27. The petitioner responded to the aforesaid Legal Notice, dated 30th March, 2020, vide letter (through counsel), dated 8th April, 2020. The petitioner categorically denied having received the communications, dated 26th February, 2020 and 13th March, 2020, addressed by the respondent. Apropos the allegation that the petitioner had failed to obtain the requisite licenses/approvals/permissions/NOCs, the petitioner pointed out, yet again, that the communications, from the respondent, were completely silent, regarding the specifics and particulars of the licenses/approvals/permissions/NOCs, which the petitioner had yet to procure or obtain. The petitioner reiterated, emphatically, that there had been no default on the part of the petitioner, in obtaining any such license/approval/permission or NOC. It was also pointed out that the respondent had inspected all the documents and licenses, before entering into the MSA. The plea of the petitioner having failed to obtain requisite licenses/approvals/permissions or NOCs, it was therefore submitted, was merely a ruse in order to avoid the respondent’s obligations under the MSA. This, it was submitted, was also apparent from the e-mail, dated 25th February, 2020, which purported to terminate the MSA, not on the ground of failure, on the part of the petitioner, to obtain licenses/approvals/ permissions/NOCs, but because the respondent expressed its inability to continue with the operations at the subject property. The accusation of failure, on the part of the petitioner, to obtain licenses/approvals/ permissions/NOCs, was, therefore, it was alleged, merely manufactured, by the respondent, to avoid the fulfilment of its obligations under the MSA. It was further pointed out that the petitioner had never accepted the
