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Amit Securities Ltd.

BSE: 531557 Sector: Others
NSE: N.A. ISIN Code: INE137E01014
BSE 00:00 | 05 Jul Amit Securities Ltd
NSE 05:30 | 01 Jan Amit Securities Ltd
OPEN 4.00
52-Week high 4.00
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P/E 40.00
Mkt Cap.(Rs cr) 3
Buy Price 0.00
Buy Qty 0.00
Sell Price 0.00
Sell Qty 0.00
OPEN 4.00
CLOSE 4.00
52-Week high 4.00
52-Week low 0.00
P/E 40.00
Mkt Cap.(Rs cr) 3
Buy Price 0.00
Buy Qty 0.00
Sell Price 0.00
Sell Qty 0.00

Amit Securities Ltd. (AMITSECURITIES) - Director Report

Company director report




The Members

Amit Securities Ltd.

The Directors take pleasure in presenting their 29th Annual Report together with theStandalone and Consolidated Audited Financial Statements for the year ended 31st March2021 and the Management Discussion and

Analysis has also been incorporated into this Report.


• Total income for the year was Rs. 132.98 Lakhs as compared to Rs. 164.45 Lakhsin the previous year with a decrease of 19.14%;

• Income from operations for the year was Rs. 110.62 Lakhs as compared to Rs.161.62 Lakhs in the previous year with a decrease of 31.55%;

• Profit (Loss) before tax for the year was Rs. 18.01 Lakhs as compared to (Rs.2.48 Lakhs) in the previous year;

• Profit (loss) after tax for the year was Rs. 15.90 Lakhs as compared to loss of(Rs. 3.49 Lakhs) previous year.

• Net Profit (loss) after other comprehensive income for the year was Rs. 4.00Lakhs as compared to Rs. 1.46 Lakhs previous year.


(Rs. In Lakhs)

Particulars Standalone Consolidated
31.03.21 31.03.20* 31.03.21 31.03.20*
Revenue from Operations (Net) 110.62 161.62 110.62 161.62
Other Income 22.37 2.83 22.37 2.83
Total Income 132.98 164.45 132.98 164.45
Total Expenditure before Depreciation 114.97 166.92 114.97 166.92
Profit before Depreciation & Tax (EBIDTA) 18.01 (2.48) 18.01 (2.48)
Less: Depreciation 0.00 0.00 0.00 0.00
Profit before Tax and exceptional item 18.01 (2.48) 18.01 (2.48)
Less: Exceptional Item 0.00 0.00 0.00 0.00
Profit before Tax 18.01 (2.48) 18.01 (2.48)
Less: (a) Current Tax 2.11 1.01 2.11 1.01
(b) Tax adjustments related to previous year 0.00 0.00 0.00 0.00
(c) Deferred Tax 0.00 0.00 0.00 0.00
Net Profit for the Year 15.91 (3.49) 15.91 (3.49)
Share of Profit from Associate - - 14.01 19.85
Add: Other Comprehensive Income (11.90) 4.95 (11.90) 4.95
Total Comprehensive Income 4.00 1.46 18.01 21.31
Paid up Equity Share Capital 710 710 710 710
EPS (Equity Shares of Rs. 10/- each) Basic & Diluted (in Rs.) 0.06 0.02 0.25 0.30


Your directors propose to preserve the profits for the growth of the company and do notrecommend any dividend for the year 2020-21. (Previous year: Nil)


The paid-up Equity Share Capital as on 31st March 2021 was Rs. 710.00 Lakhs dividedinto 71.00 Lakhs equity shares of Rs. 10/- each (excluding 568200 partly paid up equityshares earlier on which Rs. 2272800 were forfeited and the said shares were notre-issued by the Company up to 31st March 2021). During the year under review and theCompany has not issued any shares with differential voting rights nor granted stockoptions nor sweat equity. As on 31st March 2021 none of the Directors of the Companyhold any security or convertible instruments of the Company.


During the year under review your Company has transferred an amount of Rs.1590535.00(Fifteen Lakhs Ninety Thousand Five Hundred and Thirty-five only) to the general reservesand surplus.


Cash and cash equivalent as at 31st March 2021was Rs 2251441.00 (Twenty Two LakhsFifty one thousand four hundred and forty-one only). Your Company continues to focus onjudicious management of its working capital. Receivables inventories and other workingcapital parameters were kept under strict check through continuous monitoring.


During the year under review your Company has not changed its nature of business.


The details relating to deposits covered under Chapter V of the Act -

(a) Accepted during the year : Nil
(b) Remained unpaid or unclaimed as at the end of the year : Nil

(c) Whether there has been any default in repayment of deposits or payment of interestthereon during the year and if so number of such cases and the total amount involved: Nil

Details of deposits which are not in compliance with the requirements of Chapter V ofthe Act:

The Company has not accepted any deposits which are not in compliance of the Companies(Acceptance of Deposits) Rules 2014 during the financial year.


Your company has not given any guarantee or provided any security to the other businessentity during the financial year but the company has provided unsecured loan to itsAssociate concern and details of the unsecured loan given is disclosed as per therequirement of Regulation 34(3) of the SEBI (LODR) Regulations 2015 read with Schedule Vof the Listing Regulations is given as under.

Name of the Company Nature of Transactio ns Investment made/Guarantee/L oans Provided Op. Balance as on 01/04/2020 Transacti ons made during the year Cl. Balance as on 31/03/2021
Mittal Udyog (Indore) Pvt. Ltd. Associate Concern Investment made in equity shares 46500000.00 0.00 46500000.00
Investment made in Preference shares 22500000.00 0.00 22500000.00
Alokik Estate &FinvestPvt. Ltd Associate Concern Investment made in equity shares 475000.00 0.00 475000.00
Saket Securities and Investment Pvt. Ltd. Associate Concern Investment made in equity shares 750000.00 0.00 750000.00
Arpit Share & Securities Pvt. Ltd. Associate Concern Investment made in equity shares 680000.00 0.00 680000.00
AVA Mettalics Pvt. Ltd. Associate Concern Investment made in equity shares 900000.00 0.00 900000.00
Radius Estate &FinvestPvt. Ltd. Associate Concern Investment made in equity shares 1500000.00 0.00 1500000.00
Orange InfrabuildPv t.Ltd. Associate Concern Investment made in equity shares 4275000.00 0.00 4275000.00
PadamBuild martPvt.Ltd. Associate Concern Investment made in equity shares 3000000.00 0.00 3000000.00
AkashdeepFi nbuildPvt.Lt d. Associate Concern Investment made in equity shares 2300000.00 0.00 2300000.00
Vishal Realmart Pvt. Ltd. Long term Investmen ts Investment made in Preference shares 6435000.00 0.00 6435000.00

Since section 186 of the companies Act 2013 is not applicable to your company becausethe main business of the company is to acquire securities. Therefore the company was notrequired to take any approval from its members during the period under review.


Economic Scenario and Outlook with impact on business operations on account of COVID-19pandemic:

The outbreak of COVID-19 pandemic has led to an unprecedented disruption in theeconomic activities across the globe. Consequently the business has been affected in theyear 2020-21.

The Company's operation remained shut from April10 2021 due to lockdown which hasimpacted its operations during April and June 2021. The registered office of the Companyis situated in Mumbai (Maharashtra) and corporate office is situated in Indore (M.P.) andboth the cities were under complete lockdown. The activities of the Company were severelyaffected as the Company continues to bear its fixed overhead expenses and other inevitablefinancial costs without having any relaxation from the Government of India/StateGovernments/ Local Authorities leading to continue the financial stress on the Company.The Company has resumed its operations in a phased manner. The Company took utmost care ofits staff and work force like sanitisation social distancing mandatory mask wearingmaintaining proper hygiene and many of the employees were given "Work from Home"facility.

We have taken cash flow and other expenses measures to smoothly manage our operations.April - June' 2021 being lockdown months the revenues and profitability of the Companyare likely to be adversely impacted. As the business situation is very dynamic thecompany is closely monitoring it. Though we do hope the business situation shouldnormalise during remaining tenure of the coming financial year.

Industry Outlook and Opportunities:

Adverse effect of Covid-19 will be continued on the operation of the Company in thenext financial years also in all sectors. The Company is consistently monitoring thedevelopments and taking all measured to minimize the impact of outbreak of Covid-19 onbusiness of the Company.

Further the existing Government has announced various relief measures for the varioussectors of the society including the corporate sectors in terms of taxation relief andvarious other measures. In order to reduce the impact of COVID 19 on the economyGovernment is planning to announce more relief in the coming period. Company will takebenefits of all the measures and cope up with positive impact on its business.

Market Development:

The Company has made investment in the Associate and group-concern companies. Howeverit may be risk free from the changes in the capital market. The Company is making effortsto realize the investment and loans for better deployment for growth of the company.

Risk Management Policy and Internal Adequacy:

The capital market industry is mainly dependent on economic growth of country andcapital market is also further affected by number of issues arising out of Internationalpolicies of foreign government as well any change in international business environment.The industrial growth is very sensitive which is dependent on many factors which may besocial financial economical or political and also natural climatic conditions in thecountry. However with the positive attitude of country which can mitigate the avoidablerisks. Geopolitical tensions raising crude oil prices rising US bond yields scams inthe banking sector are some of the affecting factors that the country witnessed during theyear under review. The country faced the said concerns with positive measures by way ofmaking amendments or introducing new laws that can assist to grow the economy. Foreigninvestors are very positive for India and trust its policies which are very much investorfriendly. It is expected that the said efforts shall continue during the coming yearsirrespective of the Government which is in power.

Internal Control System:

The company has implemented proper system for safeguarding the operations/business ofthe company through which the assets are verified and frauds errors are reduced andaccounts information connected to it are maintained such so as to timely completion ofthe statements. The Company has adequate systems of Internal Controls commensurate withits size and operations to ensure orderly and efficient conduct of business. Thesecontrols ensure safeguarding of assets reduction and detection of fraud and erroradequacy and completeness of the accounting records and timely preparation of reliablefinancial information. The company has internal audit and verification at regularintervals. The requirement of having internal auditor compulsory by statue in case oflisted and other classes of companies as prescribed shall further strengthen the internalcontrol measures of company.

Associated Risk to the Business:

The Company emphasizes on those risks that threaten the achievement of businessobjectives of the Group over the short to medium term. An overview of these risks isprovided hereafter including the actions taken to mitigate these risks and any relatedopportunities:

i) Strategic and Commercial risks: being taken care by the Risk Management Committeeand reporting to the Board on need basis.

ii) Regulatory compliance risks: The regulatory environment has resulted into increasedregulatory scrutiny that has raised the minimum standards to be maintained by the Company.This signifies the alignment of corporate performance objectives while ensuringcompliance with regulatory requirements. The Company recognizes that regulatoryrequirements can at times be challenging and therefore will strive to understand thechanging regulatory standards so as to strengthen its decision-making processes andintegrate these in the business strategy of each of the industries in which it operates.Drive business performance through the convergence of risk compliance processes andcontrols mechanisms to ensure continued operational efficiency and effectiveness.

iii) Financial risks: It includes among others exposure to movements in interest ratesand the Company also maintains sufficient liquidity so that it is able to meet itsfinancial commitments on due dates and is not forced to obtain funds at higher interestrates.

iv) Day-to-day Risk Management: Management and staff at the Company's facilitiesassets and functions identify and manage risk promoting safe compliant and reliableoperations. These requirements along with business needs and the applicable legal andregulatory requirements underpin the practical plans developed to help reduce risk anddeliver strong sustainable performance.


Pursuant to Regulation 15 of the SEBI (LODR) Regulations 2015 which states thatRegulation 22 of the SEBI (LODR) Regulations 2015 is not applicable to the Company.However Your Company has voluntarily established a vigil mechanism named vigilmechanism/whistle blower Policy pursuant to Section 177(10) of the Companies Act 2013which has been annexed as 'Annexure-1' with the Board Report.


The names of companies which have become or ceased to be its Subsidiaries jointventures or associate companies during the year:

During the financial year 2020-21 your Company has not become or ceased to be itsSubsidiaries joint ventures or associate companies. Further the Company is not havingany Subsidiaries and Joint Ventures during the year or any period under review. Howeveryour company is having Associates Companies Details of the same is enclosed:

Name of the other Company Position as on 1st April 2020 Date on which become as an Associate/ Subsidiary Date on which ceased as an Associate/ Subsidiary Reasons Position as on 31st March 2021 Remarks
Mittal Udyog (Indore) Pvt. Ltd. Associate Concern 17/06/09 - - Associate Concern No change
Alokik Estate &Finvest Pvt. Ltd Associate Concern 01/04/17 Due to implementation of IND (AS) Associate Concern No change
Saket Securities and Investment Pvt. Ltd. Associate Concern 01/04/17 Due to implementation of IND (AS) Associate Concern No change
Arpit Share &Securities Pvt. Ltd. Associate Concern 01/04/17 Due to implementation of IND (AS) Associate Concern No change
AVA Mettalics Pvt. Ltd. Associate Concern 01/04/17 Due to implementation of IND (AS) Associate Concern No change
Radius Estate &Finvest Pvt. Ltd. Associate Concern 01/04/17 Due to implementation of IND (AS) Associate Concern No change
Orange Infrabuild Pvt. Ltd. Associate Concern 01/04/17 Due to implementation of IND (AS) Associate Concern No change
PadamBuildmart Pvt. Ltd. Associate Concern 01/04/17 Due to implementation of IND (AS) Associate Concern No change
AkashdeepFinbuild Pvt. Ltd. Associate Concern 01/04/17 Due to implementation of IND (AS) Associate Concern No change

Consolidated Financial Statements

Your company is not having any Subsidiary or Joint Venture Company during the yearunder review. However your company is having an associate company and as per therequirement of IND (AS) and the Companies Act 2013 the Consolidated Financial Statementsis also being prepared. Further Form AOC-1 is attached in the Board report as 'Annexure-2'as per the requirement of the Companies Act 2013.


Constitution of the Board

The Board of directors includes a total of 5 (Five) Directors which includes 3 (Three)Independent and 1 (one) Women director and 1 (one) Managing Director. The Chairman of theBoard is an Executive Director. The Board members are highly qualified with the variedexperience in the relevant field of the business activities of the Company which playssignificant roles for the business policy and decision making process and provide guidanceto the executive management to discharge their functions effectively.

Board Independence

Our definition of 'Independence' of Directors or Regulation is derived from Regulation16 of SEBI (LODR) Regulations 2015 and section 149(6) of the Companies Act 2013. TheCompany is having following 3 (Three) independent directors;

1. Mr. Vineet Gupta

2. Mr. Praveen Jain

3. Mr. Anand Gupta

As per provisions of the Companies Act 2013 Independent Directors were appointed fora term of 5 (five) consecutive years but shall be eligible for re-appointment on passingof a special resolution by the Company and shall not be liable to retire by rotation.

Mr. Anand Gupta (DIN:08845835) was appointed as Additional Independent Director of thecompany in the board meeting held on 27/08/2020 to hold office up to the conclusion of the28th Annual General Meeting. Further in the 28 th Annual General Meeting the membersconfirmed him as the Independent Director of the company.

Mr. Sunny Shukla(DIN: 08590103) has resigned from the Board on 27/08/2020 due to hispersonal reasons. The board of directors appreciates the contribution made by him duringhis tenure.

Declaration by Independent Directors:

All Independent Directors have given their declaration that they meet the criteria ofindependence as laid down under Section 149(6) of the Companies Act 2013. Your directorsare satisfied about their independency.

Director Retire by rotation:

As per provisions of the Companies Act 2013 Ms. Aditi Mittal (DIN:06536363)Directors of the company retires by rotation at the ensuing Annual GeneralMeeting and being eligible offer himself for re-appointment. Except this there has beenno change in Directors of the Company.

Key Managerial Personnel:

Mr.Nitin Maheshwari Managing Director; Mr. Girdhari Randhive Chief Financial Officerand CS Insiya (resigned w.e.f. 14th August 2021); have been categorized as the KeyManagerial Personnel within the meaning of section 203 of the Companies Act 2013.

There is no change in the Key Managerial Personal during the year 2020-21 except thefollowing:-

1) Ms.Swati Bansal Company Secretary & Compliance Officer has resigned from thepost w.e.f. 09th July 2020.

2) Ms.Insiya was appointed for the post of Company Secretary & Compliance Officerw.e.f. 09th July 2020.

3) Ms. Insiya resigned for the post of Company Secretary & Compliance Officerw.e.f. 14th August 2021.

4) Ms. Vaishnavi Sharma was appointed for the post of Company Secretary &Compliance Officer w.e.f. 16th August 2021.

Meetings of the Board:

The Board meets at regular intervals to discuss and decide on Company/business policyand strategy apart from other Board business. However in case of a special and urgentbusiness need the Board's approval is taken by passing resolutions through circulationas permitted by law which are confirmed in the subsequent Board meeting.

The notice of Board meeting is given well in advance to all the Directors. Meetings ofthe Board are held in Indore at the Corporate Office of the Company. The Agenda of theBoard meetings are circulated at least a week prior to the date of the meeting. The Agendafor the Board and Committee meetings includes detailed notes on the items to be discussedat the meeting to enable the Directors to take an informed decision.

The Board met 7 (Seven) times during the financial year 2020-21 on 9th July 2020 30thJuly 2020 27th August 2020 15th September 2020 10th November 2020 20th November 2020and 13th February 2021.

Independent Directors' Meeting:

In due compliance with the provisions of the Companies Act 2013 and Securities andExchange Board of India (Listing Obligations and Disclosure Requirements) Regulations2015 a separate meeting of Independent Directors was held on 13 th February 2021.


The Board has on the recommendation of the nomination and remuneration committeeframed a nomination remuneration and evaluation policy which lays down the criteria foridentifying the persons who are qualified to be appointed as directors and or seniormanagement personnel of the company along with the criteria for determination ofremuneration of directors KMP's and other employees and their evaluation and includesother matters as prescribed under the provisions of section 178 of Companies Act 2013and Regulation 19 of SEBI (LODR) Regulations 2015. Policy of the Company has been givenat the website of the Company at Link:- The details ofthe same are also covered in Corporate Governance Report forming part of this annualreport.

Annual evaluation by the Board:

The evaluation framework for assessing the performance of Directors comprises of thefollowing key areas:

i. Attendance of Board Meetings and Board Committee Meetings

ii. Quality of contribution to Board deliberations

iii. Strategic perspectives or inputs regarding future growth of Company and itsperformance

iv. Providing perspectives and feedback going beyond information provided by themanagement

v. Commitment to shareholder and other stakeholder interests

The evaluation involves Self-Evaluation by the Board Member and subsequently assessmentby the Board of Directors. An executive member of the Board does not participate in thediscussion of his evaluation.


To the best of their knowledge and belief and according to the information andexplanations obtained by them your Directors make the following statements in terms ofSection 134(5) of the Companies Act 2013:

a. that in the preparation of the annual financial statements for the year ended 31stMarch 2021 the applicable accounting standards have been followed along with properexplanation relating to material departures if any;

b. that such accounting policies as mentioned in Note 1 to the Financial Statementshave been selected and applied consistently and judgment and estimates have been made thatare reasonable and prudent so as to give a true and fair view of the state of affairs ofCompany as at March 31st 2021 and of the Profit of the Company for the year ended on thatdate;

c . that proper and sufficient care has been taken for the maintenance of adequateaccounting records in accordance with the provisions of the Companies Act 2013 forsafeguarding the assets of the Company and for preventing and detecting fraud and otherirregularities;

d. that the annual financial statements have been prepared on a going concern basis;

e. that proper internal financial controls were in place and that the financialcontrols were adequate and were operating effectively.

f. that systems to ensure compliance with the provisions of all applicable laws were inplace and were adequate and operating effectively.


The Board of Directors has devised systems policies and procedures / frameworks whichare currently operational within the Company for ensuring the orderly and efficientconduct of its business which includes adherence to Company's policies safeguardingassets of the Company prevention and detection of frauds and errors accuracy andcompleteness of the accounting records and timely preparation of reliable financialinformation. In line with best practices the Audit Committee and the Board reviews theseinternal control systems to ensure they remain effective and are achieving their intendedpurpose. Where weaknesses if any are identified as a result of the reviews newprocedures are put in place to strengthen controls. These controls are in turn reviewed atregular intervals.

Nothing has come to the attention of the Directors to indicate that any materialbreakdown in the function of these controls procedures or systems occurred during theyear under review. There have been no significant changes in the Company's internalfinancial controls during the year that have materially affected or are reasonably likelyto materially affect its internal financial controls. There are inherent limitations tothe effectiveness of any system of disclosure controls and procedures including thepossibility of human error and the circumvention or overriding of the controls andprocedures.


There were no instances for other than reportable fraud to the Central Governmentcovered under section 134(3) (ca) of the Companies Act 2013. Further that the auditorshave not found any fraud as required to be reported by them under section 143(12) to theCentral Government during the year 2020-21.


During the year in accordance with the Companies Act 2013 the Board has following4(Four) Committees as follows:

(a) Audit Committee

(b) Nomination and Remuneration Committee

(c) Stakeholders' Relationship Committee

(d) Risk management Committee

Details of all the Committees along with their charters composition and meetings heldduring the year are provided in the "Report on Corporate Governance" asannexed to this Annual Report as per Schedule V of the SEBI (LODR) Regulations 2015.


All related party transactions that were entered into during the financial year were onan arm's length basis and are in the ordinary course of business. As per Regulation 15 ofthe SEBI (LODR) Regulations 2015 the Regulation No. 17 to 27 46(2)(b)(i) and Para C D Eof the Schedule V in view of the paid up capital and net worth of the Company is notmandatory. However there are certain transaction which are material in nature and hencethe company is attaching Form AOC-2 as 'Annexure 3' as a part of the Board Report.

There are no material significant related party transactions made by the Company withPromoters Directors Key Managerial Personnel or other designated persons which may havea potential conflict with the interest of the Company at large.

All Related Party Transactions are placed before the Audit Committee and also the Boardfor approval. The transactions entered into are audited and a statement giving details ofall related party transactions is placed before the Audit Committee and the Board ofDirectors for their approval on a quarterly basis. The statement is supported by aCertificate from the MD and the CFO of the Company has developed a Related PartyTransactions Manual Standard Operating Procedures for purpose of identification andmonitoring of such transactions.

The policy on Related Party Transactions as approved by the Board is uploaded on theCompany's website. (Link: -


The BSE has suspended the trading of the Company due to non-filing of the quarterlyConsolidated Financial Results of the Company.

The Board would like to bring to notice of the stakeholders that the Company hascomplied with all the regulations as mentioned above and initiated the process forrevocation of suspension.


The shares of your Company are being traded in electronic form and the Company hasestablished connectivity with both the depositories i.e. National Securities DepositoryLimited (NSDL) and Central Depository Services (India) Limited (CDSL). In view of thenumerous advantages offered by the Depository system Members are requested to avail thefacility of dematerialization of shares with either of the Depositories as aforesaid. Ason March 31 2021-89.64% of the share capital stands dematerialized.


Statutory Auditors

The Auditors M/s Sunil Bandi& Co. Chartered Accountants (FRN: 007419C) who wereappointed for a term of 5 (five) consecutive years at the 25 th Annual General Meeting ofthe Company held on 15 th Sept. 2017 shall hold the office till the conclusion of the30th Annual General Meeting to be held in the year 2022. As required under Regulation33(d) of the SEBI (LODR) Regulation 2015 the auditors have also confirmed that they holda valid certificate issued by the Peer Review Board of the Institute of CharteredAccountants of India. The Board of the company takes pleasure in stating that no suchobservation has been made by the Auditors in their report which needs any furtherexplanation by the Board.

Secretarial Audit:

Pursuant to the provisions of Section 204 of the Companies Act 2013 and the Companies(Appointment and Remuneration of Managerial Personnel) Rules 2014 the Company hasappointed CS DipikaKataria Practicing Company Secretaries to undertake the SecretarialAudit of the Company for the year 2020-21. The Report of the Secretarial Audit Report inthe Form MR-3 is annexed as "Annexure 4" of this Report.

Your Board is pleased to inform that there is no such observation made by the Auditorsin their report which needs any explanation by the Boardexcept that;

1. Auditor Comments: The Company is carrying out the business of metal trading alongwith the business of investment the business started many years back and is not coveredin our audit period hence we reserve our comment /opinion on the same.

Management Comments:The company is carrying the business of metal trading as coveredunder the other objects Therefore the observation are clearly for informative purposeand there are no noncompliances or which needs further clarification from the managementin the particular matter.

2. Auditor Comments : The BSE has suspended the trading of the Company due tonon-filing of the Consolidated Financial Results of the Company.

Management Comments: The Board would like to bring to notice of the stakeholders thatthe Company has already initiated the process for revocation of suspension.

Cost Records and Audit:

The company is maintaining the Cost Records as specified by the Central Governmentunder section 148 of the Companies Act 2013 read with the Companies (Cost Records andAudit) Amendment Rules 2014. However The Company is not required to conduct the CostAudit as per the requirement of the Act.


A certificate of Non Disqualification of Directors is also required to be submitted andin this regard a certificate from M/s K Arun & Co. Practicing Company Secretariesthat none of the directors on the board of the company have been debarred or disqualifiedfrom being appointed or continuing as director by SEBI/MCA or any such authority isattached and forms part of this report as Annexure 5.


As per the provisions of Regulation 15(2)(a) of the SEBI (Listing Obligation &Disclosure Requirements) Regulations 2015 the compliance with the corporate governanceprovisions as specified in regulations 17 17A 18 19 20 21 22 23 24 24A 25 2627 and clauses (b) to (i) of sub-regulation (2) of regulation 46 and Para C D and E ofSchedule V shall not apply to the Company. Though the Company is voluntarily complyingwith all the provisions and provided the report on the Corporate Governance in‘Annexure-6'. Further the certificate for the same is attached as Annexure-7.

Enhancing Shareholders Value:

Your Company believes that its Members are among its most important stakeholders.Accordingly your Company's operations are committed to the pursuit of achieving highlevels of operating performance and cost competitiveness consolidating and building forgrowth enhancing the productive asset and resource base and nurturing overall corporatereputation. Your Company is also committed to create value for its other stakeholders byensuring that its corporate actions positively impact the socio-economic and environmentaldimensions and contribute to sustainable growth and development.

Code of Conduct:

The Company has formulated the code of conduct for the Board members and seniorexecutives under the SEBI (Substantial Acquisition of Shares and Takeovers) Regulations2011 and the SEBI (Prohibition of Insider Trading) Regulations 2015 as amended from timeto time. A certificate to that effect for the proper compliances given by the ManagingDirector is annexed as the 'Annexure-11' with this Report.


Pursuant to provision of section 197(12) of Companies Act 2013 read with Rule 5(1) ofthe Companies (Appointment and Remuneration of Managerial Personnel) Rules 2014 and thedetails of Top 10 employees given in the "Annexure-9".

During the year none of the employees received remuneration in excess of Rs. One CroreTwo Lakhs or more per annum or Rs. Eighty Lakhs Fifty Thousand per month for the part ofthe year. Therefore there is no information to disclose in terms of the provisions of theCompanies Act 2013.


The information on conservation of energy technology absorption and foreign exchangeearnings and outgo stipulated under Section 134(3)(m) of the Companies Act 2013 read withRule 8 of The Companies (Accounts) Rules 2014is annexed herewith as 'Annexure-10'.


There have been no material changes and commitments affecting the financial position ofthe Company which have occurred between the end of the financial year and the date ofthis Report except BSE suspended the trading of the Company due to non-filing of thequarterly Consolidated Financial Results of the Company.

The Board would like to bring to notice of the stakeholders that the Company hascomplied with all the regulations as mentioned above and initiated the process forrevocation of suspension.


Rule 4(1)(iii)(a) of the Companies (Indian Accounting Standards) Rules 2015 notifiedvide Notification No.G.S.R.111(E) on 16th Feb. 2015 provides that if the company is alisted company or having a networth of less than Rs. 500 Crore then Company is required tocomply with the Indian Accounting Standards (IND AS) w.e.f. 01stApril 2017. ThereforeIND AS is applicable on the company w.e.f. 01stApril 2017.


The Annual Return of the Company as on 31st March 2021 in Form MGT - 7 in accordancewith Section 92(3) of the Act read with the Companies (Management and Administration)Rules 2014 is available on the website of the Company at www.


The Company has placed an Anti-Sexual Harassment Policy in line with the requirementsof The Sexual Harassment of Women at the Workplace (Prevention Prohibition &Redressal) Act 2013 under the guidance of Mrs. Aditi Mittal. Internal ComplaintsCommittee (ICC) has been set up to redress complaints received regarding sexualharassment. All employees (permanent contractual temporary trainees) are covered underthis policy. Further no complaint was received during the year under review.


In view of the paid up capital profits and turnover of your company during theprevious three years it does not fall under the provisions of the section 135 of theCompanies Act 2013 and the rules made their under.


In terms of Section 131 of the Companies Act 2013 the Financial Statements andBoard's Report are in compliance with the provisions of Section 129 or Section 134 of theCompanies Act 2013 and that no revision has been made during any of the three precedingfinancial years.


We seek to promote and follow the highest level of ethical standards in all ourbusiness transactions guided by our value system. The SEBI (Listing Obligations andDisclosure Requirements) Regulations 2015 and Companies Act 2013 has mandated theformulation of certain policies for all listed companies. All the policies are availableon our website (www. The policies are reviewed periodically bythe board and updated on need and new compliance requirement.


During the year under review the Company has complied with the provisions ofapplicable Secretarial Standards issued by Institute of Company Secretaries of India.


Your Company is providing E-voting facility under section 108 of the Companies Act2013 read with Rule 20 of the Companies (Management and Administration) Amendment Rules2015. The details regarding e-voting facility is being given with the notice of theMeeting.


There are no proceedings initiated/pending against your Company under the Insolvencyand Bankruptcy Code 2016 which materially impact the business of the Company.


There was no One Time Settlement of loan taken from Banks or any financialInstitutions. Hence the difference in valuation does not arise.


The Whole Time Director(WTD) have issued certificate pursuant to the provisions ofRegulation 17(8) of the SEBI(LODR ) Regulations 2015 certifying that the financialstatements do not contain any materially untrue statement and these statements represent atrue and fair view of the Company's affairs. The said certificate is annexed and formspart of the Annual Report as Annexure-8.


The Directors thank the various Central and State Government Departments Organizationsand Agencies for the continued guidance and co-operation. The Directors gratefullyacknowledge all stakeholders of the Company viz. customers all the employees membersvendors banks and other business partners for their excellent support received during theyear.

For and on behalf of the Board
Place: Indore Praveen Jain NitinMaheshwari
Date:28.08.2021 Director Managing Director
Amit Securities Ltd. DIN:05358447 DIN 08198576
CIN: L65990MH1992PLC067266