MIRA INFORM REPORT
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Report No. : |
323681 |
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Report Date : |
25.05.2015 |
IDENTIFICATION DETAILS
|
Name : |
ECLINICALWORKS INDIA PRIVATE LIMITED |
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Registered Office
: |
A-701 to 705 and Part of B1-706, Boomerang, Main Chandivali Farm Road, Near Chandivali Studio, Andheri (East), Mumbai – 400072, Maharashtra |
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Tel No.: |
91- 22-67375000 |
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Country : |
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Financials (as
on) : |
31.03.2013 |
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Date of
Incorporation : |
30.10.2006 |
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Com. Reg. No.: |
11-165289 |
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Capital
Investment / Paid-up Capital : |
Rs.100.448 Million |
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CIN No.: [Company Identification
No.] |
U72200MH2006PTC165289 |
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TIN No.: |
Not Available |
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IEC No.: |
Not Available |
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TAN No.: [Tax Deduction &
Collection Account No.] |
Not Available |
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PAN No.: [Permanent Account No.] |
AABCE6639F |
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Legal Form : |
Private Limited Liability Company |
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Line of Business
: |
To carry on the business of Information Technology (IT) services i.e. software development, software installation, software testing and other support services and IT enabled services |
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No. of Employees
: |
Information denied by management |
RATING & COMMENTS
|
MIRA’s Rating : |
Ba (47) |
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RATING |
STATUS |
PROPOSED CREDIT LINE |
|
|
41-55 |
Ba |
Overall operation is considered normal. Capable to meet normal
commitments. |
Satisfactory |
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Status : |
Satisfactory |
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Payment Behaviour : |
Usually Correct |
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Litigation : |
Clear |
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Comments : |
Subject is a subsidiary of “ECLINICALWORKS LCC U.S.A.” It is
established company having satisfactory track record. As per registrar of companies the date of balance sheet (i.e.
financial field) is shown as 31.03.2014 but the documents related to the
financials are not been available from any sources. As per previous financial 2013, company has recorded healthy networth
position backed by it zero debt balance sheet profile. Rating takes into consideration company’s healthy financial and
managerial support that company receives from its holding company. Trade relations are fair. Business is active and payments are reported
to be usually correct. In a view of decent net worth base, managerial support from its
holding company, the company can be considered for normal 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.
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
31-03-2014.
INFORMATION DENIED BY
|
Name : |
Mr. Vishal |
|
Designation : |
Accountant |
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Contact No.: |
91-79-40222000 |
|
Date : |
21.05.2015 |
LOCATIONS
|
Registered Office : |
A-701 To 705 and Part of B1-706, Boomerang, Main Chandivali Farm Road, Near Chandivali Studio, Andheri (East), Mumbai – 400072, Maharashtra, India |
|
Tel. No.: |
91- 22-67375000 |
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Fax No.: |
Not Available |
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E-Mail : |
|
|
Website : |
DIRECTORS
As on 30.06.2014
|
Name : |
Mr. Mahesh Kumar Sunderdas Navani |
|
Designation : |
Director |
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Address : |
33 Farmington Drive, Shrewsbury Ma, 01545, United States Of America |
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Date of Birth/Age : |
09.02.1967 |
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Date of Appointment : |
18.12.2006 |
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DIN No.: |
00904484 |
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|
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Name : |
Mr. Rajesh Bhagwandas Dharampuriya |
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Designation : |
Director |
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Address : |
37 Farmington Drive, Shrewsbury Ma, 01545, United States Of America |
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Date of Birth/Age : |
05.10.1962 |
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Date of Appointment : |
03.04.1953 |
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DIN No.: |
00904503 |
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Name : |
Mr. Girish Motumal Navani |
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Designation : |
Director |
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Address : |
35, Farmington Drive, Shrewsbury Ma, 01545, United States Of America |
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Date of Birth/Age : |
18.12.2006 |
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Date of Appointment : |
18.12.2006 |
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DIN No.: |
00907586 |
KEY EXECUTIVES
|
Name : |
Mr. Vishal |
|
Designation : |
Accountant |
MAJOR SHAREHOLDERS
As on 30.06.2014
|
Names of Shareholders (Equity Shares) |
|
No. of Shares |
|
EClinicalWorks LLC, USA |
|
6372904 |
|
EClinicalWorks LLC, USA Jointly with Girish Motumal
Navani Jointly with Mahesh Kumar Sunderdas Navani Jointly with Rajesh
Bhagwandas Dharampuriya |
|
1 |
|
Total |
|
6372905 |
|
Names of Shareholders (Preference Shares) |
|
No. of Shares |
|
EClinicalWorks LLC, USA |
|
5200000 |
|
Total |
|
5200000 |
Equity Share Break up (Percentage of Total Equity)
As on 30.06.2014
|
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 : |
To carry on the business of Information Technology (IT) services i.e. software development, software installation, software testing and other support services and IT enabled services |
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Products / Services : |
Information Technology (IT) Services |
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Brand Names : |
-- |
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Agencies Held : |
-- |
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Exports : |
Not Divulged |
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Imports : |
Not Divulged |
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Terms : |
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Selling : |
Not Divulged |
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Purchasing : |
Not Divulged |
PRODUCTION STATUS – NOT AVAILABLE
GENERAL INFORMATION
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Suppliers : |
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Customers : |
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No. of Employees : |
Information denied by management |
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Bankers : |
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Auditors : |
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Name : |
Sameer B. Vageriya and Company Chartered Accountants |
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Address : |
504, Sheel Jeet Natwar Nagar, Road No. 5, Jogeswari (East), Mumbai - 400060 , Maharashtra, India |
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PAN No.: |
AACPV4953B |
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Memberships : |
-- |
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Collaborators : |
-- |
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Holding Company : |
EClinicalWorks LLC |
CAPITAL STRUCTURE
As on 30.06.2014
Authorised Capital :
|
No. of Shares |
Type |
Value |
Amount |
|
|
|
|
|
|
9800000 |
Equity Shares |
Rs.10/- each |
Rs.98.000 Million |
|
5200000 |
Preference Shares |
Rs.10/- each |
Rs.52.000 Million |
|
|
Total |
|
Rs.150.000
Million |
Issued, Subscribed & Paid-up Capital :
|
No. of Shares |
Type |
Value |
Amount |
|
|
|
|
|
|
6372905 |
Equity Shares |
Rs.10/- each |
Rs.63.729 Million |
|
5200000 |
Preference Shares |
Rs.10/- each |
Rs.52.000 Million |
|
|
Total |
|
Rs.115.729
Million |
As on 31.03.2013
Authorised Capital :
|
No. of Shares |
Type |
Value |
Amount |
|
|
|
|
|
|
9800000 |
Equity Shares |
Rs.10/- each |
Rs.98.000 Million |
|
5200000 |
Preference Shares |
Rs.10/- each |
Rs.52.000 Million |
|
|
Total |
|
Rs.150.000
Million |
Issued, Subscribed & Paid-up Capital :
|
No. of Shares |
Type |
Value |
Amount |
|
|
|
|
|
|
4844847 |
Equity Shares |
Rs.10/- each |
Rs.48.448 Million |
|
5200000 |
Preference Shares |
Rs.10/- each |
Rs.52.000 Million |
|
|
Total |
|
Rs.100.448
Million |
FINANCIAL DATA
[all figures are
in Rupees Million]
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 |
100.448 |
96.191 |
73.560 |
|
(b) Reserves & Surplus |
1,747.500 |
1,492.256 |
534.693 |
|
(c) Money
received against share warrants |
0.000 |
0.000 |
0.000 |
|
|
|
|
|
|
(2) Share Application money pending
allotment |
425.667 |
0.000 |
0.000 |
|
Total Shareholders’
Funds (1) + (2) |
2,273.615 |
1,588.447 |
608.253 |
|
|
|
|
|
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(3)
Non-Current Liabilities |
|
|
|
|
(a) long-term borrowings |
0.000 |
0.000 |
0.000 |
|
(b) Deferred tax liabilities (Net) |
(0.541) |
3.489 |
0.434 |
|
(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) |
(0.541) |
3.489 |
0.434 |
|
|
|
|
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|
(4)
Current Liabilities |
|
|
|
|
(a) Short
term borrowings |
0.000 |
0.000 |
0.000 |
|
(b) Trade
payables |
11.784 |
14.837 |
8.805 |
|
(c) Other
current liabilities |
42.193 |
32.215 |
12.712 |
|
(d) Short-term
provisions |
82.232 |
45.055 |
24.378 |
|
Total Current
Liabilities (4) |
136.209 |
92.107 |
45.895 |
|
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|
|
|
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TOTAL |
2,409.283 |
1,684.043 |
654.582 |
|
|
|
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II.
ASSETS |
|
|
|
|
(1)
Non-current assets |
|
|
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|
(a) Fixed
Assets |
|
|
|
|
(i)
Tangible assets |
971.582 |
1,044.488 |
156.372 |
|
(ii)
Intangible Assets |
4.640 |
5.800 |
5.319 |
|
(iii)
Capital work-in-progress |
505.911 |
0.000 |
0.000 |
|
(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) |
0.000 |
0.000 |
0.000 |
|
(d)
Long-term Loan and Advances |
30.534 |
26.128 |
26.638 |
|
(e) Other
Non-current assets |
0.000 |
0.000 |
0.000 |
|
Total Non-Current
Assets |
1,512.667 |
1,076.416 |
188.329 |
|
|
|
|
|
|
(2)
Current assets |
|
|
|
|
(a)
Current investments |
0.000 |
0.000 |
0.000 |
|
(b)
Inventories |
0.000 |
0.000 |
0.000 |
|
(c) Trade
receivables |
309.986 |
161.544 |
79.708 |
|
(d) Cash
and cash equivalents |
483.693 |
394.272 |
345.238 |
|
(e)
Short-term loans and advances |
48.046 |
25.773 |
19.233 |
|
(f) Other
current assets |
54.891 |
26.038 |
22.074 |
|
Total
Current Assets |
896.616 |
607.627 |
466.253 |
|
|
|
|
|
|
TOTAL |
2,409.283 |
1,684.043 |
654.582 |
PROFIT & LOSS
ACCOUNT
|
|
PARTICULARS |
31.03.2013 |
31.03.2012 |
31.03.2011 |
|
|
|
|
|
|
|
|
|
|
INCOME |
NA |
NA |
NA |
|
|
|
|
|
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|
EXPENSES |
NA |
NA |
NA |
|
|
|
|
|
|
|
|
|
|
PROFIT/(LOSS)
BEFORE TAX, DEPRECIATION AND AMORTISATION (C-D)
(E) |
167.950 |
96.639 |
79.155 |
|
|
|
|
|
|
|
|
|
Less |
DEPRECIATION/
AMORTISATION (F) |
103.184 |
40.106 |
30.851 |
|
|
|
|
|
|
|
|
|
|
PROFIT/(LOSS)
BEFORE TAX (E-F) (G) |
64.766 |
56.533 |
48.304 |
|
|
|
|
|
|
|
|
|
Less |
TAX (H) |
22.348 |
15.455 |
8.687 |
|
|
|
|
|
|
|
|
|
|
PROFIT/(LOSS)
AFTER TAX (G-H) (I) |
42.418 |
41.078 |
39.617 |
|
|
|
|
|
|
|
|
|
Add |
PREVIOUS
YEARS’ BALANCE BROUGHT FORWARD |
123.227 |
82.209 |
42.652 |
|
|
|
|
|
|
|
|
|
Less |
APPROPRIATIONS |
|
|
|
|
|
|
|
Proposed Preference Share Dividend |
0.052 |
0.052 |
0.052 |
|
|
|
Dividend Distribution tax |
0.008 |
0.008 |
0.008 |
|
|
BALANCE CARRIED
TO THE B/S |
165.585 |
123.227 |
82.209 |
|
|
|
|
|
|
|
|
|
|
EARNINGS IN
FOREIGN CURRENCY |
|
|
|
|
|
|
|
ITES/ Software Service Fees raised during the year |
784.097 |
511.498 |
349.355 |
|
|
TOTAL EARNINGS |
784.097 |
511.498 |
349.355 |
|
|
|
|
|
|
|
|
|
|
Earnings /
(Loss) Per Share (Rs.) |
3.67 |
NA |
NA |
|
CURRENT MATURITIES
OF LONG TERM DEBT DETAILS
|
Particulars |
31.03.2013 |
31.03.2012 |
31.03.2011 |
|
Current Maturities of Long term debt |
NA |
NA |
NA |
|
Cash generated from operations |
NA |
NA |
NA |
KEY RATIOS
|
PARTICULARS |
|
31.03.2013 |
31.03.2012 |
31.03.2011 |
|
Return on Total Assets (PBT/Total Assets} |
(%) |
3.40 |
3.36 |
7.38 |
|
|
|
|
|
|
|
Return on Investment (ROI) (PBT/Networth) |
|
0.03 |
0.04 |
0.08 |
|
|
|
|
|
|
|
Debt Equity Ratio (Total Debt /Networth) |
|
0.00 |
0.00 |
0.00 |
|
|
|
|
|
|
|
Current Ratio (Current Asset/Current Liability) |
|
6.58 |
6.60 |
10.16 |
FINANCIAL ANALYSIS
[all figures are
in Rupees Million]
DEBT EQUITY RATIO
|
Particular |
31.03.2011 |
31.03.2012 |
31.03.2013 |
|
|
Rs.
In Million |
Rs. In
Million |
Rs.
In Million |
|
Share Capital |
73.560 |
96.191 |
100.448 |
|
Reserves & Surplus |
534.693 |
1492.256 |
1747.500 |
|
Money received against share
warrants |
0.000 |
0.000 |
0.000 |
|
Share Application money pending allotment |
0.000 |
0.000 |
425.667 |
|
Net
worth |
608.253 |
1588.447 |
2273.615 |
|
|
|
|
|
|
Long Term borrowings |
0.000 |
0.000 |
0.000 |
|
Short Term borrowings |
0.000 |
0.000 |
0.000 |
|
Total
borrowings |
0.000 |
0.000 |
0.000 |
|
Debt/Equity
ratio |
0.000 |
0.000 |
0.000 |
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) |
No |
|
16 |
No. of employees |
No |
|
17 |
Details of sister concerns |
Yes |
|
18 |
Major suppliers |
No |
|
19 |
Major customers |
No |
|
20 |
Banking Details |
No |
|
21 |
Banking facility details |
No |
|
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 |
No |
|
26 |
Turnover of firm for last three years |
No |
|
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 |
BACKGROUND AND
PRINCIPAL ACTIVITIES
The Company is incorporated on 30th October, 2006 as a private limited company. eClinicalWorks LLC (US) (the Group) (the holding company) of the Company. The holding company is a medical software company founded in 1999. It is a leader in the unified electronic medical record (EMR) and practice management (PM) market catering to a wide variety of practices in USA. The unit has been approved under the STP scheme of the Govt. of India as a 100 % export oriented unit for computer software. Company’s primary business is to carry on the business of Information Technology (IT) services i.e. software development, software installation, software testing and other support services and IT enabled services
OPERATIONS
The company has performed very well as compared to the previous year and expects to maintain the same level of growth and performance in future. The Company further plans to expand its operations in coming near future. We expect the growth to achieve new heights with such expansions.
The company specifically provides services to its parent Company, eClinicalWorks, LLC. eClinical US is a medical software company and it is a leader in the unified electronic medical record (EMR) and practice management (PM) market catering to a wide variety of practices in USA.
It is a product based proprietary software company. The company provides Information Technology and IT enabled services (e.g. trouble shooting, handling of client complaints etc.).
REVIEW OF PROGRESS
Prospects for the current financial year appear reasonable positive in view of the company's quality of work and adherence to schedules. eClinicalWorks India has been successful in creating the technical capabilities and expertise to perform the support services with respect to the eCW-USs business or the Products.
The Company endeavours to undertake expansion plans on a large scale in coming years in view of the encouraging performance and response from prospective clients. The Directors are hopeful of exploring newer market to reach maximum client base.
NO CHARGES EXIST FOR
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.63.57 |
|
|
1 |
Rs.99.67 |
|
Euro |
1 |
Rs.70.83 |
INFORMATION DETAILS
|
Information
Gathered by : |
KSP |
|
|
|
|
Analysis Done by
: |
MNJ |
|
|
|
|
Report Prepared
by : |
VNT |
SCORE & RATING EXPLANATIONS
|
SCORE FACTORS |
RANGE |
POINTS |
|
HISTORY |
1~10 |
5 |
|
PAID-UP CAPITAL |
1~10 |
5 |
|
OPERATING SCALE |
1~10 |
6 |
|
FINANCIAL
CONDITION |
|
|
|
--BUSINESS SCALE |
1~10 |
6 |
|
--PROFITABILITY |
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 |
NO |
|
--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 |
|
47 |
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.