RPI BHATIA SOLUTIONS OPC PVT LTD – GreenPenn Outsourcing / Arrow Consulting / Neeraj Goel (Proprietor)

Reported By: RAKESHKUMAR BHATIA

Contact information:
RPI BHATIA SOLUTIONS OPC PVT LTD Pune

Dear Mr. Neeraj,
Earlier mail was sent at your email address [email protected] but the same has returned un-delivered, hence, this is being sent on this email ID for your doing the needful.

Greenpenn Outsourcing Business Advisory,
Pune.
Through: Mr. Neeraj Goel, Proprietor.

Dear Mr. Neeraj Goel,
Please find attached legal notice for and on behalf of our client M/s RPI Bhatia[OPC] Pvt. Ltd., Thane as below:

B. K. Dubey Advocate Srijan Legal Solutions Pvt. Ltd.

218-219, Raffel Tower,

Second floor, Saket Square,

Old Palasia, Indore, 452001 M.P.

Phone no. 9826527778

e-mail: [email protected]

Dated: 18th May 2021

E-mail/Regd. A.D.

1. Greenpenn,

Outsourcing Business Advisory,

Registered Office:

A] Office no. 3, 2nd Floor, Lalwani Plaza,

New Airport Road, Viman Nagar,

Pune-411014[As per website]

B] Office no. 404-405, 4th floor,

Lunkad Sky Max, Dutta Mandir Chowk,

Viman Nagar, Lohegaon,

Pune-411014 [As per Shop & Est Deptt]

E-mail ID [email protected]

Through: Mr. Neeraj Goel, Proprietor

2. Mr. Neeraj s/o Shiv Dayal Goel,

Proprietor & CEO: Greenpenn Business Advisory & GreenpennGroup

Web-Platforms viz: ISCForum, Arrowconsulting etc.,

Flat no. 304, 17/1A, Goodwill Square,

Dhanori, Haveli,

Pune-411015, Maharashtra

Website:

E-mail ID [email protected]

3. Mr. Uday Kang, Chief Marketing Officer

[CMO], Greenpenn Group,

A] Office no. 3, 2nd Floor, Lalwani Plaza,

New Airport Road, Viman Nagar,

Pune-411014[As per website]

B] Office no. 404-405, 4th floor,

Lunkad Sky Max, Dutta Mandir Chowk,

Viman Nagar, Lohegaon, Pune-411014

E-mail ID [email protected]

Subject: Legal Notice on behalf of our client company RPI Bhatia Solutions [OPC] Pvt. Ltd., for demand of an amount of Rs. 1,53,000/- [One Lakh and Fifty three thousands] only, plus taxes paid to you no. 1 through bank account, during the period 12.01.2021 to 20.03.2021 plus interest thereon from 20.03.2021, the date of last payment, besides a sum of Rs. 5,00,000/- [Rs. Five lakhs], plus interest thereon for loss sustained, till date of payment, on account of failure of delivering the services paid for.

Reference: Development and marketing of the website for the purposes of floating an EDUCATION PORTAL in the name of BIZELEARN.COM, entrusted by our client M/s RPI Bhatia Solutions [OPC] Pvt. Ltd., through it’s Director Mr. Rakeshkumar Bhatia, having it’s registered office at Flat 101, Building B, Wing-1, Galaxy, Kalyan Shilphata Road, Near Toyota Showroom, Padle, Thane — 421204, Maharashtra.

Dear sir(s),

With reference to the above, under instructions and for and on behalf of our client company M/s M/s RPI Bhatia Solutions [OPC] Pvt. Ltd., through it’s Director Mr. Rakeshkumar Bhatia, having it’s registered office at Flat 101, Building B, Wing-1, Galaxy, Kalyan Shilphata Road, Near Toyota Showroom, Padle, Thane — 421204, Maharashtra, this legal notice is being served upon you noticees, jointly and severally, demanding a sum of Rs. 6,53,000/- plus taxes and interest thereon w.e.f. 20.03.2021 till date of payment [Rs. 1,53,000 plus taxes the amount paid + Rs. 5,00,000/- [Five lakhs] for loss sustained by our client company, as below:-

1. FACTS OF THE CASE:

A. That, our client company RPI Bhatia Solutions [OPC] Pvt. Ltd., is a private company, registered under the provisions of the Companies Act, 1956, as amended upto date, having it’s registered office at Flat 101, Building B, Wing-1, Galaxy, Kalyan Shilphata Road, Near Toyota Showroom, Padle, Thane-421204, Maharashtra, which for all the purposes is a legal juristic person, being controlled by the Board of Directors, and managed by Director/Managing Director/Whole time Director, duly appointed as agents of the company. Mr. Rakeshkumar Bhatia [promoter of the company] has been duly appointed as Director of the company, for conducting business of the company, in a prudent and commercial manner, under the instructions of the Board of Directors of the company, in the capacity as agents, without having any restriction to carry out their other activities individually as per the provisions of the Company Act 1956[as amended upto date].

B. That, you noticee no. 1 is a proprietorship firm, carrying on the business of outsourcing business advisory, in the name of GREENPENN OUTSOURCING BUSINESS ADVISORY, fully owned by the noticee no. 2 Mr. Neeraj Goel, but, advertising yourself as a COMPANY. In India the company means a group of persons to form a company registered under the provisions of the Companies Act, and not otherwise. Here, noticee no. 2 is the sole proprietor of the different electronic platforms, every one is linked to the GREENPENN, termed as GREENPENN group, over another digital platform named arrowconsulting, with corporate profile over the website, which depicts of being owned by GREENPENN.

C. That, our client company, in order to achieve objectives of the business for which it was incorporated, i.e. development of a website in the name BIZELEARN.COM, and marketing of the said website was in search of single point of services provider.

D. That, one Mr. Keshavan Raghavan approached our client company’s Director Mr. Rakeshkumar Bhatia on 20th July 2020, for and on behalf of Indian Speakers and Coach Forum [ISCF], another digital platform owned by GREENPENN, and explained him about the diverse activities carried on by the firm GREENPENN, and assured of providing services for setting up the website for our client company, and further assured of promotion of the website BIZELEARN. Mr. Raghavan also sent an e-mail to our client company.

E. That, on 12th October 2020, one Ms. Pooja Shinde, contacted our client company’s Director Mr. Rakeshkumar, and informed that Mr. Raghavan has left the group, and she has taken over charge, and that now onwards she will be the point of contact. Ms. Pooja Shinde sent details of the GREENPENN and also forwarded offer from the side of GREENPENN.

F. That, on 13th Oct 2020, our client company’s Director Rakeshkumar called Ms. Pooja Shinde again and asked for an agreement copy for Non-Disclosure agreement and offered INR 35,000/- + taxes for a full-fledged e-commerce website. He sent an email as well. Ms. Shinde in turn sent our client company, a standard agreement format. Our client objected immediately as the agreement format was a mere terms and condition document, that too it was one sided and had many errors. It was not a standard legal agreement. Our client company also asked for the payment terms to be 50-50%, to which Ms. Shinde replied and informed that, payment has to be made 100% upfront, without properly addressing on objections of our client company to the agreement as forwarded by Ms. Pooja.

G. That, on 15th Oct 2020 – our client company’s Director sent an email again agreeing on 100% payment of INR 36,000/- + taxes. But since the agreement format was not proper, our client did not agree to sign the agreement. One Mr. Prasad Dhotre and Ms. Pooja arranged a con-call, after which our client company sent out the email to them sharing the minutes of the meeting.

H. That, on 19th Oct 2020 – Mr. Prasad replied to our client’s email of 15th Oct 2020 that he will get back within 2 days [four days after replying with further period of 2 days, this shows seriousness of the assignment]. Thereafter, Mr. Prasad on 20th October sent some more clarification on the agreement clauses, and desired to enter into the NDA agreement.

I. That, on 22nd Oct 2020 – Mr. Prasad, Ms. Pooja and Mr. Uday (claimed to be tech guy for GREENPENN & ISCF) connected on a zoom call at 2:00pm., Mr. Rakeshkumar of our client company, who discussed the project with them.

J. That, vide dt. 23rd Oct 2020, Mr. Prasad sent an email to our client company an offer of INR 1,00,000/- + taxes, stating therein, the details of services offered and payment terms. Marking copy to Ms. Pooja and Mr. Uday.

K. That, on 23rd Dec 2020, our client Mr. Rakeshkumar called Ms. Pooja again and asked if they are willing to do a bigger project, and also sent out an email to them mentioning that the project has become bigger and the name of the registered domain name. In response to above mail, Ms Pooja vide dt. 28th December 2020 arranged a Zoom meeting with Mr. Uday Kang and Mr. Prasad.

L. That, on 29th Dec 2020 Mr. Uday Kang sent an email to our client company, attaching therewith a draft of the NDA agreement where he mentioned himself as signing authority and designated as CMO and cofounder of LIMI Inc (tech firm of ISCF and GreenPenn).

M. That, on 30th Dec 2020, the draft NDA agreement with full details about the company, as per requirement of the agreement, duly filled therein was sent back with company’s comments on the changes required. Ms. Pooja sent the signed copy (only last page) although the changes suggested were incorporated. Our client company informed that it requires signature on all the pages from your end and then only Director of our client company will sign the same and with the said comments the agreement so sent from your side was sent back. But, you noticee no. 2 and 3, never shared the agreement duly signed on all pages. Our client company vide another email asked for KYC documents, board resolution and other verification details, which also were not shared as per requirements of the NDA Agreement.

N. That, vide dt. 31st Dec 2020 Mr. Uday Kang, sent an email informing that, since, he is travelling till 3rd Jan 2021, hence, he suggested to e-sign the document, but that too he did not do. He clarified that GreenPenn is the group parent company and ISCF is part of GreenPenn Outsourcing Business Advisory. He mentioned that there are 3 directors and he is one of them. He also mentioned that he will have the clauses of NDA revised but that too did not happen. Our client company in response to his email it was informed that, the company would require the verified KYC documents before proceeding further.

O. That, vide dt. 04th Jan 2021, Mr. Uday looped in Mr. Neeraj Goel and asked him to give the required documents. Thereafter, vide call dated 05th Jan 2021 Ms. Pooja called Mr. Rakeshkumar of our client company and tried to set up a zoom meeting with Mr. Uday Kang and team to discuss the project further. Mr. Uday also asked Ms. Pooja to change his name and put Mr. Neeraj Goel’s name in the NDA. Mr. Neeraj is the Proprietor of GreenPenn.

P. That, on 06th Jan 2021 – Ms. Pooja sent revised NDA document signed on last page by Mr. Neeraj Goel mentioning him to be CEO of ISCF. You noticee no. 2, also shared the shop and establishment document of GreenPenn Outsourcing Business Advisory. It was objected on the NDA document with reasons in the email that the signing authority, name of company and KYC documents are a mismatch.

Q. That, on 07th Jan 2021 – Mr. Uday again sent an email mentioning that ISCF falls under GreenPenn group. He assured that, all supporting documents will be provided. But these documents, as said and promised were never received at the end of our client company. Our client company replied to your Mr. Uday Kang, the noticee no. 3, thereby agreeing to move ahead with the project informing Ms. Pooja on the project cost of INR 75,000/- + taxes without Learning Management system [LIMI].

R. That, on 12th Jan 2021 our client company, made a payment to GreenPenn group for INR 75,000/- + taxes. Meanwhile many of the confidential information was shared by our client company with you noticee no. 1, and the project was getting delayed therefore, our client company in order to get it’s project started at an early date, had no choice but to proceed with your proprietorship firm.

S. That, on 15th Jan 2021 – By this time our client company agreed to proceed with the complete project at a cost of INR 1,80,000/- + taxes which included the development fee of website + Learning Management system (LMS). Over a phone call with Mr. Uday Kang and Ms. Pooja, agreed to take up the entire project on this amount, and assured to finish the project in a time bound manner.

T. That, vide dt. 16th Jan 2021 Mr. Uday Kang informed that to start with they need a payment of 60% upfront and 40% on delivery. Our client company paid the remaining payment thus total payment now made to the account of GREENPENN by 16th of January 2021 was INR 1,08,000/- + taxes (60% of 1,80,000 + taxes), without there being any service provided by you noticee no. 1 at the instance of you noticee no. 2, the proprietor of the firm.

U. That, our client company kept following up for the NDA agreement, KYC documents and development agreement verbally over phone calls with Ms. Pooja and Mr. Uday, but of no avail. Thereafter, on 18th Jan 2021 – Mr. Uday Kang shared a Google document with our client company mentioning the detailed requirement of website without sharing formal plan for the project.

V. That, on 20th Jan 2021 our client company replied to Uday Kang, informing him about the changes as per requirement of the company, and also requested for a video call to discuss the project in the morning 11am on 20th Jan 2021. During the zoom call, our client discussed the project and also raised the concern on the agreement and KYC documents pending from their side.

W. That, for next 5 days, Mr. Uday Kang, did not pick up the phone calls of Mr. Rakeshkumar Director of our client company, at all, and on 25th Jan 2021 – Mr. Uday wrote an email replying to our client company’s email, informing that, he was down with flu and could not pick up the call. Post that, there was some whatsapp chat and phone discussions, and it was discussed and agreed between your team and our client company to have calls regularly to discuss the project. There was a zoom call on 25th Jan 2021 itself again, and our client company again raised a concern for having an agreement and KYC documents.

X. That, on 30th Jan 2021, since, the discussions were still pending. Our client sent an email to your team mentioning therein a suitable time on Saturday to call and discuss, and also kept following up to send a cost break up.

Y. That, on 31st Jan 2021 Uday Kang, the noticee no. 3, sent a draft agreement for development, completely ignoring our client company’s demand of proper NDA agreement and KYC documents which was kept following up with them. Mr. Uday Kang, also mentioned hosting space and some vague cost breakup which did not make sense nor did it total to the development cost. Our client company further raised concerns on the development and it was informedto your firm, that there are 2 months left to complete the development.

Z. That, on 02nd Feb 2021 Uday Kang, the noticee no. 3 replied to our client company’s email of 31st Jan 2021 to which our client company replied and reminded them about mutually agreed calls on Saturday. Our client company also sent another email on the agreement, MOU and WO. Our client had made the changes in the documents and shared it. Thereafter, there were multiple follow ups on the agreement but your team never sent a proper reply nor supplied the desired documents i.e. agreement, MOU and WO.

AA. That, on 03rd Feb 2021 our client company vide email sought PAN card copy for TDS and IT Return purposes. The PAN card received by our client company on 4th February 2021, was in the name of you noticee no. 2, but, not in the name of the firm.

BB. That, on 04th Feb 2021, noticee no. 2 Uday Kang again shared a vague cost break up which did not make sense. He wrote development cost of INR 1,50,000/- + taxes, without giving any heed to the demand of agreement and KYC details.

CC. That, after receiving money in your account, the noticee no. 3 Uday Kang, assigned the project to one Mr. Atul, a junior wordpress website developer, and created a whats app group, and Mr. Uday Kang himself started ignoring phone calls of the Director of our client company. Although, Ms. Pooja always assured to arrange for the call with Mr. Uday Kang, which did not happen. In the meantime, a development Google Doc was shared with our client company, but, access to that file was blocked.

DD. That, on 06th Feb 2021 the noticee no. 3 Uday Kang shared a zoom link to connect at 4pm. Our client company’s Director Rakeshkumar connected at the given time, but no one else joined. Thus, our client company was ill treated. Atul, the person introduced by you noticee no. 3, Uday Kang, kept showing old web pages without any corrections as suggested over the whatsapp group, which gave a sense of deliberate delays at the instance of you noticee nos. 2 & 3. Though, Ms Pooja, in the meantime over whatapp chat, always kept assured that the project was going as planned, and will be delivered in the timeline as discussed.

EE. That, on 13th Feb 2021 – our client company raised a concern over email to Pooja and Uday that, Saturday meetings are not to be missed and sought to know update on the website and the LMS. Uday Kang the noticee no. 3 herein, replied and assured that the website and LMS are on time. He mentioned to shift the Saturday calls to Sundays at 4pm, which was accepted by our client company, but, did not receive any calls or meeting invite.

FF. That, on 18th Feb 2021, our client company sent an email to follow up on the pending MOU and WO agreement, but of no avail, despite calling and sending reminders to Pooja and you noticee no. 3, who never responded to calls. However, you noticee no. 3, vide dt. 23rd Feb 2021, replied to our client company’s email dt. 18th Feb 2021, and sent revised draft agreement. But the changes were not made as per comments sent to them. You noticee no. 3, sent with a separate email on log-in details of BIZELearn support emails.

GG. That, on 24th Feb 2021, our client company sent an email replying to you noticee no. 3 Mr. Uday Kang, stating therein that the changes in the agreement sent by the company have not been made as stated earlier and agreed upon by you noticee no. 3, time and again, therefore, Mr. Rakeshkumar Director of our client company, mentioned and requested to get on a call on 2nd March 2021 at 6pm. He replied with agreement to connect. But on 2nd Mar 2021 he did not pick up the call.

HH. That, thereafter Mr. Rakeshkumar, for and on behalf of our client company, kept calling and following up for calls, discussions on phone and whatsapp. But did not get any answer on the progress of website development, agreement, KYC documents and cost breakup.

II. That, on 09th Mar 2021, you noticee no. 3 Uday Kang, sent a revised cost breakup again, which was replied saying that the cost is not adding up to INR 1,80,000/- + taxes, to which you noticee no. 3, Mr. Uday Kang, replied that he has kept INR 12,000/- for stock images and API development. This time there was no mention about the hosting platform as earlier as mentioned AWS.

JJ. That, on 10th Mar 2021, our client company sought an information and details from you noticee no. 3 Mr. Uay Kang with reference to the name of the hosting platform and server. You noticee no. 3, Uday Kang, though replied with the configuration details but did not mention the name of the hosting platform and the server, as sought for. All this shows no integrity and sincerity unto the services offered and paid for.

KK. That, on 11th Mar 2021, our client company, raised a concern over higher costing of hosting platform, and about affiliate plugin before you noticee no. 3, Mr. Uday Kang and also sought for more options. Upon contacting Atul, informed that, they are using their own hosting platform which was not informed to our client company. That, without resolving the long pending issues, Ms. Pooja and Ms. Sneha Oza started discussing the Marketing plan with our client company w.e.f. 03.03.2021 itself.

LL. That, on 18th Mar 2021 Ms. Pooja shared a marketing plan with our client company, marking a copy to Uday, Sneha and Ms. Divya Rathod. She also shared a draft agreement for Marketing, completely ignoring the earlier agreements which till date were pending for signing on the part of you noticee no. 1, 2 and 3. Being a proprietorship firm, you noticee no. 2 are solely responsible for all or any act[s] of Noticee no. 3, and other persons acting under the authority of you noticee no. 2.

MM. That, vide dt. 19th Mar 2021 Mr. Rakeshkumar Director of our client company, made a call with Ms. Pooja, and informed that, the website development is not going as discussed. But she kept saying that they will proceed only when the website is fully developed and that the company should pay the marketing fee fully upfront.

NN. That, on 20th Mar 2021 our client company paid the marketing fee of INR 45,000/- + taxes and shared the payment advise, thus making a total payment to GREENPENN as INR 1,53,000/- + taxes.

OO. That, on 22nd Mar 2021 one Ms. Divya from your group, shared a draft Marketing agreement. Our client thought that things are back on track but it was a mistake. Our client company then kept asking for modified agreement as per mutual discussions with Ms. Pooja with reference to her various emails. But our client company never received any agreement till date. Our client kept calling Pooja and the noticee no. 3 Uday Kang. But, did not receive any reply, post that.

PP. That, on 31st Mar 2021 our client company received a notification from ISCF / GreenPenn group that Ms. Divya, Ms. Sneha, Ms. Pooja and some other employees have left the company. This started panicking with our client company, as the only contact Ms. Pooja who used to respond at often periods had left the organization and there was no clarity on our client co’s website development. Thereafter, for next few days, noticee no. 2 Mr. Uday Kang was replying to whatsapp selectively as usual and Atul kept ignoring the development.

QQ. That, on 04th Apr 2021 our client company raised concerns of the company marking email to you noticee no. 3 Uday Kang and also to you noticee no. 2 Mr. Neeraj. In the email replies, you noticee no. 3, Uday Kang started threatening our client company to halt the company’s project, but did not reply to any of the concerns in any possible way. You noticee no. 3 sent a development calendar to our client company, without any dates and without there being any clarity of completing the project on time as discussed time and again. Eventually, you noticee no. 3, instructed one Mr. Atul to completely put the project of our client company on hold. Our client company’s Director Mr. Rakeshkumar tried to e-connect with you noticee no. 2 and requested for a call. But, you noticee no. 2 Mr. Neeraj Goel, founder and owner proprietor of the GREENPENN did not bother to call our client company, who as per your demands paid amounts for numerous services, thus, it proves that, all other persons viz, Uday Kang, Pooja Shinde, Divya, Snigdha Das and Atul etc., have been hired by you to just collect the money by hook or crook, by way of promoting false assurances, and then harass the prospective and potential client, to the extent where your customer is left with no option than to take a decision to drop the project work. Thus, you are enriching yourself at the cost of others, in this case at the cost of financial loss to our client company.

RR. That, on 07th Apr 2021 our client company, received an email from Ms. Snighdha Das of ISCF GreenPenn introducing herself to be relationship manager to deal with our client company. Snigdha Das agreed to connect on call at 7 p.m., but, after some time she declined and in informed that, she is available upto 5 p.m. only. I replied that I will connect with her on call at 7pm. She replied in agreement but later she sent another email saying she is available only till 5pm. Our client company, then continued followup emails on the previous email subjected on 4th Apr 2021, and again requested for a conference call but did not receive any reply.

SS. That, on 08th Apr 2021 when called Ms. Snigdha she informed that, due to lockdown in Maharashtra, they will not be operational. So sent an email was sent to you noticee no. 2, Mr. Neeraj and to the noticee no. 3 Uday Kang asking for refund of money. On this it was informed to our client company that, they will pay only INR 1,09,000/- + taxes only, and will keep 40% in the name of development fee, which is very unfair. It is very unfair on the part of you all the noticees, because you induced our client company to part with valuable money under assurances of providing services, which you continued to defer on one or the other pretext, and finally you noticee no. 3 being hand-in-gloves with the noticee no. 2, directed one Mr. Atul to put the project on halt. Thus, not only substantial amount has been duped but, our client company is suffering losses on account of inability to start the project just because of ill, unethical and un-professional attitude of you noticee no. 2 and 3.

TT. That, Mr. Neeraj Goel, the noticee no. 2 herein, mentioned in the email that you will refund the money only after the lockdown is lifted from Maharashtra. To this, our client objected and mentioned that the amount of refund should be transacted within 7-10 days.

UU. That, on 09th Apr 2021 our client company sent an email informing therein that, the company has filed for GST and paid TDS already and the company will require you to issue the credit note. But, there is no response to the said request, and you noticees did not send any reply or credit note.

VV. That, again on 14th Apr 2021 our client company sent a reminder email again asking to issue the credit note and status of refund, but, of no avail.

WW. That, on 16th Apr 2021 our client company received an email from the accounts team saying that they have some issue with the Tally software, so they cannot issue the credit note. Our client company replied the email from your firm, asking for refund soon and again mentioned that the company has already filed the GST and paid TDS amount, hence, credit note is very much required for legal compliance. This proves that, you are working online, and there is no effect of lock-down on the working, as earlier notified to our client company, vide email dated 8th April 2021.

XX. That, on 20th Apr 2021 our client company received an email from your accounts team to the effect that, refund is accepted and they issued a ticket number for refund to our client company. This further proves that, you are working online, and there is no effect of lock-down on the working, as earlier notified to our client company, vide email dated 8th April 2021.

YY. That, since then, our client company has been following up for refund as assured but neither the amount has been refunded nor the credit note has been provided, though assured in black and white.

ZZ. That, on 30th Apr 2021 our client company received an email stating therein that, operations of the noticee no. 1 firm are put on hold and they are not able to function properly. To which our client company informed that, the banking transactions, being an activity under economic drive of the country, are not part of the LOCKDOWN from the Government, to which you have not replied. This shows your deliberate act of delaying the payment, and it is denied that, you have not made any banking transactions during the period from 8th April 2021 to 30th April 2021 or even thereafter. This is violative of your own policy of TRANSPARENCY, as claimed and assured over your website.

AAA. That, since, none of you noticees were picking up phone calls for last several days, therefore, our client company vide email 1st May 2021, informed the said fact over email, to which you noticees have not responded at all.

2. EXPERIENCE OF OUR CLIENT COMPANY VIS-À-VIS YOUR WEBSITE PROMISES:

A. That, home page of greenpenn.com speaks about fix a meeting at +919422324553.

Our client’s experience is that, your staff does not honour the words, and do not attend the meetings notified by them to the clients, as detailed in the foregoing paragraphs.

B. Vision and values: Integrity: over the website greenpenn.com, you proclaimed to be honest, ethical and treat others with fairness, dignity and respect.

Our client’s experience is that, you are not honest, not ethical nor treat your clients with fairness at all. Your organisation has no concern about hardships of your clients, and very often do not respond to phone calls/emails, what to say about providing solutions to your customer’s problems. There are number of instances elaborated in para 1 and sub-paragraphs thereof. You noticee no. 3 Mr. Uday Kang, once proclaimed as authorised signatory to the agreement with our client company, but, when the matter came for KYC, he backed out and onus was shifted on you noticee no. 2, being proprietor of the enterprise. Is it fairness ?

C. Transparency: “we are clear about our intentions and communicate openly”

Our client’s experience is that, you are not transparent, you do not communicate as per needs of your customer, but do so as per your goal to collect money under different heads, and dupe the project of your client. You never shared the agreement for providing services i.e. NDA, though assured time and again. In this particular case, in the initial stage itself you did not communicate that, if the project is completed, you will deduct substantial amount to the tune of 40% in the name of development fee. Here in this case you noticee no. 3 has instructed one Mr. Atul, to put the project of our client company on total halt, without assigning any reason to our client company, and this has been done within 10-11 days of receipt of a huge sum of Rs. 45,000/- in the name of marketing fee, which proves that, your intentions are just to induce people to part with their hard earned money unto you for a purpose, unto you, with intentions to enrich yourself at the cost of your client, and with clear intentions close the project, which has not come on the platform. Thus, your intentions are just to cheat coming up START-UP projects.

D. Entrepreneurship: “we are creative, innovative and take a measured approach to opportunities, balanced with a long term perspective”

Our client’s experience is that, you are a real entrepreneur and create, innovate new devices to trap new START-UPS, as an opportunity, in order to enrich yourself i.e. Mr. Neeraj Goel, noticee no. 3, proprietor of the business, with the help of co-accused Mr. Uday Kang. You have created several platforms and websites within the ownership of GREENPENN a proprietorship firm, so that, from either platform the client is trapped and be induced to part with money unto you with an assurance that, payment to you is safe and protected by escrow account since you are member of Escrow account, as proclaimed over the website arrowconsulting.wixsite.com, without clarifying that, you will deduct 40-50% of money paid in case the project is not completed, may be due to inefficiency and negligence of your own staff. Once money is pocketed, then the client is harassed to the max, and when it comes for refund of amounts paid, you start demanding service charges in different names. In fact you are indulged in the cheating business as defined under the provisions of section 415 of the Indian Penal Code. Besides, your failure in delivery of services also makes you to be sued under the provisions of the Consumer Protection laws of the country.

E. Accountability: “we make good decisions, take personal ownership of tasks, are responsible for our actions and deliver on our commitments.”:

Our client’s experience is that, the decisions you take are always to your own benefit and grabbing of money without taking into consideration about the loss and damages to the other party, who delivered you money for certain purposes. Mr. Uday Kang, so called your partner [who in fact is an employee of you noticee no. 1 proprietorship firm] in the offence of cheating, can not take any decision without the security of you no. 2. Even otherwise, any act or omission of an employee [by whatever name], owner of the business/enterprise is responsible. Hence, you no. 1 & 2 with the help of Mr. Uday Kang, the noticee no. 3, have committed an offence of cheating under section 415 and section 463 read with sections 34 and 120-B of the Indian Penal Code, and our client company reserves it’s rights to bring in a prosecution against all of you noticees in the competent court of law.

3. More success stories of GREENPENN shared by other tiny START-UPS, over the website consumercomplaints.in, are as below:

A. Alhamd Associates writes an alert over the website in the words “I would like to drag your attention towards the pune based company greenpenn running by mr neeraj goel (Ceo) and their crime partners harjeet singh and manish pillai..
Beware of them (Greenpenn.com)… I would say that they are #professionalcheaters. Never go for any project. They would offer you inbound, chat support but these kind of process would never b started and you would loss your time money faith everything.. They didn’t give me project nor refund the complete amount and deducted the charges in the name client’s legal fess.”

B. Jayesh Jha, from Noida U.P. writes “Mumbai and Pune, which GreenPenn has cheated as well. Please do not take any project from this scammer. All they do is take investment, make up a fraud project within the company and later tell you that, only 50% of work is done and on top of them zero payment after that. JSPM is a fake project, they said in an email it is a company based out of Delhi with 1000 employees but now we found out it’s their own entity and has only 4 employees who are from Greenpenn”

“This company is a total fraud. They don’t make payments at all. When you choose to close a project before going live, they even promise a refund but that never happens. Harjeet is the biggest manipulator of this firm, properly guided by Neeraj Goel, the CEO who runs a huge Scam in the name of Outsourcing projects. None of them are genuine. The company takes several months to hire so that eventually you would want to close the project and they keep your money. We have finally decided to go legal against them as we were able to get in touch with 3 more companies from Mumbai and Pune, which GreenPenn has cheated as well.
Please do not take any project from this scammer..
All they do is take investment, make up a fraud project within the company and later tell you that, only 50% of work is done and on top of them zero payment afterthat
JSPM is a fake project, they said in an email it is a company based out of Delhi with 1000 employees but now we found out it’s their own entity and has only 4 employees who are from Greenpenn.
Please try to avoid this company and do not take any project as all you will do is simply pay Neeraj, who will buy an office in Dubai with your hard-earned money.”

C. Mudra Financial Services from Rajasthan on the subject “Arrow Greenpenn Outsourcing Business Advisory — not paying for work (complaint)”

“personal experience with greenpenn today we are sharing with you our experiences. Greene describes herself as one of the country’s largest bpo service provider companies on her social media plat formand as an award winner for best services. Is prevalent. And this is where the real game starts first the centre is started with a small investment and then it is gradually trapped in its net…”

“As we have had a personal experience with greenpenn today we are sharing with you our experiences. Greene describes herself as one of the country’s largest bpo service provider companies on her social media plat formand as an award winner for best services. Is prevalent. And this is where the real game starts first the centre is started with a small investment and then it is gradually trapped in its net. First of all, let us tell you how the beginning started with us, here we did a process with greenpennon 29 august 2018. A good 11-month agreement for data search and mining started well after four to five weeks. Greenpenn began to show its colour gradually in paying, withholding payments and non-payment on time. The report was also delayed in the name and always forwarded to the female staff for all work. Repeated calls from the company for our bills, invoices, work, quality, etc., were mailed, but no response was given from the company! Neeraj goel, the ceo of this company would never come on call nor respond to any mail, then slowl your payout started to be stopped. And it went up from 1, 00, 000 to 1, 50, 000, and in return we were offered a new process, where we got an investment in the name of migration which is ₹ 360000, ₹1, 00, 000 in the name of handholding charges, and an 1, 00, 000 additional charge for giving the ivr facility in the name of domestic inbound process was stated. What we paid, for this process, our 20 candidates had to finalize us and like this process, in which there was no target of any kind for us in allconditions. We can also prove what we are saying so far as proof! Because we have enough evidence to prove each of our allegations, the terms and conditions of the process were introduced in a newway in between! Bills are not issued on time, and in the end the center is forced to close its business without payment. We signup the domestic inbound process (Medical blind process) with greenpenn at 120 per person / hour.in which greenpennshared the name of the end client company white coat for which we had to work, which is also shown as a partner of greenpenn on the white court businesswebsite! Going live on a 20seater process from 22 january 2020 to 31 january 2020, we worked for 1564hours with payout of 187600! Worked 3981 hours from 1st february’20 to 29thfebruary’20 with payout of rs. 4, 77, 620 and our work from 1st march 20 to 6thmarch 20 paid ₹ 1, 15, 200thus our total payout becomes 12, 49, 600 + gst and our investment becomes 4, 69, 000 + gst”soon the court will take its action on which we have full faith but there we can give so much evidence which is sufficient to prove the allegations”greenpenn could not pay nor answer!! We gave ₹59000 to the greenpenn for the ivr setup, neither tax invoice nor ivr setup, which we paid back. We gave ₹ 50000 for handholding, which was done by greenpen to get 11 months full time payout, greenpen could not get it in the first month itself, here too our refund is refunded
According to the agreement, mr. Amol had clarified in an email on 4 january 2020 that we have to go live on the inbound with five agents and outbound with 15 agents. And here, no basis of quality will be measured for the first 20 days, here too the greenpen did not stick to its point,
On the 5th of every month, greenpen will give us an invoice, by the 10th, we will have to confirm it and the bill will be credited on the 15th, it is clearly written in the csa agreement. But here too, the green pen failed as promised.
Our pay per person hour was 120 per hour which was guaranteed to be delivered without any cuts, without any quality. Because here we were working on a fixed payout, here also the greenpen was not successful on its point.
Everything from agreement to reconciliation is on record, so it is not possible for greenpenn to turn away from his word. The entire greenpan team is responsible for us, who have also coordinate about this process with us. Whose names are mr. Neeraj goyal, mr. Harjeet singh, mr. Manish pillai, uday kong, ms. Durga vyavare, mr. Amol bhosle, mr. Amit kolapkar and ms. Gayatri and all members of greenpen.
The biggest feature of greenpen is not to retract from everything or to answer at all. On-record from greenpenn is that you are eligible for your refund after 3 months. but when asked about the refund on our behalf, mr. Neeraj, the ceo of the greenpenn, first denied that what money is left of you. when they were reminded, they proposed a settlement , which we rejected outright because greenpenn has not paid us yet, which dues payment amount to rs 1249600. One thing to be kept in mind here is that we are now recall all our outstanding payments and our investment money from greenpenn.”

IN THE FACTS AND CIRCUMSTANCES, You all the noticees, are therefore, called upon to make good payment of Rs. 1,53,000/- [One Lakh and fifty three thousands] plus taxes, JOINTLY & SEVERALLY [irrespective of your excuse of lock-down which is falsified at the face of your own emails as stated herein-above paragraphs], to our client RPI Bhatia Solutions (OPC) Pvt Ltd., having it’s Registered office at Flat 101, Building B, Wing-1, Galaxy, Kalyan Shilphata Road, Near Toyota Showroom, Padle, Thane — 421204, paid to you no. 1, for the services-which you though promised, but not delivered, with interest @ 24% p.a. from 4th April 2021 [the date of instructions issued to Mr. Atul, to stop working on the project of our client company, by the noticee no. 3, in connivance with the noticee no. 2, the proprietor of the firm GREENPENN GROUP] till actual date of payment, as set out in the foregoing paragraphs and a sum of Rs. 5,00,000/-[Rs. Five Lakhs] towards loss of business and damages suffered by our client company, besides a sum of Rs. 20,000/- [Rs. Twenty Thousand] as notice charges, in order to save yourselves from the prosecution under the provisions of the Consumer Protection Act, as also under the provisions of sections 415 & 418 read with sections 34 & 120B of the Indian Penal Code, within a period of 15 days of receipt of this notice, failing which, our client shall have no other option than to file a case in the court of law of appropriate jurisdiction, at your own costs and risks.

In order to save the undue delay in the service of this notice by post, this notice is primarily being made over your e-mail IDs, and the date of service shall be reckoned from the date and time of delivery of the e-mail in the inbox of your e-mail account. However, hard copies of the notices will be sent to you through speed post/courier.

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  1. Sameer Singla

    Similar thing happened with us

    Neeraj Goel, Greenpen not returning our money, this side Sameer Singla (+91-9990412996) from we-call, legal team On Feb 17th 2021 confirmed to return back Rs. 192500 and said it will take 45 days, so when we can expect so many months passed?

    Earlier they were responding and giving us future dates, but now they even have stopped replying..