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Alkyl Amines Chemicals Ltd.

BSE: 506767 Sector: Industrials
NSE: ALKYLAMINE ISIN Code: INE150B01021
BSE 00:00 | 26 Feb 5058.75 -73.05
(-1.42%)
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5131.80

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5131.80

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5030.15

NSE 00:00 | 26 Feb 5051.40 -80.65
(-1.57%)
OPEN

5035.75

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5132.00

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5030.05

OPEN 5131.80
PREVIOUS CLOSE 5131.80
VOLUME 1529
52-Week high 5603.20
52-Week low 1030.00
P/E 40.98
Mkt Cap.(Rs cr) 10,330
Buy Price 5030.00
Buy Qty 2.00
Sell Price 5135.00
Sell Qty 1.00
OPEN 5131.80
CLOSE 5131.80
VOLUME 1529
52-Week high 5603.20
52-Week low 1030.00
P/E 40.98
Mkt Cap.(Rs cr) 10,330
Buy Price 5030.00
Buy Qty 2.00
Sell Price 5135.00
Sell Qty 1.00

Alkyl Amines Chemicals Ltd. (ALKYLAMINE) - Auditors Report

Company auditors report

To the Members of Alkyl Amines Chemicals Limited

Report on the audit of Standalone Financial Statements

Opinion

We have audited the accompanying standalone financial Statements of Alkyl AminesChemicals Limited ("the Company") which comprise the Balance Sheet as at March31 2020 the Statement of Profit and Loss (including Other Comprehensive Income) CashFlow Statement and the Statement of Change in Equity for the year then ended and a summaryof the significant accounting policies and other explanatory information (hereinafterreferred to as "the standalone financial statements").

In our opinion and to the best of our information and according to the explanationsgiven to us the aforesaid standalone financial statements give the information requiredby the Companies Act 2013 ("the Act") in the manner so required and give atrue and fair view in conformity with the Indian Accounting Standards prescribed undersection 133 of the Act read with the Companies (Indian Accounting Standards) Rules 2015as amended ("Ind AS") and other accounting principles generally accepted inIndia of the state of affairs of the Company as at March 31 2020 the profit and totalcomprehensive income its cashflows and changes in equity for the year ended on that date.

Basis for Opinion

We conducted our audit of the standalone financial statements in accordance with theStandards on Auditing specified under section 143(10) of the Act (SAs). Ourresponsibilities under those Standards are further described in the Auditor'sResponsibilities for the Audit of the Standalone Financial Statements section of ourreport. We are independent of the Company in accordance with the Code of Ethics issued bythe Institute of Chartered Accountants of India (ICAI) together with the independencerequirements that are relevant to our audit of the standalone financial statements underthe provisions of the Act and the Rules made there under and we have fulfilled our otherethical responsibilities in accordance with these requirements and the ICAI's Code ofEthics. We believe that the audit evidence we have obtained is sufficient and appropriateto provide a basis for our audit opinion on the standalone financial statements.

Key Audit Matters

Key audit matters are those matters that in our professional judgement were of mostsignificance in our audit of the standalone financial statements of the current period.These matters were addressed in the context of our audit of the standalone financialstatements as a whole and in forming our opinion thereon and we do not provide aseparate opinion on these matters. We have determined the matters described below to bethe key audit matters to be communicated in our report.

Sr.No. Key Audit Matter Auditor Response
1 Litigations - Contingencies Audit Procedures
The Company has litigations in respect of certain income tax matters. In this regard the Company has recognised provisions and has disclosed contingent liabilities as at March 31 2020. Significant management judgement is required to assess these matters and to determine the probability of material outflow of economic resources and whether a provision should be recognised or a disclosure should be made. Where considered relevant the management judgement is also supported with legal advice in these cases. Our audit procedures involved the following:
We focused on this area as the ultimate outcome of matters are uncertain and the positions taken by the management are based on the application of judgement related expert advice including those relating to interpretation of laws and regulations. Refer to Note 27 to the Standalone Financial Statements. • testing the effectiveness of controls around the recording and re- assessment of contingent liabilities;
• discussing with management the status and recent developments of these matters including their views on the likely outcome of each litigation and claim;
• performing our assessment of the underlying calculations supporting the provisions or other disclosures made in the standalone financial statements;
• evaluating the management's assessment of these matters and monitoring changes in the disputes with reference to subsequent orders passed and by way of discussion with the tax consultant where relevant in order to establish the appropriateness of the provisions / disclosures;
• evaluating management's assessment of the matters that are not disclosed as the probability of material outflow is considered to be remote by the management; and
• assessing the adequacy of the Company's disclosures.
2 Inventory Valuation Audit Procedures
Due to the lockdown imposed by the Government on account of COVID-19 it was Our audit procedures involved the following:
not possible for us to carry out the physical verification of inventories as at March 31 2020. However the management duly conducted the physical inventory counting internally as at the year end and provided to us certified physical counting sheets for all the locations for the purpose of Inventory Valuation. • performing alternative audit procedures to obtain sufficient appropriate audit evidence regarding the existence and condition of inventory;
• obtaining and evaluating the adequacy of the inventory physical verification instructions prepared and issued by the management to determine if the instructions provided were appropriate and comprehensive;
We determined the above area as a Key Audit Matter due to the materiality of the inventory figure appearing in the Standalone Financial Statements. • evaluating the control design in respect of the inventory verification process;
• testing the effectiveness of controls around the recording of inventory during the period of the audit;
• ensuring that such controls encompass the processes around purchase and sales which eventually impact the stock balance held at the end of the reporting period;
• verifying the documentation supporting purchases and subsequent sale of inventory items on a sample basis;
• ascertaining that these procedures indirectly provide evidence that stock balance which was not physically verified actually existed as on the date to enable subsequent sales and indirectly support and corroborate the assertion of existence;
• where the Company has inventory under the custody and control of a third partyobtaining direct confirmations from the respective third parties; and
• obtaining audit evidence regarding the location and condition of the inventory including documentary records about purchases/sales in case of inventories in transit.
3 Provision for Expected Credit Losses (ECL) of trade receivables Audit Procedures
The Company determines the provision for credit losses based on the Company's historical observed default rates which are negligible over the years. The Company considered current and anticipated future economic conditions relating to industries the Company deals with to calibrate the provision matrix to adjust the historical credit loss experience with forward-looking information. While determining expected credit loss the Company has also considered credit reports and other related credit information for its customers to estimate the probability of default in future and has taken into account estimates of possible effect from the pandemic relating to COVID-19. We focused on this area as the Company has exercised significant judgement in determining the ECL and accordingly has not provided for any such allowance for the credit losses as at the balance sheet date. Refer to Note 2(g) to the Standalone Financial Statements. Our audit procedures involved the following:
• testing the effectiveness of controls over the development of the methodology for the Provision for expected credit losses;
• discussing with management about their consideration of the current and estimated future economic conditions;
• evaluating the completeness and accuracy of information used in the estimation of probability of default by the customers;
• performing our assessment of the past experience supporting the non- provisioning or other disclosures made in the standalone financial statements;
• verifying subsequent collection from the customers after the balance sheet date with respect to the outstanding trade receivables in order to establish the appropriateness for not making the provisions; and
• assessing the adequacy of the Company's disclosures.

Other Information

The Company's Board of Directors is responsible for the preparation of the otherinformation. The other information comprises the information included in the Report onCorporate Governance Shareholder information and Management Discussion and Analysis

Board's Report including Annexures to Board's Report Business Responsibility ReportCorporate Governance and Shareholder's Information but does not include the standalonefinancial statements and our auditor's report thereon.

Our opinion on the standalone financial statements does not cover the other informationand we do not express any form of assurance conclusion thereon.

In connection with our audit of the standalone financial statements our responsibilityis to read the other information and in doing so consider whether the other informationis materially inconsistent with the standalone financial statements or our knowledgeobtained during the course of our audit or otherwise appears to be materially misstated.If based on the work we have performed we conclude that there is a material misstatementof this other information we are required to report that fact. We have nothing to reportin this regard.

Management's Responsibility for the Standalone Financial Statements

The Company's Board of Directors is responsible for the matters stated in section134(5) of the Act with respect to the preparation of these standalone financialstatements that give a true and fair view of the financial position financialperformance total comprehensive income changes in equity and cash flows of the Companyin accordance with the Ind AS and other accounting principles generally accepted in India.This responsibility also includes maintenance of adequate accounting records in accordancewith the provisions of the Act for safeguarding the assets of the Company and forpreventing and detecting frauds and other irregularities; selection and application ofappropriate accounting policies; making judgement and estimates that are reasonable andprudent; and design implementation and maintenance of adequate internal financialcontrols that were operating effectively for ensuring the accuracy and completeness ofthe accounting records relevant to the preparation and presentation of the standalonefinancial statements that give a true and fair view and are free from materialmisstatement whether due to fraud or error.

In preparing the standalone financial statements management is responsible forassessing the Company's ability to continue as a going concern disclosing as applicablematters relating to going concern and using the going concern basis of accounting unlessmanagement either intends to liquidate the Company or cease operations or has norealistic alternative but to do so.

The Board of Directors is responsible for overseeing the Company's financial reportingprocess.

Auditor's Responsibility for the Standalone Financial Statements

Our objectives are to obtain reasonable assurance about whether the standalonefinancial statements as a whole are free from material misstatement whether due tofraud or error and to issue an auditor's report that includes our opinion. Reasonableassurance is a high level of assurance but is not a guarantee that an audit conducted inaccordance with SAs will always detect a material misstatement when it exists.Misstatements can arise from fraud or error and are considered material if individuallyor in the aggregate they could reasonably be expected to influence the economic decisionsof users taken on the basis of these standalone financial statements. As part of an auditin accordance with SAs we exercise professional judgement and maintain professionalskepticism throughout the audit. We also:

• Identify and assess the risks of material misstatement of the standalonefinancial statements whether due to fraud or error design and perform audit proceduresresponsive to those risks and obtain audit evidence that is sufficient and appropriate toprovide a basis for our opinion. The risk of not detecting a material misstatementresulting from fraud is higher than for one resulting from error as fraud may involvecollusion forgery intentional omissions misrepresentations or the override of internalcontrol.

• Obtain an understanding of internal financial controls relevant to the audit inorder to design audit procedures that are appropriate in the circumstances. Under section143(3)(i) of the Act we are also responsible for expressing our opinion on whether theCompany has an adequate internal financial controls system in place and the operatingeffectiveness of such controls.

• Evaluate the appropriateness of accounting policies used and the reasonablenessof accounting estimates and related disclosures made by management.

• Conclude on the appropriateness of management's use of the going concern basisof accounting and based on the audit evidence obtained whether a material uncertaintyexists related to events or conditions that may cast significant doubt on the Company'sability to continue as a going concern. If we conclude that a material uncertainty existswe are required to draw attention in our auditor's report to the related disclosures inthe standalone financial statements or if such disclosures are inadequate to modify ouropinion. Our conclusions are based on the audit evidence obtained up to the date of ourauditor's report. However future events or conditions may cause the Company to cease tocontinue as a going concern.

• Evaluate the overall presentation structure and content of the standalonefinancial statements including the disclosures and whether the standalone financialstatements represent the underlying transactions and events in a manner that achieves fairpresentation.

Materiality is the magnitude of misstatements in the standalone financial statementsthat individually or in aggregate makes it probable that the economic decisions of areasonably knowledgeable user of the financial statements may be influenced. We considerquantitative materiality and qualitative factors in (i) planning the scope of our auditwork and in evaluating the results of our work; and (ii) to evaluate the effect of anyidentified misstatements in the financial statements.

We communicate with those charged with governance regarding among other matters theplanned scope and timing of the audit and significant audit findings including anysignificant deficiencies in internal control that we identify during our audit.

We also provide those charged with governance with a statement that we have compliedwith relevant ethical requirements regarding independence and to communicate with themall relationships and other matters that may reasonably be thought to bear on ourindependence and where applicable related safeguards.

From the matters communicated with those charged with governance we determine thosematters that were of most significance in the audit of the standalone financial statementsof the current period and are therefore the key audit matters. We describe these mattersin our auditor's report unless law or regulation precludes public disclosure about thematter or when in extremely rare circumstances we determine that a matter should not becommunicated in our report because the adverse consequences of doing so would reasonablybe expected to outweigh the public interest benefits of such communication.

Other Matter

Due to the COVID-19 pandemic and the resultant lockdown and other restrictions imposedby the Government and local authorities the audit processes were carried out based on theremote access to the records and documents which were made available by the managementthrough digital medium.

Our opinion is not modified in respect of this matter.

Report on Other Legal and Regulatory Requirements

1. As required by Section 143 (3) of the Act we report that:

(a) We have sought and obtained all the information and explanations which to the bestof our knowledge and belief were necessary for the purposes of our audit.

(b) In our opinion proper books of account as required by law have been kept by theCompany so far as it appears from our examination of those books.

(c) The Balance Sheet the Statement of Profit and Loss including Other ComprehensiveIncome Cash Flow Statement and Statement of Change in Equity dealt with by this Reportare in agreement with the books of account.

(d) In our opinion the aforesaid standalone financial statements comply with theIndian Accounting Standards specified under Section 133 of the Act as applicable.

(e) On the basis of the written representations received from the directors as on March31 2020 and taken on record by the Board of Directors none of the directors isdisqualified as on March 31 2020 from being appointed as a director in terms of Section164 (2) of the Act.

(f) With respect to the adequacy of the internal financial controls over financialreporting of the company and the operating effectiveness of such controls refer to ourseparate Report in "Annexure A". Our report expresses an unmodified opinion onadequacy and operating effectiveness of the Company's internal financial controls overfinancial reporting.

(g) With respect to the other matters to be included in the Auditor's Report inaccordance with Rule 11 of the Companies (Audit and Auditors) Rules 2014 as amended inour opinion and to the best of our information and according to the explanations given tous: i. The Company has disclosed the impact of pending litigations on its financialposition in its standalone financial statements – Refer Note 27 to the standalonefinancial statements; ii. The Company did not have any material foreseeable losses onlong-term contracts including derivative contracts. iii. There has been no delay intransferring amounts required to be transferred to the Investor Education and ProtectionFund by the Company.

2. With respect to the matter to be included in the Auditor's Report under section197(16):

In our opinion and according to the information and explanations given to us theremuneration paid by the Company to its directors during the current year is in accordancewith the provisions of section 197 read with Schedule V of the Act.

3. As required by the Companies (Auditor's Report) Order 2016 ("the Order")issued by the Central Government of India in terms of sub section (11) of section 143 ofthe Companies Act 2013 we give in the "Annexure B" a statement on the mattersspecified in paragraph 3 and 4 of the Order.

Place : Mumbai Date : June 23 2020

For N. M. Raiji & Co.

Chartered Accountants Firm's Registration Number: 108296W

Vinay D. Balse

Partner Membership Number: 39434 UDIN : 20039434AAAABW1070

ANNEXURE "A"

TO THE INDEPENDENT AUDITORS' REPORT OF EVEN DATE ON THE STANDALONE FINANCIAL STATEMENTSOF ALKYL AMINES CHEMICALS LIMITED

(Referred to in Paragraph 1 point (f) under the heading of

"Report on Other Legal and Regulatory Requirements" of our report of evendate)

Report on the Internal Financial Controls Over Financial Reporting under Clause(i) ofSub-section 3 of Section 143 of the Companies Act 2013 ("the Act")

We have audited the Internal Financial Controls over financial reporting of AlkylAmines Chemical Limited ("the Company") as at March 31 2020 in conjunctionwith our audit of the standalone financial statements of the Company for the year ended onthat date.

Management's Responsibility for Internal Financial Controls

The Company's management is responsible for establishing and maintaining internalfinancial controls based on the internal control over financial reporting criteriaestablished by the Company considering the essential components of internal controlstated in the Guidance Note on Audit of Internal Financial Controls over FinancialReporting issued by the Institute of Chartered Accountants of India. Theseresponsibilities include the design implementation and maintenance of adequate internalfinancial controls that were operating effectively for ensuring the orderly and efficientconduct of its business including adherence to company's policies the safeguarding ofits assets the prevention and detection of frauds and errors the accuracy andcompleteness of the accounting records and the timely preparation of reliable financialinformation as required under the Companies Act 2013.

Auditors' Responsibility

Our responsibility is to express an opinion on the Company's internal financialcontrols over financial reporting based on our audit. We conducted our audit in accordancewith the Guidance Note on Audit of Internal Financial Controls over Financial Reporting(the "Guidance Note") issued by the Institute of Chartered Accountants of Indiaand the Standards on Auditing prescribed under section 143(10) of the Companies Act 2013to the extent applicable to an audit of internal financial controls. Those Standards andthe Guidance Note require that we comply with ethical requirements and plan and performthe audit to obtain reasonable assurance about whether adequate internal financialcontrols over financial reporting was established and maintained and if such controlsoperated effectively in all material respects.

Our audit involves performing procedures to obtain audit evidence about the adequacy ofthe internal financial controls system over financial reporting and their operatingeffectiveness. Our audit of internal financial controls over financial reporting includedobtaining an understanding of internal financial controls over financial reportingassessing the risk that a material weakness exists and testing and evaluating the designand operating effectiveness of internal control based on the assessed risk. The proceduresselected depend on the auditor's judgement including the assessment of the risks ofmaterial misstatement of the financial statements whether due to fraud or error.

We believe that the audit evidence we have obtained is sufficient and appropriate toprovide a basis for our audit opinion on the Company's internal financial controls systemover financial reporting.

Meaning of Internal Financial Controls over Financial Reporting

A company's internal financial control over financial reporting is a process designedto provide reasonable assurance regarding the reliability of financial reporting and thepreparation of standalone financial statements for external purposes in accordance withgenerally accepted accounting principles. A company's internal financial control overfinancial reporting includes those policies and procedures that (1) pertain to themaintenance of records that in reasonable detail accurately and fairly reflect thetransactions and dispositions of the assets of the company; (2) provide reasonableassurance that transactions are recorded as necessary to permit preparation of standalonefinancial Statements in accordance with generally accepted accounting principles and thatreceipts and expenditures of the company are being made only in accordance withauthorisations of management and directors of the company; and (3) provide reasonableassurance regarding prevention or timely detection of unauthorized acquisition use ordisposition of the company's assets that could have a material effect on the financialStatements.

Inherent Limitations of Internal Financial Controls over Financial Reporting

Because of the inherent limitations of internal financial controls over financialreporting including the possibility of collusion or improper management override ofcontrols material misstatements due to error or fraud may occur and not be detected.Also projections of any evaluation of the internal financial controls over financialreporting to future periods are subject to the risk that the internal financial controlover financial reporting may become inadequate because of changes in conditions or thatthe degree of compliance with the policies or procedures may deteriorate.

Opinion

In our opinion to the best of our information and according to the explanation givento us the Company has in all material respects an adequate Internal Financial Controlssystem over financial reporting and such Internal Financial Controls over financialreporting were operating effectively as at March 31 2020 based on the internal controlover financial reporting criteria established by the Company considering the essentialcomponents of internal control stated in the Guidance Note on Audit of Internal FinancialControls over Financial Reporting issued by the Institute of Chartered Accountants ofIndia.

Place: Mumbai Date: June 23 2020

For N. M. Raiji & Co.

Chartered Accountants Firm's Registration Number: 108296W

Vinay D. Balse

Partner Membership Number: 039434 UDIN: 20039434AAAABW1070

ANNEXURE - B

TO THE INDEPENDENT AUDITORS' REPORT OF EVEN DATE ON THE STANDALONE FINANCIAL STATEMENTSOF ALKYL AMINES CHEMICALS LIMITED

(Referred to in Paragraph 3 under the heading of

"Report on Other Legal and Regulatory Requirements" of our report of evendate) i. (a) The Company has maintained proper records showing full particularsincluding quantitative details and situation of Property Plant & Equipment (PPE).

(b) The Company has a program of verification to cover all the items of fixed assets ina phased manner which in our opinion is reasonable having regard to the size of theCompany and the nature of its assets. Pursuant to the program certain PPE were physicallyverified by the management during the year. According to the information and explanationsgiven to us discrepancies noticed on physical verification of assets were not materialand the same have been properly dealt with in the books of account.

(c) According to the information and explanations given to us the records examined byus and based on the examination of the records provided to us we report that the titledeeds comprising all the immovable properties of land and buildings which are freeholdare held in the name of the Company as at the balance sheet date. In respect of immovableproperties of land that have been taken on lease and disclosed under Right to Use of Assetin the standalone financial statements the lease agreements are in the name of theCompany except in the case of leasehold land situated at Kurkumbh Plot No. D-6/2 taken onlease from Maharashtra Industrial Development Corporation for which lease deed is yet tobe executed. ii. Inventories other than stocks in transit and inventories lying withthird parties have been physically verified during the year by the Management. In respectof Company's inventories with third parties physical verification has been carried out.In respect of stock in transit at the year end the necessary documentary evidences havebeen obtained. In our opinion the frequency of verification is reasonable. Discrepanciesnoticed on physical verification of stocks were not material and the same have beenproperly dealt with in the books of account. iii. According to the information andexplanations given to us the Company has not granted any loans secured or unsecured tocompanies firms limited liability partnerships or other parties covered in the registermaintained under section 189 of the Companies Act 2013 (the "Act").Consequently sub-clauses (a) (b) & (c) of clause (iii) of paragraph 3 of the Orderare not applicable to the Company. iv. In our opinion and according to the information andexplanations given to us the Company has complied with the provisions of Sections 185 and186 of the Act in respect of investments made. The Company has not granted any loans orprovided guarantees and securities. Consequently clause (iv) of paragraph 3 of the Orderis not applicable to the Company. v. According to the information and explanations givento us the Company has not accepted any deposits during the year. Consequently clause (v)of paragraph 3 of the Order is not applicable to the Company. vi. We have broadly reviewedthe cost records maintained by the Company pursuant to the Companies (Cost Records andAudit) Rules 2014 as specified by the Central Government under sub-section (1) ofSection 148 of the Companies Act 2013 and are of the opinion that prima facie theprescribed cost records have been made and maintained. We have however not made adetailed examination of the cost records with a view to determine whether they areaccurate or complete. vii. According to the information and explanations given to us andon the basis of our examination of the books of account in respect of statutory dues: (a)the Company has been generally regular in depositing with the appropriate authoritiesundisputed statutory dues including Provident Fund Employees' state insuranceIncome-tax Customs Duty Goods and Service Tax Cess and other statutory dues whereverapplicable. There were no undisputed amounts payable in respect of the above statutorydues in arrears as at 31st March 2020 for a period of more than six months from the datethey became payable except in the case of electricity duty (on captive power generated)in Kurkumbh aggregating Rs. 236.29lakhs (previous year - Rs. 168.61 lakhs) with theappropriate authorities

(b) the following dues have not been paid on account of disputes with the respectiveauthorities:

Nature of Statute Nature of Dues Amount (Rs. In lakhs) Period Forum where dispute is pending Remarks
Income Tax Disallowance 144.10 AY 2004-2005 The Assessing Officer Amount of Deposit
Act1961 Of Expenditure/ AY 2007-2008 Rs. 131.16 lakhs
Deductions AY 2009-2010
AY 2010-2011
AY 2011-2012
AY 2012-2013
AY 2013-2014
AY 2018-2019
Income Tax Income Tax & 65.28 AY 2003-2004 CIT (Appeals) Amount of Deposit
Act1961 Interest AY 2009-2010 Rs. 10.62 lakhs
AY 2011-2012
Central Excise Dispute relating 914.40 FY 2002-2003 Customs Excise and Service Amount of Deposit
Act 1944 to Cenvat Credit to 2010-2011 Tax Appellate tribunal Rs. 21.07 lakhs
(Interest and
Penalty)

Except for the above there are no dues in respect of income-tax customs duty goodsand service tax and cess which have not been deposited with the appropriate authoritieson account of any dispute. viii. In our opinion and according to the information andexplanations given to us the Company has not defaulted in the repayment of dues tofinancial institutions or banks. The Company has not raised any monies from Government orFinancial Institutions and does not have any outstanding debentures. ix. The Company hasnot raised money by way of initial public offer or further public offer (including debtinstruments) during the year. In our opinion and according to the information andexplanations given to us the term loan has been applied for the purpose for which it wasobtained. x. To the best of our knowledge and according to the information andexplanations given to us no material fraud by the Company or on the Company by itsofficers or employees has been noticed or reported during the year. xi. In our opinion andaccording to the information and explanations given to us the Company has paid/providedmanagerial remuneration in accordance with the requisite approvals mandated by theprovisions of section 197 read with Schedule V to the Act. xii. In our opinion andaccording to the information and explanations given to us the Company is not a NidhiCompany. Consequently clause (xii) of paragraph 3 of the Order is not applicable to theCompany. xiii. In our opinion and according to the information and explanations given tous all transactions with related parties are in compliance with section 177 and 188 ofCompanies Act 2013 where applicable and corresponding details have been disclosed inthe standalone financial Statements as required by the applicable Indian accountingstandards. xiv. In our opinion and according to the information and explanations given tous the Company has not made any preferential allotment or private placement of shares orfully or partly convertible debentures during the year. Consequently requirement underclause (xiv) of paragraph 3 of the Order is not applicable to the Company. xv. In ouropinion and according to the information and explanations given to us the Company has notentered into non-cash transactions with its directors or persons connected with him andhence provisions of section 192 of the Act are not applicable. Consequently requirementunder clause (xv) of paragraph 3 of the Order is not applicable to the Company. xvi. Tothe best of our knowledge and belief the Company is not required to be registered undersection 45-IA of the Reserve Bank of India Act 1934.

Place: Mumbai Date: June 23 2020

For N. M. Raiji & Co.

Chartered Accountants Firm's Registration Number: 108296W

Vinay D. Balse

Partner Membership Number: 039434 UDIN: 20039434AAAABW1070

.