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This document is important and requires your immediate attention.

This Letter of Offer is being sent to you as existing shareholder(s) of

RAJATH FINANCE LIMITED

(THE TARGET COMPANY)

If you require any clarifications about the action to be taken, you may consult your stockbroker or your investment consultant or the Manager to the Offer. In case you have recently sold your shares in the Target Company, please hand over this Letter of Offer and the accompanying FORM OF ACCEPTANCE CUM ACKNOWLEDGEMENT, FORM OF WITHDRAWAL and Transfer Deed to the Member of the Stock Exchange through whom the sale was effected.

Sr No

Details

Details

1a

Name & Address of the Acquirer

UNICORN HOLDINGS PRIVATE LIMITED

907, Star Plaza, Phulchhab Chowk,

Rajkot – 360 001 Ph: (0281) 2447800-01

Fax: (0281) 2454271

1b

Name & Address of the Persons Acting in Concert (PACs)

a              Shri Chamanlal V Kamani,   

b              Shri Rashmi C Kamani,

c              Shri Deepak C Kamani,

         Common Address:

         House No. 81, Kyuna Road,

         Nairobi, Kenya

         Ph:   0025420 537592

         Fax: 0025420 553143

2

Name & Address of the Target  Company

RAJATH FINANCE LIMITED

208, Star Plaza, Phulchhab Chowk,

Rajkot – 360 001 Ph: (0281) 2447800-01

Fax: (0281) 2454271

3a

No. of shares proposed to be acquired through this Offer

8,00,000 Equity Shares of the face value of Rs. 10/- each

3b

Percentage to voting capital

20.00%

4a

Offer Price per Equity Share of Rs. 10/- each

Rs. 10/- per Equity Share plus interest @ 10% per annum with effect from 01-06-2003 till actual payment of consideration. Considering the date of payment of      31-05-2004, the Offer Price including the amount of interest would be Rs. 11.00 per share. In case of delay of payment beyond 31-05-2004, interest @ 10% per annum for a period from 01-06-2004 until the actual date of payment would also be paid over and above Rs. 11.00 per share.

4b

Mode of settlement

In cash

5

Other relevant information

a

This Offer is pursuant to the provisions of the Securities & Exchange Board of India (Substantial Acquisition of Shares and Takeovers) Regulations, 1997 and subsequent amendments thereto.

b

This Offer is not conditional as to any minimum level of acceptance.

c

This is not a competitive bid.

d

Statutory approvals required for completing the Offer – RBI approval in case of non-resident shareholders / OCBs. No other statutory approvals other than this is required.

e

Shareholders who have accepted the Offer by tendering the requisite documents, in terms of PA / Letter of Offer, can withdraw the same up to three working days prior to the date of closing of the Offer.

f

Any upward revision / withdrawal of the Offer would be informed by way of a PA in the newspapers where the original PA had appeared. The last date for such revision is 06-05-2004. Consideration at the same rate will be paid for all Equity Shares tendered anytime during the Offer period.

g

If there is a competitive bid –
  • the public offers under all the subsisting bids shall close on the same date
  • as the offer price can not be revised during seven working days prior to the closing date of the offers/bids, it would, therefore, be in the interest of shareholders to wait till the commencement of that period to know the final offer price of each bid and tender their acceptance accordingly.

h

A copy of this Letter of Offer (including the Form of Acceptance and Acknowledgement) is available on SEBI’s Website: www.sebi.gov.in

MANAGER TO THE OFFER

Mehta Integrated Finance Limited

003, Law Garden Apartments,

Scheme – I, Opp. Law Garden,

Ellis Bridge, Ahmedabad – 380 006

Telephone: (079) 26561000, 26565566

Fax: (079) 26562756

Email: mifl_in@yahoo.com

Contact Person: Mr Krupal Amin

REGISTRAR TO THE OFFER

Intime Spectrum Registry Limited

211, Sudarshan Complex, Near Mithakhali Under Bridge, Ahmedabad – 380 009

Tele-fax: 079-26465179

Email: ahmedabad@intimespectrum.com

Contact Person: Mr Hitesh Patel

The Schedule of activities is as under:

Activity

  Original -Day & Date

Revised -Day & Date

Date of PA

Wednesday, 29-10-2003

Wednesday, 29-10-2003

Specified Date

Tuesday, 11-11-2003

Tuesday, 11-11-2003

Last date for a Competitive Bid

Friday, 14-11-2003

Friday, 14-11-2003

Letter of Offer to be posted to the shareholders

Monday, 01-12-2003

Monday, 12-04-2004

Date of opening of the Offer

Friday, 12-12-2003

Friday, 16-04-2004

Last date for withdrawing acceptance from the Offer

Tuesday, 06-01-2004

Tuesday, 11-05-2004

Date of closing of the Offer

Saturday, 10-01-2004

Saturday, 15-05-2004

Last date for revising the offer price / Number of shares

Friday, 02-01-2004

Thursday, 06-05-2004

Date of communicating rejection/acceptance and payment of consideration for applications accepted

Friday, 30-01-2004

Monday, 31-05-2004

TABLE OF CONTENTS

Sr No

Subject

Page No.

1

Disclaimer Clause

3

2

Details of the Offer

4

3

Option under Regulation 21(3)

5

4

Background of Unicorn Holdings Private Limited

5

5

Background of PACs

9

6

Past action of Stock Exchanges, etc.

11

7

The specified date

12

8

Objects of the acquisition and future plans

12

9

Background of the Target Company

12

10

Offer Price & Financial Arrangements

16

11

Terms & Conditions of the Offer

17

12

Procedure for acceptance & settlement, other relevant information

18

13

Documents for inspection

20

14

Declaration by the Acquirer

21

15

Form of Acceptance cum Acknowledgement and Form of Withdrawal

Annexed

DEFINITIONS / ABBREVIATIONS:

1

Acquirer

Unicorn Holdings Private Limited, who is offering to acquire shares through this offer

2

The Target Company

Rajath Finance Limited whose Equity Shares are proposed to be acquired

3

Manager to the Offer

Mehta Integrated Finance Limited

4

Offer

Cash offer being made by the Acquirer to the shareholders of the Target The Target Company

5

Offer Document

this Letter of Offer

6

PA

Announcement of the offer dated 29-10-2003

7

PACs

Persons Acting in Concert viz. Shri Chamanlal V Kamani, Shri Rashmi C Kamani and Shri Deepak C Kamani

8

Deemed PAC

Troupe International Limited

9

RBI

Reserve Bank of India

10

SEBI

Securities & Exchange Board of India

11

SEBI (SAST) Regulations

Securities & Exchange Board of India (Substantial Acquisition of Shares and Takeovers) Regulations, 1997 and subsequent amendments thereto

12

Shares

Equity Shares

13

Specified Date

11-11-2003

14

Stock Exchanges

Each of The Stock Exchanges at Rajkot, Ahmedabad and Mumbai

1              DISCLAIMER CLAUSE

“IT IS TO BE DISTINCTLY UNDERSTOOD THAT FILING OF DRAFT LETTER OF OFFER WITH SEBI SHOULD NOT IN ANY WAY BE DEEMED OR CONSTRUED THAT THE SAME HAS BEEN CLEARED, VETTED OR APPROVED BY SEBI. THE DRAFT LETTER OF OFFER HAS BEEN SUBMITTED TO SEBI FOR A LIMITED PURPOSE OF OVERSEEING WHETHER THE DISCLOSURES CONTAINED THEREIN ARE GENERALLY ADEQUATE AND ARE IN CONFORMITY WITH THE REGULATIONS. THIS REQUIREMENT IS TO FACILITATE THE SHAREHOLDERS OF RAJATH FINANCE LIMITED TO TAKE AN INFORMED DECISION WITH REGARD TO THE OFFER. SEBI DOES NOT TAKE ANY RESPONSIBILITY EITHER FOR FINANCIAL SOUNDNESS OF UNICORN HOLDINGS PRIVATE LIMITED (ACQUIRER), PAC OR OF RAJATH FINANCE LIMITED (THE TARGET COMPANY) WHOSE SHARES/CONTROL IS PROPOSED TO BE ACQUIRED OR FOR THE CORRECTNESS OF THE STATEMENTS MADE OR OPINIONS EXPRESSED IN THE LETTER OF OFFER. IT SHOULD ALSO BE CLEARLY UNDERSTOOD THAT WHILE ACQUIRER(S) IS PRIMARILY RESPONSIBLE FOR THE CORRECTNESS, ADEQUACY AND DISCLOSURE OF ALL RELEVANT INFORMATION IN THIS LETTER OF OFFER, THE MERCHANT BANKER IS EXPECTED TO EXERCISE DUE DELIGENCE TO ENSURE THAT THE ACQUIRER(S) AND PAC DULY DISCHARGE THEIR RESPONSIBILITY ADEQUATELY. IN THIS BEHALF AND TOWARDS THIS PURPOSE, THE MERCHANT BANKER MEHTA INTEGRATED FINANCE LIMITED HAS SUBMITTED A DUE DELIGENCE CERTIFICATE DATED 08-11-2003 TO SEBI IN ACCORDANCE WITH THE SEBI (SUBSTANTIAL ACQUISITION OF SHARES AND TAKEOVERS) REGULATIONS, 1997 AND SUBSEQUENT AMENDMENT(S) THEREOF.

THE FILING OF THE LETTER OF OFFER DOES NOT, HOWEVER, ABSOLVE THE ACQUIRER FROM THE REQUIREMENT OF OBTAINING SUCH STATUTORY CLEARANCES AS MAY BE REQUIRED FOR THE PURPOSE OF THE OFFER.”


2    DETAILS OF THE OFFER

2.1 Background of the Offer

a)                  a)           M/s Unicorn Holdings Private Limited, a Company incorporated and registered under the Companies Act, 1956 (The Acquirer) along with PACs are making this offer pursuant to Regulation 11(1) of the SEBI (SAST) Regulations and in terms of SEBI Order No. CO/25/04/2003/TO dated 30-04-2003 for consolidation of holdings by the promoter group in Rajath Finance Limited (the Target Company)

b)                  b)           The Acquirer through oral agreement had acquired 2,06,760 Equity Shares representing 5.17% of the shares in the Target Company for cash at a price of Rs. 10/- per share from shareholders belonging to public category. Pursuant to the acquisition of the said 5.17% shares, the Acquirer violated the provisions of Regulation 11(1) and 14(1) of the SEBI (SAST) Regulations, and therefore, SEBI vide its Order No. CO/25/04/2003/TO dated 30-04-2003, directed the Acquirer to make an open offer to the shareholders of the Target Company. The Acquirer is accordingly making this Offer. The Acquirer intends to acquire further 8,00,000 Equity Shares representing 20.00% of the shares in the Target Company from remaining shareholders.

c)                  c)           None of the Acquirer, PAC, deemed PAC or the Target Company has been prohibited by SEBI from dealing in securities in terms of direction issued u/s 11B of the SEBI Act. SEBI vide Order dated 16-06-2003 has initiated adjudication proceedings against the Acquirer under Section 15H (ii) of the SEBI Act, 1992 for the contravention of Regulation 11(1) read with Regulation 14(1) of the SEBI (SAST) Regulations for the failure to make PA pursuant to acquisition of 5.17% shares in the Target Company. No other action has been initiated against the Acquirer/PACs/deemed PAC/Target Company under any of the Regulations of the SEBI Act, 1992.

d)                  d)           The acquirer group is already in control of the Target Company. Hence there is no proposal to change the Board of the Target Company after proposed offer except in the normal course of business.

2.2 Details of the Proposed Offer

a)                  a)           The PA and Revised PA were made on 29-10-2003 and 10-04-2004 respectively in the following newspapers, in accordance with Regulation 15 of the SEBI (SAST) Regulations.

Publications

Edition

Business Standard (English)

All Editions

Pratah Kaal ( Hindi)

All Editions

Lokasatta-Janasatta (Gujarati)

All Editions

PA as well the Revised PA are also available on the SEBI’s website at www.sebi.gov.in under Takeover Section.

b)                  b)           The purpose of acquisition is for consolidation of the holding of the promoter group. The Offer is made pursuant to the SEBI Order No. CO/25/04/2003/TO dated 30-04-2003.

c)                  c)           The consideration will be paid in cash.

d)                  d)           This is not a competitive bid.

e)                  e)           This Offer is not conditional as to any minimum level of acceptance.

f)                   f)            The Acquirer / PACs have not made any further acquisition of shares since the PA was made.

g)                  g)           The Acquirer is making an offer to the public shareholders of the Target Company to acquire 8,00,000 fully paid-up Equity Shares of Rs. 10/- each representing 20.00% of the paid-up Equity Share Capital of the Target Company at a price of Rs. 10/- (Rupees Ten only) per share and interest thereon @ 10% per annum with effect from 01-06-2003 (Offer Price) till actual payment of consideration to the shareholders under the Offer payable in cash subject to the terms and conditions mentioned hereinafter. Considering the date of payment of 31-05-2004, the Offer Price including the amount of interest would be Rs. 11.00 per share. In case of delay of payment beyond 31-05-2004, interest @ 10% per annum for a period from 01-06-2004 until the actual date of payment would also be paid over and above Rs. 11.00 per share.

h)                  h)           The Acquirer along with PACs/Troupe International Limited (deemed PAC) hold 28,42,320 Equity Shares representing 71.06% of the paid up Equity Share Capital in the Target Company as on the date of the PA.  Out of the same, the PACs hold 6,93,600 Equity Shares representing 17.34% in the Target Company as on the date of the PA.

i)                    i)             The Equity Shares of the Target Company are to be acquired, pursuant to the Offer, free from all liens, charges and encumbrances and together with all rights attached thereto, including the rights to all dividend or other distributions hereinafter declared, made or paid.

3          OPTION UNDER REGULATION 21(3)

Depending upon the response to the offer, the public holding of the Equity Shares of the Target Company is likely to fall below 10% of the paid-up capital, consequent to this offer and hence, may not satisfy continuing listing requirements of the Stock Exchanges. In such event, the Acquirer intends to exercise the delisting option provided in the Regulations by exercising the delisting option provided in the SEBI (SAST) Regulations and the Acquirer shall comply with the provisions of the SEBI (Delisting of Securities) Guidelines, 2003.

4          BACKGROUND OF UNICORN HOLDINGS PRIVATE LIMITED (THE ACQUIRER)

a)                  a)           Unicorn Holdings Private Limited, the Acquirer, is a Company incorporated under the Companies Act, 1956, having its registered office situated at 907, Star Plaza, Phulchhab Chowk, Rajkot – 360 001. The Company was incorporated as private company on 31-01-2000 by Mr Chamanlal V Kamani, Mr Rashmi C Kamani and Mr Deepak C Kamani (the PACs).

b)                  b)           The Acquirer is engaged in investments and promotion of group companies for taking up different projects. The Company’s activities include investment, acquisition, holding and dealing in shares and securities. The Company is also investing in other companies promoted by it.

c)                  c)           The Acquirer is a private Company and the entire share capital is held by the promoters, directors and their associates.

d)                  d)           The Acquirer along with PACs had acquired 2,06,760 Equity Shares representing 5.17% of the shares in the Target Company. Pursuant to the acquisition of the said 5.17% shares, the Acquirer violated the provisions of Regulation 11(1) of the SEBI (SAST) Regulations, and therefore, SEBI vide its Order No. CO/25/04/2003 dated 30-04-2003 directed the Acquirer to make an open offer. Accordingly, the Acquirer has violated the provisions of Chapter II of the SEBI (SAST) Regulations.

e)                  e)           SEBI vide Order dated 16-06-2003 has initiated adjudication proceedings against the Acquirer under Section 15H (ii) of the SEBI Act, 1992 for the contravention of Regulation 11(1) read with Regulation 14(1) of the SEBI (SAST) Regulations for the failure to make PA pursuant to acquisition of 5.17% shares in the Target Company.

f)                   f)            The Board of Directors of the Acquirer as on 31-03-2003:

Name

Designation

Residential Address

Mr. Chamanlal V. Kamani

Chairman

House No. 81, Kyuna Road, Industrial Area, Nairobi, Kenya

Mr. Rashmi C. Kamani

Director

House No. 81, Kyuna Road, Industrial Area, Nairobi, Kenya

Mr.Deepak C. Kamani

Director

House No. 81, Kyuna Road, Industrial Area, Nairobi, Kenya

Mr. Hebri Mohandas Pai

Director

17-Ketan Park

Opp. Drive-In-Cinema, Avadh Club Road, Vill. Vajdi-Virda, Rajkot

Mr. Parag I. Mody

Director

457, 8th Main, Ivth Block, Koramangala, Bangalore-560 034

By virtue of being the promoters / Directors of the Acquirer, Mr. Chamanlal V Kamani, Mr. Rashmi C Kamani and Mr. Deepak C Kamani are deemed to be PACs with the Acquirer. The Acquirer and PACs have not entered into any agreement regarding the offer / acquisition of shares. There is no other person / entity acting in concert with the Acquirer.

g)                  g)           All directors of the Acquirer are also the directors of the Target Company. All the directors have furnished declaration under Regulation 22(9) of the SEBI (SAST) Regulations that they shall not participate in any matters concerning or relating to the Offer.

h)                  h)           The shares of the Acquirer, being a private Company, are not listed on any of the Stock Exchanges.

i)                    i)             Brief Financials of the Acquirer:

Rupees in Lacs

Profit & Loss Statement

Year ended 31-03-2001

Year ended 31-03-2002

Year ended 31-03-2003

Half Year ended 30-09-2003

Income from operations

4.34

-

0.11

-

Other Income

-

-

-

-

Total Income

4.34

-

0.11

-

Total Expenditure

5.56

16.77

14.73

2.42

Depreciation

-

-

-

-

Interest

-

85.36

66.16

39.37

Profit (Loss) before tax

(1.22)

(102.13)

(80.78)

(41.79)

Prior period adjustments

(1.09)

-

-

-

Provision for Tax

-

-

-

-

Profit (Loss) after tax

(2.31)

(102.13)

(80.78)

(41.79)

Balance Sheet Statement

Sources of Funds

Paid-up Share Capital

210.05

932.85

932.85

932.85

Reserves & Surplus / (P&L A/c)

(1.02)

(103.16)

(183.93)

(225.73)

Net Worth

209.03

829.69

748.92

707.12

Secured Loans

-

-

-

-

Unsecured Loans

348.27

1088.15

872.58

838.58

Total

557.30

1917.84

1621.50

1545.70

Utilization of Funds

Net Fixed Assets

-

10.84

9.12

9.30

Pre-operative exps. pending capita.

2.45

25.21

68.58

68.58

Investments

630.81

1036.17

1138.93

1138.93

Net Current Assets

(81.85)

839.98

400.45

324.48

Total Misc. Exps not w/o

5.89

5.64

4.42

4.41

Total

557.30

1917.84

1621.50

1545.70

Other Financial Data

Dividend %

-

-

-

-

Earning Per Share Rs.

-

-

-

-

Return on Networth %

-

-

-

-

Book Value per Share

9.95

8.89

8.03

7.58

The above compilation is based on the Balance Sheet and Statement of Earnings for the years ended 31st March, 2001, 2002 and 2003 respectively and the accounts for the half-year ended on 30-09-2003, certified as being true and complete and in accordance with the records of the Acquirer. No income is generated by the Acquirer during the year ended on 31-03-2002 as well as for the half-year 30-09-2003 out of investments made by it because of poor performance by the investee companies. Net Worth disclosed above is subsequent to the adjustment of losses accumulated by the Company. However, Preliminary & Pre-operative Expenses not written off are shown separately under “Utilization of Funds”.

j)          Brief information of the subsidiary companies of the Acquirer:

Name of the Company:              Unicorn Hotel Management Academy Pvt Ltd

Date of Incorporation:    24-04-1995

Incorporated in the name of Rajath Finshare Limited. The Company was converted into a Private Company on 13-05-2002 and subsequently the name was changed on 05-03-2003.

Nature of activities:       Proposed to establish Hotel Management Academy. The required land for the project is already acquired. The project is in abeyance for the time being. Income is generated by way of interest.

The Board of Directors of the Company as on 31-03-2003:

Name

Designation

Residential Address

Mr. Chamanlal V. Kamani

Chairman

House No. 81, Kyuna Road, Industrial Area, Nairobi, Kenya

Mr. Rashmi C. Kamani

Director

House No. 81, Kyuna Road, Industrial Area, Nairobi, Kenya

Mr.Deepak C. Kamani

Director

House No. 81, Kyuna Road, Industrial Area, Nairobi, Kenya.

Mr. Hebri Mohandas Pai

Director

17-Ketan Park

Opp. Drive-In-Cinema, Avadh Club Road, Vill. Vajdi-Virda, Rajkot.

Mr. Parag I. Mody

Director

457, 8th Main, IVth Block, Koramangala, Bangalore-560 034.

Brief financials based on the audited accounts for the last three years are given below:

Rupees in Lacs

Details

31-03-2001

31-03-2002

31-03-2003

30-09-2003

Paid up equity capital

49.99

49.99

100.00

100.00

Reserves & Surplus

1.55

(1.61)

(8.66)

(11.78)

Net Worth

51.54

48.38

91.34

88.22

Total Income

1.98

2.57

1.00

0.05

Profit after tax / (Loss)

(2.75)

(3.16)

(7.05)

(3.12)

Earning Per Share (Rs.)

Negative

Negative

Negative

Negative

Net Asset Value per share (Rs.)

10.31

9.68

9.13

8.82

Name of the Company:  Infotalent Systems Pvt Ltd

Date of Incorporation:    01-12-2000       

Nature of activities:       Engaged in providing software development

services 

The Board of Directors of the Company as on 31-03-2003:

Name

Designation

Residential Address

Mr. B N Rangnath

Director

4130/50/3,1st Floor,3rd Main

B Block, Subramanyanagar

Banglore- 560 021

Mr. Parag I. Mody

Director

457, 8th Main, IVth Block, Koramangala, Bangalore-560 034

Brief financials based on the audited accounts for the last three years are given below:

Rupees in Lacs

Details

31-03-2001

31-03-2002

31-03-2003

30-09-2003

Paid up equity capital

1.00

1.00

1.00

1.00

Reserves & Surplus

-

(104.31)

(140.62)

(150.48)

Net Worth

1.00

(103.31)

(139.62)

(149.48)

Total Income

-

50.37

91.48

14.26

Profit after tax / (Loss)

-

(104.31)

(36.31)

(10.86)

Earning Per Share (Rs.)

-

Negative

Negative

Negative

Net Asset Value per share (Rs.)

10.00

Negative

Negative

Negative

Name of the Company:  Laguna Kumarakom Resorts Pvt Ltd

Date of Incorporation:    24-01-2001       

Nature of activities:       Proposed to establish Resort/Hotel

The Board of Directors of the Company as on 31-03-2003:

 Name

Designation

Residential Address

Mr. Chamanlal V. Kamani

Chairman

House No. 81, Kyuna Road, Industrial Area, Nairobi, Kenya

Mr. Rashmi C. Kamani

Director

House No. 81, Kyuna Road, Industrial Area, Nairobi, Kenya

Mr.Deepak C. Kamani

Director

House No. 81, Kyuna Road, Industrial Area, Nairobi, Kenya.

Mr. Hebri Mohandas Pai

Director

17-Ketan Park, Opp. Drive-In-Cinema, Avadh Club Road, Vill. Vajdi-Virda, Rajkot.

Mr. Parag I. Mody

Director

457, 8th Main, IVth Block, Koramangala, Bangalore-560 034

Brief financials based on the audited accounts for the last three years are given below:

Rupees in Lacs

Details

31-03-2001

31-03-2002

31-03-2003

30-09-2003

Paid up equity capital

1.00

46.70

100.00

100.00

Reserves & Surplus

-

-

-

(0.01)

Net Worth

10.00

46.70

100.00

99.99

Total Income*

-

-

-

-

Profit after tax / (Loss)*

-

-

-

(0.01)

Earning Per Share (Rs.)*

-

-

-

Negative

Net Asset Value per share (Rs.)

10.00

10.00

10.00

10.00

*not commenced any operations

5          BACKGROUND OF THE PACs/ DEEMED PAC

5.1              5.1         PACs

a)         Shri Chamanlal V Kamani, aged 72 years, residing at House No. 81, Kyuna Road, Nairobi, Kenya, and having his office at Post Box No.: 49615, Industrial Area, Nairobi, Kenya, is a Non Resident Indian and has experience of International Business (Trade). The net-worth of Shri Chamanlal V Kamani as on 29-10-2003, being the date of PA, is Rs. 588.51 Lacs as certified by S G Bhuptani & Associates, Chartered Accountants, (Membership No. 107361) 201, Royal Corner, Opp. Rajkot Colour Lab, Dr Yagnik Road, Rajkot – 360 001. Telephone: 91-281-3091180 Fax: 91-281-2431669.

b)         Shri Rashmi C Kamani, son of Shri Chamanlal V Kamani, aged 51 years, residing at House No. 81, Kyuna Road, Nairobi, Kenya, and hving his office at Post Box No.: 49615, Industrial Area, Nairobi, Kenya, is a Non Resident Indian and has experience of International Business (Trade). The net-worth of Shri Rashmi C Kamani as on 29-10-2003, being the date of PA, is Rs. 4843.12 Lacs as certified by S G Bhuptani & Associates, Chartered Accountants, (Membership No. 107361) 201, Royal Corner, Opp. Rajkot Colour Lab, Dr Yagnik Road, Rajkot – 360 001. Telephone: 91-281-3091180 Fax: 91-281-2431669.

c)         Shri Deepak C Kamani, son of Shri Chamanlal V Kamani, aged 49 years, residing at House No. 81, Kyuna Road, Nairobi, Kenya, and having his office at Post Box No.: 49615, Industrial Area, Nairobi, Kenya, is a Non Resident Indian and has experience of International Business (Trade). The net-worth of Shri Deepak C Kamani as on 29-10-2003, being the date of PA, is Rs. 2253.60 Lacs as certified by S G Bhuptani & Associates, Chartered Accountants, (Membership No. 107361) 201, Royal Corner, Opp. Rajkot Colour Lab, Dr Yagnik Road, Rajkot – 360 001. Telephone: 91-281-3091180 Fax: 91-281-2431669.

d)       The PACs mentioned at a, b and c above are engaged in the business of international trade. The PACs are based at Kenya and have promoted companies in India which are engaged/proposed to be engaged in financial services, software development and hotel management.     

e)         The Acquirer along with PACs had acquired 2,06,760 Equity Shares representing 5.17% of the shares in the Target Company. Pursuant to the acquisition of the said 5.17% shares, the Acquirer violated the provisions of Regulation 11(1) of the SEBI (SAST) Regulations, and therefore, SEBI vide its Order No. CO/25/04/2003 dated 30-04-2003 directed the Acquirer/PACs to make an open offer. Barring this, the PACs have complied with the applicable provisions of Chapter II of the SEBI (SAST) Regulations.

f)          None of the PACs is on the Board of any listed Company and none of them is a full time director with any Company.

5.2              5.2         DEEMED PAC

a)         Troupe International Limited, promoted and controlled by the PACs is holding 16,87,100 equity shares representing 42.18% of the paid-up Equity Share Capital of the Target Company. Accordingly, it is treated as deemed PAC. The brief particulars of Troupe International Limited is given hereunder:

Name of the Company:              Troupe International Limited.

Address:                                   Post Box NO. 49615, Industrial   Area, Nairobi, Kenya.

Phone:                                      0025420 537592, 0025420 553143. 

 Brief History & Major areas of Operations:

Troupe International Limited was incorporated on 08-05-1998. It is an Overseas Body Corporate engaged in Lending and Investment. It has lent moneys and made investments in share capital of group or associates companies. It has earned negligible income by way of interests and dividends. The operations are stagnant and the company has not been active since last three years.

b)         The Board of Directors of the Company as on 31-03-2003:

Name

Designation

Residential Address

Mr. Chamanlal V. Kamani

Chairman

House No. 81, Kyuna Road, Industrial Area, Nairobi, Kenya

Mr. Rashmi C. Kamani

Director

House No. 81, Kyuna Road, Industrial Area, Nairobi, Kenya

Both the above directors are also directors of the Acquirer as well as the Target Company. The Deemed PAC has complied with all applicable provisions of Chapter II of SEBI (SAST) Regulations.

c)         Brief Financials of the Deemed PAC:

Rupees in Lacs

Profit & Loss Statement

Year ended 31-03-2001

Year ended 31-03-2002

Year ended 31-03-2003

Half Year ended 30-09-2003

Income from operations

18.60

Nil

Nil

Nil

Other Income

Nil

Nil

Nil

Nil

Total Income

18.60

Nil

Nil

Nil

Total Expenditure

Nil

Nil

107.70

Nil

Depreciation

Nil

Nil

Nil

Nil

Interest

Nil

Nil

Nil

Nil

Profit (Loss) before tax

18.60

Nil

107.70

Nil

Provision for Tax

Nil

Nil

Nil

Nil

Profit (Loss) after tax

18.60

Nil

107.70

Nil

Balance Sheet Statement

Sources of Funds

Paid-up Share Capital

1940.70

1940.70

1940.70

1940.70

Reserves & Surplus / (P&L A/c)

30.80

30.80

(76.90)

(76.90)

Net Worth

1971.50

1971.50

1863.80

1863.80

Secured Loans

-

-

-

-

Unsecured Loans

-

-

-

-

Total

1971.50

1971.50

1863.80

1863.80

Utilization of Funds

Net Fixed Assets

-

-

-

-

Pre-operative exps. pending capital.

-

-

-

-

Investments

1290.90

1330.90

1580.90

1579.70

Net Current Assets

680.60

640.60

282.90

284.20

Total Misc. Exps not w/o

-

-

-

-

Total

1971.50

1971.50

1863.80

1863.80

Other Financial Data

Dividend %

-

-

-

-

Earning Per Share Rs.

0.10

-

Negative

-

Return on Networth %

0.95

-

Negative

-

Book Value per Share (Rs.)

10.16

10.16

9.60

9.60

The above compilation is based on the Balance Sheet and Statement of Earnings for the years ended 31st March, 2001, 2002 and 2003 respectively and the accounts for the half-year ended on 30-09-2003, certified as being true and complete and in accordance with the records of the Deemed PAC. No income is generated by the deemed PAC after 31-03-2001 because of poor performance by the investee companies.

6          PAST ACTION BY SEBI / STOCK EXCHANGES AGAINST THE ACQUIRER OR OTHER VENTURES OF ACQUIRER

a)         SEBI vide Order dated 16-06-2003 has initiated adjudication proceedings against the Acquirer under Section 15H (ii) of the SEBI Act, 1992 for the contravention of Regulation 11(1) read with Regulation 14(1) of the SEBI (SAST) Regulations for the failure to make PA pursuant to acquisition of 5.17% shares in the Target Company. Barring this, SEBI / the Stock Exchanges have not, in the last three years initiated any enquiries or awarded any penalties against the Acquirer, other ventures of the Acquirer / associate companies or companies in which the Acquirer is interested. No such action is taken against persons in control of the Acquirer or its directors.

b)         None of the Acquirer / ventures promoted by the Acquirer or promoted by the promoters of the Acquirer or belonging to the group is registered with SEBI as market intermediary.

7          SPECIFIED DATE

a)         The Specified Date for the Offer is 11-11-2003.

b)         Specified Date is only for the purpose of determining the names of the shareholders as on such date to whom the Letter of Offer would be sent and all owners (registered or unregistered) of shares of the Target Company anytime before the closure of the Offer are eligible to participate in the Offer.

c)         Unregistered shareholders who have sent the share certificates for transfer and not received them back or hold shares of the Target Company without being submitted for transfer are eligible to participate in this Offer.

8          OBJECTS AND PURPOSE OF THE OFFER AND FUTURE PLANS

a)                                                                  a)            The Acquirer proposes to make consolidation of existing holding of shares in the Target Company and de-list the shares from the Exchanges if total holding of the Acquirer exceeds 90%. This Offer of 20.00% of Equity Capital i.e. 8,00,000 Equity Shares of the Target Company is made in terms of Regulation 11(1) of the SEBI (SAST) Regulations and SEBI Order No. CO/25/04/2003/TO dated 30-04-2003.

b)                                                                  b)           The Acquirer wants to utilize its existing resources for managing the Target Company’s operations.

c)                                                                  c)            The Acquirer does not have any plan to dispose of or otherwise encumber any assets of the Target Company in the two years from the date of closure of the Offer except in the ordinary course of business of the Target Company. However, reorganization and/or streamlining of various businesses may be considered for commercial reasons and operational efficiency. Further the Acquirer undertakes not to sell, dispose of or otherwise encumber any substantial assets of the Target Company, except with prior approval of shareholders of the Target Company.

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