MIRA INFORM REPORT

Report No. :	348294
Report Date :	10.11.2015

IDENTIFICATION DETAILS

Name :	S ZHAVERI PHARMAKEM PRIVATE LIMITED
Registered Office :	308/310, Shiv Smriti Chambers, 49, Dr. Annie Besant Road, Worli, Mumbai – 400018, Maharashtra
Tel. No.:	91-22-43676666 / 66607756
Country :	India
Financials (as on) :	31.03.2014
Date of Incorporation :	06.06.2005
Com. Reg. No.:	11-153790
Capital Investment / Paid-up Capital :	Rs. 1.605 Million
CIN No.: [Company Identification No.]	U51397MH2005PTC153790
IEC No.:	0305023136
TAN No.: [Tax Deduction & Collection Account No.]	Not Available
PAN No.: [Permanent Account No.]	AAJCS0402N
Legal Form :	Private Limited Liability Company
Line of Business :	Subject is engaged in manufacturing and marketing pharmaceutical raw materials and chemicals.
No. of Employees :	Not Available [We tried to confirm the number of employees but no one is ready to part any information from the company management]

RATING & COMMENTS

MIRA’s Rating :

Ba (46)

RATING		STATUS	PROPOSED CREDIT LINE
41-55	Ba	Overall operation is considered normal. Capable to meet normal commitments.	Satisfactory

Maximum Credit Limit :	USD 960000
Status :	Satisfactory
Payment Behaviour :	Usually correct
Litigation :	Clear
Comments :	Subject was incorporated in the year 2005 and it is engaged in manufacturing and marketing pharmaceutical raw materials and chemicals. Its products include aluminum collapsible tubes, plastic tubes and tritely citrate. For the financial year ended 2014, company has reported 43.46% sales turnover and it has reported below average profit margins at 0.69% during the year under a review. Rating also into account of company above average financial profile marked by its sound networth base along with fair liquidity position and satisfactory debt coverage indicators. Trade relations are reported as fair. Payment terms are reported to be usually correct. In view of aforesaid, the company can be considered for business dealings at usual trade terms and condition. Note : As per registrar of companies the date of balance sheet (i.e. financial filed) is shown as 31.03.2015 but the documents related to the financial are not available from any source.

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

Rating Agency Name	Not Available
Rating	Not Available
Rating Explanation	Not Available
Date	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 31-03-2015.

LOCATIONS

Registered Office :	308/310, Shiv Smriti Chambers, 49, Dr. Annie Besant Road, Worli, Mumbai – 400018, Maharashtra
Tel. No.:	91-22-43676666 / 66607756
Fax No.:	91-22-66607758
E-Mail :	hemang@szhavri.net accounts@szhaveri.net
Website :	http://www.szhavri.com
Area :	1000 sq. ft.
Location :	Owned
Research Centre / Factory :	B -10 and 10-1, Dombivali MIDC, Phase – I, Kalyan, Shil Phta Road, Dombivali Thane – 421203, Maharashtra, India
Tel. No.:	91-251-3918000/1/2/3
Area :	48000 sq. ft.
Location :	Owned

DIRECTORS

As on 31.03.2015

Name :

Mrs. Uma Rajan Javeri

Designation :

Director

Address :

1002, Jaywant Tower Chs Ltd.Tardeo Road,Tardeo,Mumbai-400034, Maharashtra

Date Of Birth/Age :

29.05.1957

Date Of Appointment :

06.06.2005

DIN No.:

00140841

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	U74140MH1998PTC115077	S ZAVERI CONTRACT RESEARCH ORGANISATION PRIVATE LIMITED	Director	10/04/1999	10/04/1999	-	Active	NO
2	U51397MH2005PTC153790	S ZHAVERI PHARMAKEM PRIVATE LIMITED	Director	06/06/2005	06/06/2005	-	Active	NO
3	U99999MH1992PLC065026	PRASOL CHEMICALS LIMITED	Director	30/07/2015	30/03/2015	-	Active	NO

Name :

Mrs. Suhagi Dhaval Parikh

Designation :

Director

Address :

1002, Jaywant Tower Chs Ltd.Tardeo Road,Tardeo, Mumbai-400034, Maharashtra

Date Of Birth/Age :

15.10.1981

Date Of Appointment :

06.06.2005

DIN No.:

00140949

Name :

Mr. Josef Otto Rettenmaier

Designation :

Director

Address :

Holzmuhle, 6, Rosenberg,73494,Germany

Date Of Birth/Age :

22.01.1961

Date Of Appointment :

04.02.2008

DIN No.:

02095744

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	U24229GJ1989PTC011737	GUJARAT MICROWAX PRIVATE LIMITED	Director	23/06/2006	23/06/2006	-	Active	NO
2	U51397MH2005PTC153790	S ZHAVERI PHARMAKEM PRIVATE LIMITED	Director	04/02/2008	04/02/2008	-	Active	NO
3	U24100MH2009PTC244642	Rettenmaier India Private Limited	Director	28/09/2010	20/01/2010	-	Active	NO

Name :

Mr. Heinrich Ernst Wilhelm Petersen

Designation :

Director

Address :

Lessing Str,2, 73486, Adelmannsfelden, Adelmannsfelden, 73486,Germany

Date Of Birth/Age :

09.09.1949

Date Of Appointment :

04.02.2008

DIN No.:

02166885

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	U51397MH2005PTC153790	S ZHAVERI PHARMAKEM PRIVATE LIMITED	Director	04/02/2008	04/02/2008	24/03/2015	Active	NO
2	U24229GJ1989PTC011737	GUJARAT MICROWAX PRIVATE LIMITED	Director	30/06/2008	30/06/2008	26/08/2015	Active	NO
3	U24100MH2009PTC244642	Rettenmaier India Private Limited	Director	28/09/2010	20/01/2010	30/07/2015	Active	NO

Name :

Hans Friedrich Wollmann

Designation :

Additional Director

Address :

Recklinghausen, Kohlstrasse 110, Recklinghausen, 45659, Germany

Date of Appointment :

22.05.2015

DIN No.:

01774016

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	U51109MH2007PTC176177	Fanales Candles Private Limited	Director	26/11/2007	26/11/2007	-	Active	YES
2	U51397MH2005PTC153790	S ZHAVERI PHARMAKEM PRIVATE LIMITED	Additional director	22/05/2015	22/05/2015	-	Active	NO
3	U24100MH2009PTC244642	Rettenmaier India Private Limited	Additional director	30/07/2015	30/07/2015	-	Active	NO

MAJOR SHAREHOLDERS / SHAREHOLDING PATTERN

As on 30.09.2014

Names of Shareholders	No. of Shares
Uma R. Javeri	69745
Saloni R Javeri	5265
Parikh Dhaval Suhagi	5265
Gmbh Asiaholding Retten Maier	80275
Total	160550

Equity Share Break up (Percentage of Total Equity)

As on 30.09.2014

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	57.84
Bodies corporate	42.16
Total	100.00

BUSINESS DETAILS

Line of Business :	Subject is engaged in manufacturing and marketing pharmaceutical raw materials and chemicals.
Products :	Pharmaceutical Raw Materials and Chemicals
Brand Names :	Not Available
Agencies Held :	Not Available
Exports :	Not Available
Imports :	Not Available
Terms :	Not Available

PRODUCTION STATUS NOT AVAILABLE

GENERAL INFORMATION

Suppliers :

Reference :	Not Available
Name of the Person :	Not Available
Contact No.:	Not Available
Since How Long Known :	Not Available
Maximum Limit Dealt :	Not Available
Experience :	Not Available
Remark:	Not Available

Customers :

Reference :	Not Available
Name of the Person :	Not Available
Contact No.:	Not Available
Since How Long Known :	Not Available
Maximum Limit Dealt :	Not Available
Experience :	Not Available
Remark:	Not Available

No. of Employees :

Not Available [We tried to confirm the number of employees but no one is ready to part any information from the company management]

Bankers :

Bank Name	HDFC Bank Limited
Branch	HDFC Bank Housesenapati Bapat Marg, Lower Parel (West), Mumbai-400013, Maharashtra, India
Person Name (With Designation)	Not Available
Contact Number	Not Available
Name of Account Holder	Not Available
Account Number	Not Available
Account Since (Date/Year of Account Opening)	Not Available
Average Balance Maintained (If Possible)	Not Available
Credit Facilities Enjoyed (If any)	Not Available
Account Operation	Not Available
Remarks (If any)	Not Available

Facilities :

Secured Loan	31.03.2014 (Rs. in Million)	31.03.2013 (Rs. in Million)
Long-term Borrowings
HDFC Overdraft	40.094	0.000
Vehicle Loans	2.126	3.022
Total	42.220	3.022

Auditors :
Name :	Vinay H Panjabi and Associates Chartered Accountants
Address :	206, Dalamal Chamber, New Marine Lines, Mumbai – 400020, Maharashtra , India
PAN N Income-tax PAN of auditor or auditor's firm :	AABPP1697J
Memberships :	--
Collaborators :	--
Associates/Subsidiaries :	Not Available

CAPITAL STRUCTURE

As on 30.09.2014

Authorised Capital :

No. of Shares	Type	Value	Amount
300,000	Equity Shares	Rs.10/- each	Rs. 3.000 Million

Issued, Subscribed & Paid-up Capital :

No. of Shares	Type	Value	Amount
160,550	Equity Shares	Rs.10/- each	Rs. 1.605 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	1.605	1.605	0.869
(b) Reserves & Surplus	334.379	329.331	175.236
(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)	335.984	330.936	176.105
(3) Non-Current Liabilities
(a) long-term borrowings	125.556	68.744	85.076
(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)	125.556	68.744	85.076
(4) Current Liabilities
(a) Short term borrowings	0.000	0.000	0.000
(b) Trade payables	169.871	98.133	69.744
(c) Other current liabilities	6.868	5.008	4.387
(d) Short-term provisions	9.528	7.745	7.257
Total Current Liabilities (4)	186.267	110.886	81.388
TOTAL	647.807	510.566	342.569
II. ASSETS
(1) Non-current assets
(a) Fixed Assets
(i) Tangible assets	301.128	239.478	136.083
(ii) Intangible Assets	0.000	0.000	0.000
(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	0.000	0.000	0.000
(c) Deferred tax assets (net)	1.937	2.836	3.861
(d) Long-term Loan and Advances	1.011	1.011	1.118
(e) Other Non-current assets	0.000	0.000	0.000
Total Non-Current Assets	304.076	243.325	141.062
(2) Current assets
(a) Current investments	0.000	0.000	5.643
(b) Inventories	71.772	83.783	44.715
(c) Trade receivables	200.441	143.726	112.272
(d) Cash and cash equivalents	9.617	10.297	4.269
(e) Short-term loans and advances	41.165	20.410	22.748
(f) Other current assets	20.736	9.025	11.860
Total Current Assets	343.731	267.241	201.507
TOTAL	647.807	510.566	342.569

PROFIT & LOSS ACCOUNT

	PARTICULARS		31.03.2014	31.03.2013	31.03.2012
	SALES
		Income	730.315	505.355	424.056
		Other Income	1.181	4.464	2.546
		TOTAL (A)	731.496	509.819	426.602
Less	EXPENSES
		Cost of Goods Consumed	555.598	371.815	299.066
		Employees benefits expense	59.647	46.732	40.324
		Selling and Development Expenses	43.814	35.660	29.776
		Research and Development Expenses	9.419	6.858	7.816
		TOTAL (B)	668.478	461.065	376.982
	PROFIT/ (LOSS) BEFORE INTEREST, TAX, DEPRECIATION AND AMORTISATION (C)		63.018	48.754	49.620
Less	FINANCIAL EXPENSES (D)		26.532	7.560	12.109
	PROFIT / (LOSS) BEFORE TAX, DEPRECIATION AND AMORTISATION (C-D) (E)		36.486	41.194	37.511
Less/ Add	DEPRECIATION/ AMORTISATION (F)		28.783	17.655	15.004
	PROFIT/ (LOSS) BEFORE TAX (E-F) (G)		7.703	23.539	22.507
Less	TAX (H)		2.655	8.173	7.773
	PROFIT/ (LOSS) AFTER TAX (G-H) (I)		5.048	15.366	14.734
	Earnings / (Loss) Per Share (Rs.)		36.37	110.71	169.44

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 flows from (used in) operation	NA	NA	NA

KEY RATIOS

PARTICULARS		31.03.2014	31.03.2013	31.03.2012
Net Profit Margin (PAT / Sales)	(%)	0.69	3.04	3.47
Operating Profit Margin (PBIDT/Sales)	(%)	8.63	9.65	11.70
Return on Total Assets (PBT/Total Assets}	(%)	1.19	4.64	6.64
Return on Investment (ROI) (PBT/Networth)		0.02	0.07	0.13
Debt Equity Ratio (Total Debt /Networth)		0.37	0.21	0.48
Current Ratio (Current Asset/Current Liability)		1.85	2.41	2.48

FINANCIAL ANALYSIS

[all figures are in Rupees Million]

DEBT EQUITY RATIO

Particular	31.03.2012	31.03.2013	31.03.2014
	(Rs. In Million)	(Rs. In Million)	(Rs. In Million)
Share Capital	0.869	1.605	1.605
Reserves & Surplus	175.236	329.331	334.379
Net worth	176.105	330.936	335.984
long-term borrowings	85.076	68.744	125.556
Short term borrowings	0.000	0.000	0.000
Total borrowings	85.076	68.744	125.556
Debt/Equity ratio	0.483	0.208	0.374

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	424.056	505.355	730.315
		19.172	44.515

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	424.056	505.355	730.315
Profit	14.734	15.366	5.048
	3.47%	3.04%	0.69%

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	No
8]	Designation of contact person	No
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	No
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	No
35]	Negative Reporting by Auditors in the Annual Report	No

UNSECURED LOAN

PARTICULARS	31.03.2014 (Rs. in Million)	31.03.2013 (Rs. in Million)
Long-term Borrowings
From Directors, Share Holders	83.336	65.722
Total	83.336	65.722

INDEX OF CHARGES

S.No.	Charge ID	Date of Charge Creation/Modification	Charge amount secured	Charge Holder	Address	Service Request Number (SRN)
1	10484331	03/07/2014 *	50,000,000.00	HDFC BANK LIMITED	HDFC BANK HOUSESENAPATI BAPAT MARG, LOWER PAREL W  , MUMBAI, Maharashtra - 400013, INDIA	C12263885

* Date of charge modification

FIXED ASSETS

• Air Conditioners
• Computers and Fittings
• Electrical Fittings
• Furniture
• Mobile Phone
• Motor Car
• Office Equipments
• Office Premises
• Software
• Building
• Consultancy (Architect)
• Electric Work
• Furniture and Fixture
• HVAC
• Land
• Plant and Machinery
• 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.65.79
UK Pound	1	Rs.99.94
Euro	1	Rs.71.55

INFORMATION DETAILS

Analysis Done by :	KAR
Report Prepared by :	JYTK

SCORE & RATING EXPLANATIONS

SCORE FACTORS	RANGE	POINTS
HISTORY	1~10	6
PAID-UP CAPITAL	1~10	5
OPERATING SCALE	1~10	5
FINANCIAL CONDITION
--BUSINESS SCALE	1~10	5
--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	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	NO
--LISTED	YES/NO	NO
--OTHER MERIT FACTORS	YES/NO	YES
DEFAULTER
--RBI	YES/NO	NO
--EPF	YES/NO	NO
TOTAL		46

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.