Submissions from the Petitioner: -

1. The shareholding pattern of the Petitioners and the R2 and R3 in the R1 Co., is equal i.e. 50:50. It is in the nature of Quasi-Partnership Since the last 6 plus years (i.e. since about the year 2016), the R2 and R3 have completely abstained and absented themselves from gainfully participating in the affairs of the R1 Co. Although being non-contributive to the business and affairs of the R1 Co., the R2 and R3 continue to malafide and to the prejudice of the R1 Co., draw disproportionate remuneration, perquisites, allowances, dividends, profit share and other benefits out of the R1 Co.,which are being generated solely and exclusively by the efforts of the Petitioners.

2. Pursuant to the COVID-19 pandemic, the business of the R1 Co., was badly affected and in order to sustain the operations of the R1 Co., it was imperative that funds were immediately arranged to meet with the day-to-day expenses and operations of the R1 Co. In these circumstances, Petitioner No.1 (referred as P1) came in contact with one Mr. Chadha, who agreed to grant an unsecured loan to R1 Co., towards financing the projects of R1 Co., subject to Mr. Chadha being appointed as ind