Send a legal notice

I want to send a legal notice to proprietor of Delhi based one cable manufacturing factory who took 15000 in advance (50% of total order value) for order confirmation from my end and he promised that he would deliver the order within 7-10 working days from the date of advance payment. Although, it had been more than 25 working days since advance payment from my end, he hadn't even started and during those days upon inquiring through phone calls, every time, he was simply hurling wrong statements, giving different timelines which were later proved to be fake only and completely fake promises like 'your order would be surely delivered by this date and so on'. I waited till one month since the date of advance payment, later I asked him to cancel the order and return my advance payment of 15000/- which he agreed to pay within a week from date of cancelling the order and even in returning the said amount also, he again started giving false promises and not at all returning the money despite repeated warning of severe actions to be taken against you if you won't return. Later I asked him to give his correct factory address in writing, that also he is not giving as address of his factory whichever he has mentioned on some of the platforms has been changed. on phone also, orally he is simply giving baseless statements about his correct factory address. so finally I want to take legal action against him and want to recover said amount with all other damages.