MIRA INFORM REPORT

Report No. :	334758
Report Date :	01.08.2015

IDENTIFICATION DETAILS

Name :	SELLOWRAP INDUSTRIES PRIVATE LIMITED [w.e.f.16.02.2011]
Formerly Known As :	SELLOWRAP MANUFACTURING PRIVATE LIMITED
Registered Office :	208, Plot No. C-5, Abhishek Building, Dalia Estate, New Link Road, Andheri (West), Mumbai – 400053, Maharashtra
Country :	India
Financials (as on) :	31.03.2014
Date of Incorporation :	06.04.2004
Com. Reg. No.:	11-145548
Capital Investment / Paid-up Capital :	Rs. 94.903 Million
CIN No.: [Company Identification No.]	U25202MH2004PTC145548
IEC No.:	Not Available
TAN No.: [Tax Deduction & Collection Account No.]	MUMS42856C
PAN No.: [Permanent Account No.]	AAICS1972L
Legal Form :	Private Limited Liability Company
Line of Business :	Manufacturer and Exporter of Automobile and White Goods Components.
No. of Employees :	160 (Approximately)

RATING & COMMENTS

MIRA’s Rating :

B (27)

RATING		STATUS	PROPOSED CREDIT LINE
26-40	B	Capability to overcome financial difficulties seems comparatively below average.	Small

Maximum Credit Limit :	USD 450000
Status :	Moderate
Payment Behaviour :	Slow but correct
Litigation :	Clear
Comments :	Subject is an established company having moderate track record. The rating is constrained on account of company’s moderate financial risk profile and loss that company has incurred from its operational activities during 2014. However, trade relations are fair. Business is active. Payments are reported to be slow but correct. The company can be considered for business dealings 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 – March 31, 2015

Country Name	Previous Rating (31.12.2014)	Current Rating (31.03.2015)
India	A1	A1

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

EXTERNAL AGENCY RATING

NOT AVAILABLE

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 31-03-2013.

INFORMATION PARTED BY

Name :	Mr. Ashok Kumar
Designation :	Assistant Accounts Manager
Contact No.:	91-124-4015973

LOCATIONS

Registered/ Corporate Office :	208, Plot No. C-5, Abhishek Building, Dalia Estate, New Link Road, Andheri (West), Mumbai – 400053, Maharashtra, India
Tel. No.:	91-22-66750560/ 67076268
Fax No.:	91-22-66750561
E-Mail :	accountsho@sellowrap.com contact@sellowrap.com
Website :	http://www.sellowrap.com
Factory 1 :	Plot No. 54, Sector 18, Maruti Industrial Estate, Gurgaon – 122015, Haryana, India
Tel. No.:	91-124-4015973/ 4015974/ 2340660/ 2340661
Fax No.:	91-124-4015975
Factory 2 :	Plot No. D-57 and 58, MIDC Industrial Estate, Ranjangaon Industrial Area, Taluka Shirur, District Pune – 412220, Maharashtra, India
Tel. No.:	91-2138-660766/ 67
Fax No.:	91-2138-670124

DIRECTORS

AS ON 30.09.2014

Name :

Mr. Saurabh Poddar

Designation :

Managing director

Address :

A-501, Fairyland CHS Limited, Plot No. 9A, 10^th Road, Juhu, Vile Parle [West], Mumbai – 400049, Maharashtra, India

Date of Birth/Age :

28.12.1973

Date of Appointment :

01.05.2011

PAN No.:

AFGPP1534F

DIN No.:

00032858

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	U51909DL1985PTC022849	SAURABH MARKETING PRIVATE LTD.	Director	20/12/1996	20/12/1996	-	Active	NO
2	U51100MH1998PTC115231	PROTON CONSULTANCY SERVICES PRIVATE LIMITED	Director	04/06/1998	04/06/1998	-	Active	NO
3	L24298WB1992PLC054815	GUJARAT METALLIC COAL & COKE LIMITED	Director	28/06/2002	28/06/2002	07/04/2011	Active	NO
4	U25202MH2004PTC145548	Sellowrap Industries Private Limited	Managing director	01/05/2011	24/05/2005	-	Active	NO
5	U24130MH2005PTC155220	SELLOWRAP EPP INDIA PRIVATE LIMITED	Director	09/08/2005	09/08/2005	-	Active	NO
6	U25209WB2000PTC160635	APARNA POLYFLEX PRIVATE LIMITED	Director	29/09/2006	30/01/2006	29/04/2014	Active	NO
7	U63010MH2007PTC171750	PROTON LOGISTICS SOLUTIONS PRIVATE LIMITED	Director	18/06/2007	18/06/2007	-	Strike off	NO

Name :

Mr. Sushil Kumar Poddar

Designation :

Director

Address :

F-704, Somvihar Apartment, R.K. Puram, New Delhi – 110022, India

Date of Birth/Age :

01.01.1947

Date of Appointment :

06.04.2004

PAN No.:

AFYPP8572R

DIN No.:

00149285

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	U51909DL1985PTC022849	SAURABH MARKETING PRIVATE LTD.	Director	20/12/1985	20/12/1985	-	Active	NO
2	U25202MH2004PTC145548	Sellowrap Industries Private Limited	Director	06/04/2004	06/04/2004	-	Active	NO
3	U24130MH2005PTC155220	SELLOWRAP EPP INDIA PRIVATE LIMITED	Managing director	06/07/2007	09/08/2005	28/07/2011	Active	NO
4	L24111WB1991PLC051709	ARVIND INTERNATIONAL LTD	Director	28/09/2007	31/10/2006	16/03/2010	Active	NO

KEY EXECUTIVES

Name :	Mr. Ashok Kumar
Designation :	Assistant Accounts Manager

MAJOR SHAREHOLDERS / SHAREHOLDING PATTERN

AS ON 30.09.2014

Names of Shareholders	No. of Shares
Sushil Kumar Poddar	2009600
Saurabh Poddar	1555200
Meena Poddar	342500
Pooja Poddar	995000
S.K. Poddar and Sons HUF	191000
Saurabh Marketing Private Limited, India	2477000
Anupama Bajoria	320000
Aparna Polyflex Private Limited, India	75000
Gujarat Metallic Coal and Coke Limited, India	810000
Kaizen Organics Private Limited, India	200000
Aditya Rungta HUF	10
Shyamsunder Rungta HUF	10
Arvind Coir Foam Private Limited, India	250000
Arvind International Limited, India	265000
Total	9490320

AS ON 30.09.2014

Equity Share Breakup	Percentage of Holding
Category
Bodies corporate	42.96
Directors or relatives of directors	53.67
Other top fifty shareholders	3.37
Total	100.00

BUSINESS DETAILS

Line of Business :

Manufacturer and Exporter of Automobile and White Goods Components.

Products/ Services :

ITC Code No.	Product Descriptions
39269099	Plastic Components and Article of Foam PU
56039400	Article of Non-Woven Fabric
87081090	M.V. Parts

Brand Names :

Not Available

Agencies Held :

Not Available

Exports :

Products :

Automobile and White Goods Components

Countries :

· UK

· Spain

Imports :

Products :

Raw Material

Countries :

· Dubai

· Korea

· China

Terms :

Selling :

Cash and Advance Payment

Purchasing :

Cash and Advance Payment

PRODUCTION STATUS: NOT AVAILABLE

GENERAL INFORMATION

Suppliers :

Reference:	Not Divulged
Name of the Person (Designation):	Not Divulged
Contact Number:	Not Divulged
Since how long known:	Not Divulged
Maximum limit dealt:	Not Divulged
Experience:	Not Divulged
Remark	Not Divulged

Customers :

Wholesalers and Retailers

Reference:	Not Divulged
Name of the Person (Designation):	Not Divulged
Contact Number:	Not Divulged
Since how long known:	Not Divulged
Maximum limit dealt:	Not Divulged
Experience:	Not Divulged
Remark	Not Divulged

No. of Employees :

160 (Approximately)

Bankers :

Bank Name:	Bank of India
Branch:	Juhu Branch, Plot No. 6-B, Nehru Nagar A, Juhu Tara Road, Mumbai - 400049, Maharashtra, India
Person Name (with Designation):	Not Divulged
Contact Number:	Not Divulged
Name of Account Holder:	Not Divulged
Account Number:	Not Divulged
Account Since (Date/ Year of A/c Opening):	Not Divulged
Average Balance Maintained (Optional):	Not Divulged
Credit Facilities Enjoyed (CC/OD/Term Loan):	Not Divulged
Account Operation:	Not Divulged
Remarks: Not Divulged

· Small Industries Development Bank of India

Mittal Court A Wing, 2nd Floor, Nariman Point, Mumbai - 400021, Maharashtra, India

· ICICI Bank Limited

· Dhanlaxmi Bank

· Barclays Bank

· HDFC Bank Limited

Facilities :

CC = Rs. 145.000 Million [From Bank of India]

SECURED LOANS	31.03.2014 (Rs. In Million)	31.03.2013 (Rs. In Million)
LONG-TERM BORROWINGS
Rupee term loans from banks	5.477	10.956
Term loans from others	37.496	52.772
Other loans and advances	1.243	1.631
SHORT TERM BORROWINGS
Term loans from banks	5.480	5.480
Rupee term loans from others	17.404	3.666
Working capital loans from banks	74.954	68.066
Other loans and advances	1.504	2.827
Total	143.558	145.398

Financial Institutions :	· Kotak Mahindra Prime Limited · India Bulls Financial Services Limited · Bajaj Finance Limited · Tata Capital Limited · ECL Finance Limited · Magma Fincorp Limited
Auditors :
Name :	Khurdia Jain and Company Chartered Accountants
Address :	C-1, 309, Bharateeya Kala, Om Nagar, Sahar Pipeline Road, Andheri (East), Mumbai - 400099, Maharashtra, India
Tel. No.:	91-22-28220907
Fax No.:	91-22-28226348
E-Mail :	vbjain1@gmail.com
Income-tax PAN of auditor or auditor's firm :	AAEFK1739J
Associate :	Sellowrap EPP India Private Limited [U24130MH2005PTC155220]

CAPITAL STRUCTURE

AS ON 31.03.2014

Authorised Capital :

No. of Shares	Type	Value	Amount
16,000,000	Equity Shares	Rs. 10/- each	Rs. 160.000 Million

Issued, Subscribed & Paid-up Capital :

No. of Shares	Type	Value	Amount
9,490,320	Equity Shares	Rs. 10/- each	Rs. 94.903 Million

FINANCIAL DATA

[all figures are in Rupees Million]

ABRIDGED BALANCE SHEET

SOURCES OF FUNDS	31.03.2014	31.03.2013	31.03.2012
I. EQUITY AND LIABILITIES
(1)Shareholders' Funds
(a) Share Capital	94.903	94.903	94.903
(b) Reserves & Surplus	63.477	109.967	107.814
(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)	158.380	204.870	202.717
(3) Non-Current Liabilities
(a) Long-term borrowings	94.114	115.727	91.965
(b) Deferred tax liabilities (Net)	1.327	1.327	1.333
(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)	95.441	117.054	93.298
(4) Current Liabilities
(a) Short term borrowings	109.140	88.157	92.786
(b) Trade payables	73.693	47.947	60.689
(c) Other current liabilities	65.472	47.887	43.679
(d) Short-term provisions	0.000	0.000	0.000
Total Current Liabilities (4)	248.305	183.991	197.154
TOTAL	502.126	505.915	493.169
II. ASSETS
(1) Non-current assets
(a) Fixed Assets
(i) Tangible assets	195.598	206.592	215.599
(ii) Intangible Assets	0.799	1.331	0.457
(iii) Capital work-in-progress	0.000	0.000	0.000
(iv) Intangible assets under development	0.000	0.000	0.000
(b) Non-current Investments	72.676	72.663	72.649
(c) Deferred tax assets (net)	0.000	0.000	0.000
(d) Long-term Loan and Advances	5.177	4.960	3.485
(e) Other Non-current assets	0.084	0.528	1.056
Total Non-Current Assets	274.334	286.074	293.246
(2) Current assets
(a) Current investments	0.000	0.000	0.000
(b) Inventories	42.030	58.039	53.515
(c) Trade receivables	138.936	140.531	124.628
(d) Cash and cash equivalents	11.164	2.926	5.921
(e) Short-term loans and advances	35.218	17.817	15.331
(f) Other current assets	0.444	0.528	0.528
Total Current Assets	227.792	219.841	199.923
TOTAL	502.126	505.915	493.169

PROFIT & LOSS ACCOUNT

	PARTICULARS		31.03.2014	31.03.2013	31.03.2012
	SALES
		Income	454.231	484.126	418.076
		Other Income	3.487	2.723	4.487
		TOTAL	457.718	486.849	422.563
Less	EXPENSES
		TOTAL	NA	NA	NA
	PROFIT/ (LOSS) BEFORE TAX		NA	NA	NA
Less	TAX		NA	NA	NA
	PROFIT/ (LOSS) AFTER TAX		(46.489)	2.152	2.241
	Earnings/ (Loss) Per Share (Rs.)		(4.90)	0.23	0.24

NOTE:

Director Report contains errors with the PAT Amount, so we are considering the amount mentioned in the schedule of Reserve and Surplus for the year 2014.

CURRENT MATURITIES OF LONG TERM DEBT DETAILS

Particulars	31.03.2014	31.03.2013	31.03.2012
Current Maturities of Long term debt	NA	NA	NA
Cash generated from operations	NA	NA	NA
Net cash Flow from used in operation	NA	NA	NA

KEY RATIOS

PARTICULARS		31.03.2014	31.03.2013	31.03.2012
Net Profit Margin (PAT/Sales)	(%)	(10.23)	0.44	0.54
Debt Equity Ratio (Total Debt/Networth)		1.28	1.00	0.91
Current Ratio (Current Asset/Current Liability)		0.92	1.19	1.01

FINANCIAL ANALYSIS

[all figures are in Rupees Million]

DEBT EQUITY RATIO

Particulars	31.03.2012	31.03.2013	31.03.2014
	(Rs. In Million)	(Rs. In Million)	(Rs. In Million)
Share Capital	94.903	94.903	94.903
Reserves & Surplus	107.814	109.967	63.477
Net worth	202.717	204.870	158.380
Long-term borrowings	91.965	115.727	94.114
Short term borrowings	92.786	88.157	109.140
Total borrowings	184.751	203.884	203.254
Debt/Equity ratio	0.911	0.995	1.283

YEAR-ON-YEAR GROWTH

Year on Year Growth	31.03.2012	31.03.2013	31.03.2014
	(Rs. In Million)	(Rs. In Million)	(Rs. In Million)
Sales	418.076	484.126	454.231
		15.799	(6.175)

NET PROFIT MARGIN

Net Profit Margin	31.03.2012	31.03.2013	31.03.2014
	(Rs. In Million)	(Rs. In Million)	(Rs. In Million)
Sales	418.076	484.126	454.231
Profit/ (Loss)	2.241	2.152	(46.489)
	0.54%	0.44%	(10.23%)

LOCAL AGENCY FURTHER INFORMATION

Sr. No.	Check list by info agents	Available in Report (Yes/No)
1	Year of establishment	Yes
2	Constitution of the entity -Incorporation details	Yes
3	Locality of the entity	Yes
4	Premises details	No
5	Buyer visit details	--
6	Contact numbers	Yes
7	Name of the person contacted	Yes
8	Designation of contact person	Yes
9	Promoter’s background	Yes
10	Date of Birth of Proprietor / Partners / Directors	Yes
11	Pan Card No. of Proprietor / Partners	No
12	Voter Id Card No. of Proprietor / Partners	No
13	Type of business	Yes
14	Line of Business	Yes
15	Export/import details (if applicable)	Yes
16	No. of employees	Yes
17	Details of sister concerns	Yes
18	Major suppliers	No
19	Major customers	No
20	Banking Details	Yes
21	Banking facility details	Yes
22	Conduct of the banking account	--
23	Financials, if provided	Yes
24	Capital in the business	Yes
25	Last accounts filed at ROC, if applicable	Yes
26	Turnover of firm for last three years	Yes
27	Reasons for variation <> 20%	--
28	Estimation for coming financial year	No
29	Profitability for last three years	Yes
30	Major shareholders, if available	Yes
31	External Agency Rating, if available	No
32	Litigations that the firm/promoter involved in	--
33	Market information	--
34	Payments terms	Yes
35	Negative Reporting by Auditors in the Annual Report	No

INDEX OF CHARGES

S. No.	Charge ID	Date of Charge Creation/Modification	Charge amount secured	Charge Holder	Address	Service Request Number (SRN)
1	10049430	08/04/2015 *	40,000,000.00	Bank of India	Juhu Branch, 53 Nehru Nagar "A", Juhu-Tara Road, Juhu, Mumbai, Maharashtra - 400049, INDIA	C54036520
2	80028060	08/04/2015 *	10,000,000.00	Bank of India	Juhu Branch, 53 Nehru Nagar "A", Juhu-Tara Road, Juhu, Mumbai, Maharashtra - 400049, INDIA	C54037403
3	80028061	08/04/2015 *	30,000,000.00	Bank of India	Juhu Branch, 53 Nehru Nagar "A", Juhu-Tara Road, Juhu, Mumbai, Maharashtra - 400049, INDIA	C54037601

* Date of charge modification

UNSECURED LOANS

PARTICULARS	31.03.2014 (Rs. In Million)	31.03.2013 (Rs. In Million)
LONG-TERM BORROWINGS
Rupee term loans from banks	0.897	0.000
Loans repayable on demand	0.000	4.141
Intercorporate borrowings	45.907	33.857
Loans and advances from related parties	3.094	12.370
SHORT TERM BORROWINGS
Term loans from banks	3.243	3.408
Rupee term loans from others	6.555	4.710
Total	59.696	58.486

FIXED ASSETS:

· Land

· Buildings

· Plant and equipment

· Factory equipments

· Other plant and equipment

· Furniture and fixtures

· Vehicles

· Motor vehicles

· Office equipment

· Computer equipments

· Other equipments

· 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. 64.00
UK Pound	1	Rs. 99.83
Euro	1	Rs. 70.16

INFORMATION DETAILS

Information Gathered by :	SVA
Analysis Done by :	KAR
Report Prepared by :	DDD

SCORE & RATING EXPLANATIONS

SCORE FACTORS	RANGE	POINTS
HISTORY	1~10	4
PAID-UP CAPITAL	1~10	3
OPERATING SCALE	1~10	4
FINANCIAL CONDITION
--BUSINESS SCALE	1~10	4
--PROFITABILITY	1~10	--
--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	YES
--AFFILIATION	YES/NO	YES
--LISTED	YES/NO	NO
--OTHER MERIT FACTORS	YES/NO	YES
DEFAULTERS
--RBI	YES/NO	NO
--EPF	YES/NO	NO
TOTAL		27

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.