https://www.scconline.com/blog/post/2020/10/10/levy-of-liquidated-damages-by-one-party-to-a-contract-when-arbitrable-comments-in-light-of-sc-judgment-of-mitra-guha-v-ongc/
Levy of Liquidated Damages by one party to a contract: When arbitrable? Comments in light of SC Judgment of Mitra Guha v. ONGC