MIRA
INFORM REPORT
|
Report Date : |
10.10.2014 |
IDENTIFICATION DETAILS
|
Name : |
ASHLAND INDIA PRIVATE LIMITED |
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Registered
Office : |
601, 606-608, Platinum Technopark, Plot No. 17-18, Sector - 30A,
Vashi, Navi Mumbai – 400705, |
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Country : |
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Financials (as
on) : |
31.03.2013 |
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Date of
Incorporation : |
19.07.2007 |
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Com. Reg. No.: |
11-172506 |
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Capital
Investment / Paid-up Capital : |
Rs.500.000 Millions |
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CIN No.: [Company Identification
No.] |
U24100MH2007FTC172506 |
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IEC No.: |
0307056198 |
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TAN No.: [Tax Deduction &
Collection Account No.] |
MUMA30926A |
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PAN No.: [Permanent Account No.] |
AAGCA5023J |
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Legal Form : |
Private Limited Liability Company. |
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Line of Business
: |
Manufacturer and Trader of Chemical and Chemical Compounds, Plastics, Technical
Equipment and Technical Components. |
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No. of Employees
: |
Information denied by management |
RATING & COMMENTS
|
MIRA’s Rating : |
B (30) |
|
RATING |
STATUS |
PROPOSED CREDIT LINE |
|
|
26-40 |
B |
Capability to overcome financial difficulties seems comparatively
below average. |
Small |
|
Status : |
Moderate |
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Payment Behaviour : |
Slow But Correct |
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Litigation : |
Clear |
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Comments : |
Subject is a subsidiary of “Ashland Holdings B.V”. It is an
established company having moderate track record. There appears accumulated losses recorded by the company. However, the
company has achieved profit during the financial year 2013. However, trade relations are fair. Business is active. Payment terms
are slow but correct. In view of strong holding, the company can be considered for business
dealing with some caution. |
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 |
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Moderate |
B1 |
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High |
B2 |
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Very High |
C1 |
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Restricted |
C2 |
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Off-credit |
D |
INDIAN ECONOMIC OVERVIEW
N E W S
Verdict Implications:
Apex court order may alter coal import dynamics. Traders go slowly on talks
over coal supply contracts, uncertainty over cancellation of blocks weigh on
stocks.
Recent arrest of the
Chennai head of the Registrar of Companies, the ministry of corporate affairs
arm that ensures that companies file all the information required by the
Companies Act is the latest manifestation of a messy fight between a father and
his adopted son for the control of Rs 40000 mn Business Empire. The Central
Bureau of Investigation arrested Manumeethi Cholan after he accepted Rs 10
lakhs as bribe from M a M Ramaswamy, a CBI official said.
Central Bureau of
Investigation books Electrotherm for cheating Central Bank of Rs 4360 mn.
Infosys maintains
revenue guidance. COO Rao says attrition still an area of concern and it would
take a few more quarters to bring down levels to 13-15 %.
DHL to invest Euro
100 mn in India over next 2 years. The firm has chosen India to pilot its
e-commerce business model for the Asia-Pacific region.
Blackstone may buy
stake in BlueRidge SEZ in line with the fund’s real estate strategy in India.
Kingfisher Airlines
Ltd grounded in October 2012 under the weight of heavy debt and accumulated
losses, recently approached the Delhi high court for relief in two separate
cases. The airline challenged a notice by Punjab & National Bank alleging
that it had wilfully defaulted on Rs 7700 mn of loans and sought more time to
comply with the requirements under the listing agreements with the Stock
Exchanges.
OnMobile likely to
sack another 300 employees. The lay-offs follow a spate of senior-level exits
over the past two years, starting with of its founder. The overall lay-offs
could number around 600 and are driven by the need to cut costs, says a former
employee.
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 DENIED
Management Non Co-Operative (Tel No.: 91-22-61489655)
LOCATIONS
|
Registered Office : |
601, 606-608, Platinum Technopark, Plot No. 17-18, Sector - 30A,
Vashi, Navi Mumbai – 400705, Maharashtra, India |
|
Tel. No.: |
91-22-61489696 / 61489613 |
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Mobile No.: |
91-9920472211 (Mr. Sharma) |
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Fax No.: |
91-22-61712514 |
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E-Mail : |
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Website : |
DIRECTORS
As on 27.09.2013
|
Name : |
Mr. Vivek Kumar Singh |
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Designation : |
Managing Director |
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Address : |
Flat No. 62, 1st Floor, Block – III, Erose Garden,
Faridabad – 121001, Haryana, India |
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Date of Birth/Age : |
04.08.1970 |
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Date of Appointment : |
30.06.2009 |
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DIN No.: |
01317510 |
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Other Directorship:
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Name : |
Mr. Frank Adriaan Jumelet |
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Designation : |
Director |
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Address : |
T Vrije 53, JX Zierikzee – 4301, Netherland |
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Date of Birth/Age : |
14.02.1960 |
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Date of Appointment : |
19.07.2007 |
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DIN No.: |
01126173 |
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Name : |
Lynn Pannell Freeman |
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Designation : |
Director |
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Address : |
2321, Summer Woods, Drive, Hebron, Kentucky – 40148, U.S.A. |
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Date of Birth/Age : |
14.05.1962 |
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Date of Appointment : |
29.03.2012 |
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DIN No.: |
05252005 |
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Other Directorship:
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KEY EXECUTIVES
|
Name : |
Mr. Nagendra Pal Goel |
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Designation : |
Secretary |
|
Address : |
Flat No. 801, Building 57, Seawoods Estate, NRI Complex, Phase – II,
Nerul (West), Navi Mumbai, Thane – 400705, Maharashtra, India |
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Date of Birth/Age : |
10.09.1973 |
|
Date of Appointment : |
08.08.2013 |
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PAN No.: |
AARPP9811D |
MAJOR SHAREHOLDERS
As on 27.09.2013
|
Names of Shareholders |
|
No. of Shares |
|
Ashland Holding B.V., Netherlands |
|
49999999 |
|
Ashland Canada Holding B.V., Netherlands |
|
1 |
|
Total |
|
50000000 |
Equity Share Break up (Percentage of Total Equity)
As on 27.09.2013
|
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 |
BUSINESS DETAILS
|
Line of Business : |
Manufacturer and Trader of Chemical and Chemical Compounds, Plastics,
Technical Equipment and Technical Components. |
GENERAL INFORMATION
|
No. of Employees : |
Information denied by management |
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Bankers : |
Citi Bank NA - 6th Floor, Bandra Kurla Complex, Bandra
(East), Mumbai – 400051, Maharashtra, India |
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Banking
Relations : |
-- |
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Auditors : |
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|
Name : |
Price Waterhouse and Company Chartered Accountants |
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Address : |
Price Waterhouse Building, 7th and 8th Floor,
Tower – Board, DLF Cyber city |
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PAN
No. : |
AAEFP5579P |
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Holding Company : |
·
Ashland Holdings B.V. |
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Ultimate Holding Company: |
·
Ashland Inc |
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Fellow Subsidiaries : |
·
Aqualon Company ·
Hercules Inc. ·
Ashland (China) Holdings Company Limited ·
Ashland Performance Material ·
Iberia Ashland Chemicals S.A. ·
Hercules Chemicals Taiwan Company Limited ·
Ashland Industries Europe Gmbh ·
Ashland Chemical Company ·
Ashland UK Limited ·
Ashland Poland SP ZOO ·
Ashland (Changzhou) Advanced Chemicals Company
Limited ·
Ashland France SAS ·
Hercules Industrial Chemicals Private Limited ·
Ashland Chemical Hispania SL ·
Valvoline Cummins Limited(VCL) ·
Valvoline International ·
ISP Sales UK Limited ·
Ashland Finland OY ·
Ashland Singapore Private Limited |
CAPITAL STRUCTURE
As on 27.09.2013
Authorised Capital :
|
No. of Shares |
Type |
Value |
Amount |
|
|
|
|
|
|
50000000 |
Equity Share |
Rs.10/- each |
Rs.500.000 Millions |
Issued, Subscribed & Paid-up Capital :
|
No. of Shares |
Type |
Value |
Amount |
|
|
|
|
|
|
50000000 |
Equity Share |
Rs.10/- each |
Rs.500.000 Millions |
FINANCIAL DATA
[all figures are
in Rupees Millions]
ABRIDGED BALANCE
SHEET
|
SOURCES OF FUNDS |
31.03.2013 |
31.03.2012 |
31.03.2011 |
|
I.
EQUITY
AND LIABILITIES |
|
|
|
|
(1)Shareholders' Funds |
|
|
|
|
(a) Share Capital |
500.000 |
500.000 |
465.000 |
|
(b) Reserves & Surplus |
(161.203) |
(226.861) |
(196.488) |
|
(c) Money
received against share warrants |
0.000 |
0.000 |
0.000 |
|
|
|
|
|
|
(2) Share Application money pending allotment |
0.000 |
0.000 |
35.000 |
|
Total
Shareholders’ Funds (1) + (2) |
338.797 |
273.139 |
303.512 |
|
|
|
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(3)
Non-Current Liabilities |
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|
|
|
(a) long-term borrowings |
0.000 |
0.000 |
0.000 |
|
(b) Deferred tax liabilities (Net) |
0.000 |
0.000 |
0.000 |
|
(c) Other long term liabilities |
638.745 |
460.539 |
180.250 |
|
(d) long-term provisions |
6.754 |
3.679 |
1.731 |
|
Total Non-current Liabilities (3) |
645.499 |
464.218 |
181.981 |
|
|
|
|
|
|
(4) Current Liabilities |
|
|
|
|
(a) Short term borrowings |
550.430 |
258.149 |
40.000 |
|
(b) Trade payables |
401.532 |
398.047 |
249.280 |
|
(c) Other current
liabilities |
45.842 |
32.643 |
9.967 |
|
(d) Short-term provisions |
0.282 |
0.260 |
0.701 |
|
Total Current Liabilities (4) |
998.086 |
689.099 |
299.948 |
|
|
|
|
|
|
TOTAL |
1982.382 |
1426.456 |
785.441 |
|
|
|
|
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II.
ASSETS |
|
|
|
|
(1) Non-current assets |
|
|
|
|
(a) Fixed Assets |
|
|
|
|
(i) Tangible assets |
259.274 |
154.570 |
69.367 |
|
(ii) Intangible Assets |
0.000 |
0.000 |
0.000 |
|
(iii) Capital
work-in-progress |
525.146 |
346.707 |
26.606 |
|
(iv)
Intangible assets under development |
0.000 |
0.000 |
0.000 |
|
(b) Non-current Investments |
0.000 |
0.000 |
0.000 |
|
(c) Deferred tax assets (net) |
8.945 |
0.000 |
0.000 |
|
(d) Long-term Loan and Advances |
45.566 |
55.401 |
111.297 |
|
(e) Other Non-current assets |
1.853 |
0.000 |
0.000 |
|
Total Non-Current Assets |
840.784 |
556.678 |
207.270 |
|
|
|
|
|
|
(2) Current assets |
|
|
|
|
(a) Current investments |
0.000 |
0.000 |
0.000 |
|
(b) Inventories |
329.950 |
171.600 |
151.547 |
|
(c) Trade receivables |
628.793 |
542.052 |
325.397 |
|
(d) Cash and cash
equivalents |
35.102 |
28.210 |
30.571 |
|
(e) Short-term loans and
advances |
147.753 |
114.845 |
57.675 |
|
(f) Other current assets |
0.000 |
13.071 |
12.981 |
|
Total Current Assets |
1141.598 |
869.778 |
578.171 |
|
|
|
|
|
|
TOTAL |
1982.382 |
1426.456 |
785.441 |
PROFIT & LOSS
ACCOUNT
|
|
PARTICULARS |
31.03.2013 |
31.03.2012 |
31.03.2011 |
|
|
|
|
|
|
|
|
GROSS SALES |
2542.627 |
1752.354 |
1098.722 |
|
|
|
|
|
|
|
|
PROFIT/(LOSS)
BEFORE TAX, DEPRECIATION AND AMORTISATION |
72.856 |
(23.479) |
(41.705) |
|
|
|
|
|
|
|
Less |
DEPRECIATION/
AMORTISATION |
16.143 |
6.892 |
5.318 |
|
|
|
|
|
|
|
|
PROFIT/(LOSS)
BEFORE TAX |
56.713 |
(30.372)
|
(47.023) |
|
|
|
|
|
|
|
Less |
TAX |
(8.945) |
0.000 |
0.000 |
|
|
|
|
|
|
|
|
PROFIT/(LOSS)
AFTER TAX |
65.658 |
(30.372) |
(47.023) |
|
|
|
|
|
|
|
|
Earnings /
(Loss) Per Share (Rs.) |
1.31 |
0.60 |
NA |
KEY RATIOS
|
PARTICULARS |
|
31.03.2013 |
31.03.2012 |
31.03.2011 |
|
Return on Total Assets (PBT/Total Assets} |
(%) |
3.92 |
-2.81 |
-6.20 |
|
|
|
|
|
|
|
Return on Investment (ROI) (PBT/Networth) |
|
0.17 |
-0.11 |
-0.15 |
|
|
|
|
|
|
|
Debt Equity Ratio (Total Debt /Networth) |
|
1.62 |
0.95 |
0.13 |
|
|
|
|
|
|
|
Current Ratio (Current Asset/Current Liability) |
|
1.14 |
1.26 |
1.93 |
FINANCIAL ANALYSIS
[all figures are
in Rupees Millions]
DEBT EQUITY RATIO
|
Particular |
31.03.2011 |
31.03.2012 |
31.03.2013 |
|
|
Rs.
In Millions |
Rs.
In Millions |
Rs.
In Millions |
|
Share Capital |
465.000 |
500.000 |
500.000 |
|
Reserves & Surplus |
(196.488) |
(226.861) |
(161.203) |
|
Share Application money
pending allotment |
35.000 |
0.000 |
0.000 |
|
Net
worth |
303.512 |
273.139 |
338.797 |
|
|
|
|
|
|
long-term borrowings |
0.000 |
0.000 |
0.000 |
|
Short term borrowings |
40.000 |
258.149 |
550.430 |
|
Total
borrowings |
40.000 |
258.149 |
550.430 |
|
Debt/Equity
ratio |
0.132 |
0.945 |
1.625 |
YEAR-ON-YEAR GROWTH
|
Year
on Year Growth |
31.03.2011 |
31.03.2012 |
31.03.2013 |
|
|
Rs.
In Millions |
Rs.
In Millions |
Rs.
In Millions |
|
Gross Sales |
1,098.722 |
1,752.354 |
2,542.627 |
|
|
|
59.490 |
45.098 |
NET PROFIT MARGIN
|
Net
Profit Margin |
31.03.2011 |
31.03.2012 |
31.03.2013 |
|
|
Rs.
In Millions |
Rs.
In Millions |
Rs.
In Millions |
|
Gross Sales |
1,098.722 |
1,752.354 |
2,542.627 |
|
Profit |
(47.023) |
(30.372) |
65.658 |
|
|
(4.28%) |
(1.73%) |
2.58% |
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 |
No |
|
10] |
Designation of contact
person |
No |
|
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 |
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 |
No |
|
33] |
Voter ID No of Proprietor/Partner/Director,
if available |
No |
|
34] |
External Agency Rating,
if available |
No |
UNSECURED LOANS:
|
Particulars |
31.03.2013 Rs. In Millions |
31.03.2012 Rs. In Millions |
|
SHORT TERM BORROWINGS |
|
|
|
Foreign Currency Term Loan From Bank |
0.000 |
108.149 |
|
Working Capital Loans From Bank |
530.430 |
130.000 |
|
Loans Repayable on Demand From Others |
0.000 |
20.000 |
|
Loans and Advances From Related Parties |
20.000 |
0.000 |
|
Total |
550.430 |
258.149 |
GENERAL
INFORMATION:
The Company was
incorporated on July 19, 2007 and is owned by Ashland Holdings BV Netherlands.
The Company has been established to carry on the business of manufacturing, processing,
packing, distributing, supplying, selling, importing, exporting and trading of
chemicals, chemical compounds, oil and oil derivatives, plastics, tech nical
equipment and technical components, as well as the rendering of technical
services and business support services. The ultimate holding company is Ashland
Inc. which is a technology leader in metal casting consumables and design
services of unsaturated polyester, vinyl ester resins, gel coats
high-performance adhesives and specialty resins.
NO CHARGES EXIST
FOR THE COMPANY
FIXED ASSETS:
·
Land
·
Building
·
Plant and Machinery
·
Computer
·
Vehicles
·
Furniture and Fixture
CMT REPORT (Corruption, Money Laundering & Terrorism]
The Public Notice information has been collected from various sources
including but not limited to: The Courts,
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.61.46 |
|
|
1 |
Rs.96.69 |
|
Euro |
1 |
Rs.77.65 |
INFORMATION DETAILS
|
Information
Gathered by : |
HTL |
|
|
|
|
Analysis Done by
: |
RAS |
|
|
|
|
Report Prepared
by : |
VNT |
SCORE & RATING EXPLANATIONS
|
SCORE FACTORS |
RANGE |
POINTS |
|
HISTORY |
1~10 |
3 |
|
PAID-UP CAPITAL |
1~10 |
4 |
|
OPERATING SCALE |
1~10 |
3 |
|
FINANCIAL CONDITION |
|
|
|
--BUSINESS SCALE |
1~10 |
4 |
|
--PROFITABILIRY |
1~10 |
4 |
|
--LIQUIDITY |
1~10 |
3 |
|
--LEVERAGE |
1~10 |
3 |
|
--RESERVES |
1~10 |
3 |
|
--CREDIT LINES |
1~10 |
3 |
|
--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 |
|
30 |
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 |
||
This report is issued at your request without any
risk and responsibility on the part of MIRA INFORM PRIVATE LIMITED (MIPL)
or its officials.