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Ambuja Cements Ltd.

BSE: 500425 Sector: Industrials
NSE: AMBUJACEM ISIN Code: INE079A01024
BSE 00:00 | 27 Jan 381.15 -78.95
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NSE 00:00 | 27 Jan 380.45 -79.75
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OPEN 457.95
PREVIOUS CLOSE 460.10
VOLUME 2689531
52-Week high 598.15
52-Week low 274.00
P/E 37.96
Mkt Cap.(Rs cr) 75,683
Buy Price 0.00
Buy Qty 0.00
Sell Price 0.00
Sell Qty 0.00
OPEN 457.95
CLOSE 460.10
VOLUME 2689531
52-Week high 598.15
52-Week low 274.00
P/E 37.96
Mkt Cap.(Rs cr) 75,683
Buy Price 0.00
Buy Qty 0.00
Sell Price 0.00
Sell Qty 0.00

Ambuja Cements Ltd. (AMBUJACEM) - Auditors Report

Company auditors report

To The Members of

Ambuja Cements Limited

REPORT ON THE AUDIT OF THE STANDALONE FINANCIAL STATEMENTS

Opinion

We have audited the accompanying standalone financial statements of Ambuja CementsLimited ("the Company") which comprise the Balance Sheet as at 31st December2021 and the Statement of Profit and Loss (including Other Comprehensive Income) theCash Flow Statement and the Statement of Changes in Equity for the year then ended and asummary of significant accounting policies and other explanatory information and whichincludes a joint operation accounted on proportionate basis.

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 a trueand fair view in conformity with the Indian Accounting Standards prescribed under section133 of the Act read with the Companies (Indian Accounting Standards) Rules 2015 asamended ("Ind AS") and other accounting principles generally accepted in Indiaof the state of affairs of the Com pany as at 31 st Decem ber 2021 and its profit totalcomprehensive income its cash flows and the changes in equity for the year ended on thatdate.

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'sResponsibility for the Audit of the Standalone Financial Statements section of our report.We are independent of the Company in accordance with the Code of Ethics issued by theInstitute of Chartered Accountants of India (ICAI) together with the ethical requirementsthat are relevant to our audit of the standalone financial statements under the provisionsof the Act and the Rules made thereunder and we have fulfilled our other ethicalresponsibilities in accordance with these requirements and the ICAI's Code of Ethics. Webelieve that the audit evidence obtained by us is sufficient and appropriate to provide abasis for our audit opinion on the standalone financial statements.

Emphasis of Matter

We draw attention to the following matters in Notes 48(b)(i) and 48(b)(ii) to thestandalone financial statements:

a. In terms of the order dated 31st August 2016 the Competition Commission of India(CCI) had imposed a penalty of Rs. 1163.91 crores for alleged contravention of theprovisions of the Competition Act 2002 (the Competition Act) by the Company. On theCompany's appeal National Company Law Appellate Tribunal (NCLAT) which replaced theCompetition Appellate Tribunal (COMPAT) effective 26th May 2017 in its order passed on25th July 2018 had upheld the CCI's Order. The Company's appeal against the saidjudgement of NCLAT before the Hon'ble Supreme Court was admitted vide its order dated 5thOctober 2018 with a direction that the interim order passed by the Tribunal wouldcontinue.

b. In a separate matter pursuant to a reference filed by the Government of Haryanathe CCI vide its order dated 19th January 2017 had imposed a penalty of Rs. 29.84 croresfor alleged contravention of the provisions of the Competition Act. On Company's filing anappeal together with application for interim stay against payment of penalty COMPAT hasstayed the penalty pending hearing of the application. This matter is listed before theNCLAT for hearing.

Based on the Company's assessment on the outcome of these appeals supported by theadvice of external legal counsel the Company is of the view that no provision isnecessary in respect of these matters in these Standalone Financial Statements.

Our opinion is not modified in respect of these matters.

Key Audit Matters

Key audit matters are those matters that in our professional judgment 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.

Key Audit Matters Auditor's Responses
1 Litigation Claims and Contingent Liabilities: Principal audit procedures performed:
(Refer Notes 3J and 48 read along with Emphasis of Matter in Independent Auditor's Report of the standalone financial statements) • We understood the processes evaluated the design and implementation of controls and tested the operating effectiveness of the Company's controls over the recording and re-assessment of uncertain legal positions claims (including claims receivable) and contingent liabilities.
The Company is exposed to a variety of different laws regulations and interpretations thereof which encompasses indirect taxation and legal matters. In the normal course of business provisions and contingent liabilities may arise from legal proceedings including regulatory and other Governmental proceedings constructive obligations as well as investigations by authorities and commercial claims. • We held discussions with senior management including the person responsible for legal and compliance to obtain an understanding of the factors considered by management in classification of the matter as ‘probable' ‘possible' and ‘remote'.
Based on the nature of regulatory and legal cases management applies significant judgement when considering whether and how much to provide for the potential exposure of each matter. These estimates could change substantially over time as new facts emerge as each legal case or matters progresses. • For those matters where Management concluded that no provision should be recorded we also considered the adequacy and completeness of the Company's disclosures made in relation to contingent liabilities.
Given the different views possible basis the interpretations complexity and the magnitude of the potential exposures and the judgement necessary to determine required disclosures this is a key audit matter. • Examined the Company's legal expenses on sample basis and read the minutes of the board meetings and the legal compliance committee in order to ensure completeness.
• We read the correspondence from Court authorities and considered legal opinion obtained by the Management from external law firms to evaluate the basis used for provisions recognised or the disclosures made in the standalone financial statements.
• We also obtained direct legal confirmations for significant matters from the law firms handling such matters to corroborate management's conclusions.
2. Income tax provision : Principal audit procedures performed:
(Refer Notes 3P 30 31 and 48 of the standalone financial statements) • Our audit procedures to test uncertain tax positions included understanding processes evaluation of design and implementation of controls and testing of operating effectiveness of the Company's controls over provision for taxation assessment of uncertain tax positions and disclosure of contingencies.
This matter has been identified as a Key Audit Matter due to the significant level of management judgement required in the estimation of provision for income taxes including any write back of provisions due to the following factors: • Obtained details of completed tax assessments and demands as of December 312021 from the management.
• Existence of multiple uncertain tax positions leading to multiple disputes / litigations • We discussed with appropriate senior management personnel independently assessed management's estimate of the possible outcome of the disputed cases; and evaluated the Management's underlying key assumptions in estimating the tax provisions.
• Provision for tax involves interpretation of various rules and law. It also involves consideration of on-going disputes and disclosures of related contingencies. • We considered legal precedence and other rulings in evaluating management's position on these uncertain tax positions the provisions made and/or write back of the provisions.
• We also involved our direct tax specialist in evaluating management's assessment for the uncertain tax positions.
• For those matters where Management concluded that no provision should be recorded we also considered the adequacy and completeness of the Company's disclosures made in relation to contingent liabilities.

Information Other than the Financial Statements and Auditor's Report Thereon

The Company's Board of Directors is responsible for the other information. The otherinformation comprises the information included in the Directors' report and ManagementDiscussion and Analysis Report on Corporate Governance and Business Responsibilityreport but does not include the consolidated financial statements standalone financialstatements and our auditor's report thereon.

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

• In connection with our audit of the standalone financial statements ourresponsibility is to read the other information and consider whether the otherinformation is materially inconsistent with the standalone financial statements or ourknowledge obtained during the course of our audit or otherwise appears to be materiallymisstated.

• If based on the work we have performed we conclude that there is a materialmisstatement of this other information we are required to report that fact. We havenothing to report in this regard.

Management's Responsibility for the Standalone Financial Statements

The respective Board of Directors of the Company and its Joint Operation Company areresponsible for the matters stated in section 134(5) of the Act with respect to thepreparation of these standalone financial statements that give a true and fair view of thefinancial position financial performance including other comprehensive income cash flowsand changes in equity of the Company in accordance with the Ind AS and other accountingprinciples generally accepted in India. This responsibility also includes maintenance ofadequate accounting records in accordance with the provisions of the Act for safeguardingthe assets of the respective companies and for preventing and detecting frauds and otherirregularities; selection and application of appropriate accounting policies; makingjudgments and estimates that are reasonable and prudent; and design implementation andmaintenance of adequate internal financial controls that were operating effectively forensuring the accuracy and completeness of the accounting records relevant to thepreparation and presentation of the standalone financial statements that give a true andfair view and are free from material misstatement 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 related to going concern and using the going concern basis of accounting unlessmanagement either intends to liquidate the Company or to cease operations or has norealistic alternative but to do so.

Those Board of Directors are also responsible for overseeing the Company's financialreporting process.

Auditor's Responsibility for the Audit of 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 to fraudor error and to issue an auditor's report that includes our opinion. Reasonable assuranceis a high level of assurance but is not a guarantee that an audit conducted in accordancewith SAs will always detect a material misstatement when it exists. Misstatements canarise from fraud or error and are considered material if individually or in theaggregate they could reasonably be expected to influence the economic decisions of userstaken on the basis of these standalone financial statements.

As part of an audit in accordance with SAs we exercise professional judgment andmaintain professional skepticism 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 control 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 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 the 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 standalone financial statements may be influenced. Weconsider quantitative materiality and qualitative factors in (i) planning the scope of ouraudit work and in evaluating the results of our work; and (ii) to evaluate the effect ofany identified misstatements in the standalone 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.

Report on Other Legal and Regulatory Requirements

1. As required by Section 143(3) of the Act based on our audit we report to theextent applicable 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 and its joint operation so far as it appears from our examination of those books.

c. The Balance Sheet the Statement of Profit and Loss including Other ComprehensiveIncome the Cash Flow Statement and Statement of Changes in Equity dealt with by thisReport are in agreement with the relevant books of account.

d. In our opinion the aforesaid standalone financial statements comply with the Ind ASspecified under Section 133 of the Act.

e. On the basis of the written representations received from the directors as on 31stDecember 2021 taken on record by the Board of Directors of the Company and the report ofthe statutory auditors of its joint operation none of the directors of the Company andits joint operation is disqualified as on 31st December 2021 from being appointed as adirector in terms of Section 164(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 onthe adequacy 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 the requirements of section 197(16) of the Act as amended

In our opinion and to the best of our information and according to the explanationsgiven to us the remuneration paid by the Company to its directors during the year is inaccordance with the provisions of section 197 of the Act.

h. 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 48 to the standalonefinancial statements;

ii. The Company did not have any long-term contracts including derivative contracts forwhich there were any material foreseeable losses.

iii. There has been no delay in transferring amounts required to be transferred tothe Investor Education and Protection Fund by the Company on the basis of informationavailable with the Company.

2. As required by the Companies (Auditor's Report) Order 2016 ("the Order")issued by the Central Government in terms of Section 143(11) of the Act we give in"Annexure B" a statement on the matters specified in paragraphs 3 and 4 of theOrder.

ANNEXURE "A" TO THE INDEPENDENT AUDITOR'S REPORT

(Referred to in paragraph 1 (f) under ‘Report on Other Legal and RegulatoryRequirements' section of our report of even date on the Standalone financial statements ofAmbuja Cements Limited as at and for the year ended 31st December 2021)

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 AmbujaCements Limited ("the Company") as of 31st December 2021 in conjunction withour audit of the standalone financial statements of the Company for the year ended on thatdate.

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 control statedin the Guidance Note on Audit of Internal Financial Controls Over Financial Reportingissued by the Institute of Chartered Accountants of India. These responsibilities includethe design implementation and maintenance of adequate internal financial controls thatwere operating effectively for ensuring the orderly and efficient conduct of its businessincluding adherence to the Company's policies the safeguarding of its assets theprevention and detection of frauds and errors the accuracy and completeness of theaccounting records and the timely preparation of reliable financial information asrequired under the Companies Act 2013.

AUDITOR'S RESPONSIBILITY

Our responsibility is to express an opinion on the Company's internal financialcontrols over financial reporting of the Company based on our audit. We conducted ouraudit in accordance with the Guidance Note on Audit of Internal Financial Controls OverFinancial Reporting (the "Guidance Note") issued by the Institute of CharteredAccountants of India and the Standards on Auditing prescribed under Section 143(10) of theCompanies Act 2013 to the extent applicable to an audit of internal financial controls.Those Standards and the Guidance Note require that we comply with ethical requirements andplan and perform the audit to obtain reasonable assurance about whether adequate internalfinancial controls over financial reporting was established and maintained and if suchcontrols operated 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 financial statements for external purposes in accordance with generallyaccepted accounting principles. A company's internal financial control over financialreporting includes those policies and procedures that

(1) pertain to the maintenance of records that in reasonable detail accurately andfairly reflect the transactions and dispositions of the assets of the Company;

(2) provide reasonable assurance that transactions are recorded as necessary to permitpreparation of financial statements in accordance with generally accepted accountingprinciples and that receipts and expenditures of the Company are being made only inaccordance with authorisations of management and directors of the Company; and

(3) provide reasonable assurance regarding prevention or timely detection ofunauthorised acquisition use or disposition of the Company's assets that could have amaterial effect on the financial statements.

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 explanations 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 31st December 2021 based on the criteria forinternal financial control over financial reporting established by the Company consideringthe essential components of internal control stated in the Guidance Note on Audit ofInternal Financial Controls Over Financial Reporting issued by the Institute of CharteredAccountants of India.

ANNEXURE "B" TO THE INDEPENDENT AUDITOR'S REPORT

(Referred to in paragraph 2 under ‘Report on Other Legal and RegulatoryRequirements' section of our report of even date on the Standalone financial statementsfor the year ended 31st December 2021 of Ambuja Cements Limited)

(i) (a) The Company has maintained proper records showing full particulars includingquantitative details and situation of fixed assets.

(b) The Company has a programme of verification of fixed assets to cover all the itemsin a phased manner over a period of two years which in our opinion is reasonable havingregard to the size of the Company and the nature of its assets. Pursuant to the programmecertain fixed assets were physically verified by the Management during the year. Accordingto the information and explanations given to us no material discrepancies were noticed onsuch verification.

(c) (i) In our opinion and according to the information and explanations given to usand the records examined by us and based on the examination of the registered sale deed /transfer deed / conveyance deed / other relevant records evidencing title of the companywe report that the title deeds comprising all the immovable properties of land andbuildings which are freehold other than self constructed assets included in property plantand equipment are held in the name of the Company as at the balance sheet date exceptthe following which are not held in the name of the company as given below:

(Rs.inCrore)

Particulars of the land and building Gross block as at 31st December 2021 Net Block as at 31st December 2021 Total number of cases Remarks
Freehold land 1.30 1.30 13 Title deeds are in the name of the wholly owned subsidiary and entities taken over/ merged with the Company.

(ii) In respect of immovable properties of land and buildings that have been taken onlease and disclosed as property plant and equipment's / right-of-use assets in thefinancial statements the lease agreements are in the name of the Company where theCompany is the lessee in the agreement.

(ii) As explained to us the inventories were physically verified during the year bythe Management at reasonable intervals and no material discrepancies were noticed onphysical verification.

(iii) The Company has not granted any loans secured or unsecured to companies firmsLimited Liability Partnerships or other parties covered in the register maintained underSection 189 of the Companies Act 2013.

(iv) In our opinion and according to the information and explanations given to us theCompany has not granted any loans or provided guarantees to directors or companies inwhich directors are interested which are covered under Section 185. In our opinion andaccording to the information and explanations given to us the Company has complied withthe provisions of Section 186 of the Companies Act 2013 in respect of grant of loansmaking investments and providing guarantees and securities as applicable.

(v) According to the information and explanations given to us the Company has notaccepted any deposit during the year. The Company does not have unclaimed deposits as at31st December 2021 and accordingly provisions of Sections 73 to 76 or any other relevantprovisions of the Companies Act are not applicable to the Company.

(vi) The maintenance of cost records has been specified by the Central Government undersection 148(1) of the Companies Act 2013 for manufacture of cement. We have broadlyreviewed the cost records maintained by the Company pursuant to the Companies (CostRecords and Audit) Rules 2014 as amended prescribed by the Central Government undersub-section (1) of Section 148 of the Companies Act 2013 and are of the opinion thatprima facie the prescribed cost records have been made and maintained. We have howevernot made a detailed examination of the cost records with a view to determine whether theyare accurate or complete.

(vii) According to the information and explanations given to us in respect ofstatutory dues:

(a) The Company has generally been regular in depositing undisputed statutory duesincluding Provident Fund Employees' State Insurance Income-tax Goods and Service Tax(GST) Service Tax Customs Duty Cess and other material statutory dues applicable to itwith the appropriate authorities.

(b) There were no undisputed amounts payable in respect of Provident Fund Employees'State Insurance Income-tax Goods and Service Tax (GST) Sales Tax Service Tax CustomsDuty Excise Duty Value Added Tax Cess and other material statutory dues in arrears asat 31st December 2021 for a period of more than six months from the date they becamepayable.

(c) Details of dues of Income-tax Sales Tax Goods and Service Tax (GST) Service TaxCustoms Duty Excise Duty and Value Added Tax which have not been deposited as on 31stDecember 2021 on account of disputes are given below:

Name of the Statute Nature of Dues Period to which the amount relates Forum where dispute is pending
(Rs.inCrore)
Commisionerate Appellate authorities and Tribunal High Courts Supreme Court Total
Central Sales Tax Act 1956 and various State Sales Tax Acts Demand of sales tax/ Additional purchase tax Interest and Penalty 1988-89 to 2017-18 28.36 14.34 129.21 112.92 284.93
Customs Act 1962 Demand of Customs Duty interest and penalty 2000-01 to 2013-14 0.48 38.07 38.55
Goods and Service Tax Act 2017 Demand of GST 2018-19 to 2020-21 1.19 - - - 1.19
Central excise Act 1944 Demand of Excise duty Denial of Cenvat Credit Interest and Penalty 1994-95 to 2017-18 8.99 18.60 0.18 2.06 29.83
Finance Act 1994 Denial of service tax credit and penalty 2004-05 to 2017-18 6.74 256.11 - - 262.85
Income Tax Act 1961 Income tax and Interest AY 2007-08 to AY 2013-14 76.63 15.56 1.38 - 93.57

Amounts given above are net of amounts deposited.

(viii) In our opinion and according to the information and explanations given to usthe Company has not defaulted in the repayment of loans or borrowings to government. TheCompany did not have any outstanding loans or borrowings in respect of a financialinstitution or bank or dues to debenture holders during the year.

(ix) The Company has not raised moneys by way of initial public offer or further publicoffer (including debt instruments) or term loans and hence reporting under clause (ix) ofthe CARO 2016 Order is not applicable.

(x) To the best of our knowledge and according to the information and explanationsgiven to us no fraud by the Company and no material fraud on the Company by its officersor employees has been noticed or reported during the year.

(xi) In our opinion and according to the information and explanations given to us theCompany has paid / provided managerial remuneration in accordance with the requisiteapprovals mandated by the provisions of Section 197 read with Schedule V to the CompaniesAct 2013.

(xii) The Company is not a Nidhi Company and hence reporting under clause (xii) of theCARO 2016 Order is not applicable.

(xiii) In our opinion and according to the information and explanations given to usthe Company is in compliance with Section 177 and 188 of the Companies Act 2013 whereapplicable for all transactions with the related parties and the details of related partytransactions have been disclosed in the financial statements etc. as required by theapplicable accounting standards.

(xiv) During the year the Company has not made any preferential allotment or privateplacement of shares or fully or partly convertible debentures and hence reporting underclause (xiv) of CARO 2016 is not applicable to the Company.

(xv) In our opinion and according to the information and explanations given to usduring the year the Company has not entered into any non-cash transactions with itsdirectors or persons connected with him and hence provisions of Section 192 of theCompanies Act 2013 are not applicable to the Company.

(xvi) The Company is not required to be registered under Section 45-IA of the ReserveBank of India Act 1934.

For DELOITTE HASKINS & SELLS LLP
Chartered Accountants
(Firm's Registration No. 117366W / W-100018)
Saira Nainar
(Partner)
(Membership No. 040081)
(UDIN: 22040081ACYQCW4402)
Place : Mumbai
Date : 17th February 2022

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