ALL EYES ON INCOME TAX AUTHORITIES TO UNRAVEL NEXUS BETWEEN NAND KISHORE CHATURVEDI AND ASHOK MITTAL

 Bharat Jeetega, Corruption Meetaga!

PUBLIC INVESTIGATION

EXPOSE ON INDIA'S MAJOR HAWALA RACKET 

Key players: Nand Kishore Chaturvedi and Ashok Mittal (Note: All facts and documents are public and submitted in court. The link of key document is here: https://www.scribd.com/document/690485435/Ia-No-386-of-2023-Volume-i-to-Volume-IV-in-Cp-No-47-of-2010-1?secret_password=H1wu4g3dAlSaAWDFi1Sx

 (The purpose of this article is to create public awareness and not target any individual.)

ALL EYES ON INCOME TAX AUTHORITIES TO UNRAVEL NEXUS BETWEEN NAND KISHORE CHATURVEDI AND ASHOK MITTAL

By Ashok Tandon

Income Tax authorities are probing the role of India's most wanted hawala dealer, #NandKishoreChaturvedi, who has recently received a trove of information on his two-decade-old financial activities, his close links with businessman #AshokMittal, and their role in grabbing Hotel Plaza at Ashoka Road, Delhi. https://economictimes.indiatimes.com/news/india/i-t-dept-raids-hotel-royal-plazas-chairman-for-stashing-rs-40-crore-abroad/articleshow/93074759.cms

Now every eye is on the income tax authorities to see what kind of action is being taken to book those who have been playing with the country's financial system. https://www.outlookindia.com/business-spotlight/delhi-high-court-upholds-loc-black-money-launderer-ashok-mittal-of-hotel-royal-plaza-by-abhinav-sharma-news-334756

EXTRACTS FROM IMPORTANT DOCUMENTS SENT TO IT AUTHORITIES: 

The daughter of RP Mittal, Jyoti Kesri, has written to the Income Tax authorities to demand that the accused be charged under the Prohibition of Benami Property Transactions Act, 1988, read with the Benami Transactions (Prohibition) Amendment Act, 2016. She has given proof of illegal financial transactions that happened in Hotel Plaza through a Malaysian company called Hillcrest Relaty. https://www.indiatoday.in/india/story/income-tax-dept-raids-hawala-operator-nandkishore-chaturvedi-entities-several-states-2390183-2023-06-08

Here are the relevant extracts: That the Complainants shall set out below in Graphic Form, a Broad Overview of the flow of the Undisclosed Income / Black Money of Mr. Ashok Mittal, from India to Swiss bank Accounts of his son Mr. Ashok Mittal ,and therefore its return to India to hold “Benami Property” of Rs. 28,29,29,000/- camouflaged as a Foreign Investment of a Company called Hillcrest Realty SDN. BHD., Malaysia to purchase “Benami Property” of 28,29,290 Nos. (23,65,000 + 4,64,290) 8.5% Preference Shares of Rs.100/- each aggregating to a value of Rs. 28,29,29,000/- in 2003 (while present market value could be around Rs. 450/- Crore)vide Share Certificate No. 101 dated 05.05.2003 for 23,65,000 Nos. Preference Shares of Rs. 100 each of value of Rs.23,65,00,000/- and Share Certificate No.102 dated 19.07.2003 for 4,64,290 Nos. Preference Shares of Rs. 100 eachof value of Rs.4,64,29,000/-, in the Indian Company namely Hotel Queen Road Private Ltd., 19 Ashok Road, New Delhi-110001.The said “Benami Property” is an outcome of a “Benami Transaction” of Mr. Ashok Mittal and it belongs to Mr. Ashok Mittal and is held in the Benami name of HillcrestRealty SON BHD, Malaysia,and hence the said “Benami Property” is liable to be attached / acquired / confiscated. 3. That, for the sake of easier comprehension, the various PHASES of First transferring the Undisclosed Income / Black Money of Mr. Ashok Mittal from India to Citi Bank Account of his son Mr. Vikram Mittal in Switzerland, and thereafter to bring back the said Undisclosed Income / Black Money of Mr. Ashok Mittal to hold the aforesaid “Benami Transaction/Benami Property” of 28,29,290 Nos. (23,65,000 + 4,64, 290) of 8.5% Redeemable Preference Share of Rs.100/- each of the Indian Company Hotel Queen Road Pvt. Ltd. with aggregating value of Rs.28,29,29,000/- (having present market value of Approx. Rs.450 Crores) vide Share Certificate No. 101 dated 05.05.2003 for 23,65,000 Nos. Preference Shares of Rs. 100 each of value of Rs.23,65,00,000/- and Share Certificate No.102 dated 19.07.2003 for 4,64,290 Nos. Preference Shares of Rs. 100 each, of value of Rs.4,64,29,000/-in the name of fictitious Foreign Equity called HillcrestRealty SDN. BHD., Malaysia as follows: 

PHASE 1 That Mr. Ashok Mittal carried on all his businesses dishonestly, in complete disregard of the laws, tax regulations and interests of other stakeholders. Like in his other businesses, he has indulged in these practices in the business of Hotel Queen Road Pvt. Ltd ever since he was appointed as a director on 08.10.2002. As reported in the News Article dated 23.07.2022, the Income Tax officers raided and searched 18 premises of Ashok Mittal across Delhi, Mumbai and Daman. The searches included the locations of the business of Royal Plaza Hotel owned by Hotel Queen Road Pvt. Ltd., Lights Trading and the real estate business of Ashok Mittal. The Central Board of Direct Taxes disclosed the seizure of a large amount of incriminating evidence in the form of hard copy documents and digital data. It was discovered that a large stash of wealth was parked abroad, investments of unaccounted wealth held in Swiss bank accounts were routed back to India through a web of Malaysian companies, neither existence nor profits of the foreign businesses were disclosed by Ashok Mittal. Furthermore, CBDT found that Ashok Mittal’s businesses were involved in out-of-books cash sales in its India operations, unaccounted cash sales to the extent of 50% to 70% of its total sales, undisclosed excess stocks of Rs.30 Crores. In Ashok Mittal’s hospitality business, unaccounted cash sales were detected specifically in the banquet division.

PHASE 2 Shell entities were set up by Mr, Ashok Mittal in Tax Heaven Foreign Country around the year 2003, in the form of Malaysian Companies named Cardiff Limited Malaysia and Hillcrest Reality SDN BHD. Malaysia for the purpose of routing the said Undisclosed Income/Black Money through them, wheeling the tainted monies via his son Mr. Vikram Mittal’s offshore Swiss bank accounts into the Indian Company M/s Hotel Queen Road Pvt. Ltd. These shell entities were set up by Mr. Ashok Mittal with the assistance of Portcullis group and Ben Locknat Daby Seesaram, along with Indian advisors Chartered Accountants Nand Kishore Chaturvedi and Chaturvedi Sohan Lal. 

 PHASE 3 Following transfers were made by Mr. Ashok Mittal’s son Mr. Vikram Mittal Bank Account to Cardiff Limited, Malaysia and his name was entered in the books of Cardiff Ltd. as unsecured creditor: S.N. Date Amount(in USD) Source Amount In Rs. 1. 01.04.2003 $ 2501000 Vikram Mittal’s Bank Account in Citibank Switzerland 11.75 Crore 2. 22.04.2003 $ 2501000 Vikram Mittal’s Bank Account in Citibank Switzerland 11.75 Crore 3. 26.06.2003 $ 999995 Vikram Mittal does not disclose source. 4.79 Crore TOTAL $6,00,1995 28.29 Crore The above transfers were disclosed in the letters issued by Mr. Vikram Mittal himself to his collaborators, after making the transfers. A copy of the letter dated 24.10.2003 issued by Vikram Mittal to Portcullis TrustNet (Labuan) Limited, wherein he confirmed the above three payments. A copy of the letter dated 16.04.2007 issued by Vikram Mittal to Cardiff Limited c/o Portcullis TrustNet (Singapore) Pte Ltd. confirming transfers at Serial No.1 and Serial No.2 of the above table, made from his account in Citibank Switzerland and instructing that his name in the books as unsecured creditor in respect of the transferred funds be altered to the name Bamberg Management Inc. A similar letter of same date i.e. 16.04.2007 issued by Vikram to Cardiff Limited c/o Portcullis TrustNet (Singapore) Pte Ltd. confirming the transfer shown at Serial No.3 of the above table, for which he says he has no documentary evidence as to source and making similar request to alter his name in the books to the name of Bamberg Management Inc., and disclosures be made accordingly to third parties. On the same date i.e. 16.04.2007, a second set of letters is issued by Vikram Mittal to the same recipient Cardiff Limited c/o Portcullis TrustNet (Singapore) Pte Ltd., one in respect of transfers shown at Serial No.1 and 2 of the above table and the other in respect of transfer at Serial No.3 of the above table, the purpose of these letters being to establish the beneficial ownership and control of Ashok Mittal and Vikram Mittal in respect of the debt and to forbid disclosure of the same to third parties. A copy of the said letter dated 16.04.2007 in respect of the transactions shown at Serial No.1 and 2 of the above table and the other letter of the same date 16.04.2007 in respect of the transaction shown at Serial No.3 of the above table. In the context of Vikram Mittal’s failure to disclose the source of the transfer shown at Serial No.3 of the above table, Vikram Mittal issued an indemnity letter dated 26.12.2008 to Cardiff Limited c/o Portcullis TrustNet (Singapore) Pte Ltd. Mr. Ashok Mittal also signed the said letter dated 26.12.2008 and became a Joint Indemnifier alongwith Mr. Vikram Mittal.

PHASE 4 Having received funds from Vikram Mittal as detailed in the preceding paragraph, Cardiff Limited immediately transferred a matching amount to Hillcrest Reality SDN BHD, Malaysia, as summarised below. S.N. Date Amount Source Amount in Rs. 1. 03.04.2003* $ 2500500 Cardiff Ltd. Rs. 11.75 Crores 2. 21.04.2003* $ 2500500 Cardiff Ltd. Rs. 11.75 Crores 3. 23.06.2003* $ 1000000 Cardiff Ltd. Rs. 4.79 crore There is a copy of the transfer memo from April 3, 2003, to the bank for the transfer shown at Serial No.1 in the table above, a copy of the transfer memo from April 21, 2003, for the transfer shown at Serial No.2 in the table above, and a copy of the transfer memo from June 23, 2003, for the transfer shown at Serial No.3 in the table above. Portcullis (Singapore) Pte Ltd. chased the bank to urgently carry out the transfers instructed in the said transfer memos. The fax from Portcullis (Singapore) Pte Ltd on April 3, 2003, asking for an urgent transfer of funds. It is related to the transfer at Serial No.1 of the above table, and the fax from April 21, 2003, is related to the transfer at Serial No.2 of the above table. Portcullis, Malaysia, also reported to Cardiff about the chasers issued to the bank. A copy of the fax dated 04.04.2003 and 22.04.2003 issued by Portcullis to Cardiff Limited, forwarding a copy of the chaser that it had issued to the bank. PHASE 5 Having received funds from Cardiff Limited, Malaysia as detailed in the preceding para, Hillcrest Reality SDN BHD., Malaysia immediately transferred a matching amount to M/s Hotel Queen Road Pvt. Ltd. as summarized in the table below: S.N. Date Amount Source Amount in Rs. 1. 11.04.2003* $ 2500000 Hillcres t Reality SDN BHD. Rs.11.75 Crores 2. 24.04.2013* $ 2500000 Hillcrest Reality SDN BHD. Rs.11.75 Crores 3. 24.06.2003* $ 1000000 Hillcrest Reality SDN BHD. Rs.4.79 Crores Against these transfers, 28,29,290 Nos, 8.5% Redeemable Preference Shares of Rs. 100 each aggregating to value of Rs.28,29,29,000/- were issued in the name of Hillcrest Reality SDN BHD, controlled at the backend by Ashok Mittal, as will become clear in subsequent paras of this context. Copies of Transfer Memos dated 11.04.2003, 11.04.2003, 24.03.2003 and 24.06.2003 for transfer of funds from M/s Hillcrest Reality SDN BHD to M/s Hotel Queen Road Pvt. Ltd. vi. PHASE 6 Having consummated the transfer of the proceeds of crime in April/ June 2003, Ashok Mittal moved swiftly to consolidate his control and to cover his tracks. The steps taken by him included giving instructions to their shell entities and puppets to alter the books of account to remove their names and to identify their beneficial interest with a direction to keep this confidential. Furthermore, many of the shell entities, agents and puppets controlled by Ashok Mittal and involved in the illegal transfer of funds sought to conceal themselves by changing their names and later by dissolving themselves, so that as of today, they cannot be identified by the same name and form in which they existed earlier. A Copy of the Documents showing the current status of portcullis Trust (Labusan) Ltd. having been dissolved. That by the efforts of journalists worldwide to expose the truth including efforts by exposures contained in the database, with investigative journalists like International Consortium of Investigative Journalists (hereinafter called “ICIJ”). Some of the developments which are to the knowledge of the Complainants are summarized below: (i) After the bulk of the monies had been transferred in April 2003, Ashok Mittal who was earlier acting through fronting entities, installed himself as Director and got the Complainant Mr. R.P. Mittal to sign papers showing him as the second Director of Cardiff Limited; (ii) As mentioned earlier, Vikram Mittal issued letters on 16.04.2007 first to ensure that his name was removed from the books of account and disclosures to third party should not reveal his name and second to ensure that he was recorded as the beneficial owner in respect of the unsecured debt in relation to the transfers made by him and that his father Ashok Mittal would have the exclusive authority to deal with the unsecured debt and no other person has any beneficial interest in this; (iii) Portcullis Trust (Labuan) Limited, involved in holding the shareholding of Ashok Mittal’s shell entity Cardiff Limited, changed its name to Majestic Limited and subsequently dissolved itself. Cardiff Limited transferred its shareholding to Bamberg Management Inc. And then dissolved itself. Further details will be set out in subsequent paras while discussing the various actors involved in the criminal transaction. 5. That a summary of the flows of the Undisclosed Income/ Black Money of Mr. Ashok Mittal from Vikram Mittal into M/s Hotel Queen Road Pvt. Ltd. referable to Phase 1 to 6 as described in the preceding paragraph are summarized below in a tabular format, and clearly show the flow of funds with matching dates and amounts: Tranche Date Amount in USD Amount in Rs. From To FIRST 01.04.2003 $ 2501000 11.75 Crores Vikram Mittal Swiss Account Cardiff Ltd. 03.04.2003* $ 2500500 11.75 Crores Cardiff Ltd. Hillcrest 11.04.2003* $ 2500000 11.75 Crores Hillcrest Realty SDN. BHD. Hotel Queen Road Pvt. Ltd. SECOND 22.04.2003 $ 2501000 11.75 Crores Vikram Mittal Swiss Account Cardiff Ltd. 21.04.2003* $ 2500500 11.75 Crores Cardiff Ltd. Hillcrest Realty SDN. BHD. 24.04.2013* $ 2500000 11.75 Crores Hillcrest Realty SDN. BHD. Hotel Queen Road Pvt. Ltd. THIRD 26.06.2003 $ 999995 4.79 Crores Vikram Mittal Unknown source Cardiff Ltd. 23.06.2003* $ 1000000 4.79 Crores Cardiff Ltd. Hillcrest 24.06.2003* $ 1000000 4.29 Crores Hillcrest  Realty SDN. BHD. Hotel Queen Road Pvt. Ltd. 6. Briefly the details of the shell Entities created by Mr. Ashok Mittal to bring back his own Undisclosed Income / Black Money into India to hold “Benami Transaction/ Benami Property” 8.5% Redeemable Preference Shares of 28,29,290 Nos. (23,65,000 + 4,64, 290) of Rs. 100/- each vide Share Certificate No. 101 dated 05.05.2003 for 23,65,000 Nos. Preference Shares of Rs. 100 each and Share Certificate No.102 dated 19.07.2003 for 4,64,290 Nos. Preference Shares of Rs. 100 each issued by an Indian Company named Hotel Queen Road Private Limited, 19, Ashoka Road, New Delhi-110001 in the name of M/s Hillcrest Realty SON BHD, Malaysia which is the “Benami Transaction”/“Benami Property” of Mr. Ashok Mittal resident of resident of Doctor Centre, 135, August Kranti Marg, Kemp’s Corner, Mumbai-36 (and also at 42, Ashoka Avenue ,Sainik Farms, M.B Road New Delhi – 62)are as under: CARDIFF LIMITED a) Cardiff Limited was a shell entity, incorporated as a registered Labuan Company on 26.02.2003, bearing Company No. LL03634, with its head office in Labuan Malaysia. The company was incorporated on 26.02.2003 with the assistance of the Portcullis group, with an authorized capital of US$ 12000 comprising 12000 shares of US$1 equal to Rs. 50/- in 2003 & Rs. 84/-INR in 2023 each but issued share capital of only 1 share of US$1. Portcullis TrustNet (Labuan) Ltd. was the 100% shareholder (i.e. holder of one share of US$ 1 equal to Rs.50/- in 2003 & Rs. 84/-INR in 2023 only) of Cardiff Limited. Furthermore, on the same day as its incorporation, a Service Agreement dated 26.02.2003 was executed between a Portcullis entity named Portcullis Trust (Labuan) Sdn. Bhd and Ashok Mittal pursuant to which Cardiff Limited was populated with puppet directors and secretary, who would act on the instructions of the Authorized Person Ben Locknat Daby Seesaram, the front man of Ashok Mittal. b) Cardiff Limited was incorporated under the Offshore Companies Act, 1990, a statute of Malaysia. As per the legal requirements of the said Malaysian law, an offshore company was required to have one resident director and one resident secretary. In accordance with Sections 87 and 93 of the said Act, a domestic Malaysian company wholly owned by a trust company could act as director and secretary. Taking advantage of this, two shady domestic Malaysian private companies wholly owned by a trust company of Portcullis group and named GurkerSdnBhd and SherperSdnBhd were installed as resident director and resident secretary respectively at the time of incorporation of Cardiff Limited on 26.02.2003. c) As will be detailed in the hereinafter on HillcrestRealty SDN BHD immediately after its incorporation, Cardiff Limited acquired 100% shareholding of HillcrestRealty SDN BHD in March 2003, another shell entity owned and controlled by Ashok Mittal at the backend. d) Shortly after incorporation of Cardiff Limited on 26.02.2003 and shortly after Cardiff Limited had acquired 100% shareholding (i.e. 2 shares of RM 1 each equal to Rs.23/- in 2003 & Rs.38/-INR in 2023) of HillcrestRealty SDN BHD in March 2003, Ashok Mittal’s proceeds of crime were routed through Cardiff Limited in April/ June 2003 from Vikram Mittal onward to its wholly owned subsidiary HillcrestRealty SDN BHD. The bulk of the proceeds were routed in April 2003, immediately after which Ashok Mittal was appointed as director of Cardiff Limited, understandably to further secure the beneficial ownership of Ashok Mittal of the monies routed through Cardiff Limited. Presumably, Ashok Mittal also wanted to be at the direct helm of affairs when the third tranche of funds sent by Vikram Mittal, from unknown source, was routed through Cardiff Limited. e) With the funds flowing from Vikram Mittal,through the Ashok Mittal controlled shell entities, first Cardiff Limited and then its wholly owned subsidiary HillcrestRealty SDN BHD. into Hotel Queen Road Pvt. Ltd., 28,292,290 (23,65,000 + 4,64,290), 8.5% Redeemable Preference Shares of Rs. 100 each were issued in the name of HillcrestRealty SDN BHD. in two lots of i.e.23,65,000 Nos. Preference Shares of Rs.100/- each aggregating to value of Rs.23,65,00,000/- on 05.05.2003 and thereafter 4,64,290 Nos. Preference Shares of Rs.100/- each aggregating to value of Rs.4,64,29,000 on 19.07.2003. f) The Complainants understand that, at some point of time after the illegal routing of proceeds of crime was completed in April to June 2003 and after Vikram Mittal had issued letters dated 16.04.2007 instructing Cardiff Limited to delete his name from the book of accounts substituting the name of Bamberg Management Inc instead, for the purpose of third party disclosures, but to confidentially hold the funds in the beneficial ownership of Vikram Mittal and Ashok Mittal, Cardiff Limited transferred its shareholding of HillcrestRealty SDN BHD. to Bamberg Management Inc. And dissolved itself. These steps appear to have been taken to conceal the criminal tracks of Ashok Mittal and his son Vikram Mittal. g) It is respectfully clarified that though the Complainants Mr. Ram Parshotam Mittal name figures in the Service Agreement dated 26.02.2003 as a Principal (along with Ashok Mittal) and later his name figures as a director of Cardiff Limited (along with Ashok Mittal) with effect from 26.02.2003, the Complainants was neither directly involved in nor aware of the true criminal nature of this entity. Ashok Mittal induced the Mr. Ram Parshotam Mittal to sign papers after convincing him that these were arrangements for procuring foreign investments into M/s Hotel Queen Road Pvt.Ltd. and Mr. Ram Parshotam Mittal trusting his younger brother had no reason to believe that there was any criminal intention involved. The fact that the Complainant Mr. Ram Parshotam Mittal was involved only on papers is also borne out by subsequent developments. HILLCREST REALTY SDN BHD a) HillcrestRealty SDN BHD. was incorporated as another shell entity, covertly owned, and controlled by Ashok Mittal. As per pre-planning, it was incorporated just a couple of months prior tothe incorporation of the other shell company Cardiff Limited already discussed above, but by February/March 2003 it had become the 100% subsidiary of Cardiff Limited just before the routing of the proceeds of crime starting in April 2003. Its ultimate purpose was to act as the holder of 28,292,290, 8.5% Redeemable Preference Shares of Rs. 100 each, as a front of Ashok Mittal who owned and controlled it. Thus, after routing the proceeds of crime from Vikram Mittal to M/S Hotel Queen Road Pvt. Ltd., 28,292,290, 8.5% Redeemable Preference Shares of Rs. 100 each having INR value of Rs.28,29,29,000/- were issued in favour of HillcrestRealty SDN BHD. in two lots of i.e. 23,65,000 Nos. Preference Shares of Rs.100/- each aggregating to value of Rs.23,65,00,000/- on 05.05.2003 and thereafter 4,64,290 Nos. Preference Shares of Rs.100/- each aggregating to value of Rs.4,64,29,000 on 19.07.2003. More specific details about HillcrestRealty SDN BHD. are set out below. All these illegal transactions where completed back to back in a period of approx, 2 months b) HillcrestRealty SDN BHD. was originally incorporated on 22.11.2002 with the stated purpose of carrying on the business of Investment Company.Various Documents came to the knowledge of the Complainants reveal that HillcrestRealty SDN BHD. was incorporated with an authorized share capital of RM 100,000 comprising 100,000 shares of RM 1 each. However, the total issued capital of said company was only RM 2 (equal to approx. Rs.23/- in INR in 2003 and presently approx. Rs.38/- in INR in 2023) comprising only two issued shares, one share each being owned by two Malaysian residents named George Pathmanathan A/L Michael Gandhi Nathan and Francisca Wong Chi Hiong and they were also the initial directors of HillcrestRealty SDN BHD. Incidentally, George Pathmanathan A/L Michael Gandhi Nathan is also revealed in the ICIJ Offshore Links database as a director of Portcullis TrustNet (Labuan) Limited. Ben Locknat Daby Seesaram, the front man of Ashok Mittal (who was the Authorized Representative in respect of Cardiff Limited) was appointed as one of the directors of the HillcrestRealty SDN BHD on or around 20.02.2003. c) That the initial shareholders and directors were just temporary name lenders/ puppets of Ashok Mittal playing their pre-determined roles is evident from the fact that just around two months after the incorporation of HillcrestRealty SDN BHD., the two shares owned by them for the grand total of RM 2 (equal to approx. Rs.23/- in INR in 2003 and Rs.38/- in INR in 2023) were transferred by them to Cardiff Limited, immediately after the latter company was incorporated on 26.02.2003. A resolution dated 17.03.2003 of Cardiff Limited, issued by the sole director of Cardiff Limited viz. GurkerSdnBdh, resolving to purchase the entire shareholding of two shares of RM 2 equivalent INR Rs.23/- in 2003 and INR Rs.38/- in 2023 from the original shareholders namely George Pathmanathan A/L Michael Gandhi Nathan and Francisca Wong Chi Hiong.The foregoing resolution also authorized the George Pathmanathan A/L Michael Gandhi Nathan (selling shareholder and director of HillcrestRealty SDN BHD) to act as the representative of Cardiff Limited, in all General Meetings of Hillcrest Realty SDN BHD again showing the close nexus and preplanning between the parties. Simultaneously, on the same date as the Cardiff’s resolution, i.e. 17.03.2003, the selling shareholders George Pathmanathan A/L Michael Gandhi Nathan and Francisca Wong Chi Hiong who are also directors of HillcrestRealty SDN BHD. passed a resolution to sell their shares to Cardiff Limited. This resolution is signed by the three directors, including the two named above, the third director being Ben Locknat Daby Seesaram d) Immediately after HillcrestRealty SDN BHD. was acquired by Cardiff Limited as its wholly owned subsidiary in March 2003, the illegal transfer of proceeds of crime was carried out in April/June 2003, as already narrated earlier, enabling purchase of 28,292,290, 8.5% Redeemable Preference Shares of Rs. 100 each having aggregative INR value of Rs.28,29,29,000/- in the name of HillcrestRealty SDN BHD., owned and controlled at the backend by Ashok Mittal. As earlier mentioned under the preceding section relating to Cardiff Limited, at some point of time after the illegal routing of proceeds of crime was completed in April to June 2003 and after Vikram Mittal had issued letters dated 16.04.2007 instructing Cardiff Limited c/o Portcullis to delete his name from the book of accounts substituting the name of Bamberg Management Inc instead, for the purpose of third party disclosures, but to confidentially hold the funds in the beneficial ownership of Vikram Mittal and Ashok Mittal, Cardiff Limited transferred its shareholding of HillcrestRealty SDN BDH to Bamberg Management Inc. And dissolved itself. Thereafter to further conceal the criminal tracks, on 23.11.2022, Bamberg Management Inc transferred the entire shareholding comprising two shares of RM 1 each to a company named Aravali Trading LLC incorporated in Sharjah UAE. A copy of the Register of Members showing the transfer of entire shareholding of HillcrestRealty SDN BDH from Bamberg Management Inc. To Aravali Trading LLC. It is also worth highlighting that this transfer of 23.11.2022 took place just after the Income Tax Raid in July 2022. 7.

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