Kamal Formsrocreply

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To

The Registrar of Companies,

No. 35, Elango Nagar,

Pondicherry – 605 011

Sir,

Sub. Submission of Reply to your letter dt. 12.05.2010

With reference to your above notice, we wish to submit the following:

1. Mr. Habibur Rahman was appointed as the Managing Director and Chairman

of the Company and Mrs. Athiya Shakir was re-designated as a Director with

effect from _______. However, inadvertently, the form 32 in respect of these

changes have not been filed with your goodself. Similarly, the designation

mentioned in the accounts is also inadvertent. However, the actual persons whohad to sign the report as per the reconstituted Board of Directors, as per Section

219(4) and Section 215 (1) & (2) of the Companies Act, 1956, have actually

signed the reports. The form 32 in respect of the above change have since been

filed vide SRN No. ___________ dt. _________ together with applicable

additional fees. As such, we request you to condone the technical lapse and treat

the accounts as being in compliance with Section 219(4) and Section 215 (1) &

(2) of the Companies Act, 1956.

2. The Balance Sheet of the company for the year 2009 has been filed vide SRN

No. _______ dt. ___________.

3. The Annual Return of the company for the year 2009 has been filed vide SRN

No. _______ dt. ___________.

4. The Name of the persons and the nature of relationship with the Directors are

as below:

Sl. Name Status Nature of

relationship with

Directors

1 Smt. Athiya Shakir Director Not applicable

2 Smt. Nazreen Jehangir Director Not applicable

3 Sri. Habibur Rehman Director Not applicable

4 Smt. Parveen FathimaShakir

Director Not applicable

5 Sri. Shakir Abdul Ali Not Applicable [Nature of

relationship to be

updated]

In the accounts, the above loans from parties in Sl. Nos. 1 to 4 have been

disclosed as Unsecured Loans from Directors. However, with respect to Party No.

5, the same should have been disclosed separately, which however, by

inadvertence has got included along with Loans from Directors.

As may be seen, all the above unsecured loans are either from Directors or relativeof Directors. All the above persons have given a declaration to the effect that these



loans were not extended from neither from borrowed funds or from deposits

accepted from others. As such, the above unsecured loans are not in the nature of

deposit in accordance with Section 58A of the Companies Act, 1956 read with

The Companies (Acceptance of Deposits) Rules, 1975, copies of which are

enclosed for your ready reference.

5. Copy of Form 32 enclosed

6. The party wise break-up of the amounts held as Share Application money is as

under:

Sl. Name of the Party Relationship with the

Company / Director

Amount (Rs.)

As may be seen, the above parties are either directors or relatives of directors. As

such, the above unsecured loans are not in the nature of deposit in accordance

with Section 58A of the Companies Act, 1956 read with The Companies

(Acceptance of Deposits) Rules, 1975.

The delay in allotment of shares is purely on account of administrative reasons.

The company has already taken necessary steps and has allotted the shares. We

are enclosing herewith Form 2 filed vide SRN No.___________dt.__________ in

respect of the above allotment.

It may not be out of place to mention here that the company already has the

necessary Authorised Share capital and as such there is no loss of revenue (in the

form of increase in fee for authorised share capital) on account of the delay.

7. The form 8 in respect of Loan availed from ICICI Bank Limited has not been

filed. The company is in the process of taking necessary steps for getting the delay

condoned from the Company Law Board and has filed an application in this

regard vide SRN No.____________ dt._______. On receipt of the approval, the

company will file the necessary forms.

8. The nature of property offered in respect of Secured Loan obtained from M/s.

ICICI Bank is as follows :

“_____________________”

The same has inadvertently not been indicated in the accounts. We request you to

kindly condone the lapse. We assure you that we will comply with this

requirement in our annual accounts for the year 2009-10.

9. Pending certain procedural formalities, we are yet to receive the document of

satisfaction of charge. On receipt, we shall arrange to file the Form 17 in this

regard.

10. We request you to kindly condone the misclassification. We shall ensure that

the same is classified appropriately in our annual accounts for the year 2009-10.





18. Inventories are valued at Cost or market value whichever is less. The cost

formula used is ______________________. Non-disclosure of the same is

unintentional. We shall ensure that the classification is appropriately disclosed in

our annual accounts for the year 2009-10.

19. The company recognises revenue in full compliance with AccountingStandard 9 – Revenue Recognition issued by the Institute of Chartered

Accountants of India. We shall ensure that that appropriate disclosures are made

in our annual accounts for the year 2009-10

20. The requirement to publish Earnings per Share (EPS) is not mandatory to the

company as per Accounting Standard 20 – Earnings per Share issued by ICAI. As

such, the same is not disclosed.

21. The break-up of deferred tax assets and deferred tax liabilities into major

components is disclosed in Schedule IV of the Accounts. The company, as may be

seen, has turned around and has made profits during the year. As such, the

directors are of the opinion, that the deferred tax assets recognised in respect of

the tax losses are recoverable. We shall ensure that that appropriate disclosures aremade in our annual accounts for the year 2009-10

22. We shall ensure that information relating to Quantiative and other details as

specified under Para 3(1)(a), 3(ii)(a), 4B,4C and 4D of Schedule VI, Part II of the

Companies Act, 1956 are appropriately disclosed in our annual accounts for the

year 2009-10. Non disclosure of the above is not involving any public interest or

is not bound to cause any injury to Public, in as much the company is a closely

held Private Limited Company. Hence, we request you to kindly take the same on

record and drop further proceedings in this regard.

23. The Company, as of date, does not have any employees qualifying to receive

gratuity. As such, no provision has been made. We shall ensure that the

accounting policy in respect of the above is duly disclosed in our annual accounts

for the year 2009-10.

As may be seen, most of the non-disclosures in the accounts do not have any

significant bearing on the status of accounts. Such non-disclosures do not affect

any public and will not cause any injury / injustice to any stake holder / public in

as much the company is a Private Limited Company with no interest of outsiders.

As such we request that the lapses, may be condoned.

Thanking You,

for KAMAL FOAMS PRIVATE LIMITED

Authorised Signatory.



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Kamal Formsrocreply