MIRA INFORM REPORT

Report Date :

21.08.2014

IDENTIFICATION DETAILS

Name :	CONCORD FORTUNE MINERALS (INDIA) PRIVATE LIMITED
Registered Office :	238A, A.J.C. Bose Road, 5^th Floor, Unit Nos.-5A, 5B and 5C, Kolkata – 700020, West Bengal
Country :	India
Financials (as on) :	31.03.2013
Date of Incorporation :	31.08.2007
Com. Reg. No.:	21-118239
Capital Investment / Paid-up Capital :	Rs.9.898 Millions
CIN No.: [Company Identification No.]	U14200WB2007PTC118239
TAN No.: [Tax Deduction & Collection Account No.]	CALC06346E
PAN No.: [Permanent Account No.]	AADCC1614J
Legal Form :	Private Limited Liability Company
Line of Business :	The Company was incorporated with a view to trade in the Iron Ore Fines i.e., to procure the materials in India and to sell the same overseas.
No. of Employees :	Information declined by the management

RATING & COMMENTS

MIRA’s Rating :

Ca (16)

RATING		STATUS	PROPOSED CREDIT LINE
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

Status :	Moderate
Payment Behaviour :	Slow
Litigation :	Clear
Comments :	Subject is an established company having a moderate track record. Net worth of the company has been eroded due to accumulated loss incurred from its operation during 2013. However, business is active. Payment terms are reported to be slow. The company can be considered for business dealings on safe and secured 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 1, 2014

Country Name	Previous Rating (31.03.2014)	Current Rating (01.06.2014)
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

N E W S

As per the latest IMF study, the total weigh of emerging markets in the GDP of the world on a purchasing power parity basis has seen a sizeable shift. It highlights how as against 51 % in 2005, the emerging economies now account for close to 56 % of the global purchasing power GDP as per the latest survey. And with the emerging economies growing at a faster rate than their developed counterparts, there are every possibility that the their share goes up further in the coming years.  China may surpass the US over the next few years.

Politics and economics are very intricately connected. They tend to influence each other in ways that could be very complex and far-reaching. The prospects of the India’s economy have been seriously compromised due to political corruption. High inflation, poor standard of living are to a great extent a result of rampant corruption in the country. China on the other hand, seems to be facing diametrically opposite challenge. American hedge fund manager Jim Chanos has been keenly following the political and economic development in the dragon economy and has figured out something that is quite worrying. He is of the view that the Chinese economy could be heading toward trouble on account of new Chinese President Xi Jingping’s very aggressive anti-corruption drive. Chanos believes tat many things such as apartment sales, luxury products, etc. were largely bought with dirty money. And it is now beginning to impact consumption. This may indeed be bad news for an economy that is struggling to transition from an investment-driven export-oriented economy to a domestic consumption-driven economy.

A study published by Firstpost has revealed that asset classes like real estate and equities were the biggest beneficiaries of the liberalization policies.  A firm called Ciane Analytics studied returns from assets including equities, gold, fixed deposits, G-Secs and real estate since 1991. Real estate outperformed every other asset classes during the 23-year period with an annualized return of 20 % ! Equities came in second with annualized return of 15.5 % ! However, while these returns may seem mouthwatering, the fact is that the return from equities adjusted for inflation came down to just 7.1 %.

Some brief news are as under

. R-Power to buy Jaypee’s hydro assets

. Investors await justice in NSEL case

. India seeks MFN status from Pakistan ahead of meeting

. Ukrain’s clashes with rebels hinder MH17 crash investigation

. India exploring merger of state-owned hydro PSUs

..Higher costs weigh down profit growth to slowest in 9 quarters

..Wal-Mart to expand wholesale business in India

. GMR group moves to strengthen balance sheet

. Central Bank to sell 4 % stake to Life Insurance Corporation

. Tata Chemicals plans to raise up to Rs 10000 mn.

EXTERNAL AGENCY RATING

Rating Agency Name	CRISIL
Rating	Short term rating: A4+
Rating Explanation	Have minimal degree of safety and carry very high credit risk.
Date	14.07.2014

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 31-03-2014.

INFORMATION DECLINED BY

Name :	Mr. P Mukherjee
Designation :	Finance Head
Contact No.:	91-33-40134128
Date :	20.08.2014

LOCATIONS

Registered Office :	238A, A.J.C. Bose Road, 5^th Floor, Unit Nos.-5A, 5B and 5C, Kolkata – 700020, West Bengal, India
Tel. No.:	91-33-40134128/40134100
Fax No.:	Not Available
E-Mail :	rahul@concordfortune.in

DIRECTORS

As on 30.09.2013

Name :

Ms. Sweta Sonthalia

Designation :

Director

Address :

3 Old Mayors Court, Sova Bazar, Shyampukur, Kolkata – 700005, West Bengal, India

Date of Birth/Age :

09.07.1978

Date of Appointment :

06.12.2010

DIN No.:

00670026

PAN No.:

ANBPS4352H

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	Date of cessation	Company/ LLP Status	Defaulting status
1	U51109WB2004PTC099036	ANOUSHKA AGENCIES PRIVATE LIMITED	Director	21/04/2005	21/04/2005	-	Active	NO
2	U14200WB2007PTC118239	CONCORD FORTUNE MINERALS (INDIA) PRIVATE LIMITED	Director	31/08/2007	31/08/2007	-	Active	NO
3	U63010WB2009PTC135282	CONCORD FORTUNE SHIPPING AND LOGISTICS PRIVATE LIMITED	Director	22/05/2009	22/05/2009	-	Active	NO
4	U70102WB2010PTC155440	CONCORD FORTUNE SEAWAYS PRIVATE LIMITED	Director	06/12/2010	06/12/2010	-	Active	NO
5	U45400WB2011PTC157678	CONCORD FORTUNE INFRASTRUCTURE PRIVATE LIMITED	Director	20/01/2011	20/01/2011	-	Active	NO

Name :

Mr. Rahul Sonthalia

Designation :

Director

Address :

3, Old Mayors Court, Sova Bazar Shyampukur, Kolkata – 700005, West Bengal, India

Date of Birth/Age :

21.09.1974

Date of Appointment :

31.08.2007

DIN No.:

00670055

PAN No.:

AJRPS0753J

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	Date of cessation	Company/ LLP Status	Defaulting status
1	U51109WB2004PTC099036	ANOUSHKA AGENCIES PRIVATE LIMITED	Director	09/07/2004	09/07/2004	-	Active	NO
2	U14200WB2007PTC118239	CONCORD FORTUNE MINERALS (INDIA) PRIVATE LIMITED	Director	31/08/2007	31/08/2007	-	Active	NO
3	U63010WB2009PTC135282	CONCORD FORTUNE SHIPPING AND LOGISTICS PRIVATE LIMITED	Director	22/05/2009	22/05/2009	-	Active	NO
4	U70102WB2010PTC155440	CONCORD FORTUNE SEAWAYS PRIVATE LIMITED	Director	06/12/2010	06/12/2010	-	Active	NO
5	U45400WB2011PTC157678	CONCORD FORTUNE INFRASTRUCTURE PRIVATE LIMITED	Director	20/01/2011	20/01/2011	-	Active	NO

Name :

Pushpal Mukherjee

Designation :

Director

Address :

Amrita Vihar Apartments, Flat No. A-4/2, Kamalgazi, Narendrapur, Sonarpur, 24 Paraganas South – 700103, West Bengal, India

Date of Birth/Age :

22.03.1961

Date of Appointment :

30.09.2013

DIN No.:

03521052

PAN No.:

AHSPM1428K

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	Date of cessation	Company/ LLP Status	Defaulting status
1	U52190WB2011PTC162787	RICHER TRADECOM PRIVATE LIMITED	Director	19/05/2011	19/05/2011	10/12/2011	Active	NO
2	U14200WB2007PTC118239	CONCORD FORTUNE MINERALS (INDIA) PRIVATE LIMITED	Director	30/09/2013	01/03/2013	-	Active	NO

KEY EXECUTIVES

Name :	Mr. P Mukherjee
Designation :	Finance Head

MAJOR SHAREHOLDERS / SHAREHOLDING PATTERN

As on 30.09.2013

Names of Shareholders	No. of Shares
Rahul Sonthalia	1
Concord Fortune International Holding Limited, Hong Kong	989749
Total	989750

Equity Share Break up (Percentage of Total Equity)

As on 30.09.2013

Category	Percentage
Foreign holdings( Foreign institutional investor(s), Foreign companie(s) Foreign financial institution(s), Non-resident Indian(s) or Overseas Corporate bodies or Others	100.00
Total	100.00

s

BUSINESS DETAILS

Line of Business :

The Company was incorporated with a view to trade in the Iron Ore Fines i.e., to procure the materials in India and to sell the same overseas.

Products :

Item Code No.	Product Description
99652190	inland water transport services of freight
27011920	steam coal

GENERAL INFORMATION

No. of Employees :	Information declined by the management
Bankers :	· Standard Chartered Bank, 19, N.S. Road, Kolkata - 700001, West Bengal, India

Banking Relations :	--
Auditors :
Name :	Saraf and Chandra Chartered Accountants
Address :	Ashoka House, Suite #501, 3A-Hare Street, 5th floor, Kolkata 700001, West Bengal, India
PAN N Income-tax PAN of auditor or auditor's firm :	AAMFS1204Q
Holding Company:	· Concord Fortune International Holdings Limited
100% Subsidiary Company:	· Concord Fortune Shipping and Logistics (Private) Limited, India [U63010WB2009PTC135282]
Fellow Subsidiary Company:	· Concord Fortune Trading Limited · Concord Fortune Resources Pte Limited
Associate Company:	· Concord Fortune Minerals Limited
Enterprise Controlled by KMP:	· Concord Fortune Infrastrcuture (Private) Limited, India [U45400WB2011PTC157678] · Concord Fortune Seaways (Private) Limited · Anouskha Agencies (Private) Limited, India [U51109WB2004PTC099036]

CAPITAL STRUCTURE

As on 31.03.2013

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
989750	Equity Shares	Rs.10/- each	Rs. 9.898 Millions

FINANCIAL DATA

[all figures are in Rupees Millions]

ABRIDGED BALANCE SHEET

SOURCES OF FUNDS	31.03.2013	31.03.2012
I.              EQUITY AND LIABILITIES
(1)Shareholders' Funds
(a) Share Capital	9.898	9.898
(b) Reserves & Surplus	(41.610)	(1.582)
(c) Money received against share warrants	0.000	0.000
(2) Share Application money pending allotment	0.000	0.000
Total Shareholders’ Funds (1) + (2)	(31.712)	8.316
(3) Non-Current Liabilities
(a) long-term borrowings	0.000	0.000
(b) Deferred tax liabilities (Net)	0.000	0.000
(c) Other long term liabilities	0.000	0.000
(d) long-term provisions	0.000	0.000
Total Non-current Liabilities (3)	0.000	0.000
(4) Current Liabilities
(a) Short term borrowings	0.000	0.000
(b) Trade payables	2.114	4.737
(c) Other current liabilities	88.242	227.164
(d) Short-term provisions	0.377	0.200
Total Current Liabilities (4)	90.733	232.101
TOTAL	59.021	240.417
II.          ASSETS
(1) Non-current assets
(a) Fixed Assets
(i) Tangible assets	21.694	24.726
(ii) Intangible Assets	0.023	0.025
(iii) Capital work-in-progress	0.000	0.000
(iv) Intangible assets under development	0.000	0.000
(b) Non-current Investments	0.457	0.407
(c) Deferred tax assets (net)	0.000	0.000
(d) Long-term Loan and Advances	16.093	17.836
(e) Other Non-current assets	2.020	1.315
Total Non-Current Assets	40.287	44.309
(2) Current assets
(a) Current investments	0.000	0.000
(b) Inventories	0.000	39.084
(c) Trade receivables	1.017	32.107
(d) Cash and cash equivalents	3.302	81.818
(e) Short-term loans and advances	13.805	42.063
(f) Other current assets	0.610	1.036
Total Current Assets	18.734	196.108
TOTAL	59.021	240.417

SOURCES OF FUNDS		31.03.2011
SHAREHOLDERS FUNDS
1] Share Capital		9.898
2] Share Application Money		0.000
3] Reserves & Surplus		23.983
4] (Accumulated Losses)		0.000
NETWORTH		33.881
LOAN FUNDS
1] Secured Loans		145.482
2] Unsecured Loans		0.000
TOTAL BORROWING		145.482
DEFERRED TAX LIABILITIES		0.512
TOTAL		179.875
APPLICATION OF FUNDS
FIXED ASSETS [Net Block]		28.695
Capital work-in-progress		0.000
INVESTMENT		0.317
DEFERREX TAX ASSETS		0.000
CURRENT ASSETS, LOANS & ADVANCES
	Inventories	72.542
	Sundry Debtors	0.000
	Cash & Bank Balances	9.727
	Other Current Assets	0.000
	Loans & Advances	183.669
Total Current Assets		265.938
Less : CURRENT LIABILITIES & PROVISIONS
	Sundry Creditors	105.155
	Other Current Liabilities
	Provisions	9.920
Total Current Liabilities		115.075
Net Current Assets		150.863
MISCELLANEOUS EXPENSES		0.000
TOTAL		179.875

PROFIT & LOSS ACCOUNT

	PARTICULARS	31.03.2013	31.03.2012	31.03.2011
	SALES
	Turnover	33.230	1166.020	NA
	Other Income	NA	NA	NA
	TOTAL	NA	NA	NA
Less	EXPENSES	NA	NA	NA
	PROFIT/ (LOSS) BEFORE TAX	NA	NA	NA
Less	TAX	NA	NA	NA
	PROFIT/ (LOSS) AFTER TAX	(40.030)	(25.570)	11.095
	Earnings / (Loss) Per Share (Rs.)	(40.44)	(25.83)	11.21

KEY RATIOS

PARTICULARS	31.03.2013	31.03.2012	31.03.2011
Debt Equity Ratio (Total Debt /Networth)	0.00	0.00	4.29
Current Ratio (Current Asset/Current Liability)	0.21	0.84	2.31

FINANCIAL ANALYSIS

[all figures are in Rupees Millions]

DEBT EQUITY RATIO

Particular	31.03.2012	31.03.2013
	(Rs. In Millions)	(Rs. In Millions)
Share Capital	9.898	9.898
Reserves & Surplus	(1.582)	(41.610)
Net worth	8.316	(31.712)
long-term borrowings	0.000	0.000
Short term borrowings	0.000	0.000
Total borrowings	0.000	0.000
Debt/Equity ratio	0.000	0.000

YEAR-ON-YEAR GROWTH

Year on Year Growth	31.03.2012	31.03.2013
	(Rs. In Millions)	(Rs. In Millions)
Turnover	1166.020	33.230
		(97.150)

NET PROFIT MARGIN

Net Profit Margin	31.03.2012	31.03.2013
	(Rs. In Millions)	(Rs. In Millions)
Sales	1166.020	33.230
Profit	(25.570)	(40.030)
	(2.19%)	(120.46%)

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	No
5]	Type of Business	Yes
6]	Line of Business	Yes
7]	Promoter's background	Yes
8]	No. of employees	No
9]	Name of person contacted	Yes
10]	Designation of contact person	Yes
11]	Turnover of firm for last two 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	Yes
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]	Date of Birth of Proprietor/Partner/Director, if available	Yes
32]	PAN of Proprietor/Partner/Director, if available	Yes
33]	Voter ID No of Proprietor/Partner/Director, if available	No
34]	External Agency Rating, if available	Yes

FINANCIAL RESULTS AND PROSPECTS

The Company’s turnover has decreased to INR 33.230 Millions as compared to INR 1166.020 Millions in the previous year. The Directors are looking for new business opportunities and hope for better results in the current fiscal. The Company has incurred a Net Loss of INR 40.030 Millions as against a Loss of INR 25.570 Millions in the previous year. The Directors are expecting the present situation to improve.

CORPORATE INFORMATION

The Company was incorporated in August 2007 with a view to trade in the Iron Ore Fines i.e., to procure the materials in India and to sell the same overseas. It is operating from its different offices in India besides having its head office at Kolkata (West Bengal).

Its business comprises of :

1. Trading in Steam Coal which is imported from various parts of the world and is sold in India.

2. Rendering of services to the other exporters facilitating the handling and shipping of export cargo at the port of export.

INDEX OF CHARGES

S.NO.	CHARGE ID	DATE OF CHARGE CREATION/MODIFICATION	CHARGE AMOUNT SECURED	CHARGE HOLDER	ADDRESS	SERVICE REQUEST NUMBER (SRN)
1	10259890	09/10/2013 *	550,000,000.00	STANDARD CHARTERED BANK	19, N.S. ROAD, KOLKATA, WEST BENGAL - 700001, INDIA	B87602488

* Date of charge modification

FIXED ASSETS

Tangible assets

· Buildings

· Furniture and fixtures

· Vehicles

· Office equipment

Intangible assets

· Computer software

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 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.60.67
UK Pound	1	Rs.100.81
Euro	1	Rs.80.73

INFORMATION DETAILS

Information Gathered by :	PRT
Analysis Done by :	RAS
Report Prepared by :	KVT

SCORE & RATING EXPLANATIONS

SCORE FACTORS	RANGE	POINTS
HISTORY	1~10	2
PAID-UP CAPITAL	1~10	2
OPERATING SCALE	1~10	2
FINANCIAL CONDITION
--BUSINESS SCALE	1~10	2
--PROFITABILIRY	1~10	1
--LIQUIDITY	1~10	2
--LEVERAGE	1~10	2
--RESERVES	1~10	1
--CREDIT LINES	1~10	2
--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	YES
--LISTED	YES/NO	NO
--OTHER MERIT FACTORS	YES/NO	YES
DEFAULTER
--RBI	YES/NO	NO
--EPF	YES/NO	NO
TOTAL		16

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.