Mr. Raj Kumar Dad Vs Srithik Ispat Private Limited

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Judgment

756 paragraphs · 6,425 words

Kishore Vemulapalli, Member (Judicial)

This is an application being IA No. 716/MB-IV/2021 filed by Mr. Raj Kumar Dad, the Applicant, under Section 31 of IBC, 2016 (the Code), for approval of the Resolution Plan filed by Girija Agarwal for an amount of Rs. 8.7 crores, for the Corporate Debtor Srithik Ispat Private Limited (hereinafter called as the “Corporate Debtor”) and approved by 100% CoC members.

The brief submissions on behalf of the Applicant is as under:

a) This Tribunal vide its order dated 30.09.2019 admitted the Petition filed by the Financial Creditor under section 9 and 8 of the Code against the Corporate Debtor and the Applicant was appointed as an IRP in the matter.

b) Pursuant to the appointment of the Applicant as an Interim Resolution Professional (hereinafter referred as IRP), the Applicant was confirmed and appointed as an Resolution Professional (hereinafter referred as RP) by the members of Committee of Creditors (hereinafter referred as CoC), the Applicant has since then carried out its duties in accordance with the provisions and rules as envisaged under the Code with respect to the Corporate Insolvency Resolution Process (hereinafter referred as CIRP) of the Corporate Debtor.

c) The Applicant has conducted the meetings of the CoC in the past on eight occasions. Following is the list of the dates on which the said CoC meetings were conducted:

Sr. No.

Particulars

Date

1st CoC Meeting

24/10/2019

2nd CoC Meeting

2/12/2019

3rd CoC Meeting

17/01/2020

4th CoC Meeting

3/03/2020

5th CoC Meeting

27/04/2020

6th CoC Meeting

27/07/2020

7th CoC Meeting

21/08/2020

8th CoC Meeting

26/02/2021

d) The Applicant states that the Form G inviting Expression of Interest (hereinafter referred as EoI) was published on 20.01.2020 consequent to which the RP received a Resolution Plan submitted on 11.03.2020 and the same was rejected by the CoC following which in the 7th CoC Meeting which held on 21.08.2020, the members of CoC passed a Resolution to file an Application seeking the directions of this Tribunal to liquidate the Assets of the Corporate Debtor. In view of the above, the RP filed an Application bearing IA 241 of 2021 on 09.10.2020 for Liquidation of the Corporate Debtor.

e) However, the RP received a revised Resolution Plan which was submitted to the RP on 23.02.2021 following which the ‘Final Plan’ was arrived at which was submitted on 25.02.2021. The said Final Plan was placed before the members of the CoC for their approval. The members of the CoC after deliberations during its 8th CoC meeting conducted on 26.02.2021 arrived at a conclusion to approve the said Final Plan. The Final Plan submitted by Mrs. Girija Agarwal was approved by the CoC members vide E-voting conducted till 06.03.2021.

f) The Resolution Plan submitted by the Resolution Applicant (hereinafter referred as RA) is for a total amount of Rs.8,70,00,000/- (Rupees eight crore seventy lakh only). The RA has proposed the following broad steps to revive the unit of the Corporate Debtor, they are as follows:

i. Reductions in Debt of the Company;

ii. Extinguishment of various operational and statutory liabilities;

iii. Reliefs from the Contingent liabilities;

iv. Reliefs from the ongoing cases against the company and ratification of the various non-compliances;

v. Obtaining necessary approvals form pollution control board, electricity board and others statutory departments for restarting the unit Better raw material resourcing and Necessary working capital to be raised at low cost of funds.

g) The RA has further arranged the proposed resolution consideration from family and friends with an option to provide equity share against the unsecured loan. Total consideration is proposed to be paid as upfront payment in the revised Resolution Plan by the RA.

h) The Applicant further says that there are no dues to be paid to the workers as wages or salaries. The statutory dues towards labour, including the dues towards the Provident Fund Department being more than 2 years old are covered under Operational Creditors (Statutory Creditors). Hence no amount is to be paid towards the same. The RA also proposes to pay full amount for any accepted claim by the RP before the Final Order date within 90 days from the date of the Order.

i) The RP says that there is one Secured Financial Creditor and the total claim of Secured Financial Creditor as accepted by the RP is Rs.3263.64 lakh.

j) The RA under the proposed plan shall make a payment of Rs.820/- lakh to the Secured Financial Creditor as their full and final settlement of claims of SFCs amount of Rs.3263.64 lakh at the time the beginning of the CIRP.

k) The Applicant further says that no changes are proposed in the Equity Shareholding of the Corporate Debtor and there are no amounts which are due to be paid to the statutory creditors expect the one mentioned above.

l) The Applicant further states that as per the provisions of the Code, the period of CIRP was supposed to end on 28.03.2020. The Applicant states that, on 25.03.2020, the ‘Government of India’ imposed a nationwide Lockdown on account of COVID-19 pandemic vide its notification. The Applicant further states that the above-mentioned period of lockdown was extended by the Government of India till 31.05.2020. The Applicant states that in addition to the said notifications issued by the Government of India, the State Government of Maharashtra was pleased to issue additional notifications from time to time to extend the lockdown period within the State of Maharashtra, which currently is up to 31.12.2020.

m) The Applicant states that to give effect to the same, Regulation 40C was introduced by the IBBI (Insolvency Resolution Process for Corporate Persons) (Third Amendment) Regulations, 2020 as and by way of an amendment that came into force on 29.03.2020 which states the following:

40C. Special provision relating to time-line

Notwithstanding the time-lines contained in these regulations, but subject to the provisions in the Code, the period of lockdown imposed by the Central Government in the wake of Covid-19 outbreak shall not be counted for the purposes of the time-line for any activity that could not be completed due to such lockdown, in relation to a corporate insolvency resolution process.

n) The Applicant further states that the Hon’ble NCLAT, vide its Suo Motto order passed dated 30.03.2020 was pleased to pass the following order:

(1) That the period of lockdown ordered by the Central Government and the State Governments including the period as may be extended either in whole or part of the country, where the registered office of the Corporate Debtor may be located, shall be excluded for the purpose of counting of the period for ‘Resolution Process under Section 12 of the Insolvency and Bankruptcy Code, 2016, in all cases where ‘Corporate Insolvency Resolution Process’ has been initiated and pending before any Bench of the National Company Law Tribunal or in Appeal before this Appellate Tribunal.

(2) It is further ordered that any interim order/ stay order passed by this Appellate Tribunal in anyone or the other Appeal under Insolvency and Bankruptcy Code, 2016 shall continue till next date of hearing, which may be notified later.

o) The Applicant states that the Applicant has so far performed his duties as the RP and discharged his functions as under the provisions of the Code. It is further submitted that a detailed closure report with respect to the CIRP of the Corporate Debtor prepared on behalf of the Applicant has set out details of the entire functions and activities performed by the RP since the commencement of the CIRP till the filing of this Applications.

p) That the present Application is made on behalf of the Applicant in the most bonafide manner and in the interest of Justice. Since 180 days for the conclusion of CIRP was 28.03.2020, the same is given under the compliance certificate under Form H as per Regulation 39(4) of the IBBI (Insolvency Resolution Process for Corporate Persons) Regulation, 2016.

q) The CoC member in the 4th CoC meeting decided to file an Application for Extension of the CIRP period as the time period of 180 days for completion of the CIRP was approaching.

r) The Applicant has submitted the brief overview of the Resolution Plan as under:

CONSTITUTION OF THE COC:

Sr. No.

Name of the COC Member

Voting %

CFM Assets Reconstruction

Private Limited

100%

Total

100

FAIR VALUE AND LIQUIDATION VALUE:

i. Average fair value is Rs. 11,62,29,995/-

ii. Average liquidation value is Rs. 8,03,01,371/-

AMOUNT UNDER THE RESOLUTON PLAN:

Amount envisaged under the Resolution Plan is Rs. 8.7 crores payable as per the given below schedule:

Sr. No

Particulars of Claim

Type of Claim

Admitted Amount

(INR)

Settlement Amount

(INR)

CIRP Costs

Atactuals

15,00,000

100%

Financial Creditors not having a right to vote under sub section (2) of Section 21

Secured

1,29,90,874

NIL

Financial Creditors

Secured

32,63,64,000

8,20,00,000

25%

Operational Creditors-

Government

Secured

10,44,83,597

7,00,000

0.66%

Operational Creditors – Other than Government, Employees and Workmen

Secured

4,17,00,000

1,50,000

0.35%

Statutory Dues (GIDC Electricity Dues and Cost of License regularization)

NIL

(Expected Compliance cost to restart the

operations)

31,50,000

Working Capital and

Maintenance Capex

NIL

10,00,000

GRAND TOTAL

8,70,00,000

17.92 %

TREATMENT OF CIRP COSTS:

CIRP costs to be paid in priority to any other creditor. Amount of Rs. 15,00,000/- (Rupees Twenty Lakhs Only) is estimated to be the CIRP cost and shall be paid in full from the realization of the Secured Financial Creditors of this plan.

TREATMENT OF SECURED FINANCIAL CREDITORS:

Sr. No.

Particulars of

Claim

Admitted Amount

(INR)

Settlement Amount

(INR)

Secured Financial

Creditors

32,63,64,000

8,20,00,000

25%

Resolution Applicant proposes to pay the said amount to the secured Financial Creditor in order to settle the personal guarantee obligation towards the secured financial creditor.

The Resolution Applicant proposes to pay in the following schedule to the Secured Financial Creditor:

a. Rs. 15,00,000 as EMD with resolution plan in Escrow account.

b. Rs. 25,00,000 upfront payment with resolution plan within 30 days of approval of COC as performance guarantee in form of FDR for the said plan.

c. c. Rs. 7,55,00,000 upfront payment within 90 days of order from Hon'ble NCLT (including the fees of the Resolution Professional and CIRP cost).

d. Rs. 25,00,000 to be paid within 90 days of approval of Hon'ble NCLT of the resolution plan for release of Personal Guarantees and Corporate Guarantees.

TREATMENT OF OPERATIONAL CREDITORS:

Operational Creditors (Unrelated Parties including Statutory Authorities)

Admitted Amount

Total payment within 30 days

Commercial Tax including any other department claim

Rs.10,44,83,597

Rs.7,00,000

0.66%

GIDC (House tax & Lease rentals)

NIL

Rs.10,50,000

0.00%

Electricity Dues

NIL

Rs. 16,00,000

0.00%

Other Duties and Taxes and Licences regularization

NIL

Rs. 5,00,000

0.00%

Swastik Coal Corporation Private

Limited

Rs.4,17,00,000

Rs.1,50,000

0.35%

TOTAL

Rs.40,00,000

TREATMENT OF EQUITY SHAREHOLDERS:

The Resolution Applicant proposes no changes in the Equity Shareholding of the Corporate Debtor.

s) Following are the details of the Resolution Applicant:

Brief Profile:

Promoter is Mrs. Girija Agarwal of the company which is registered as Micro Small and Medium Enterprises. The Director has hands-on skills and experience to operate the said plant at the present operating levels.

Sector expertise and strength to Turnaround Sick Companies

The Key reason to turn the unit into a Sick Company was unviability of the operation due to increase in operating cost of the Company which involve transportation of RM from outside state. The burden to pay up incremental finance costs without attaining the optimal operational capacity further deteriorated the Company’s condition.

Strength to turnaround the Company:

• Promoter Experience

• Intensified Sponge Iron Demand

• Change in Price scenario. Increase in Steel prices.

• Better government policies for Steel sector

• Expected change in regulatory framework

• Investment of addition working capital at low interest rates

• Reduced financial burden

• Incremental synergy from ancillary production unit

Financial Tie Up

The revised Resolution Plan proposes financial consideration as upfront payment in place of staggered payment over five year as proposed in previous plan. The RA has arranged the proposed resolution consideration from family and friends with an option to provide equity share against the unsecured loan, again reducing the interest burden.

t) Hence, the Applicant prays as follows:

i. To exclude the period of 183 days from the CIRP period owing to the Lockdown declared by the Government of India, State Government of Maharashtra, the Suo moto order passed by the Hon’ble NCLAT dated 30.03.2020 and the notification issued by the IBBI dated 29.03.2020.

ii. Therefore, to grant an additional period of 183 or such number of days including the Lockdown period continued to be imposed in the State of Maharashtra, to the CIRP period on account of it being excluded from the CIRP period so far.

iii. To allow the Applicant to withdraw the Liquidation Application being IA No. 241 of 2021 filed under section 33 on 09.10.2020 before this Tribunal.

iv. Pass an order ratifying the 8th meeting of the CoC held on 26.02.2021 and the resolution passed therein; and

v. Pass an order and approve the Resolution Plan proposed by the Resolution Applicant which has is been approved by the CoC and which shall be binding on the Corporate Debtor and its employees, members, including the Central Government, any State Government or any local authority.

vi. Pass any further or other order which this Tribunal deems fit and appropriate in the interest of Justice.

The Applicant has filed its Additional Affidavit as submits as under:

a) during the pendency of the present Resolution Plan before this Hon’ble Tribunal, the Hon’ble Apex Court in the matter of Sales Tax Officer v/s. Rainbow Papers Ltd. (CA 1661-2020) (hereinafter referred to as ‘Rainbow Papers’) decided the issue with respect to priority of charge and payout to the Sales Tax Department of Gujarat. It is in these circumstances the present Affidavit is filed to place on record that there is no impact of the said judgment in the present case and the values assigned in the resolution plan will not undergo any change as far as the present case is concerned.

b) As far as the judgment is concerned, it will not have any retrospective effect on the matters which are already sanctioned. However, without prejudice to the same, there is no impact in the present case for the reasons set out herein below:

i. In the present case, the Commercial Tax Department through the Commissioner of Commercial Tax had filed its claim vide a letter dated May 5, 2020.

ii. In the said letter, the claim is made in respect of following dues:

a) VAT dues;

b) CST dues; and

c) Entry Tax dues.

iii. As far as VAT dues are concerned, the claim is for Rs.5.91 crores along with interest penalty aggregating to Rs.7.55 crores.

iv. As far as CST dues is concerned, the claim is for Rs.1.61 crores along with interest penalty aggregating to Rs.1.83 crores.

v. As far as Entry Tax dues is concerned, the claim is for Rs.73.24 lakhs along with interest penalty aggregating to Rs.1.04 crores.

vi. As per the letter issued by the concerned Commissioner, these dues are to be recovered as per the provisions of:

a) Goa Value Added Act, 2005

b) Central Sales Tax Act, 1956

c) Goa Tax on Entry of Goods Act, 2000.

vii. The Hon'ble Apex Court in the case of Rainbow Papers (supra) was taking into consideration Section 48 of Gujarat Value Added Tax Act, 2003 (hereinafter referred to as “GVAT Act”). In the case of Rainbow Papers, the Hon’ble Apex Court has held that Section 48 of GVAT Act creates a priority first charge on the assets of the dealer and accordingly the department will have to be considered as a secured creditor. Therefore, the department will be entitled to the liquidation value treating it as a secured creditor and not as an operational creditor.

viii. In order to consider this, Section 48 of the Gujarat Value Added Tax Act is reproduced herein below first:

“48. Tax to be first charge on property. — Notwithstanding anything to the contrary contained in any law for the time being in force, any amount payable by a dealer or any other person on account of tax, interest or penalty for which he is liable to pay to the Government shall be a first charge on the property of such dealer, or as the case maybe, such person.”

ix. Section 66 of the Goa Value Added Tax Act:

“66. (1)] Every dealer, who is liable to pay tax shall send a declaration in such form, within such period and to such authority as may be prescribed, stating therein the particulars of the Bank accounts operated by him in connection with his business and shall within the period prescribed, intimate to the authority the changes in the particulars in the declaration.

(2) If the dealer fails to intimate to the authority the changes in the particulars in the declaration referred to sub-section (1), the Commissioner may, after giving an opportunity of being heard to such dealer, by order in writing, impose a penalty of a sum not exceeding rupees ten thousand.”

This provision is distinct from Section 48 of GVAT Act. GVAT Act creates a priority, similarly this Act also creates a priority. However, under the Goa Act, this priority is subject to provisions under the Central Act. In such a case, the provisions of any other Central Act will prevail. The Central Act, being Insolvency and Bankruptcy Code,2016, creates priority in favor of secured creditors and workers. The dues of Goa Value Added Tax will be subservient to the secured creditors and workers. Therefore, the treatment given in the present case to the Value Added Tax demand is concerned is appropriate and in accordance with law.

x. Even in case of liquidation, the VAT dues will be subservient to the dues of secured creditors and workers as the section itself says that it is subject to provisions of Central Act. Accordingly, the plan is in compliance and in accordance with law.

xi. The next provision which falls for consideration is of Central Sales Tax Act, Section 17(3), in fact the provision in this act provides that the other priority in case of liquidation are the other creditors having priority to be paid first. There is no other provision which the Deponent came across which creates priority for Central sales tax dues. The relevant part of Section 17(3) is reproduced herein below:

“17. Company in liquidation. — ……………

(3) The liquidator shall not part with any of the assets of the company or the properties in his hands until he has been notified by the appropriate authority under sub-section (2) and on being so notified, shall set aside an amount equal to the amount notified and, until he so sets aside such amount, shall not part with any of the assets of the company or the properties in his hands:

Provided that nothing contained in this sub-section shall debar the liquidator from parting with such assets or properties in compliance with any order of a court or for the purpose of the payment of the tax payable by the company under this Act or for making any payment to secured creditors whose debts are entitled under law to priority of payment over debts due to Government on the date of liquidation or for meeting such costs and expenses of the winding up of the company as are in the opinion of the appropriate authority reasonable.”

xii. In View of the above, there is no priority created for Central Sales Tax Act like Gujarat Act and therefore the treatment given to the CST dues is in accordance with law and the plan is in conformity with law.

xiii. The third claim is of Entry Tax. This is governed as stated hereinabove by Goa Tax on Entry Goods Act, 2000. The provision for priority in the said Act is Section 19(2) (i). The same is reproduced herein below for reference:

“19. Payment and recovery of tax. — ….

(2) If default is made in making payment in accordance with sub-section (1), — (i) the whole of the amount outstanding on the date of default shall become immediately due and shall be a charge on the property of the person or persons liable to pay tax under this Act; …”

xiv. It is submitted that though a charge is created under 19(2)(i) but no first charge is created. Therefore, even this claim will not stand, and the plan is in conformity and the payment allocated is in accordance with the judgment of Hon'ble Supreme Court.

xv. The judgment in the case of Rainbow Papers will not be applicable to the present facts and circumstances as the provisions under the three Acts which relates to this Corporate Debtor do not have any provision which is pari materia to Section 48 of the Gujarat Act and therefore there is no such priority which is created.

The Applicant submitted that the Compliance Certificate in Form - H under Regulation 39(4) of the Regulations showing the compliances of the Plan as mandatorily required under the Code and Regulations and that the Plan had been approved by the CoC which is produced as hereunder:

FORM H

COMPLIANCE CERTIFICATE

(Under Regulation 39(4) of the Insolvency and Bankruptcy Board of India (Insolvency Resolution Process for Corporate Persons) Regulations, 2016

I, Mr. Raj Kumar Dad, an insolvency professional enrolled with Indian Institute of Insolvency Professionals of ICAI and registered with the Board with registration number IBBI/IPA-001/IP-P00537/2017-2018/10962, am the resolution professional for the corporate insolvency resolution process (CIRP) of M/s Srithik Ispat Private Limited.

The details of the CIRP are as under:

Sr.

No.

Particulars

Description

Name of the CD

M/s Srithik Ispat Private

Limited.

Date of Initiation of CIRP

30/09/2019

Date of Appointment of IRP

2/10/2019

Date of Publication of Public Announcement

5/10/2019

Date of Constitution of CoC

18/10/2019

Date of First Meeting of CoC

24/10/2019

Date of Appointment of RP

24/10/2019

Date of Appointment of Registered Valuers

18/11/2019

Date of Issue of Invitation for EoI

16/12/2019

Date of Final List of Eligible Prospective Resolution Applicants

12/02/2020

Date of Invitation of Resolution Plan

8/02/2020

Last Date of Submission of Resolution Plan

9/03/2020

Date of Approval of Resolution Plan by CoC

6/03/2021

Date of Filing of Resolution Plan with Adjudicating Authority

19/03/2021

Date of Expiry of 180 days of CIRP

28/03/2020

Date of Order extending the period of CIRP

Due to COVID-19, lockdown was imposed on 25th March, 2020 by Government of India and subsequent to that IBBI issued instructions that period of lockdown imposed by the Central Government in the wake of COVID-19 outbreak shall not be counted for the purposes of the time-line for any activity that could not be completed due to such lockdown, in relation to a corporate insolvency resolution process.”

Accordingly, the period of Lockdown shall be excluded from the total period of

CIRP.

Date of Expiry of Extended Period of CIRP

May 01,2021

Fair Value

Rs 11,62,29,995

Liquidation value

Rs 8,03,01,371

Number of Meetings of CoC held

Assuming Exclusion of period of Covid 19 will be sought from NCLT from March 25, 2020 till October 30,2021, thus the expiry of extended period of CIRP will be subject to NCLT approval

I have examined the Resolution Plan received from Resolution Applicant Mrs.Girija Agarwal and approved by Committee of Creditors (CoC) of M/s Srithik Ispat Private Limited under Corporate Insolvency Resolution Process.

I hereby certify that-

(i) the said Resolution Plan complies with all the provisions of the Insolvency and Bankruptcy Code 2016 (Code), the Insolvency and Bankruptcy Board of India (Insolvency Resolution Process for Corporate Persons) Regulations, 2016 (CIRP Regulations) and does not contravene any of the provisions of the law for the time being in force.

(ii) the Resolution Applicant Mrs. Girija Agarwal has submitted an affidavit pursuant to section 30(1) of the Code confirming its eligibility under section 29A of the Code to submit resolution plan. The contents of the said affidavit are in order.

(iii) the said Resolution Plan has been approved by the CoC in accordance with the provisions of the Code and the CIRP Regulations made thereunder. The Resolution Plan has been approved by 100% of voting share of financial creditors after considering its feasibility and viability and other requirements specified by the CIRP Regulations.

(iv) the agenda was proposed to approve or reject the resolution plan tabled in the meeting of the CoC on February 26, 2021 where all the members of the CoC were present. I sought vote of members of the CoC by electronic voting system which was kept open from March 01,2021 and was concluded on March 06,2021 wherein the Resolution Plan was approved with 100% voting.

The list of financial creditors of the CD M/s Srithik Ispat Private Limited under Corporate Insolvency Resolution Process being members of the CoC and distribution of voting share among them is as under:

Sr. No

Name of Creditor

Votin g Share (%)

Voting for Resolution Plan

(Voted for / Dissented /Abstained)

For

Against

Abstain

CFM Assets Reconstruction Private Limited

100%

Total

100.00

0.00%

00.00%

The Resolution Plan includes a statement under regulation 38(1A) of the CIRP Regulations as to how it has dealt with the interests of all stakeholders in compliance with the Code and regulations made thereunder.

Yes, the resolution plan provides a statement declaring that it has dealt with the interests of all stakeholders

The amounts provided for the stakeholders under the Resolution Plan is as under:

(Amount in Rs.)

Sr.

No.

Category of Stakeholder

Sub-Category of Stakeholder

Amount Claimed

Amount Admitted

Amount Provided under the Plan#

Amount Provided to the Amount Claimed

(%)

(1)

(2)

(3)

(4)

(5)

(6)

(7)

Secured Financial Creditors

(a) Creditors not having a right to vote under sub- section (2) of

section 21

1,29,90,874

NIL

0.00%

(b) Other than

(a) above:

25.00%

(i) who did not vote in favor of the resolution Plan

NIL

(ii) who voted in favour of the resolution plan

32,63,64,000

8,20,00,000

Total (a) + (b) 33,93,54,874

33,93,54,874

8,20,00,000

24.16%

Unsecured Financial Creditors

(a) Creditors not having a right to vote under sub- section (2) of section 21

Not Applicable

(b) Other than

(a) above:

(i) who did not vote in favor of the resolution Plan

(ii) who voted in favor of the

resolution plan

Total[(a) +

(b)]

NIL

Operational Creditors

(a) Related Party of Corporate

Debtor

NIL

(b) Other than

(a) above: (i)Government

(ii) Workmen (iii)

Employees

(iv) Other than above

10,44,83,597

NIL NIL

4,17,00,000

10,44,83,597

NIL NIL

4,17,00,000

7,00,000

NIL NIL 1,50,000

0.66%

0.35%

Total[(a) +

(b)]

14,61,83,597

8,50,000

0.581%

Other debts and dues

GIDC

Electricity Dues and Cost of License regularization

NIL

(Expected Compliance cost to re- start the

operations)

NIL

(Expected Compliance cost to re- start the

operations)

31,50,000

0.00%

Amount attributed towards working Capital and Maintenance

e Capex

NIL

10,00,000

0.00%

Grand Total

48,55,38,471

8,70,00,000

17.92

*If there are sub-categories in a category, please add rows for each sub-category.

The interests of existing shareholders have been altered by the Resolution plan as under:

Sl. No