MIRA INFORM REPORT

 

 

Report Date :

13.09.2014

 

IDENTIFICATION DETAILS

 

Name :

INDEPESCA OVERSEAS PRIVATE LIMITED (w.e.f.21.12.2004)

 

 

Formerly Known As :

SAGARVIHAR FISHERIES PRIVATE LIMITED

 

 

Registered Office :

Plot No. M-03, MIDC, Taloja, District Raigad – 410208, Maharashtra

 

 

Country :

India

 

 

Financials (as on) :

31.03.2013

 

 

Date of Incorporation :

04.03.2004

 

 

Com. Reg. No.:

11-144847

 

 

Capital Investment / Paid-up Capital :

Rs. 170.000 Millions

 

 

CIN No.:

[Company Identification No.]

U05005MH2004PTC144847

 

 

TAN No.:

[Tax Deduction & Collection Account No.]

MUMS42591D

 

 

PAN No.:

[Permanent Account No.]

AAICS1304G

 

 

Legal Form :

Private Limited Liability Company

 

 

Line of Business :

Manufacturer and Exporter of Fish and Fish Products.

 

 

No. of Employees :

500 (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

 

Status :

Satisfactory

 

 

Payment Behaviour :

Slow but correct

 

 

Litigation :

Clear

 

 

Comments :

Subject is an established company having a satisfactory track record.

 

Trade relations are fair. Business is active. Payments terms are reported to be slow but correct.

 

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.

 

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.

 

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 PARTED BY

 

Name :

Mr. Mohan

Designation :

Business Head

Contact No.:

91-22-64552222

Date:

11.09.2014

 

 

LOCATIONS

 

Registered Office/ Factory :

Plot No. M-03, MIDC, Taloja, District Raigad – 410208, Maharashtra, India

Tel. No.:

91-22-27410414/ 27402005/ 64552222

Fax No.:

91-22-27410984

E-Mail :

mohan.bhatkoorse@indepesca.com

kasturi.rangan@indepesca.com

info@indepesca.com

pavitra.mehta@tritongroup.biz

Website :

http://www.indepesca.com

Area :

5000 Sq. ft.

Location :

Owned

 

 

DIRECTORS

 

As on 30.09.2013

 

Name :

Mr. Ashvin Mohanlal Samtani

Designation :

Director

Address :

11-N, Shamshiba, Nargis Dutt Road, Pali Hill, Bandra (West), Mumbai-400050, Maharashtra, India

Date of Birth/Age :

23.05.1954

Date of Appointment :

01.06.2004

PAN No.:

AAKPS0657B

DIN No.:

00264281

 

 

Name :

Mr. Praveen Kumar Rao

Designation :

Director

Address :

Flat No. 703, Raheja Classique, Building No. 3, CTS 619B/1, Link Road, Oshiwara, Andheri (West), Mumbai-400053, Maharashtra, India

Date of Birth/Age :

13.04.1955

Date of Appointment :

09.08.2005

DIN No.:

02076376

 

 

KEY EXECUTIVES

 

Name :

Mrs. Pavitra Ajit Mehta

Designation :

Secretary

Address :

7A, Shri-Niketan, 61-B, North Avenue, Santacruz (West), Mumbai – 400054, Maharashtra, India

Date of Birth/Age :

18.03.1984

Date of Appointment :

29.03.2010

PAN No.:

AQXPM8687Q

 

 

Name :

Mr. Mohan

Designation :

Business Head

 

 

MAJOR SHAREHOLDERS / SHAREHOLDING PATTERN

 

As on 30.09.2013

 

Names of Shareholders

 

No. of Shares

 

Ashvin Mohanlal Samtani

 

16608000

Gaurav Ashvin Samtani

 

196000

Lavin Ashvin Samtani

 

196000

 

 

 

Total

 

 

17000000

 

Equity Share Break up (Percentage of Total Equity)

 

As on 30.09.2013

 

Equity Share Breakup

 

Percentage of Holding

Category

 

 

Directors or relatives of directors

 

100.00

 

 

 

Total

 

 

100.00

 

 

 

 

BUSINESS DETAILS

 

Line of Business :

Manufacturer and Exporter of Fish and Fish Products.

 

 

Products :

ITC Code

Product Descriptions

0304

Fish fillets and other fish meat (whether or not minced), Fresh, chilled or frozen

0305

Fish, dried, salted or in brine, smoked fish, whether or not cooked before or during the smoking pro

0306

Crustaceans, whether in shell or not, live, fresh, chilled, frozen, dried, salted or in brine crust

0307

Mollusks whether in shell or not, live, fresh, chilled, frozen, dried, salted or in brine: aquatic

 

 

Exports :

 

Products :

Finished Goods

Countries :

Ø       Africa

Ø       Middle East

Ø       Asian Country

Ø       Europe

Ø       US

 

 

Terms :

 

Selling :

Cash and Credit

 

 

Purchasing :

Cash and Credit

 

PRODUCTION STATUS (AS ON 31.03.2011)

 

Particulars

Unit

Actual Production

Processed fish

Kgs.

4091019

 

 

GENERAL INFORMATION

 

Customers :

End Users

 

 

No. of Employees :

500 (Approximately)

 

 

Bankers :

·         Indian Bank, Vile Parle Branch, 325, Geethanjali Building, 1st Floor, Nehru Road, Vile Parle (East), Mumbai - 400057, Maharashtra, India

 

Indian Overseas Bank, Vile Parle (East), Mumbai - 400057, Maharashtra, India

 

·         HDFC Bank Limited, HDFC Bank House Senapati Bapat Marg, Lower Parel WEST, Mumbai - 400013, Maharashtra, India

 

 

Facilities :

Secured Loans

31.03.2013

31.03.2012

 

 

(Rs. In Millions)

LONG-TERM BORROWINGS

 

 

Term Loans from Banks

0.000

3.318

Term loans from others

131.497

137.991

Deferred payment liabilities

0.000

0.126

Other loans and advances

146.824

216.483

 

 

 

Total

 

278.321

357.918

 

 

 

Banking Relations :

 

 

 

Auditors :

 

Name :

K R Raheja and Company

Chartered Accountants

Address :

103, Commerce House, Maruaai Mandir Road, Danpada , Khar (West), Mumbai, Maharashtra, India

Tel. No.:

91-22-26001122/ 26001133/ 26496104

Fax No.:

91-22-26044425

E-Mail :

kamleshraheja@gmail.com

kamleshraheja@hotmail.com

Income-tax PAN of auditor or auditor's firm :

ADQPR8580H

 

 

Associates :

Ø       Triton Management Services Private Limited [U72200MH2004PTC145988]

Ø       Big Sam Snacks and Foods Private Limited [U15201MH2009PTC190221]

Ø       Indepesca Aquaculture Private Limited [U05000MH2009PTC189686]

Ø       Triton Cold Chain and Logistics Services Private Limited [U63020MH2010PTC206681]

Ø       Gemini Enterprises FZE

 

 

CAPITAL STRUCTURE

 

As on 31.03.2013

 

Authorised Capital :

No. of Shares

Type

Value

Amount

 

 

 

 

20,000,000

Equity Shares

Rs. 10/- each

Rs. 200.000 Millions

 

 

 

 

 

Issued, Subscribed & Paid-up Capital :

No. of Shares

Type

Value

Amount

 

 

 

 

17,000,000

Equity Shares

Rs. 10/- each

Rs. 170.000 Millions

 

 

 

 

 


 

FINANCIAL DATA

[all figures are in Rupees Millions]

 

ABRIDGED BALANCE SHEET

 

SOURCES OF FUNDS

 

31.3.2013

31.03.2012

31.03.2011

I.        EQUITY AND LIABILITIES

 

 

 

(1)Shareholders' Funds

 

 

 

(a) Share Capital

170.000

170.000

170.000

(b) Reserves & Surplus

431.543

441.538

454.808

(c) Money received against share warrants

0.000

0.000

0.000

 

 

 

 

(2) Share Application money pending allotment

0.000

0.000

0.000

Total Shareholders’ Funds (1) + (2)

601.543

611.538

624.808

 

 

 

 

(3) Non-Current Liabilities

 

 

 

(a) long-term borrowings

425.613

666.341

393.431

(b) Deferred tax liabilities (Net)

0.000

0.000

0.000

(c) Other long term liabilities

0.000

0.000

0.000

(d) long-term provisions

0.000

0.000

0.000

Total Non-current Liabilities (3)

425.613

666.341

393.431

 

 

 

 

(4) Current Liabilities

 

 

 

(a) Short term borrowings

0.000

0.000

0.000

(b) Trade payables

86.817

40.281

67.944

(c) Other current liabilities

303.041

191.882

72.900

(d) Short-term provisions

1.408

2.201

3.549

Total Current Liabilities (4)

391.266

234.364

144.393

 

 

 

 

TOTAL

1418.422

1512.243

1162.632

 

 

 

 

II.      ASSETS

 

 

 

(1) Non-current assets

 

 

 

(a) Fixed Assets

 

 

 

(i) Tangible assets

807.239

564.164

578.921

(ii) Intangible Assets

0.000

0.000

0.000

(iii) Capital work-in-progress

89.471

306.822

29.751

(iv) Intangible assets under development

0.000

0.000

0.000

(b) Non-current Investments

23.351

31.959

0.000

(c) Deferred tax assets (net)

1.373

1.683

2.043

(d)  Long-term Loan and Advances

0.000

0.000

0.000

(e) Other Non-current assets

1.500

0.000

0.000

Total Non-Current Assets

922.934

904.628

610.715

 

 

 

 

(2) Current assets

 

 

 

(a) Current investments

0.000

0.000

0.000

(b) Inventories

252.973

330.451

354.608

(c) Trade receivables

117.138

73.237

53.253

(d) Cash and cash equivalents

7.507

3.716

1.260

(e) Short-term loans and advances

117.870

200.211

142.796

(f) Other current assets

0.000

0.000

0.000

Total Current Assets

495.488

607.615

551.917

 

 

 

 

TOTAL

1418.422

1512.243

1162.632

 

PROFIT & LOSS ACCOUNT

 

 

PARTICULARS

 

31.03.2013

31.03.2012

31.03.2011

 

SALES

 

 

 

 

 

Income

NA

478.999

521.391

 

 

Other Income

NA

NA

NA

 

 

TOTAL                                    

NA

NA

NA

 

 

 

 

 

 

PROFIT BEFORE TAX, DEPRECIATION AND AMORTISATION

NA

14.365

16.847

 

 

 

 

 

Less/ Add

DEPRECIATION/ AMORTISATION                    

NA

13.210

12.406

 

 

 

 

 

 

PROFIT BEFORE TAX

NA

1.155

4.441

 

 

 

 

 

Less

TAX                                                                 

NA

0.590

1.276

 

 

 

 

 

 

PROFIT AFTER TAX

2.038

0.565

3.165

 

 

 

 

 

Add

PREVIOUS YEARS’ BALANCE BROUGHT FORWARD

NA

4.705

1.540

 

 

 

 

 

 

BALANCE CARRIED TO THE B/S

NA

5.270

4.705

 

 

 

 

 

 

EARNINGS IN FOREIGN CURRENCY

 

 

 

 

 

Export Earnings

NA

423.313

414.585

 

 

 

 

 

 

IMPORTS

 

 

 

 

 

Raw Materials

NA

NA

1.293

 

 

 

 

 

 

Earnings Per Share (Rs.)

0.12

0.03

0.19

 

Particulars

 

 

 

31.03.2014

Sales Turnover (Approximately)

 

 

500.000

 

The above information has been parted by Mr. Mohan (Business Head)

 

KEY RATIOS

 

PARTICULARS

 

 

31.03.2013

31.03.2012

31.03.2011

Net Profit Margin

(PBT/Sales)

(%)

NA
0.24
0.85

 

 

 
 
 

Return on Total Assets

(PBT/Total Assets}

(%)

NA
0.10
0.39

 

 

 
 
 

Return on Investment (ROI)

(PBT/Networth)

 

NA
0.00
0.01

 

 

 
 
 

Debt Equity Ratio

(Total Debt/Networth)

 

0.71
1.09
0.63

 

 

 
 
 

Current Ratio

(Current Asset/Current Liability)

 

1.27
2.59
3.82

 

 

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

170.000

170.000

170.000

Reserves & Surplus

454.808

441.538

431.543

Net worth

624.808

611.538

601.543

 

 

 

 

long-term borrowings

393.431

666.341

425.613

Short term borrowings

0.000

0.000

0.000

Total borrowings

393.431

666.341

425.613

Debt/Equity ratio

0.630

1.090

0.708

 

 

 

LOCAL AGENCY FURTHER INFORMATION

 

CURRENT MATURITIES OF LONG-TERM DEBT DETAILS: NOT AVAILABLE

 

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

Yes

17]

Major suppliers

No

18]

Major customers

No

19]

Payments terms

Yes

20]

Export / Import details (if applicable)

Yes

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

No

 

NOTE:

The registered office of the company has been shifted from Plot No. M-03, MIDC, Next to Kingfisher Beer Company, Taloja – 410208, Maharashtra, India to present address w.e.f.18.07.2011

 

UNSECURED LOANS

 

Unsecured Loas

31.03.2013

31.03.2012

 

 

(Rs. In Millions)

LONG-TERM BORROWINGS

 

 

Loans and Advance from Related Parties

147.292

308.423

 

 

 

Total

 

147.292

308.423

 

INDEX OF CHARGES

 

S.NO.

CHARGE ID

DATE OF CHARGE CREATION/MODIFICATION

CHARGE AMOUNT SECURED

CHARGE HOLDER

ADDRESS

SERVICE REQUEST NUMBER (SRN)

1

10032242

20/09/2010 *

255,500,000.00

INDIAN BANK

VILE PARLE BRANCH,325,GEETHANJALI BUILDING, 1ST FLOOR,NEHRU ROAD,VILE PARLE-EAST, MUMBAI, MAHARASHTRA - 400057, INDIA

A95142816

2

10046826

03/12/2007 *

300,000,000.00

HDFC BANK LIMITED

HDFC BANK HOUSESENAPATI BAPAT MARG, LOWER PAREL W, MUMBAI, MAHARASHTRA - 400013, INDIA

A29501913

 

* Date of charge modification

 

FIXED ASSETS:

 

Tangible assets

 

·         Land

·         Buildings

·         Plant and equipment

·         Furniture and fixtures

·         Vehicles

·         Office equipment


 

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 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.60.84

UK Pound

1

Rs.98.73

Euro

1

Rs.78.64

 

 

INFORMATION DETAILS

 

Information Gathered by :

GYT

 

 

Analysis Done by :

RAS

 

 

Report Prepared by :

KVT


 

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

YES

--AFFILIATION

YES/NO

YES

--LISTED

YES/NO

NO

--OTHER MERIT FACTORS

YES/NO

YES

DEFAULTER

 

 

--RBI

YES/NO

NO

--EPF

YES/NO

NO

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.