rate
Rate of income tax 30%
Surcharge where total income exceeds ₹ 1 Crore 12%
Marginal relief available Yes
Health and education cess 4%
iv. Tax treatment of Capital gains
 Determination of nature of asset (short term/ long term) based on the period of holding:

Asset Period of holding Short Term / Long Term
Listed equity shares <12 months Short Term
>12 Months Long Term
Unlisted shares <24 months Short Term
>24 months Long Term
Equity Oriented Mutual funds <12 months Short Term
>12 months Long Term
Debt mutual funds <36 months Short Term
(on purchases before 1 April 2023) >36 months Long Term
Debt mutual funds
Any Short term
(on purchases after 1 April 2023)
 Tax on Short-Term and Long-Term Capital Gains
Tax Type Condition Tax applicable

Long-term capital Except on sale of equity shares/ 20%
gains tax units of equity-oriented fund
Long-term capital On sale of Equity shares/ units of 10% over and above ₹ 1 lakh
gains tax equity-oriented fund where
securities transaction tax [STT] is
applicable
Short-term capital Except on sale of equity shares/ The short-term capital gain is added to
gains tax units of equity-oriented fund your income tax and the taxpayer is
taxed according to his income tax slab.
Short-term capital On sale of Equity shares/ units of 15%.
gains tax equity-oriented fund where STT is
applicable
v. Tax treatment of Dividends
The Finance Act, 2020 changed the method of dividend taxation as the DDT liability on companies and mutual
funds stand withdrawn, all dividend received on or after 1 April 2020 is taxable in the hands of the investor/
shareholder. Similarly, the tax of 10% on dividend receipts of resident individuals, HUF, and firms in excess of
Rs 10 lakh (Section 115BBDA) also stands withdrawn.
vi. Tax treatment of Bonus
For computing short term or long-term capital gains, cost of acquisition of bonus shares are considered zero
and entire sale value is taxed at applicable rate.
vii. Tax treatment of Buyback
Capital gains tax are not applicable on the buy-back of shares to the investor.

viii. Tax treatment of demerger
Demerger as an event has no tax implications to investors, however when the demerged shares are sold,
following shall be noted:
The three issues that arise are:
 Whether the new shares (in the resulting companies) are long-term assets or short-term: To find out
whether shares in the resulting companies are long-term or not, the holding period of the original shares
will be included in the period of holding of the new shares.
 Indexation of the capital gains: The indexation will start from the date of allotment of the new shares and
not from the date of acquisition of the original shares. Relevance of indexation is only for working out the
capital gain amount if the same must be set off against capital loss. However, for most shareholders,
there will be no need of this.
 Cost of acquisition of various shares after the demerger transaction: To calculate capital gains when the
shares are sold, a vital piece of information is the cost of acquisition. The original cost of acquisition of
shares will change now on account of the demerger. Plus, there will be a new cost accorded to the new
shares of the resulting companies. The IT Act specifies a formula that considers the proportion of the net
worth of original company vis-à-vis the book value of the businesses transferred to arrive at the new costs
of acquisition.
ix. TDS applicability:
TDS is applicable on dividend distribution by companies and mutual funds on or after 1 April 2020. The normal
rate of TDS is 10% on dividend income paid in excess of ₹ 5,000 from a company or mutual fund.
A resident individual receiving dividends whose estimated annual income is below the exemption limit can
submit form 15G to the company or mutual fund paying the dividend. Similarly, a senior citizen whose
estimated annual tax payable is Nil can submit Form 15H to the company paying the dividend. The company
or mutual fund informs the shareholder about the dividend declaration on their registered mail id and
requires submission of form 15G or form 15H to claim dividend income without TDS.
x. Set of and carry forward of losses
Set off of losses means adjusting the losses against the profit or income of that particular year. Losses that are
not set off against income in the same year can be carried forward to the subsequent years for set off against
income of those years. A set-off could be an intra-head set-off or an inter-head set-off.

a. Intra-head Set Off
The losses from one source of income can be set off against income from another source under the same
head of income.
 Losses from a Speculative business will only be set off against the profit of the speculative business.
One cannot adjust the losses of speculative business with the income from any other business or
profession.
 Loss from an activity of owning and maintaining race-horses will be set off only against the profit
from an activity of owning and maintaining race-horses.
 Long-term capital loss will only be adjusted towards long-term capital gains. However, a short-term
capital loss can be set off against both long-term capital gains and short-term capital gain.
 Losses from a specified business will be set off only against profit of specified businesses. But the
losses from any other businesses or profession can be set off against profits from the specified
businesses.
b. Inter-head Set Off
After the intra-head adjustments, the taxpayers can set off remaining losses against income from other
heads, but the only exceptions are:
 Loss from speculative Business
 Loss from Specified business
 Capital Losses
 Losses from an activity of owning and maintaining race-horses
xi. Cary forward of losses:
After making the appropriate and permissible intra-head and inter-head adjustments, there could still be
unadjusted losses. These unadjusted losses can be carried forward to future years for adjustments against
income of these years. The rules in connection with carry forward differ slightly for different heads of income.
These have been discussed here:
 Losses from House Property:
 Can be carry forward up to next 8 assessment years from the assessment year in which the loss was
incurred.
 Can be adjusted only against Income from house property.
 Can be carried forward even if the return of income for the loss year is belatedly filed.
 Losses from non-speculative business (regular business) loss:
incurred.
 Can be adjusted only against Income from business or profession
 Not necessary to continue the business at the time of set off in future years.

 Cannot be carried forward if the return is not filed within the original due date.
 Speculative Business Loss:
incurred.
 Can be adjusted only against Income from speculative business.
 Not necessary to continue the business at the time of set off in future years.
 Capital Losses:
incurred
 Long-term capital losses can be adjusted only against long-term capital gains.
 Short-term capital losses can be set off against long-term capital gains as well as short-term capital
gains
xii. Deduction options available
Deductions allowed under the IT Act helps to reduce taxable income. One can avail the deductions only if he/
she has made any tax-saving investments or incurred eligible expenses. There are several deductions available
under various sections that will bring down taxable income. The most popular one is section 80C of Chapter
VI-A of the IT Act. Other preferred deductions under Chapter VI-A of the IT Act are 80D, 80E, 80G, 80DDB etc.
Section Deduction on Allowed Limit (maximum)

80C – Investment in PPF ₹ 1,50,000
– Employee’s share of PF contribution
– NSCs
– Life Insurance Premium payment
– Children’s Tuition Fee
– Principal Repayment of home loan
– Investment in Sukanya Samriddhi Account
– ULIPS
– ELSS
– Sum paid to purchase deferred annuity
– Five-year deposit scheme
– Senior Citizens savings scheme
– Subscription to notified securities/notified deposits
scheme
– Contribution to notified Pension Fund set up by Mutual
Fund or UTI.
– Subscription to Home Loan Account scheme of the

National Housing Bank
– Subscription to deposit scheme of a public sector or
company engaged in providing housing finance
– Contribution to notified annuity Plan of LIC
– Subscription to equity shares/ debentures of an approved
eligible issue
– Subscription to notified bonds of NABARD
80CCC For amount deposited in annuity plan of LIC or any other -
insurer for a pension from a fund referred to in
Section 10(23AAB)
80CCD(1) Employee’s contribution to NPS account Maximum up to 10% of
salary
80CCD(2) Employer’s contribution to NPS account Maximum up to 10% of
salary
80CCD(1B) Additional contribution to NPS ₹ 50,000
80TTA(1) Interest Income from Savings account Maximum up to ₹ 10,000
80TTB Exemption of interest from banks, post office, etc. Maximum up to ₹ 50,000
Applicable only to senior citizens
80G Donations to fund/ charitable entities 100%/ 50% of the donation
depending on the donation
recipient
80GG For rent paid when HRA is not received from employer Least of:
– Rent paid minus 10% of
total income
– ₹ 5,000 per month
– 25% of total income
80E Interest on education loan Interest paid for a period of
8 years
80EE Interest on home loan for first time homeowners ₹ 50,000
80EEA Interest on home loan for first time homeowners ₹ 150,000
80EEB Interest on electric vehicle for first time buyers ₹ 150,000
80D Medical Insurance – Self, spouse, children – ₹ 25,000
Medical Insurance – Self, spouse, children [aged >60 years] – ₹ 50,000
Medical Insurance – Parents aged <60 years – ₹ 25,000
Medical Insurance – Parents aged more than 60 years old or – ₹ 50,000
medical expenditure incurred for uninsured parents aged
more than 60 years old
80DD Medical treatment for handicapped dependent or payment
to specified scheme for maintenance of handicapped
dependent
– Disability is 40% or more but less than 80% – ₹ 75,000
– Disability is 80% or more – ₹ 1,25,000
80DDB Medical Expenditure on Self or Dependent Relative for

diseases specified in Rule 11DD
– For less than 60 years old – Lower of ₹ 40,000 or the
amount actually paid
– For more than 60 years old – Lower of ₹ 1,00,000 or the
amount actually paid
80U Self-suffering from disability:
– An individual suffering from a physical disability (including – ₹ 75,000
blindness) or mental retardation.
– An individual suffering from severe disability – ₹ 1,25,000
80GGB Contribution by companies to political parties Amount contributed (not
allowed if paid in cash)
80GGC Contribution by individuals to political parties Amount contributed (not
allowed if paid in cash)
80RRB Deductions on Income by way of Royalty of a Patent Lower of ₹ 3,00,000 or
income received
13) Accounting policies

Capitalmind clients can access the reports related to their portfolio through secured access to its web
app. These reports are also sent to clients periodically (Quarterly) The accounting polies related to the
reports are as under. Annual audited financials are issued to the clients as prescribed under regulation 30
(3) and accounting policies followed for such reporting shall be reported as part of such report.
i. Basis of Preparation:
The portfolio statements have been prepared in accordance with the generally accepted accounting
principles on accrual basis, except for the disclosure of equity and mutual funds under “Portfolio
Summary” which are measured at market value.
ii. Portfolio Investments:

Portfolio investments are stated at cost in the balance sheet. The difference between market value
prevailing as at the year end and cost is disclosed as unrealised gain/loss in the portfolio summary for
the year. Market value of the portfolio investments are determined as follows:
a. Investments in listed securities are valued at the closing price quoted on National Stock
Exchange ("NSE")/ Bombay Stock Exchange ("BSE") as at 31 st March 2023.
b. Investments in units of a mutual fund are valued at the closing Net Asset Value (NAV) of
the relevant scheme as at 31st March 2023.
c. Purchase and sale of investments are accounted for on transaction date basis.
iii. Income
Income comprises of realized gain/ loss from sale of securities and dividend income. Sale of securities
include buy back transactions.
a. Realized gain/loss on sale of investments which is accounted on transaction date is the
difference between the selling price and cost. The cost of investment is identified following

First-in First-Out (FIFO) method.
b. Dividend income is recorded when the right to receive payment is established due to
holding of such securities as on record date. Dividend income is recognised on gross basis
i.e., before tax deduction at source (TDS). TDS on dividend is recognised as capital
withdrawal from client’s portfolio which is accounted based on information received from
the custodian.
c. Distributions from REITs (Real Estate Investment Trusts)/ InvITs (Infrastructure Investment
Trusts) normally comprise of repayment of capital, repayment of debt, dividend,
interest, etc. Dividend and interest are shown under the head ‘Dividends’ in the statement
of profit and loss. Repayment of capital and repayment of debt are adjusted against the
cost of investments.
iv. Expenses
The expenses disclosed in the statement of profit and loss comprises of portfolio management fees,
custodian fees and transaction fees. The basis for accounting is explained below:
a. Portfolio Management fee is accounted at agreed percentage as mentioned in the
portfolio management service agreement, calculated on a daily basis on the value of assets
under management (AUM) and billed on a quarterly basis.
b. Custodian charges are accounted based on the agreed rates calculated on a daily basis on
the value of assets under custody (AUC) / on the transaction value and billed on a quarterly
basis at actuals.
c. Transaction charges on purchase and sale of securities are accounted on transaction dates
at actuals. Transaction charges include exchange transaction fee, securities transaction tax,
stamp duty, SEBI charges, brokerage charges and GST on brokerage and exchange
transaction fees.
v. Balance with banks

Balance with banks represents client’s uninvested amount as on the year end held in the common pool
bank account under the control of the custodian.
vi. Net current assets under portfolio summary.

Net current asset is the sum of balance in bank, receivables from sales, dividends and other corporate
actions as reduced by fees payable towards management and custodian fees.
vii. Partial Withdrawal of Capital

Partial capital withdrawal from the clients is shown as deduction from the capital invested.

14) Investors services
i. Name, address, and telephone number of the investor relation officer who shall attend to the
investor queries and complaints.
Investor Relation Officer Ms. Akanksha Maulik Pandey
Address: Capitalmind Financial Services Private Limited

(Formerly known as Wizemarkets Analytics Private
Limited), #2323, “Prakash Arcade” 3rd Floor, 17th cross,
27th Main, 1st Sector, HSR Layout, Bangalore 560102
Telephone number 080 41211210
ii. Grievance redressal and dispute settlement mechanism.

In case of any concerns first point of contact is team headed by Ms. Akansha Maulik Pandey, Director,
Marketing and Client Relationships and if the client’s complaints are not redressed within a week’s time
then they can approach Mr. Naganandan R M, Compliance Officer. If the client is not satisfied with the
redressal, they can approach Mr. Deepak Shenoy, CEO, Managing Director and the Principal Officer or Mr.
Shray Chandra, Director. If the complaint is not redressed within 1 month, they can complaint to SEBI on
SCORES portal. Though we have prescribed the escalation matrix, based on the severity of the complaint,
the client can choose to contact any person in the above list at any time or to register their complaint on
SCORES. We maintain a register of complaints at the registered office of the company and if an investor can
choose to write their complaints in the register.
For Capitalmind Financial Services Pvt Ltd For Capitalmind Financial Services Pvt. Ltd.
(Formerly known as Wizemarkets Analytics Pvt. Ltd.) (Formerly known as Wizemarkets Analytics Pvt. Ltd.)
SHRAY Digitally signed by SHRAY

CHANDRA
Digitally signed by Deepak
Deepak Shenoy Shenoy
CHANDRA Date: 2023.07.26 15:27:59

+05'30'
Date: 2023.07.26 15:30:00
+05'30'
Shray Chandra Deepak Shenoy

Director Managing Director and CEO
Date: 26th July 2023 Date: 26th July 2023

Place: Bangalore Place: Bangalore

Form C
Securities & Exchange Board of India(Portfolio Managers) Regulations 2020,
[Regulation 22]
Capitalmind Financial Services Private Limited

#2323, “Prakash Arcade”, 17th Cross,
27 main, 1st Sector, HSR Layout, Bangalore-560102
th
Phone: 080 41211210, Email: support@capitalmind.in
We confirm that:
i) The Disclosure Document forwarded to the Securities & Exchange Board of India (SEBI) is in
accordance with the SEBI (Portfolio Managers) Regulations, 2020 and the guidelines and directives
issued by SEBI from time to time;
ii) The disclosures made in the document are true, fair and adequate to enable the investors to make
a well informed decision regarding entrusting the management of the portfolio to us / investment
through Portfolio Manager;
iii) The Disclosure Document has been duly certified by an independent Chartered Accountant,
Naveen S N, Partner, M S N A & Associates LLP, 304 & 305, 3rd Floor, Annex E block, Brigade MM,
Krishna Rajendra Road, Jayanagar, Bangalore, 560082, Phone no. +91 90367 27740, Membership
No.240003 (Firm Registration No. S200365)
Date: 26th July 2023 For Capitalmind Financial Services Pvt. Ltd.
(Formerly known as Wizemarkets Analytics Pvt. Ltd.)
Place: Bangalore
Deepak Digitally signed by Deepak
Shenoy
Shenoy Date: 2023.07.26 17:44:10

+05'30'
Deepak Shenoy
Principal Officer, MD & CEO
Wizemarkets Analytics Private Limited
#2323, 3rd Floor, “Prakash Arcade”,
17th Cross, 27th main, 1st Sector,
HSR Layout, Bangalore-560102
M S N A & ASSOCIATES LLP
Chartered Accountants
DISCLOSURE DOCUMENT CERTIFICATE
To,
The Board of directors
Wizemarkets Analytics Private Limited
#2323, "Prakash Arcade",
17th Cross, 27th Main,
1st Sector, HSR Layout, Bangalore - 560102
1. This certificate is issued in connection with the request made by Capitalmind Financial Services
Private Limited (Formerly known as Wizemarkets Analytics Private Limited and hereinafter
referred to as “Client”) for the purpose of submission to Securities and Exchange Board of India
(hereinafter referred to as “SEBI”) in accordance with the Regulation 22(5) of Securities and
Exchange Board of India (Portfolio Managers) Regulations, 2020 (hereinafter referred to as
“Regulations”).
2. SEBI registered portfolio manager is required to prepare a Disclosure Document (hereinafter

referred to as “Document”) as per the Regulations. Such document shall be submitted to SEBI as
and when there is any material change and shall disclose to the customers prior to entering into
an agreement with such customer as per the Regulations.
Client Responsibility:
3. The management is responsible for preparation of the Disclosure Document according to the
terms of Regulations including maintenance of all accounting and other records supporting the
contents of the document. This responsibility includes the design, implementation and
maintenance of internal control relevant to the preparation and presentation of the document.
4. The client holds full responsibility with respect to the maintenance of sufficient and appropriate
records/ documents/ supportings to substantiate the contents of the document. Further, it is the
responsibility of the client to fully comply with provisions of the Securities and Exchange Board
of India (Portfolio Managers) Regulations, 2020. It is also the responsibility of the client to
ensure that information provided is complete in all aspects and are true and correct.
Practitioner’s Responsibilities:
5. We conducted our examination of the Statement in accordance with the Guidance Note on
Reports or Certificates for Special Purposes issued by the Institute of Chartered Accountants of
India. The Guidance Note requires that we comply with the ethical requirements of the Code of
Ethics issued by the Institute of Chartered Accountants of India.
Registered Office: No. 304 & 305, 3rd Floor, Annexe Block, Brigade MM, K R Road, Jayanagar 7th Block, Bengaluru - 560082
LLP Registration No: AAR-8776
6. We have complied with the relevant applicable requirements of the Standards on Quality
Control (SQC) 1, Quality Control for Firms that perform Audits and Reviews of Historical Financial
Information, and Other Assurance and Related Services Engagements.
7. Pursuant to the requirements of the Regulation, it is our responsibility to provide limited

assurance whether if something has come to our attention that causes us to believe that the
Disclosure Document is materially misstated.
8. This is a limited assurance engagement. Consequently, procedures performed in a limited

assurance engagement vary in nature and timing from, and are less in extent than for, a
reasonable assurance engagement. Therefore, the level of assurance obtained in a limited
assurance engagement is substantially lower than the assurance that would have been obtained
had a reasonable assurance engagement been performed. We have performed our procedures
based on the nature, timing and extent necessary to form our opinion.
9. Pursuant to our procedures, we state that:
a. We have relied on the directors’ declaration with respect to their background. Accordingly,
we have not checked the veracity of such declarations.
b. We have relied on the signed financial statements for the year ended 31 March 2023 of the
Company for related party transactions. Further, we have relied upon the representations/
declarations by the management for the disclosure.
c. The data presented under ‘financial performance of Capitalmind’ has been extracted out of
the audited financial statements of the Company for the year ended 31st March 2023.
d. Pursuant to the circular SEBI/HO/IMD/DF1/CIR/P/2020/26 dated February 13, 2020, the
Company has applied the methodology of time weighted rate of return for the returns as
disclosed under ‘Performance of Portfolio Manager’. The return so mentioned is verified
with the SEBI returns filed for May 2023, May 2022 and May 2021 respectively. We have also
relied on the independent practitioner’s certificate dated May 26, 2023 who has expressed
unqualified opinion in this regard.
e. The amount of funds managed as disclosed under ‘Client Representation’ is verified with the
SEBI returns filed and we have relied on the management representation.
f. We have relied on the signed financial statements for the year ended 31 March 2023 of the
Company for information pertaining to pending litigations and management representation
for the period commencing from April 01, 2023 till May 31, 2023. With respect to the
penalties, the management has provided us the ledger extracts as part of the
representations for the period covered in the disclosure document.
g. With respect to the name change of the company from Wizemarkets Analytics Private
Limited to Capitalmind Financial Services Private Limited, we have verified the details from
Ministry of Corporate Affairs(MCA) website and the name approval status in the MCA
website with effect from 21-July-2023.
10. The financial statements referred to in paragraph 9 above have not been audited by us.
Opinion:
11. Based on the procedures performed and evidence obtained, nothing has come to our attention
that causes us to believe that the Disclosure Document is materially misstated as per the
provisions of Regulations
Restrictions on use:
12. The certificate is addressed to and provided to the Client solely for the purpose as mentioned in
paragraph 1 and 2 and should not be used by any other person or for any other purpose.
Accordingly, we do not accept or assume any liability or any duty of care for any other purpose
or to any other person to whom this certificate is shown or into whose hands it may come
without our prior consent in writing.
For M S N A & Associates LLP

Firm Registration No: S200365
Naveen S Digitally signed by

Naveen S N
N Date: 2023.07.26
19:39:33 +05'30'
Naveen S N
Partner
Membership No: 240003
UDIN: 23240003BGWWBH9684
Place: Bengaluru
Date: 26-July-2023

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Capitalmind Financial Services Private Limited

(Formerly known as Wizemarkets Analytics Private Limited)

Portfolio Management Disclosure Document

 Disclosure on filing with SEBI:

 Scope and objective of this Document:

 Portfolio Manager Information:

Name of the Portfolio Manager Capitalmind Financial Services Private Limited

Date of Incorporation and CIN No. U74900KA2014PTC076018, 26th August 2014

Registered address #2323, “Prakash Arcade”, 17th cross, 27th Main,

SEBI PMS Registration No. and INP000005847, 27th September 2021

 Principal Officer Information:

Name of the Principal Officer Deepak Shenoy

July 2023 Page 2 of 31

Particulars Page No.

July 2023 Page 3 of 31

i. “Capitalmind” is the trade name of the registered portfolio manager.

vii. “related party” in relation to a portfolio manager, means

(i) a director, partner or his relative;

July 2023 Page 4 of 31

July 2023 Page 5 of 31

i. History, Present Business and Background of the portfolio manager.

a. Capitalmind subscriptions (Aug 2014 onwards, 8+ years)

b. Capitalmind Wealth (Sep 2017 onwards, 6+ years)

c. Capitalmind Mutual Fund

July 2023 Page 6 of 31

NATIONAL INSTITUTE OF TECHNOLOGY (NIT) – SURATHKAL

NATIONAL COLLEGE – Bangalore

ICREATE SOFTWARE – Bangalore

ESTEE ADVISORS- Gurugram

July 2023 Page 7 of 31

Flovate technologies- Bangalore

Agni software – Bangalore

icode india – Bangalore

b) Details of Promoter and Director- Shray Chandra – Promoter and Director

2012-2014 HARVARD BUSINESS SCHOOL - BOSTON, USA

2005-2009 YALE UNIVERSITY - New Haven, USA

1993-2004 LOYOLA SCHOOL – Jamshedpur, India

July 2023 Page 8 of 31

2014-2016 COVRD – San Francisco, USA

Summer 2013 Amazon Web Services - Seattle, USA

2011-2012 SILICONINDIA.COM (1 year) – Bangalore

2009-2011 JP MORGAN CHASE & CO. – New York, USA

July 2023 Page 9 of 31

 Non-Discretionary Services: Not offered currently.

(ii) The nature of the penalty/direction: None

July 2023 Page 10 of 31

Our investment approaches are:

B. Momentum - Active, Algorithm Based on the momentum factor.

C. Index / Market - Simple, Efficient and High Performing

July 2023 Page 11 of 31

D. All Weather Equity - Capitalmind MF portfolio

We follow a process that looks at:

 Longevity and Track Record

E. Sticker shock- High priced stocks only

We rebalance the portfolio annually.

F. Strategic debt – Long term and strategic allocation

July 2023 Page 12 of 31

G. Short term debt – Tactical allocation with systematic transfers

Changes once a year. Risk management is by checking portfolio regularly.