REGD. POST / ELETRONIC MODE

To,                                                                           Dt.: xxxxx

MR. xxxxxxxxxxxxx

Executive Director

M/s. xxxxxxxxxx Pvt. Ltd.

Unit xxxxxxxxxxx.

Emailxxxxxxxxxxxxxx

Sub:  Reply to your Letter / Notice dated xxxxxxxx issued by you to my client Anuradha Logistics Services.

Dear Sir,

In reference to your Letter-cum-Notice dated xxxxxxx addressed to my client M/s. xxxxxxxxxx Services. I have been instructed to give reply to the same as under :-

At the very out-set, I would like to inform you that your notice as based on wrong, false and incorrect and as such the contents of your notice are false, frivolous and baseless except wherever the same are specifically admitted by my aforesaid client. Had you known the ground situation prevailing you would yourself had understood the whole scenario and you must have thereon tried to persuade, anyways I wish to clarify and reply your notice in the following paragraphs.

The notice under reply is based on false and frivolous facts and as such the same is liable to be withdrawn by you out-rightly. Therefore by all these activities of you it is very much clear evident that you is giving false and unreliable information which don’t have any ground reality.

That my client has been a consistent and reliable partner, delivering high-quality logistics solutions across India. Your company has previously acknowledged dedication and commitment of my client to providing seamless services without any interruptions. However, my client have noted your recent concerns and will address each point systematically.

That my client have provided all services on pan India basis from the day one without any problems, it can be seen from previous month invoice of my client, you paid the same and your management never stop any payment not raise any debit note of my client, but past some months, when your company has changed and you have changed your custom broker and your transportation from then onwards you have problems with old bills and services of my client.

Response to the Letter/Notice On Merits:-

That you have raised objections to the miscellaneous charges of Rs.xxxxx/- stating that you are beyond the market rate and only accept Rs.xxxxx as a reasonable charge, based on your experience with other vendors. In response to the same that the charge of Rs. xxxxxx is consistent with amounts charged in prior invoices, which were approved by your former management, specifically by Mr. xxxxx. This precedent indicates an established understanding of the necessity and reasonableness of these charges. These charges were incurred due to delays in receiving necessary documentation for EPR (Extended Producer Responsibility) and LMPC (Legal Metrology Packaged Commodities) submissions. Despite multiple reminders, your company did not provide the required documents in a timely manner, necessitating additional efforts from the end of my client. The charge is not arbitrary but reflects the actual additional resources and interventions needed. The variability in charges is a common practice in the industry, dependent on the specific interventions required at customs ports. This has been communicated to your team multiple times and aligns with industry standards.

You further disputed the detention charges, arguing that the cargo should have been released within xx hours of paying customs duty on xxxxxxx, but instead, it was released on xxxxx. You alleged that this delay and the resultant detention charges are due to inaction on the part of my client. In response to the same firstly you have to see the timeline in details that BoE filed on xxxxxxx, Customs Duty Paid on xxxxxxx, KYC Submission done by you on xxxxxx (one day post customs duty payment), Initially, the shipping line raised an incorrect debit note for factory de-stuffing instead of port de-stuffing, necessitating a revision. A revised debit note issued on xxxxxx, correcting the previous errors and providing a 14-day free time extension. On xxxxx, my client awaited your response regarding the payment and container release. The next two days (xxxxx and xxxxx) included a Sunday and a public holiday (Parliament election in xxxx), further delaying the process. A WhatsApp conference call was organized on xxxxx, involving key stakeholders, where the debit note was recalled and the payment was released. The container was subsequently released on xxxxx. These timelines show that delays were significantly influenced by your internal processes, including late KYC submissions and erroneous debit notes, which were beyond control of my client.

You further disputed that booked 55 sqm for one container, but my client have charged for xx sqm. In response to the same that in records of my client, verified during a visit by your representative xxxx on xxxxx, confirm that your goods occupied 110 sqm across seven BoEs. Mr. xxxx acknowledged this discrepancy and agreed to it during his visit. This information, along with the standards for warehouse space calculation, was communicated to your management, and the charges applied are accurate and justified based on the actual space utilized.

You alleged that my client is harassing and blackmailing your Company by withholding services and making false commitments regarding payments. In response to the same that despite delayed payments and unsubstantiated debit notes from your side, my client has continued to provide services to avoid disruptions in your operations. This demonstrates commitment of my client to maintaining a professional relationship. Your company recent changes, including appointing a new custom broker and transportation provider, have coincided with the withholding of payments for services of my client. This pattern suggests a deliberate attempt to avoid settling valid invoices. Invoices of my client reflect previously negotiated rates, and my client have not charged for additional travel expenses, further illustrating our efforts to maintain fair billing practices. My client have consistently provided discounts in their invoices, which should be considered when evaluating charges of my client.

My client value their partnership with you and hope to resolve these issues amicably. However, if the payments are not settled, my client will have no choice but to pursue appropriate legal remedies to ensure the recovery of dues and protect interests of my client.

As such the ground / contents raised in your letter is false, unknown, shocking and frivolous. That the contents of your letter under reply is wrong and denied as stated.

As such my client are in shock and surprise that from where you has cooked up this fake/ false stories which don’t even have any ground reality. Therefore, my client has instructed me to take a strict legal action against you, if you don’t withdraw this notice and my client is not liable to pay any damages.

In light of the above, my client requests you to immediate release the pending advance payment against PI for the current shipment of my client and make payment of the full amount of Rs. xxxx0/- for the miscellaneous charges as previously agreed upon and substantiated by service records of my client. Further resolution of outstanding payments for the past three to four months to avoid further service disruptions. If you will not release same, my client will have no choice but to take legal action to protect his right / interests. Please note that our client is also entitled to claim compensation for any losses they may have suffered as a result of false and frivolous claim of you.

Please note that in case, you shall take any legal proceedings against my client, in that event, you shall be doing so at its costs, risks and consequences thereof. Any threatened action if you chooses to take; you shall be doing so at its costs, risks and consequences therefore.

This notice has not legal force and still you proposes to take any legal action against my client, in that event, you shall be doing so at its own costs, risks and consequences thereof which you may please advise you.

A copy of this notice has been kept in my office for further reference and action.

                             xxxxxxxxx

                                                              Advocate   

For xxxxxxxxx