Dated: 13/03/2020

To,
Mr. Manoj Agarwal
Director of Gujarat Colourlam Pvt Ltd
Block No.285/2, Tadkeshwar,
Tal-Mandvi, Dist-Surat.
Gujarat- 394170.

Sub: Reply to your letter dated:07.02.2020 sent by Mr. Ashwin

Parmar( Distributor) to my client via whats app on ………………….

Sir,
Under the instructions and authority of my client 1. Mr. Tabrez Khan,
Proprietor of Euro Wood Maker Having Office at-Shop No-8, Khan
Compound, Survey No.29, Near Shanbar Hotel, Dhaniv Gaon,
Navjeevan Road, Soparphata, Nalasopara-East, Palghar-401208, I
hereby address you as under:
 Dated: 13/03/2020
2

1. At the outset my client denies the allegation against them in the

letter addressed to them by you.

2. My client parawise reply is as follows:

a. With reference to para 1, my client agrees that you are
Plywood(Bagasse Board) merchant and running said business
in name and style of Gujarat Colourlam Pvt Ltd.

b. With reference to para 2, it is correct and true that my client

are partners of Euro Wood Maker and both are liable and
responsible for said business equally.

c. With reference to Para 3, it is true to say that my client

approached you for trading Business of Plywood i.e Bagasse
Board but it is strictly denied by my client that he made you
any kind of false and rosy promises and cheated on you nor
tempted you by showing their image as big Business Tycoon.
That it is agreed that my client purchased Plywood i.e Bagasse
Board vide Bill No: BB/812 Dated:30.08.2018 amounting to
Rs.1,83,740/- and Bill No: BB/1106 Dated:25.10.2018
amounting to Rs.1,81,442/- total amounting to Rs.3,65,182 out
of which amount paid by them is Rs. 79,891/- and balance is
 Dated: 13/03/2020
3
outstanding according to you is Rs.2,85,291/-.But as per my
client record amount outstanding is Rs. 2,70,051 as the goods
of Plywood i.e Bagasse Board supplied by you was of inferior
quality which was conveyed by them to your Distributor
Mr.Ashwin Parmar. And thereafter due to defect in quality of
goods supplied by you, discount amounting to Rs.10,240/- was
acknowledged with his writing on Invoice No:BB/812
dated:30/08/18 amounting to 1,83,740 and also discount of Rs.
5000/- on Invoice No:BB/1106 dated: 25/10/2018 And it is
denied that 24% interest will be paid by them after credit
period of 30 days.

d. That it is agreed by my client no.1 that a cheque amounting to

Rs.1,83,742/- was been issued to you against the outstanding
amount but had clearly written behind cheque and had
requested to you not to deposit the cheque before prior
intimation. As my client had discussed with your Distibutor
Mr.Ashwin Parmar that due to inferior quality of goods their
reputation in market is spoilt and it’s a severe loss for their
business and after his request my client no.1 gave him cheque
no. 000068 of DCB Bank(Vasai) amounting to Rs.1,83,742/- as
only security purpose and on his assurance that it will not be
 Dated: 13/03/2020
4.

deposited without prior intimation to my client. As my client

never said that he will not repay your outstanding amount and
always showed their intention of repayment of said amount in
installments but is seeking time for repayment as it was a great
loss for their Business due to poor quality supplied by you.
That due to inferior quality of goods of Plywood i.e Bagasse
Board supplied by you , he incurred further loss of his raw
material, labour charges, etc of which who shall be liable and
responsible. He has also beared that loss which he has suffered
due to your negligence towards quality for which you are liable
and responsible.

Under circumstances, you are requested to settle the said dispute

mutually with my client henceforth failing which my client will be
constrained to initiate the appropriate legal proceeding and also
defend if need arises at the cost and consequences of your client.

Under Instruction of my client

(Mr. Tabrez Khan) Advocate