From, Date :

Dibyendu Das

Director

Sagnik Fuel Chain Private Limited,

Having its registered office at Durgachak,

Block- D, Plot No. 107/2,

Post Office & Police Station-Durgachak, Haldia,

Pin-721602.

To,

The Superintendent of Police,

District- Purba Medinipur,

Durgachak, Haldia,

District- Purba Medinipur,

West Bengal-721602.

Sub : Complaint of cheating, fraud and

breach of contract.
Respected Sir,

I, Dibyendu Das, is the founder and Co-Director of a startup

company namely Sagnik Fuel Chain Private Limited, having its registered
office at Durgachak, Block-D, Plot No. 107/2, Post Office & Police
Station- Durgachak, Haldia, Pin Code- 721602.

The company is registered under the Companies Act, 2013, and we

have been operating since 2020, on a pan-India basis complying with all
necessary legal procedure and requirements. On January, 2021, I on
behalf of the company, Sagnik Fuel Chain Private Limited, got into
contact with one Susanta Tewari, who represented himself as the
Director of Tera Bundle Analytics Private Limited, a company
specialising in Web -Development, developing Computer Software and
App Development, and accordingly, our company entered into a contract
with the said Director of Tera Bundle Analytics Private Limited being the
said Susanta Tewari on a contractual basis for development and
maintenance of a website dedicated for our company, and, development
and maintenance of an android application (APP) including development
and maintenance of an App-server and development and implementation
of a ERP, accounting System for our company. For the same purpose,
two separate quotations were sent by said Susanta Tewari on behalf of
Tera Bundle Analytics Private Limited, for website, Android and App-
server amounting to Rs.4,00,000/- and another for ERP, for accounts
amounting to Rs.2,50,000/-. In terms of the quotations raised by said
Susanta Tewari, this undersigned is liable to pay the total sum of
Rs.6,50,000/- (Rupees Six Lakhs Fifty Thousand) Only.

That after the contract was finalised we paid a sum of Rs.65,000/-

as initial payment and subsequently paid a total sum of Rs.5,40,000/-
(Rupees Five Lakhs Forty Thousand) only, in parts, as per the contract
and have fulfilled our part of the contract as required, but, said Susanta
Tewari on behalf of Tera Bundle Analytics Pvt. Ltd after some initial co-
operation started to totally mislead us, demanding more amounts of
money from us raising false, frivolous and fictitious bills, outside the
scope of our contract, and on every occasion threatening us that unless
such payments are made, they will stop maintaining our website and app
which would lead to huge losses on our part.

It also came to our notice that the bills sent to us by Tera Bundle
Analytics were without any GST Number and on further enquiry we came
to know that Tera Bundle Analytics are running their business without
fulfilling basic GST norms which is illegal under the Finance rules of the
Government.

I, on behalf of Sagnik Fuel Chain Pvt Ltd, to keep the business

running, and in good faith have made regular payments on diverse dates
through Bank Transfers in the name of Tera Bundle Analytics Private
Limited and have paid a sum of total Rs.5,40,000/- (Rupees Five Lakh
Forty Thousand).

On the recommendation of said Susanta Tewari, we hired one Mr.

Tajel Khan as employee to maintain ERP System from our end and paid
her salary, PF, EFI for one year costing us over Rs.1,56,000/- (Rupees
One Lakh Fifty Six Thousand) only. We have also purchased on the
recommendation of the said Susanta Tewari, multiple computer parts
and Motherboards from Amazon and sent them to the office location of
the office of Susanta Tewari to maintain our online systems. The cost of
such equipments amount to Rs.40,000/- (Rupees Forty Thousand) only .

It came to our notice that on December, 2021, that the

work/project has been stopped by Tera Bundle Analytics Private Limited
on the false premises of non-payment and despite making several
attempts and requests to review the project/work, they have refused to
co-operate with us, which has till now resulted in damage amounting to
Rs.15 Lakhs being suffered by our company. It also came to our
knowledge that without having the company’s permission and/or
consent, said Susanta Tewari and his company have been using our
website and app for advertising and promoting their own company. On
top of that, said Susanta Tewari is demanding and threatening that if
the project/work is to be continued, a new and fresh agreement must be
done, which is totally arbitrary and against the contract entered between
our company and said Susanta Tewari.

On March, 2022, when this undersigned, being one of the Directors

of Sagnik Fuel Chain Private Limited, requested said Susanta Tewari to
hand over the source codes of the projects and all the completed and
incompleted works/projects in proportion to the amount of money which
has already been paid by our company. After such request, some source
codes were provided to our company, which upon verification were found
to be unworthy and of no value whatsoever, and upon further verification
and enquiry, it came to our knowledge that the entire project was based
on a Demo project created by Tera Bundle Analytics Private Limited,
which was done just to deceive us, and no permanent work has ever
been done as per the contract.

The said Susanta Tewari and his company namely Tera Bundle
Analytics Private Limited runs their business without following GST
norms and have cheated and done fraud to our company multiple times
by sending false and fictitious bills, and threatening to stop our business
website and app without any reason, if, our company doesn’t pay the
arbitrary and unjustifiable amounts demanded by them. The said
Susanta Tewari have also used our Company’s website and app to
promote and advertise his own company without our knowledge,
permission and consent. He has failed to fulfill his part of the
contractual obligations as per the contract and even though our
company have paid him a sum of Rs.5,40,000/-, he has based our
project on a dubious demo basis and all materials, dates and source
codes submitted by him has turned out to be almost useless. That due to
such cheating, fraud and breach of contract on their part, our Company
till date have suffered losses amounting to Rs.30,00,000/- (Rupees
Thirty Lakhs) only. That to the best of our knowledge, the residential
address of Susanta Tewari is Basudevpur, Madhapalli Near HFC River,
Khanjachak , Haldia, Purba Medinipur, West Bengal -721602, and the
registered office address of the company Tera Bundle Analytics Private
Limited is New Market D/8, Durgachak, Haldia, West Bengal, Pin-
721602.

I have already made a written complaint via a letter dated

16/01/2023 to the Officer-in-Charge of Durgachak Police Station via
India Post Courier service (having tracking consignment No.
EW284473935IN) which have been received by the Police Station on
20/01/2023, but, unfortunately the Officer-in-Charge of Durgachak
Police Station have failed to take cognizance of this matter and take
necessary criminal action against the said Susanta Tewari and Tera
Bundle Analytics Private Limited and have not registered the complaint
as a First Information Report till date.

In view of the above, I kindly request your good–self to take

cognizance of this matter and take necessary criminal action against said
Susanta Tewari and Tera Bundle Analytics Private Limited and to treat
this letter as First Information Report and to act in accordance with law.

Thanking you.

Yours Faithfully

(DIBYENDU DAS)
Founder and Co-Director of
Sagnik Fuel Chain Private
Limited.