MIRA INFORM REPORT

Report Date :

23.02.2013

IDENTIFICATION DETAILS

Name :	ADANI PHARMACHEM PRIVATE LIMITED
Registered Office :	Plot No. 198/2, Aji, GIDC, Phase II, Road – M, Rajkot-360003, Gujarat
Country :	India
Financials (as on) :	31.03.2012
Date of Incorporation :	05.04.1999
Com. Reg. No.:	04-035693
Capital Investment / Paid-up Capital :	Rs.4.344 Millions
CIN No.: [Company Identification No.]	U24231GJ1999PTC035693
IEC No.:	2488007005
TAN No.: [Tax Deduction & Collection Account No.]	RKTA00042A
PAN No.: [Permanent Account No.]	AADCA2201R
Legal Form :	Private Limited Liability Company
Line of Business :	Manufacturers and Exporters of Bulk Drugs and Fine Chemicals.
No. of Employees :	36 (In Office 10) (In Factory 20) (In Branch 6) (Approximately)

RATING & COMMENTS

MIRA’s Rating :

Ba (45)

RATING		STATUS	PROPOSED CREDIT LINE
41-55	Ba	Overall operation is considered normal. Capable to meet normal commitments.	Satisfactory

Maximum Credit Limit :	USD 139000
Status :	Satisfactory
Payment Behaviour :	Usually Correct
Litigation :	Clear
Comments :	Subject is an established company having satisfactory track. Trade relations are reported as fair. Business is active. Payments are reported to be usually correct and as per commitments. The company can be considered normal for business dealings at usual trade terms and conditions.

NOTES :

Any query related to this report can be made on e-mail : infodept@mirainform.com while quoting report number, name and date.

ECGC Country Risk Classification List – June 30, 2012

Country Name	Previous Rating (31.03.2012)	Current Rating (30.06.2012)
India	A1	A1

Risk Category	ECGC Classification
Insignificant	A1
Low	A2
Moderate	B1
High	B2
Very High	C1
Restricted	C2
Off-credit	D

INDIAN ECONOMIC OVERVIEW

India is developing into an open-market economy, yet traces of its past autarkic policies remain. Economic liberalization, including industrial deregulation, privatization of state-owned enterprises, and reduced controls on foreign trade and investment, began in the early 1990s and has served to accelerate the country's growth, which has averaged more than 7% per year since 1997. India's diverse economy encompasses traditional village farming, modern agriculture, handicrafts, a wide range of modern industries, and a multitude of services. Slightly more than half of the work force is in agriculture, but services are the major source of economic growth, accounting for more than half of India's output, with only one-third of its labor force. India has capitalized on its large educated English-speaking population to become a major exporter of information technology services and software workers. In 2010, the Indian economy rebounded robustly from the global financial crisis - in large part because of strong domestic demand - and growth exceeded 8% year-on-year in real terms. However, India's economic growth in 2011 slowed because of persistently high inflation and interest rates and little progress on economic reforms. High international crude prices have exacerbated the government's fuel subsidy expenditures contributing to a higher fiscal deficit, and a worsening current account deficit. Little economic reform took place in 2011 largely due to corruption scandals that have slowed legislative work. India's medium-term growth outlook is positive due to a young population and corresponding low dependency ratio, healthy savings and investment rates, and increasing integration into the global economy. India has many long-term challenges that it has not yet fully addressed, including widespread poverty, inadequate physical and social infrastructure, limited non-agricultural employment opportunities, scarce access to quality basic and higher education, and accommodating rural-to-urban migration.

Source : CIA

EXTERNAL AGENCY RATING

Rating Agency Name	CRISIL
Rating	SE1B
Rating Explanation	Moderate
Date	21.06.2012

RBI DEFAULTERS’ LIST STATUS

Subject’s name is not enlisted as a defaulter in the publicly available RBI Defaulters’ list.

EPF (Employee Provident Fund) DEFAULTERS’ LIST STATUS

Subject’s name is not enlisted as a defaulter in the publicly available EPF (Employee Provident Fund) Defaulters’ list as of 31-03-2012.

INFORMATION PARTED BY

Name :	Mr. Rushabh Haresh Adani
Designation :	Director
Contact No.:	91-9825213332

LOCATIONS

Registered Office / Factory 1 :	Plot No. 198/2, Aji, GIDC, Phase II, Road – M, Rajkot-360003, Gujarat, India
Tel. No.:	91-281-2387652 / 2389068
Mobile No. :	91-9825213332 / 9825077652 (Mr. Rushabh Haresh Adani)
Fax No.:	91-281-2387607
E-Mail :	exports@adanipharma.com rushabh@adanipharma.com cb191@corpbank.co.in
Website :	http://www.adanipharma.com
Area :	1087 sq. ft. / 1084 Sq. ft.
Location :	(Factory) (Owned)
Corporate Office :	Rashtriyashala Marg, Rajkot-360002, Gujarat, India
Tel. No.:	91-181-2466796 / 2464365
Admin Office / Factory 2 :	Plot No. 2729 to 2731, Road I-1, Lodhika, GIDC, Village Metoda, Taluka Lodhika, Rajkot-360021, Gujarat, India
Tel. No.:	91-2827-287165/640131/32/33/34
Fax No.:	91-2827-287166
Branch Office :	Manish Compound, Building No. 2, Thane-Bhiwandi Road, Bhiwandi, District Thane, Maharashtra, India
Location :	Rented

DIRECTORS

AS ON 25.09.2012

Name :

Mrs. Nirali Rushabh Adani

Designation :

Director

Address :

7^th Floor, C 7, Prayag C, Shroff Road, Kitab Ghar Street, Rajkot – 360 001, Gujarat, India

Date of Birth/Age :

29.05.1981

Date of Appointment :

07.01.2011

Din No.:

03383012

Name :

Mr. Harshad Anantrai Adani

Designation :

Director

Address :

B/H Tashtriya School, Rashrtiya Shala Compound, Near Yagnik Road, Rajkot - 360 002, Gujarat, India.

Date of Birth/Age :

15.06.1953

Qualification :

B.Sc.

Date of Appointment :

05.04.1999

Din No.:

00290012

Other Directorship:

S. No.	CIN/LLPIN	Name of the Company/ LLP	Current designation of the Director/ Designated Partner	Date of appointment at current designation	Original date of appointment	Company/ LLP Status	Defaulting status
1	U15400GJ1995PTC027318	ADANI FOOD PRODUCTS PRIVATE LIMITED	Director	06-09-95	06-09-95	Active	NO
2	U24231GJ1999PTC035693	ADANI PHARMACHEM PRIVATE LIMITED	Director	05-04-99	05-04-99	Active	NO

Name :

Mr. Rushabh Haresh Adani

Designation :

Director

Address :

7^th Floor, C 7, Prayag C, Shroff Road, Kitab Ghar Street, Rajkot – 360 001, Gujarat, India

Date of Birth/Age :

28.08.1981

Qualification :

BBA

Date of Appointment :

01.04.2004

Din No.:

00298500

MAJOR SHAREHOLDERS / SHAREHOLDING PATTERN

AS ON 25.09.2012

Names of Shareholders	No. of Shares
Harshad Anantrai Adani	77736
Mrudaula P. Adani	37067
Usha A. Adani	34729
Rushabh Haresh Adani	227800
Nirali Rushabh Adani	27668
Arunaben H Adani	20000
Kappac Pharma Limited, India	18750
Total	443750

AS ON 25.09.2012

Equity Share Breakup	Percentage of Holding
Category
Bodies corporate	4.41
Directors or relatives of directors	95.59
TOTAL	100.00

BUSINESS DETAILS

Line of Business :

Manufacturers and Exporters of Bulk Drugs and Fine Chemicals.

GENERAL INFORMATION

No. of Employees :

36 (In Office 10) (In Factory 20) (In Branch 6) (Approximately)

Bankers :

• Corporation Bank, Main Branch, “Nijanand”, Dhebar Road, Rajkot-360001, Gujarat, India
• Axis Bank Limited, Kalavad Road Branch, Rajkot-360001, Gujarat, India
• HDFC Bank, Near Rajkumar College, Rajkot-360001, Gujarat, India
• ICICI Bank

Facilities :

Secured Loan	As on 31.03.2012 [Rs. in Millions]	As on 31.03.2011 [Rs. in Millions]
Corporation Bank [Cash Credit]	4.741	8.982
Corporation Bank [FBP]	16.238	5.936
Corporation Bank [PCL]	4.994	0.000
Corporation Bank [Term Loan]	12.374	13.607
TOTAL	38.347	28.525

Banking Relations :	--
Auditors :
Name :	Kalpesh S. Doshi and Company Chartered Accountants
Address :	411, Cosmo Complex, Mahila College Circle, Rajkot – 360 001, Gujarat, India.
Tel. No.:	91-181-2225278 / 2473599
PAN No:	ABXPD9051A

CAPITAL STRUCTURE

AS ON 31.03.2012

Authorised Capital :

No. of Shares	Type	Value	Amount
1000000	Equity Shares	Rs.10/- each	Rs.10.000 Millions

Issued, Subscribed & Paid-up Capital :

No. of Shares	Type	Value	Amount
443750	Equity Shares	Rs.10/- each	Rs.4.344 Millions

FINANCIAL DATA

[all figures are in Rupees Millions]

ABRIDGED BALANCE SHEET

SOURCES OF FUNDS		31.03.2012	31.03.2011	31.03.2010
SHAREHOLDERS FUNDS
1] Share Capital		4.344	4.250	4.250
2] Share Application Money		0.000	0.000	0.000
3] Reserves & Surplus		30.411	18.787	15.796
4] (Accumulated Losses)		0.000	0.000	0.000
NETWORTH		34.755	23.037	20.046
LOAN FUNDS
1] Secured Loans		38.347	28.525	17.270
2] Unsecured Loans		16.248	15.777	13.004
TOTAL BORROWING		54.595	44.302	30.274
DEFERRED TAX LIABILITIES		0.969	0.000	0.000
TOTAL		90.319	67.339	50.320
APPLICATION OF FUNDS
FIXED ASSETS [Net Block]		39.747	29.500	17.979
Capital work-in-progress		0.000	0.000	0.000
INVESTMENT		0.000	0.000	0.000
DEFERREX TAX ASSETS		0.000	0.311	0.263
CURRENT ASSETS, LOANS & ADVANCES
	Inventories	24.836	13.725	18.390
	Sundry Debtors	85.071	42.309	26.597
	Cash & Bank Balances	12.185	5.603	3.501
	Other Current Assets	0.000	0.000	0.000
	Loans & Advances	11.833	7.353	2.949
Total Current Assets		133.925	68.990	51.437
Less : CURRENT LIABILITIES & PROVISIONS
	Sundry Creditors	33.634	18.616	17.764
	Other Current Liabilities	49.719	12.848	1.598
	Provisions	0.000	0.000	0.000
Total Current Liabilities		83.353	31.464	19.362
Net Current Assets		50.572	37.526	32.075
MISCELLANEOUS EXPENSES		0.000	0.002	0.003
TOTAL		90.319	67.339	50.320

PROFIT & LOSS ACCOUNT

	PARTICULARS		31.03.2012	31.03.2011	31.03.2010
	SALES
		Income	418.311	274.612	184.348
		Other Income	0.252	0.417	0.101
		TOTAL (A)	418.563	275.029	184.449
Less	EXPENSES
		Purchases	355.136	222.185
		Employee Benefits Expenses	4.733	2.920	177.103
		Other Expenses	42.877	34.649
		Changes in Inventories	(11.112)	4.666
		TOTAL (B)	391.634	264.420	177.103
Less	PROFIT / (LOSS) BEFORE INTEREST, TAX, DEPRECIATION AND AMORTISATION (A-B) (C)		26.929	10.609	7.346
Less	FINANCIAL EXPENSES (D)		6.518	5.167	3.890
	PROFIT / (LOSS) BEFORE TAX, DEPRECIATION AND AMORTISATION (C-D) (E)		20.411	5.442	3.456
Less/ Add	DEPRECIATION/ AMORTISATION (F)		3.529	0.687	0.785
	PROFIT / (LOSS) BEFORE TAX (E-F) (G)		16.882	4.755	2.671
Less	TAX (H)		8.165	1.763	0.352
	PROFIT / (LOSS) AFTER TAX (G-H) (I)		8.717	2.992	2.319
Add	PREVIOUS YEARS’ BALANCE BROUGHT FORWARD		10.569	7.577	5.258
	BALANCE CARRIED TO THE B/S		19.286	10.569	7.577
	EARNINGS IN FOREIGN CURRENCY
		Export Earnings	238.165	169.323	124.165
	IMPORTS		161.004	NA	NA
	Earnings / (Loss) Per Share (Rs.)		20.00	7.00	5.46

KEY RATIOS

PARTICULARS		31.03.2012	31.03.2011	31.03.2010
PAT / Total Income	(%)	2.08	1.09	1.26
Net Profit Margin (PBT/Sales)	(%)	4.04	1.73	1.45
Return on Total Assets (PBT/Total Assets}	(%)	9.72	4.83	3.85
Return on Investment (ROI) (PBT/Networth)		0.49	0.21	0.13
Debt Equity Ratio (Total Debt/Networth)		1.57	1.92	1.51
Current Ratio (Current Asset/Current Liability)		1.61	2.19	2.66

LOCAL AGENCY FURTHER INFORMATION

Sr. No.	Check List by Info Agents	Available in Report (Yes / No)
1]	Year of Establishment	Yes
2]	Locality of the firm	Yes
3]	Constitutions of the firm	Yes
4]	Premises details	Yes
5]	Type of Business	Yes
6]	Line of Business	Yes
7]	Promoter's background	Yes
8]	No. of employees	Yes
9]	Name of person contacted	Yes
10]	Designation of contact person	Yes
11]	Turnover of firm for last three years	Yes
12]	Profitability for last three years	Yes
13]	Reasons for variation <> 20%	--
14]	Estimation for coming financial year	No
15]	Capital in the business	Yes
16]	Details of sister concerns	No
17]	Major suppliers	No
18]	Major customers	No
19]	Payments terms	No
20]	Export / Import details (if applicable)	No
21]	Market information	--
22]	Litigations that the firm / promoter involved in	--
23]	Banking Details	Yes
24]	Banking facility details	Yes
25]	Conduct of the banking account	--
26]	Buyer visit details	--
27]	Financials, if provided	Yes
28]	Incorporation details, if applicable	Yes
29]	Last accounts filed at ROC	Yes
30]	Major Shareholders, if available	Yes
31]	PAN of Proprietor/Partner/Director, if available	No
32]	Date of Birth of Proprietor/Partner/Director, if available	Yes
33]	Voter ID No of Proprietor/Partner/Director, if available	No
34]	External Agency Rating, if available	No

Unsecured Loan	As on 31.03.2012 [Rs. in Millions]	As on 31.03.2011 [Rs. in Millions]
From Directors, Shareholders and Relatives	16.248	15.777
TOTAL	16.248	15.777

BANKERS CHARGES REPORT AS PER REGISTRY

This form is for	Modification of charge
Charge identification number of the modified	90105415
Corporate identity number of the company	U24231GJ1999PTC035693
Name of the company	ADANI PHARMACHEM PRIVATE LIMITED
Address of the registered office or of the principal place of business in India of the company	Plot No. 198/2, Aji, GIDC, Phase II, Road – M, Rajkot-360003, Gujarat, India
Type of charge	Book Debts Movable Property [not being pledge] Floating Charge Immovable Property Others
Particular of charge holder	Corporation Bank, Main Branch, “Nijanand”, Dhebar Road, Rajkot-360001, Gujarat, India Email: cb191@corpbank.co.in
Nature of description of the instrument creating or modifying the charge	- Supplemental Common Deed of Hypothecation of Movables/Assets/Debts. - Memorandum of Agreement for extension of mortgage.
Date of instrument Creating the charge	30.01.2013
Amount secured by the charge	Rs.170.203 Millions
Brief particulars of the principal terms an conditions and extent and operation of the charge	Rate of Interest CC:12.60% p.a., PCL: Upto 270 days 11.00% beyond 270 days and Upto 360 days 15.40% p.a., FDBN : Upto 180 days from advance: 11.00% p.a., TL I - Review: 14.50% p.a. and TL II - Review: 13.00% p.a. Terms of Repayment - CC: Running account repayable on demand subject to annual review/renewal - PCL: Each PCL shall be cleared within a period of 90 days from the date of availment out of the proceeds of export bills negotiated/purchased/discounted - FDBN: sight bills shall be cleared within 120 Days from the date of bill of lading. - T L I - Review : In 16 Quarterly installments of Rs. 9,37,500/- each - T L II - New: In 20 Quarterly installments of Rs. 1.00 Lac each. Margin - CC: 30% on inventory and 50% on domestic Book Debts of not more than 90 day, PCL: 25% - BG - renewal: 25% Cash Margin by way of Term Deposit. - Import LC cum buyer’s credit - 15% by way of Term Deposit. - Term Loan- Review : 26.83% - Term Loan - new : 27.14% Extent and Operation of the charge The Charge by way of Hypothecation and Equitable mortgage on assets referred to in this form shall operate as security for aggregate credit facility of Rs. 170.203 Millions (individual limit is given as under) with interest, cost and charges. Cash Credit cum PCL: Rs. 25.000 Millions, FDBN/FDBP/FDBD: Rs. 35.000 Millions, Bank Guarantee: Rs. 0.500 Millions, Import Letter of Credit: Rs. 100.000 Millions, Term Loan I - Review: Rs. 8.103 Millions and Term Loan II - Review Rs. 1.600 Millions. Others As per Sanction letter dated 29.11.2012
Short particulars of the property charged	Hypothecation of Present and Future Stock in Trade stored at factory, Godown or anywhere else or in transit and hypothecation of Book Debts and other current assets Hypothecation of Plant and Machinery including electrification and other movable fixed assets excluding vehicles acquired out of bank finance of charge holder EMG on immovable property being Land adm. 1087 Sq. Mtrs. with construction thereon of Plot No. 198/2 of R. S. No. 206 paiki CSW No. 12, CS No. 4249 of Rajkot at Aji-II Industrial Estate, Rajkot EMG on Immovable Property being Land adm. 4782.90 Sq. Mtrs. located at Plot No. 2729,2730,2731 at Lodhika Ind. Estate on Khirsara R.S. No. 188 and 189 paiki Lodhika GIDC, Kalavad Road, Dist. Rajkot
Date of latest modification prior to the present modification	01.10.2011
Particulars of the present modification	The total limit of credit facilities has been revised from Rs. 100.625 Millions to Rs. 170.203 Millions and charge being hypothecated and mortgaged to secure the enhanced credit facility of Rs. 170.203 Millions as under together with interest, cost and charges. Cash Credit cum PCL: Rs. 25.000 Millions, FDBN/FDBP/FDBD: Rs. 35.000 Millions, Bank Guarantee: Rs. 0.500 Millions, Import Letter of Credit: Rs. 100.000 Millions, Term Loan I - Review: Rs. 8.103 Millions and Term Loan - II Review: Rs. 1.600 Millions.

FIXED ASSETS:

• Factory Land
• Factory Land at Metoda
• Factory Buildings and Shed
• Electric Fittings
• Every Scale
• Furniture
• Cycle
• Plant and Machinery
• Laboratory Equipments
• Type writer
• Freeze
• Scooter
• Fax Machine
• Air Cooler
• Computer
• Computer Cabin
• Air Conditioner
• Mobile
• Water Plant
• Inverter
• Xerox Machine
• Car (Swift)
• Television
• Factory Building WIP

CMT REPORT (Corruption, Money Laundering & Terrorism]

The Public Notice information has been collected from various sources including but not limited to: The Courts, India Prisons Service, Interpol, etc.

1] INFORMATION ON DESIGNATED PARTY

No exist designating subject or any of its beneficial owners, controlling shareholders or senior officers as terrorist or terrorist organization or whom notice had been received that all financial transactions involving their assets have been blocked or convicted, found guilty or against whom a judgement or order had been entered in a proceedings for violating money-laundering, anti-corruption or bribery or international economic or anti-terrorism sanction laws or whose assets were seized, blocked, frozen or ordered forfeited for violation of money laundering or international anti-terrorism laws.

2] Court Declaration :

No records exist to suggest that subject is or was the subject of any formal or informal allegations, prosecutions or other official proceeding for making any prohibited payments or other improper payments to government officials for engaging in prohibited transactions or with designated parties.

3] Asset Declaration :

No records exist to suggest that the property or assets of the subject are derived from criminal conduct or a prohibited transaction.

4] Record on Financial Crime :

Charges or conviction registered against subject: None

5] Records on Violation of Anti-Corruption Laws :

Charges or investigation registered against subject: None

6] Records on Int’l Anti-Money Laundering Laws/Standards :

Charges or investigation registered against subject: None

7] Criminal Records

No available information exist that suggest that subject or any of its principals have been formally charged or convicted by a competent governmental authority for any financial crime or under any formal investigation by a competent government authority for any violation of anti-corruption laws or international anti-money laundering laws or standard.

8] Affiliation with Government :

No record exists to suggest that any director or indirect owners, controlling shareholders, director, officer or employee of the company is a government official or a family member or close business associate of a Government official.

9] Compensation Package :

Our market survey revealed that the amount of compensation sought by the subject is fair and reasonable and comparable to compensation paid to others for similar services.

10] Press Report :

No press reports / filings exists on the subject.

CORPORATE GOVERNANCE

MIRA INFORM as part of its Due Diligence do provide comments on Corporate Governance to identify management and governance. These factors often have been predictive and in some cases have created vulnerabilities to credit deterioration.

Our Governance Assessment focuses principally on the interactions between a company’s management, its Board of Directors, Shareholders and other financial stakeholders.

CONTRAVENTION

Subject is not known to have contravened any existing local laws, regulations or policies that prohibit, restrict or otherwise affect the terms and conditions that could be included in the agreement with the subject.

FOREIGN EXCHANGE RATES

Currency	Unit	Indian Rupees
US Dollar	1	Rs.54.43
UK Pound	1	Rs.83.20
Euro	1	Rs.71.91

INFORMATION DETAILS

Report Prepared by :

TPT

SCORE & RATING EXPLANATIONS

SCORE FACTORS	RANGE	POINTS
HISTORY	1~10	5
PAID-UP CAPITAL	1~10	5
OPERATING SCALE	1~10	5
FINANCIAL CONDITION
--BUSINESS SCALE	1~10	5
--PROFITABILIRY	1~10	5
--LIQUIDITY	1~10	5
--LEVERAGE	1~10	5
--RESERVES	1~10	5
--CREDIT LINES	1~10	5
--MARGINS	-5~5	-
DEMERIT POINTS
--BANK CHARGES	YES/NO	YES
--LITIGATION	YES/NO	NO
--OTHER ADVERSE INFORMATION	YES/NO	NO
MERIT POINTS
--SOLE DISTRIBUTORSHIP	YES/NO	NO
--EXPORT ACTIVITIES	YES/NO	NO
--AFFILIATION	YES/NO	NO
--LISTED	YES/NO	NO
--OTHER MERIT FACTORS	YES/NO	YES
TOTAL		45

This score serves as a reference to assess SC’s credit risk and to set the amount of credit to be extended. It is calculated from a composite of weighted scores obtained from each of the major sections of this report. The assessed factors and their relative weights (as indicated through %) are as follows:

Financial condition (40%) Ownership background (20%) Payment record (10%)

Credit history (10%) Market trend (10%) Operational size (10%)

RATING EXPLANATIONS

RATING		STATUS	PROPOSED CREDIT LINE
>86	Aaa	Possesses an extremely sound financial base with the strongest capability for timely payment of interest and principal sums	Unlimited
71-85	Aa	Possesses adequate working capital. No caution needed for credit transaction. It has above average (strong) capability for payment of interest and principal sums	Large
56-70	A	Financial & operational base are regarded healthy. General unfavourable factors will not cause fatal effect. Satisfactory capability for payment of interest and principal sums	Fairly Large
41-55	Ba	Overall operation is considered normal. Capable to meet normal commitments.	Satisfactory
26-40	B	Capability to overcome financial difficulties seems comparatively below average.	Small
11-25	Ca	Adverse factors are apparent. Repayment of interest and principal sums in default or expected to be in default upon maturity	Limited with full security
<10	C	Absolute credit risk exists. Caution needed to be exercised	Credit not recommended
-	NB	New Business	-

PRIVATE & CONFIDENTIAL : This information is provided to you at your request, you having employed MIPL for such purpose. You will use the information as aid only in determining the propriety of giving credit and generally as an aid to your business and for no other purpose. You will hold the information in strict confidence, and shall not reveal it or make it known to the subject persons, firms or corporations or to any other. MIPL does not warrant the correctness of the information as you hold it free of any liability whatsoever. You will be liable to and indemnify MIPL for any loss, damage or expense, occasioned by your breach or non observance of any one, or more of these conditions

This report is issued at your request without any risk and responsibility on the part of MIRA INFORM PRIVATE LIMITED (MIPL) or its officials.